Mitigation Measure AQ-8 is required to limit generator testing to one generator per day. This mitigation measure would apply during any testing scenario (normal or full load). Table 4.2-11, p.
4.2-50, presents the maximum daily Phase 1 emissions with the mitigated stationary source emissions under the different generator testing scenarios. Based on the new testing schedule required by City of South San Francisco
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Mitigation Measure AQ-8, the number of operations days when no generator testing would occur would accordingly be less than when unmitigated (25 days out of a 30-day month [rather than 29] and 910 days out of a 1095-day three-year period [rather than 1,058]).
Table 4.2-11. Mitigated Operational Average Daily Emissions from Phase 1 – Comparison of Generator Testing Scenarios (pounds/day)
Condition/Source ROG NOX CO PM10 PM2.5
2024 Without Phase 1
Total 2024 Without Phase 1 a 103 114 821 267 72
2024 With Phase 1 – Full Load Testing Scenario (4 hours/day) Non-Stationary Sources 149 166 1,103 345 94
Stationary Sources 15 70 12 1 1
Total 2024 With Phase 1 (4-hour)a 165 236 1,114 346 95
2024 With Phase 1 v. 2024 Without Phase 1 (4-hour) a 61 122 294 79 22 Threshold 54 54 — 82 54
Exceeds Threshold? Yes Yes No No
2024 With Phase 1 – Normal Testing Scenario (0.5 hours/day) Non-Stationary Sources 149 166 1,103 345 94
Stationary Sources 2 9 1 < 1 < 1
Total 2024 With Phase 1 (0.5-hour)a 151 175 1,104 345 94 2024 With Phase 1 v. 2024 Without Phase 1 (0.5-hour) a 48 60 283 79 22 Threshold 54 54 — 82 54
Exceeds Threshold? No Yes No No
2024 With Phase 1 – No Generator Testing
Non-Stationary Sources 149 166 1,103 345 94
Stationary Sources — — — — —
Total 2024 With Phase 1 (0-hour)a 149 166 1,103 345 94
2024 With Phase 1 v. 2024 Without Phase 1 (0-hour) a 46 51 282 79 22 Threshold 54 54 — 82 54
Exceeds Threshold? No No No No
Source: See Appendix 4.2-1 for operations modeling outputs.
Notes:
a. Values may not add up because of rounding.
b. As shown in Table 4.2-5, p. 4.2-31, the full load testing scenario would occur once every three years. c. As shown in Table 4.2-5, p. 4.2-31, the normal testing scenario would occur once a month.
As shown in Table 4.2-11, p. 4.2-50, with Mitigation Measure AQ-8, operation of Phase 1 under both the normal and full load generator testing scenarios would still result in a net increase of NOx emissions that would exceed BAAQMD’s project-level thresholds. Testing under the full load generator testing scenario would also exceed ROG daily thresholds. The exceedances under the full load generator testing scenario (which requires testing every three years) would occur for 5 days of each testing year. The exceedance under the normal generator testing scenario (which requires testing every month) would occur during 60 days of every year.
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Mitigation Measure AQ-7 is required for Phase 1 to offset the net operational criteria pollutant emissions exceeding BAAQMD’s project-level thresholds during days with Phase 1 generator testing.
Through implementation of Mitigation Measure AQ-7, the Phase 1 applicant would pay mitigation fees to offset the ROG and/or NOx pollutant emissions, thereby ensuring that BAAQMD’s daily pollutant thresholds would not be exceeded. Offsetting emissions to a level below BAAQMD’s threshold levels would ensure that future emissions from Phase 1 would not contribute a significant level of air pollution such that regional air quality within the SFBAAB would be degraded. Based on recent precedent regarding the offsets feasibly available for other large projects in the San Francisco Bay Area, it is reasonable to assume that offset programs will be available in the future, and that Phase 1 emissions can be reduced to levels below threshold levels. However, because it cannot be concluded that offset programs would always be available in the future at the time and in the amount needed to mitigate Phase 1’s annual emissions, for the purposes of this EIR analysis, operational air quality impacts of Phase 1 are conservatively assumed to be significant and unavoidable.
While not related to the significance determination of this impact, note that NOx and CO emissions from stationary sources would be more than 10 pounds per day of testing and would therefore be subject to the BACT requirements of BAAQMD under their New Source Review regulation. Annual NOx emissions would be approximately two tons per year,68 less than the BAAQMD minimum threshold of 10 tons per year that, if reached, would subject the project to the NOx offset requirements of BAAQMD under the New Source Review regulation.
Health Impacts of Regional Criteria Pollutants
Please see discussion of health impacts for the Project operational emissions above.
Mitigation Measure AQ-7: Purchase of Mitigation Credits for Operational Emissions Exceeding BAAQMD’s Daily Pollutant Thresholds (All Phases) For future Precise Plans not including Phase 1: Applicants proposing development of future Precise Plans other than Phase 1 shall compare their project size with the BAAQMD screening sizes appropriate to their project for operational criteria pollutants, as found in Table 3-1 of BAAQMD’s current CEQA Guidelines (2017). The screening limit for general office buildings, an office park, or a government office building is 346,000 square feet, 323,000 square feet, and 61,000 square feet, respectively. The screening limits for general light industrial buildings, including Research and Development uses, are any of the following: 541,000 square feet, 72 acres, or 1,249 employees. If the project is less than the screening limit for the project type, then no further action shall be required.
Projects not excluded by the conditions above shall estimate annual average operational emissions for each operational year over the life of the project (30 years) and compare the annual average emissions for each year of operation to the BAAQMD thresholds used in the EIR for criteria pollutants (see Table 4.2-4). The emissions estimate shall be provided as part of the project’s Precise Plan application to the City for the project. The City will review the estimate and confirm whether offsets are required for operation. If so, the procedure described below shall be followed. Should the City-confirmed estimate indicate that the proposed development 68 309 pounds of NOx per 4-hour testing day multiplied by 50 hours of testing per year allowed by BAAQMD divided by 4 hours and converted from pounds to tons.
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estimate would not result in operational emissions exceeding BAAQMD’s daily pollutant thresholds, no further action shall be required.
For Phase 1 and future Precise Plans that are shown to exceed BAAQMD’s annual operations emissions thresholds: For proposed developments that are estimated to result in exceedances of thresholds during any year of the project’s life, including Phase 1, the project applicant shall coordinate with a third-party (e.g., Bay Area Clean Air Foundation) or governmental entity to pay criteria pollutant offsets for every year in which operational emissions are estimated to exceed the BAAQMD thresholds. If the estimate shows exceedances of multiple criteria pollutants above the BAAQMD thresholds, then offsets must be obtained to address each pollutant above the thresholds. Emission reduction projects and fees will be determined in consultation with the applicant and the third-party or governmental entity and include administrative costs for the offset provider (e.g., five percent of the fee amount). The agreement that specifies fees and the timing of payment shall be provided to the City for review and signed by the applicant and the third-party or governmental entity. The emission reductions shall be secured prior to any operational activity which is estimated to result in an exceedance for the year. The payment for the emissions can either be on an annual basis or made once up front prior to operation.
To qualify under this mitigation measure, the specific emissions reduction project(s) must result in emission reductions in the SFBAAB that are real, surplus, quantifiable, enforceable, and would not otherwise be achieved through compliance with existing regulatory requirements or any other legal requirement. During operation, building managers will provide annual operation activity monitoring data to estimate actual operation emissions. Applicants will submit the annual operation activity monitoring data and an estimate of actual annual criteria pollutant emissions to the City and BAAQMD for review by February 1 of each year for the prior operation year. The annual report will reconcile paid fees for the prior year relative to actual emissions. If more emissions were generated than fees paid, the applicant will submit payment to the thirdparty or governmental entity for the deficient amount. If more fees were paid than emissions generated, the third-party or governmental entity will either issue the applicant a refund for the surplus or a credit that can be applied to future fee payments.
Example offset projects include electrification of stationary internal combustion engines; replacing old trucks with new, cleaner, more efficient trucks; and other stationary and mobile source emissions-reducing projects.
Mitigation Measure AQ-8: Limit the Number of Phase 1 Emergency Generators Tested to One Generator Per Day (Phase 1 Only)
No more than one Phase 1 emergency generator shall be tested in any 24-hour period. This requirement shall apply to routine testing events anticipated to occur every month and full load testing events anticipated to occur every 36 months (3 years).
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Impact AQ-3: Future phases of the project, not including Phase 1, could expose sensitive receptors to substantial pollutant concentrations. (Project: Significant and Unavoidable; Phase 1: Less than Significant with Mitigation)
Project
The primary pollutants of concern to human health generated by the proposed project are criteria pollutants and TACs. These pollutants and their potential impacts on receptors are analyzed below.
Localized Criteria Pollutants
Localized criteria pollutants generated by the proposed project (e.g., fugitive dust, PM, CO) could be deposited near the emissions source and affect the population near that emissions source. Although these pollutants dissipate with distance, emissions from individual projects can result in direct and material health impacts on adjacent sensitive receptors. As discussed above, the NAAQS and CAAQS are health protective standards that have been set at levels that are considered safe with respect to protecting public health, including the health of sensitive populations, such as asthmatics, children, and the elderly.
Construction
During grading and excavation activities associated with construction, localized fugitive dust would be generated. The amount of dust generated by a project is highly variable and dependent on the size of the disturbed area at any given time, the amount of activity, soil conditions, and meteorological conditions. BAAQMD’s CEQA Guidelines considers dust impacts to be less than significant if BAAQMD’s construction BMPs are employed to reduce such emissions. Because BAAQMD’s Basic Construction Mitigation Measures would be implemented, per Mitigation Measure AQ-1, construction-related fugitive dust emissions would be less than significant with mitigation and would not expose receptors to substantial pollutant concentrations or risks.
Operation
Continuous engine exhaust may elevate localized CO concentrations, resulting in hot spots.
Receptors exposed to these CO hot spots may have a greater likelihood of developing adverse health effects. CO hot spots are typically observed at heavily congested intersections where a substantial number of gasoline-powered vehicles idle for prolonged durations throughout the day.
As discussed above, BAAQMD developed screening criteria to assist lead agencies in evaluating potential impacts from localized CO. The proposed project, at buildout, would not increase traffic volumes at any intersection to more than 44,000 vehicles per hour or 24,000 vehicles per hour in areas where vertical or horizontal mixing is limited, as specified by BAAQMD. However, the intersection of San Bruno Avenue/El Camino Real currently does not meet the applicable congestion management plan standard. 69 As such, the proposed project would not meet BAAQMD’s CO hot-spot screening criteria. Because BAAQMD’s screening criteria cannot be used, a site-specific analysis has been conducted to determine if the proposed project could contribute to a localized CO hot spot and expose receptors to substantial CO concentrations or risks. CO impacts were analyzed at the intersection of San Bruno Avenue/El Camino Real using the traffic conditions from existing 69 Fehr & Peers. 2021. Southline Transportation Impact Analysis. June.
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conditions (2018) and from project buildout (2030). Table 4.2-12, p. 4.2-54, presents project CO concentrations summed with background CO levels and compared against the CAAQS and NAAQS.
As shown in Table 4.2-12, p. 4.2-54, CO concentrations are not expected to contribute to any new localized violations of the 1-hour or 8-hour ambient state or federal air quality standards.
Accordingly, sensitive receptors would not be exposed to substantial concentrations of CO.
Therefore, this impact would be less than significant for the project.
Table 4.2-12. CO Concentrations at San Bruno Avenue/El Camino Real Intersection at Project Buildout (parts per million)
Source Receptora
1 Hour 8 Hours
Existing
(2018)
Project
(2030)
Existing
(2018)
Project
(2030)
San Bruno Avenue/El Camino Real 1 3.1 3.2 2.2 2.2
2 3.4 3.3 2.4 2.3
3 3.3 3.3 2.3 2.3
4 3.1 3.2 2.2 2.2
CAAQS 20 20 9.0 9.0
Exceed CAAQS? No No No No
NAAQS 35 35 9 9
Exceed NAAQS? No No No No
Source: See Appendix 4.2-1 for CO modeling outputs.
Notes:
CAAQS = California Ambient Air Quality Standards; NAAQS = National Ambient Air Quality Standards a. Receptors are located at each of the four corners of the intersection. The intersection modeled has two intersecting roadways.
Toxic Air Contaminants
The primary TACs of concern associated with the proposed project are asbestos, DPM, and evaporative ROG. Note that evaporative ROG is a potential TAC of concern only for the Life Sciences Scenario, which could involve R&D buildings with wet laboratories and process boilers. These could emit ROGs from solvents and chemicals specific to the type of research and development being conducted, as discussed further below.
Construction
Structure demolition could disperse particulates that contain asbestos-containing material (ACM) adjacent to the locations of sensitive receptors. ACMs were commonly used as fireproofing and insulating agents prior to the 1970s. The U.S. Consumer Product Safety Commission banned the use of most ACMs in 1977 because of their link to mesothelioma. However, buildings constructed prior to 1977 that would be demolished by development supported by the proposed Specific Plan may have used ACM and therefore could expose receptors to asbestos, which may become airborne with other particulates during demolition.
All demolition activities would be subject to EPA's asbestos NESHAP if asbestos is present at the existing facilities. The asbestos NESHAP regulations protect the public by minimizing the release of asbestos fibers during activities involving the processing, handling, and disposal of ACM. The City of South San Francisco
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asbestos NESHAP regulations for demolition and renovation are outlined in BAAQMD Regulation 11, Rule 2. In addition to demolition and renovation measures, BAAQMD Regulation 11, Rule 2 also includes measures to address ACM during haul truck transport. More specifically, it includes provisions such as treating ACM with water prior to transport and placing it in leak-tight containers for haul truck transport to disposal sites. The project will be required by conditions of approval to comply with all applicable BAAQMD regulations. Consequently, regulatory mechanisms exist that would ensure that impacts from ACM, if present during demolition activities within the Specific Plan area, would be less than significant.
DPM is a carcinogen emitted by diesel internal combustion engines. Construction activities would generate DPM (PM2.5 exhaust from diesel-powered vehicles) 70 and PM2.5 that could expose
adjacent receptors to significant health risks. Without specific details regarding the locations or construction schedules, a quantitative evaluation of potential health risk impacts is not possible.
There are sensitive receptors within 1,000 feet of the project site, including approximately 100 residential uses in the city of San Bruno and 1 recreational trail in the City (conservatively assumed to be a sensitive receptor), within 1,000 feet of the project site. The closest sensitive receptors are the residential uses on the south side of Tanforan Avenue adjacent to the Tanforan Avenue improvements proposed as part of Phase 1. Figure 4.2 1, p. 4.2-10, shows sensitive receptors within 1,000 feet of the Specific Plan area.
Depending on the construction schedule and proximity to receptors, there may also be instances where DPM emissions could result in cancer or non-cancer health risks that would exceed BAAQMD thresholds, resulting in a potentially significant impact. The potentially significant impact from the exposure of receptors to DPM during project construction activities would be reduced by Mitigation Measures AQ-1 through AQ-4 and AQ-6, which would reduce fugitive dust through construction BMPs, reduce DPM through Tier 4 engines and model year 2010 engines in clean diesel trucks, and offset any remaining emissions to below BAAQMD thresholds through the purchase of mitigation credits. However, emissions generated by construction activities could still expose receptors to cancer and non-cancer risks in excess of BAAQMD significance thresholds during construction.
Mitigation Measure AQ-9 would require a project-level evaluation of health risks from future projects.
At this time, definitive conclusions regarding project-level evaluations of health risks cannot be made. Construction-generated DPM would be evaluated for specific projects, per Mitigation Measure AQ-9, and mitigated to the extent feasible, but this mitigation measure does not ensure that the evaluations would find less-than-significant impacts. Therefore, it is possible that mitigation to address future project health risks and pollutant concentrations may be inadequate with respect to reducing impacts to levels below BAAQMD thresholds. This impact would be significant and unavoidable.
Operation
It is conservatively assumed that in the Life Sciences Scenario, R&D buildings could involve research activity in wet laboratories and/or require process boilers. The wet laboratories would result in various ROG emissions from solvents and chemicals specific to the type of research being conducted (e.g., chemistry, chemical engineering, biological sciences, physical sciences). The exact number and size of future laboratories that may be constructed under the Life Sciences Scenario are not currently known. ROG emissions from laboratory activity could include carcinogenic organics with 70 Per BAAQMD guidance, PM2.5 exhaust is used as a surrogate for DPM.
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acute and chronic hazard risks. In the event that laboratory space is added among future R&D buildings under the Life Sciences Scenario, Mitigation Measure AQ-9 would be required to provide a project-level evaluation of health risks related to emissions of ROG and its constituent gases from solvents and chemicals specific to the type of research being conducted. Similarly, in the event that process boilers are added among future R&D buildings under the Life Sciences Scenario and boiler details are specified (i.e., geographic location, release height, stack inside diameter, gas exit temperature, gas exit flow rate), Mitigation Measure AQ-9 would be required to evaluate health risks related to emissions of ROG and its constituent gases from process boilers.
As discussed above, the proposed project would include the installation and operation of dieselfueled generators, a new stationary source of TACs. All new stationary sources would be subject to the permit authority of BAAQMD, which will not issue a permit for a new source that results in an operational cancer risk in excess of 10.0 cases per million or a hazard index in excess of 1.0.
Consequently, regulatory mechanisms exist that would ensure that cancer and health hazard impacts from stationary sources developed under the project would be less than significant.
However, BAAQMD’s permit does not specifically address PM2.5 concentrations. Therefore, emissions generated by new stationary resources could still expose receptors to PM2.5 concentrations in excess of BAAQMD significance thresholds during operations. Mitigation Measure AQ-9 would be required to provide a project-level evaluation of operational PM2.5 concentrations from future projects.
At this time, definitive conclusions regarding project-level evaluations of health risks cannot be made. Operational emissions of TAC from future lab uses, and PM2.5 from future diesel generators would be evaluated for specific projects, per Mitigation Measure AQ-9, but this mitigation measure does not ensure that the evaluations would find less-than-significant impacts. Therefore, it is possible that mitigation to address future project health risks and pollutant concentrations may be inadequate with respect to reducing impacts to levels below BAAQMD thresholds. This impact would be significant and unavoidable.
Mitigation Measure AQ-9: Require Future Projects within 1,000 Feet of Sensitive Receptors to Perform a Health Risk Assessment (Future Phases Only) All applicants proposing development of projects, other than Phase 1, within 1,000 feet of existing sensitive receptors, as defined by BAAQMD (e.g., residential), shall prepare a site-specific construction and operational HRA. The HRA shall include all reasonably foreseeable sources of TAC, consistent with BAAQMD guidelines. If the HRA demonstrates, to the satisfaction of the City, that the health risk exposures or PM2.5 concentrations for adjacent receptors would be less than BAAQMD project-level thresholds, then additional mitigation would be unnecessary. However, if the HRA demonstrates that health risks or PM2.5 concentrations would exceed BAAQMD projectlevel thresholds, additional feasible on- and off-site mitigation would be analyzed by the applicant to help reduce risks to the greatest extent practicable. Mitigation may include installation of indoor air filters (MERV 13 or higher) at sensitive receptor locations and planting of vegetation and trees as pollution buffers.
Phase 1
The types of pollutants of concern to human health generated by construction and operation of Phase 1 would be the same as evaluated above for the project—criteria pollutants and TAC. These pollutants and their potential impacts on receptors are analyzed below.
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Localized Criteria Pollutants
Localized criteria pollutants generated by Phase 1 (e.g., fugitive dust, PM, CO) would be similar to those generated by the project.
Construction
During grading and excavation activities associated with construction, localized fugitive dust would be generated. BAAQMD’s CEQA Guidelines considers dust impacts to be less than significant if BAAQMD’s construction BMPs are employed to reduce such emissions. Because BAAQMD’s Basic Construction Mitigation Measures would be implemented, per Mitigation Measure AQ-1, construction-related fugitive dust emissions would be less than significant and would not expose receptors to substantial pollutant concentrations or risks.
Operation
As discussed above, BAAQMD has developed screening criteria to assist lead agencies in evaluating potential impacts from localized CO. Phase 1 would not increase traffic volumes at any intersection to more than 44,000 vehicles per hour or 24,000 vehicles per hour in areas where vertical or horizontal mixing is limited, as specified by BAAQMD. However, the intersection of San Bruno Avenue/El Camino Real currently does not meet the applicable congestion management plan standard. 71 As such, operation of Phase 1 would not meet BAAQMD’s CO hot-spot screening criteria.
Therefore, BAAQMD’s screening criteria cannot be used; a site-specific analysis has been conducted to determine if Phase 1 could contribute to a localized CO hot spot and expose receptors to substantial CO concentrations or risks. CO impacts were analyzed at the intersection of San Bruno Avenue/El Camino Real using the traffic conditions from existing conditions (2018) and from the Phase 1 buildout (2024). Table 4.2-13, p. 4.2-57, presents Phase 1 CO concentrations summed with background CO levels and compared against the CAAQS and NAAQS.
Table 4.2-13. CO Concentrations at San Bruno Avenue/El Camino Real Intersection at Phase 1 Operation (parts per million)
Source Receptora
1 Hour 8 Hours
Existing
(2018)
Phase 1
(2024)
Existing
(2018)
Phase 1
(2024)
San Bruno Avenue/El Camino Real 1 2.5 2.6 1.8 1.8
2 2.6 2.7 1.8 1.9
3 2.6 2.7 1.8 1.9
4 2.5 2.5 1.8 1.8
CAAQS 20 20 9.0 9.0
Exceed CAAQS? No No No No
NAAQS 35 35 9 9
Exceed NAAQS? No No No No
Source: See Appendix 4.2-1 for CO modeling outputs.
Notes:
CAAQS = California Ambient Air Quality Standards; NAAQS = National Ambient Air Quality Standards a Receptors are located at each of the four corners of the intersection. The intersection modeled has two intersecting roadways.
71 Fehr & Peers. 2021. Southline Transportation Impact Analysis. June.
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As shown in Table 4.2-13, p. 4.2-57, CO concentrations are not expected to contribute to any new localized violations of the 1-hour or 8-hour ambient state or federal air quality standards.
Accordingly, sensitive receptors would not be exposed to substantial concentrations of CO.
Therefore, this impact would be less than significant.
Toxic Air Contaminants
The primary TACs of concern associated with Phase 1 are asbestos and DPM.
Construction
All demolition activities would be subject to EPA's asbestos NESHAP if asbestos is present at the existing facilities. The asbestos NESHAP regulations protect the public by minimizing the release of asbestos fibers during activities involving the processing, handling, and disposal of ACM. The asbestos NESHAP regulations for demolition and renovation are outlined in BAAQMD Regulation 11, Rule 2. In addition to demolition and renovation measures, BAAQMD Regulation 11, Rule 2 also includes measures to address ACM during haul truck transport. More specifically, it includes provisions such as treating ACM with water prior to transport and placing such material in leaktight containers for haul truck transport to disposal sites. Consequently, regulatory mechanisms exist that would ensure that impacts from ACM, if present during demolition activities within the Phase 1 site, would be less than significant.
Construction activities would generate DPM and PM2.5 that could expose adjacent receptors to significant health risks. The receptors affected by the highest concentrations of DPM exhaust and PM2.5 exhaust are adjacent to (i.e., property boundaries are less than a foot away from construction area boundaries) and south of the off-site improvement area at Tanforan Avenue. Table 4.2-14, p.
4.2-54, presents the unmitigated and mitigated construction-related health risk for the maximally exposed individual receptorwithin 1,000 feet of Phase 1 construction activities. In an unmitigated scenario, Phase 1 would result in a significant increase in cancer risk (90 per million) and annual PM2.5 concentrations (0.4 µg/m3) for the maximally exposed individual receptor. As a result of these exceedances of the cancer risk and PM2.5 thresholds, mitigation measures would be required to reduce impacts. Implementation of Mitigation Measure AQ-1 and AQ-2 would require BAAQMD’s BMPs and Tier 4 engines in construction equipment to reduce fugitive dust and DPM emissions and correspondingly reduce cancer risks and annual PM2.5 concentrations. With these mitigation measures, this impact would be less than significant with mitigation.
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Table 4.2-14. Phase 1 Cancer and Chronic Hazard Risks and PM.5 Concentrations during Constructiona
Unmitigated Mitigatedb
Receptor
Cancer
Riska
(cases
per
million)
NonCancer
Hazard
Index
Annual PM2.5
Concentration
(µg/m3)
Cancer
Risk
(cases
per
million)
NonCancer
Hazard
Index
Annual PM2.5
Concentration
(µg/m3)
Maximally Exposed
Individual Receptorc
89.6 0.1 0.4 4.5 < 0.1 0.2
Significance Threshold 10.0 1.0 0.3 10.0 1.0 0.3
Exceed Threshold? Yes No Yes No No No
Source: See Appendix 4.2-1 for modeling outputs and calculations.
Note: µg/m3 = micrograms per cubic meter; PM2.5 = particulate matter no more than 2.5 microns in diameter Exceedances of BAAQMD thresholds are underlined.
a The Phase 1 mitigated results account for BAAQMD thresholds regarding fugitive dust (Mitigation Measure AQ1) and 95 percent of offroad equipment with Tier 4 engines (Mitigation Measure AQ-2) (see Impact AQ-2a). b This receptor is adjacent to the southern boundary of the off-site improvement area (Tanforan Avenue) associated with Phase 1 construction.
Operation
As discussed above, Phase 1 would include the installation and operation of five diesel-fueled generators, a new stationary source of TACs. All new stationary sources would be subject to the permit authority of BAAQMD, which will not issue a permit for a new source that results in an operational cancer risk in excess of 10.0 cases per million or a hazard index in excess of 1.0.
Because BAAQMD’s permit does not specifically address PM2.5, concentrations from operation of the emergency generators were modeled, and Table 4.2-15, p. 4.2-59, presents the results of the modeling. Generators were assumed to operate for 50 hours per year, consistent with CARB’s Airborne Toxic Control Measure for Stationary Compression Ignition Engines and Section 330.3 of BAAQMD Regulation 9, Rule 8. Cancer and non-cancer health risks are presented for informational purposes. The receptors affected by the highest concentrations of DPM exhaust are adjacent to and south of the off-site improvement area at Tanforan Avenue. As shown in Table 4.2-15, p. 4.2-59, Phase 1 operations would not result in a significant increase in PM2.5 exhaust concentrations.
Therefore, this impact would be less than significant. No mitigation is required.
Table 4.2-15. Phase 1 Cancer and Chronic Hazard Risks and PM.5 Concentrations during Operation Receptor
Unmitigated
Cancer Riska
(cases per
million)
Non-Cancer
Hazard Index
Annual PM2.5
Concentration
(µg/m3)
Maximally Exposed Individual Receptora 2.7 < 0.1 < 0.1
Significance Threshold 10.0 1.0 0.3
Exceed Threshold? No No No
Source: See Appendix 4.2-1 for modeling outputs and calculations.
Note: µg/m3 = micrograms per cubic meter; PM2.5 = particulate matter no more than 2.5 microns in diameter City of South San Francisco
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Receptor
Unmitigated
Cancer Riska
(cases per
million)
Non-Cancer
Hazard Index
Annual PM2.5
Concentration
(µg/m3)
a This receptor is adjacent to the southern boundary of the off-site improvement area (Tanforan Avenue) associated with Phase 1 construction.
The cancer risk threshold defined by BAAQMD is for exposure of a maximally exposed sensitive receptor (generally within 1,000 feet) to an individual emissions source, resulting in an excess cancer risk level of more than 10 in 1 million. The approach for estimating cancer risk is based on long-term inhalation, assuming a 24-hour per day, 350-day per year, 30-year exposure for residential receptors. Accordingly, to determine the Phase 1 combined cancer risk, the risk from the 3-year-long mitigated construction period (approximately three cases per million, per Table 4.2-14, p. 4.2-59) and the risk from the 30-year-long operational period (approximately three cases per million, per Table 4.2-15, p. 4.2-59) are added together (approximately six cases per million). The combined cancer risk would not exceed BAAQMD’s threshold of 10 cases per million. Therefore, this impact would be less than significant with mitigation.
Impact AQ-4: The project would not result in other emissions (such as those leading to odors) that would adversely affect a substantial number of people. (Project: Less than Significant; Phase 1: Less than Significant)
Project and Phase 1
BAAQMD and CARB have identified the types of land uses below as being commonly associated with odors. Although this list is not exhaustive, it is intended to help lead agencies recognize the types of facilities where more analysis may be warranted.
• Sewage treatment plants
• Coffee roasters
• Asphalt plants
• Metal smelters
• Landfills
• Recycling facilities
• Waste transfer stations
• Petroleum refineries
• Biomass operations
• Auto body shops
• Coating operations
• Fiberglass manufacturers
• Foundries
• Rendering plants
• Livestock operations
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The project would be constructed and operated within 1,000 feet of existing sensitive receptors (see Figure 4.2-1, p. 4.2-10). The proposed project would establish a new zoning district in the proposed Specific Plan area, referred to as the Southline Campus District (S-C District). The list of land uses that could be permitted in the S-C District does not include any of the odor-generating land uses identified above (see Table 3-6 in Chapter 3, Project Description, of this EIR, for a list of permitted land uses).
Potential odor emitters during construction activities include diesel exhaust, asphalt paving, and the use of architectural coatings and solvents. Construction-related activities would be temporary and would not be likely to result in nuisance odors that would violate BAAQMD Regulation 7. Odors during operation could emanate from the emergency diesel generators and the reapplication of architectural coatings. These odors would be limited to the immediate vicinity of the project site and occur infrequently. Although such brief exhaust- and paint-related odors may be considered adverse, they would not affect a substantial number of people. Given mandatory compliance with BAAQMD rules, no proposed construction or operational activities would create a significant level of objectionable odors. Therefore, odor impacts for the proposed project, inclusive of Phase 1, would be less than significant. No mitigation is required.
4.2.4.4 Cumulative Impacts
The cumulative geographic context for air quality is the SFBAAB. The cumulative geographic context for health risks and odors is the immediate vicinity of the project site (i.e., within 1,000 feet).
Impact C-AQ-1: The project, inclusive of Phase 1, together with the cumulative projects identified, would not conflict with or obstruct implementation of the applicable air quality plan. (Project: Less than Significant; Phase 1: Less than Significant) As discussed under Impact AQ-1, the proposed project, inclusive of Phase 1, would support the goals of BAAQMD’s Clean Air Plan, would include all applicable control measures, and would not conflict with Clean Air Plan implementation. The purpose of the Clean Air Plan is to improve regional air quality in the air basin; therefore, the analysis and less-than-significant finding under Impact AQ-1 is inherently cumulative. For these reasons, the proposed project, inclusive of Phase 1, in combination with past, present, and reasonably foreseeable future projects would not contribute to or result in a significant cumulative impact related to air quality plan consistency. The cumulative impact would be less than significant. No mitigation is required.
Impact C-AQ-2: Construction and operation under the Specific Plan, inclusive of Phase 1, together with the cumulative projects identified, could result in a cumulatively considerable net increase in any criteria pollutant for which the project region is a non-attainment area under an applicable federal or state ambient air quality standard. (Project: Significant and Unavoidable; Phase 1: Significant and Unavoidable)
As discussed above, BAAQMD has identified project-level thresholds to evaluate criteria pollutant impacts (Table 4.2-4, p. 4.2-21). In developing these thresholds, BAAQMD considers levels at which project emissions are cumulatively considerable. As noted in BAAQMD’s guidelines, 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 exceeds the identified significance thresholds, its emissions would be cumulatively considerable, resulting in City of South San Francisco
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significant adverse air quality impacts on the region’s existing air quality conditions. Therefore, additional analysis to assess cumulative impacts is unnecessary.
Project
Per BAAQMD guidelines, exceedances of project-level thresholds would be cumulatively considerable, and the cumulative impact would be significant. As discussed above under Impacts AQ-2a and AQ-2b, construction and operational emissions resulting from individual projects developed under the Specific Plan could exceed BAAQMD’s regional ROG, NOX, and PM thresholds.
Mitigation Measures AQ-1 through AQ-7 would reduce regional emissions of ROG, NOX, and PM to a level below BAAQMD’s regional thresholds. Because it cannot be concluded that offset programs per Mitigation Measures AQ-6 and AQ-7 would be available in the future at the time and in the amount needed for any given future development under the Specific Plan, for the purposes of this EIR analysis, impacts during construction and operation related to regional criterial pollutants quality impacts from the project are conservatively assumed to result in a significant and unavoidable cumulative impact.
Phase 1
Per BAAQMD guidelines, exceedances of project-level thresholds would be cumulatively considerable, and the cumulative impact would be significant. As shown in Table 4.2-7, p. 4.2-41, construction of Phase 1 would not generate regional criteria pollutants in excess of BAAQMD thresholds with implementation of Mitigation Measure AQ-2. In addition, Mitigation Measure AQ1 would require implementation of all feasible dust control measures, thereby reducing localized fugitive dust emissions during construction. As such, construction of Phase 1 would not be expected to contribute a significant level of air pollution such that air quality within the SFBAAB would be degraded. Consequently, construction-related criteria pollutant emissions would be less than cumulatively considerable. The cumulative impact would be less than significant with mitigation.
As discussed above under AQ-2b, operation of Phase 1 would generate ROG and NOx emissions in excess of BAAQMD thresholds during days on which emergency generator testing would occur. As such, operation of Phase 1 would be expected to contribute a significant level of air pollution such that air quality within the SFBAAB would be degraded. Mitigation Measure AQ-8 would reduce the daily emission from stationary sources by limiting the number of emergency generators that can be tested in any given day. Mitigation Measure AQ-7 would reduce regional emissions of ROG, NOX, and PM from Phase 1 to a level below BAAQMD’s regional thresholds, resulting in a less-thansignificant impact. However, because it cannot be concluded that offset programs would be available in the future at the time and in the amount needed for any given future development under the Specific Plan, for the purposes of this EIR analysis, impacts related to regional criteria pollutants are conservatively assumed to result in cumulative impact that would be significant and unavoidable.
Impact C-AQ-3: Construction and operation of future Precise Plans under the Specific Plan, not including Phase 1, together with the cumulative projects identified, could expose sensitive receptors to substantial pollutant concentrations. (Project: Significant and Unavoidable; Phase 1: Less than Cumulatively Considerable) According to BAAQMD’s guidelines, combined risk levels should be determined from all nearby DPM sources within 1,000 feet of a project site, and these combined risk levels should be compared to BAAQMD’s cumulative health risk thresholds.
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Project
Localized Criteria Pollutants and Toxic Air Contaminants The analysis of localized criteria pollutants in Impact AQ-3 included modeling to evaluate CO hotspot concentrations. As shown in Table 4.2-12, p. 4.2-54, CO concentrations are not expected to contribute to any new localized violations of the 1-hour or 8-hour ambient state or federal air quality standards. Accordingly, sensitive receptors would not be exposed to substantial concentrations of CO. This impact was concluded to be less than significant. Because the projectlevel CO hot-spot analysis already accounts for (1) background concentrations of CO as measured at local air quality monitoring stations and (2) cumulative background traffic in the project analysis year of 2030, the significance determination is inherently cumulative. The project-level impact determination for CO hotspots therefore serves as the impact determination for Impact C-AQ-3, which would be less than significant.
Existing nearby DPM sources and the project could contribute to a cumulative health risk for sensitive receptors near the project site. As discussed above under Impact AQ-3, a quantitative evaluation of potential health risk impacts for the proposed project is not possible. Mitigation Measures AQ-1 through AQ-7 and Mitigation Measure AQ-9 would develop and maintain best practices for reducing emissions associated with construction and operational activities and require that new development with sensitive receptors adjacent to TAC sources be designed to minimize health risks, which would reduce construction and operational health risks for existing and future receptors. However, there may be instances where project-specific conditions would preclude a reduction in the health risk to a level below adopted thresholds and expose receptors to cumulative health risks. For instance, this may include the installation or operation of new stationary sources of TACs (e.g., generators) on the project site that result in significant PM2.5 concentrations. However, BAAQMD permitting would ensure that cancer risks and the hazard index would be below the applicable thresholds but would not ensure that PM2.5 concentrations would be below the applicable threshold. In addition, future development projects under the Specific Plan could generate DPM, PM2.5, or other TACs, such as those emitted from laboratory uses or process boilers, that could expose adjacent receptors to significant health risks (e.g., from construction and operational sources that are adjacent to sensitive receptors). Therefore, it is conservatively assumed that the proposed project in combination with other past, present, and reasonably foreseeable future projects would result in a cumulative impact that would be significant and unavoidable.
Phase 1
Localized Criteria Pollutants and Toxic Air Contaminants The analysis of localized criteria pollutants in Impact AQ-3 included modeling to evaluate CO hotspot concentrations. As shown in Table 4.2-13, p. 4.2-70, CO concentrations are not expected to contribute to any new localized violations of the 1-hour or 8-hour ambient state or federal air quality standards. Accordingly, sensitive receptors would not be exposed to substantial concentrations of CO. This impact was concluded to be less than significant. Because the Phase 1- level CO hot-spot analysis already accounts for (1) background concentrations of CO as measured at local air quality monitoring stations and (2) cumulative background traffic in the Phase 1 analysis year of 2024, the significance determination is inherently cumulative. The Phase 1-level impact determination for CO hotspots therefore serves as the impact determination for Impact C-AQ-3, which would be less than significant.
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Phase 1 construction activities and operation of the five new diesel-fueled generators on the project site would generate DPM and PM2.5. Existing nearby DPM and PM2.5 sources within 1,000 feet of the project site, along with the Phase 1 site, could contribute to a cumulative health risk for existing and future sensitive receptors adjacent to and within the project site (see Figure 4.2-1, p. 4.2-10).
This is a potentially significant impact. Data files and distance multipliers provided by BAAQMD were used to estimate background impacts and concentrations for existing stationary, roadway, and railway sources, as shown in Figure 4.2-1, p. 4.2-10. The combined risks from mitigated construction (with implementation of Mitigation Measures AQ-1 and AQ-2) and operation of Phase 1 and ambient sources are summarized in Table 4.2-16, p. 4.2-64. The methods used to estimate Phase 1 emissions are described above in Section 4.2.4.2, Approach to Analysis, and provided in Appendix 4.2-1.
As shown in Table 4.2-16, p. 4.2-64, the combined PM2.5 concentration from Phase 1 construction, Phase 1 operation, and ambient sources would exceed the BAAQMD cumulative threshold. This is largely a result of the existing stationary sources—specifically, the multiple emission sources at Central Concrete Supply, Inc., an asphalt concrete plant approximately 900 feet northeast of the maximally exposed individual receptor. This facility accounts for 97 percent of the cumulative PM2.5 concentration. Therefore, for Phase 1, there is a significant cumulative impact for receptors in the project area. The contribution of Phase 1 is a very small proportion of the PM2.5 concentration, however, and below BAAQMD’s project-level threshold. Therefore, while a cumulative impact exists with respect to annual PM2.5 emissions, Phase 1’s contribution is considered less than cumulatively considerable.
Table 4.2-16. Mitigated Cumulative Health Risks from Phase 1 Source
Cancer Risk
(cases per
million)
Non-Cancer
Hazard Index
Annual PM2.5
Concentration
(μg/m3)
Contribution from Existing Sourcesa
Stationary Sources < 1 < 0.1 9.6
Roadway Sources 6 — 0.2
Rail Sources 21 — < 0.1
Contribution from Phase 1 Constructionb
Maximally Exposed Individual Receptor 1 < 0.1 0.1
Contribution from Phase 1 Operation
Maximally Exposed Individual Receptor 2 < 0.1 < 0.1
Cumulative Totals
Existing + Phase 1 Construction 28 < 0.1 9.9
Existing + Phase 1 Operation 29 < 0.1 9.8
Existing + Phase 1 Construction and Operation 30 < 0.1 9.9 BAAQMD Thresholds 100 10.0 0.8
Source: See Appendix 4.2-1 for modeling outputs and calculations.
Notes:
Exceedances of BAAQMD thresholds are underlined.
μg/m3 = micrograms per cubic meter
a Contributions from existing sources represent the health risks within 1,000 feet of the maximum exposed receptor, which is a residence on the east corner on the south side of Tanforan Avenue. See Figure 4.2-1, p. 4.2- 10, for existing stationary, roadway, and rail sources.
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Source
Cancer Risk
(cases per
million)
Non-Cancer
Hazard Index
Annual PM2.5
Concentration
(μg/m3)
b Contributions from Phase 1 construction reported with implementation of Mitigation Measures AQ-1 and AQ2.
Impact C-AQ-4: The project, inclusive of Phase 1, together with the cumulative projects identified would not result in other emissions (such as those leading to odors) that would adversely affect a substantial number of people. (Project: Less than Significant; Phase 1: Less than Significant)
As discussed under Impact AQ-4, the project, inclusive of Phase 1, would not generate substantial odors. The cumulative projects do not include land uses that are known to generate adverse odors.
Construction activities would generate odors from diesel exhaust, asphalt paving, and the use of architectural coatings and solvents, but these activities would be temporary and would not result in nuisance orders that would violate BAAQMD’s Regulation 7. In addition, odors during operation could emanate from the emergency diesel generators and the reapplication of architectural coatings.
These odors would be limited to within the project site and occur infrequently. Given mandatory compliance with BAAQMD rules, the proposed project in combination with other past, present, and reasonably foreseeable future projects would not result in significant odor impacts. The cumulative impact would be less than significant.
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4.3 Biological Resources
4.3.1 Introduction
This section evaluates the potential impacts related to construction and operation of the Southline Specific Plan and off-site improvements (proposed project), including the first phase of development under the proposed project (Phase 1), on biological resources. This section also describes existing conditions at the project site, including the Phase 1 site, as well as the regulatory framework for this analysis. The impacts of the proposed project are generally analyzed at a program level, and the impacts of Phase 1 are analyzed at a project level. Impacts resulting from implementation of the proposed project, impacts resulting from implementation of Phase 1, and cumulative impacts are described. Feasible mitigation measures, where applicable, are also described. Relevant technical documentation used in this analysis includes the Tree Inventory of Southline, South San Francisco, CA 94080 (Tree Inventory) prepared for the Specific Plan area by Urban Tree Management in May 2020 (Appendix 4.3-1)
1 and biological database queries conducted for the project site by ICF in September 2020 (Appendix 4.3-2).
Issues identified in response to the Notice of Preparation (NOP) (Appendix 1) were considered in preparing this analysis. The NOP comments pertaining to biological resources include comments from the California Department of Fish and Wildlife (CDFW) that recommend mitigation for nesting birds and roosting bats and note the potential for special-status species, including Alameda song sparrow and hoary bat, to be present on the project site. These issues are addressed below in Section 4.3.4, Impacts and Mitigation Measures.
4.3.2 Environmental Setting
This section provides a discussion of the existing conditions related to biological resources on the project site.
4.3.2.1 Regional Setting
The city of South San Francisco encompasses approximately 4,298 acres and is largely composed of single-use areas, with industry in the eastern and southeastern portions of the city and single-family homes to the north and west. Much of the city is already urbanized, and the amount of vacant land is limited. The project site is located within the Pacific Flyway, which extends from Alaska to Patagonia; the Pacific Flyway is one of four major flyways in North American used by migratory birds for their annual migrations. Naturally occurring open space in proximity to the project site includes San Bruno Mountain State and County Park, 1.65 miles to the northwest; San Francisco Bay,
1.1 mile to the east, and San Francisco watershed land, 2 miles to the southwest. In addition, a north–south running strip of fragmented open space belonging to San Francisco International Airport (known as the West of Bayshore Subarea to the Airport Planning Department) is 0.6 mile southeast of the project site.
1 Urban Tree Management. 2020. Tree Inventory of Southline, South San Francisco, CA 94080. May 13.
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4.3.2.2 Project Site
The project site totals approximately 33 acres and is comprised of the Specific Plan area and the offsite improvement areas. The Specific Plan area is located in the City of South San Francisco, and comprises seven parcels totaling approximately 26.5 acres, which are completely developed. The off-site improvement areas, which include approximately 6.4 acres, portions of which are located within the jurisdictions of the City of South San Francisco, the City of San Bruno, and Bay Area Rapid Transit (BART), are also completely developed. The project site is bounded by commercial, industrial, and warehouse facilities to the north and east; to the south are predominately singlefamily residences. To the west are the San Bruno BART station, The Shops at Tanforan, and the San Bruno Towne Center.
The Specific Plan area includes 15 existing buildings and/or structures ranging in height from one to three stories and totaling approximately 344,000 square feet, all of which would be removed in connection with implementation of the project. The existing buildings include occupied and unoccupied office, industrial, warehouse, and storage uses. In addition, surface parking lots with approximately 380 surface parking spaces are interspersed among the Specific Plan area buildings.
The off-site improvement areas consist of rights-of-way and easements developed with existing circulation and utility infrastructure improvements. The topography of the project site and surrounding area is relatively flat, with a slight slope downward toward the northeast. The Specific Plan area contains some ornamental landscaping and approximately 162 trees, including two protected trees.
2,3 The off-site improvement areas contain additional ornamental landscaping and approximately 19 trees, with four trees near the intersection of South Linden Avenue and Dollar Avenue in the city of South San Francisco, and approximately 15 trees near the proposed Huntington Avenue/Sneath Lane/Southline Avenue/Maple Avenue intersection in the cities of South San Francisco and San Bruno.
4 The trees and buildings on or adjacent to the project site could provide nesting substrate for bird and bat species. No sensitive natural communities, wetlands, streams, or other aquatic features are present on the project site.
4.3.2.3 Phase 1 Site
As a component of the developed project site, the environmental setting of the Phase 1 site is the same as described for the project site overall. The 16.96-acre Phase 1 site includes approximately
11.93 acres of the Specific Plan area in the City of South San Francisco and approximately 5.03 acres of off-site improvement areas in the cities of South San Francisco and San Bruno. The Phase 1 site is developed with nine buildings ranging in height from one to three stories. The portion of the Phase 1 site within the Specific Plan area contains ornamental landscaping and approximately 80 trees; the off-site improvement areas included in the Phase 1 site contain additional ornamental landscaping and approximately 19 trees. No protected trees are located within the Phase 1 site. 2 Urban Tree Management. 2020. Tree Inventory of Southline, South San Francisco, CA 94080. May 13. 3 City of South San Francisco. n.d. South San Francisco Municipal Code. Chapter 13.30, Tree Preservation.
Available: http://www.qcode.us/codes/southsanfrancisco/?view=desktop&topic=13-13_30-13_30_080.
Accessed: September 16, 2020.
4 Aerial and street view imagery from Google Earth was used to approximate the number of trees in the off-site improvement areas.
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The trees and buildings on or adjacent to the Phase 1 site could provide nesting substrate for bird and bat species. No sensitive natural communities, wetlands, streams, or other aquatic features are present on the Phase 1 site.
4.3.3 Regulatory Framework
This section provides a summary of the biological resources plans and policies of federal, state, and local agencies that have policy and regulatory control over the project site.
4.3.3.1 Federal
Federal Endangered Species Act
The federal Endangered Species Act (FESA) (16 United States Code [USC], Section 1531 et seq.) designates threatened and endangered animal and plant species and provides measures for their protection and recovery. Take (i.e., to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect or attempt to engage in any such conduct) of listed plant or wildlife species is prohibited without first obtaining a federal permit. The FESA also generally requires a determination of critical habitat for listed species. If critical habitat has been designated, impacts on areas that contain the primary constituent elements identified for the species, whether or not the species is currently present, are also prohibited. FESA Section 7 (for actions by federal agencies) and Section 10 (for actions by non-federal agencies) provide pathways for obtaining authority to take listed species.
Migratory Bird Treaty Act
The federal Migratory Bird Treaty Act (MBTA) (16 USC, Section 703, Supplement I, 1989) prohibits any attempt to take, kill, possess, sell, or trade migratory birds, except in accordance with regulations prescribed by the Secretary of the Interior. This act applies to whole birds, parts of birds, and bird nests and eggs. Although the MBTA itself does not provide specific take avoidance measures, over time, the U.S. Fish and Wildlife Service (USFWS) has developed measures regarding take avoidance with respect to nesting birds. These measures include avoiding vegetation removal or ground disturbance during the nesting season (typically February 15–September 15), conducting preconstruction nesting bird surveys in a project area during nesting season, and establishing appropriately sized protective buffers if active nests are found.
On December 22, 2017, the U.S. Department of the Interior Office of the Solicitor issued a memorandum: M-37050 The Migratory Bird Treaty Act Does Not Prohibit Incidental Take (referred to as the Jorjani Opinion). On August 11, 2020, the United States District Court Southern District of New York concluded that the Jorjani Opinion is contrary to the plain meaning of the MBTA and therefore must be vacated. The court has since vacated the Jorjani Opinion and remanded the case to U.S. Department of the Interior and USFWS for further action. If the Jorjani Opinion were adopted, it would have impacted implementation of the MBTA; however, since the Jorjani Opinion has been vacated and remanded, it is not anticipated to impact this analysis and therefore is not discussed further.
Federal Clean Water Act, Section 404
The Clean Water Act is the primary federal law that protects the quality of the nation’s waters, including wetlands, lakes, rivers, and coastal areas. Section 404 of the Clean Water Act regulates the City of South San Francisco
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discharge of dredged or fill material into the waters of the United States, including wetlands. The Clean Water Act provides that all discharges into the nation’s waters are unlawful unless specifically authorized by a permit; issuance of such permits constitutes its principal regulatory tool.
The U.S. Army Corps of Engineers (USACE) is authorized to issue Section 404 permits, which allow the placement of dredged or fill materials into jurisdictional waters of the United States under certain circumstances. The USACE issues two types of permits under Section 404: general permits, which are either nationwide permits or regional permits, and standard permits, which are either letters of permission or individual permits. General permits are issued by the USACE to streamline the Section 404 permitting process for nationwide, statewide, or regional activities that have minimal direct or cumulative environmental impacts on the aquatic environment. Standard permits are issued for activities that do not qualify for a general permit because they may have more than a minimal adverse environmental impact.
Federal Clean Water Act, Section 401
Under Clean Water Act Section 401, applicants for a federal license or permit to conduct activities that may result in the discharge of a pollutant into waters of the United States must obtain certification from the state in which the discharge would originate. Therefore, all projects that have a federal component and may affect state water quality, including projects that require federal agency approval, such as issuance of a Section 404 permit, must also comply with Clean Water Act Section 401 and the Porter-Cologne Water Quality Control Act (Porter-Cologne). In California, Section 401 certification is handled by the nine Regional Water Quality Control Boards (RWQCBs) and the State Water Resources Control Board. The city of South San Francisco falls under the jurisdiction of the San Francisco Bay RWQCB. The San Francisco Bay RWQCB must certify that the discharge will comply with state water quality standards and other requirements of the Clean Water Act.
USACE Jurisdictional Areas
In January 2020, U.S. EPA and USACE signed an agreement on a new definition of waters of the United States; this agreement is known as the new Navigable Waters Protection Rule (NWPR). The NWPR revised the definition of waters that are federally regulated under the CWA. The new NWPR narrows the definition of waters of the United States, focusing on traditional navigable waters and whether there is a surface water connection between them. The NWPR was published in the Federal Register on April 21, 2020 (85 Federal Register 22250) and became effective June 22, 2020.
The revised definition identifies four clear categories of federally regulated waters. • Territorial seas and traditional navigable waters
• Perennial and intermittent tributaries to those waters • Certain lakes, ponds, and impoundments
• Wetlands that are adjacent to jurisdictional waters.
This final action lists 12 categories of exclusions, including the following. • Features that only contain water in direct response to rainfall (e.g., ephemeral streams) • Groundwater
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• Many ditches, including most farm and roadside ditches • Prior converted cropland
• Farm and stock watering ponds
• Waste treatment systems.
There must be surface water connection that is at least intermittent or perennial: “wetlands that are meaningfully connected to other jurisdictional waters, for example, by directly abutting or having regular surface water communication with jurisdictional waters.” However, there can be nonjurisdictional connectors (e.g., ditches, sheet flow) between two jurisdictional waters.
The revised definition leaves unchanged the parameters used to identify and delineate wetlands and the Ordinary High Water Mark (OHWM) characteristics used to define the upper boundary of USACE jurisdiction over non-wetland waters such as streams, ponds, and lakes. The boundaries of non-tidal, non-wetland waters (streams) were delineated at the OHWM as defined in 33 Code of Federal Regulations (CFR) 328.3. The OHWM represents the limit of potential USACE jurisdiction over non-tidal waters (e.g., streams, ponds) in the absence of adjacent wetlands (33 CFR 328.04).
USACE defines jurisdictional wetlands under CWA Section 404 as areas that exhibit positive field indicators for all three wetland parameters. The three parameters used to determine the presence of CWA Section 404 wetlands are (1) hydrophytic vegetation, (2) hydric soils, and (3) wetland hydrology. According to the U.S. Army Corps of Engineers Wetlands Delineation Manual (1987 Manual; Environmental Laboratory 1987:12), “evidence of a minimum of one positive wetland indicator from each parameter (hydrology, soil, and vegetation) must be found in order to make a positive wetland delineation.”
4.3.3.2 State
California Endangered Species Act
Administered by the CDFW, the California Endangered Species Act (CESA) prohibits the take of listed species as well as species that are formally under consideration for listing in California, referred to as candidate species. Under the CESA, take means to “hunt, pursue, catch, capture, or kill or attempt to hunt, pursue, catch, capture, or kill” (California Fish and Game Code Section 86). Under this definition, in contrast to the FESA, the CESA does not prohibit harm to a listed species.
Furthermore, take under the CESA does not include “the taking of habitat alone or the impacts of the taking” (Environmental Council of Sacramento v. City of Sacramento (2006) 142 Cal.App.4th 1018).
However, the killing of a listed species that is incidental to an otherwise lawful activity and not the primary purpose of the activity constitutes take under the CESA; in contrast to FESA, “incidental take” is not defined in state statues or regulations.
5 State Fish and Game Code, Section 1600–1616
The CDFW has jurisdictional authority over streams and lakes, as well as wetland resources associated with these aquatic systems, under California Fish and Game Code Section 1600 et seq.
The CDFW has the authority to regulate work that will “substantially divert or obstruct the natural 5 CDFW 2021. CESA to the Federal Endangered Species Act. Available:
https://wildlife.ca.gov/Conservation/CESA/FESA. Available: Accessed: September 10, 2021.
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flow of, or substantially change or use any material from the bed, channel, or bank of, any river, stream, or lake, or deposit or dispose of debris waste or other material containing crumbled, flaked, or ground pavement where it may pass into any river, stream, or lake” (California Fish and Game Code Section 1602.). An entity that proposes to carry out such an activity must first inform CDFW.
Where CDFW concludes that the activity will “substantially adversely affect an existing (2014) fish or wildlife resource,” the entity proposing the activity must negotiate an agreement with CDFW that specifies terms under which the activity may be carried out in a way that protects the affected wildlife resource.
Porter-Cologne Water Quality Control Act
California Water Code Section 13260 requires “any person discharging waste, or proposing to discharge waste, in any region that could affect the waters of the state to file a report of discharge (an application for waste discharge requirements).” Under the Porter-Cologne definition, waters of the state are “any surface water or groundwater, including saline waters, within the boundaries of the state.” Although all waters of the United States that are within the borders of California are also waters of the state, the reverse is not true. Accordingly, California retains authority to regulate discharges of waste into any waters of the state, regardless of whether USACE has concurrent jurisdiction under CWA Section 404. If USACE determines that a wetland is not subject to regulation under Section 404, CWA Section 401 water quality certification is not required. However, the RWQCB may impose waste discharge requirements if fill material is placed into waters of the state.
Waters of the State
Under the recent Wetland Riparian Area Protection Policy (May 28, 2020), RWQCBs will maintain jurisdiction over features excluded in the U.S. Environmental Protection Agency (EPA) and the Department of Army’s Navigable Waters Protection Rule (NWPR). The newly adopted regulations (April 2, 2019) by the State Water Resources Control Board entitled “State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State” create a new statewide wetland definition that expands to features not previously covered under federal law and creates a new permitting program for activities that result in the discharge of dredged or fill materials to any waters of the state. The new rules are adopted under the federal CWA and the state Porter-Cologne Act. Under the latter act, waters of the state are broadly defined as “[a]ny surface water or groundwater, including saline waters within state boundaries,” including both natural and certain artificial or constructed facilities. Waters of the state include both waters of the United States and non-federal waters of the state.
California Native Plant Protection Act
The California Native Plant Protection Act of 1977 (CNPPA) prohibits the importation of rare and endangered plants into California, take of rare and endangered plants, and sale of rare and endangered plants. The CESA defers to the CNPPA, ensuring that state-listed plant species are protected when state agencies are involved in projects that are subject to the California Environmental Quality Act (CEQA). In this case, plants that are listed as rare under the CNPPA are not protected under the CESA but rather under CEQA.
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California Fish and Game Code – Fully Protected Species Certain species are considered fully protected, meaning that the California Fish and Game Code explicitly prohibits all take of individuals from these species, except for take permitted for scientific research and relocation of bird species for the protection of livestock. Fully protected amphibians and reptiles, fish, birds, and mammals are listed in Sections 5050, 5515, 3511, and 4700, respectively, of the California Fish and Game Code.
California Fish and Game Code – Protection of Birds and Their Nests Under Section 3503 of the California Fish and Game Code, it is unlawful to take, possess, or needlessly destroy the nest or eggs of any bird, except as otherwise provided by this code or any regulation made pursuant thereto. Section 3503.5 of the California Fish and Game Code prohibits take, possession, or destruction of any birds in the orders Falconiformes (hawks) or Strigiformes (owls) or of their nests and eggs. Migratory non-game birds are protected under Section 3513, whereas other specified birds are protected under Section 3800.
California Fish and Game Code – Protection of Non-game Mammals Bats and other non-game mammals are protected in California. Section 4150 of the California Fish and Game Code states that all non-game mammals or parts thereof may not be taken or possessed except as otherwise provided in the Fish and Game Code or in accordance with regulations adopted by the Fish and Game Commission. Thus, destruction of an occupied, non-breeding, bat roost, resulting in the death of bats, or disturbance that causes the loss of a maternity colony of bats (resulting in the death of young), is regulated under the Fish and Game Code.
4.3.3.3 Local
South San Francisco General Plan
The 1999 South San Francisco General Plan provides a vision for long-range physical and economic development of the City, provides strategies and specific implementing actions, and establishes a basis for judging whether specific development proposals and public projects are consistent with the City’s plans and policy standards. The City General Plan contains an Open Space and Conservation Element, which outlines policies relating to habitat and biological resources, water quality, air quality, greenhouse gas emissions and historic and cultural resources conservation. The General Plan includes the following policies applicable to biological resources:
• Policy 7.1-G-1: Protect special-status species and supporting habitats within South San Francisco, including species that are state or federally listed as endangered, threatened, or rare. • Policy 7.1-I-1: Cooperate with state and federal agencies to ensure that development does not substantially affect special-status species appearing on any state or federal list for any rare, endangered, or threatened species. Require assessments of biological resources prior to approval of any development on sites with ecologically sensitive habitat, as depicted in Figure 7-1. • Policy 7.2-G-1: Comply with the San Francisco Bay Regional Water Quality Control Board regulations and standards to maintain and improve the quality of both surface water and groundwater resources.
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• Policy 7.2-G-3: Discourage use of insecticides, herbicides, or toxic chemical substances within the city.
• Policy 7.2-I-1: Continue working with the San Francisco Bay Regional Water Quality Control Board in the implementation of the National Pollutant Discharge Elimination System and continue participation in the San Mateo Countywide Stormwater Pollution Prevention Program for the protection of surface water and groundwater quality.
South San Francisco Municipal Code
Chapter 13.30, Tree Preservation, of the South San Francisco Municipal Code concerns the preservation of trees for the health, welfare, and quality of life of the citizens of the City. Trees preserve the scenic beauty of the City, maintain ecological balance, prevent the erosion of topsoil, counteract air pollution and oxygenate the air, absorb noise, maintain a climatic and microclimatic balance, help block wind, and provide shade and color. The chapter is designed to:
• Provide standards and requirements for the protection of certain large trees (trees with a circumference of 48 inches or greater at 54 inches above the natural grade), heritage trees, as well as trees and stands with unique characteristics (having been so designated by the Parks and Recreation director);
• Provide standards and requirements for the planting and maintenance of trees for new development; and
• Establish recommended standards for the planting and maintaining of trees on property that is already developed.
The chapter achieves these objectives in ways that support and encourage reasonable economic enjoyment of private property, not in ways that prevent it (SSFMC Section 13.30.010; Ordinance 1271, Section 1 [part], 2000; Ordinance 1060, Section 1 [part], 1989).
According to South San Francisco Municipal Code Chapter 13.30, certain trees are subject to conditions before being removed, pruned, or otherwise materially altered. Protected trees include heritage trees and are defined by South San Francisco Municipal Code Chapter 13.30.020 as follows:
1. Any upright, single-trunked tree of a species not considered to be a heritage tree, as defined in Subsection 3, below, or listed in Subsection 2, below, with a circumference of 48 inches or more when measured 54 inches above natural grade; or
2. Any upright, single-trunk tree of the following species: blue gum (Eucalyptus globulus), black acacia (Acacia melanoxylon), myoporum (Myoporum lactum), sweetgum (Liquidambar styraciflua), glossy privet (Lingustrum lucidum), or Lombardy poplar (Populus nigra) with a circumference of 75 inches or more when measured 54 inches above natural grade; or
3. Any upright, single-trunk tree considered to be a heritage tree species, with a circumference of 30 inches or more when measured at 54 inches above natural grade. A heritage tree means any of the following: California bay (Umbellaria californica), oak (Quercus spp.), cedar (Cedrus spp.), California buckeye (Aesculus californica), Catalina ironwood (Lyonothamnus asplenifolium), strawberry tree (Arbutus spp.), mayten (Maytenus boaria), or little gem dwarf southern magnolia (Magnolia grandiflora, “Little Gem”).
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4. A tree or stand of trees so designated by the director, based upon findings that it is unique and of importance to the public due to its unusual appearance, location, historical significance, or other factor; or
5. A stand of trees in which the director has determined each tree is dependent upon the others for survival.
Protected trees cannot be removed or pruned without a permit from the City and must be protected from development-related impacts such as soil compaction and underground trenching for utilities.
In addition, new developments must conform to a series of tree planting requirements.
San Bruno Plans and Policies
As further described in Chapter 3, Project Description, of this EIR, the project proposes certain circulation and infrastructure improvements that are located within the City of San Bruno (San Bruno) but would not develop any new structures or new land uses in San Bruno. The improvements would occur on areas that are already developed with existing circulation improvements. The specific off-site improvements located within San Bruno include: constructing a new signalized intersection at Huntington Avenue/Sneath Lane/Southline Avenue/Maple Avenue; improving Huntington Avenue from Southline Avenue south to the existing BART garage intersection located west of Pacific Avenue; converting Tanforan Avenue to a cul-de-sac adjacent to Huntington Avenue; and realigning the existing storm drain main within Huntington Avenue to conform to the proposed intersection improvements at Huntington Avenue/Southline Avenue. This section identifies and evaluates the proposed project’s consistency with relevant policies from the San Bruno General Plan and the San Bruno Municipal Code related to biological resources as related to the portions of the off-site improvements located within San Bruno’s jurisdiction. For additional discussion of the proposed project’s consistency with San Bruno land use plans and policies, refer to Section 4.10, Land Use and Planning, and Section 4.15, Transportation and Circulation.
San Bruno General Plan
The 2009 San Bruno General Plan outlines a vision for the long-range physical and economic development of the community through 2025. This vision includes balanced development, conservation of residential neighborhoods, and revitalization of downtown and other aging commercial and industrial areas. The San Bruno General Plan land use designations, policies, and implementing actions will guide City of San Bruno officials in making decisions on private development proposals and public facilities. The San Bruno General Plan contains an Environmental Resources and Conservation Element, which outlines policies relating to biological resources and habitat, water quality, air quality, global climate change, historical and cultural resources, and environmental resources and conservation policies. The General Plan includes the following policies applicable to biological resources that are relevant to the proposed off-site improvements in San Bruno’s jurisdiction:
• 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 wild life, from destruction during new construction or redevelopment within San Bruno.
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• ERC-C: Recognize areas of overlapping jurisdiction with respect to open space and environmental resources, and coordinate the City of San Bruno’s actions with efforts of surrounding cities, agencies, and San Mateo County.
• 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 of San Bruno’s control.
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. 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 can yon areas is sensitive to the natural environment. Preserve the natural topography and vegetation. • 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.
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 dripline 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 ERC-13 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-14: Preserve wetlands habitat and associated species in compliance with the federal “no net loss” policy using mitigation measures such as:
o Avoidance of sensitive habitat areas;
o Clustering of development away from wetlands;
o Transfer of development rights for preservation of existing sensitive lands; and/or o 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. If no special status species are detected during these surveys, then construction- City of South San Francisco
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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, 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.
San Bruno Municipal Code
Chapter 8.24, Street Trees and Other Plantings, and Chapter 8.25, Heritage Trees, in Title 8, Streets, Sidewalks, and Rights-of-Way, of the San Bruno Municipal Code concern the preservation of trees.
Chapter 8.24 provides a plan to regulate the planting and maintenance of trees and other plantings in and along the public streets, ways, and public easements within San Bruno and to provide for orderly development and promote the health, safety, comfort, and general welfare of the public. (Ordinance 1668, Section 2, 2002). Chapter 8.25 notes that the vast majority of trees within San Bruno are located on private property, and the provisions in Chapter 8.24 for the protection of street trees are inadequate to fully protect and preserve the San Bruno’s urban forest canopy against the unregulated pruning and removal of mature trees on private property. Chapter 8.25 regulates the removal of heritage trees within San Bruno in order to retain as many trees as possible.
Protected trees, which include street trees and heritage trees, are defined by San Bruno Municipal Code, Title 8, as follows:
• Street tree: any tree planted after the adoption of Ordinance No. 1320 within any street, right-ofway, or easement adjacent thereto. (Ordinance 1320, Section 1, 1979 [prior code: Sections 25-
2.1–25-2.6]). The director of public works or designee shall be solely responsible for determining whether existing trees planted in or adjacent to the public right-of-way are to be deemed official street trees for purposes of the application of this chapter; • Heritage tree:
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 6 inches or more measured 54 inches above natural grade;
2. Any tree or stand of trees designated by resolution of the San Bruno 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 10 inches or more, measured 54 inches above natural grade.
Pursuant to San Bruno Municipal Code Chapter 8.24, a permit is required prior to pruning, removal, or interference with street trees and tree stakes. Pursuant to Chapter 8.25, a permit is required for the removal or certain types of pruning of heritage trees. Protected trees cannot be removed, City of South San Francisco
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pruned, or otherwise materially altered without a permit from the City of San Bruno and must be protected from development-related impacts. Removed protected trees are required to be replaced in accordance with San Bruno Municipal Code requirements (in the case of street trees, in-lieu fees may be paid). In addition, new developments must conform to a series of tree planting requirements.
4.3.4 Impacts and Mitigation Measures
This section describes the impact analysis related to biological resources for the proposed project, including Phase 1. It describes the methods and thresholds used to determine whether an impact would be significant. Feasible measures to mitigate (i.e., avoid, minimize, rectify, reduce, eliminate, or compensate for) significant impacts accompany each impact discussion, when necessary.
4.3.4.1 Significance Criteria
Based on Appendix G of the CEQA Guidelines, the proposed project would have a significant biological resources impact if it would:
• 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 CDFW or USFWS;
• Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by CDFW or USFWS; • 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;
• 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;
• Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance;
• Conflict with the provisions of an adopted habitat conservation plan, natural community conservation plan, or other approved local, regional, or state habitat conservation plan.
4.3.4.2 Approach to Analysis
The evaluation of the proposed project’s impacts on biological resources is based on a desktop review of the following sources:
• California Natural Diversity Database6 (CNDDB) species list query for a 1-mile buffer around the project site;
6 California Department of Fish and Wildlife. 2020. California Natural Diversity Database RareFind Records Search.
RareFind Version 5. Available: https://www.wildlife.ca.gov/Data/CNDDB/Maps-and-Data. Accessed:
September 16, 2020.
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• California Native Plant Society7 species list query for the U.S. Geological Survey South San Francisco (3712264), Hunters Point (3712263), Montara Mountain (3712254), and San Mateo (3712253) 7.5-minute quadrangles;
• USFWS8 Information for Planning and Consultation (IPaC) query of the project site; • Tree Inventory of Southline, South San Francisco, CA 94080; 9 • South San Francisco General Plan;10
• San Bruno General Plan;11
• National Wetland Inventory and EPA for the identification of waters and wetlands, using existing water/wetland inventory data;12,13 and
• Aerial imagery from Google Earth (using a representative address for the project site for search purposes).
14 Buildout Scenario Studied (Office Scenario)
As discussed in Section 3.6.2.2 in Chapter 3, Project Description, of this EIR, the proposed project would allow for development of the commercial campus as either office or research-anddevelopment (R&D) uses, or a combination of both, up to a total buildout of 2,800,000 square feet.
For the purposes of program-level EIR analysis, two projected buildout scenarios were identified which would represent the reasonably foreseeable range of development expected to occur under the proposed project: the Office Scenario and the Life Sciences Scenario. Each section within Chapter 4, Environmental Setting, Impacts, and Mitigation, of this EIR analyses the buildout scenario that represents the “worst-case” scenario for the resource area being analyzed. The “worst-case” scenario is the scenario with the greatest potential to result in significant impacts.
A project’s biological resources impacts are site-specific, and analysis of the potential impacts related to special-status species, sensitive natural communities, protected wetlands, the use of a site as a wildlife corridor or nursery site, and local policies or ordinances protecting biological resources 7 California Native Plant Society. 2019. Online Inventory of Rare and Endangered Plants of California. Available:
http://cnps.site.aplus.net/cgi-bin/inv/inventory.cgi/Html?item=checkbox_9.htm. Accessed: September 16, 2020.
8 U.S. Fish and Wildlife Service. 2020. IPaC Species List. Available: https://ecos.fws.gov/ipac/. Accessed:
September 16, 2020.
9 Urban Tree Management. 2020. Tree Inventory of Southline, South San Francisco, CA 94080. May 13. 10 City of South San Francisco. 1999. City of South San Francisco General Plan, Chapter 7: Open Space and Conservation Element. Available: https://www.ssf.net/home/showdocument?id=480. Accessed: September 16, 2020.
11 City of San Bruno. 1999. San Bruno General Plan, Chapter 6: Environmental Resources & Conservation. Available:
https://www.sanbruno.ca.gov/gov/city_departments/commdev/planning_division/long_range_planning/gene ral_plan.htm. Accessed: October 8, 2020.
12 U.S. Fish and Wildlife Service. 2019. National Wetland Inventory. October 8. Available:
https://www.fws.gov/wetlands/data/Mapper.html. Accessed: September 16, 2020. 13 U.S. Environmental Protection Agency. 2020. WATERS GeoViewer. Available:
https://www.epa.gov/waterdata/waters-geoviewer. Accessed: September 16, 2020. 14 Google Earth Pro. 2018. Online research, 240 Dollar Avenue (representative address used for search purposes),
37.641463°N and -122.414340°W. Available: https://www.google.com/earth/versions/#earth-pro. Accessed:
September 16, 2020.
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is dependent on a number of factors, including the project location, the amount of existing development, the type of habitat present, the presence of trees, the type of construction disturbance and activities, and other factors. The two buildout scenarios occur on the same parcels within the Specific Plan area and off-site improvement areas, and have the same amount of existing development, type of habitat, and number of trees. While the two potential buildout scenarios are similar, the Office Scenario has the greatest building footprint (543,315 square feet versus 531,765 square feet), lot coverage (49 percent versus 46 percent), built area (2,800,000 square feet versus 2,025,050 square feet), and building height (up to 115 feet above ground level versus 113 feet).
Therefore, the Office Scenario has a slightly greater potential to result in significant impacts, specifically those related to the movement of wildlife species, including birds, and is analyzed as the “worst-case” scenario.
4.3.4.3 Impact Evaluation
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 specialstatus species in local or regional plans, policies, or regulations or by CDFW or USFWS. (Project: Less than Significant with Mitigation; Phase 1: Less than Significant with Mitigation) Project
The project site and surrounding area are characterized by dense urban development and are void of natural land cover or communities. Therefore, special-status species are not anticipated to occur on or in proximity to the project site with the exception of peregrine falcon (Falco peregrinus), roosting special-status bat species (i.e., pallid bat [Antrozous pallidus], Townsend’s big-eared bat [Corynorhinus townsendii]), and hoary bat [Lasiurus cinereus]), additional bat species protected under state law (California Fish and Game Code 4150), and resident and migratory nesting birds protected under state (California Fish and Game Code Sections 3503, 3503.5 and 3513) and federal (e.g., MBTA) laws. Peregrine falcon has additional protection under state law (California Fish and Game Code Sections 3503.5). Queries of USFWS, CDFW’s CNDDB, and the California Native Plant Society regarding species with potential to occur in the region that were considered in this analysis are included in Appendix 4.3-2 of this EIR. Additional species (other than those listed above) shown in the queries have low or no potential to occur on the project site due to lack of suitable habitat on the project site and the amount of dense urban development between potential habitat and the project site, which acts as a barrier to movement and sound.
In its response letter to the NOP (Appendix 1), CDFW noted a potential for Alameda song sparrow, a species of special concern designated by CDFW, to be present on the project site. This species is not anticipated to be present on or near the project site due to lack of habit (i.e., brackish marsh associated with pickleweed) for the species; its nearest habitat is a tidal slough located approximately 0.20 mile east of the project site. The project site is separated from this habitat by multiple paved roads, buildings, and railroad tracks, thus, the proposed project would not impact Alameda song sparrow if present in the slough.
Peregrine falcon is designated as fully protected by CDFW. Peregrine falcons normally nest in a scrape on a cliff ledge, but will also nest in snags or large vacant nests in trees and on structure City of South San Francisco
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ledges including buildings; pigeons are often favored prey around cities.15 Although nesting habitat on-site is marginal due to the moderate stature of the existing on-site trees and the one to three story16 existing buildings on the project site, the buildings and trees within and surrounding the project site may provide suitable nesting and roosting habitat for this species. In addition, open-air space in and around the project site provides foraging habitat if prey is present. The nearest CNDDB occurrence for peregrine falcon (occurrence #55) was in 2014. Although CNDDB does not disclose the exact location of the occurrence, the size of the occurrence area is approximately eight square miles and includes the project site. The CNDDB occurrence indicates the nest was located on the side of a hangar, which is a structure typically found at an airport. Thus, it is presumed the occurrence was at least 0.85 mile southeast of the project site at San Francisco International Airport.
Nonetheless, if nests of this species are present on-site or in the surrounding area, and eggs, nestlings, or nesting individuals are taken during construction activities including tree removal or building demolition, a significant impact would occur.
In addition to peregrine falcon, on-site buildings and vegetation including trees may also provide suitable nesting habitat for resident and migratory birds that are protected under state (California Fish and Game Code Sections 3503 and 3513) and federal (e.g., MBTA) laws, special-status bat species including pallid bat, Townsend’s big-eared bat, and hoary bat, and other bat species protected under state (California Fish and Game Code 4150) law. Pallid bat is designated as a species of special concern by CDFW and Townsend’s big-eared bat is a candidate for state threatened listing by CDFW. In addition, the Western Bat Working Group designates pallid bat and Townsend’s big-eared bat as “high” and hoary bat as “medium” in relation to priority for funding, planning, and conservation actions. Although there are no recent CNDDB occurrences (since 1960) of pallid bat in San Mateo County and no CNDDB occurrences of pallid bat in nearby San Francisco County, there are several presumed extant occurrences of hoary bat and Townsend’s big-eared bat in San Mateo and San Francisco counties. The nearest presumed extant CNDDB occurrence for hoary bat (#119 from 1990) overlaps with the project site, and the nearest presumed extant CNDDB occurrence for Townsend’s big-eared bat (#431 from 2011) is approximately 2.41 miles southwest of the project site. While being completely developed, the project site has moderate potential for roosting bats due to the presence of potential on-site roosting habitat and nearby foraging habitat.
Potential on-site roosting habitat for bats include the old vacant buildings and trees. Riparian woodland, orchards, and stands of mature broadleaf trees are considered potential habitat for solitary foliage-roosting bat species. Foraging habitat in proximity to the project site includes the California Golf Club of San Francisco, Golden Gate National Cemetery, Crestmoor Canyon, San Bruno Mountain State and County Park, Colma Creek, the San Francisco Bay shoreline, and San Francisco International Airport's West-of-Bayshore property. Bat occupancy of on-site structures depends on access points (e.g., building vent, opening in the roof or wall, an open window) or suitable roosting habitat under their eaves; occupancy of trees depends on tree size (usually found in large trees) and the presence of cavities. Other non-special-status bat species could also roost in structure cavities.
Construction activities including tree removal and structure demolition associated with the proposed project could impact bats resulting in take (i.e., direct mortality of adult or young, the 15 National Audubon Society. 2018. Guide to North American Birds – Peregrine Falcon. Available:
https://www.audubon.org/field-guide/bird/peregrine-falcon. Accessed: August 31, 2021. 16 The buildings on the project site are considered to be of moderate stature because peregrine falcons have only been documented to nest on larger buildings in the Bay Area, including an eight-story building in Berkeley, a 14- story building in Redwood Shores, an 18-story building in San José, and a 34-story building in San Francisco.
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destruction of active nesting sites, disturbance of nesting adults, with associated nest abandonment and/or loss of reproductive effort), which would be a significant impact if take were to occur.
On-site buildings and landscaped areas (including trees) may also provide suitable nesting habitat for resident and migratory birds that are protected by state California Fish and Game Code Sections 3503 and 3513) and federal MBTA laws. If the proposed project is implemented during the nesting season February 15–Sept 15), construction activities including tree removal and structure demolition associated with the proposed project could impact nesting birds, resulting in take (i.e., direct mortality of adult or young, the destruction of active nests, disturbance of nesting adults, with associated nest abandonment and/or loss of reproductive effort), which would be a significant impact.
Implementation of Mitigation Measure BIO-1a and Mitigation Measure BIO-1b would reduce these potentially significant impacts on peregrine falcon, special-status bat species, and nesting birds by ensuring that project activities would not significantly impact nesting special-status species or other resident or migratory birds. Therefore, this impact would be less than significant with mitigation. Because all tree removals and building demolition would be conducted during Phase 1, implementation of Mitigation Measure BIO-1b would be limited to Phase 1 and not be required in future phases since all potential bat roosting habitat (i.e., structures and trees) would be absent from the project site after completion of Phase 1.
Mitigation Measure BIO-1a: Preconstuction Nesting Bird Surveys and Buffer Areas (All Phases)
The Phase 1 applicant, and applicants of future Precise Plans, shall implement the following measures prior to the commencement of any demolition or construction activities on the project site that meet the criteria set forth below:
a. To the extent feasible, conduct initial activities, including, but not limited to, vegetation removal, tree removal, ground disturbance, building or parking lot demolition, site grading, and other construction activities which may compromise breeding birds or the success of their nests outside the nesting season (February 15–September 15). b. If construction occurs during the bird nesting season, a qualified wildlife biologist 17 shall conduct a nesting bird preconstruction survey within 14 days prior to the start of construction or demolition at areas within the project site where construction or demolition activities have not previously occurred, or after any pause in construction or demolition activities of 14 days or more in areas where construction or demolition activities have not previously occurred. The survey shall be performed within the following radii of the applicable construction area in order to locate any active nests: 100 feet for passerine species, 300 feet for raptor (birds of prey) species, and 500 feet for peregrine falcon; and shall be of those areas that constitute suitable habitat for these species.
17 The experience requirements for a “qualified biologist” shall include a minimum of 4 years of academic training and professional experience in biological sciences and related resource management activities, and a minimum of 2 years of experience conducting surveys for each species that may be present within the project site.
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c. If active nests are located during the preconstruction nesting bird survey, a qualified biologist shall determine if the schedule of construction activities could affect the active nests; if so, the following measures would apply:
1. If the qualified biologist determines that construction is not likely to affect an active nest, construction may proceed without restriction; however, a qualified biologist shall regularly monitor the nest at a frequency determined appropriate for the surrounding construction activity to confirm there is no adverse effect. Spot-check monitoring frequency would be determined on a nest-by-nest basis, considering the particular construction activity, duration, proximity to the nest, and physical barriers that may screen activity from the nest.
2. If it is determined that construction may cause abandonment of an active nest, the qualified biologist shall establish a no-disturbance buffer around the nest(s), and all project work shall halt within the buffer to avoid disturbance or destruction until a qualified biologist determines that the nest is no longer active. Typically, buffer distances are a minimum of 100 feet for passerines and 300 feet for raptors; however, the buffers may be decreased if an obstruction, such as a building, is within line-ofsight between the nest and construction.
3. Modifying nest buffer distances, allowing certain construction activities within the buffer, and/or modifying construction methods in proximity to active nests shall be approved by the qualified biologist and in coordination with the Planning Division. To the extent necessary to remove or relocate an active nest, such removal or relocation shall be coordinated with the Planning Division, and the removal or relocation shall be in compliance with the California Fish and Game Code and other applicable laws.
4. Any work that must occur within established no-disturbance buffers around active nests shall be monitored by a qualified biologist. If adverse effects in response to project work within the buffer are observed and could compromise the nest, work within the no-disturbance buffer(s) shall halt until the nest occupants have fledged.
5. Any birds that begin nesting within the project site and survey buffers amid construction activities are assumed to be habituated to construction-related or similar noise and disturbance levels. Work may proceed around these active nests subject to Measure c.2 above.
Mitigation Measure BIO-1b: Preconstuction Bat Surveys and Protection (Phase 1 Only) Prior to the demolition of the existing buildings and structures within the Specific Plan area, the Phase 1 applicant shall retain a qualified biologist to conduct a habitat assessment and implement protective measures for pallid bat, Townsend’s big-eared bat, and hoary bat, and other roosting bats, which shall include an initial daytime survey to assess the building for potential bat roosting habitat, and to look for bats and signs of bats. It is recommended that the habitat assessment be conducted by a qualified biologist at least two months and no more than six months prior to demolition activities. Qualified biologists shall have knowledge of the natural history of the species that could occur and sufficient experience determining bat occupancy and bat survey techniques. The qualified biologist shall examine both the inside and outside of the buildings and structures for potential roosting habitat, as well as routes of entry to the buildings and structures. Locations of any roosting bats, signs of bat use, and entry and exit points shall be noted and mapped on a drawing of the buildings and structures. Roost sites shall also be photographed as feasible. The methods and results of the habitat assessment and the future City of South San Francisco
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steps to be taken shall be submitted to CDFW. Recommendations received from CDFW shall be considered by the City and incorporated into future steps to be taken unless the City determines them to be infeasible. The City shall make good faith efforts to coordinate with CDFW to discuss revisions to any CDFW recommendations the City considers to be infeasible. Depending on the results of the habitat assessment, the following steps will be taken as described below. ⚫ If the buildings and structures can be adequately assessed (i.e., sufficient areas of the buildings and structures can be examined) and no habitat or limited habitat for roosting bats is present, and no signs of bat use are present, a preconstruction survey of the interior and exterior of the buildings and structures by a qualified biologist shall be conducted within 24 hours of demolition.
⚫ If moderate or high potential habitat is present but there are no signs of bat use, the Phase 1 applicant shall implement feasible measures under the guidance of a qualified biologist to exclude and/or discourage bats from using the buildings and structures as a roost site, such as sealing off entry points. Feasible measures shall be determined based on the condition of the buildings and structures. Prior to installing exclusion measures, a qualified biologist shall re-survey the buildings and structures to ensure that no bats are present. In addition, a preconstruction survey of the interior and exterior of the buildings and structures shall be conducted within 24 hours of demolition to confirm that no bats are present. ⚫ If moderate or high potential habitat is present and bats or signs of bats are observed, or if exclusion measures are not installed as described above, or the buildings or structures provide suitable habitat but could not be adequately assessed, the Phase 1 applicant shall implement the following protective measures.
Follow-up surveys shall be conducted to determine if bats are present prior to commencement of demolition. The Phase 1 applicant shall submit a survey plan (number, timing, and type of surveys) to the City and CDFW; recommendations received from CDFW shall be considered and incorporated into the plan unless the City determines them to be infeasible. If CDFW requests that the bats be identified to species, the follow-up survey(s) shall include use of night vision goggles and active acoustic monitoring using full spectrum bat detectors.
Based on the timing of demolition, the extent of bat signs and/or occupied habitat, and the species present (if determined), as determined by the qualified biologist, the biologist shall develop a bat exclusion plan to discourage or exclude bat use prior to demolition. The Phase 1 applicant shall submit the bat exclusion plan to the City and CDFW for review and approval, pursuant to Section 4150 of the Fish and Game Code.
Reasonable methods to discourage or exclude bat use may include installing exclusion measures such as one-way doors or using light or other means to deter bats from using the buildings and structures to roost, such as sealing large holes or gaps void of bats using the installation of plywood and/or metal sheeting, and/or sealing small holes or gaps void of bats using installation of expandable foam or steel wool. A preconstruction survey of the interior and exterior of the buildings and structures shall be conducted within 24 hours of demolition.
Depending on the species of bats present, the size of the bat roost, and timing of the demolition, additional protective measures may be recommended by the qualified biologist or CDFW, and may include measures listed below, which shall be undertaken by the Phase 1 applicant.
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To avoid impacts on maternity colonies or hibernating bats, the buildings and structures shall not be demolished while bats are confirmed to be present, generally between April 1 and September 15 (maternity season) and from November 1 to March 1 (hibernation). Removal of occupied roosting habitat shall only occur following the maternity season and prior to hibernation, generally between September 15 and October 31, unless exclusionary devices are first installed (as described above). Other measures, such as using lights to deter bat roosting, may be used if developed in compliance with applicable law and coordination with and approval by CDFW. Installation of exclusion devices shall occur before maternity colonies establish or after they disperse, generally from March 1–30 or September 15–October 31 to preclude bats from occupying a roost site during demolition to the extent feasible. Exclusionary devices shall only be installed by or under the supervision of a qualified biologist.
The Phase 1 applicant shall implement the following measures prior to any tree removal on the project site:
⚫ A qualified biologist shall examine trees to be removed for suitable bat roosting habitat (e.g., large tree cavities, basal hollows, loose or peeling bark, larger snags, palm trees with intact thatch) before tree removal. Trees providing suitable or potential bat habitat shall be marked with flagging and identified as potential habitat. Because of the limited timeframe for tree removal for trees containing bat habitat (i.e., September 15-October 31), the tree habitat assessment should be conducted early enough in the calendar year to provide information to the applicant and City to inform tree removal planning. The protective measures listed below shall be implemented for trees containing potential roosting habitat. o Removal or disturbance of trees providing bat roosting habitat shall be avoided between April 1 and September 15 (the maternity period) to avoid effects on pregnant females and active maternity roosts (whether colonial or solitary). o Removal of trees providing bat roosting habitat shall be conducted between September 15 and October 31, which corresponds to a time period when bats have not yet entered torpor or would be caring for nonvolant young.
o If a maternity roost is found, whether solitary or colonial, that roost shall remain undisturbed until September 15 or until a qualified biologist has determined the roost is no longer active. The qualified biologist will determine appropriate no-work buffers around roost and/or hibernaculum sites. Buffer distances may vary depending on the species and activities being conducted.
⚫ Removal of trees (between September 15 and October 31) providing suitable roosting habitat shall be monitored by qualified biologists. Trees that provide suitable habitat for bats shall be removed in a two-phase removal process conducted over two consecutive days.
In the afternoon on the first day, limbs and branches shall be removed by a tree cutter using chainsaws only. Limbs with cavities, crevices, or deep bark fissures shall be avoided, and only branches or limbs without those features shall be removed. On the second day, the remainder of the tree shall be removed. A qualified biologist shall search downed vegetation for dead and injured bats. After tree removal and monitoring completion, the biologist shall prepare a biological monitoring report, which shall be provided to the City and to CDFW. The presence of dead or injured bats that are species of special concern resulting from downed trees shall be included in the monitoring report.
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Loss of occupied roosting habitat shall be mitigated by constructing and/or installing suitable replacement habitat on-site or near the project site which shall be undertaken by the Phase 1 applicant. The roosting habitat shall be monitored by a qualified biologist to ensure it functions as intended, as set forth under a roosting habitat design and monitoring plan developed in coordination with CDFW.
Phase 1
The impact under Phase 1 would be the same as under the proposed project because all tree removals and demolition activities are planned during Phase 1. These activities could potentially harm or kill special-status bird (i.e., peregrine falcon) and bat species (i.e., pallid bat, Townsend’s big-eared bat, and hoary bat), bat species protected under state (California Fish and Game Code 4150) law, and resident and migratory nesting birds protected under state (California Fish and Game Code 3503, 3503.5, and 3513) and federal (e.g., MBTA) laws which would result in a potentially significant impact. For the reasons stated above in the project analysis, implementation of Mitigation Measure BIO-1a and Mitigation Measure BIO-1b would reduce these potentially significant impacts on special-status bird and bat species, bat species protected under California Fish and Game Code, and nesting birds protected under the MBTA and California Fish and Game Code, by ensuring that Phase 1 activities would not affect nesting special-status species, other bats, or other resident or migratory birds. Therefore, this impact under Phase 1 would be less than significant with mitigation.
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 CDFW or USFWS. (Project: No Impact; Phase 1: No Impact) Project
The project site and surrounding area are completely developed, composed entirely of industrial, warehouse, and storage facilities; surface parking lots; and roadways. No riparian habitat or other sensitive natural community is present on the project site or in the immediate vicinity. The nearest creek, Colma Creek, is 0.47 mile north of the project site, just south of North Canal Street.18,19 The creek is predominately concrete lined and, thus, has little associated riparian habitat. A tidal slough federally classified as estuarine and marine wetland located approximately 0.16 mile east of the project site has potential for pickleweed mats, a sensitive natural community.20 The project site is separated from this habitat by dense urban development, including multiple paved roads, buildings, and railroad tracks; thus, the proposed project would not affect pickleweed mats if present in the slough. Therefore, the proposed project would have no impact on riparian habitat or other sensitive natural communities. No mitigation is required. 18 U.S. Fish and Wildlife Service. 2019. National Wetland Inventory. October 8. Available:
https://www.fws.gov/wetlands/data/Mapper.html. Accessed: September 16, 2020. 19 U.S. Environmental Protection Agency. 2020. WATERS GeoViewer. Available:
https://www.epa.gov/waterdata/waters-geoviewer. Accessed: September 16, 2020. 20 U.S. Fish and Wildlife Service. 2019. National Wetland Inventory. October 8. Available:
https://www.fws.gov/wetlands/data/Mapper.html. Accessed: September 16, 2020.
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Phase 1
The impact under Phase 1 would be the same as under the proposed project because the entire project site and surrounding area are completely developed, and no riparian habitat or other sensitive natural community is present on the project site or in the immediate vicinity. Therefore, for the reasons stated above in the project analysis, Phase 1 would have no impact on riparian habitat or other sensitive natural communities. No mitigation is required.
Impact BIO-3: The project would not 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. (Project: No Impact; Phase 1: No Impact)
Project
No State or federally protected wetlands or other jurisdictional waters are present on the project site or in the immediate vicinity. The nearest federally protected wetlands in proximity to the project site are: an unnamed vegetated channel classified as riverine habitat located approximately
0.31 mile northwest of the project site, just north of South Spruce Avenue along the Centennial Way Trail; and a tidal slough classified as estuarine and marine wetland located approximately 0.16 mile east of the project site.
21 The project site is separated from these habitats by dense urban development including multiple paved roads and buildings, and would not cause any direct removal, filling, hydrological interruption, or other effects on these features. On-site runoff would not impact these wetlands as runoff is collected in the City’s storm drain system which is discharged into Colma Creek that leads to the San Francisco Bay, as discussed in Section 4.9, Hydrology and Water Quality, of this EIR. Therefore, the proposed project would have no impact on State or federally protected wetlands. No mitigation is required.
Phase 1
The impact under Phase 1 would be the same as under the proposed project because the entire project site and surrounding area are completely developed, and there are no State or federal wetlands or other jurisdictional waters present on the project site or in the immediate vicinity.
Therefore, for the reasons stated above in the project analysis, Phase 1 there would have no impact on State or federally protected wetlands. No mitigation is required.
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. (Project: Less than Significant with Mitigation; Phase 1: Less than Significant with Mitigation) Project
No wetlands or running waters are present on or within the vicinity of the project site; therefore, the proposed project would have no impact on the movement of fish species. As discussed above under Impact BIO-1, existing buildings, structures, and trees on the project site could provide nesting 21 U.S. Fish and Wildlife Service. 2019. National Wetland Inventory. October 8. Available:
https://www.fws.gov/wetlands/data/Mapper.html. Accessed: September 16, 2020.
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habitat for resident and migratory birds and bats; therefore, the proposed project has the potential to affect a native wildlife nursery site, which would be a potentially significant impact.
Implementation of Mitigation Measure BIO-1a and Mitigation Measure BIO-1b would reduce this potentially significant impact on nesting resident and migratory birds and bats by ensuring that project activities would not significantly impact the use of native wildlife nursery sites. Therefore, this impact would be less than significant with mitigation.
Wildlife corridors are described as pathways or habitat linkages that connect discrete areas of natural open space that would otherwise be separated or fragmented by topography, changes in vegetation, or natural or man-made obstacles, such as urbanization. Because the project site and surrounding area are developed, it does not connect directly to areas of natural open space. Given that the area surrounding the project site is heavily urbanized, large numbers of birds are not expected to be flying over the project site at altitudes low enough for substantial bird-strike mortality to occur. Any common urban-adapted species that currently move through the project site would continue to be able to do so during and following project construction. Notwithstanding, operation of the proposed project would include the use of new lighting and construction of buildings with potentially reflective surfaces. Although the proposed project would remove and replace existing structures, the new lighting and new surfaces could misdirect or confuse migratory birds, resulting in disruption of natural behavioral patterns and possible injury or death from exhaustion or collisions with buildings, which would be a significant impact. The potential for these types of impacts could be heightened because of the project site’s proximity to San Bruno Mountain and San Francisco Bay. Section 5.4.10 of the Specific Plan includes various exterior lighting Design Guidelines intended to minimize light intrusion that may reduce impacts to birds, including directing illumination downward, not causing glare or spillover into neighboring properties, and encouraging low voltage and low intensity lighting. Nonetheless additional mitigation is needed to further reduce the potential impact. Implementation of Mitigation Measure BIO-2a and Mitigation Measure BIO-2b would reduce potentially significant impacts on the native resident or migratory birds by ensuring that project activities would not significantly impact resident or migratory bird movement or use of the project site as a wildlife corridor. Therefore, this impact would be less than significant with mitigation.
Mitigation Measure BIO-2a: Lighting Measures to Reduce Impacts on Birds (All Phases) During design, the Phase 1 applicant and applicants of future phases shall ensure that a qualified biologist experienced with bird strikes and building/lighting design issues shall identify lighting-related recommended measures to minimize the effects of the building’s lighting on birds to. The applicant shall incorporate such measures into the building’s design and operation to the extent feasible, subject to design review and approval by the City, which may include the following and/or other measures.
a. Use strobe or flashing lights in place of continuously burning lights for obstruction lighting.
Use flashing white lights rather than continuous light, red light, or rotating beams. b. Install shields onto light sources not necessary for air traffic to direct light towards the ground.
c. Extinguish all exterior lighting (i.e., rooftop floods, perimeter spots) not required for public safety as determined by the City.
d. When interior or exterior lights must be left on at night, the operator of the buildings shall examine and adopt feasible alternatives to bright, all-night, floor-wide lighting, which may City of South San Francisco
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include installing motion-sensitive lighting, using desk lamps and task lighting, reprogramming timers, or using lower-intensity lighting. e. Windows or window treatments that reduce transmission of light out of the building shall be implemented to the extent feasible.
Mitigation Measure BIO-2b: Building Design Measures to Minimize Bird Strike Risk (All Phases)
During design, the Phase 1 applicant and applicants of future phases shall ensure that a qualified biologist experienced with bird strikes and building/lighting design issues shall identify recommended measures related to the external appearance of the building to minimize the risk of bird strikes. The applicant shall incorporate such measures into the building’s design to the extent feasible, subject to design review and approval by the City, which may include the following and/or other measures:
a. Minimize the extent of glazing.
b. Use low-reflective glass and/or patterned or fritted glass. c. Use window films, mullions, blinds, or other internal or external features to “break up” reflective surfaces rather than having large, uninterrupted areas of surfaces that reflect, and thus to a bird may not appear noticeably different from, vegetation or the sky.
Phase 1
The impact on the movement of fish species under Phase 1 would be the same as under the proposed project because there are no wetlands or running waters are present on or in the vicinity of the project site, therefore Phase 1 would have no impact on the movement of fish species. The impact to native wildlife nursery sites under Phase 1 would be the same as under the proposed project because existing structures and trees planned for removal during Phase 1 could provide nesting habitat for resident and migratory birds and bats, which would be a potentially significant impact. Implementation of Mitigation Measure BIO-1a and Mitigation Measure BIO-1b would reduce this potentially significant impact on nesting resident and migratory birds and bats by ensuring that project activities would not impede the use of native wildlife nursery sites. Therefore, this impact would be less than significant with mitigation.
The impact on wildlife corridors under Phase 1 would be the same as under the proposed project because the project site and surrounding area are developed and do not connect directly to areas of natural open space. Any common urban-adapted species that currently move through the project site would continue to be able to do so following project construction. Nonetheless, the likelihood exists for trees on the project site to be used by migratory birds for foraging and/or roosting during migration. If a substantial number of nesting migratory birds were incidentally injured or killed due to construction or operation under Phase 1, it would be a significant impact. In addition, operation under Phase 1 would include the use of new lighting and construction of buildings with potentially reflective surfaces. While the Phase 1 Precise Plan would be required to comply with Specific Plan Design Guidelines that would reduce light and glare effects, the presence of new lighting and new surfaces could misdirect or confuse migratory birds, resulting in disruption of natural behavioral patterns and possible injury or death from exhaustion or collisions with buildings, which would be a potentially significant impact. Implementation of Mitigation Measure BIO-1a, Mitigation Measure BIO-2a, and Mitigation Measure BIO-2b would reduce these potentially significant impacts on native resident or migratory birds by ensuring that Phase 1 activities would not significantly impact City of South San Francisco
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resident or migratory bird movement or use of the project site as a wildlife corridor. Therefore, for the reasons stated above in the project analysis, this impact would be less than significant with mitigation.
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. (Project: Less than Significant; Phase 1: Less than Significant)
Project
The proposed project would comply with all local policies and ordinaces protecting biological resources and is consistent with local general plan policies applicable to biological resources, including applicable policies in the South San Francisco General Plan and San Bruno General Plan, provided in Section 4.3.3.3, page 4.3-7. Local policies and ordinaces for protecting biological resources located within the City of South San Francisco include the Tree Preservation Ordinance (Chapter 13.30) in the South San Francisco Municipal Code. Local policies and ordinances for protecting biological resources located within the City of San Bruno include the Streets, Sidewalks, and Rights-of-Way Ordinance (Title 8) in the San Bruno Municipal Code, which addresses heritage trees, street trees and other plantings. A tree inventory and assessment of the Specific Plan area was performed by Urban Tree Management in May 2020.
22 A total of 162 trees were documented in the
Specific Plan area in the City of South San Francisco, two of which are protected under the City’s ordinance. The two protected trees, both blue gum (Eucalyptus globulus) with circumferences of over 75 inches when measured 54 inches above grade, are located on the east side of Maple Avenue, north of where the new Southline Avenue east–west connection road is planned. The proposed project would require the removal of all 162 trees in the Specific Plan area, including the two protected trees. Approximately 19 additional trees may be required for removal within the off-site improvement areas (approximately four trees near the South Linden Avenue and Dollar Avenue intersection in the City of South San Francisco, and approximately 15 trees near the new South Maple Avenue and Southline Avenue intersection in the cities of South San Francisco and San Bruno).
23 Tree removals in San Bruno could also involve removal of protected street trees. All tree removals are anticipated to occur during Phase 1. The Phase 1 applicant would be required to abide by all regulations specified in the South San Francisco and San Bruno municipal codes, which would require the Phase 1 applicant to obtain permits to remove protected trees, including street trees, and compensate for their removal by planting replacement trees of certain sizes and species (in the case of San Bruno street trees, in-lieu fees may be paid). Street trees removed in the City of San Bruno would require a permit in accordance with San Bruno Municipal Code Section 8.24.070, which protects street trees designated by the Director of Public Works. The proposed project would include a total of 581 new trees to be planted for a total net increase of 419 trees within the project site; a conceptual landscape plan of the Specific Plan area is provided in Figure 3-20 in Chapter 3, Project Description, of this EIR. Additional trees may be planted in the City of San Bruno in accordance with the San Bruno Municipal Code Section 8.24.070 if trees within the off-site improvement areas located in San Bruno require removal and replacement.
The proposed project would comply with local policies and ordinances for protecting biological resources, such as a tree preservation policy or ordinance, ensuring that project activities would not 22 Urban Tree Management. 2020. Tree Inventory of Southline, South San Francisco, CA 94080. May 13. 23 Aerial and street view imagery from Google Earth was used to approximate the number of trees in the off-site improvement areas.
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result in an unauthorized impact on a protected tree. Therefore, this impact would be less than significant. No mitigation measures are required.
Phase 1
The impact under Phase 1 would be the same as under the proposed project because all trees are planned for removal during Phase 1 and the Phase 1 applicant would be required to comply with all regulations specified in the South San Francisco and San Bruno municipal codes. The proposed project would plant 311 trees during Phase 1 within the Specific Plan area. Additional trees may be planted in the City of San Bruno in accordance with the San Bruno Municipal Code Section 8.24.070 if trees within the off-site improvement areas located in San Bruno require removal. To the extent applicable, Phase 1 would comply with local policies and ordinances for protecting biological resources, such as a tree preservation policy or ordinance, ensuring that Phase 1 activities would not result in an unauthorized impact on a protected tree. Therefore, for the reasons stated above in the project analysis, this impact under Phase 1 would be less than significant. No mitigation is required.
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. (Project: No Impact; Phase 1: No Impact) Project
The project site is not part of an existing habitat conservation plan (HCP), natural community conservation plan (NCCP), or any other local, regional, or state habitat conservation plan. The nearest area covered by an HCP, the San Bruno Mountain Habitat Conservation Plan, is approximately 1.65 miles north of the project site, and construction and operation of the proposed project would have no direct or foreseeable indirect effects on the area covered by that HCP.
Therefore, the proposed project would have no impact on the provisions of an adopted HCP, NCCP, or other approved local, regional, or state habitat. No mitigation is required.
Phase 1
The impact under Phase 1 would be the same as under the proposed project because the project site is not part of an existing HCP, NCCP, or any other local, regional, or state habitat conservation plan.
Therefore, for the reasons stated above in the project analysis, Phase 1 would have no impact on provisions of an adopted HCP, NCCP, or other approved local, regional, or state habitat. No mitigation is required.
4.3.4.4 Cumulative Impacts
Impact C-BIO-1: The project, inclusive of Phase 1, together with the cumulative projects identified, would not result in a cumulatively considerable contribution to significant cumulative impacts on biological resources. (Project: Less than Cumulatively Considerable with Mitigation; Phase 1: Less than Cumulatively Considerable with Mitigation) The proposed project would not modify any undeveloped habitat and would have no impact on sensitive natural communities, including riparian habitat; protected wetlands; the movement of native resident or migratory fish species; or an approved conservation plan. Therefore, the City of South San Francisco
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proposed project would not have the potential to contribute to cumulative impacts with regard to these topics.
The cumulative geographic context for other evaluated biological resources is the immediate vicinity of the project site, which is the area where construction activities, including tree removal, could potentially affect biological resources including nesting special-status bird and bat species, nesting migratory birds, and protected trees that may be present on or near the site. The cumulative projects located within approximately 0.5 mile of the project site are described in Section 4.1.6, Approach to Cumulative Impact Analysis, of this EIR and shown in Figure 4.1-1.
Similar to the project site, the majority of the sites for cumulative projects contain development with ornamental landscaping; therefore, habitat for candidate, sensitive, or special-status species is marginal. The future projects would primarily involve primarily the construction of new buildings on previously developed sites or modifications to existing buildings or infrastructure, and associated tree removals. Therefore, as with the proposed project, such development could have an impact on nesting special-status bird and bat species, nesting migratory bird species, the movement of native resident or migratory wildlife species, established native resident or migratory wildlife corridors, the use of native wildlife nursery sites, and local policies or ordinances for protecting biological resources. Cumulative impacts on these biological resources could be significant because reasonably foreseeable projects would affect or remove additional structures and trees and erect new structures. Structures and trees provide roosting and nesting habitat for special-status and migratory birds and act as potential nursery sites; new structures could affect the movement of species. However, these future projects would also be subject to the requirements of the wildlife protection laws, including CESA, MBTA, and the California Fish and Game Code, as well as wildlife protection policies and provisions in the general plans and municipal codes for the cities of South San Francisco and San Bruno. Nonetheless, cumulative impacts on these biological resources would be potentially significant because reasonably foreseeable projects could affect or remove a substantial number of structures and trees and erect new structures.
The proposed project would remove all structures and trees on the project site, and construct several new four- to seven-story buildings in the Specific Plan area. Implementation of Mitigation Measure BIO-1a, Mitigation Measure BIO-1b, Mitigation Measure BIO-2a, and Mitigation Measure BIO-2b would require pre-construction surveys for bats and nesting birds as well as building design measures to minimize lighting effects on birds and bird strike risk. Implementation of these mitigation measures would ensure that the proposed project’s contribution to cumulative impacts on nesting special-status bat and migratory bird species, the movement of native resident or migratory wildlife species, established native resident or migratory wildlife corridors, the use of native wildlife nursery sites, and local policies or ordinances for protecting biological resources would be less than cumulatively considerable. The impact would be less than cumulatively considerable with mitigation.
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4.4 Cultural Resources
4.4.1 Introduction
This section evaluates the potential impacts related to the construction and operation of the Southline Specific Plan and off-site improvements (proposed project), including the first phase of development under the Specific Plan (Phase 1), on cultural (i.e., historical and archaeological) resources. Impacts on tribal cultural resources are evaluated in Section 4.16, Tribal Cultural Resources, of this EIR, and impacts on paleontological resources are evaluated in Section 4.6, Geology and Soils, of this EIR. This section also describes existing conditions at the project site, including the Phase 1 site, as well as the regulatory framework for this analysis. The impacts of the proposed project are generally analyzed at a program level, and the impacts of Phase 1 are analyzed at a project level. Impacts resulting from implementation of the proposed project, impacts resulting from implementation of Phase 1, and cumulative impacts are described. Feasible mitigation measures, where applicable, are also described. Relevant technical documentation used in this analysis includes Department of Parks and Recreation (DPR) 523A, 523B, and 523L forms prepared for the buildings and structures within the Specific Plan area (Appendix 4.4-1) and the South San Francisco Preliminary Assessment of Potential Historic District (Potential Historic District Preliminary Assessment) prepared by ICF in August 2021 (Appendix 4.4-2).
Issues identified in response to the Notice of Preparation (NOP) (Appendix 1) were considered in preparing this analysis. No questions or concerns related to historical or archaeological resources were raised in the responses to the NOP. Comments pertaining to tribal cultural resources were received. These comments are summarized in Section 4.16, Tribal Cultural Resources, of this EIR and are included in Appendix 1.
4.4.2 Environmental Setting
This section provides a discussion of the existing conditions related to cultural resources on the project site. Due to the relationship between cultural resources and tribal cultural resources, some information presented in this discussion is also relevant to tribal cultural resources, and is referenced in Section 4.16, Tribal Cultural Resources, of this EIR.
The project site is in the Coast Ranges physiographic province, which is characterized by a series of northwest-to-southeast-trending mountain ranges and valleys. It is situated along the eastern margin of an uplifted ridge whose southern extent includes the Santa Cruz Mountains. Although the topography of the project site vicinity was largely shaped by tectonic deformation, several geologic trends during the period of human occupation have resulted in substantial sedimentary deposition and shoreline change in the vicinity. These trends include eustatic sea-level rise, which resulted in the establishment of widespread tidal flats and tidal marshes in the project site vicinity, and largescale anthropogenic landscape alterations.
4.4.2.1 Prehistoric Setting
Studies of the archaeology and prehistory of the Bay Area have been taking place since the early 20th century. Early investigators, such as Nels Nelson, Max Uhle, W.E. Schenk, and L. Loud, focused primarily on excavating the shell mounds that lined the shores of San Francisco Bay, eventually City of South San Francisco
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investigating and recording more than 425 of them. These investigations were exclusively focused on one resource type (shell mounds) and relied on informal and unsystematic methods. 1 From the
early to mid-20th century, the role of universities in local archaeological inquiry increased. With this inquiry, the focus on a wider range of resource types increased, and more rigorous and systematic methodologies were adopted. Academic research continues to play a role in archaeological inquiry in the Bay Area. With the adoption of a range of environmental and cultural resource regulations in the mid-20th century, including the National Historic Preservation Act, archaeological inquiry in the region has been increasingly driven by regulatory compliance. This work, which is performed by professionally trained and qualified archaeologists, makes up a significant portion of the prehistoric archaeological record in the Bay Area.2
The cultural chronology of the Bay Area has been summarized by numerous reviewers. 3,4,5,6,7,8 These
summaries have divided the prehistoric cultural sequence into multiple phases or periods, which are delineated by changes in regional patterns of land use, subsistence, and tool types over time. The most recent chronologies encompass a time period that ranges from around 13,500 calibrated years before present (cal BP) to around 170 cal BP. This section uses the prehistoric cultural chronology proposed by Beardsley9 to help describe patterns in prehistoric cultural development in the Bay Area. The sequence incudes four periods, which are identified below. However, these periods are academic constructs and do not necessarily reflect Native American viewpoints.
The following summary presents the prehistory of the Bay Area by the geologic time segments:
⚫ Terminal Pleistocene (13,500–11,600 cal BP)
⚫ Early Holocene (11,600–7700 cal BP)
⚫ Middle Holocene (7700–3800 cal BP)
⚫ Late Holocene (3800 cal BP onward), with further divisions of the Late Holocene based on recent data.
Terminal Pleistocene (13,500–11,600 cal BP)
Traditionally, it was thought that the earliest human inhabitants of North America were highly mobile terrestrial hunters. Commonly referred to as the Clovis, these people used intricate bone and 1 Lightfoot, K. and E. Luby. 2002. Late Holocene in the San Francisco Bay Area: Temporal Trends in the Use and Abandonment of Shell Mounds in the East Bay. In Catalysts to Complexity: The Late Holocene on the California Coast, edited by J. Erlandson and T. Jones, pp. 263-281. Institute of Archaeology, University of California, Los Angeles.
2 Morrato, M. J. 1992. CRM in California: Retrospect on 25 Years of Progress. Proceedings of the Society for California Archaeology.
3 Beardsley. 1948. Cultural Sequences in Central California archaeology. American Antiquity 14:1–28. 4 Heizer, R.F. 1941. The Direct-Historical Approach in California Archaeology. American Antiquity 7, no. 2. 5 Heizer, R. F. and F. Fenenga. 1939. Archaeological Horizons in Central California. American Anthropologist 41:378-399.
6 Lillard et al. 1939. An Introduction to the Archaeology of Central California. Sacramento Junior College, Department of Anthropology, Bulletin 2.
7 Lillard and Purves. 1936. The Archeology of the Deer Creek-Cosumnes Area. California. Sacramento Junior College, Department of Anthropology Bulletin No. 1.
8 Schenck and Dawson. 1929. Archaeology of the Northern San Joaquin Valley. University of California Publications of American Archaeology and Ethnology 25(4):289–413. 9 Beardsley. 1948. Cultural Sequences in Central California archaeology. American Antiquity 14:1–28.
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stone technology. On the West Coast of North America, Clovis assemblages are characterized by a wide but sparse distribution of isolated tools and caches, dated to between 12,800 and 12,500 BP.
10,11 However, over the last few decades, along the western coasts of North and South America, several archaeological sites and sets of human remains have been documented in island and mainland coastal contexts that date to the same period as the Clovis.12 These discoveries have forced researchers to reconsider how early humans migrated to the Americas and their land use strategies, with a greater emphasis placed on coastal environments.
In the south coastal region of California, the earliest evidence of human occupation has been found on the Channel Islands.
13 For example, in addition to the set of human remains dated to around 13,000 years ago on Santa Rosa Island, an archaeological site dating to around 11,600 cal BP has been documented on San Miguel Island. The site contains numerous fish and shellfish remains, indicating an emphasis on marine resources.14 Although no archaeological sites from earlier than 5080 BP (Stanford Man) have been documented in the San Francisco Bay Area, it is inferred that the absence of sites is largely a function of long-term trends in sea-level rise, shoreline erosion, and localized subsidence in the region,
15 which are likely to have obscured and/or destroyed early coastal sites with datable materials.
Early Holocene (11,600–7700 cal BP)
The Early Holocene landscape of central California is characterized by semi-mobile hunters and gatherers who exploited a wide range of food resources from marine, lacustrine, and terrestrial contexts.
16 However, the sample of prehistoric archaeological sites in the Bay Area is limited; therefore, it most likely represents an incomplete picture of local prehistoric land use during this period.
The six dated Early Holocene sites in or near the Bay Area consist of two sites at Los Vaqueros Reservoir in the East Bay (CCO-696 and CCO-637), the Blood Alley Site (SCL-178) in the Coyote Narrows of the Santa Clara Valley, SCR-177 at Scott’s Valley in the Santa Cruz Mountains, the BART woman (SFR-28), and the Transbay Man (Cartier 1993). All of these sites were recovered from buried terrestrial contexts.
17 10 Meltzer, D. J. 2004. Peopling of North America. In Developments in Quaternary Science Volume 1, The Quaternary Period in the United States, A. R. Gillespie, S. C. Porter, and B. F. Atwater (eds.). Elsiever, Amsterdam, The Netherlands.
11 Erlandson, J. T. Rick, T. Jones, and J. Porcasi. 2007. One if by Land, Two if by Sea: Who Were the First Californians? In California Prehistory: Colonization, Culture, and Complexity, Terry L. Jones and Kathryn Klar, pp. 53-62.
Altamira Press, Walnut Creek, CA.
12 Ibid.
13 Rick, T. C., J. M. Erlandson, and R. L. Vellanoweth. 2001. Paleocoastal Marine Fishing on the Pacific Coast of the Americas: Perspectives from Daisy Cave, California. American Antiquity 66:595–614. 14 Ibid.
15 Byrd et al. 2010. Archaeological Research Design and Treatment Plan for the Transit Center District Plan Area, San Francisco, California. Prepared for R. Dean, Major Environmental Analysis, San Francisco Planning Department, San Francisco, CA.
16 Erlandson, J. T. Rick, T. Jones, and J. Porcasi. 2007. One if by Land, Two if by Sea: Who Were the First Californians? In California Prehistory: Colonization, Culture, and Complexity, Terry L. Jones and Kathryn Klar, pp. 53-62. 17 Rosenthal, Jeffrey S., and Jack Meyer. 2000. A Middle Holocene Olivella Wall-Bead Assemblage from Central California. Society for California Archaeology Newsletter 34(4):27–28.
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Middle Holocene (7700–3800 cal BP)
The Middle Holocene is characterized by a diverse range of habitation sites and artifact assemblages, suggesting higher population levels, more complex adaptive strategies, and longer seasonal occupation compared with the Early Holocene.
18 Several isolated human burials, including two on
the San Francisco Peninsula (SFR-28 and SMA-273), have also been dated to the Middle Holocene. 19 The artifact assemblages include ground stones; side-notched dart points; cobble-based chopping, scraping, and pounding implements; and shall beads and ornaments. 20,21 Type N grooved
rectangular Olivella beads are present at the San Bruno Mountain mound site (SMA-40) along the eastern edge of San Pablo Bay.
22 These beads are well dated to the Middle Holocene across a large region, from the northwestern Great Basin to San Clemente Island. They indicate the presence of an extensive regional sphere of interaction.
23,24,25
Late Holocene (3800–170 cal BP)
The Late Holocene is generally divided into the following five main time slices: Early (4500/3800– 2450 cal BP), Early-Middle Transition (2450–2050 cal BP), Middle (2050–900 cal BP), Middle-Late Transition (900–700 cal BP), and Late (700–170 cal BP).
The chronology detailed above includes sites studied from around the greater Bay Area. Although this information in indeed helpful, a closer, more detailed look at the archaeology of the San Francisco Peninsula will inform the current study. By understanding past investigations and the larger context, areas where further data is needed can be identified.
There are more than 200 documented Late Holocene sites in the Bay Area. The Early Period of the Late Holocene marks the establishment of a number of large shell mounds. Several prominent sites along the bay margins, including University Village (SMA-77) and the San Bruno Mound (SMA-40), 18 Byrd et al. 2010. Archaeological Research Design and Treatment Plan for the Transit Center District Plan Area, San Francisco, California. Prepared for R. Dean, Major Environmental Analysis, San Francisco Planning Department, San Francisco, CA.
19 Ibid.
20 Fitzgerald. 1993. Archaic Milling Cultures of the Southern San Francisco Bay Region. Edited by Gary S. Breschni and Trudy Haversat. Coyote Press Archives of California Prehistory, No. 35. Coyote Press, Salinas, CA. 21 Meyer and Rosenthal. 1998. An Archaeological Investigation of Artifacts and Human Remains from CA-CCO-637, Los Vaqueros APE, Contra Costa County, California. Anthropological Studies Center, Sonoma State University Academic Foundation, Rohnert Park, CA. Submitted to the Contra Costa Water District, Concord, CA. Copies available from Northwest Information Center, Department of Anthropology, Sonoma State University, Rohnert Park, CA.
22 Clark, M. R. 1998. Evaluative Archaeological Investigations at the San Bruno Mountain Mound Site, CA-SMA-40, South San Francisco, California. Holman and Associates, San Francisco. Submitted to Terrabay Development.
Copies available from the Northwest Information Center, Department of Anthropology, Sonoma State University, Rohnert Park, CA.
23 Byrd, B. and L. M. Raab. 2007. Prehistory of the Southern Bight: Models for a New Millennium. In California Prehistory: Colonization, Culture, and Complexity, Terry L. Jones and Kathryn Klar, pp. 215-228. Altamira Press, Walnut Creek, CA.
24 Vellanoweth, R. L. 2001. AMS Radiocarbon Dating and Shell Bead Chronologies: Middle Holocene Trade and Interaction in Western North America. In Journal of Archaeological Science 28:941–950. 25 Byrd et al. 2010. Archaeological Research Design and Treatment Plan for the Transit Center District Plan Area, San Francisco, California. Prepared for R. Dean, Major Environmental Analysis, San Francisco Planning Department, San Francisco, CA.
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have produced particularly early dates, including dates from the end of the Middle Holocene; 26 only
one site, SFR-4, is dated to 300 years.
27 These sites have yielded stemmed and short broad-leaf projectile points, square-based knife blades, unshaped and cylindrical mortars, and cylindrical pestles. Burials throughout the Early Period of the Late Holocene were often flexed and frequently contained grave offerings. Grave offerings often included obsidian originating east of the Sierra Nevada and from Napa County,
28 which suggests that an extensive trade network had been established by this time.
29 The Middle Period of the Late Holocene is characterized by greater settlement permanence (either sedentary or multi-seasonal occupation), mound building, and increased social complexity and ritual elaboration.
30 Some male burials yielded thousands of shell beads. Isotopic analyses of human bone and food remains indicate that terrestrial (faunal) resources were exploited more than shellfish, and the use of the acorn also increased.
31,32,33,34
4.4.2.2 Ethnographic Setting
The project site was traditionally inhabited by the Urebure people. 35 The Urebre spoke the Ramaytush
dialect of the Costanoan language. The Costanoan languages are part of the larger Utian language family, which is part of a larger language family, the Penutian language, with languages and dialects spoken by groups of Native Americans across California, Oregon, and Washington.36 The territory of the Ohlone 26 Milliken, Randall, Richard T. Fitzgerald, Mark G. Hylkema, Randy Groza, Tom Origer, David G. Bieling, Alan Leventhal, Randy S. Wiberg, Andrew Gottsfield, Donna Gillette, Viviana Bellifemine, Eric Strother, Robert Cartier, and David A. Fredrickson. 2007. Punctuated Culture Change in the San Francisco Bay Area. In California Prehistory: Colonization, Culture, and Complexity, Terry L. Jones and Kathryn Klar, pp. 99-123. Altamira Press, Walnut Creek, CA.
27 DeGeorgey, A. 2016. Archaeological Research Design and Treatment Plan (ARDTP) Van Ness Corridor Transit Improvement Project. Prepared for San Francisco Municipal Transportation Authority. 28 Hughes, R. and R. Milliken. 2007. Prehistoric Material Conveyance. Tidal Marsh, Oak Woodlands, and Cultural Fluorescence in the Southern San Francisco Bay Region. In California Prehistory: Colonization, Culture, and Complexity, Terry L. Jones and Kathryn Klar, pp. 259-272. Altamira Press, Walnut Creek, CA. 29 Byrd et al. 2010. Archaeological Research Design and Treatment Plan for the Transit Center District Plan Area, San Francisco, California. Prepared for R. Dean, Major Environmental Analysis, San Francisco Planning Department, San Francisco, CA.
30 Milliken, Randall, Richard T. Fitzgerald, Mark G. Hylkema, Randy Groza, Tom Origer, David G. Bieling, Alan Leventhal, Randy S. Wiberg, Andrew Gottsfield, Donna Gillette, Viviana Bellifemine, Eric Strother, Robert Cartier, and David A. Fredrickson. 2007. Punctuated Culture Change in the San Francisco Bay Area. In California Prehistory: Colonization, Culture, and Complexity, Terry L. Jones and Kathryn Klar, pp. 99-123. Altamira Press, Walnut Creek, CA.
31 Bartelink. 2006. Resource Intensification in Precontact Central California: A Bioarchaeological Perspective on Diet and Health Patterns among Hunter-Gatherers from the Lower Sacramento Valley and San Francisco Bay.
Ph.D. dissertation, Department of Anthropology, Texas A&M University, College Station, TX. 32 Bickel. 1978. Changing Sea Levels along the California Coast: Anthropological Implications. Journal of California Anthropology 5(1):6–20.
33 Wohlgemuth, E. 2004. The Course of Plant Food Intensification in Native Central California. Ph.D. dissertation, Department of Anthropology, University of California, Davis. 34 Byrd et al. 2010. Archaeological Research Design and Treatment Plan for the Transit Center District Plan Area, San Francisco, California. Prepared for R. Dean, Major Environmental Analysis, San Francisco Planning Department, San Francisco, CA.
35 Milliken. 1995:24. A Time of Little Choice: The Disintegration of the Tribal Culture in the San Francisco Bay Area, 1769–1810. Ballena Press Anthropological Papers 43, series editor Thomas C. Blackburn, Novato, CA. 36 Callaghan, C. A. 1967. Miwok-Coastanoan as a Subfamily of Pentutian. International Journal of American Linguistics, Vol. 33, No. 3, pp.224–227. University of Chicago Press.
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people, who were referred to as the Costanoans by the Spanish because they lived along the coast, extended from the Golden Gate to just below Carmel. They also occupied several inland valleys. 37 Land Use
At the time of contact, South San Francisco was a coastal prairie. The Urebure, a single village group, occupied the San Bruno Creek area south of San Bruno Mountain. Mission records indicate that the “Captain of San Bruno,” said to be from “Urebure and other places,” and 43 villagers were baptized at Mission San Francisco (SFR-B 35,40). By the end of 1785, the group was entirely absorbed into the mission.
38 Lands extending from the present city of Millbrae to the present city of South San Francisco were included in a Mexican land grant patented in 1826.
The Urebure fished in San Bruno and Colma Creek in winter and spring for king salmon and trout, which spawn in fresh water. The coastline would have been a prime area for beach strawberries (Fragaria chiloensis) in spring, harbor seals year-round, and oysters, abalone, and macoma in winter.
Resource Collection
As with other Ohlone tribelets, the Urebure were primarily hunters and gatherers. They hunted terrestrial game, such as mule deer, tule elk, pronged antelope, and mountain lion. Traps were set for smaller game, such as rabbit and quail. Marine resources were hunted along the shores, including sea lions and whales, which were prized for their blubber. Water fowl were a very important part of the tribal diet and trapped along the tidal marshes. Other marine resources, such as salmon, steelhead, school fish, and shellfish, including mussels, were collected and were a major dietary staple. Tule boats were used to collect both saltwater and freshwater marine resources.
The Ohlone also used a wide range of other foods, including various seeds (the growth of which was promoted by controlled burning), buckeye, berries, roots, acorns, nuts, fruits, land and sea mammals, water fowl, reptiles, and insects. The Ohlone used tule balsas for watercraft, bows and arrows, cordage, and bone and ground stone tools to procure and process their foodstuffs. 39,40,41,42
The primary trading partners of the Ohlone were most likely the Coast Miwok, Pomo groups, and Wappo. Exports from the Ohlone territory included mussels, salt, abalone shells, dried abalone, and Olivella shells.
43 37 Levy. 1978:485–486. Costanoan. In The Handbook of North American Indians Volume 8: California. Heizer, R.F., Editor. Pp. 485-495. Smithsonian Institution. Washington, D.C. 38 Milliken, R. T. 1995. A Time of Little Choice: The Disintegration of Tribal Culture in the San Francisco Bay Area, 1769–1810. Ballena Press, Menlo Park, CA.
39 Levy, R. 1978. Costanoan. In The Handbook of North American Indians Volume 8: California. Heizer, R.F., Editor.
Pp. 485-495. Smithsonian Institution. Washington, D.C.
40 Milliken, R. 1995. A Time of Little Choice: The Disintegration of Tribal Culture in the San Francisco Bay Area 1769- 1810. Ballena Press. Novato, CA.
41 Milliken, R. T. 1995. A Time of Little Choice: The Disintegration of Tribal Culture in the San Francisco Bay Area, 1769–1810. Ballena Press, Menlo Park, CA.
42 Krober, A.L. 1925. Handbook of the Indians of California. Dover Press. New York, New York. 43 Levy. 1978:488; 1991:31. Costanoan. In The Handbook of North American Indians Volume 8: California. Heizer, R.F., Editor. Pp. 485-495. Smithsonian Institution. Washington, D.C.
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Social Organization
The Ohlone were politically organized by tribelet, with each having a designated territory. A tribelet consisted of one or more villages and camps within a territory that were designated by physiographic features. Primary sources describe tribelets as small groups of people, averaging 60 to 90 individuals, that were located 3 to 5 miles apart. These groups within a territory were often linked by marriage. The office of tribelet chief, which was inherited patrilineally, could be occupied by a man or a woman. If there was no son to inherit the position, a sister or daughter would assume the position. Duties of the chief included providing for visitors, directing ceremonial activities, and leading fishing, hunting, gathering, and warfare expeditions. The chief served as the leader of a council of elders, which functioned primarily in an advisory capacity to the community.
Tribelets consisted of several households, which averaged 10 to 15 individuals and were grouped into clans and moieties. The extended family was included in these households, which were divided patrilineally. Marriage was informal, with only an exchange of a small gift from the groom’s family to the bride’s family. Marriage often occurred between neighboring tribes and was used as a means to resolve conflict. After the union, the couple was absorbed into the family group of the groom’s father. There is some ethnographic evidence of polygynous family groups, with multiple wives and their children living together. If a couple split up, the children would stay with the mother. 44,45,46
Family households would host dances, assist with inter-tribelet resource collection and land management, and come together to defend their territory. Most of the year, households shared a single village location, but at other times, groups would disperse to satellite villages. This was often for resource extraction during seasonal changes. Trade feasts were held when households found themselves with a surplus of resources and called together neighbors for a social and ceremonial gathering. These trade feasts served to redistribute wealth as well as a way for groups across different regions to socialize and trade goods.
47 As stated above, a single tribelet, comprising patrilineal family groups, would occupy a village location at different times of the year. Ohlone villages in the Late Period of the Late Holocene typically had four types of structures. Dwellings were generally domed structures with central hearths. They were thatched with tule, grass, or other vegetal material and bound with willow withes. Permanent settlements were usually placed away from the ocean shore, on high ground.
Sweathouses were used by men and women and usually located along streambanks. A sweathouse consisted of a pit that was excavated into the streambank, with a thatched portion constructed against the bank. Dance structures were circular or oval in plan and enclosed by a woven fence of brush or laurel branches, standing approximately 5 feet high. These structures would have one 44 Harrington, J. P. (cited in Levy, 1978). 1921. Chochenyo Fieldnotes. Manuscript in Survey of California Indian Languages, Department of Linguistics, University of California, Berkeley; Levy, R. 1978. Costanoan. In California, pages 486 and 487. Handbook of North American Indians, Volume 8. R. F. Heizer (ed.). Smithsonian Institution, Washington, D.C.
45 Levy. 1978:490. Costanoan. In The Handbook of North American Indians Volume 8: California. Heizer, R.F., Editor.
Pp. 485-495. Smithsonian Institution. Washington, D.C.
46 Milliken. 1995:20–23. A Time of Little Choice: The Disintegration of the Tribal Culture in the San Francisco Bay Area, 1769–1810. Ballena Press Anthropological Papers 43, series editor Thomas C. Blackburn, Novato, CA. 47 Ibid., pp. 21–24. A Time of Little Choice: The Disintegration of the Tribal Culture in the San Francisco Bay Area, 1769–1810. Ballena Press Anthropological Papers 43, series editor Thomas C. Blackburn, Novato, CA.
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doorway, with a smaller opening directly opposite. The assembly house was a thatched dome structure that was large enough to accommodate all of the inhabitants of the village. 48 From Contact to the Present
On November 4, 1769, a Spanish expedition led by Gaspàr de Portolà crossed the Coast Ranges on its way north from Monterey. This party encountered the first group of native Bay Area peoples at the village of Ssalson (near modern day San Mateo). According to Juan de Crespì, a diarist, this meeting was amicable, and the people of Ssalson took them into their village and feasted with them. 49 On August 6, 1775, the Spanish ship San Carlos sailed into San Francisco Bay and anchored between what is today Richardson Bay and Angel Island. The ship, commanded by Juan Manuel de Ayala, carried 30 men who were there to chart the bay. The Huimen, in what is modern-day Marin County, observed the ships and would eventually meet the party. Up until this point, the only Spanish expeditions the native people of the Bay Area encountered were on foot or horseback and stayed only for a couple days. The San Carlos was the first ship to sail into the San Francisco Bay; it anchored for 1 month.
50 In June 1776, almost 1 year after the San Carlos entered San Francisco Bay, an expedition arrived to establish a mission on the San Francisco Peninsula. Father Francisco Palòu led the expedition of soldiers, settlers, and missionary priests. The expedition encountered the Yelamu on June 27, 1776, near what is thought to be the seasonal village of Chutchui, slightly inland from the shore. Soon after the Spanish set up their encampment, the Yelamu were attacked by the Ssalson and fled to the coast and across the bay to the east. Soon after this incident, violence broke out between the Yelamu and the Spaniards. A Yelamu man offended a Spanish soldier by attempting to kiss his wife. This man was ordered to be arrested and flogged the same day. His two companions fled, although, the following day, they were tracked down by Spanish soldiers and one was shot. This altercation could have been a defining moment in the Spanish assertion of power over the local community. 51 Seven Spanish missions were founded in Ohlone territory from 1776 to 1797. Mission San Francisco was established within Yelamu territory. The first baptisms at the mission were of three young Yelamu men on June 24, 1776. One of the fathers noted that the Yelamu were attracted by presents and “other inducements.” By 1780, most of the Yelamu under the age of 20 were baptized at Mission San Francisco. Slowly, older married couples joined the young people. Although it did not appear to be a forcible entry into mission life, strife with neighboring tribes may have caused extenuating circumstances. Most of the young men baptized at Mission San Francisco had fathers who had been killed in fights with the Ssalson.
52 Once neophytes were inducted into mission life, there was no leaving. If newly baptized neophytes decided they wanted to return to their old way of life, they were considered runaways. Runaways were tracked down and forcibly returned to the missions. 48 Crespi. 1927. Missionary Explorer on the Pacific Coast 1769–1774. H. E. Bolton, editor and translator. Berkeley, CA: University of California Press. (Reprinted: AMS Press, New York, 1971). 49 Milliken. 1995:32. A Time of Little Choice: The Disintegration of the Tribal Culture in the San Francisco Bay Area, 1769–1810. Ballena Press Anthropological Papers 43, series editor Thomas C. Blackburn, Novato, CA. 50 Ibid., pp. 40–42. A Time of Little Choice: The Disintegration of the Tribal Culture in the San Francisco Bay Area, 1769–1810. Ballena Press Anthropological Papers 43, series editor Thomas C. Blackburn, Novato, CA. 51 Ibid., pp. 63–65. A Time of Little Choice: The Disintegration of the Tribal Culture in the San Francisco Bay Area, 1769–1810. Ballena Press Anthropological Papers 43, series editor Thomas C. Blackburn, Novato, CA. 52 Ibid., pp. 93–96. A Time of Little Choice: The Disintegration of the Tribal Culture in the San Francisco Bay Area, 1769–1810. Ballena Press Anthropological Papers 43, series editor Thomas C. Blackburn, Novato, CA.
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While living within the mission system, the Ohlone commingled with other groups, including the Esselen, Yokuts, Miwok, and Patwin. Mission life was devastating to the Ohlone population.53 By the time of secularization of the California missions, the Ohlone population numbered less than 2,000 as a result of disease, harsh living conditions, and reduced birth rates. 54 Under the Mexican government, secularization of the mission lands began in earnest in 1834. The indigenous population scattered away from the mission centers, and the few that were given rancherias from the mission lands were ill equipped to maintain or work their land. Most of the former mission land was divided among loyal Mexican subjects, and the Ohlone who chose to remain in their ancestral territory usually became squatters. Some were given jobs as manual laborers or domestic servants on Mexican ranchos or, later, American cattle ranches. During the next few decades, there was a partial return to aboriginal religious practices, particularly shamanism, and some return to food collection as a means of subsistence.55 Consequently, several multi-ethnic Indian communities (consisting of individuals of Chochenyo, Plains Miwok, Northern Valley Yokuts, Patwin, and/or Coast Miwok descent) were established in the mid-19th century within Ohlone territory.
56 Ohlone recognition and assertion began to move to the forefront during the early 20th century. Two law suits were brought against the U.S. government by the Indians of California (1928–1964) for reparation due them for the loss of traditional lands. Anthropologists, historians, and Indians were consulted regarding the nature of traditional land holding. A review of what was known about Indians in the state of California commenced. The political organizing necessary to mount this action on the part of Indians of California led to the formation of political advocacy groups throughout the state. The Ohlone participated, and a new roll of descendants was established, bringing a new focus on the community and re-evaluation of rights due its members. 57 Although they have yet to receive formal recognition from the federal government, the Ohlone are becoming increasingly organized as a political unit and have developed an active interest in preserving their ancestral heritage. In the later part of 20th century, the Galvan family of Mission San José worked closely with the American Indian Historical Society and successfully prevented destruction of a mission cemetery that lay in the path of a proposed freeway. These descendants incorporated as the Ohlone Indian Tribe and now hold title to the Ohlone Indian Cemetery in 53 Milliken. 1995. A Time of Little Choice: The Disintegration of the Tribal Culture in the San Francisco Bay Area, 1769–1810. Ballena Press Anthropological Papers 43, series editor Thomas C. Blackburn, Novato, CA. 54 Cook. 1943a. The Conflict between the California Indians and White Civilization, I: The Indian Versus the Spanish Mission. Ibero-Americana. 21. Berkeley, CA.; Cook, 1943b. The Conflict between the California Indians and White Civilization, II: The Physical and Demographic Reaction of the Non-Mission Indians in Colonial and Provincial California. Ibero-Americana. 22. Berkeley, CA. 55 Harrington, J. P. (cited in Levy, 1978). 1921. Chochenyo Fieldnotes. Manuscript in Survey of California Indian Languages, Department of Linguistics, University of California, Berkeley; Levy, R. 1978. Costanoan. In California, pages 486 and 487. Handbook of North American Indians, Volume 8. R. F. Heizer (ed.). Smithsonian Institution, Washington, D.C.
56 Levy. 1978:487. Costanoan. In The Handbook of North American Indians Volume 8: California. Heizer, R.F., Editor.
Pp. 485-495. Smithsonian Institution. Washington, D.C.. 57 Bean, L.J. 1994. The Ohlone Past and Present: Native Americans of the San Francisco Bay Region. Ballena Press.
Novato, California.
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Fremont.58 The descendants are active in maintaining their traditions and advocating for Native American issues.
4.4.2.3 Historical Setting
Industrial Origins
As part of the Mexican Governments redistribution of land, which occurred after the Spanish Period, Senor Don José Sanchez was granted Rancho Buri in 1835. This 14,639-acre rancho was located in what is today South San Francisco. Over the next 20 years, the acreage changed hands several times, until Charles Lux purchased the rancho in 1856 to graze cattle. Lux built a country home for his family and would move his cattle from the prime grazing land up to San Francisco along El Camino Real. After Lux’s death in 1890, the rancho was sold to successful Omaha meat packer Gustavus Swift, who designated the land as South San Francisco.
59 Before Swift bought the rancho, the majority of San Francisco’s meat came from within the city itself.
Butchertown was located near Islais Creek in what is today the Bay View neighborhood. 60 With
San Francisco’s population expanding exponentially, both residential communities and the health department pressured Butchertown to find a new location for its operations. Lux land appeared to be the best location—far enough away from downtown San Francisco to avoid offense and close enough to the shoreline to keep things sanitary.
61 Tanneries, wool pulleries, and fertilizer plants
popped up to take advantage of the by-products of the slaughterhouses. 62 Lux’s meatpacking business and associated industries were incorporated into Western Meat, a company headed by Swift. It was at this time that Swift began to focus on promoting the city of South San Francisco as a home for emerging industries. As a result, South San Francisco was deemed “The Industrial City.”
63,64
Steel and Manufacturing
Beginning in the mid-1890s, South San Francisco developed businesses that produced construction materials.
65 Further construction-related businesses soon emerged, such as steel and metal foundries, which supplied needed materials to San Francisco as it rebuilt following the 1906 earthquake.
66,67 In 1907, completion of the 9.8-mile-long Southern Pacific Railroad (SPRR) Bayshore Cutoff connected South San Francisco’s industrial yards to San Francisco markets to the north. 58 Yamane, Linda G. (cited in Bean, 1994). 1994. Costanoan/Ohlone. In Native America in the Twentieth Century: An Encyclopedia, pages 143 and 144. Mary B. David (ed.). Garland Publishing, Inc., New York and London; Bean, L. J. 1994. The Ohlone: Past and Present, page xxiv. Ballena Press Anthropological Papers No. 42. Ballena Press, Menlo Park, CA.
59 Blum, J. 1984. South San Francisco: The Making of an Industrial City. In California History 63(2):114–134 60 Blum, J. 1984. South San Francisco: The Making of an Industrial City. In California History 63(2):114–134 61 Blum, J. 1984. South San Francisco: The Making of an Industrial City. In California History 63(2):114–134. 62 Ibid., pp. 120–123.
63 Ibid., pp. 119–134.
64 Blum, J. 1984. South San Francisco: The Making of an Industrial City. In California History 63(2):114–134 65 Bamburg, B.L. n.d. South San Francisco Historic Preservation Survey, 1985–1986: A Comprehensive Study of History and Architecture. City of South San Francisco: CA. 66 Blum, J. 1984. South San Francisco: The Making of an Industrial City. In California History 63(2). 67 City of South San Francisco. 2020. Historic Articles: General History. Available: https://www.ssf.net/ourcity/about-south-san-francisco/history/historical-articles. Accessed: June 23, 2020.
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The Selby Smelting and Lead Company’s purchase of land on San Bruno Point raised concerns of pollution from South San Francisco landowners, prompting San Mateo County to pass an ordinance against smelting within county lines. In turn, South San Francisco incorporated in 1908, exempting the city from the ordinance and allowing heavy industrial development to rapidly expand. 68 In 1923,
it installed a sign on Signal Hill that read, “SOUTH SAN FRANCISCO, THE INDUSTRIAL CITY”; in 1929, it replaced the sign with 60-foot-high concrete letters.69 The steel, metals, and materials industries received a boost from defense spending during both world wars but particularly during World War II. In 1943, Bethlehem Steel was hiring mill helpers, hearth stockers, and yard laborers in support of the war effort at its South San Francisco plant. 70 Some non-defense–related metal and manufacturing employers, such as American Brake Shoe, saw growth as well, others, such as Poetsch & Peterson (located within the Specific Plan area, see Appendix 4.4-1), experienced difficulties because of war-time embargos on materials.
With South San Francisco’s population doubling as defense workers poured into the City, the federal government built temporary housing at several locations. The developments were cheaply constructed and densely packed. Lindenville, a 720-unit development for 4,200 people, was constructed between Victory and Railroad Avenues as a series of barracks-like row units just north of the Project site.
71,72
At the conclusion of World War II, suburbanization in California increased demand for metals, concrete, lumber, and other building materials. Vannucci Brothers Concrete Construction Company maintained a South San Francisco office (located within the Specific Plan Area, see Appendix 4.4-1) and supplied concrete for the development of California’s massive freeway system. 73 In 1955, when
Governor Goodwin Knight presented the “Man of Industry” award in front of 400 civic and industrial leaders he said, “For better or for worse, San Mateo County has made its choice for industry. You have voted to see smoke stacks rather than geraniums.”
74 However, his choice of recipient—M.W.
Reece, vice president of South San Francisco’s Reinhold Chemical Corporation—illustrated a transition away from the smoke stacks that had defined the city through the war era and toward the emergence of light industry (i.e., distribution centers, office parks, chemical suppliers), as well as distribution business connected to San Francisco International Airport, which was constructed to the east of the Project Site in 1953.
75 By the 1960s, heavy industry in South San Francisco was winding down and in1981, the Bethlehem Steel building was demolished. 76 68 Blum, J. 1984. South San Francisco: The Making of an Industrial City. In California History 63(2). 69 Bamburg, B.L. n.d. South San Francisco Historic Preservation Survey, 1985–1986: A Comprehensive Study of History and Architecture. City of South San Francisco: CA. 70 San Francisco Examiner. 1943. “Help Wanted.” July 11, p. 39. San Francisco, CA. 71 Bamburg, B.L. n.d. South San Francisco Historic Preservation Survey, 1985–1986: A Comprehensive Study of History and Architecture. City of South San Francisco: CA. 72 Kious, J. n.d. Lindenville. Available: https://www.ssf.net/our-city/about-south-san-francisco/history/historicalarticles. Accessed: June 23, 2020. 73 San Francisco Examiner. 1966. “Lawrence Vannucci at 77.” January 16, p. 56. San Francisco, CA. 74 The Times. 1955. “$75,000 Fire Razes SSF Chemical Plant.” June 12, p. 1. San Mateo, CA. 75 City of South San Francisco. 2020. Historic Articles: General History. Available: https://www.ssf.net/ourcity/about-south-san-francisco/history/historical-articles. Accessed: June 23, 2020. 76 Ibid.
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Chemical Industry
South San Francisco’s chemical industry began concurrent developing in the mid-1930s. In 1935, the South San Francisco Land and Improvement Company won out against Los Angeles County and enticed the E.I. du Pont de Nemours Company to purchase a 7-acre area on Linden Avenue to construct a varnish and lacquer plant,
77 which was completed by 1940 (within the Specific Plan area, see Appendix 4.4-1). Other chemical corporation followed suit and set up shop in South San Francisco. Following World War II, many of the light industry and chemical businesses located in Bay View continued to relocate to South San Francisco to take advantage of the large industrial yards that were newly available in the post-war era. The postwar boom brought a demand for chemical products used in consumer products such as cars, ships, and refrigerators. 78 In 1958, South
San Francisco reported a record year for industrial building permits, doubling the previous year’s number.
79 E.F. Houghton & Company opened its 300,000-square-foot manufacturing plant, laboratory, office building, and storage yard at 54 Tanforan Avenue in 1960 (within the Specific Plan area, see Appendix 4.4-1) and was soon launching a new line of aluminum lubricants. 80,81 By the
mid-1970s, E.F. Houghton & Company was hiring local chemistry and physics graduates and becoming something of an industry thought-leader, employing Gerald Loeb, the “Wizard of Wall Street,” a financial author credited with predicting the 1929 stock market crash, as a senior consultant.
82 Gamlen Chemical expanded operations in the City during the 1970s, constructing a two-story, 7,200-square-foot international headquarters building that would house its technical, customer service, and electronic data processing staff83 and later expanding its central marketing and development operations.
84 The chemical industry took a further turn in the 1970s when Robert Swanson and Dr. Herbert Boyer founded Genentech, spurring new development in the biotech and pharmaceutical industries, which would further shape the City’s future.
4.4.2.4 Existing Setting
Surrounding Area
Built Environment
Buildings and structures located adjacent to the project site include different building types and uses. The Shops at Tanforan (a retail shopping center) was built c. 1971 to the west of the project site, across South Maple Avenue in the City of San Bruno on the site of the former Tanforan Detention Camp (P-41-000207, CHL No. 934; see below for further discussion). Mixed industrial and commercial development is located north and east of the project site, with construction dates that span the 20th century. A SPRR branch line runs in a north–south alignment along South Linden Avenue and Dollar Avenue west of the project site. The tracks appear to have been constructed c. 1907; they were evaluated for historical significance in 2019 and determined to be not eligible as a 77 San Francisco Examiner. 1943. “Help Wanted.” July 11, p. 4. San Francisco, CA. 78 The Times. 1949. “DuPont Plans SSF Expansion.” April 1, p. 4. San Mateo, CA. 79 The Times. 1958. “Building in S.S.F. Heads For Record.” August 12, p. 15. San Mateo, CA. 80 The Times. 1960. “S.S.F. Opening New Company.” April 23, p. 11. San Mateo, CA. 81 The Times. 1963. “New Product for S.S.F. Firm.” August 26, p. 24. San Mateo, CA. 82 The Times. 1972a. “Companies Told to Push Negative.” April 24, p. 21. San Mateo, CA. 83 The Times. 1972b. “New Headquarters Started.” April 24, p. 21. San Mateo, CA. 84 The Times. 1975. “Gamlen Chemical Expands.” January 24, p. 25. San Mateo, CA.
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historical resource under the California Environmental Quality Act (CEQA). 85 Residential
development is located south of project site, on the south side of Tanforan Avenue, comprised of single-family homes; that area was largely constructed in the 1940s.86 As discussed in Section 4.4.2.3, Historical Setting, South San Francisco is recognized and embraced as the Industrial City, and the project area is characterized by industrial development. Although the City has not designated a historic district related to its industrial development and heritage, the potential exists for such a district to be present. Accordingly, a Potential Historic District Preliminary Assessment was prepared and is included in Appendix 4.4-2. The purpose of the Potential Historic District Preliminary Assessment is to provide sufficient information to inform the analysis in this EIR; it does not constitute a complete historic district evaluation, which would be beyond the scope of information required to evaluate the project’s potential impacts. The City retains discretion as to whether it will proceed with further analysis at a future date, unrelated to the project. To provide for conservative analysis, this EIR assumes that a potential historic district exists and concludes that the boundary of that potential district includes the Specific Plan area, as further described below.
The Potential Historic District Preliminary Assessment identifies broad parameters for the potential historic district, including a potential district area, a period of significance, and a list of typical industrial building types that may contribute to the potential district. As described and shown in Section D.1 in the Potential Historic District Preliminary Assessment (Appendix 4.4-2), the potential historic district area is expansive. Roughly 1,840 acres, it is concentrated on the east side of South San Francisco and includes the area east of U.S. 101 (including San Bruno and Oyster Points), the Lindenville Planning Sub-Area (the area of the project site), and the San Francisco International Airport area. Recognizing that the character of the potential district area varies greatly on either side of the U.S. 101 freeway, the area has been further divided into Zone 1, located west of the freeway and totaling approximately 470 acres, and Zone 2, located east of the freeway and totaling approximately 1,370 acres (refer to Figure 1 in Appendix 4.4-2). The Specific Plan area is located in Zone 1.
As shown in Figure 4.4-1, p. X, the Specific Plan area and most of the off-site improvements (not including those located in San Bruno) are within the potential district area. Eleven of the sixteen extant buildings located within the Specific Plan area meet the potential district parameters, as described below. The exact boundary, size, and number and locations of contributing properties within the potential historic district are unknown; a complete historic district evaluation would be required to identify these features. However, because the Potential Historic District Preliminary Assessment concludes that the Specific Plan area is located within the potential historic district area, the preliminary information regarding boundary and size is sufficient to evaluate the project’s potential impacts related to development in that area. The period of significance is defined as 1890- 1978. Properties that contribute to the district would exhibit physical characteristics that are typical of industrial development in the region. For further description of the potential historic district, refer to Appendix 4.4-2.
85 JRP. 2019. Southern Pacific Railroad, San Francisco to Gilroy DPRs for the FJ HSR. California High-Speed Rail Historical Architectural Survey Report: San Francisco to San Jose. 86 ParcelQuest. 2020. 160 South Linden Avenue, South San Francisco, CA 94080. Available:
https://www.parcelquest.com/. Accessed: July 1, 2020.
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Archaeological Resources
As described above in Section 4.4.2.1, Prehistoric Setting, and Section 4.4.2.2, Ethnographic Setting, the greater San Francisco Bay region has been subject to human habitation for millennia. The project site’s location in proximity to freshwater streams and the San Francisco Bay suggests a high likelihood for the presence of prehistoric resources.
To understand the level of archaeological study that has occurred in the vicinity of the project site, and to collect information regarding previously recorded archaeological resources, a records search was conducted through the Northwest Information Center (NWIC) of the California Historical Resources Information System (CHRIS) on June 16, 2020. The records search looked at previously conducted cultural resources studies and previously recorded archaeological resources both within a 0.25-mile radius of the project site. The records search identified 17 previous cultural resources studies that were conducted within 0.25 mile of the project site, including two studies within the project site. The records search concluded that there are no known cultural resources within the project site.
Three archaeological resources have been previously identified outside of the project site but within
0.25 mile, as shown in Table 4.4-1, p. 4.4-14; none of these resources have been identified as tribal cultural resources. Two of these previously identified archaeological resources, P-41-000048 (CASMA-44) and P-41-000051 (CA-SMA-47), are prehistoric shell midden sites, and one, P-41-000207, consists of the Tanforan Detention Camp.
Table 4.4-1. Previously Identified Cultural Resources within 0.25 Mile of the Project Site PNumber Trinomial Description
Evaluated for
Eligibility for
listing to the
CRHR or NRHP?
Distance
from
Project
Site
Within
Project
Site?
P-41-
000048
CA-SMA-44 Nelson shellmound 383 No 1,200 feet
northwest
No
P-41-
000051
CA-SMA-47 Nelson shellmound 386 No 550 feet
northeast
No
P-41-
000207
n/a This resource consists of the Tanforan
Detention Camp. The Tanforan
Detention Camp was one of 12
temporary detention camps in
California that were established for
the mass imprisonment of Americans
of Japanese descent, pursuant to
Executive Order 9066, February 19,
1942. Originally a racetrack, the
stables at Tanforan were converted
into makeshift homes for 8,033
California residents. The detention
center operated from April 1942 until
October 1942.
Yes; California
Registered
Landmark (No.
934)
250 feet
southwest
No
Source: Northwest Information Center (NWIC) of the California Historical Resources Information System (CHRIS), 2020.
Notes:
CRHR = California Register of Historical Resources
NRHP = National Register of Historic Places
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The Tanforan Detention Camp (non-extant) site is located approximately 250 feet southwest of the project site and was designated a California Historical Landmark in 1980 (No. 934). This landmark includes the entire property of what was once the Tanforan Racetrack. The Tanforan Racetrack operated as a detention center used to imprison Americans of Japanese descent during World War II. The detention center was operational from April to October 1942.87 The Tanforan Shopping Center, which currently occupies the site, was built in 1971. A California Historical Landmark Plaque and small garden now stand at the Tanforan Shopping Center to memorialize the site’s history.
Project Site
Built Environment
As described in the Chapter 3, Project Description, of this EIR, the 33-acre project site is comprised of the 26.5-acre Specific Plan area and the off-site improvement areas, which total 6.4 acres. The Specific Plan area is located at the intersection of South Maple Avenue and Tanforan Avenue, adjacent to the City of San Bruno. The Specific Plan area is located approximately 0.1 mile from the San Bruno Bay Area Rapid Transit (BART) station and the co-located SamTrans Transit Center, approximately 0.75 mile from the San Bruno Caltrain station, and approximately 1.5 miles from the South San Francisco Caltrain station.
The Specific Plan area occupies an irregular footprint bounded by South Maple Avenue, South Linden Avenue, Dollar Avenue, and Tanforan Avenue. It encompasses seven parcels, including Assessor’s Parcel Numbers (APNs) 014-250-090, 014-250-080, 014-250-050, 014-241-030, 014- 241-040, 014-232-030, and 014-232-050. The Specific Plan area is occupied by existing and vacant industrial uses and surface parking. Six of the parcels contain a total of 16 buildings and/or structures, 11 of which were constructed more than 45 years ago. The seventh parcel is a vacant former right-of-way that formerly contained an SPRR spur. A summary of the properties located within the Specific Plan area is included in Table 3-1 in Chapter 3, Project Description, of this EIR.
None of the buildings associated with the parcels within the Specific Plan area are included within the South San Francisco Historic Preservation Survey 1985–1986 or listed in the National Register of Historic Places (NRHP) or the California Register of Historical Resources (CRHR).
Because several of the buildings and structures on the Specific Plan area are 45 years or older, ICF completed DPR 523A, 523B, or 523L forms (Appendix 4.4-1) for each parcel to record and evaluate its historical significance and eligibility for the CRHR, as defined in Section 4.4.3.2. Based on the evaluations and analysis attached in Appendix 4.4-1, none of the buildings and structures located within the Specific Plan area individually meet CEQA’s definition of a historical resource.
However, as discussed above, the Specific Plan area is located within the potential historic district.
Applying the parameters identified in the Potential Historic District Preliminary Assessment (Appendix 4.4-2) to the buildings and structures within the Specific Plan area, eleven of the sixteen extant buildings fall within the potential district parameters. These buildings, listed in Table 4.4-2, p. 4.4-16, were originally constructed between 1890 and 1978, exhibit physical characteristics that are aligned with industrial building forms, and are located within the boundaries of the potential historic district area. Therefore, these buildings have the potential to contribute to a historic district and are considered historical resources under CEQA for purposes of analyzing the project’s potential impacts.
87 Kagawa. 1980. Site record for P-41-000207. On file at the Northwest Information Center, Rohnert Park, CA.
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Table 4.4-2. Potential Historic District Contributors within the Specific Plan Area APN Address Use Type Location on Parcel Year Built
014-250-090 30 Tanforan Ave.* Administrative office Southwest corner 1963 40 Tanforan Ave.* Industrial warehouse Center c. 1956
347 S. Maple Ave. Industrial warehouse Northeast corner c. 1965 349 S. Maple Ave. Industrial warehouse Northeast corner 1959 014-250-080 50 Tanforan Ave.* Industrial warehouse West boundary 1959 014-250-050 54 Tanforan Ave.* Industrial warehouse Center c. 1943 014-241-030 240 Dollar Ave.* Industrial factory Center c. 1943/ 1956/1965
180 Linden Ave.* Industrial warehouse West boundary 1956/1982 014-241-040 160 S. Linden Ave.* Chemical plant Southeast corner 1940/1958 160 S. Linden Ave.* Ancillary building Southeast corner c. 1940 325 S. Maple Ave. Industrial warehouse Southwest corner 1946/1957 * Property addresses marked with an asterisk symbol are located partially or fully within the Phase 1 site.
The off-site improvement areas consist of rights-of-way and easements located in the cities of South San Francisco and San Bruno, and within BART’s jurisdiction. The off-site improvement areas are developed with circulation and utility infrastructure and do not contain any buildings or structures.
No known cultural resources are located within the off-site improvement areas.
Archaeological Resources
As discussed above, the records search conducted for the project site concluded that there are no known cultural resources within the project site.
Phase 1 Site
The 11.93-acre Phase 1 site includes approximately nine existing buildings on five parcels, all of which are located within the Specific Plan area. Existing buildings that intersect partially or fully within the Phase 1 site are identified with an asterisk in Table 3-1 in Chapter 3, Project Description, of this EIR. As shown in Table 4.4-2, p.4.4-16, eight of the 11 buildings that have been identified as potential contributors to the potential historic district are located within the Phase 1 site. The Phase 1 site also includes most of the off-site improvement areas within the Project Site, with the exception of the Maple Avenue improvements north of the proposed intersection with Southline Avenue. As noted above, no buildings or structures are located within the off-site improvement areas. Additionally, no known cultural resources are located on the Phase 1 site.
Conclusion
No known archaeological resources or individual built resources are located within the project site.
Eleven of the sixteen buildings located within the Specific Plan area, eight of which are located on the Phase 1 site, have the potential to contribute to a potential historic district relating to the city’s industrial heritage, and are therefore considered historical resources under CEQA.
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4.4.3 Regulatory Framework
This section provides a summary of the cultural resources plans and policies of federal, state, and local agencies that have policy and regulatory control over the project site.
4.4.3.1 Federal
The sections below summarize the relevant federal regulations and guidelines.
National Historic Preservation Act and National Register of Historic Places Archaeological resources are protected through the National Historic Preservation Act (16 United States Code 470f), the Archaeological and Historic Preservation Act of 1974, and the Archaeological Resources Protection Act of 1979. Section 106 of the National Historic Preservation Act requires project review for effects on historical properties only when projects involve federal funding or permitting or occur on federal land; therefore, it is not applicable to discretionary actions on privately owned land at the municipal level. However, the National Historic Preservation Act establishes the NRHP, which provides a framework for resource evaluation and informs the process of determining impacts on historical resources under CEQA.
The NRHP is the nation’s official comprehensive inventory of historical resources. Administered by the National Park Service, the NRHP includes buildings, structures, sites, objects, and districts that possess historical, architectural, engineering, archaeological, or cultural significance at the national, state, or local level. Typically, a resource that is more than 50 years of age is eligible for listing in the NRHP if it meets any one of the four eligibility criteria and also retains sufficient historical integrity.
A resource less than 50 years old may be eligible if it can be demonstrated that it is of “exceptional importance” or a contributor to a historical district. NRHP criteria are defined in National Register Bulletin Number 15: How to Apply the National Register Criteria for Evaluation and listed below:
A. Properties that are associated with events that have made a significant contribution to the broad patterns of our history.
B. Properties that are associated with the lives of persons significant in our past.
C. Properties that embody the distinctive characteristics of a type, period, or method of construction; represent the work of a master; possess high artistic values; or represent a significant and distinguishable entity whose components may lack individual distinction.
D. Properties that have yielded, or may be likely to yield, information important in prehistory or history.
Properties that are listed in the NRHP, as well as properties that are formally determined to be eligible for listing in the NRHP, are automatically listed in the CRHR and, therefore, considered historical resources under CEQA.
4.4.3.2 State
California Public Resources Code and related California Register of Historical Resources Administration
Cultural resources, including archaeological and historical sites, are protected pursuant to a wide variety of state policies and regulations, as enumerated under the California Public Resources Code City of South San Francisco
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(PRC). Cultural resources are recognized as nonrenewable resources and receive additional protection under the California PRC and CEQA. The following California PRC sections are applicable to the project:
⚫ California PRC Sections 5020–5029.5 continued the former Historical Landmarks Advisory Committee as the State Historical Resources Commission. The commission oversees the administration of the CRHR and is responsible for the designation of State Historical Landmarks and Historical Points of Interest.
⚫ California PRC Sections 5079–5079.65 define the functions and duties of the Office of Historic Preservation (OHP). The OHP is responsible for the administration of federally and statemandated historic preservation programs in California and the California Heritage Fund. ⚫ California PRC Sections 5097.9–5097.991 provide protection to Native American historical and cultural resources and sacred sites and identify the powers and duties of the Native American Heritage Commission (NAHC). These sections also require notification to descendants of discoveries of Native American human remains and provide for treatment and disposition of human remains and associated grave goods. See Section 4.16, Tribal Cultural Resources, for more detail.
California Environmental Quality Act
CEQA requires projects to be assessed to determine their potential to affect historical resources.
CEQA uses the term historical resources to include buildings, sites, structures, objects, or districts, which may have historical, pre-historical, architectural, archaeological, cultural, or scientific importance. If implementation of a project would result in significant effects on historical resources, CEQA states that alternative plans or mitigation measures must be considered; however, only significant historical resources need to be addressed (14 California Code of Regulations [CCR] 15064.5, 15126.4). Therefore, before impacts and mitigation measures can be identified, the significance of historical resources must be determined.
The State CEQA Guidelines define three ways that a property may qualify as a historical resource for the purposes of CEQA review.
1. The resource is listed in or determined eligible for listing in the CRHR (as described below).
2. The resource is included in a local register of historical resources, as defined in Section 5020.1(k) of the California PRC or identified as significant in a historical resource survey meeting the requirements of Section 5024.1(g) of the California PRC, unless the preponderance of evidence demonstrates that it is not historically or culturally significant.
3. The lead agency determines the resource to be significant, as supported by substantial evidence in light of the whole record (CCR, Title 14, Division 6, Chapter 3, Section 15064.5[a]).
The CEQA Guidelines also establish the criteria for CRHR eligibility as the standard for the significance of historical resources and find that cultural resources that meet the criteria of eligibility for the CRHR are significant historical resources. A historical resource may be eligible for inclusion in the CRHR if it meets any of the following conditions:
1. The resource is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage.
2. The resource is associated with the lives of persons important in our past.
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3. The resource embodies the distinctive characteristics of a type, period, region, or method of construction or represents the work of an important creative individual or possesses high artistic values.
4. The resource has yielded, or may be likely to yield, information important in prehistory or history.
Properties that are listed in or eligible for listing in the NRHP are considered eligible for listing in the CRHR (PRC Section 5024.1[d][1]) and, thus, are significant historical resources for the purpose of CEQA. Previously unidentified and identified or known cultural resources within the project site will be evaluated per the CRHR criteria (as needed) for eligibility in order to determine if the resource is significant on a state level.
Pursuant to CEQA Guideline Section 15064.5(c)(4), a historical resource that has not been formally evaluated for eligibility for listing to a local or state register does not preclude the lead agency from assuming the resource is a historical resource as defined in Public Resources Code Sections 5020.1(j) or 5024.1.
According to CEQA, a project that may cause a substantial adverse change in the significance of a historical resource is a project that may have a significant impact on the environment (14 CCR 15064.5[b]). Under CEQA, a substantial adverse change in the significance of a resource means the physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of the historical resource would be materially impaired.
Actions that would materially impair the significance of a historical resource are any actions that would demolish or adversely alter the physical characteristics that convey the property’s historical significance and qualify it for inclusion in the CRHR or in a local register or survey that meets the requirements of PRC Sections 5020.1(k) and 5024.1(g).
Treatment of cultural resources under CEQA requires the evaluation of resources in a project’s area of potential affect, assessment of potential impacts on significant or unique resources, and development of mitigation measures for potentially significant impacts, which may include monitoring, combined with data recovery and/or avoidance.
Treatment of Human Remains
The disposition of burials falls first under the general prohibition on disturbing or removing human remains under California Health and Safety Code (CHSC) Section 7050.5. Specifically, remains suspected to be Native American are regulated under CEQA at CCR Section 15064.5(d)-(e). Public Resources Code Section 5097.98 establishes the process to be followed in the event that remains are discovered. If human remains are discovered during construction, no further disturbance to the site shall occur, and the County Coroner must be notified (CCR 15064.5 and Public Resources Code 5097.98).
Assembly Bill 52
Refer to Section 4.16, Tribal Cultural Resources, of this EIR for a description of Assembly Bill (AB) 52, which established tribal cultural resources as environmental resources under CEQA.
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Senate Bill 18
Refer to Section 4.16, Tribal Cultural Resources, of this EIR for a description of Senate Bill (SB) 18, which established tribal cultural resources as environmental resources under CEQA.
4.4.3.3 Local
South San Francisco General Plan
The 1999 South San Francisco General Plan (General Plan) provides a vision for long-range physical and economic development of the city, provides strategies and specific implementing actions, and establishes a basis for judging whether specific development proposals and public projects are consistent with City plans and policy standards. The General Plan contains an Open Space and Conservation Element, outlining policies related to a number of resource topics, including historical and cultural resources. The General Plan includes the following policies applicable to cultural resources:
⚫ Policy 7.5-G-1: Conserve historic, cultural, and archaeological resources for the aesthetic, educational, economic, and scientific contribution they make to South San Francisco’s identity and quality of life.
The General Plan also establishes several specific policies for implementation of the guiding principles of the document. Specific policies that are relevant to this project include:
⚫ Policy 7.5-I-3: Explore mechanisms to incorporate South San Francisco’s industrial heritage in historic and cultural preservation.
⚫ Policy 7.5-I-4: Ensure the protection of known archaeological resources in the city by requiring a records review for any development proposed in areas with known resources. ⚫ Policy 7.5-I-5: In accordance with state law, require the preparation of a resource mitigation plan and monitoring program by a qualified archaeologist in the event that archaeological resources are uncovered.
South San Francisco Municipal Code
Chapter 2.56,of the South San Francisco Municipal Code (Planning Commission) contains several sections that pertain to the identification and treatment of historical resources within South San Francisco. A historical resource is defined as “a structure, a natural feature, or a site which is 50 years old or older, of architectural, artistic, cultural, engineering, aesthetic, archeological, historical, political, or social significance to the citizens of the city of South San Francisco, the state, or the nation” (SSFMC Section 2.56.090, Ordinance 1440, Section 2, 2011).
Per Section 2.56.170, prior to issuance of a building permit to materially alter the exterior of a designated historical resource or issuance of a demolition permit for all or a portion of a designated historic resource, the City’s Planning Commission must issue a Certificate of Alteration. A Planning Application for a Certificate of Alteration shall be filed with the Planning Division and is subject to review by the Planning Commission.
A survey of historic properties in South San Francisco was conducted in 1985–1986 and is documented in the South San Francisco Historic Preservation Survey 1985–1986, which is considered to be the most up-to-date inventory of historical resources in the City. In addition, per City of South San Francisco
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Section 15.32.010, the 2019 California Historical Building Code was adopted by resolution as the building code for historic buildings in South San Francisco.
San Bruno Plans and Policies
As further described in Chapter 3, Project Description, of this EIR, the project proposes certain circulation and infrastructure improvements that are located within the City of San Bruno (San Bruno) but would not develop any new structures or new land uses in San Bruno. The improvements would occur on areas that are already developed with existing circulation improvements. The specific off-site improvements located within San Bruno include: constructing a new signalized intersection at Huntington Avenue/Sneath Lane/Southline Avenue/Maple Avenue; improving Huntington Avenue from Southline Avenue south to the existing BART garage intersection located west of Pacific Avenue; converting Tanforan Avenue to a cul-de-sac adjacent to Huntington Avenue; and realigning existing utilities within Huntington Avenue to conform to the proposed intersection improvements at Huntington Avenue/Southline Avenue. This section identifies and evaluates the proposed project’s consistency with relevant policies from the San Bruno General Plan related to cultural resources as related to the portions of the off-site improvements located within San Bruno’s jurisdiction. For additional discussion of the proposed project’s consistency with San Bruno land use plans and policies, refer to Section 4.10, Land Use and Planning, and Section 4.15, Transportation and Circulation.
San Bruno General Plan
The City of San Bruno 2009 General Plan outlines a vision for the long-range physical and economic development of the community through 2025. The General Plan land use designations, policies, and implementing actions will guide local officials in making decisions on private development proposals and public facilities. The City of San Bruno General Plan contains an Environmental Resources and Conservation Element, which outlines policies relating to biological resources and habitat, water quality, air quality, global climate change, historical and cultural resources, and environmental resources and conservation policies. Given that the proposed project activities located within the city of San Bruno consist of only off-site circulation and utility improvements and no structures would be affected, most San Bruno General Plan policies related to historic or cultural resources do not apply to the project.) The applicable policies include:
⚫ Guiding Policy ERC-F: Preserve and enhance historic and cultural resources within the city, particularly within the historic Downtown area.
⚫ Implementing Policy ERC-35: Develop criteria for designation of local historic or cultural resources. Designation may not be based solely on the age of a resource, but rather special qualities, detailing, people, or events associated with it. Resources may also include special signage and/or landmarks known to city residents.
⚫ Implementing Policy 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.
4.4.4 Impacts and Mitigation Measures
This section describes the impact analysis related to cultural resources for the proposed project, including Phase 1. It describes the methods and thresholds used to determine whether an impact City of South San Francisco
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would be significant. Feasible measures to mitigate (i.e., avoid, minimize, rectify, reduce, eliminate, or compensate for) significant impacts accompany each impact discussion, when necessary.
4.4.4.1 Significance Criteria
Based on Appendix G of the CEQA Guidelines, the proposed project would have a significant cultural resources impact if it would:
⚫ Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5,
⚫ Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5, or
⚫ Disturb any human remains, including those interred outside of formal cemeteries.
4.4.4.2 Approach to Analysis
The project site and surrounding area were studied to determine whether cultural resources are potentially present and, if so, the potential impacts of the proposed project on those resources.
Several methodologies were employed for the purpose of determining the potential presence of cultural resources.
Records Search
As described above in Section 4.4.2.4, Existing Setting, a records search was conducted at the NWIC.
The records search did not identify any previously recorded archaeological resources within the project site. However, three archaeological resources have been previously identified within 0.25 mile of the project site (outside of the project site area). Two of these previously identified archaeological resources, P-41-000048 (CA-SMA-44) and P-41-000051 (CA-SMA-47), consist of prehistoric shell midden sites, and one, P-41-000207, consists of the Tanforan Detention Camp, as summarized in Table 4.4-1, p. 4.4-16.
Native American Tribal Consultation
Refer to Section 4.16, Tribal Cultural Resources, of this EIR for a description of the tribal notification efforts conducted by the City of South San Francisco under existing law and pursuant to AB 52 and SB 18.
Research Summary
As described above, ICF architectural historians completed research on the buildings located within the Specific Plan area, documented under DPR 523A, 523B, or 523L forms included in Appendix
4.4-1 and the Preliminary Assessment of Potential Historic District (Appendix 4.4-2) described in Section 4.4.2.4 above, to understand the overall development of South San Francisco’s industrial history. ICF architectural historians confirmed building ages and alterations over time by compiling all available building permits for the 16 existing buildings within the Specific Plan Area. Directory information was compiled by reference librarians at the City’s public library and reviewed by ICF architectural historians to determine occupancy and ownership history over time. Additional research was conducted using available online resources such as ancestry.com, digital newspaper archives, DavidRumsey.com (historical map collection), and historicaerials.com.
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Field Survey
Because of COVID-19 restrictions, ICF architectural historians were unable to survey the project site in person. Photos of all buildings and general views within the project site were provided to ICF by the project applicant, and an online visual survey was conducted using Google Earth images.
No archaeological pedestrian survey occurred because of the developed nature of the project site.
Buildout Scenario Studied (Office Scenario)
As discussed in Section 3.6.2.2 in Chapter 3, Project Description, of this EIR, the proposed project would allow for development of the commercial campus as either office or research-anddevelopment (R&D) uses, or a combination of both, up to a total buildout of 2,800,000 square feet.
For the purposes of program-level EIR analysis, two projected buildout scenarios were identified which would represent the reasonably foreseeable range of development expected to occur under the proposed project: the Office Scenario and the Life Sciences Scenario. Each section within Chapter 4, Environmental Setting, Impacts, and Mitigation, of this EIR analyses the buildout scenario that represents the “worst-case” scenario for the resource area being analyzed. The “worst-case” scenario is the scenario with the greatest potential to result in significant impacts.
A project’s impacts to cultural resources are site-specific, and analysis of the potential impacts related to cultural resources is dependent on a number of factors, including the project location, proposed demolition, the amount of ground that would be disturbed, the type of disturbance, the potential depth of excavation, and other factors. The two buildout scenarios would occur on the same parcels so present no difference in location. Both scenarios would remove all existing uses in the Specific Plan area and would include implementation of the same off-site improvements. While the two potential buildout scenarios are similar, the Office Scenario has the greatest building footprint (543,315 square feet versus 531,765 square feet), lot coverage (49 percent versus 46 percent), and built area (2,800,000 square feet versus 2,025,050 square feet). Similarly, while both scenarios would have the same maximum depth of excavation (31 feet below grade surface), the Office Scenario would result in a greater excavation volume than the Life Sciences Scenario (688,400 cubic yards compared to 353,700 cubic yards). Therefore, the Office Scenario has a greater potential to result in significant impacts to cultural resources and is analyzed as the “worst-case” scenario.
4.4.4.3 Impact Evaluation
Impact CR-1: The project would not cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5. (Project: Less than Significant Impact with Mitigation; Phase 1: Less than Significant Impact with Mitigation) Project
The proposed project would demolish all buildings and structures within the Specific Plan area. The Specific Plan area includes seven parcels. Six of those parcels contain industrial buildings or structures that were constructed more than 45 years ago; the buildings within these parcels are evaluated for individual historical significance in the DPR forms included in Appendix 4.4-1 of this EIR. The seventh parcel once contained a Southern Pacific Railroad (SPRR) spur; however, the tracks are no longer extant. The DPR evaluations concluded that no extant buildings within the Specific Plan area meet the criteria for individual listing in the CRHR and thus do not qualify as individual historical resources under CEQA. Therefore, the proposed project would not cause a substantial City of South San Francisco
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adverse change to any individual buildings or structures that qualify as historical resources within the Specific Plan area.
The proposed project would also construct several off-site circulation and infrastructure improvements in the off-site improvement areas. There are no buildings or structures in the off-site improvement areas. Furthermore, the records search results, which included a desktop visual analysis and the research and documentation included in the DPR 523L form regarding the nonextant SPRR spur (see Appendix 4.4-1) do not reveal any other individual historical resources (including archaeological resources) located within the off-site improvement areas or adjacent to the project site. Therefore, the proposed project would not cause a substantial adverse change to any individual historical resources within the off-site improvement areas.
As described in Section 4.4.2, Environmental Setting, based on preliminary assessment (see Appendix 4.4-1), the Specific Plan area is located within the boundaries of a potential historic district. A historic district qualifies as a historical resource as defined in Section 15064.5 of the CEQA Guidelines, so analysis is included here for purposes of analyzing the project’s potential impacts to cultural resources. Eleven of the buildings within the Specific Plan area, eight of which are located on the Phase 1 site, appear to contribute to the potential historic district based on the criteria defined under Appendix 4.4-1; under the proposed project, all eleven buildings would be demolished to allow for new development within the Specific Plan area. It is possible that further research could reveal that the potential district is able to maintain and convey its significance without these properties, but because the full scale of the potential district is unknown at this time, it is conservatively concluded that demolition of eleven potential contributors would impair qualities that qualify the potential historic district as a CEQA historical resource. As such, this impact is considered potentially significant, and mitigation is required. Implementation of Mitigation Measure CR-1: Interpretive Signage Plan, described below, would reduce the potentially significant impact to a less-than-significant level by requiring an on-site interpretive signage program, visible from a public right-of-way, that would provide public notice and awareness of the industrial history of the buildings, businesses, and products previously associated with the Specific Plan area, as well as the broader industrial history and significance of South San Francisco. Finally, because the Specific Plan area is located within a potential historic district, the new construction proposed under the project has the potential to impact the character and the setting of the potential district. The Specific Plan (Appendix 2) includes design guidelines for development within the Specific Plan area, including site design, building architecture, lighting, landscaping and signage. The design guidelines describe and illustrate the designs, concepts, and features intended to promote the high-quality development that is envisioned for the Specific Plan area. The design guidelines state that building design and materials should evoke an “Industrial Modern aesthetic that is sensitive and well suited to the surrounding architectural vernacular.” The design guidelines for commercial buildings encourage a contemporary interpretation of the existing industrial motif using glass, metal and “brick-like” materials in a rich color palette, reflecting the industrial history of the Lindenville Planning Sub-Area. The design guidelines also state that landscape elements (including planting, lighting, hardscape, etc.) within the Specific Plan area should be designed to reflect a contemporary campus setting that is compatible with the Industrial Modern building architecture and aesthetic. Through adherence to the design guidelines, proposed construction under the Specific Plan would have a less-than-significant impact on the character and the setting of the potential historic district. No mitigation is required.
In summary, the demolition of eleven buildings within the Specific Plan area would result in a potentially significant impact to a potential historic district. Implementation of Mitigation Measure City of South San Francisco
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CR-1 would reduce the potentially significant impact to historical resources to a less-thansignificant level by requiring an on-site interpretive signage program. The mitigation measure shall be implemented during Phase 1 because all proposed building demolition would occur during Phase
1. This impact would be less than significant with mitigation.
Mitigation Measure CR-1: Interpretive Signage Program (Phase 1 Only) The Phase 1 applicant shall prepare an interpretive signage plan document setting forth the process for design and installation of interpretive signage within the Specific Plan area. The interpretive signage plan shall be developed in coordination with professionals who meet the Secretary of the Interior’s Professional Qualification Standards in History or Architectural History.
The interpretive signage plan shall include details regarding the proposed locations for the signage and the design of the visual components of the interpretive historic district signage program. The interpretive signage plan does not need to include cost analysis or specifications for the fabrication or installation of the signage program.
The interpretive signage plan shall be reviewed and approved by the City of South San Francisco prior to the issuance of a demolition permit for the proposed project. No further discretionary review or approvals are anticipated to be required by the City to implement the interpretive historic district signage program. Implementation of the interpretive signage program shall include the following elements:
1. Temporary Signage: The temporary historic district interpretive signage program shall include at least one temporary marker or sign regarding South San Francisco’s industrial heritage to display within or at the perimeter of the Specific Plan area for the duration of the construction process. The temporary signage shall be installed at a location that is visible from a public right-of-way and shall include a written narrative accompanied by historic images where feasible. As needed due to construction activity, the temporary signage may be relocated to another location that meets these criteria.
2. Permanent Signage: The permanent interpretive signage program shall include a minimum of two and a maximum of four permanent interpretive markers or signs that interpret South San Francisco’s industrial heritage and include a history of the land uses previously located within the Specific Plan area. The signs shall describe the industries that operated within the Specific Plan area, such as Colorado Fuel and Iron, Poetsch & Peterson Tannery, and E. I. du Pont de Nemours, and provide a written or visual narrative that places these companies within the context of the City’s industrial development. The permanent signage shall use relevant historic photos, historic maps, and company archival materials (such as logos), to illustrate the narrative where feasible given availability and publication permissions of the images. The signs shall be located within the Specific Plan area boundary and shall be visible to both Specific Plan area tenants and the general public from a public right-of-way. No more than half of the signs may be located in lobbies, restaurants, or other public spaces that are inside buildings. The permanent signs shall be installed prior to the issuance of the first Certificate of Occupancy for Phase 1, and may be located solely within the Phase 1 area.
Phase 1
The impact under Phase 1 would be the same as that analyzed above for the proposed project because all of the proposed building demolition and the majority of the off-site improvement City of South San Francisco
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construction would occur during Phase 1. As noted in the project analysis above, implementation of Mitigation Measure CR-1 would be required during Phase 1. With implementation of this mitigation measure, the impact would be less than significant with mitigation.
Impact CR-2: The project would not cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5. (Project: Less than Significant with Mitigation; Phase 1: Less than Significant with Mitigation) Project
The proposed project would require major grading and excavation to construct the new subterranean parking garages to a depth of up to 31 feet below grade level. An estimated 1,435,737 square feet of ground area would be disturbed, requiring approximately 688,400 cubic yards of soil to be excavated.
The records search conducted at the NWIC did not identify any previously recorded archaeological resources within the project site. However, the presence of two precontact midden deposits within
0.25 mile of the project site indicates increased potential for encountering as-yet undocumented archaeological deposits during project-related ground disturbance. Although the Project Area is highly developed, much of the prior development has been occupied by office, industrial, warehousing and distribution facilities that do not include sub-levels beneath grade. Therefore, the excavation and grading activity associated with construction of the subterranean portions of the proposed project also contributes to the potential for encountering as-yet undocumented archaeological deposits during project-related ground disturbance. This impact is considered potentially significant. Implementation of Mitigation Measure CR-2a and Mitigation Measure CR2b would reduce this potentially significant impact on archaeological resources to a less-thansignificant level by ensuring that project activities would not result in the inadvertent destruction of a significant archaeological resource.
Given the relationship between archaeological resources and tribal cultural resources, the mitigation measures below would also serve to mitigate potential impacts on tribal cultural resources that could potentially be encountered during project construction. Refer to Section 4.16, Tribal Cultural Resources, of this EIR for an evaluation of the proposed project’s impacts on tribal cultural resources.
Mitigation Measure CR-2a: Cultural Resources Worker Environmental Awareness Program (All Phases)
The Phase 1 applicant and applicants of future Precise Plans shall ensure that a qualified archaeologist shall conduct Worker Environmental Awareness Program (WEAP) training for all construction personnel on the project site prior to project-related construction and ground-disturbing activities. The training shall include basic information about the types of artifacts that might be encountered during construction activities and procedures to follow in the event of a discovery. This training shall be provided for any additional personnel added to the project, even after the initiation of construction and ground-disturbing activities.
Mitigation Measure CR-2b: Halt Construction Activity, Evaluate Find, and Implement Mitigation for Archaeological and Tribal Cultural Resources (All Phases) Should a potential archaeological or tribal cultural resource be encountered during project construction activities, the construction contractor shall halt construction within 25 feet of the City of South San Francisco
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find and immediately notify the City. A qualified archaeologist, in consultation with the City, shall 1) evaluate the potential resource to determine if it meets the CEQA definition of a unique archaeological resource pursuant to Public Resources Code Section 21083.2 or a tribal cultural resource pursuant to Public Resources Code Section 21074 and 2) make recommendations about the treatment of the resource, as warranted. If the qualified archaeologist determines the find is not a unique archaeological resource, then proper recordation and identification shall be completed and construction shall continue without delay.
If the resource meets the CEQA definition of a unique archaeological resource or tribal cultural resource, it shall be avoided to the extent feasible by project construction activities to allow for preservation in place as described under CEQA Guidelines Section 15126.4 (b)(3)(A)-(B).
If avoidance is not feasible, and the resource is determined to be a unique archaeological resource, adverse effects to the resource shall be mitigated as specified by Public Resources Code Section 21083.2. This mitigation may include, but is not limited to, a thorough recording of the resource on Department of Parks and Recreation Form 523 records, or archaeological data recovery excavation. If data recovery excavation is warranted, CEQA Guidelines Section 15126.4 (b)(3)(C), which requires a data recovery plan prior to data recovery excavation, shall be followed. If avoidance is not feasible, and the resource is determined to be a tribal cultural resource, additional coordination with the appropriate California Native American tribe(s) shall be conducted in accordance with existing laws to determine appropriate mitigation, including consideration of the measures identified in Public Resources Code Section 21084.3.
Phase 1
Phase 1 would require grading or disturbing an area of approximately 740,000 square feet during construction. Phase 1 would excavate approximately 293,000 cubic yards of soil to a depth of up to 31 feet below grade level. For the reasons stated above in the project analysis, construction of Phase 1 could have the potential to encounter as-yet undocumented precontact archaeological deposits.
This impact is considered potentially significant. Implementation of Mitigation Measure CR-2a and Mitigation Measure CR-2b would reduce this potentially significant impact to archaeological resources to less than significant.
Refer to Section 4.16, Tribal Cultural Resources, of this EIR for an evaluation of Phase 1 impacts on tribal cultural resources.
Impact CR-3: The project would not disturb any human remains, including those interred outside of formal cemeteries. (Project: Less than Significant with Mitigation; Phase 1: Less than Significant with Mitigation)
Project
As stated above, no previously identified archaeological resources have been recorded within the project site. However, the presence of two precontact midden deposits within 0.25 mile of the project site indicates that there is increased potential for project-related ground disturbance to encounter as-yet undocumented archaeological deposits. Midden deposits, like the ones identified in the vicinity of the project site, often contain human remains. Therefore, for the reasons stated in Impact CR-2, construction of the proposed project has the potential to encounter as-yet undocumented precontact archaeological deposits that may contain human remains. This impact is City of South San Francisco
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considered potentially significant. Implementation of Mitigation Measure CR-2a and Mitigation Measure CR-2b, as well as Mitigation Measure CR-3, which specifies discovery procedures for human remains, would reduce this potentially significant impact on human remains to a less-thansignificant level. The impact would be less than significant with mitigation.
Mitigation Measure CR-3: Halt Construction Activity, Evaluate Remains, and Take Appropriate Action in Coordination with Native American Heritage Commission (All Phases)
In the event that human remains are uncovered during site preparation, excavation, or other construction activity, the Phase 1 applicant and applicants of future Precise Plans shall cease or ensure the ceasing of all such construction activity within a radius of 25 feet of the discovery and shall notify the San Mateo county coroner immediately. No further construction activity shall occur within this 25-foot radius until the San Mateo county coroner has evaluated the remains and has taken appropriate action in accordance with Section 5097.98 of the California Public Resources Code. Concurrently, an archaeologist shall be contacted to assess the situation and consult with the appropriate agencies. If the human remains are of Native American origin, the coroner shall notify the Native American Heritage Commission (NAHC) within 24 hours of this identification in accordance with section 5097.98 of the California Public Resources Code, and section 7050.5 of the California Health and Safety Code, as applicable. The NAHC shall identify a Most Likely Descendant (MLD) to inspect the site and provide recommendations for the proper treatment of the remains and associated grave goods. The MLD may inspect the site of the discovery and shall complete the inspection within 48 hours of notification by the NAHC.
Phase 1
For the reasons stated in the project analysis, construction of Phase 1 has the potential to encounter as-yet undocumented precontact archaeological deposits that may contain human remains. This impact is considered potentially significant. Implementation of Mitigation Measure CR-2a and Mitigation Measure CR-2b, as well as Mitigation Measure CR-3, which specifies discovery procedures for human remains, would reduce this potentially significant impact on human remains to a less-than-significant level. The impact would be less than significant with mitigation.
4.4.4.4 Cumulative Impacts
Impact C-CR-1: The Project, inclusive of Phase 1, together with the cumulative projects identified, would not result in a considerable contribution to significant cumulative impacts on historical resources. (Project: Less than Significant; Phase 1: Less than Significant) The cumulative geographic context for historical resources is the potential historic district area (see Figure 1 in Section D.1 in the Potential Historic District Assessment memo in Appendix 4.4-1). The potential district is roughly 1,840 acres and is concentrated on the east side of South San Francisco, including San Bruno and Oyster Points, the Lindenville Planning Sub-Area (the area of the project site), and the San Francisco International Airport area. The exact boundary, size, and number and locations of contributing properties within the potential historic district are unknown; a complete historic district evaluation would be required to identify these features, which is beyond the scope of this analysis for purposes of evaluating the project’s potential impacts.
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The Potential Historic District Assessment outlines broad parameters for the potential district (see Appendix 4.4-1). It is assumed that many extant properties fall within the identified parameters, and may qualify as potential historic district contributors due to the district’s large scale, the prevalence of industrial architecture in the City, and the relatively recent period of industrial development that took place in South San Francisco. Therefore, the current integrity of the potential district is assumed to be intact. A significant cumulative impact to the potential historic district would occur if enough potential contributing properties were to be demolished or altered to the point where the potential historic is unable to convey its historic significance.
Section 4.1.6, Approach to Cumulative Impact Analysis, of this EIR identifies 32 cumulative projects in the City of South San Francisco. Nearly all of the projects are located within the potential historic district area. Three projects propose the demolition or alteration of existing industrial uses.
Conservatively assuming that all of the existing industrial uses are potential contributors to the potential historic district, a total of 14 contributors to the potential historic district (including the 11 buildings that would be demolished by the proposed project) would be demolished or altered. Given the size of the potential historic district area and the number of assumed contributors, it is reasonable to assume that the potential historic district would continue to be able to convey its historic significance, and a less than significant cumulative impact would occur.
Impact C-CR-2: The Project, inclusive of Phase 1, together with the cumulative projects identified, would not result in a cumulatively considerable contribution to significant cumulative impacts on archaeological resources or human remains. (Project: Less than Cumulatively Considerable with Mitigation; Phase 1: Less than Cumulatively Considerable with Mitigation)
The cumulative geographic context for archaeological resources and human remains is the immediate vicinity of the project site, which is the area where construction activities, including ground-disturbing activities, could encounter archaeological resources and human remains that may be present on or near the site. The cumulative projects within 0.5 mile of the project site are described in Section 4.1.6, Approach to Cumulative Impact Analysis, of this EIR and shown in Figure 4.1-1.
The cumulative projects in the vicinity of the project site would be constructed on infill sites in highly disturbed areas. It is likely that the cumulative projects would be constructed on sites where the ground surface has been disturbed and/or covered with fill and gravel. Similar to the proposed project, all cumulative projects would be required to implement mitigation measures to ensure that project activities would not result in the inadvertent destruction of an archaeological resource and that discovery procedures pertaining to human remains would be implemented. Nonetheless, cumulative impacts on archaeological resources and human remains are considered potentially significant because the reasonably foreseeable projects would most likely involve ground-disturbing activities that could uncover resources related to resources that could be uncovered by the project.
Implementation of Mitigation Measure CR-2a, Mitigation Measure CR-2b, and Mitigation Measure CR-3 would ensure that the proposed project’s contribution to cumulative impacts on archaeological resources and human remains would be less than cumulatively considerable with mitigation.
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4.5 Energy
4.5.1 Introduction
This section evaluates the potential impacts related to the construction and operation of the Southline Specific Plan and off-site improvements (proposed project), including the first phase of development under the Specific Plan (Phase 1), on energy. This section also describes existing conditions at the project site, including the Phase 1 site, as well as the regulatory framework for this analysis. The impacts of the proposed project are generally analyzed at a program level, and the impacts of Phase 1 are analyzed at a project level. Impacts resulting from implementation of the proposed project, impacts resulting from implementation of Phase 1, and cumulative impacts are described. Feasible mitigation measures, where applicable, are also described. Relevant technical documentation used in this analysis includes greenhouse gas (GHG) and energy modeling files and calculations (Appendix 4.2-1).
Issues identified in response to the Notice of Preparation (NOP) (Appendix 1) were considered in preparing this analysis. No questions or concerns related to energy were raised in response to the NOP.
4.5.2 Environmental Setting
Energy resources in California include natural gas, electric, water, wind, oil, coal, solar, geothermal, and nuclear resources. Energy production and energy use both result in the depletion of nonrenewable resources, such as oil, natural gas, and coal, and emissions of pollutants.
State Energy Resources and Use
California’s diverse portfolio of energy resources produced approximately 2,408.2 trillion British thermal units (BTUs)
1 in 2018.2 Excluding offshore areas, the state ranked seventh in the nation in crude oil production in 2018 (the most recent year for which data are available), producing the equivalent of approximately 965.3 trillion BTUs.3 Other energy sources in the state include natural gas (228.9 trillion BTUs), nuclear (190.4 trillion BTUs), and biofuel (35.5 trillion BTUs).4,5,6 In addition, because of the mild Mediterranean climate and strict conservation requirements for energy efficiency, California has lower energy consumption rates than most parts of the United 1 One BTU is the amount of energy required to heat 1 pound of water by 1°F at sea level. BTU is the standard unit of energy used in the United States and based on the English system of units (foot-pound-second system). 2 U.S. Energy Information Administration. 2020a. Table P5B—Primary Energy Production Estimates, Renewable and Total Energy, in Trillion BTU, Ranked by State, 2018. Available: https://www.eia.gov/state/seds/sep_prod/ pdf/P5B.pdf. Accessed: November 3, 2020.
3 U.S. Energy Information Administration. 2020b. Table P5A—Primary Energy Production Estimates, Fossil Fuels and Nuclear Energy, in Trillion BTU, Ranked by State, 2018. Available: https://www.eia.gov/state/seds/sep_prod/pdf/ P5A.pdf. Accessed: November 3, 2020.
4 No coal production occurs in California.
5 U.S. Energy Information Administration. 2020a. Table P5B—Primary Energy Production Estimates, Renewable and Total Energy, in Trillion BTU, Ranked by State, 2018. 6 U.S. Energy Information Administration. 2020b. Table P5A—Primary Energy Production Estimates, Fossil Fuels and Nuclear Energy, in Trillion BTU, Ranked by State, 2018.
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States. According to the U.S. Energy Information Administration, California consumed approximately 7,966.6 trillion BTUs of energy in 2018.7 California’s per capita energy consumption of approximately 201.9 million BTUs is one of the lowest in the country and ranked 48th in the nation as of 2018.8
In 2018, natural gas accounted for the majority of energy consumption (2,207.4 trillion BTUs, or 28 percent), followed by gasoline (1,716.3 trillion BTUs, or 21 percent); renewable energy, including nuclear electric power, hydroelectric power, biomass, and other renewables (1,344.9 trillion BTUs, or 17 percent); distillates and jet fuel (1,260.5 trillion BTUs, or 16 percent); and interstate electricity (865.7 trillion BTUs, or 11 percent), with the remaining 7 percent coming from a variety of other sources.9 Of the natural gas consumed, industrial uses consumed approximately 37 percent, followed by residential uses (22 percent) and commercial uses (12 percent), among many other uses.10
The transportation sector consumed the greatest quantity of energy (3,170.0 trillion BTUs, or 40 percent), followed by the industrial (1,848.2 trillion BTUs, or 23 percent), commercial (1,509.2 trillion BTUs, or 19 percent), and residential (1,439.2 trillion BTUs, or 18 percent) sectors.11
Per capita energy consumption, in general, is declining because of improvements in energy efficiency and designs. However, despite this reduction in per capita energy use, the state’s total overall energy consumption (i.e., non-per capita energy consumption) is expected to grow over the next several decades as a result of increases in population, jobs, and vehicle miles traveled (VMT).
Regional Energy Resources and Use
Pacific Gas and Electric (PG&E) provides natural gas and electricity services to the vast majority of Northern California, including the City of South San Francisco and the project site. PG&E’s service area extends from Eureka to Bakersfield (north to south) and from the Sierra Nevada to the Pacific Ocean (east to west). PG&E purchases gas and power from a variety of sources, including other utility companies. It also obtains energy from power plants and natural gas fields in Northern California.
PG&E operates a grid distribution system that channels all power produced at the various generation sources into one large energy pool for distribution throughout the service territory. In addition, PG&E provides all of the natural gas and electric infrastructure in South San Francisco.
PG&E has two plan options, known as Solar Choice options, in addition to its base plan, which give customers the option of purchasing energy from solar resources. The first Solar Choice option 7 U.S. Energy Information Administration. 2020c. Table C11—Energy Consumption Estimates by End-Use Sector, Ranked by State, 2018. Available: https://www.eia.gov/state/seds/sep_sum/html/rank_use.html. Accessed:
November 3, 2020.
8 U.S. Energy Information Administration. 2020d. Table C14—Energy Consumption Estimates per Capita by EndUse Sector, Ranked by State, 2018. Available: https://www.eia.gov/state/seds/data.php?incfile=/state/seds/ sep_sum/html/rank_use_capita.html&sid=US. Accessed: November 3, 2020. 9 U.S. Energy Information Administration. 2020e. California State Energy Profile. Available: https://www.eia.gov/ state/print.php?sid=CA. Accessed: November 3, 2020.
10 U.S. Energy Information Administration. 2020f. Natural Gas Consumption by End Use—California. Available:
https://www.eia.gov/dnav/ng/ng_cons_sum_dcu_SCA_a.htm. Accessed: November 3, 2020. 11 U.S. Energy Information Administration. 2020c. Table C11—Energy Consumption Estimates by End-Use Sector, Ranked by State, 2018.
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provides up to 50 percent of a customer’s energy from solar resources, while the other option provides up to 100 percent of a customer’s energy from solar resources. In addition, Peninsula Clean Energy (PCE) is San Mateo County’s official Community Choice Aggregation electricity provider.
PCE’s power comes from a mix of sources, including solar, wind, geothermal, biomass and biowaste, and hydroelectric generation resources. PCE delivers power to its customers through existing PG&E utility infrastructure.12 PCE allows customers to choose between two different electricity product operations: ECOplus (50 percent renewable electricity sources) and ECO100 (100 percent renewable electricity sources).13
In San Mateo County, a total of approximately 214.4 million therms of natural gas were consumed in 2019 (the most recent year for which data are available). In 2019, natural gas in San Mateo County was consumed primarily by the residential sector (56 percent), followed by the non-residential sector (44 percent).14 In 2019, San Mateo County consumed a total of approximately 4,325.2 million kilowatts of electricity. In San Mateo County, electricity was consumed primarily by the nonresidential sector (64 percent), followed by the residential sector (36 percent).15 Electricity usage for different land uses varies substantially by the types of uses in a building, the types of construction materials used, and the efficiency of the electricity-consuming devices. However, energy consumption in the city of South San Francisco has generally decreased over recent years despite a growing population, as shown in the 2010–2015 data (the most recent years for which data are available).16
Table 4.5-1, p. 4.5-4, outlines PG&E’s and PCE’s power mix in 2018, compared to the power mix for the state, and Table 4.5-2, p. 4.5-5, outlines the city of South San Francisco’s electricity and natural gas consumption from 2010 to 2015.
Specific Plan Area and Phase 1 Site Energy Resources and Use As described in more detail in Chapter 3, Project Description, the project site comprises the Specific Plan area and the off-site improvement areas. The Phase 1 site includes part of the Specific Plan area and most of the off-site improvement areas. The off-site improvement areas consist of rights-of-way and easements in the cities of South San Francisco and San Bruno that are developed with circulation and utility infrastructure. The off-site improvement areas do not include any land uses that consume energy. Therefore, the existing setting discussion in the energy analysis focuses on the Specific Plan area, including the portion of the Phase 1 site located within the Specific Plan area.
The Specific Plan area, including the portion of the Phase 1 site in the Specific Plan area, currently comprises a variety of office, industrial, warehouse, and storage facilities as well as surface parking spaces. Table 4.5-3, p. 4.5-5, shows existing energy usage at the Specific Plan area, inclusive of the Phase 1 Site.
12 PCE charges each of its customers an electric delivery charge for maintenance of PG&E’s wires, infrastructure, and delivery of electricity to customers.
13 Peninsula Clean Energy. 2020. What are My Rates? Available: https://www.peninsulacleanenergy.com/forbusinesses/. Accessed: November 3, 2020. 14 California Energy Commission. n.d. Gas Consumption by County—San Mateo County 2019. Available:
https://ecdms.energy.ca.gov/gasbycounty.aspx. Accessed: November 3, 2020. 15 California Energy Commission. n.d. Electricity Consumption by County—San Mateo County 2018. Available:
https://ecdms.energy.ca.gov/elecbycounty.aspx. Accessed: November 3, 2020. 16 County of San Mateo Datahub. 2019a. County of San Mateo Performance—South San Francisco. Available:
https://performance.smcgov.org/stories/s/pii5-fvmc. Accessed: November 3, 2020.
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As stated previously, PG&E provides natural gas and electricity to the City of South San Francisco through right-of-way electric and natural gas lines. The East Grand Substation, which serves the Specific Plan area, has 115-kilovolt (kV) overhead feeds and four three-phase 115/12 kV transformer banks. Local electric distribution infrastructure around the Specific Plan area consists of 600- and 200- amp 12 kV underground and overhead distribution lines as well as secondary systems (i.e., below 600 volts). PG&E 12 kV overhead and underground radial distribution and secondary service systems are present within the Specific Plan area. Along South Maple Avenue, Tanforan Avenue, and Dollar Avenue, overhead 12 kV distribution facilities are present.17 Natural gas pipelines are located below ground in adjacent public rights-of-way. The gas transmission pipelines adjacent to U.S. 101 are approximately
0.5 mile east of the Specific Plan area.
18 Table 4.5-1. PG&E, PCE, and the State’s Power Mix in 2018 Energy Resources
PG&E
Option:
Base
Plan
PG&E
Option:
50% Solar
Choice
PG&E
Option:
100% Solar
Choice
PCE
Option:
ECOplus
PCE
Option:
ECO100
California
Power
Mix, 2018
Eligible renewable: 39% 69% 100% 51% 100% 31%
Biomass and waste 4% 2% 0% 5% 0% 2%
Geothermal 4% 2% 0% 2% 0% 5%
Small hydroelectric 3% 1% 0% 5% 0% 2%
Solar 18% 59% 100% 7% 50% 11%
Wind 10% 5% 0% 33% 50% 11%
Coal 0% 0% 0% 0% 0% 3%
Large hydroelectric 13% 6% 0% 35% 0% 11%
Natural gas 15% 7% 0% 0% 0% 35%
Nuclear 34% 17% 0% 0% 0% 9%
Other 0% 0% 0% 0% 0% < 1%
Unspecifieda 0% 0% 0% 14% 0% 11%
Total 100% 100% 100% 100% 100% 100%
Source: PG&E. 2019. Where Your Electricity Comes From. Available: https://www.pge.com/pge_global/common/ pdfs/your-account/your-bill/understand-your-bill/bill-inserts/2019/1019-Power-Content-Label.pdf. Accessed:
November 3, 2020.
PCE. 2019. 2018 Power Content Label. Available: https://www.peninsulacleanenergy.com/wp-content/uploads/ 2019/10/PCE_EV-Incentive-Program-Postcard-Series_Final.pdf. Accessed: November 3, 2020. a. Electricity from transactions that are not traceable to specific generation sources are classified as unspecified sources of power.
17 Power Design Systems. 2020. PG&E Electric/Dry Utility Planning Study. April 9, 2020. 18 U.S. Department of Transportation. n.d. NPHMS Public Viewer—Gas Transmission Pipelines, San Mateo County.
Available: https://pvnpms.phmsa.dot.gov/PublicViewer/#. Accessed: November 4, 2020.
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Table 4.5-2. Electricity and Natural Gas Consumption in the City of South San Francisco, 2010–2015 Energy Resources Electricity (kWh) Natural Gas (therms) 2010
Residential 106,482,913 9,430,667
Commercial and industrial 231,478,981 14,967,060
Total 337,961,894 24,397,727
2011
Residential 104,502,797 9,472,247
Commercial and industrial 228,863,085 15,054,584
Total 333,365,882 24,526,831
2012
Residential 103,260,746 9,208,976
Commercial and industrial 223,204,783 14,878,901
Total 326,465,529 24,087,877
2013
Residential 101,583,862 9,130,055
Commercial and industrial 217,442,565 14,529,796
Total 319,026,427 23,659,851
2014
Residential 96,370,466 7,379,210
Commercial and industrial 224,214,612 12,837,263
Total 320,585,078 20,216,473
2015
Residential 95,163,472 7,310,750
Commercial and industrial 221,831,910 13,295,230
Total 316,995,382 20,605,980
Sources: County of San Mateo Datahub. 2019a. County of San Mateo Performance—South San Francisco. Available:
https://performance.smcgov.org/stories/s/pii5-fvmc. Accessed: November 3, 2020.
County of San Mateo Datahub. 2019b. South San Francisco Energy Contribution to Greenhouse Gas Emissions, Natural Gas Consumption Bar Graph 2. Available: https://performance.smcgov.org/stories/s/pii5-fvmc. Accessed: November 3, 2020.
kWh = kilowatt-hour
Table 4.5-3. Existing Operational Energy Resource Consumption at the Specific Plan Area Energy Resources Project Site
Electricity (kWh/year) 1,606,732
Natural gas (therm/year) 59,934
Gasoline (gallons/year)a 3,151,950
Diesel (gallons/year)a 179,964
Source: CalEEMod. See Appendix 4.2-1.
kWh = kilowatt-hour
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4.5.3 Regulatory Framework
This section provides a summary of energy-related plans and policies of federal, state, and local agencies that have policy and regulatory control over the project site.
4.5.3.1 Federal
As discussed in Sections 4.2, Air Quality, and 4.7, Greenhouse Gas Emissions, of this EIR, the National Highway Traffic Safety Administration (NHTSA) sets Corporate Average Fuel Economy (CAFE) standards to improve average fuel economy (i.e., reduce fuel consumption) and reduce GHG emissions generated by cars and light-duty trucks. NHTSA and the U.S. Environmental Protection Agency (EPA) have proposed amendments to the current fuel efficiency standards for passenger cars and light-duty trucks and new standards for model years 2021 through 2026. Under the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule, current 2020 standards would be maintained through 2026. California, 22 other states, the District of Columbia, and two cities filed suit against the proposed action on September 20, 2019 (California et al. v. United States Department of Transportation et al., 1:19-cv-02826, U.S. District Court for the District of Columbia).19 The lawsuit requests a “permanent injunction prohibiting defendants from implementing or relying on the preemption regulation” but does not stay its implementation during legal deliberations. Part 1 of the SAFE Vehicles Rule went into effect on November 26, 2019, and Part 2 went into effect on March 30, 2020.20 The SAFE Vehicles Rule will decrease the stringency of CAFE standards by 1.5 percent each year through model year 2026 compared with the standards issued in 2012, which would have required about 5 percent annual increases.
4.5.3.2 State
California has adopted statewide legislation to address various aspects of climate change and GHGs, which often pertain directly or indirectly to energy resources and uses. This section focuses on state legislation that specifically mentions energy use or energy resources. For other state legislation that focuses mainly on GHG reductions and climate change, refer to Section 4.7, Greenhouse Gas Emissions, of this EIR.
Assembly Bill 1493, Pavley Rules (2002, amendments 2009)/Advanced Clean Cars (2011) Known as Pavley I, Assembly Bill (AB) 1493 provided the nation’s first GHG standards for automobiles. AB 1493 required the California Air Resources Board (CARB) to adopt vehicle standards to lower GHG emissions from automobiles and light-duty trucks to the maximum extent 19 On February 11, 2020, California et al. v. United States Department of Transportation et al. was pending resolution of the related litigation of Union of Concerned Scientists v. National Highway Traffic Safety Administration (19-1230, U.S. Court of Appeals for the District of Columba Circuit). The Union of Concerned Scientists, Environmental Defense Fund, and other groups filed a protective petition for review after the federal government sought to dismiss or transfer to the D.C. Circuit a case filed in federal court in D.C. challenging NHTSA’s final rule withdrawing California’s waiver for its GHG and zero-emission vehicle (ZEV) program and preempting state programs that regulate vehicle greenhouse gas emissions or create ZEV mandates. On February 8, 2021, the D. C. Circuit Court of Appeals issued an order holding the cases in abeyance pending regulatory review.
20 Of note, on January 20, 2021, President Biden released EO No. 13990, which, among other things, calls for agency review for Part 1 of the SAFE Vehicles Rule by April 2021, and Part 2 by July 2021. The order states that agencies shall consider whether to propose, suspend, revise, or rescind these rules.
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feasible beginning in 2009. In 2012, strengthening of the Pavley standards (referred to previously as Pavley II but now referred to as the Advanced Clean Cars measures) was adopted for vehicle model years 2017 through 2025. Together, the two standards are expected to increase average fuel economy to roughly 54.5 miles per gallon in 2025. The increase in fuel economy will help lower the demand for fossil fuels.
California Energy Efficiency Standards for Residential and Nonresidential Buildings— California Green Building Standards Code (2011), Title 24 Updates The California Green Building Standards Code (Part 11, Title 24), or CALGreen, was adopted as part of the California Building Standards Code (24 California Code of Regulations). CALGreen, which applies to the planning, design, operation, construction, use, and occupancy of newly constructed buildings, required energy- and water-efficient indoor infrastructure to be installed in all new projects, beginning January 1, 2011. CALGreen also required newly constructed building to develop a waste management plan and divert at least 50 percent of the construction materials generated during project construction.
The current Building Energy Efficiency Standards were adopted in 2019 and took effect on January 1, 2020. Under the 2019 standards, homes will use about 53 percent less energy than homes constructed under the 2016 standards, while nonresidential buildings will use about 30 percent less energy. Future standards are expected to require zero net energy for new commercial buildings.
Executive Order B-16-12 (2012)
Executive Order (EO) B-16-12 orders state entities, under the direction of the governor, including CARB, the California Energy Commission, and the California Public Utilities Commission (CPUC), to support rapid commercialization of zero-emission vehicles. It directs these entities to achieve various benchmarks related to zero-emission vehicles.
Senate Bill 350, Chapter 547, Clean Energy and Pollution Reduction Act of 2015 Senate Bill (SB) 350 (DeLeon), also known as the Clean Energy and Pollution Reduction Act of 2015, was approved by California legislature in September 2015 and signed by Governor Brown in October 2015. Its key provisions require the following by 2030: (1) a Renewables Portfolio Standard (RPS)21 of 50 percent and (2) doubling of the statewide energy efficiency savings related to natural gas and electricity end uses. In order to meet these provisions, the bill requires large utilities to develop and submit integrated resource plans that detail how the utilities will reduce GHG emissions and increase the use of clean energy resources while meeting customers’ needs.
Senate Bill 100—The 100 Percent Clean Energy Act of 2018 (2018) SB 100 builds on SB 350, the Clean Energy and Pollution Reduction Act of 2015. SB 100 increases the 2030 RPS target set in SB 350 to 60 percent and requires an RPS of 100 percent by 2045. 21 The RPS is one of California’s key programs for promoting renewable energy use within the state. The program sets forth continuous procurement of renewable energy for load-serving entities within California (California Energy Commission 2020).
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4.5.3.3 Regional
PG&E Integrated Resource Plan
PG&E adopted the 2020 Integrated Resource Plan (IRP) on September 1, 2020, to provide guidance for serving the electricity and natural gas needs of residents and businesses within its service area while fulfilling regulatory requirements. The IRP contains the following objectives that are relevant to the proposed project:
⚫ Clean Energy: In 2019, PG&E delivered nearly 30 percent of its electricity from RPS-eligible renewable resources, such as solar, wind, geothermal, biomass, and small hydropower. In addition, PG&E’s GHG-free energy production, which encompasses renewable resources, large hydropower, and nuclear, satisfied all of PG&E’s bundled retail sales in 2019. ⚫ Reliability: PG&E’s IRP analysis includes PG&E’s contribution to system and local reliability, in compliance with the CPUC’s resource adequacy requirements, especially as California transitions toward higher shares of GHG-free generation resources. ⚫ Affordability: PG&E’s IRP analysis selects resources to meet the state’s clean energy and reliability goals and provides a system average rate forecast in compliance with the CPUC’s requirements for investor-owned utilities.
PCE 2018 Integrated Resource Plan
PCE is a Community Choice Aggregation energy program that serves the entirety of San Mateo County, including the City of South San Francisco. PCE adopted the 2018 IRP 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 to 2027. The plan contains the following strategic goals that are relevant to the proposed project:
• Design a diverse power portfolio that is GHG free, as follows, o 100 percent GHG free by 2021,
o 100 percent RPS-eligible renewable energy by 2025, and o Delivering a minimum of 20 megawatts of new local power by 2025; • Stimulate development of new renewable energy projects and clean-tech innovation in San Mateo County and California through PCE’s procurement activities; and • Implement programs to reduce GHG emissions by investing in programs, such as those related to local clean power production, electric vehicles, energy efficiency, and demand response, and partnering effectively with local businesses, schools, and nonprofit organizations.
PCE meets its renewable energy requirements with a combination of RPS-eligible energy products.
According to its 2018 IRP, PCE procured enough renewable energy to meet a voluntary 50 percent target as of 2017. The proportion of PCE’s resource mix that is sourced from bundled renewable energy products will significantly increase as PCE transitions toward 100 percent renewable energy content in 2025. Based on targeted renewable energy percentages, PCE intends to significantly outpace California’s annual RPS procurement mandates throughout the 2018–2027 planning period.
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4.5.3.4 Local
As described in Chapter 3, Project Description, of this EIR, the project proposes certain circulation and infrastructure improvements that are located within the City of San Bruno, but would not include the development of any new structures or land uses within the City of San Bruno. These improvements include: constructing a new signalized intersection at Huntington Avenue/Sneath Lane/Southline Avenue/Maple Avenue; improving Huntington Avenue from Southline Avenue south to the existing BART garage intersection located west of Pacific Avenue; converting Tanforan Avenue to a cul-de-sac adjacent to Huntington Avenue; and realigning the existing storm drain main within Huntington Avenue to conform to the proposed intersection improvements at Huntington Avenue/Southline Avenue. Because the off-site improvements within the City of San Bruno’s jurisdiction would not generate a permanent demand for energy, this section does not evaluate the project’s consistency with San Bruno plans and policies related to energy.
South San Francisco General Plan
The South San Francisco 1999 General Plan provides a vision for long-range physical and economic development of the city, provides strategies and specific implementing actions, and establishes a basis for judging whether specific development proposals and public projects are consistent with the City’s plans and policy standards. The City General Plan contains an Open Space and Conservation Element, which includes policies related to air quality, GHG emissions, and energy resources. The City’s General Plan includes the following policies that are applicable to energy:
• Guiding Policy 7.3-G-3: Reduce energy use in the built environment. • Guiding Policy 7.3-G-4: Encourage land use and transportation strategies that promote the use of alternatives to the automobile for transportation, including bicycling, bus transit, and carpooling.
• Guiding Policy 7.3-G-5: Promote clean and alternative-fuel combustion in mobile equipment and vehicles.
• Implementing Policy 7.3-I-9: Promote land uses that facilitate alternative transit use, including high-density housing, mixed uses, and affordable housing served by alternative transit infrastructure.
• Implementing Policy 7.3-I-10: Facilitate energy efficiency in building regulations and streamline review processes, thereby providing the flexibility needed to achieve specified energy performance levels while requiring energy efficiency measures as appropriate. • Implementing Policy 7.3-I-13: Encourage efficient, clean energy and fuel use through collaborative programs, award programs, and incentives while removing barriers to the expansion of alternative-fuel facilities and infrastructure. • Implementing Policy 7.3-I-14: Ensure that design guidelines and standards support operation of alternative-fuel facilities, vehicles, and equipment.
Climate Action Plan
The City’s Climate Action Plan (CAP), adopted in 2014, includes goals, policies, and strategies to reduce South San Francisco’s GHG emissions, in compliance with AB 32 and SB 375. GHG reduction strategies identified in the CAP include a development checklist for identifying applicable plan City of South San Francisco
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measures pertaining to discretionary projects. The City’s CAP was adopted with the purpose of reducing GHGs community-wide and meeting the reduction target (i.e., 15 percent below 2005 emission levels by 2020). The City has identified GHG reduction measures in the transportation, energy, waste, water and wastewater, and land use sectors, which can be coupled with state and existing local actions to reduce GHG emissions. GHG emissions largely involve energy consumption (i.e., fossil-fuel usage); therefore, a reduction in GHG emissions would also equate to a reduction in energy consumption.
• The following GHG reduction measures are applicable to energy:
o Measure 1.1: Expand active transportation alternatives by providing infrastructure and enhancing connectivity for bicycle and pedestrian access. o Measure 2.1: Expand the use of alternative-fuel vehicles by, in part, requiring large-scale nonresidential developments to provide a conduit for future electric-vehicle charging installations and encouraging the installation of conduits or electric-vehicle charging stations for all new development.
o Measure 3.1: Maximize energy efficiency in the built environment through standards and the plan review process.
o Measure 4.1: Promote the installation of alternative energy facilities by, in part, (i) requiring new nonresidential conditioned space of 5,000 square feet or more to meet energy reduction standards by providing a minimum of 50 percent of the building’s electricity needs through on-site renewable energy, participating in a power purchase agreement to offset a minimum of 50 percent of modeled building electricity use, or complying with CALGreen (Title 24) Tier 2 energy efficiency requirements to exceed mandatory energy efficiency requirements by 20 percent or more and (ii) requiring all new development to install a conduit to accommodate wiring for solar.
As described in Section 4.10, Land Use and Planning, of this EIR, the City’s CAP is currently being updated as part of the update to the City General Plan. The 2014 CAP remains active until completion and adoption of the new CAP.
4.5.4 Impacts and Mitigation Measures
This section describes the impact analysis related to energy for the proposed project, including Phase 1. It describes the methods and thresholds used to determine whether an impact would be significant. Feasible measures to mitigate (i.e., avoid, minimize, rectify, reduce, eliminate, or compensate for) potentially significant impacts accompany each impact discussion, when necessary.
4.5.4.1 Significance Criteria
Based on Appendix G of the CEQA Guidelines, the proposed project would have a significant energy impact if it would:
• Result in potentially significant environmental impact due to the wasteful, inefficient, or unnecessary consumption of energy resources during project construction or operation; or • Conflict with or obstruct a state or local plan for renewable energy or energy efficiency.
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4.5.4.2 Approach to Analysis
Energy impacts associated with construction and operation of the proposed project were assessed and quantified, where applicable, using standard and accepted software tools and techniques. A summary of the methodology for calculating the project’s energy use is provided in the paragraphs below.
Appendix F of the CEQA Guidelines provides guidance for determining whether a project would result in the wasteful, inefficient, or unnecessary consumption of energy resources. As stated in Appendix F, the goal of conserving energy implies a wise and efficient use of energy; the means for achieving this goal include:
• Decreasing overall per capita energy consumption;
• Decreasing reliance on fossil fuels, such as coal, natural gas and oil; and • Increasing reliance on renewable energy sources.
Based on Appendix F, environmental considerations in the assessment of energy consumption impacts may include the following:
• The project’s energy requirements as well as its energy efficiencies by amount and fuel type for each stage of the project, including construction, operation, maintenance, and/or removal. If appropriate, the energy intensiveness of materials may be discussed; • The effects of the project on local and regional energy supplies and on requirements for additional capacity;
• The effects of the project on peak- and base-period demands for electricity and other forms of energy;
• The degree to which the project complies with existing energy standards; • The effects of the project on energy resources; and
• The project’s projected transportation energy use requirements and its overall use of efficient transportation alternatives.
Project
Buildout Scenario Studied (Office Scenario)
As discussed in Section 3.6.2.2 in Chapter 3, Project Description, of this EIR, the Specific Plan would allow for the development of up to 2.8 million net new square feet of office or research-anddevelopment (R&D) uses, or a combination of both, the exact amount and configuration of which cannot be forecast with precision. To account for the variability resulting from office and R&D development within the Specific Plan area, two different buildout scenarios have been developed for purposes of the EIR analysis, the Office Scenario and the Life Sciences Scenario. Each section within Chapter 4, Environmental Setting, Impacts, and Mitigation, of this EIR analyses the buildout scenario that represents the “worst-case” scenario for the resource being analyzed. The “worst-case” scenario is the scenario with the greatest potential to result in significant impacts.
The types of construction and the levels of construction-related energy consumption are anticipated to be similar for both scenarios, but as described below, they cannot be precisely quantified.
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Therefore, either buildout scenario represents the worst-case scenario in terms of the energy consumption impacts associated with construction. On the other hand, the differences in the gross square footage and land uses would influence long-term energy consumption. The R&D buildings under the Life Sciences Scenario would have a higher building energy consumption rate (in terms of kilowatt-hour per square foot of space) and higher-horsepower emergency diesel generators, which would consume more diesel fuel. However, the Office Scenario would involve more building development than the Life Sciences Scenario (i.e., an additional approximately 774,950 square feet).
Although the Office Scenario would have a lower building energy consumption rate per square foot and lower-horsepower generators, the increased building square footage would offset these features, making the Office Scenario the worst-case scenario in terms of the energy consumption associated with operation. Furthermore, the Office Scenario would generate nearly twice as many vehicle trips by commuters compared with the Life Sciences Scenario (11,200 employees versus 5,786). Therefore, for the analysis of energy consumption associated with project operation, the worst-case scenario is assumed to be the Office Scenario. Therefore, that scenario is evaluated in this section.
Construction
Construction activities under the project would result in energy consumption from the use of construction equipment; the use of vehicles, including haul trucks, by workers; and the use of electricity. At this time, the construction schedule and activities associated with each individual development project within the Specific Plan area are not known, other than Phase 1, which is evaluated separately below. With anticipated buildout in 2030, development of the various land uses associated with the proposed Specific Plan would occur over an extended period of time and would depend on local economic conditions, market demand, and other financing considerations.
Consequently, without these specific details, it is not possible to develop a quantified estimate of construction-related energy use for Specific Plan buildout. 22 As such, the evaluation of constructionrelated energy impacts resulting from implementation of the Specific Plan is conducted qualitatively in this EIR.
Operation
Energy consumption associated with the project includes the use of natural gas, electricity, and fuel for mobile sources (i.e., vehicles). Specifically, landscaping equipment, including gasoline-powered equipment (e.g., trimmers, mowers); the five emergency generators; water usage; and natural gas for building and water heating would all result in energy consumption during project operation.
Natural gas and electricity use was quantified using the California Emissions Estimator Model (CalEEMod), version 2016.3.2, for existing (2018) and buildout (2030) conditions with the Specific Plan area, reflecting implementation of state measures to reduce energy use and resulting GHG emissions (e.g., Pavley standards). Defaults were assumed, based on the anticipated land uses and square footage identified in the Office Scenario. The analysis quantifies energy reductions that would result from the Specific Plan’s requirement for the project to utilize 100 percent carbon-free electricity for all operational electricity needs through participation in programs such as PG&E Solar Choice or Peninsula Clean Energy, as discussed in Chapter 3, Project Description, of this EIR. The 22 Project-level information includes details such as the size and scale of the project to be constructed, the construction schedule, the equipment fleet, estimates regarding the size of the construction crew, and demolition and grading specifics.
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analysis also accounts for energy reductions from weather-based irrigation controls, which would reduce water consumption and therefore indirect energy consumption. Quantifiable features required for compliance with CALGreen (i.e., low-flow fixtures) were also incorporated into the CalEEMod model. Consistent with the capabilities of CalEEMod, the analysis does not quantify the energy reductions that would occur with implementation of the Specific Plan’s range of nontransportation-related sustainability features, such as exterior electrical power infrastructure to support electric landscaping equipment, Leadership in Energy and Environmental Design (LEED) Silver rating for buildings, high-efficiency natural gas appliances, and a 10 percent better energy performance compared with an American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE) 90.1-2010 reference baseline building.
Fuel use was quantified using CalEEMod, version 2016.3.2; CARB’s EMFAC2017 emissions model; and daily VMT estimates. VMT estimates were based on the City/County Association of Governments of San Mateo County travel demand model and then modified to account for 1) the VMT reduction associated with the extension of Southline Avenue through the Specific Plan area (see Section 4.15, Transportation and Circulation, of this EIR) and 2) the VMT reduction associated with the City’s Transportation Demand Management (TDM) Ordinance, under which the project would be required to achieve an alternative mode shift of 45 percent, resulting in a 23 percent reduction in project VMT.23 Please refer to Appendix 4.2-1 for the CalEEMod output files and fuel use calculations.
Phase 1
Construction
Construction of Phase 1 would require energy usage, such as electricity for mobile offices and fuel for off-road equipment, haul trucks, and vehicles used by vendors and workers. Data regarding total electricity usage during Phase 1 construction was provided by the Phase 1 applicant. Fuel usage was quantified from the construction emissions profile, with construction data (e.g., construction schedule, equipment operating details, trip numbers and lengths, construction quantities) provided by the project applicant. Assuming all off-road activities, hauling, and vendor activities would be carried out with diesel equipment and vehicles and all workers would use gasoline vehicles to travel to and from the Phase 1 site, the annual number of metric tons of carbon dioxide equivalent (CO2e) emissions associated with each corresponding construction activity (e.g., off-road equipment, worker trips) can be converted to gallons of diesel or gasoline and summed accordingly.
Operation
Energy consumption from operational activities associated with buildout of Phase 1 was evaluated using the same methods and models (e.g., CalEEMod) described above for the project.
4.5.4.3 Impact Evaluation
Impact EN-1a: The project would not result in potentially significant environmental impact due to the wasteful, inefficient, or unnecessary consumption of energy resources during 23 Ibid.
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Environmental Setting, Impacts, and Mitigation
Energy
Southline Specific Plan EIR 4.5-14 September 2021
ICF 0082.20
project construction. (Project: Less than Significant with Mitigation; Phase 1: Less than Significant with Mitigation)
Project
Construction activities associated with the project would result in the temporary usage and consumption of energy resources within the project site. Construction energy use would include the electricity used to power electric construction equipment and mobile offices or deliver water to construction sites, the gasoline and diesel fuel used to transport workers and drive haul trucks to and from construction sites, and the fuel used to operate off-road equipment. Construction-related energy usage and consumption would occur intermittently throughout the course of Specific Plan buildout and would vary substantially, depending on the level of activity, the length of construction periods, specific construction operations, the types of equipment, and the number of workers, which could result in a significant energy impact if best management practices (BMPs) are not implemented.
Because the timing and intensity of future development projects under the Specific Plan are not yet known, the precise effects of construction activities associated with buildout of the Specific Plan cannot be accurately quantified at this time. However, the types of land uses permitted under the Specific Plan would involve construction activities that are considered typical of development within an urban area. No land uses are expected to require an extraordinary amount of energy consumption during construction, as may occur with large industrial facilities, like new power plants or dams, because no such land uses are proposed or permitted within the Specific Plan area.
In order to reduce energy consumption during project construction, grid electric power would be used instead of diesel generators for all activities requiring electricity, besides those associated with welding. Furthermore, as discussed in Section 4.7, Greenhouse Gas Emissions, all development under the Specific Plan, including Phase 1, would be required to comply with Mitigation Measure GHG-1, which would require construction contractors to implement the Bay Area Air Quality Management District’s (BAAQMD’s) recommended BMPs; these include ensuring that alternative-fuel (e.g., biodiesel, electric) construction vehicles/equipment make up at least 15 percent of the fleet, using local building materials, sourced from within 100 miles of the planning area, for at least 10 percent of construction; and recycling and reusing at least 50 percent of construction waste and demolition materials. Note that BAAQMD’s recommended BMP to recycle and reuse at least 50 percent of construction waste or demolition materials is not as rigorous as the City’s requirement that new construction submit a Waste Management Plan identifying how at least 65 percent of noninert project waste materials and 100 percent of inert materials will be diverted from the landfill through recycling and salvage. In addition, as discussed in Section 4.2, Air Quality, Mitigation Measure AQ-4 would require future development under the Specific Plan after Phase 1 to use renewable diesel fuel for all off-road equipment greater than 50 horsepower. These measures would reduce the amount of fossil fuel consumed during construction activities and the energy intensiveness associated with new building materials as well as discarded construction and demolition waste. With incorporation of these mitigation measures, construction under the project would not result in the wasteful, inefficient, or unnecessary consumption of energy resources. This impact would be less than significant with mitigation.
Phase 1
The types of construction-related energy consumption under Phase 1 would be similar to those described above for the project. Construction activities under Phase 1 would include the demolition City of South San Francisco
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Energy
Southline Specific Plan EIR 4.5-15 September 2021
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of all structures within the proposed Specific Plan area; construction of two new office/R&D buildings on the Phase 1 site; construction of an amenities building on the Phase 1 site; and utility relocations, partial construction of a parking structure, intersection and roadway construction, and streetscape and landscape improvements. Construction energy use would include the electricity used to power mobile offices, the gasoline and diesel fuel used to transport workers and drive haul trucks to and from construction sites, and the fuel used to operate off-road equipment. Estimated construction-related energy consumption is provided in Table 4.5-4. The table shows that Phase 1 construction would consume approximately 173,253 million BTUs over the 30-month construction period, primarily from diesel-powered sources.
Table 4.5-4. Estimated Construction Energy Consumption from Phase 1 (MMBTUs)a Source Total mBTU
Electricity 789
Fuel – gasoline 11,121
Fuel – diesel 161,343
Total 173,253
Source: Refer to Appendix 4.2-1 for CalEEMod model outputs and construction energy calculations. a. Emissions represent the sum of emissions from CalEEMod for construction output and energy consumption (approximately 78,000 kilowatt-hours per year) during construction.
Similar to the project, construction of Phase 1 would not result in the wasteful, inefficient, or unnecessary consumption of energy resources with implementation of Mitigation Measure GHG-1.
This measure would reduce the amount of fossil fuel consumed during construction activities as well as the energy intensiveness associated with new building materials and discarded construction and demolition waste by requiring construction contractors to implement BAAQMD’s recommended BMPs—specifically, those associated with alternative fuel use and recycling. This impact would be less than significant with mitigation.
Impact EN-1b: The project would not result in potentially significant environmental impact due to the wasteful, inefficient, or unnecessary consumption of energy resources during project operation. (Project: Less than Significant; Phase 1: Less than Significant) Project
Once operational, the project would generate vehicle trips, which would result in gasoline and diesel being consumed. The project would also result in the consumption of electricity and natural gas for operational uses such as electrical power needs, emergency generator operations, heating, cooling, and landscaping. As discussed above, the project’s energy consumption is evaluated for the Office Scenario under existing (2018) and buildout-year (2030) conditions with the project. The analysis accounts for benefits achieved by the Specific Plan’s requirement for the project to utilize 100 percent carbon-free electricity for all operational electricity needs through participation in programs such as PG&E Solar Choice or Peninsula Clean Energy, as discussed in Chapter 3, Project Description, of this EIR. In addition, the analysis accounts for energy reductions from weather-based irrigation controls, which would reduce water consumption and therefore indirect energy consumption.
Quantifiable features, such as low-flow fixtures, were also incorporated. The project could achieve additional reductions in energy consumption and usage through 10 percent or better energy performance compared with an ASHRAE 90.1-2010 reference building baseline, LEED Silver or City of South San Francisco
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Energy
Southline Specific Plan EIR 4.5-16 September 2021
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equivalent certification for buildings, on-site renewable energy and energy storage, and energyefficient lighting and building designs. However, these strategies were not quantified because the exact number of installed systems and affected structures is currently unknown and not all such measures are mandated by the Specific Plan.24 Therefore, this analysis may overstate the project’s actual operational energy impacts. Table 4.5-5 presents the results of the operational energy analysis (expressed in terms of million BTU or MMBTU). The project’s net energy consumption is determined by taking the difference in operational energy consumption between existing (2018) and proposed (2030) conditions at the Specific Plan area.
Table 4.5-5. Estimated Operational Net Energy Consumption for the Project Analysis Condition/Source MMBTU/Year
Existing (2018)
Electricity 5,482
Natural gas 599
Mobile – gasoline 379,136
Mobile – diesel 24,724
Total Existinga 409,940
Proposed Project Buildout (2030)
Electricity 148,927
Natural gas 57,062
Mobile – gasoline 646,224
Mobile – diesel 54,503
Total Project Buildouta 906,716
Net Change with Project
Existing vs. Proposed 496,776
Energy per Square Foot (MMBTU/sf)
Existing 1.42
Proposed 0.32
Source: Refer to Appendix 4.2-1 for CalEEMod model outputs.
Notes:
As noted above, the energy analysis reflects implementation of quantifiable state measures to reduce energy consumption (CALGreen) and Specific Plan features related to the use of green consumer products and installation of high-efficiency fixtures. In addition, for the proposed condition, the energy consumption numbers presented are maximums anticipated under the Office Scenario. Therefore, total energy consumption provided represents the worst-case scenario.
a. Values may not add due to rounding.
As shown, buildout of the Specific Plan would increase operational energy consumption at the Specific Plan area by approximately 496,776 million BTUs compared with existing conditions.
However, energy usage per square foot would decrease from approximately 1.42 million BTUs per square foot under existing conditions to 0.32 million BTU per square foot under the Specific Plan, despite the nearly tenfold increase in building square footage. This is attributable to the relative 24 Per the requirements of the Specific Plan, the project would be mandated to achieve additional reductions in energy consumption and usage through 10 percent or better energy performance compared with an ASHRAE 90.1- 2010 reference building baseline, and LEED Silver or equivalent certification for buildings.
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Energy
Southline Specific Plan EIR 4.5-17 September 2021
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energy efficiency of the future buildings and vehicles, which would be subject to increasingly robust regulations over time to meet the state’s renewable energy and efficiency mandates. Furthermore, as discussed in Section 4.15, Transportation and Circulation, of this EIR, the project would include a TDM Plan designed to meet the 45 percent mode-share target required by the City. The TDM Plan would provide direct access to transit, on-site amenities for bicycle and pedestrian access, shuttle service, carpooling and vanpooling facilities and services, mode shift incentives, and other TDM features, resulting in a reduction in VMT, and, consequently, the amount of energy (i.e., gasoline and diesel) consumed.
Based on the above, buildout of the Specific Plan would not result in the wasteful, inefficient, or unnecessary consumption of energy resources. This impact would be less than significant. No mitigation is required.
Phase 1
The types of operational energy consumption under Phase 1 would be similar to those described above for the project. Phase 1’s operational energy consumption was evaluated under existing-year (2018) and buildout-year (2024) conditions. The analysis includes implementation of quantifiable measures to reduce energy usage (e.g., CALGreen) as well as the benefits achieved through quantifiable sustainability measures, including the use of weather-based irrigation controls and 100 percent carbon-free electricity for all electricity needs, items that are incorporated into the Phase 1 design. Similar to the project, Phase 1 could achieve additional reductions in energy consumption and usage through voluntary sustainability features; however, these strategies are not currently quantifiable and, therefore, not factored into the Phase 1 operational energy analysis.
Table 4.5-6, below, presents the results of the operational energy analysis (expressed in terms of million BTU or MMBTU). Phase 1 net energy consumption is determined by taking the difference in operational energy consumption between existing (2018) and proposed (2024) conditions at the Specific Plan area. Since Phase 1 would demolish all existing uses within the Specific Plan area, netting out the existing energy usage of those uses, Phase 1’s operational energy usage is estimated in the context of the Specific Plan area as a whole, rather than just the Phase 1 site.
As shown in Table 4.5-6, buildout of Phase 1 would increase operational energy consumption on the Specific Plan area by approximately 115,369 million BTUs compared with existing conditions.
However, energy use per square foot would decrease from approximately 1.42 million BTUs per square foot under existing conditions to 0.75 million BTU per square foot, despite the significant increase in building square footage. This decrease is attributable to the relative energy efficiency of the future buildings and vehicles, as well as energy efficiency measures to be incorporated into Phase 1, as described below.
Phase 1 would meet the United States Green Building Council’s LEED v4 Silver or equivalent certification standards, and exceed ASHRAE 90.1-2010 standards by approximately 10 percent. In addition, the design of Phase 1 would incorporate environmentally sustainable design features, including LED lighting, daylighting and occupancy controls, efficient heating and air-conditioning systems, energy-efficient windows, and high-efficiency water fixtures (e.g., toilets, urinals), highefficiency natural gas appliances, along with other mechanical systems, which would be designed around maximizing energy efficiency and natural lighting. Furthermore, as discussed in Section 4.15, Transportation and Circulation, of this EIR, the project would include a TDM Plan designed to meet the 45 percent mode-share target required by the City, and Phase 1 would be subject to the TDM Plan. The TDM Plan would provide direct access to transit, on-site amenities for bicycle and City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Energy
Southline Specific Plan EIR 4.5-18 September 2021
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pedestrian access, shuttle service, carpooling and vanpooling facilities and services, mode shift incentives, and other TDM features, resulting in a reduction in VMT, and, consequently, the amount of energy (i.e., gasoline and diesel) consumed.
Table 4.5-6. Estimated Operational Net Energy Consumption for Phase 1 Analysis Condition/Source MMBTU/Year
Existing (2018)
Electricity 5,482
Natural gas 599
Mobile – gasoline 379,136
Mobile – diesel 24,724
Total Existinga 409,940
Proposed Phase 1 Buildout (2024)
Electricity 16,487
Natural gas 51,470
Mobile – gasoline 424,067
Mobile – diesel 33,285
Total Phase 1 Buildouta 525,309
Net Change with Phase 1
Existing vs. Proposed 115,369
Energy per Square Foot (MMBTU/SF)
Existing 1.42
Proposed 0.75
Source: Refer to Appendix 4.2-1 for CalEEMod model outputs and mobile emissions calculations.
Notes:
As noted above, the emissions analysis does not include benefits achieved by the voluntary sustainability features but does reflect implementation of quantifiable state measures to reduce energy consumption (e.g., CALGreen). a Values may not add because of rounding.
Based on the above analysis, operation of Phase 1 would not result in the wasteful, inefficient, or unnecessary consumption of energy resources. This impact would be less than significant. No mitigation is required.
Impact EN-2: The project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. (Project: Less than Significant; Phase 1: Less than Significant) Project
The state and local renewable energy and energy efficiency plans that would be applicable to the project are discussed in Section 4.5.3, p. 4.5-6. State plans include the AB 1493 Pavley Rules, California Title 24 energy efficiency standards, EO B-16-12, SB 350, and SB 100. Each of these contain required standards related to renewable energy development and energy efficiency. Local plans that address energy efficiency, which are designed to achieve the state’s RPS mandates, include PG&E’s 2020 IRP, PCE’s 2018 IRP, and the City’s Climate Action Plan. The City’s General Plan also includes goals and policies related to energy use and energy reductions.
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Energy
Southline Specific Plan EIR 4.5-19 September 2021
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As discussed above under Impact EN-1, the project would encourage implementation of sustainability and transportation features. Furthermore, energy use per square foot would decrease compared with existing conditions, despite the nearly tenfold increase in building area that would occur. Development under the Specific Plan would be required to comply with state and local renewable energy and energy efficiency plans. Such development would benefit from resulting increases in renewable energy development and energy efficiency. Even with increased VMT and an increase in the number of average daily trips in the area, vehicle and energy use is expected to become increasingly more efficient as a result of the regulations included in Pavley and EO B-16-12, which address average fuel economy and the commercialization of zero-emission vehicles, respectively. Energy efficiency within buildings is also expected to increase as a result of compliance with Title 24 building codes, which are expected to move toward zero net energy for newly constructed buildings and shift toward a 100 percent renewable energy target under SB 350 and SB 100 regulations. With implementation of the Specific Plan, PG&E would continue to pursue the procurement of renewable energy sources to meet its RPS portfolio goals and comply with state regulations. As mentioned in the IRP, PG&E is on track to meet the 2030 target that calls for GHGfree energy emissions. Therefore, the project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency, and the impact would be less than significant. No mitigation is required.
Phase 1
Phase 1 would be consistent with the proposed Specific Plan. In addition, Phase 1 would install energy-efficient appliances, meet the United States Green Building Council’s LEED v4 Silver or equivalent certification standards, and exceed ASHRAE 90.1-2010 standards by approximately 10 percent. Phase 1 would incorporate environmental and performative design criteria. Like all development within the Specific Plan, Phase 1 would be required to comply with state and local renewable energy and energy efficiency plans. For the reasons stated above for the project analysis, Phase 1 would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency, and the impact would be less than significant. No mitigation is required.
4.5.4.4 Cumulative Impacts
The cumulative geographic context for energy is the service area of PG&E (i.e., the electric and natural gas service area), which comprises the larger Northern California area and the PCE service area.
Impact C-EN-1: The project, inclusive of Phase 1, together with the cumulative projects identified would not result in a potentially significant environmental impact due to the wasteful, inefficient, or unnecessary consumption of energy resources during project construction or operation. (Project: Less than Significant; Phase 1: Less than Significant) Continued growth throughout PG&E’s service area could contribute to ongoing increases in demand for electricity and natural gas. These anticipated increases would be countered, in part, as state and local requirements related to renewable energy become more stringent and energy efficiency increases. The extent to which cumulative development through 2030, the project’s buildout year, could result in the wasteful, inefficient, or unnecessary consumption of energy resources would depend on the specific characteristics of new development, which are not known at this time. As discussed previously, SB 100 obligates utilities to supply 100 percent carbon-free electricity by 2045. PG&E reached California’s 2020 renewable energy goal 3 years ahead of schedule and is City of South San Francisco
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currently projected to meet the new SB 100 goal, which calls for 60 percent renewable energy by 2030, ahead of schedule. Similarly, the Pavley standards are expected to increase average fuel economy to roughly 54.5 miles per gallon by 2025, thereby lowering the demand or fossil fuels.
Therefore, it is anticipated that future energy users will become more efficient and less wasteful over time.
As stated above, buildout of the Specific Plan would increase operational energy consumption on the project site by approximately 496,776 million BTUs compared with existing conditions. However, energy use per square foot would decrease to approximately 0.32 million BTU per square foot from
1.42 million BTUs per square foot under existing conditions, despite the nearly tenfold increase in building area that would occur. This is attributable to the energy efficiency of the future buildings and vehicles, which would be subject to increasingly robust regulations over time to meet the state’s renewable energy and efficiency mandates. The Specific Plan encourages building design features that reduce energy consumption and increase renewable energy generation. Because buildout under the Specific Plan, inclusive of Phase 1, would not result in the wasteful, inefficient, or unnecessary consumption of energy resources, and because cumulative development would be subject to increasingly robust standards regarding energy efficiency, the cumulative impact would be less than significant.
Impact C-EN-2: The project, inclusive of Phase 1, together with the cumulative projects identified would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. (Project: Less than Significant; Phase 1: Less than Significant) Cumulative development would be required to comply with all adopted state and local renewable energy and energy efficiency regulations and plans. Therefore, cumulative impacts would be less than significant.
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Geology and Soils
Southline Specific Plan EIR 4.6-1September 2021
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4.6 Geology and Soils
4.6.1 Introduction
This section evaluates the potential impacts related to construction and operation of the Southline Specific Plan and off-site improvements (proposed project), including the first phase of development under the proposed project (Phase 1), on geology and soils, including paleontological resources.
This section also describes the existing conditions at the project site, including the Phase 1 site, as well as the regulatory framework for this analysis. The impacts of the proposed project are generally analyzed at a program level, and the impacts of Phase 1 are analyzed at a project level. Impacts resulting from implementation of the proposed project, impacts resulting from implementation of Phase 1, and cumulative impacts are described. Feasible mitigation measures, where applicable, are also described. Relevant technical documentation used in this analysis includes the Southline Development Design-Level Geotechnical Investigation (Design-Level Geotechnical Investigation) prepared for the proposed project by Cornerstone Earth Group in July 2020 (Appendix 4.6-1). 1 The
study area for the Design-Level Geotechnical Investigation is the Specific Plan area. Given the proximity of the off-site improvement areas to the Specific Plan area, it is assumed that existing conditions and impacts described for the Specific Plan area would be the same or substantially similar at the off-site improvement areas. Therefore, unless otherwise noted, this section applies the findings of the Design-Level Geotechnical Investigation to the project site as a whole.
Issues identified in response to the Notice of Preparation (NOP) (Appendix 1) were considered in preparing this analysis. No questions or concerns related to geology and soils were raised in the responses to the NOP.
4.6.2 Environmental Setting
This section provides a discussion of the existing conditions related to geology and soils on the project site.
4.6.2.1 Project Site
Physiography
The City of South San Francisco is located on the bay plain and the northern foothills of the Coastal Range. The project site is located on the bay plan. The topography of the project site is relatively flat, with a gentle downward slope to the east. The elevation of the site ranges from approximately 17 feet above mean sea level (amsl) (NAVD 88)2 in the eastern portion to approximately 33 feet amsl in the western portion.
1 Cornerstone Earth Group. 2020. Southline Development: Design-Level Geotechnical Investigation, Project Number 129.3.6. July 28, 2020.
2 The North American Vertical Datum of 1988 (NAVD 88) is the vertical control datum established in 1991 by the minimum-constraint adjustment of the Canadian-Mexican-United States leveling observations. It held fixed the height of the primary tidal bench mark, referenced to the new International Great Lakes Datum of 1985 local mean sea level height value, at Father Point/Rimouski, Quebec, Canada.
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Southline Specific Plan EIR 4.6-2September 2021
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Subsurface Conditions
The principal geologic units underlying the project site are, from top to bottom, artificial fill, Colma Formation, Merced Formation (assumed), and Franciscan Complex. Depth to these layers varies by location where boring was advanced. Generally, artificial fill is underlain by Colma Formation, characterized as friable, well sorted medium sand containing a few beds of sandy silt, clay and gravel. Merced Formation is assumed to underlie the Colma Formation, and the bedrock Franciscan Complex is found at depth.
Artificial fill generally underlies the project site to a depth of 2–5 feet below ground surface (bgs), except at 50 and54 Tanforan Avenue where artificial fill was discovered to a depth of 22 feet. The fill consists of sandy clay at most of the areas within the project site, and of and sandy clay with gravel and asphalt pieces at 50 and 54 Tanforan Avenue. The Colma Formation underlies the artificial fill and consists of soft sandy silty clay, very stiff to hard clay with sand, stiff silt with sand, dense silty sand, and very dense poorly graded sand, depending on location and depth. Merced Formation is assumed to underlie the Colma Formation and consists of a range of sandy clays and sands, generally dense. Colma Formation and Merced Formation together range from approximately 2 feet bgs to 17 feet up to 95 feet bgs, the maximum depth of exploration, depending on location. These sediments and others overlie the bedrock Franciscan Formation, which lies from about 420 feet bgs in the northeast part of the project site to about 540 feet bgs in the southwest.
Depth to groundwater at the proposed project site ranges from approximately 8 to 27 feet bgs.3 While historic high groundwater levels are not mapped for the project site, groundwater monitoring wells within 500 feet of the site indicated groundwater levels of 5 to 16 feet bgs. Seasonal and ambient changes in water availability can result in changes to the groundwater level.
Sediments above the water table are generally stiff to very stiff clays and medium dense to dense sands. Sediments below the water table include dense sand.
Primary Seismic Hazards
Surface Fault Rupture
The project site is not located within a State-designated Alquist-Priolo Earthquake Fault Zone, and no known active or potentially active surface expression of fault traces crosses the site. 4 5 Therefore,
the likelihood of surface fault rupture within the project site area is low. However, the project site is located between two active fault zones: the Hayward Fault Zone, located approximately 16 miles east of the project site, and the San Andreas Fault Zone, located approximately 2 miles west of the 3 Cornerstone Earth Group. 2020. Southline Development: Design-Level Geotechnical Investigation, Project Number 129.3.6. July 28, 2020.
4 Cornerstone Earth Group. 2020. Southline Development: Design-Level Geotechnical Investigation, Project Number 129.3.6. July 28, 2020.
5 Figure 7-2 in the San Bruno General Plan (2009) depicts a “concealed or uncertain fault trace” described as the “San Bruno Fault” traversing north/south along El Camino Real and through the adjacent Shops at Tanforan property. However, according to most recent USGS data, no known or inferred fault is located at or near this location. Source: U.S. Geologic Survey. 2021. U.S. Quaternary Faults. Available here:
https://usgs.maps.arcgis.com/apps/webappviewer/index.html?id=5a6038b3a1684561a9b0aadf88412fcf.
Accessed: June 22, 2021.
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Geology and Soils
Southline Specific Plan EIR 4.6-3September 2021
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project site.
6 In a seismically active area such as the San Francisco Bay Area, the possibility of future surface fault rupture occurring in areas where faults have not been mapped is small, but the possibility exists. Table 4.6-1 lists the active faults within 20 miles of the project site.
Table 4.6-1. Active Regional Faults within 20 Miles of the Specific Plan Area Fault Name Distance (miles)
Northern San Andreas 2.1
San Gregorio 7.1
Hayward 16.5
Source: Cornerstone Earth Group 2020.
Seismic Ground Shaking
Ground shaking is the most widespread hazardous phenomenon associated with seismic activity. As stated above under Seismic Fault Rupture, the project site is located between two active faults, the Northern San Andreas and Hayward faults, each of which is capable of generating a large earthquake7 (see Figure 4.6-1, p. 4.6-4). Because the project site is located within a seismically active area, it will most likely experience periodic minor earthquakes and a major earthquake (i.e., moment magnitude greater than 6) during the operational life of the project. The U.S. Geological Survey has recently updated its 2015 Uniform California Earthquake Rupture Forecast (Version 3), estimating a 72 percent change of one or more magnitude 6.7 earthquakes occurring somewhere in the Bay Area between 2014 and 2043.8 During a seismic event, the project site could experience “violent shaking” (Modified Mercalli Intensity Shaking Severity Level 9). 9 The intensity of
earthquake ground motion at the project site would depend on the characteristics of the generating fault, the distance to the earthquake epicenter, the magnitude, and the duration of the earthquake.
Secondary Seismic Hazards
Liquefaction
Liquefaction occurs when saturated soils lose cohesion, strength, and stiffness with applied shaking, such as that from an earthquake. The lack of cohesion causes solid soil to behave like a liquid, resulting in ground failure. When a load such as a structure is placed on ground that is subject to liquefaction, ground failure can result in the structure sinking and soil being displaced. Ground 6 U.S. Geologic Survey. 2020. U.S. Quaternary Faults. Available here:
https://usgs.maps.arcgis.com/apps/webappviewer/index.html?id=5a6038b3a1684561a9b0aadf88412fcf.
Accessed: September 22, 2020.
7 Field, E.H., Biasi, G.P., Bird, P., Dawson, T.E., Felzer, K.R. Jackson, D.D., Johnson, K.M., Jordan, T.H., Madden, C.
Michael, A.J., Milner, K.R., Page, M.T., Parsons, T., Powers, P.M., Shaw, B.E., Thatcher, W.R., Weldon, R.J. II, and Zeng, Y. 2015. UCERF3: A New Earthquake Forecast for California’s Complex Fault System. (U.S. Geological Survey Fact Sheet 2015-3009.) Available: https://pubs.usgs.gov/fs/2015/3009/pdf/fs2015-3009.pdf.
Accessed: February 8, 2021.
8 Cornerstone Earth Group. 2020. Southline Development: Design-Level Geotechnical Investigation, Project Number 129.3.6. July 28, 2020.
9 ABAG. 2020. MTC/ABAG Hazard Viewer Map.
https://mtc.maps.arcgis.com/apps/webappviewer/index.html?id=4a6f3f1259df42eab29b35dfcd086fc8.
Accessed: September 22, 2020.
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Figure 4.6-1
Regional Fault Map
Source: Cornerstone Earth Group, 2020. Base by California Geological Survey - 2010 Fault Activity Map of California (Jennings and Bryant, 2010) City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Geology and Soils
Southline Specific Plan EIR 4.6-5September 2021
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failure can take on many forms, including flow failures, lateral spreading, lowering of the ground surface, ground settlement, loss of bearing strength, ground fissures, and sand boils. Liquefaction within subsurface layers, which can occur during ground shaking associated with an earthquake, can also result in ground settlement.
The project site is within an area that has not been evaluated for liquefaction by the California Geological Survey.10 The Health and Safety Element of the General Plan notes that a large portion of the City, primarily east of U.S. 101, is underlain by deposits of bay mud, up to 80 feet deep in some places, that could be subject to liquefaction. However, the project site is located 0.5 mile west of U.S. 101 and is not expected to be underlain with liquefiable soils. As shown in Figure 7-2 in the San Bruno General Plan, the off-site improvement areas in San Bruno’s jurisdiction also are not within an area identified as being susceptible to liquefaction. Further, the Design-Level Geotechnical Investigation concluded, based on modeling for the soil types present, that the potential for liquefaction at the project site is very low and were it to occur, resulting settlement would be negligible.11
Lateral Spreading
Lateral spreading is a phenomenon in which a surficial soil displaces along a shear zone that formed within an underlying liquefied layer. The surficial blocks are transported downslope or in the direction of a free face, such as a bay or creek, by earthquake and gravitational forces. Lateral spreading is generally the most pervasive and damaging type of liquefaction-induced ground failure generated by earthquakes. As discussed above, the potential for liquefaction at the project site is negligible. In addition, the project site is not located near any open face which would allow for lateral spreading. Therefore, the potential risk of lateral spreading is very low.
Seismic Settlement
Loose unsaturated sandy soils can settle during strong seismic shaking. As discussed above under Subsurface Conditions, the soils encountered at the project site above the water table were predominantly stiff to very stiff clays and medium dense to dense sands. Therefore, the potential for differential seismic settlement affecting the proposed improvements is very low to none.
Expansive Soils
Expansive soils can undergo significant volume change with changes in moisture content. Where these soils lie in the zone of seasonal moisture fluctuation,12 they shrink and harden when dried and expand and soften when wetted. According to the Design-Level Geotechnical Investigation, moderately expansive surficial soils generally blanket the project site.13 Additionally, as shown in Figure 7-2 in the San Bruno General Plan, the off-site improvement areas in San Bruno’s jurisdiction are within areas known to contain expansive soils. Therefore, potential exists for increased risk of injury as a result of construction on expansive soils.
10 California Geologic Survey. 2020. Earthquake Zones of Required Investigation. Available:
https://maps.conservation.ca.gov/cgs/EQZApp/app/. Accessed: September 22, 2020. 11 Cornerstone Earth Group. 2020. Southline Development: Design-Level Geotechnical Investigation, Project Number 129.3.6. July 28, 2020.
12 The zone of seasonal fluctuation is the depth of soil to which moisture penetrates, varying by season. 13 Cornerstone Earth Group. 2020. Southline Development: Design-Level Geotechnical Investigation, Project Number 129.3.6. July 28, 2020.
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Landslide
Landslides occur when the stability of a slope changes from a stable to an unstable condition. The stability of a slope is affected by the following primary factors: inclination, material type, moisture content, orientation of layering, and vegetative cover. In general, steeper slopes are less stable than more gently inclined ones. The topography of the project site is relatively flat with a generally gentle downward slope to the east. The Metropolitan Transportation Commission (MTC)/Association of Bay Area Governments (ABAG) Hazard View map show the project site as flat land no risk of landslide.14 Therefore, the likelihood of a landslide at the project site is low.
Paleontological Resources
Paleontological resources are found within geologic units, which can sometimes extend large distances. The relevant unit for identifying likelihood of discovering paleontological resources is the geologic unit rather than proximity.
As discussed above under Subsurface Conditions, the surficial geologic unit at the project site is artificial fill to a depth of generally 2 to 5 feet bgs, although boring indicated artificial fill was present at 50 and 54 Tanforan Avenue to a depth of 22 feet bgs. 15 The artificial fill is immediately underlain
by Colma Formation (refer to Figure 4.6-2, p. 4.6-7).
16,17 The Colma Formation is a Late Pleistocene
sedimentary unit that is characterized as friable, well sorted medium sand containing a few beds of sandy silt, clay and gravel. The Colma Formation in this area is likely underlain by the PlioPleistocene Merced Formation in the area. The Merced Formation is underlain by Cretaceous Franciscan Complex Sedimentary rock at a depth of approximately 420 to 540 bgs. Bedrock surface contours suggest the depth to Franciscan bedrock in the area of the site may be in the range of about 420 feet bgs in the northeast portion of the site to about 540 feet in the southwest portion of the site. However, these estimates can vary considerably in the area of the project site as the bedrock surface can be highly irregular in the subsurface.
The Colma Formation is known to have yielded vertebrate fossils. 18 At a site on Pacific Avenue in San
Francisco, Mammuthus (an extinct genus that belongs to the order of trunked mammals, including 14 MTC/ABAG. 2020. Hazard View Map. Available here:
https://mtc.maps.arcgis.com/apps/webappviewer/index.html?id=4a6f3f1259df42eab29b35dfcd086fc8.
Accessed: September 25, 2020.
15 Cornerstone Earth Group. 2020. Design-Level Geotechnical Investigation: 30, 50, and 54 Tanforan Avenue, 160 South Linden Avenue, 240 Dollar Avenue, and 325 South Maple Avenue, South San Francisco, California. July 28.
Sunnyvale, CA. Prepared for Lane Partners, LLC, Menlo Park, CA. 16 Cornerstone Earth Group. 2020. Design-Level Geotechnical Investigation: 30, 50, and 54 Tanforan Avenue, 160 South Linden Avenue, 240 Dollar Avenue, and 325 South Maple Avenue, South San Francisco, California. July 28.
Sunnyvale, CA. Prepared for Lane Partners, LLC, Menlo Park, CA. 17 Wagner, D.L., E.J. Bortugno, and R.D. McJunkin. 1991. Geologic Map of the San Francisco-San Jose Quadrangle, California, 1:250,000. Available: https://www.conservation.ca.gov/cgs/Documents/Publications/RegionalGeologic-Maps/RGM_005A/RGM_005A_SanFrancisco-SanJose_1991_Sheet1of5.pdf. Accessed: September 29, 2020.
18 Rodda, P.U., and N. Baghai. 1993. Late Pleistocene Vertebrates from Downtown San Francisco, California.
Journal of Paleontology 67(5):1058–1063.
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ICF Graphics … 00082.20 (10-7-20) JC
Source: Cornerstone Earth Group, 2020.
Base: USGS, Preliminary Geologic Map of the San Francisco South 7.5’ Quadrangle and Part of the Hunter’s Point 7.5’ Quadrangle, San Francisco Bay Area, California, by M.G. Bonilla, 1998 City of South San Francisco
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mammoth) and Bison (bison) fossils were recovered. University of California Museum of Paleontology records indicate that remains of Equus (horse) have been recovered in South San Francisco.19
The Merced Formation, believed to underlie the Colma Formation at the project site, has also yielded vertebrate fossils.20 Mammalian remains recovered from the Merced Formation include Mammuthus, Magalonyx (an extinct species of ground sloth), and Equus, among others. Bird remains include Fulmarus (a genus of sea bird) and Pramancalla (a genus of diving bird). Fish remains include cartilaginous fish, including Cetorhinus (a genus of shark), Hexanchus (a genus of shark), and Myliobatis (a genus of ray); as well as bony fish, including Anarrhichthys (a genus of eel), Ophiodon (a genus of lingcod), and Sardinops (a genus of sardine). The University of California Museum of Paleontology indicates that six mammalian species fossils have been recovered from coastal San Mateo County. These include Enhydra (sea otters), Glossotherium (an extinct genus of ground sloth), and Mammuthus.
The bedrock Franciscan Formation underlies all other geologic units at the project site.
Paleontological resources records have identified significant fossils in the Franciscan Formation.21 Vertebrate paleontological resources recovered from this unit include Ichthyosaurus (San Joaquin County) and Plesiosaurus (San Luis Obispo County). Although vertebrate fossils are uncommon in this geologic unit, fossils have been important in understanding formation of the Franciscan Formation.22
4.6.2.2 Phase 1 Site
Geology and soils conditions at the Phase 1 site are the same as those at the project site as a whole.
Accordingly, potential for seismic hazards, expansive soils, and landslide are the same as at the project site.
Geologic units at the Phase 1 site are the same as those at the project site as a whole. Accordingly, potential for paleontological resources to be present at the Phase 1 site is the same as at the project site.
4.6.3 Regulatory Framework
This section provides a summary of the geology and soils plans and policies of federal, state, and local agencies that have policy and regulatory control over the project site. 19 University of California Museum of Paleontology. 2020. Advanced Specimen Search, San Mateo County. Available:
https://ucmpdb.berkeley.edu/advanced.html. Accessed: September 29, 2020. 20 University of California Museum of Paleontology. 2020. Advanced Specimen Search, Merced Formation. Available:
https://ucmpdb.berkeley.edu/advanced.html. Accessed: September 29, 2020. 21 University of California Museum of Paleontology. 2020. Advanced Specimen Search, Franciscan Formation.
Available: https://ucmpdb.berkeley.edu/advanced.html. Accessed: September 29, 2020. 22 Wakabayashi, J. 1992. Nappes, Tectonics of Oblique Plate Convergence, and Metamorphic Evolution Related to 140 Million Years of Continuous Subduction, Franciscan Complex, California. The Journal of Geology 100:1(19- 40). Chicago, IL: University of Chicago Press.
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4.6.3.1 Federal
Earthquake Hazard Reduction Act of 1977
Federal laws codified in United States Code Title 42, Chapter 86, were enacted to reduce risks to life and property from earthquakes in the United States through the establishment and maintenance of an effective earthquake hazards reduction program. Implementation of the requirements are regulated, monitored, and enforced at the state and local levels.
4.6.3.2 State
The Alquist-Priolo Earthquake Fault Zoning Act of 1972
The Alquist-Priolo Earthquake Fault Zoning Act of 1972 (Alquist-Priolo Act) (Public Resources Code Section 2621 et seq.) is intended to reduce the risk to life and property from surface fault rupture during earthquakes. The Alquist-Priolo Act prohibits the location and construction of most types of structures intended for human occupancy23 over active fault traces and strictly regulates construction in corridors along active faults. The California state geologist has established regulatory zones along active faults,24 called “earthquake fault zones,” and published maps that identify areas where surface traces of active faults are present.25 Seismic Hazards Mapping Act
The Seismic Hazards Mapping Act of 1990 (Public Resources Code Sections 2690–2699.6) directs the California Geological Survey to identify and map areas that are prone to liquefaction and landslides resulting from seismic evens. The Act mandates project applicants to have a site-specific geotechnical investigation performed to identify potential seismic hazards and formulate mitigation measures prior to permitting most developments within specific zoned areas.
California Building Standards Code
The California Building Standards Code, or state building code, is codified in Title 24 of the California Code of Regulations. The state building code provides standards that must be met to safeguard life or limb, health, property, and public welfare by regulating and controlling the design, construction, quality of materials, use and occupancy, location, and maintenance of all buildings and structures within the state. The state building code generally applies to all occupancies in California, with modifications adopted in some instances by state agencies or local governing bodies. The current state building code incorporates, by adoption, the 2018 edition of the International Building Code of the International Code Council, with the California amendments. These amendments include building design and construction criteria that have been tailored for California earthquake conditions.
23 With reference to the Alquist-Priolo Act, a structure for human occupancy is defined as one “used or intended for supporting or sheltering any use or occupancy that is expected to have a human occupancy rate of more than 2,000 person-hours per year” (CCR, Title 14, Division 2, Section 3601[e]). 24 An active fault, for the purposes of the Alquist-Priolo Act, is one that has ruptured in the past 11,000 years. 25 California Geological Survey. 2020. The Alquist-Priolo Earthquake Fault Zoning Act. Available:
http://www.conservation.ca.gov/cgs/rghm/ap. Accessed: September 3, 2021.
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Chapter 16 of the state building code deals with structural design requirements governing seismically resistant construction (Section 1604), including, but not limited to, factors and coefficients used to establish a seismic site class and seismic occupancy category appropriate for the soil/rock at the building location and the proposed building design (Sections 1613.5 through 1613.7). Chapter 18 includes, but is not limited to, the requirements for foundation and soil investigations (Section 1803); excavation, grading, and fill (Section 1804); allowable load-bearing values of soils (Section 1806); foundation and retaining walls (Section 1807); and foundation support systems (Sections 1808 through 1810). Chapter 33 includes, but is not limited to, requirements for safeguards at work sites to ensure stable excavations and cut-and-fill slopes (Section 3304) as well as the protection of adjacent properties, including requirements for noticing (Section 3307). Appendix J of the state building code includes, but is not limited to, grading requirements for the design of excavation and fill (Sections J106 and J107), specifying maximum limits on the slope of cut-and-fill surfaces and other criteria, required setbacks and slope protection for cut-and-fill slopes (Section J108), and erosion control through the provision of drainage facilities and terracing (Sections J109 and J110).
California Division of Occupational Safety and Health Regulations Construction activities are subject to occupational safety standards pertaining to excavation, shoring, and trenching, as specified in California Division of Occupational Safety and Health regulations (Title 8).
State Historic Significance Criteria
As discussed in Section 4.6.4.1, Significance Criteria, Appendix G of the California Environmental Quality Act (CEQA) Guidelines includes the following question: “Would the project directly or indirectly destroy a unique paleontological resource or site?” Although CEQA does not define what constitutes “a unique paleontological resource or site,” Section 21083.2 defines unique archaeological resources as “an archaeological artifact, object, or site about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it meets any of the following criteria:
• Contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information.
• Has a special and particular quality, such as being the oldest of its type or the best available example of its type.
• Is directly associated with a scientifically recognized important prehistoric or historic event or person.”
This definition is equally applicable to recognizing a unique paleontological resource or site. CEQA Section 15064.5(a)(3)(D) provides additional guidance, indicating that, generally, a resource shall be considered historically significant if it has yielded, or may be likely to yield, information important in prehistory or history.
The CEQA lead agency having jurisdiction over a project is responsible for ensuring that paleontological resources are protected in compliance with CEQA and other applicable statutes.
Public Resources Code Section 21081.6, Mitigation Monitoring Compliance and Reporting, requires the CEQA lead agency to demonstrate project compliance with the mitigation measures developed during the environmental impact review process.
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4.6.3.3 Local
South San Francisco General Plan
The 1999 South San Francisco General Plan provides a vision for long-range physical and economic development of the City, provides strategies and specific implementing actions, and establishes a basis for judging whether specific development proposals and public projects are consistent with the City’s plans and policy standards. The City General Plan provides a vision for long-range physical and economic development of the City, provides strategies and specific implementing actions, and establishes a basis for judging whether specific development proposals and public projects are consistent with the City’s plans and policy standards. The City General Plan contains a Health and Safety Element, which acknowledges and mitigates the risks posed by hazards (e.g., geologic and seismic). The City General Plan includes the following policy applicable to seismic activity and geologic hazards:
• Policy 8.1-G-1: Minimize the risk to life and property from seismic activity and geologic hazards in South San Francisco.
The General Plan includes no policies relevant to paleontological resources.
City of South San Francisco Building Code
The City Building Division enforces the minimum standards found in the various codes adopted by the state through the Building Standards Commission and as adopted and amended by the City Council. In particular, the City adopted by reference the California Building Standards Code, volumes 1 and 2 (2019 edition), as the building code for the city of South San Francisco, codified as Title 15 to the South San Francisco Municipal Code.
26 Other Titles of the City of San South San Francisco Municipal Code The City has adopted requirements to regulate excavation and construction on public property, codified as Chapter 13.04 to the South San Francisco Municipal Code. The municipal code requires that excavation and construction must adhere to certain conditions, including adhering to applicable restrictions and requirements for excavation and grading as imposed by the Uniform Building Code (enforced through adoption of the California Building Standards Code), disposing of constructed or excavated materials, adhering to maximum or minimum slopes to be used, adhering to requirements for degree of compaction of fill immaterial, and adhering to requirements for safe and adequate drainage of the site.27
The City Municipal Code does not reference paleontological resources or fossil resources.
San Bruno Plans and Policies
As further described in Chapter 3, Project Description, of this EIR, the project proposes certain circulation and infrastructure improvements that are located within the City of San Bruno (San Bruno) but would not develop any new structures or new land uses in San Bruno. The improvements would occur on areas that are already developed with existing circulation 26 South San Francisco Municipal Code Section 15.08.010. 27 South San Francisco Municipal Code Section 13.04.040.
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improvements. The specific off-site improvements located within San Bruno include: constructing a new signalized intersection at Huntington Avenue/Sneath Lane/Southline Avenue/Maple Avenue; improving Huntington Avenue from Southline Avenue south to the existing BART garage intersection located west of Pacific Avenue; converting Tanforan Avenue to a cul-de-sac adjacent to Huntington Avenue; and realigning the existing storm drain main within Huntington Avenue to conform to the proposed intersection improvements at Huntington Avenue/Southline Avenue. This section identifies and evaluates the proposed project’s consistency with relevant policies from the San Bruno General Plan and the San Bruno Municipal Code related to geology and soils as related to the portions of the off-site improvements located within San Bruno’s jurisdiction. For additional discussion of the proposed project’s consistency with San Bruno land use plans and policies, refer to Section 4.10, Land Use and Planning, and Section 4.15, Transportation and Circulation.
San Bruno General Plan
The 2009 San Bruno General Plan outlines a vision for the long-range physical and economic development of the community through 2025. The San Bruno General Plan contains a Health & Safety Element, which acknowledges and mitigates the risks posed by hazards (e.g., earthquake).28 The San Bruno General Plan includes the following policies applicable to seismic and geologic hazards that are relevant to the proposed off-site improvements in San Bruno’s jurisdiction:
• Policy HS-1: Regulate development … to assure adequate mitigation of safety hazards on sites having a history of threat of slope instability, erosion, subsidence, seismic dangers (including those resulting from liquefaction, ground failure, ground rupture)[…] • Policy 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[…] • Policy HS-4: Prevent soil erosion by retaining and replanting vegetation and by siting development to minimize grading and land form alterations.
• Policy 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. • Policy 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. • Policy 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 singlefamily 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.
• Policy 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. 28 City of San Bruno. 2009. General Plan: Health & Safety Element. Available:
https://www.sanbruno.ca.gov/civicax/filebank/blobdload.aspx?BlobID=24020. Accessed: November 10, 2020.
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Geologic reports must be filed with the State Geologist by the City of San Bruno within 30 days of receipt.
The San Bruno General Plan also contains an Environmental Resources and Conservation Element, which prescribes mitigation for grading or construction on geologic units sensitive for paleontological resources.29
• Policy ERC-45: 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.
City of San Bruno Building Code
The Building Division of the City of San Bruno enforces the minimum standards found in the various codes adopted by the state through the Building Standards Commission and as adopted and amended by the San Bruno City Council. In particular, the City of San Bruno adopted by reference the California Building Standards Code (2019 edition) as the building code for the city. 30 San Bruno Municipal Code
The San Bruno Municipal Code does not reference paleontological resources or fossil resources except for those that may occur in recreational facilities such as parks and trails. 31 4.6.4 Impacts and Mitigation Measures
This section describes the impact analysis related to geology and soils for the proposed project, including Phase 1. It describes the methods and thresholds used to determine whether an impact would be significant. Feasible measures to mitigate (i.e., avoid, minimize, rectify, reduce, eliminate, or compensate for) significant impacts accompany each impact discussion, when necessary.
4.6.4.1 Significance Criteria
Based on Appendix G of the CEQA Guidelines, the proposed project would have a significant geology and soils impact if it would:
• Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
o Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault. Refer to Division of Mines and Geology Special Publication 42;
o Strong seismic ground shaking;
29 City of San Bruno. 2009. General Plan: Environmental Resources & Conservation Element. Available:
https://www.sanbruno.ca.gov/civicax/filebank/blobdload.aspx?BlobID=24019. Accessed: November 10, 2020. 30 City of San Bruno. n.d. Building Division. Available:
https://www.sanbruno.ca.gov/gov/city_departments/commdev/building_division/. Accessed: August 30, 2021. 31 San Bruno Municipal Code 9.20.040 Prohibited acts.
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o Seismic-related ground failure, including liquefaction; o Landslides;
• Result in substantial soil erosion or the loss of topsoil; • 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;
• Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property; • Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water; or • Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.
4.6.4.2 Approach to Analysis
Geology, Soils, and Seismicity
Evaluation of the project and Phase 1 development is based on the Design-Level Geotechnical Investigation prepared for the project, unless otherwise noted.32 The Design-Level Geotechnical Investigation provided design-level analysis for the parcels comprising the Specific Plan area inclusive of Phase 1. The Design-Level Geotechnical Investigation included field and laboratory programs to evaluate physical and engineering properties of the subsurface soils as well as engineering analysis to prepare recommendations for site work and grading, building foundations, flatwork, temporary shoring and dewatering, retaining walls, and pavements. While the DesignLevel Geotechnical Investigation did not cover the off-site improvement areas, given the close proximity of the off-site improvement areas to the Specific Plan area, it is assumed that similar conditions apply to these areas. Therefore, existing conditions and impacts are described for the project site as a whole. The geotechnical investigation concluded that the proposed project is feasible from a geotechnical standpoint, provided the recommendations included in the investigation are incorporated into project plans and specifications.
In the California Building Industry Association v. Bay Area Air Quality Management District case, decided in 2015,33 the California Supreme Court held that CEQA does not generally require lead agencies to consider how existing environmental conditions might affect a project, except where the project would significantly exacerbate an existing environmental condition. Accordingly, placing new development in an existing or future seismic hazard area or an area with unstable soils is not considered an impact under CEQA unless the project would significantly exacerbate the seismic hazard or unstable soil conditions. Therefore, the analysis below evaluates whether the proposed project would exacerbate existing or future seismic hazards or unstable soils at the project site and result in a substantial risk of loss, injury, or death. 32 Cornerstone Earth Group. 2020. Southline Development: Design-Level Geotechnical Investigation, Project Number 129.3.6. July 28, 2020.
33 California Building Industry Association v. Bay Area Air Quality Management District, 62 Cal.4th 369. Opinion filed December 17, 2015. Available: https://caselaw.findlaw.com/ca-supreme-court/1721100.html. Accessed:
August 30, 2021.
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Paleontological Resources
The Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources (Procedures)34 of the Impact Mitigation Guidelines Revision Committee of the Society of Vertebrate Paleontology include procedures for the investigation, collection, preservation, and cataloging of fossil-bearing sites. This includes the designation of paleontological sensitivity. The Procedures are widely accepted among paleontologists and followed by most investigators. The Procedures identify two key phases of paleontological resource protection: (1) assessment and (2) implementation. Assessment involves identifying the potential for a project site or area to contain significant, nonrenewable paleontological resources that could be damaged or destroyed by project excavation or construction. Implementation involves formulating and applying measures to reduce such adverse effects.
For the assessment phase, the Society of Vertebrate Paleontology uses one of four sensitivity categories for sedimentary rocks (i.e., high, undetermined, low, no potential) to define the level of potential.35
• High Potential. Assigned to geologic units from which vertebrate or significant invertebrate, plant, or trace fossils have been recovered as well as sedimentary rock units suitable for the preservation of fossils (middle Holocene and older fine-grained fluvial sandstones, fine-grained marine sandstones, etc.). Paleontological potential refers to the potential for yielding abundant fossils, a few significant fossils, or recovered evidence for new and significant taxonomic, phylogenetic, paleoecologic, taphonomic, biochronologic, or stratigraphic data. • Undetermined Potential. Assigned to geologic units for which little information is available concerning their paleontological content, geologic age, and depositional environment. In cases where no subsurface data already exist, paleontological potential can sometimes be assessed by subsurface site investigations.
• Low Potential. Field surveys or paleontological research may determine that a geologic unit has low potential for yielding significant fossils (e.g., basalt flows). • No Potential. Some geologic units have no potential to contain significant paleontological resources (e.g., high-grade metamorphic rocks [gneisses and schists] and plutonic igneous rocks [granites and diorites]).
The methods used to analyze potential impacts on paleontological resources and develop mitigation for the identified impacts followed the Society of Vertebrate Paleontology’s Procedures. • Assessment
o Identify the geologic units that would be affected by the project, based on the project’s depth of excavation—either at the ground surface or below the ground surface, defined as at least 5 feet bgs.
o Evaluate the potential of the identified geologic units to contain significant fossils (paleontological sensitivity).
34 Society of Vertebrate Paleontology. 2010. Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources. Available: http://vertpaleo.org/Membership/MemberEthics/SVP_Impact_ Mitigation_Guidelines.aspx. Accessed: September 29, 2020. 35 Ibid.
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o Identify impacts on paleontologically sensitive geologic units as a result of near-term and longer-term construction and operation that involve ground disturbance. o Evaluate impact significance.
• Implementation
o According to the identified degree of sensitivity, formulate and implement measures to mitigate potential impacts.
The potential of the project to affect paleontological resources is related to ground disturbance.
Geologic units at the project site were identified through California Geological Survey regional maps.36 A determination regarding the presence of paleontological resources in the units was based on the fossil record, as documented by the University of California Museum of Paleontology.37 After the records search, the paleontological sensitivity of the units was assessed according to the Procedures.38
For the purposes of this analysis, an impact on paleontological resources was considered significant, thereby requiring mitigation, if it would result in any of the following:
• Damage to, or destruction of, vertebrate paleontological resources. • Damage to, or destruction of, any paleontological resource that:
o Provides important information about evolutionary trends, including the development of biological communities;
o Demonstrates unusual circumstances in the history of life; o Represents a rare taxon or a rare or unique occurrence; o Is in short supply and in danger of being destroyed or depleted; o Has a special and particular quality, such as being the oldest of its type or the best available example of its type; or
• Provides information used to correlate strata for which it may be difficult to obtain other types of age information.
Buildout Scenario Studied (Office Scenario)
As discussed in Section 3.6.2.2 in Chapter 3, Project Description, of this EIR, the proposed project would allow for development of the commercial campus as either office or research-anddevelopment (R&D) uses, or a combination of both, up to a total buildout of 2,800,000 square feet.
For the purposes of program-level EIR analysis, two projected buildout scenarios were identified which would represent the reasonably foreseeable range of development expected to occur under 36 Wagner, D.L., E.J. Bortugno, and R.D. McJunkin. 1991. Geologic Map of the San Francisco-San Jose Quadrangle, California, 1:250,000. Available: https://www.conservation.ca.gov/cgs/Documents/Publications/RegionalGeologic-Maps/RGM_005A/RGM_005A_SanFrancisco-SanJose_1991_Sheet1of5.pdf. Accessed: September 29, 2020.
37 University of California Museum of Paleontology. 2020. Advanced Specimen Search, San Mateo County. Available:
https://ucmpdb.berkeley.edu/advanced.html. Accessed: September 29, 2020. 38 Society of Vertebrate Paleontology. 2010. Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources. Available: http://vertpaleo.org/Membership/MemberEthics/SVP_Impact_Mitigation_Guidelines.aspx. Accessed: September 29, 2020.
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the proposed project: the Office Scenario and the Life Sciences Scenario. Each section within Chapter 4, Environmental Setting, Impacts, and Mitigation, of this EIR analyzes the buildout scenario that represents the “worst-case” scenario for the resources area being analyzed. The “worst-case” scenario is the scenario with the greatest potential to result in significant impacts.
A project’s geological impacts are site-specific, and analysis of the potential impacts related to geology, soils, and paleontology is dependent on a number of factors, including the project location, the amount of ground that would be disturbed, the type of disturbance, the potential depth of excavation, and other factors. The two buildout scenarios would occur on the same parcels – within the Specific Plan area and the off-site improvement areas – so they present no difference in location that would impact the analysis. While the two potential buildout scenarios are similar in building footprint and lot coverage, the Office Scenario has the greatest building footprint (543,315 square feet versus 531,765 square feet) and lot coverage (49 percent versus 46 percent). While both scenarios would have the same area of ground disturbance (1,435,737 square feet) and maximum depth of excavation (31 feet below grade surface), the Office Scenario would result in a greater excavation volume than the Life Sciences Scenario (688,400 cubic yards versus 353,700 cubic yards, most of this quantity to be off-hauled). Therefore, the Office Scenario has a greater potential to result in significant geological and paleontological resource impacts and is analyzed as the “worst-case” scenario.
4.6.4.3 Impact Evaluation
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, strong seismic ground shaking, seismic-related ground failure, including liquefaction, or landslides. (Project: Less than Significant; Phase 1: Less than Significant) Project (Inclusive of Phase 1)
Fault Rupture
As discussed in Section 4.6.2, Environmental Setting, under Primary Seismic Hazards, the project site is not within an Alquist-Priolo earthquake fault zone, and no known potentially active fault exists in the vicinity of the project site. In addition, the geotechnical investigation found no evidence of active faulting on the project site and concluded that the risk of surface faulting and consequent secondary failure from previous unknown faults is very low. Therefore, the project, inclusive of Phase 1, would not exacerbate the risk of surface fault rupture. This impact would be less than significant. No mitigation is required.
Ground Shaking
As discussed in Section 4.6.2, Environmental Setting, under Primary Seismic Hazards, the project site is in a seismically active area. The project site is expected to experience periodic minor earthquakes and a major earthquake (i.e., moment magnitude greater than 6) during the operational life of the project .
39 The Design-Level Geotechnical Investigation recommended, based on site-specific 39 A “strong” earthquake is defined on the Modified Mercalli Intensity scale as an VI. It would be felt by all and cause damage to weak plaster, adobe buildings, and some masonry buildings. A “violent” earthquake is defined on the Modified Mercalli Intensity scale as a IX. It could cause some masonry buildings to collapse and other buildings shift off their foundations (see http://resilience.abag.ca.gov/shaking/mmi/).
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Geology and Soils
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investigation, that the project site be classified as Soil Classification D, which is described as a “stiff soil” profile. The proposed project would comply with the California Building Standards Code’s seismic requirements for the applicable soil classification, as enforced through the South San Francisco Building Code and (for the off-site improvements in San Bruno’s jurisdiction) the San Bruno Building Code. These requirements were established to reduce risks to life from damage to newly constructed buildings due to seismic hazards. Therefore, the project, inclusive of Phase 1, would not exacerbate the risk of ground shaking resulting from a seismic event. This impact would be less than significant. No mitigation is required.
Soil Liquefaction, Lateral Spreading, and Seismic Settlement As discussed in Section 4.6.2, Environmental Setting, under Secondary Seismic Hazards, risk of seismically induced liquefaction and associated settlement, lateral spreading, and seismic settlement is low at the project site. In addition, the proposed project would comply with the California Building Standards Code’s seismic requirements, as enforced through the South San Francisco Building Code, as well as the San Bruno Building Code for the off-site improvements in San Bruno’s jurisdiction.
These requirements which were established to reduce risks to life from damage to newly constructed buildings due to seismic hazards. Therefore, the project would not exacerbate the risk of liquefaction and associated settlement, lateral spreading, and seismic settlement resulting from a seismic event. This impact would be less than significant. No mitigation is required.
Seismically Induced Landslide
As discussed in Section 4.6.2, Environmental Setting, under Landslide, the project site is located on flat land and a gentle slope. It is not located in a landslide risk area; therefore, the potential for a landslide occurring at or near the project site is low. The project would comply with standard regulatory requirements—including completion of a detailed geotechnical investigation required by the California Building Code, which are adopted by reference under the South San Francisco Building Code and the City of San Bruno Building Code. Therefore, the project would result in a lessthan-significant impact related to landslides. No mitigation is required.
Impact GEO-2: The project would not result in substantial soil erosion or the loss of topsoil. (Project: Less than Significant; Phase 1: Less than Significant) Project (Inclusive of Phase 1)
The project site slopes gently from west to east and lies, as discussed in Section 4.6.2, Environmental Setting, between 17 and 33 feet above mean sea level. Construction of the proposed project (inclusive of the off-site improvement areas) would require grading or disturbing an area of approximately 33 acres and excavating up to approximately 688,400 cubic yards of soil. While the proposed project would involve changes to the existing grade, no unprotected, exposed soils at risk of substantial erosion would remain on the project site. The utility and circulation improvements proposed for the off-site improvement areas would involve surface grading and trenching for utilities but would not involve major excavation.
As discussed in Section 4.9, Hydrology and Water Quality, construction activities associated with the proposed project must comply with the National Pollutant Discharge Elimination System (NPDES) Construction General Permit, the Municipal Regional Permit (MRP), the City’s General Plan and Municipal Code, and, in the case of the off-site improvement areas in San Bruno, the City of San Bruno’s General Plan and Municipal Code. These requirements include preparation and City of South San Francisco
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Geology and Soils
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implementation of a stormwater pollution prevention plan (SWPPP) that incorporates best management practices (BMPs), such as the installation of erosion control measures (e.g., silt fences, staked straw bales/wattles, silt/sediment basins or traps), geofabric, sandbag dikes, covers for stockpiles, or storage precautions for outdoor material storage areas.
In addition, implementation of the proposed project would involve a change in the proportion of impervious and pervious surfaces from 94 percent impervious/6 percent pervious to 77 percent impervious/23 percent pervious, therefore resulting in an increase in pervious surface area across the project site (see Section 4.9, Hydrology and Water Quality). Site grading within the Specific Plan area would create two drainage areas to provide appropriate drainage for Specific Plan development: Drainage Area A, which drains to the south and corresponds with the portion of the Phase 1 site located in the Specific Plan area, and Drainage Area B, which drains to the north and corresponds with the future phases in the Specific Plan area. Consistent with C.3 requirements in the MRP and the City of South San Francisco requirements, stormwater runoff from the Specific Plan area will be treated through low impact development (LID) methods, which may consist of bioretention basins, flow through planters, pervious permeable pavements, and other site design features intended to manage stormwater runoff flows from the Specific Plan area and to reduce stormwater pollution. Off-site storm water treatment methods would also comply with C.3 requirements in the MRP and local stormwater requirements of the jurisdiction in which the improvements are located. These project features would avoid substantial soil erosion by implementing measures that would provide adequate drainage and stormwater runoff flow management for surface water.
The proposed improvements within the City of South San Francisco would comply with the City of South San Francisco’s standard conditions of approval and grading permit requirements. The City of South San Francisco’s grading permit requires applicants to have erosion control measures in place, such as de-silting basins, silt fences, asphaltic emulsions, hay bales, fabric and sand filters, swales, and/or sumps. In the case of the off-site improvement areas in San Bruno, the City of San Bruno’s conditions of approval require a grading permit prior to any on-site grading activity. The City of San Bruno’s grading permit requires applicants to install sandbags or other erosion control measures to prevent silt runoff to public roadways. In addition, all construction activities would comply with standard construction BMPs.
Therefore, with adherence to the BMPs included in the SWPPP, compliance with the City of South San Francisco’s standard conditions of approval and the City of San Bruno’s conditions of approval regarding grading, compliance with City of South San Francisco’s and City of San Bruno’s requirements for grading permits, adherence to standard construction BMPs, and compliance with the California Building Standards Code, impacts related to the proposed project’s potential to result in substantial soil erosion would be less than significant. No mitigation is required.
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Environmental Setting, Impacts, and Mitigation
Geology and Soils
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Impact GEO-3: The project would not be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project. (Project: Less than Significant; Phase 1:
Less than Significant)
Project (Inclusive of Phase 1)
Unstable Soils as a Result of High Groundwater
As discussed in Section 4.6.2, Environmental Setting, the depth to groundwater on the project site ranges from approximate 8 to 27 feet bgs. The Design-Level Geotechnical Investigation prepared for the project recommends a high groundwater level of 8 feet be used for project design. Deep excavations proposed within the Specific Plan area may extend into saturated clay and sand that may be too saturated to hold an applied load. Heavy construction equipment could potentially make this material unstable. Therefore, as discussed in the Design-Level Geotechnical Investigation, temporary dewatering is recommended during construction of buildings within the Specific Plan area to a depth of at least 5 feet below the bottom of the building foundation.40 A bridging layer, such as crushed rock, may also be needed below the foundation. Shoring and tie backs may also be necessary during construction. Specifically, the Design-Level Geotechnical Investigation recommends that excavations less than 30 feet deep be supported by soldier beams and tiebacks, sheet piles, or soil mixed walls with internal bracing or tiebacks, or other methods. Excavations greater than 30 feet deep should be shored with less pervious walls consisting of soldier pile tremie concrete (SPTC) or mixed-in-place soil/cement. Below-grade parking level walls within the Specific Plan area would need to be permanently waterproofed and designed for earth pressures that include hydrostatic pressure. Dewatering would not be required for construction in off-site improvement areas. As discussed above, issuance of a grading permit from the Cities of South San Francisco and/or San Bruno, for grading work with each respective jurisdiction, would be required prior to commencing grading activity. Both jurisdictions require preparation of a geotechnical report prior to commencing grading or excavation activity which would further analyze the risk of instability resulting from excavations in areas with high ground water and would provide recommendations for dewatering, shoring, and waterproofing, as may be required. Compliance with the above Design Level Geotechnical Investigation recommendations and grading permit requirements, which would be required as conditions of approval for the proposed project and future development under the Specific Plan, would reduce any risk related to unstable soils as a result of high groundwater levels to a less-than-significant level. No mitigation is required.
Subsidence as a Result of Dewatering
The proposed project includes excavation activity and development of subterranean parking facilities within the Specific Plan area at a maximum depth of 31 feet bgs. The design groundwater depth of 8 feet bgs, the shallowest depth to groundwater encountered during subsurface investigations, was used for geotechnical analysis.41 High ground water levels can have impacts on grading which may require dewatering. Because the depth to groundwater is above the maximum depth of excavation (31 feet bgs for Phase 1), dewatering during construction of below-grade 40 Cornerstone Earth Group. 2020. Southline Development: Design-Level Geotechnical Investigation, Project Number 129.3.6. July 28, 2020.
41 Cornerstone Earth Group. 2020. Southline Development: Design-Level Geotechnical Investigation, Project Number 129.3.6. July 28, 2020.
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facilities, specifically the subterranean parking structures, would be required. No dewatering would be required in the off-site improvement areas in the City of San Bruno.
Dewatering, if it is extensive, can result in subsidence. Assuming the groundwater drawdown will be from the design high groundwater level of 8 feet bgs down to 5 feet below the bottom of the excavations within the Specific Plan area, the geotechnical report prepared for the project estimated that settlement as a result of subsidence of the ground surface could be 1.5 to 2 inches for the areas of deepest excavations.
42 However, this potential for subsidence is not anticipated to result in soils becoming unstable as a result of the project dewatering. The City of South San Francisco, in connection with issuance of grading permits for work within the Specific Plan area, would evaluate whether alternative shoring methods such as tied back slurry walls or soil mixed curtain walls should be utilized to reduce the potential for subsidence.43 Prior to commencing applicable grading activities, the proposed project would be required to secure a grading permit from the City of South San Francisco for work within its jurisdiction and/or the City of San Bruno for work within its jurisdiction, depending on the location. These grading permits require a soils report and a geotechnical report for issuance of the grading permit. The geotechnical report would address then need for dewatering, shoring, and/or waterproofing measures as may be required. The project would be required, through conditions of approval, to comply with the recommendations in the soils report and geotechnical investigation regarding the design of foundations, floor slabs, and other geotechnical aspects of this project. In addition, the proposed project would comply with applicable regulations required by the California Building Code, which are adopted by reference under the South San Francisco Building Code and the City of San Bruno Building Code, as applicable for work conducted within each respective city. Therefore, impacts related to potential settlement and subsidence due to dewatering related to project constructionin soil that is unstable, or could become unstable as a result of such construction, would be less than significant. No mitigation is required.
Static Settlement as a Result of Structural Loads
The project would construct commercial buildings ranging up to seven stories and a parking garage up to nine stories over one or two levels of below-ground parking. When vertical stresses resulting from the structural loads of buildings are applied to soft or loose soil strata, the compression can result in static settlement. The Design Level Geotechnical Investigation found that construction of the project could result in between ¾ to 1 inch of total settlement, depending on the structure and the specific location within the project site. This amount of settlement is typically tolerable on shallow foundations, and the Design Level Geotechnical Investigation concluded that mat foundation44 would provide a feasible support for the proposed buildings. In addition, the Design Level Geotechnical Investigation found undocumented fill between 2 to 5 feet in some borings and as far as 22 feet bgs at the 50 and 54 Tanforan Avenue location. If undocumented fill is not replaced by engineered soils, it has the potential to exacerbate static settlement; therefore, the Design Level Geotechnical Investigation recommended that undocumented fill be replaced by engineered fill in 42 Cornerstone Earth Group. 2020. Southline Development: Design-Level Geotechnical Investigation, Project Number 129.3.6. July 28, 2020.
43 Cornerstone Earth Group. 2020. Southline Development: Design-Level Geotechnical Investigation, Project Number 129.3.6. July 28, 2020.
44 A mat foundation is a continuous thick concrete slab on the soil that supports the structure constructed on it and that increases the soil bearing capacity.
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order to avoid impacts related to static settlement. As discussed above, the project would be required to prepare a geotechnical report which would further analyze the risk of static settlement and would provide recommendations in terms of foundation design which would reduce any risk to a less-than-significant level. No mitigation is required.
Impact GEO-4: The project would not be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property. (Project: Less than Significant; Phase 1: Less than Significant) Project (Inclusive of Phase 1)
As discussed in Section 4.6.2, Environmental Setting, the project site, including the off-site improvement areas in San Bruno, includes soils with a moderate expansion potential. Expansive soils may also underlie surficial soils.
The project has been designed to respond to existing soil conditions by incorporating recommendations from the Design-Level Geotechnical Investigation. To address the potential impact of expansive soils, the Design-Level Geotechnical Investigation recommended that slabs-ongrade should be constructed with sufficient reinforcement and be supported on a layer of nonexpansive fill to reduce potential damage to the planned structures from expansive soils. The Design-Level Geotechnical Investigation further recommended that footings extend below the zone of seasonal moisture fluctuation and stressed the importance of using drainage to limit moisture changes in surficial soils. The project would comply with standard regulatory requirements— including completion of a detailed geotechnical investigation as may be required for issuance of grading permits, and compliance with the California Building Code, which is adopted by reference under the South San Francisco Building Code and the City of San Bruno Building Code. Therefore, the project would result in a less-than-significant impact related to expansive soils. No mitigation is required.
Impact GEO-5: The project would not have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water. (Project: No Impact; Phase 1: No Impact) Project (Inclusive of Phase 1)
The proposed project would connect to South San Francisco’s sewer and stormwater collection and treatment system, including certain upgrades and modifications to that system, as described in Chapter 3, Project Description. Therefore, the proposed project, inclusive of Phase 1, would not use a septic or alternative water disposal system and would have no impact relating to such systems. No mitigation is required.
Impact GEO-6: The project would not directly or indirectly destroy a unique paleontological resource or site or unique geologic feature. (Project: Less than Significant with Mitigation; Phase 1: Less than Significant with Mitigation)
As discussed in Section 4.6.2, Environmental Setting, under Paleontological Resources, geologic units underlying the project site, specifically the Colma Formation and Merced Formation, are known to have yielded significant vertebrate fossils. Therefore, the paleontological sensitivity of these geologic units is considered to be high, and these geologic units have the potential to contain significant fossils at the project site. Although the project site is already substantially disturbed and City of South San Francisco
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contains artificial fill, in certain portions of the project site, artificial fill extends as little as 2 feet bgs, at which point native sediments are encountered.
Because paleontological resources are located below the ground surface, ground disturbances such as excavating, grading, and resurfacing could affect any paleontological resources that may be present. Therefore, it is possible for construction activities affecting areas at a depth greater than 2 feet bgs to directly or indirectly destroy any paleontological resources within the project site.
Project
Excavation for the new subterranean parking garage is proposed to a depth of 31 feet bgs. Across the project site, an estimated 1,435,737square feet of ground surface would be disturbed. In addition, shallow ground disturbance associated with the improvements in the off-site improvement areas (discussed in Section 3.6.2, Project Characteristics, in Chapter 3, Project Description) may reach depths greater than 2 feet bgs and therefore has potential to disturb paleontological resources, including direct or indirect destruction. An estimated 688,400 cubic yards of soil would be excavated. In addition, utility and circulation improvements in the off-site improvement areas would require surface grading and trenching for utilities.
Destruction of any paleontological resources present within the project site would constitute a significant impact. Implementation of Mitigation Measure GEO-1 would reduce this potentially significant impact on paleontological resources to less than significant with mitigation by providing training for construction personnel related to the possibility of encountering fossils, requiring work to halt within 25 feet of any potential fossil find, and requiring a qualified paleontologist to evaluate and excavate any such find. Therefore, the impact would be less than significant with mitigation.
Mitigation Measure GEO-1: Halt Construction Activity in Case of Finding Paleontological Resources, Evaluate Find, and Excavate Find (All Phases) In the event that previously unidentified paleontological resources are uncovered during site preparation, excavation, or other construction activity, the project applicant or successor shall cease all such activity within 25 feet of the discovery or ensure that all such activity within 25 feet of the discovery ceases until the resources have been evaluated by a qualified professional and specific measures can be implemented to protect these resources in accordance with Sections 21083.2 and 21084.1 of the California Public Resources Code. If the find is potentially significant, the project applicant or successor shall ensure a qualified paleontologist shall excavate the find in compliance with state law, keeping project delays to a minimum. If the qualified paleontologist determines the find is not significant then proper recordation and identification shall ensure and the project will continue without delay.
Phase 1
Phase 1 development includes excavation for the new subterranean parking garage, which is proposed to a depth of 31 feet bgs. An estimated 740,000 square feet of ground would be disturbed during construction of Phase 1. In addition, Phase 1 would require a maximum depth of excavation reaching approximately 31 feet bgs. For areas outside the deep basement excavation, maximum depth of excavation would extend to approximately 9 feet bgs to accommodate utility trenching.
This excavation has potential to disturb paleontological resources, including direct or indirect destruction. An estimated 293,000 cubic yards of soil would be excavated.
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Geology and Soils
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Destruction of any paleontological resources present at the Phase 1 site would constitute a significant impact. Implementation of Mitigation Measure GEO-1 would reduce this potentially significant impact on paleontological resources to less than significant with mitigation by providing training for construction personnel related to the possibility of encountering fossils, requiring work to halt within 25 feet of any potential fossil find in case of finding paleontological resources, and requiring a qualified paleontologist to evaluate and excavate any such find.
4.6.4.4 Cumulative Impacts
Impact C-GEO-1: The project, inclusive of Phase 1, together with the cumulative projects identified would not result in a significant cumulative impact on geology and soils. (Project:
Less than Significant; Phase 1: Less than Significant)
In general, a project’s potential impacts related to geology and soils are individual and localized, depending on the project site and underlying soils. Each structure will have different levels of excavation, cut-and-fill work, and grading, which would affect local geologic conditions in different ways. Therefore, the geographic context for cumulative impacts to geology and soils is site-specific.
Past, present, and reasonably foreseeable future projects within a 0.5-mile radius of the project site are identified in Section 4.1.6, Approach to Cumulative Impact Analysis, of this EIR and shown in Figure 4.1-1. The cumulative projects could require various levels of excavation or cut-and-fill, which would affect local geologic conditions. However, the cumulative projects would be required to go through environmental and regulatory review and comply with local and state building codes. In addition, each project would also be required to have a site-specific geotechnical investigation performed, which would provide design recommendations to reduce each project’s impacts related to geologic and seismic safety. Similar to the proposed project, mandatory seismic safety standards, design review and conditions of approval would apply to the reasonably foreseeable future projects.
For these reasons, the proposed project, in combination with other past, present, and reasonably foreseeable future projects, would not result in a cumulative geology and soils impact. The cumulative impact would be less than significant. No mitigation is required.
Impact C-GEO-2: The project, inclusive of Phase 1, together with the cumulative projects identified would not result in a cumulatively considerable contribution to significant cumulative impacts on paleontological resources. (Project: Less than Cumulatively Considerable; Phase 1: Less than Cumulatively Considerable) The geographic context for paleontological resources is the full extent of geologic units with high or unknown paleontological sensitivity that underlie the construction area. For purposes of evaluating potential cumulative impacts on paleontological resources, the cumulative projects are those located within approximately 0.5 mile of the project site, as described in Section 4.1.6, Approach to Cumulative Impact Analysis, of this EIR and shown in Figure 4.1-1. The cumulative projects in the geographic context for paleontological resources would be constructed on infill sites in highly disturbed areas. It is likely that the cumulative projects would be constructed on sites where the ground surface has been disturbed and/or covered with fill and gravel. However, deep excavation could reach areas of undisturbed native sediments that could contain significant paleontological resources. Reasonably foreseeable projects planned or proposed for construction on these sensitive geologic units could encounter paleontological resources. Therefore, the cumulative impact could be significant because the reasonably foreseeable projects would likely involve ground-disturbing activities that could uncover resources related to resources that could be uncovered by the project.
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However, implementation of Mitigation Measure GEO-1 would ensure that the proposed project’s contribution to cumulative impacts on paleontological resources would be less than cumulatively considerable because it would ensure that information that may be recoverable from any identified paleontological resource would be recorded and properly curated as required under state law.
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Greenhouse Gas Emissions
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4.7 Greenhouse Gas Emissions
4.7.1 Introduction
This section evaluates the potential impacts related to the construction and operation of the Southline Specific Plan and off-site improvements (proposed project), including the first phase of development under the Specific Plan (Phase 1), on greenhouse gas (GHG) emissions. This section also describes existing conditions at the project site, including the Phase 1 site, as well as the regulatory framework for this analysis. The impacts of the proposed project are generally analyzed at a program level, and the impacts of Phase 1 are analyzed at a project level. Impacts resulting from implementation of the proposed project, impacts resulting from implementation of Phase 1, and cumulative impacts are described. Feasible mitigation measures, where applicable, are also described. Relevant technical documentation used in this analysis includes GHG modeling files and calculations (Appendix 4.2-1).
Issues identified in response to the Notice of Preparation (NOP) (Appendix 1) were considered in preparing this analysis. No questions or concerns related to GHG emissions were raised in the responses to the NOP.
4.7.2 Environmental Setting
4.7.2.1 Project Site and Phase 1 Site
As described in more detail in Chapter 3, Project Description, the project site comprises the proposed Specific Plan area and the off-site improvement areas. The Phase 1 site is in the southern portion of the Specific Plan area. The Specific Plan area currently includes a variety of office, industrial, warehouse, and storage facilities as well as surface parking spaces. The off-site improvement areas consist of rights-of-way and easements in the cities of South San Francisco and San Bruno that are developed with circulation and utility infrastructure. Because the project site boundary is inclusive of the boundaries of the Phase 1 site and the offsite improvement areas, for purposes of the GHG emissions analysis, the environmental setting for the project site is considered to be the same as the environmental setting for the Phase 1 site and the offsite improvement areas.
The following sections discuss the environmental setting related to GHG emissions and climate change.
4.7.2.2 Global Climate Change
The process known as the greenhouse effect keeps the atmosphere near Earth’s surface warm enough for the successful habitation of humans and other life forms. The greenhouse effect is created by sunlight that passes through the atmosphere. Some of the sunlight striking Earth is absorbed and converted to heat, which warms the surface. The surface emits a portion of this heat as infrared radiation, some of which is re-emitted toward the surface by GHGs. Human activities that generate GHGs increase the amount of infrared radiation absorbed by the atmosphere, thereby enhancing the greenhouse effect and amplifying the warming of Earth.
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Greenhouse Gas Emissions
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Increases in fossil fuel combustion and deforestation have exponentially increased concentrations of GHGs in the atmosphere since the Industrial Revolution. 1 Rising atmospheric concentrations of
GHGs in excess of natural levels result in increasing global surface temperatures—a process commonly referred to as global warming. Higher global surface temperatures, in turn, result in changes to Earth’s climate system, including increased ocean temperatures and acidity, reduced sea ice, variable precipitation, and increased frequencies and intensities for extreme weather events.2 Large-scale changes to Earth’s system are collectively referred to as climate change.
The Intergovernmental Panel on Climate Change (IPCC) was established by the World Meteorological Organization and United Nations Environment Programme to assess scientific, technical, and socioeconomic information relevant to the understanding of climate change, its potential impacts, and options for adaptation and mitigation. The IPCC estimates that humaninduced warming reached approximately 1°C above pre-industrial levels in 2017 and is increasing at
0.2°C per decade. Under the current nationally determined estimates of contributions of GHGs from each country until 2030, global warming is expected to rise to 3°C by 2100, with warming to continue afterwards.3 Large increases in global temperatures could have substantial adverse effects on the natural and human environments in California and worldwide.
4.7.2.3 Greenhouse Gases
The principal anthropogenic (human-made) GHGs contributing to global warming are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), and fluorinated compounds, including sulfur hexafluoride, hydrofluorocarbons, and perfluorocarbons. Water vapor, the most abundant GHG, is not included in this list because its natural concentrations and fluctuations far outweigh its anthropogenic sources.
The primary GHGs of concern associated with the project are CO2, CH4, and N2O. The principal characteristics of these pollutants are discussed below.
CO2 enters the atmosphere through fossil fuel (i.e., oil, natural gas, coal) combustion, solid waste decomposition, plant and animal respiration, and chemical reactions (e.g., from cement manufacturing). CO2 is also removed from the atmosphere (or sequestered) when it is absorbed by plants as part of the biological carbon cycle.
CH4 is emitted during the production and transport of coal, natural gas, and oil. These emissions also result from livestock operations and other agricultural practices as well as the decay of organic waste in municipal solid waste landfills.
N2O is emitted during agricultural and industrial activities and from the combustion of fossil fuels and solid waste.
Methods have been set forth to describe emissions of GHGs in terms of a single gas to simplify reporting and analysis. The most commonly accepted method for comparing GHG emissions is the 1 Intergovernmental Panel on Climate Change. 2007. Climate Change 2007: The Physical Science Basis.
Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change. Available: https://www.ipcc.ch/site/assets/uploads/2018/05/ar4_wg1_full_report-1.pdf. Accessed:
November 9, 2020.
2 Intergovernmental Panel on Climate Change. 2018. Global Warming of 1.5°C. Contribution of Working Group I, II, and III. Available: https://www.ipcc.ch/sr15/. Accessed: November 9, 2020. 3 Ibid.
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global warming potential (GWP) methodology, as defined in IPCC reference documents. IPCC defines the GWP of various GHG emissions on a normalized scale that recasts all GHG emissions in terms of carbon dioxide equivalent (CO2e), which compares the gas in question to that of the same mass of CO2 (CO2 has a global warming potential of 1 by definition).
Table 4.7-1, p. 4.7-3, lists the global warming potential of CO2, CH4, and N2O and their lifetimes in the atmosphere.
Table 4.7-1. Lifetimes and Global Warming Potentials of Key Greenhouse Gases Greenhouse Gas
Global Warming Potential
(100 years)
Lifetime
(years)
CO2 1 50–200
CH4 25 9–15
N2O 298 121
Source: California Air Resources Board. 2020a. Global Warming Potentials. Last reviewed: June 22. Available:
https://www.arb.ca.gov/cc/inventory/background/gwp.htm#transition. Accessed: August 17, 2020.
CH4 = methane
CO2 = carbon dioxide
N2O = nitrous oxide
All GWPs used for the California Air Resources Board’s (CARB’s) GHG inventory and for assessing attainment of the state’s 2020 and 2030 reduction targets are considered over a 100-year timeframe (as shown in Table 4.7-1, p. 4.7-3). However, CARB recognizes the importance of short-lived climate pollutants as well as the importance of reducing these emissions to achieve the state’s overall climate change goals. Short-lived climate pollutants have atmospheric lifetimes on the order of a few days to a few decades, and their relative climate-forcing impacts, when measured in terms of how they heat the atmosphere, can be tens, hundreds, or even thousands of times greater than that of CO2.
4 Because of their short-term lifespan and warming impact, short-lived climate pollutants are measured in terms of CO2e, using a 20-year time period. The use of GWPs with a time horizon of 20 years captures the importance of short-lived climate pollutants and gives a better perspective on the speed at which emission controls will affect the atmosphere relative to CO2 emission controls.
The Short-Lived Climate Pollutant Reduction Strategy, discussed in Section 4.7.3, Regulatory Framework, addresses issues associated with CH4, hydrofluorocarbon gases, and anthropogenic black carbon. CH4 has a lifetime of 12 years and a 20-year GWP of 72. Hydrofluorocarbon gases have lifetimes of 1.4 to 52 years and a 20-year GWP of 437 to 6,350. Anthropogenic black carbon has a lifetime of a few days to weeks and a 20-year GWP of 3,200.5
4.7.2.4 Greenhouse Gas Reporting
A GHG inventory is a quantification of all GHG emissions and sinks6 within a selected physical and/or economic boundary. GHG inventories can be performed on a large scale (e.g., for global and national entities) or on a small scale (e.g., for a building or person). Several agencies have developed 4 California Air Resources Board. 2017b. Short-Lived Climate Pollutant Reduction Strategy. Available:
https://ww2.arb.ca.gov/ sites/default/files/2018-12/final_slcp_report%20Final%202017.pdf. Accessed:
November 9, 2020.
5 Ibid.
6 A GHG sink is a process, activity, or mechanism that removes a GHG from the atmosphere.
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tools to quantify emissions from certain sources. Table 4.7-2, p. 4.7-3, outlines the most recent global, national, statewide, and local GHG inventories to help contextualize the magnitude of potential project-related emissions.
Table 4.7-2. Global, National, State, Regional, and Local Greenhouse Gas Emissions Inventories Emissions Inventory CO2e (metric tons)
2010 IPCC Global GHG Emissions Inventory 52,000,000,000 2018 EPA National GHG Emissions Inventory 6,676,600,000 2018 CARB State GHG Emissions Inventory 425,300,000
2015 BAAQMD GHG Emissions Inventory 85,000,000
2005 South San Francisco Inventory 548,600
Sources:
Intergovernmental Panel on Climate Change. 2014. Climate Change Synthesis Report. Available:
https://www.ipcc.ch/site/assets/uploads/2018/02/SYR_AR5_FINAL_full.pdf. Accessed: November 9, 2020; U.S. Environmental Protection Agency. 2019. Inventory of U.S. Greenhouse Gas Emissions and Sinks, 1990–2017.
Available: https://www.epa.gov/sites/production/files/2019-02/documents/us-ghg-inventory-2019-main-text.pdf.
Accessed: September 14, 2021;
California Air Resources Board. 2020b. California Greenhouse Gas Emissions for 2000 to 2018. Available:
https://ww3.arb.ca.gov/cc/inventory/pubs/reports/2000_2018/ghg_inventory_trends_00-18.pdf. Accessed:
November 9, 2020;
Bay Area Air Quality Management District. 2017b. Final 2017 Clean Air Plan. Adopted: April 19. Available:
http://www.baaqmd.gov/~/media/files/planning-and-research/plans/2017-clean-air-plan/attachment-a_- proposed-final-cap-vol-1-pdf.pdf. Accessed: November 9, 2020; City of South San Francisco. 2014. City of South San Francisco Climate Action Plan. Adopted: February 13. Available:
https://www.ssf.net/home/showdocument?id=1318. Accessed: November 9, 2020.
Notes:
CO2e = carbon dioxide equivalent; IPCC = Intergovernmental Panel on Climate Change; EPA = U.S. Environmental Protection Agency; BAAQMD = Bay Area Air Quality Management District; CARB = California Air Resources Board
4.7.2.5 Potential Climate Change Effects
Climate change is a complex process that has the potential to alter local climatic patterns and meteorology. Although modeling indicates that climate change will result in sea-level rise (both globally and regionally) as well as changes in climate and rainfall, among other effects, there remains uncertainty about characterizing precise local climate characteristics and predicting precisely how various ecological and social systems will react to any changes in the existing climate at the local level. Regardless of this uncertainty, it is widely understood that substantial climate change is expected to occur in the future, although the precise extent will take further research to define. Specifically, significant impacts from global climate change worldwide and in California include:
⚫ Declining sea ice and mountain snowpack levels, thereby increasing sea levels and sea surface evaporation rates, with a corresponding increase in atmospheric water vapor due to the atmosphere’s ability to hold more water vapor at higher temperatures; 7 7 California Natural Resources Agency. 2018. California’s Fourth Climate Change Assessment, Statewide Summary Report. Available: http://www.climateassessment.ca.gov/state/docs/20190116-StatewideSummary.pdf.
Accessed: November 9, 2020.
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⚫ Rising average global sea levels, primarily due to thermal expansion and the melting of glaciers, ice caps, and the Greenland and Antarctic ice sheets;8
⚫ Changing weather patterns, including changes in precipitation, ocean salinity, and wind patterns, along with the more energetic aspects of extreme weather, including droughts, heavy precipitation, heat waves, extreme cold, and intense tropical cyclones;9 ⚫ Declining snowpack levels in the Sierra Nevada; snowpacks account for approximately half of the surface water storage in California but are projected to decline by 70 to as much as 90 percent over the next 100 years;
10 ⚫ Increasing the number of days that are conducive to ozone formation (e.g., clear days with intense sun light) by 25 to 85 percent, depending on the future temperature scenario, by the end of the 21st century in high ozone areas, including Southern California;11 ⚫ Increasing the potential for erosion along California’s coastlines as well as seawater intrusion at the Sacramento Delta and associated levee systems due to the rise in sea level; and12 ⚫ Exacerbating the severity of drought conditions in California such that durations and intensities are amplified, ultimately increasing the risk of wildfires and consequential damage. 13 Under changing climate conditions, agriculture is projected to experience lower crop yields because of extreme heat waves, heat stress, increased water needs associated with crops and livestock (particularly during dry and warm years), and new and changing pest and disease threats. 14 The impacts of climate change, such as increased heat-related events, droughts, and wildfires, pose direct and indirect risks to public health because people will experience earlier deaths and worsening illnesses. Indirect impacts on public health include an increase in vector-borne diseases, stress and mental trauma due to extreme events and disasters, economic disruptions, and residential displacement.
15 4.7.3 Regulatory Framework
This section provides a summary of the GHG emissions plans and policies of the City of South San Francisco (City) as well as regional, state, and federal agencies that have policy and regulatory control over the project site.
4.7.3.1 International
In 2015, the twenty-first session of the Conference of Parties took place in Paris, France. The session included representatives from 196 parties to the United Nations Framework Convention on Climate Change. The Paris Climate Agreement included limiting global temperature increases to well below 8 Ibid.
9 Intergovernmental Panel on Climate Change. 2018. Global Warming of 1.5°C. Contribution of Working Group I, II, and III. Available: https://www.ipcc.ch/sr15/. Accessed: November 9, 2020. 10 Ibid.
11 Ibid.
12 Ibid.
13 Ibid.
14 Ibid.
15 Ibid.
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2°C, establishing binding commitments so all parties make Nationally Determined Contributions (NDCs), pursuing domestic policies to achieve the NDCs, and having all countries report regularly regarding their emissions and progress made in implementing and achieving their NDCs. In April 2016, 174 states and the European Union signed the agreement, including the United States.
However, on November 4, 2019, former President Donald Trump formally notified the United Nations that the United States would withdraw from the Paris Climate Agreement. The United States then entered a 1-year process for exiting the deal, which officially occurred on November 4, 2020; however, President Joseph Biden, who assumed office on January 20, 2021, submitted the United States instrument of acceptance to re-join the agreement on his first day in office. 16 President
Biden’s Executive Order No. 14008, released on January 27, 2021, begins the process of developing the United States’ NDCs and ratifying the Kigali Amendment, among other things. The Kigali Amendment is a 2016 global pact under the Montreal Protocol to phase down climate-warming hydrofluorocarbons (HFCs) over the coming decades. It will ultimately fall to the United States Senate to determine whether to move forward with Kigali ratification.
The Under2 Coalition is an international coalition of jurisdictions that signed the Global Climate Leadership Memorandum of Understanding (Under2 MOU), following former President Trump’s decision to withdraw from the Paris agreement. The Under2 MOU aims to limit global warming to 2°C, limit GHGs to 80 to 95 percent below 1990 levels, and/or achieve an annual per capita emissions goal of less than 2 metric tons by 2050. The Under2 MOU has been signed or endorsed by more than 220 jurisdictions, representing 32 countries and six continents. Included among the jurisdictions is California.
4.7.3.2 Federal
There is currently no overarching federal law specifically related to climate change or the reduction of GHG emissions. During the Obama administration, EPA worked to develop regulations under the Clean Air Act. Settlement agreements among EPA, several states, and nongovernmental organizations have been used to address GHG emissions from electric generating plants and refineries. In addition, EPA issued an Endangerment Finding and a Cause or Contribute Finding. EPA has also adopted a Mandatory Reporting Rule and Clean Power Plan. Under the Clean Power Plan, EPA issued regulations to control CO2 emissions from new and existing coal-fired power plants.
However, on February 9, 2016, the Supreme Court issued a stay regarding these regulations pending litigation. In addition, former EPA Administrator Scott Pruitt signed a measure to repeal the Clean Power Plan. The fate of the proposed regulations is uncertain, given the pending deliberations in federal courts.
Corporate Average Fuel Economy Standards
As discussed in Section 4.2, Air Quality, of this draft environmental impact report (EIR), the National Highway Traffic Safety Administration (NHTSA) sets Corporate Average Fuel Economy (CAFE) standards to improve average fuel economy and reduce GHG emissions generated by cars and lightduty trucks. The standards were updated in October 2012 to apply to new passenger cars, lightduty trucks, and medium-duty passenger vehicles, covering model years 2017 through 2025. The standards are equivalent to 54.5 miles per gallon.
16 U.S. White House. 2021. Paris Climate Agreement. Statements and Releases. January. Available:
https://www.whitehouse.gov/briefing-room/statements-releases/2021/01/20/paris-climate-agreement/.
Accessed: February 3, 2021.
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On August 2, 2018, NHTSA and EPA proposed to amend the fuel efficiency standards for passenger cars and light-duty trucks and establish new standards, covering model years 2021 through 2026, by maintaining the current model year 2020 standards through 2026 (i.e., Safer Affordable FuelEfficient [SAFE] Vehicles Rule). The Clean Air Act allows California to seek a waiver of the preemption which prohibits states from enacting emission standards for new motor vehicles. EPA had granted California waivers for decades based on its long-standing determination that California’s standards are at least as protective as federal standards, they are needed to meet compelling and extraordinary conditions, and are not inconsistent with Clean Air Act provisions related to technical feasibility and lead time to manufacturers. However, EPA and NHTSA published their decisions to withdraw California’s waiver and finalize regulatory text related to the preemption on September 27, 2019 (84 Federal Register 51310). Part One of the SAFE Vehicles Rule went into effect on November 26, 2019, and Part Two went into effect on March 30, 2020. The SAFE Vehicles Rule will decrease the stringency of the previously adopted CAFE standards by 1.5 percent each year through model year 2026 compared with the standards issued in 2012, which would have required about 5 percent annual increases. California, 22 other states, the District of Columbia, and two cities filed suit against the proposed One National Program Rule on September 20, 2019 (California et al. v. United States Department of Transportation et al., 1:19-cv-02826, U.S. District Court for the District of Columbia). The lawsuit requests a “permanent injunction prohibiting defendants from implementing or relying on the preemption regulation” but does not stay its implementation during legal deliberations.
On February 11, 2020, California et al. v. United States Department of Transportation et al. was stayed pending resolution of the related litigation of Union of Concerned Scientists v. National Highway Traffic Safety Administration (19-1230, U.S. Court of Appeals for the District of Columba Circuit). The Union of Concerned Scientists, Environmental Defense Fund, and other groups filed a protective petition for review after the federal government sought to dismiss or transfer to the D.C.
Circuit a case filed in federal court in D.C. challenging NHTSA’s final rule withdrawing California’s waiver for its GHG and zero-emission vehicle program and preempting state programs that regulate vehicle greenhouse gas emissions or create ZEV mandates. On February 8, 2021, the D. C. Circuit Court of Appeals issued an order holding the cases in abeyance pending regulatory review.
On January 20, 2021, President Biden released Executive Order No. 13990, which, among other things, calls for agency review for Part One of the SAFE Vehicles Rule by April 2021 and Part Two by July 2021. The order states that agencies shall consider whether to propose, suspend, revise or rescind these rules. On April 22, 2021, NHTSA proposed a rule to repeal Part One of the SAFE rule and restore California’s waiver to set its own vehicle standards. The fates of the proposed rules are uncertain, given the pending court deliberations and executive order.
4.7.3.3 State
California has established various regulations to address GHG emissions. The most relevant of these regulations are described below.
State Legislative Reduction Targets
Assembly Bill (AB) 32 (Chapter 488, Statutes of 2006), the Global Warming Solutions Act of 2006, requires GHG emissions in the state to be reduced to 1990 levels by 2020. Senate Bill (SB) 32 (2016) requires emissions in the state to be reduced to 40 percent below the 1990 level by 2030. The state’s plans to reach these targets are presented in periodic scoping plans. CARB most recently adopted City of South San Francisco
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the 2017 Climate Change Scoping Plan in November 2017 to meet the GHG reduction requirement set forth in SB 32.17 It proposes continuing the major programs of the previous Scoping Plan, including cap-and-trade regulations; low-carbon fuel standards; programs pertaining to more efficient cars, trucks, and freight movement; the Renewables Portfolio Standard (RPS); and programs pertaining to reducing CH4 emissions from agricultural and other wastes. The current Scoping Plan articulates a key role for local governments, recommending they establish GHG reduction goals for both their municipal operations and the community consistent with those of the state.
Executive Order Reduction Targets
In 2005, Executive Order (EO) S-3-05 established goals to reduce California’s GHG emissions to 1) 2000 levels by 2010 (achieved), 2) 1990 levels by 2020 (achieved), and 3) 80 percent below the 1990 levels by 2050. In 2018, EO B-55-18 established a new state goal designed to achieve carbon neutrality as soon as possible (no later than 2045) and maintain net negative emissions thereafter.
Executive orders are binding on state government agencies but are not legally binding on cities and counties or on private development.
Renewables Portfolio Standard
SBs 1078 (2002), 107 (2006), 2 (2011), and 100 (2015) govern California’s RPS, under which investor-owned utilities, energy service providers, and Community Choice Aggregators must procure additional retail sales each year from eligible renewable sources. The state’s existing RPS requires all retail sellers to procure a certain amount of electricity from eligible renewable energy resources so that the total number of kilowatt-hours sold to their retail customers equals 25 percent of sales by December 31, 2016 (achieved); 33 percent by December 31, 2020; 40 percent by December 31, 2024; 45 percent by December 31, 2027; and 50 percent by December 31, 2030. SB 100 revises and extends these renewable resource targets to 50 percent by December 31, 2026; 60 percent by December 31, 2030; and 100 percent by December 31, 2045.
Energy Efficiency Standards
The California Green Building Standards Code (Part 11, Title 24), commonly referred to as CALGreen, was adopted as part of the California Building Standards Code (24 California Code of Regulations). Part 11 established voluntary standards that became mandatory under the 2010 edition of the code. The standards concern sustainable site development, energy efficiency (in excess of California Energy Code requirements), water conservation (e.g., low-flow fixtures), material conservation, and internal air contaminants. The current energy efficiency standards were adopted in 2019 and took effect on January 1, 2020.
Vehicle Efficiency Standards
AB 1493 (2002) (Pavley I) requires CARB to develop and implement regulations to reduce GHG emissions. These stricter emissions standards were designed to apply to automobiles and light-duty trucks beginning with the 2009 model year. Additional strengthening of the Pavley standards (referred to previously as Pavley II and now referred to as the Advanced Clean Cars measure) led to 17 California Air Resources Board. 2017a. The 2017 Climate Change Scoping Plan Update: The Strategy for Achieving California’s 2030 GHG Target. January. Available: https://www.arb.ca.gov/cc/scopingplan/scopingplan.htm.
Accessed: November 9, 2020.
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measures being adopted for vehicle model years 2017–2025 in 2012. Together, the two standards are expected to increase average fuel economy to roughly 54.5 miles per gallon in 2025.
Low-Carbon Fuel Standard
With EO S-01-07, Governor Schwarzenegger set forth the low-carbon fuel standard for California.
Under this 2007 executive order, the carbon intensity of California’s transportation fuels is to be reduced by at least 10 percent by 2020.
18 On September 27, 2018, CARB approved amendments
requiring a 20 percent reduction in carbon intensity by 2030. CARB is expected to determine whether the 2020 standard was achieved sometime in late 2021.
Regional Land Use and Transportation Planning to Reduce Vehicle Miles Traveled SB 375 (2009) requires the state’s 18 metropolitan planning organizations to develop Sustainable Communities Strategies (SCSs) as part of their Regional Transportation Plans (RTPs) through integrated land use and transportation planning and demonstrate their ability to attain the GHG emissions reduction targets CARB established for the region by 2020 and 2035. This would be accomplished through either a financially constrained SCS, as part of the RTP, or an unconstrained alternative planning strategy. A financially constrained SCS refers to an SCS with committed, available, or reasonably available revenue sources for implementation. If regions develop integrated land use, housing, and transportation plans that meet the SB 375 targets, new projects in these regions can be relieved of certain California Environmental Quality Act (CEQA) review requirements. The SCS for the San Francisco Bay Area is addressed in Section 4.7.3.4, p. 4.7-11.
CEQA Requirements to Assess Greenhouse Gas Emissions
Per CEQA Guidelines section 15064.4, lead agencies are required to describe, calculate, or estimate the amount of GHG emissions that would result from a project. Moreover, the CEQA Guidelines emphasize the necessity to determine potential climate change effects of a project and propose mitigation as necessary. The CEQA Guidelines confirm the lead agency’s discretion to determine the appropriate significance threshold, but require the preparation of an environmental impact report (EIR) if “there is substantial evidence that the possible effects of a particular project are still cumulatively considerable notwithstanding compliance with adopted regulations or requirements.” CEQA Guidelines section 15126.4 includes considerations for lead agencies related to feasible mitigation measures to reduce GHG emissions, which may include, among others, measures in an existing plan or mitigation program for the reduction of emissions that are required as part of the lead agency’s decision; implementation of project features, project design, or other measures that are incorporated into the project to substantially reduce energy consumption or GHG emissions; offsite measures, including offsets that are not otherwise required. 18 From 2011 to 2018, the GHG intensity of transportation fuels was reduced by approximately 5 percent.
Source: GHG Institute. 2020. The Low Carbon Fuel Standard Has Succeeded, But How Does It Work? Available:
https://ghginstitute.org/2020/01/22/the-low-carbon-fuel-standard-has-succeeded-but-how-does-itwork/#:~:text=The%20State%20of%20California%20has,the%20baseline%20year%20of%202010. Accessed May 27, 2021.
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CEQA Requirements to Assess Vehicle Miles Traveled
SB 743, adopted in 2013, required revisions to the CEQA Guidelines to establish new impact analysis criteria for the assessment of a project’s transportation impacts (Public Resources Code section 21099). The intent behind SB 743 and revising the CEQA Guidelines was to integrate and balance the needs of congestion management, infill development, active transportation, and GHG emissions reduction strategies. The California Office of Planning and Research (OPR) recommended that vehicle miles traveled (VMT) serve as the primary analysis metric, replacing the existing criteria of delay and level of service. In 2018, OPR released a technical advisory, outlining potential VMT significance thresholds for different project types. Per CEQA Guidelines section 15064.3, the new VMT criteria and methodology are required as of July 1, 2020.
Short-Lived Climate Pollutants Reduction Strategy
SB 605 directed CARB, in coordination with other state agencies and local air districts, to develop a comprehensive Short-Lived Climate Pollutants (SLCP) Reduction Strategy. SB 1383 directed CARB to approve and implement the SLCP Reduction Strategy to achieve the following reductions in SLCPs. ⚫ 40 percent reduction in CH4 (below 2013 levels by 2030), ⚫ 40 percent reduction in hydrofluorocarbon gases (below 2013 levels by 2030), and ⚫ 50 percent reduction in anthropogenic black carbon (below 2013 levels by 2030).
The bill also establishes the following targets for reducing organic waste in landfills and CH4 emissions from dairy and livestock operations:
⚫ 50 percent reduction in organic waste disposal from the 2014 level by 2020, ⚫ 75 percent reduction in organic waste disposal from the 2014 level by 2025, and ⚫ 40 percent reduction in CH4 emissions from livestock manure management operations and dairy manure management operations from the dairy sector’s and livestock sector’s 2013 levels by 2030.
CARB and the California Department of Resources Recycling and Recovery (CalRecycle) are currently developing regulations to achieve the organic waste reduction goals found under SB 1383.
In January 2019 and June 2019, CalRecycle proposed new and amended regulations in Titles 14 and 27 of the California Code of Regulations. Among other things, the regulations set forth minimum standards for organic waste collection, hauling, and composting. The final regulations will take effect on or after January 1, 2022.
Water Conservation Act of 2009
SB X7-7, enacted in November 2009, requires all water suppliers to increase their water use efficiency to achieve a 20 percent reduction in urban per capita water use in California by December 31, 2020. The state was required to make incremental progress toward this goal by reducing per capita water use by at least 10 percent on or before December 31, 2015. The bill required each water supplier to develop urban water use targets.
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Solid Waste Diversion Targets
To minimize the amount of solid waste that must be disposed of in landfills, the state legislature passed the California Integrated Waste Management Act of 1989 (AB 939), effective January 1990.
According to AB 939, all cities and counties were required to divert 25 percent of all solid waste from landfill facilities by January 1, 1995, and 50 percent by January 1, 2000. This 50 percent diversion rate also applies to state agencies. In order of priority, waste reduction efforts must promote source reduction, recycling and composting, and environmentally safe transformation and land disposal.
In 2011, AB 341 modified the California Integrated Waste Management Act and directed CalRecycle to develop and adopt regulations for mandatory commercial recycling. As of July 1, 2012, the resulting Mandatory Commercial Recycling Regulation required certain businesses that generate 4 cubic yards or more of commercial solid waste per week to arrange recycling services. To comply with this requirement, businesses may either separate recyclables and self-haul them or subscribe to a recycling service that includes mixed-waste processing. AB 341 also established a statewide recycling goal of 75 percent; the 50 percent disposal reduction mandate still applies for cities and counties under AB 939.
4.7.3.4 Regional
Metropolitan Transportation Commission and Sustainable Communities Strategy The Metropolitan Transportation Commission (MTC) is the metropolitan planning organization for the nine counties that make up the San Francisco Bay Area and the San Francisco Bay Area Air Basin (SFBAAB), which includes the city of South San Francisco. As required by SB 375, in 2010 CARB set the first per capita GHG emissions targets for the SFBAAB of a 7 percent reduction by 2020 and a 15 percent reduction by 2035 compared with 2005 levels. In 2013, MTC adopted a Sustainable Communities Strategy (SCS) as part of its Regional Transportation Plan (RTP) for the SFBAAB. This was known as Plan Bay Area. The plan goes beyond the regional per capita targets, achieving 10 and 16 percent reductions in per capita GHG emissions by 2020 and 2035, respectively. 19 On July 26, 2017, the strategic update to this plan, known as Plan Bay Area 2040, was adopted by the Association of Bay Area Governments and the MTC. As a limited and focused update, Plan Bay Area 2040 builds upon the growth pattern and strategies developed in the original Plan Bay Area but with updated planning assumptions that incorporate the key economic, demographic, and financial trends since 2013.20 Plan Bay Area 2040 provides a long-range framework to minimize transportation impacts on the environment, improve regional air quality, protect natural resources, and reduce GHG emissions. The plan supports smart growth principles, promotes infill development, and proactively links land use, air quality, and transportation needs in the region.
The SCS policies include a mix of strategies that encourage compact growth patterns, mixed-use designs, alternative transportation, transit, mobility and access, network expansion, and transportation investment.
19 Metropolitan Transportation Commission and Association of Bay Area Governments. 2013. Plan Bay Area.
Adopted: July 18. Available: http://files.mtc.ca.gov/library/pub/28536.pdf. Accessed: November 11, 2020. 20 Metropolitan Transportation Commission and Association of Bay Area Governments. 2017. Plan Bay Area 2040.
Adopted: July 26. Available: http://2040.planbayarea.org/cdn/ff/buje2Q801oUV3Vpib-FoJ6mkOfWC9S9sgrSgJrwFBgo/ 1510696833/public/2017-11/Final_Plan_Bay_Area_2040.pdf. Accessed: November 11, 2020.
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As required by SB 375, CARB updated the per capita GHG emissions reduction targets in 2018. The new targets, which will be addressed in MTC’s forthcoming RTPs, are a 10 percent per capita GHG reduction by 2020 and 19 percent per capita reduction by 2035 compared with 2005 levels.21 Bay Area Air Quality Management District
As discussed in Section 4.2, Air Quality, the Bay Area Air Quality Management District (BAAQMD) is responsible for air quality planning within the SFBAAB, including projects in the city of South San Francisco. BAAQMD has adopted advisory emission thresholds to assist CEQA lead agencies in determining the level of significance of a project’s GHG emissions. The thresholds are outlined in the agency’s CEQA Guidelines.22 The BAAQMD CEQA Guidelines also outline methods for quantifying GHG emissions as well as developing potential mitigation measures. As discussed in Section 4.2, Air Quality, BAAQMD has also adopted air quality plans to protect the climate, including the 2017 Clean Air Plan: Spare the Air, Cool the Climate.23 The 2017 Clean Air Plan outlines feasible measures for reducing GHG emissions to 40 percent below 1990 levels by 2030 and 80 percent below 1990 levels by 2050.
4.7.3.5 Local
As further described in Chapter 3, Project Description, of this EIR, the project proposes certain circulation and infrastructure improvements that are located within the City of San Bruno (San Bruno) but would not develop any new structures or new land uses in San Bruno. The improvements would occur on areas that are already developed with existing circulation improvements. The specific off-site improvements located within San Bruno include: constructing a new signalized intersection at Huntington Avenue/Sneath Lane/Southline Avenue/Maple Avenue; improving Huntington Avenue from Southline Avenue south to the existing BART garage intersection located west of Pacific Avenue; converting Tanforan Avenue to a cul-de-sac adjacent to Huntington Avenue; and realigning the existing storm drain main within Huntington Avenue to conform to the proposed intersection improvements at Huntington Avenue/Southline Avenue.
Climate change is a global problem, and GHGs are global pollutants. Given the scale of the impact of GHGs, the limited scale of construction that would occur in San Bruno’s jurisdiction, and the fact at the proposed project would not introduce any new permanent land uses in San Bruno, this section evaluates the proposed project’s consistency with City of South San Francisco plans and policies related to GHGs, and does not include a local-level evaluation of consistency with San Bruno plans and policies related to GHGs.
South San Francisco General Plan
The 1999 City of South San Francisco General Plan, as amended, provides a vision for long-range physical and economic development of the city, provides strategies and specific implementing 21 California Air Resources Board 2020. SB 375 Regional Plan Climate Targets. Available: https://ww2.arb.ca.gov/ our-work/programs/sustainable-communities-program/regional-plan-targets. Accessed: August 17, 2020. 22 Bay Area Air Quality Management District. 2017a. California Environmental Quality Act, Air Quality Guidelines.
May. Available: https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa_guidelines_ may2017-pdf.pdf?la=en. Accessed: November 11, 2020.
23 Bay Area Air Quality Management District. 2017b. Final 2017 Clean Air Plan. Adopted April 19. Available:
https://www.baaqmd.gov/~/media/files/planning-and-research/plans/2017-clean-air-plan/attachment-a_- proposed-final-cap-vol-1-pdf.pdf?la=en. Accessed: January 6, 2020.
City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Greenhouse Gas Emissions
Southline Specific Plan EIR 4.7-13 September 2021
ICF 0082.20
actions, and establishes a basis for judging whether specific development proposals and public projects are consistent with the City’s plans and policy standards. The City General Plan contains an Open Space and Conservation Element, which outlines policies related to habitat and biological resources, water quality, air quality, GHG emissions, and historic and cultural resources. The City General Plan includes the following policies, which are applicable to GHG emissions:
⚫ Guiding Policy 7.3-G-4: Encourage land use and transportation strategies that promote the use of alternatives to the automobile for transportation, including bicycling, bus transit, and carpooling.
⚫ Guiding Policy 7.3-G-5: Promote clean and alternative fuel combustion in mobile equipment and vehicles.
⚫ Implementing Policy 7.3-I-2: Use the City’s development review process and the CEQA regulations to evaluate and mitigate the local and cumulative effects of new development on air quality and GHG emissions.
⚫ Implementing Policy 7.3-I-6: Periodically update the inventory of community-wide GHG emissions and evaluate appropriate GHG emissions reduction targets, consistent with current state objectives, statewide guidance, and regulations.
⚫ Implementing Policy 7.3-I-7: Adopt and implement the City’s Climate Action Plan, which will identify a GHG emissions reduction target and measures and actions to achieve the reduction target.
⚫ Implementing Policy 7.3-I-8: Evaluate and regularly report to City Council, or its designee, on the implementation status of the Climate Action Plan and update the Climate Action Plan as necessary should the City find that adopted strategies are not achieving anticipated reductions or otherwise incorporate new opportunities.
⚫ Implementing Policy 7.3-I-9: Promote land uses that facilitate alternative transit use, including high-density housing, mixed uses, and affordable housing served by alternative transit infrastructure.
⚫ Implementing Policy 7.3-I-10: Facilitate energy efficiency in building regulations and streamline review processes, thereby providing the flexibility needed to achieve specified energy performance levels while requiring energy efficiency measures as appropriate. ⚫ Implementing Policy 7.3-I-11: Coordinate with the business community to encourage energy efficiency in the city’s largest energy users while supporting economic growth objectives. ⚫ Implementing Policy 7.3-I-12: Adopt guidelines, standards, and flexible regulations that promote on-site renewable energy systems while strengthening South San Francisco’s economic competitiveness.
⚫ Implementing Policy 7.3-I-13: Encourage efficient, clean energy and fuel use through collaborative programs, award programs, and incentives while removing barriers to the expansion of alternative-fuel facilities and infrastructure. ⚫ Implementing Policy 7.3-I-14: Ensure that design guidelines and standards support operation of alternative-fuel facilities, vehicles, and equipment.
City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Greenhouse Gas Emissions
Southline Specific Plan EIR 4.7-14 September 2021
ICF 0082.20
South San Francisco Climate Action Plan
The City’s Climate Action Plan (CAP), adopted in 2014, includes goals, policies, and strategies to reduce the city’s GHG emissions, in compliance with AB 32 and SB 375. GHG reduction strategies identified in the CAP include a development checklist to identify applicable measures for discretionary projects. The City’s CAP was adopted to reduce GHGs community-wide and achieve a reduction target of 15 percent below 2005 emission levels by 2020.
The City has identified GHG reduction measures and strategies to reduce GHG emissions. These strategies include implementation of Transportation Demand Management (TDM) Plans, expanding active transportation alternatives, maximizing energy efficiency in the build environment, developing a waste reduction strategy to increase recycling and the reuse of materials, and reducing water demand.24 The City’s CAP is currently being updated as part of the update to the City General Plan. The 2014 CAP remains active until completion and adoption of the new CAP.
Because the City’s CAP only demonstrates consistency with the AB 32 near-term reduction target for 2020, it is not a “qualified” CAP available for CEQA streamlining for projects after 2020 (see further discussion in Section 4.7.4.1, Significance Criteria). However, until an updated CAP is adopted, the current CAP’s measures and development requirements still apply to projects constructed and operated after 2020. Therefore, this analysis evaluates the proposed project’s consistency with applicable measures and development requirements in the City’s CAP.
Transportation Demand Management Ordinance
The City’s TDM Ordinance requires projects to incorporate measures to reduce the number of trips generated and achieve goals related to alternative mode use. According to the ordinance, a project that is categorized as a business and professional office and requests a floor area ratio (FAR) of 2.3 is required to achieve a minimum alternative mode use of 45 percent (i.e., percentage of total trips). 25 Although the proposed project would implement zoning map and zoning text amendments to reflect adoption of the Specific Plan and implement the Southline Campus (S-C) District zoning, the City considers the 45 percent mode share reduction requirement to be applicable to the project based on similarities to the project site’s currently underlying zoning designation and the fact that 45 percent is the maximum mode share reduction required for any use type under the TDM Ordinance. The ordinance requires an annual employee mode-share survey at the project site to ensure that desired transportation mode shares are achieved. Where the mode share target is not achieved, City officials may require program modifications to increase alternative mode share or impose administrative penalties.
City of South San Francisco Construction and Demolition Waste Management Plan The City is mandated by the State of California to divert 65 percent of all solid construction waste from landfills either by reusing or recycling. To help meet this goal, a city ordinance requires completion of a Waste Management Plan for covered building projects identifying how at least 65 24 Ibid.
25 South San Francisco, California, Municipal Code § 20.400. The maximum FAR of 2.5 in the BPO district may be achieved through both the TDM measures described above (up to 2.3 FAR), and inclusion of (a) high quality, innovative design and product type, and maximum provisions for pedestrian and bicycle use, and (b) provision of green building measures over and above the applicable green building compliance thresholds required pursuant to Title 15 of the South San Francisco Municipal Code (up to 0.2 additional FAR). South San Francisco, California, Municipal Code § 20.090.003(C).
City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Greenhouse Gas Emissions
Southline Specific Plan EIR 4.7-15 September 2021
ICF 0082.20
percent of non-inert project waste materials and 100 percent of inert materials will be diverted from the landfill through recycling and salvage.26
4.7.4 Impacts and Mitigation Measures
This section describes the impact analysis related to GHG emissions for the proposed project, including Phase 1. It describes the methods and thresholds used to determine whether an impact would be significant. Feasible measures to mitigate (i.e., avoid, minimize, rectify, reduce, eliminate, or compensate for) potentially significant impacts accompany each impact discussion, when necessary.
4.7.4.1 Significance Criteria
Based on Appendix G of the CEQA Guidelines, the proposed project would have a significant GHG emissions impact if it would:
⚫ Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment; or
⚫ Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing emissions of GHG.
CEQA Guidelines Section 15064.4 provides guidance to lead agencies for determining the significance of environmental impacts pertaining to GHG emissions. Section 15064.4(a) states that a lead agency should make a good-faith effort that is based, to the extent possible, on scientific and factual data to describe, calculate, or estimate the amount of GHG emissions that would result from implementation of a project. Section 15064.4(b) also states that, when assessing the significance of impacts from GHG emissions, a lead agency should consider 1) the extent to which the project may increase or reduce GHG emissions compared with existing conditions, 2) whether the project’s GHG emissions would exceed a threshold of significance that the lead agency has determined to be applicable to the project, and 3) the extent to which the project would comply with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions.
The California Supreme Court’s decision in Center for Biological Diversity et al. v. California Department of Fish and Wildlife (62 Cal. 4th 204; “Newhall Ranch”) confirmed that there are multiple potential pathways for evaluating GHG emissions consistent with CEQA. Several air quality management agencies throughout the state have also drafted or adopted various threshold approaches and guidelines for analyzing GHG emissions in CEQA documents. Common threshold approaches include 1) compliance with a qualified GHG reduction strategy, 2) numeric “bright-line” thresholds, 3) efficiency-based thresholds, 4) performance-based reductions,27 and 5) compliance with regulatory programs.
26 City of South San Francisco. 2017. Construction and Demolition Waste Management Plan – Information for the Applicants. Available: https://www.ssf.net/home/showdocument?id=2416. Accessed: September 14, 2021. 27 Performance-based thresholds are based on the percentage reduction from a projected future condition (e.g., reducing future business-as-usual emissions to meet the SB 32 target [40 percent below 1990 levels]) through a combination of state measures; project design features, such as features related to renewable energy; and mitigation.
City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Greenhouse Gas Emissions
Southline Specific Plan EIR 4.7-16 September 2021
ICF 0082.20
Given the available threshold concepts recommended by air districts and the courts, GHG emissions from the project are evaluated on a sector-by-sector (e.g., energy, water) basis with respect to the most applicable regulatory programs, policies, best management practices (BMPs), and thresholds recommended by BAAQMD, CARB, and OPR, as described below.
BAAQMD’s CEQA Guidelines do not identify a GHG emission threshold for construction-related emissions. Instead, BAAQMD recommends that GHG emissions from construction be quantified and disclosed and that a determination regarding the significance of the GHG emissions be made with respect to whether a project is consistent with emissions reduction goals. BAAQMD further recommends incorporation of BMPs to reduce GHG emissions during construction, as feasible and applicable. This approach is used to evaluate construction-generated emissions.
An adopted qualified CAP may have a near-term focus, in terms of GHG reduction targets and associated reduction measures that are consistent with the 2020 target established in AB 32, but may not be consistent with a longer-term 2030 target expressed in SB 32 because the CAP was adopted before SB 32 was passed in Fall 2016. In such cases, a local CAP may no longer be considered “qualified” to meet the criteria in CEQA Guidelines Section 15183.5. This is the case for the City’s CAP, which was adopted in 2014. The City has not adopted a qualified GHG reduction plan beyond 2020 (i.e., when the proposed project would be constructed and operational) for the purposes of showing consistency with the 2030 SB 32 target and thus tiering per CEQA Guidelines Section 15183.5 is not an applicable option for assessing the proposed project’s GHG impacts.28 The CAP measures and development requirements still apply to projects constructed and operated after 2020. The proposed project is compared with the CAP to determine consistency as part of Impact GHG-2.
BAAQMD’s CEQA Guidelines recommend efficiency-based thresholds for land use projects (1,100 metric tons of CO2e per year and 4.6 metric tons of CO2e per service population per year,29 respectively)30 to evaluate a project’s total GHG emissions. However, these thresholds were developed by BAAQMD in accordance with the 2020 AB 32 GHG reduction targets. The proposed project would be constructed and would operate entirely in the post-2020 period; therefore, it is not appropriate to evaluate the project’s emissions relative to the 2020 land use project thresholds.31 All operational GHG impacts (excluding stationary sources, which are discussed separately below) are evaluated based on implementation of BMPs to reduce GHG emissions and compliance with regulatory programs, consistent with the California Supreme Court’s determination that compliance with statewide emissions reduction targets may be an acceptable pathway for evaluating projectlevel GHG emissions under CEQA (Newhall Ranch, 62 Cal. 4th 204, 222-24).
The Newhall Ranch decision, which concerned a 2010 EIR prior to adoption of SB 32, specifically mentions consistency with SCSs (per SB 375) and AB 32 as a potential mechanism for evaluating significance. A lead agency could assess project‐level consistency with AB 32 in whole or part by evaluating whether the project complies with applicable policies in the AB 32 Scoping Plan. The AB 28 However, the CAP measures and development requirements still apply to projects constructed and operated after 2020. Consistency with the CAP framework is considered in this analysis. 29 Service population refers to the total number of residents and/or employees. 30 Bay Area Air Quality Management District. 2017a. California Environmental Quality Act, Air Quality Guidelines.
May. Available: https://www.baaqmd.gov/~/media/files/planning-andresearch/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en. Accessed: January 7, 2020. 31 These thresholds do not account for GHG emissions reductions from new development post-2020 and are not tailored to the proposed project.
City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Greenhouse Gas Emissions
Southline Specific Plan EIR 4.7-17 September 2021
ICF 0082.20
32 Scoping Plan does not consider the deeper reductions needed to meet the state’s 2030 target under SB 32. Accordingly, relying exclusively on consistency with the AB 32 Scoping Plan and related programs to evaluate emissions generated by land use development projects constructed after 2020 would not fully consider a project’s potential GHG impacts on the state’s long‐term reduction trajectory.
The state has a carbon neutrality goal, which was set by EO B-55-18. However, the state’s 2045 goal has not been codified into law, and neither the state nor the City has adopted a plan or framework for achieving the 2045 goal. The state’s 2030 target was codified into law through SB 32 and the 2017 Climate Change Scoping Plan32 was adopted to meet that goal. Therefore, 2030 marks the next statewide statutory milestone target that would be applicable to the proposed project, with buildout years for Phase 1 and the Specific Plan in 2024 and 2030, respectively.
This analysis focuses on the 2030 target and the plans, policies, and regulations adopted pursuant to achieving 2030 reductions. Emissions generated in 2030 are used as an indicator of long-term progress toward emissions reductions and evaluated as they relate to the proposed project’s impacts on the state’s long-term GHG reduction targets. More specifically, BMPs and project design features stipulated by Title 24, the California Department of Water Resources Model Water Efficient Landscape Ordinance, the 2019 California Green Building Standards Code, and CARB’s 2017 Climate Change Scoping Plan, for instance, could be used to show compliance with performance-based standards and fulfill the statewide goal of reducing GHG emissions. To the extent that the proposed project complies with or exceeds the regulations outlined in the 2017 Scoping Plan and adopted by CARB or other state agencies, the proposed project could appropriately rely on their use to demonstrate compliance with the performance‐based standards adopted to fulfill the statewide goal of reducing GHG emissions. The proposed project’s consistency with regulatory programs adopted by CARB and other state agencies is therefore used to evaluate the significance of the proposed project’s GHG emissions. Although the regulatory framework to achieve long‐term (post‐2030) emissions reductions is in its infancy, many of the programs outlined in the 2017 Scoping Plan are likely to be carried forward or have already been adopted with post‐2030 requirements (e.g., the RPS). Accordingly, evaluating consistency with BMPs, design features, programs, and relevant guidance published by OPR and CARB for the reduction of long‐term emissions is also considered in the analysis of the proposed project’s emissions.
⚫ Mobile Sources: CARB’s 2017 Scoping Plan recognizes that, although vehicle technologies and low-carbon fuels will continue to reduce transportation-sector emissions, VMT reductions are necessary to achieve California’s long-term GHG emissions reduction target. Mobile emissions are evaluated against the screening threshold for transportation impacts under SB 743. There is a nexus between SB 743 and the state’s goals to reduce GHG emissions; one of the criteria under SB 743 for determining the significance of transportation impacts from a project is whether the project reduces GHG emissions. As such, if the proposed project is consistent with SB 743 screening thresholds, it would be considered to have a less-than-significant GHG impact from mobile emissions. In addition, compliance with regulatory programs (e.g., AB 1493, the lowcarbon fuel standard, SB 375) would also be required to reduce statewide mobile GHG emissions impacts to a less-than-significant level.
32 California Air Resources Board. 2019. 2017 Scoping Plan – Identified VMT Reductions and Relationship to State Climate Goals. January. Available: https://ww2.arb.ca.gov/sites/default/files/2019- 01/2017_sp_vmt_reductions_jan19.pdf. Accessed: November 9, 2020.
City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Greenhouse Gas Emissions
Southline Specific Plan EIR 4.7-18 September 2021
ICF 0082.20
⚫ Energy, Water, Waste, Area, and Land Use Sources. CARB’s 2017 Scoping Plan, which relies heavily on state programs (e.g., Title 24, SB 100), outlines the strategies required to reduce statewide GHG emissions and achieve California’s SB 32 reduction target.33 Projects that implement applicable strategies from the 2017 Scoping Plan would be consistent with the state’s GHG reduction framework as well as requirements for these sectors. Accordingly, a sector-by-sector review of the respective sustainability design features and objectives included in the proposed project is provided to evaluate consistency with BMPs, design features, plans, and policies. This assessment also considers recent CARB guidance34 related to long-term reductions in statewide emissions. Accordingly, impacts from energy, water, waste, area, and land use sources would be considered less than significant if the proposed project is consistent with all applicable BMPs, design features, strategies, and supporting regulations and guidance. ⚫ Stationary Sources. BAAQMD has adopted a threshold of 10,000 metric tons of CO2e for stationary sources.35 This threshold is consistent with stationary-source thresholds adopted by other air quality management districts throughout the state. The threshold level is intended to capture 95 percent of all GHG emissions associated with new permit applications for stationary sources in the air basin. It would do so by capturing only the large, significant projects because permit applications with emissions above the threshold of 10,000 metric tons of CO2e account for less than 10 percent of all applications. The emergency generator included as part of the proposed project would be a permitted source, and as such, BAAQMD’s threshold of 10,000 metric tons of CO2e is appropriate for analyzing the significance of emissions generated by the generator. Impacts from stationary sources would be considered less than significant if the emissions total less than 10,000 metric tons of CO2e.
4.7.4.2 Approach to Analysis
GHG impacts from construction and operation of the project were assessed and quantified (where applicable) using standard and accepted software tools, techniques, and emission factors. A summary of the methodology is provided below. A full list of assumptions can be found in Appendix
4.2-1.
Project
Buildout Scenario Studied (Office Scenario)
As discussed in Section 3.6.2.2 in Chapter 3, Project Description, of this EIR, the Specific Plan would allow development of the commercial campus as either office or research-and-development (R&D) uses, or a combination of both, with a total buildout of 2,800,000 square feet. For the purposes of program-level EIR analysis, two projected buildout scenarios were identified that represent the reasonably foreseeable range of development expected to occur under the Specific Plan, the Office Scenario and the Life Sciences Scenario. Each section within Chapter 4, Environmental Setting, Impacts, and Mitigation, of this EIR analyses the buildout scenario that represents the “worst-case” 33 California Air Resources Board. 2017a. California’s 2017 Climate Change Scoping Plan. November. Accessed:
https://ww3.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf. Accessed: November 111, 2020. 34 California Air Resources Board. 2019. 2017 Scoping Plan-Identified VMT Reductions and Relationship to State Climate Goals. January. Available: https://ww2.arb.ca.gov/sites/default/files/2019- 01/2017_sp_vmt_reductions_jan19.pdf. Accessed: November 11, 2020. 35 Ibid.
City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Greenhouse Gas Emissions
Southline Specific Plan EIR 4.7-19 September 2021
ICF 0082.20
scenario for the resource area being analyzed. The “worst-case” scenario is the scenario with the greatest potential to result in significant impacts.
The Office Scenario would develop up to seven buildings with office uses up to seven stories tall and the four-story amenity building for a total of 2,800,000 square feet (FAR of approximately 2.4). The Life Sciences Scenario would develop up to nine buildings with R&D uses, including laboratory and office spaces, up to six stories tall and the four-story amenity building for a total of 2,025,050 square feet (FAR of approximately 1.75). Construction-related emissions are anticipated to be similar for the two buildout scenarios, but as described below, they cannot be precisely determined at this time.
Therefore, either buildout scenario represents the worst-case scenario in terms of the GHG emissions impacts associated with construction.
On the other hand, the differences in the gross square footage and land uses would influence longterm operational emissions. The R&D buildings under the Life Sciences Scenario would have a higher building energy consumption rate (in terms of kilowatt-hour per square foot of space) and higher-horsepower emergency diesel generators, which would be more emissions intensive. The Life Sciences Scenario also includes the unique emission source of up to six process boilers that would be used to generate steam for a range of applications (e.g., intensive cleaning of manufacturing equipment). However, the Office Scenario would involve more building development than the Life Sciences Scenario (i.e., an additional 774,950 square feet). Although the Office Scenario would have a lower building energy consumption rate per square foot, lower-horsepower generators and no process boilers, the increased building square footage would result in higher total energy consumption compared to the Life Sciences Scenario, making the Office Scenario the worstcase scenario in terms of GHG emissions associated with operation. Furthermore, the Office Scenario would generate nearly twice as many vehicle trips by commuters compared with the Life Sciences Scenario (11,200 employees versus 5,786). Mobile-source emissions typically make up the largest portion of a project’s operational emissions profile. Therefore, for the analysis of GHG emissions associated with operation, the worst-case scenario is assumed to be the Office Scenario. That scenario is evaluated in this section.
Construction Emissions
Land uses that could be developed under the Specific Plan and offsite improvements would generate construction related GHG emissions from the use of mobile and stationary construction equipment; the use of vehicles, including haul trucks, by workers; and the use of electricity. The specific size, location, construction techniques, and scheduling for each individual development project occurring on the project site from implementation of the proposed Specific Plan are not currently known. With an anticipated buildout year of 2030, development of the various land uses associated with the proposed Specific Plan would occur over an extended period of time. As such, without specific project-level details, with the exception of Phase 1, which is described below, it is not possible to develop a refined construction emissions inventory.36 Consequently, the determination of construction-related GHG impacts for each individual development project, or a combination of these projects, is not reasonably foreseeable and would require speculation regarding potential future project-level environmental impacts. Therefore, in the absence of the necessary construction information required to provide an informative and meaningful analysis, the evaluation of potential 36 Project-level information includes details such as the size and scale of the project to be constructed, the construction schedule, the equipment fleet, estimates regarding the size of the construction crew, and demolition and grading specifics.
City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Greenhouse Gas Emissions
Southline Specific Plan EIR 4.7-20 September 2021
ICF 0082.20
construction-related impacts resulting from implementation of the Specific Plan is conducted qualitatively and at a program level in this EIR. Emission-generating activities and the types of emissions are described, and additional details regarding timing and phasing are provided for context.
Operational Mobile-Source Emissions
GHG emissions impacts from motor vehicles associated with the project were evaluated using the California Emissions Estimator Model (CalEEMod), version 2016.3.2; vehicle emission factors from CARB’s EMFAC2017 emissions model; and daily VMT estimates based on the countywide travel demand model developed by the City/County Association of Governments of San Mateo County (C/CAG).
37Daily VMT under existing conditions (2018) in the traffic analysis zone (TAZ) that contains the project site was estimated to be 258,452 miles.38 Daily VMT in the TAZ in 2040, following Specific Plan buildout, was estimated to be 566,750 miles.39 VMT estimates were based on the City/County Association of Governments of San Mateo County travel demand model and then modified to account for 1) the VMT reduction associated with the east-west extension through the Specific Plan area via Southline Avenue (see Section 4.15, Transportation and Circulation) and 2) the VMT reduction associated with the City’s TDM Ordinance, under which the project would be required to achieve an alternative mode share of 45 percent, resulting in a 23 percent reduction in project VMT.
40 Daily VMT was annualized using a factor of 347 days, consistent with CARB guidance.41
Mobile emissions from gasoline-powered light-duty vehicles (e.g., vehicles for employee commuting) were adjusted to account for the impact of implementation of Part Two of the SAFE Vehicles Rule. Consistent with the capabilities of CalEEMod, this analysis does not quantify the emissions benefit from vehicle fuel switching that could be induced by electric vehicle chargers in parking spaces. This emissions benefit is qualitatively described where applicable in the impact analysis. See Appendix 4.2-1 for the EMFAC2017 emission factors and traffic data utilized in this analysis.
Operational Area, Energy, Water, Waste, and Land Use Emissions Area, energy, water, waste, and land use emissions were estimated using CalEEMod, version 2016.3.2. Landscaping equipment, including gasoline-powered equipment (e.g., trimmers, mowers), is the primary area source of GHG emissions. Calculations of area-source emissions rely on CalEEMod’s default assumptions, which represent a conservative estimate of equipment usage, based on the square footage of the new building space. The combustion of natural gas and use of electricity for building and water heating and cooling is the primary source of operational, nonmobile GHG emissions. Water consumption results in indirect GHG emissions from the electricity used to convey and treat the water. Waste generation results in fugitive CH4 and N2O emissions from 37 Fehr & Peers. 2021. Southline Transportation Impact Analysis. June. 38 The existing conditions reflect transportation conditions prior to the COVID-19 pandemic. Due to the atypical travel patterns and transit service levels during the COVID-19 pandemic, new data was not collected for this analysis.
39 Ibid.
40 Ibid.
41 California Air Resources Board. 2018. EMFAC2017 Volume III – Technical Documentation. Available:
https://ww3.arb.ca.gov/msei/downloads/emfac2017-volume-iii-technical-documentation.pdf. Accessed:
November 11, 2020.
City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Greenhouse Gas Emissions
Southline Specific Plan EIR 4.7-21 September 2021
ICF 0082.20
the decomposition of organic matter. Changes to the natural land, specifically the net change in the number of trees and the amount of vegetation on the project site, results in changes to the sequestration capacity of the project site.
Emissions were quantified for existing conditions (2018) and buildout conditions for the worst-case scenario (i.e., the Office Scenario [2030]). The 2030 modeling reflects implementation of state measures to reduce GHG emissions (e.g., SB 100, Pavley). The assumed defaults were based on the anticipated land uses and square footage identified in the Office Scenario. The analysis quantifies the emissions benefit from the Specific Plan’s requirement that the project utilize 100 percent carbonfree electricity for all operational electricity needs through participation in programs such as PG&E Solar Choice or Peninsula Clean Energy (see Chapter 3, Project Description, of this EIR). This would eliminate any electricity-based operational GHG emissions from the proposed project. The analysis also accounts for the emissions benefit from weather-based irrigation controls to reduce water consumption and therefore indirect GHG emissions. Quantifiable features required for compliance with CALGreen (i.e., low-flow fixtures) were also incorporated into the CalEEMod model. Consistent with the capabilities of CalEEMod, the analysis does not quantify the emissions benefit that would occur with implementation of the Specific Plan’s range of non-transportation-related sustainability features (e.g., exterior electrical power infrastructure to support electric landscaping equipment, a Leadership in Energy and Environmental Design (LEED) Silver rating for buildings, high-efficiency natural gas appliances, and a 10 percent improvement in energy performance compared with an American Society of Heating, Refrigerating, and Air-Conditioning Engineers [ASHRAE] 90.1-2010 reference baseline building). These emissions benefits are qualitatively described in the impact analysis where applicable. Please refer to Appendix 4.2-1 for the CalEEMod output files.
Operational Stationary-Source Emissions
Stationary sources under the Office Scenario include the five emergency diesel generators that would be installed under Phase 1. Additional generators may be installed as part of development constructed under future phases, but their locations and specifications are unknown at this time.
Generator information is described further under the Phase 1 approach to analysis.42 Selection of Future Year Baseline Conditions
The CEQA Guidelines provide that existing conditions at the time a Notice of Preparation is released or when environmental review begins “normally” constitute the baseline for environmental analysis. (Guidelines Section 15125). In 2010, the California Supreme Court issued an opinion holding that while lead agencies have some flexibility in determining what constitutes the baseline, relying on “hypothetical allowable conditions” when those conditions are not a realistic description of the conditions without the project would be an illusory basis for a finding of no significant impact from the project and, therefore, a violation of CEQA (Communities for a Better Environment v. South Coast Air Quality Management District (2010) 48 Cal.4th 310).
On August 5, 2013, the California Supreme Court handed down another baseline decision, Neighbors for Smart Rail v. Exposition Metro Line Construction Authority (57 Cal.4th 439), which clarified that, 42 The Life Sciences Scenario would include up to six process boilers. While this buildout scenario would be the worst-case scenario for stationary source emissions, associated emissions would still be well below BAAQMD’s threshold. For consistency with the rest of the operational source analysis, and because impacts would be the same, the stationary source equipment and activity rates defined under the Office Scenario were used to quantify stationary source emissions.
City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Greenhouse Gas Emissions
Southline Specific Plan EIR 4.7-22 September 2021
ICF 0082.20
under certain circumstances, a baseline may reflect future, rather than existing, conditions. The rule specifies that factual circumstances can justify an agency departing from that norm in the following circumstances, when such reasons are supported by substantial evidence:
⚫ When necessary to prevent misinforming or misleading the public and decision makers; and ⚫ When their use in place of existing conditions is justified by unusual aspects of the project or surrounding conditions.
With respect to the Specific Plan, utilizing existing conditions to evaluate criteria pollutant impacts could potentially misinform the public and decision makers with respect to potential climate change impacts for three reasons: 1) natural vehicle fleet mix turnover, 2) changes in on-road emission factors, and 3) changes in renewable content of grid-based electricity, each as described below.
1. The fleet mix in San Mateo County will be different by the time the Specific Plan is fully implemented in 2030, as the percentage of truck traffic to all vehicle traffic changes. Per CTEMFAC 2017, in 2018, 5.4 percent of the San Mateo County fleet mix was made up of trucks, while in 2030 it is forecasted to increase to 7 percent.43 Trucks have different emission profiles and are generally more emission-intensive than passenger vehicles. Quantifying emissions under existing conditions would therefore misrepresent vehicle emissions associated with the vehicle fleet that will be in place once the Specific Plan is fully operational.
2. On-road vehicle emissions rates are anticipated to lessen in the future due to continuing engine advancements and more stringent environmental regulations. Analyzing existing conditions (2018) and quantifying emissions utilizing 2018 vehicle emissions rates instead of the reduced 2030 vehicle emission rates would not only represent an unrealistic scenario but would also overestimate emissions reductions and potential GHG benefits achieved by the Specific Plan.
3. The electricity intensity factor of the utility servicing the project study area, PG&E, is anticipated to lessen in the future due to the renewable resource targets set by SB 100. Analyzing existing conditions (2018) and quantifying emissions utilizing the 2018 electricity intensity factor instead of the reduced 2030 factor would not only represent an unrealistic scenario but would also overestimate reductions and potential GHG benefits achieved by the Specific Plan.
Accordingly, the CEQA baseline for the purposes of this GHG analysis is defined as Specific Plan buildout (2030) conditions. The 2030 baseline represents the full buildout year under the Specific Plan, with impacts accounting for future fleet changes, appropriate engine exhaust emission factors, and utility electricity intensity factors. Utilizing the Specific Plan buildout conditions as the CEQA baseline is most appropriate to inform public and decision makers with respect to climate change impacts, consistent with current CEQA case law. Where appropriate, emissions under existing conditions (2018) are also presented for informational purposes.
Phase 1
Construction Emissions
Construction-related GHG emission sources similar to those described above for the overall project are anticipated with construction of Phase 1. GHG emissions were estimated using the emission 43 California Department of Transportation. 2017. CT-EMFAC 2017. Available:
https://dot.ca.gov/programs/environmental-analysis/air-quality/project-level-air-quality-analysis. Accessed:
February 3, 2021.
City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Greenhouse Gas Emissions
Southline Specific Plan EIR 4.7-23 September 2021
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calculation methods provided in CalEEMod, version 2016.3.2, and its technical support documentation. The construction schedule, equipment operating details, trip numbers, trip lengths, electricity consumption from mobile trailers, and material quantities were provided by the project applicant’s construction contractor.
44,45 Annual construction emissions were estimated using these project-specific details. Please refer to Appendix 4.2-1 for the construction modeling inputs and CalEEMod outputs.
Operational Mobile Source Emissions
GHG emissions from motor vehicles associated with Phase 1 were evaluated using the same methods and models (e.g., EMFAC2017, CalEEMod) described above for the Specific Plan. Phase 1 (2024) daily VMT in the TAZ was estimated to be 335,006 miles.46 Operational Area, Energy, Water, Waste and Land Use Emissions GHG emissions from other operational sources associated with buildout of Phase 1 were evaluated using the same methods and models (e.g., CalEEMod) described above for the proposed Specific Plan.
Operational Stationary-Source Emissions
Stationary sources include the five emergency diesel generators. Annual stationary source emissions were estimated in 2030 using CalEEMod, version 2016.3.2. Generator emissions factors and horsepower were based on the makes and models identified by the project applicant.47, 48, 49, 50 On an annual basis, each generator would run for up to 50 hours per year for testing, consistent with CARB’s Airborne Toxic Control Measure for Stationary Compression Ignition Engines and Section 330.3 of BAAQMD Regulation 9, Rule 8. It was assumed that generators would run under full load, which is the most emissions-intensive load. Table 4.7-3, p. 4.7-24, summarizes the generator equipment specifications and testing schedule. Note that only the annual generator activity is relevant to the GHG analysis given GHG emissions are typically reported on an annual timescale. See Appendix 4.2-1 for the CalEEMod output files and generator emissions factors. 44 McKinley, Jerry. DPR Construction. October 13, 2020—email to Devan Attenberry of ICF regarding Southline (call requested to discuss outstanding data needs).
45 As described in Chapter 3, Project Description, there are two options for the construction haul truck routes, each using different access/exit roads from the project site. The incremental differences in total route length between the two options do not influence the GHG impact analysis. (Three options were identified at the onset of Draft EIR preparation; one has since been removed from consideration.) 46 Ibid.
47 Cummins, Inc. 2017a. Exhaust Emission Data Sheet 1250DQGAE. Available: https://powersuite.cummins.com/ PS5/PS5Content/SiteContent/en/Binary_Asset/pdf/Commercial/Datasheets/Emissions/eds-1110.pdf.
Accessed: November 11, 2020.
48 Cummins, Inc. 2017b. Exhaust Emission Data Sheet 1500DQGAF. Available: https://powersuite.cummins.com/ PS5/PS5Content/SiteContent/en/Binary_Asset/pdf/Commercial/Datasheets/Emissions/eds-1111.pdf.
Accessed: November 11, 2020.
49 Cummins, Inc. 2018. Exhaust Emission Data Sheet 500DFEK. Available: https://powersuite.cummins.com/ PS5/PS5Content/SiteContent/en/Binary_Asset/pdf/Commercial/Datasheets/Emissions/eds-173.pdf.
Accessed: November 11, 2020.
50 Meyers+ Engineers. 2020. Southline CEQA Response. May.
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Table 4.7-3. Phase 1 Emergency Generator Technical Specifications and Testing Schedule Generator Building1 HP Hours Tested per Year
1 1 1700 50
2 1 1700 50
3 2 700 50
4 7 1700 50
5 7 1700 50
Total 250
1 Generators listed include only those known for the buildings constructed as part of Phase 1. Additional generators may be installed as part of development constructed under future phases, but their locations and specifications are unknown at this time.
Selection of Future Year Baseline Conditions
Similar to the Specific Plan GHG analysis, utilizing existing conditions to evaluate criteria pollutant impacts of Phase 1 would potentially mislead the public and decision makers with respect to potential climate change impacts for three reasons: 1) natural vehicle fleet mix turnover, 2) changes in on-road emission factors, and 3) changes in renewable content of grid-based electricity (detailed further above for the Specific Plan). Accordingly, the CEQA baseline for the purposes of this GHG analysis is defined as Phase 1 opening year (2024) conditions. Where appropriate, emissions under existing conditions (2018) are also presented for informational purposes.
4.7.4.3 Impact Evaluation
Impact GHG-1a. The project would not generate GHG emissions, either directly or indirectly, that would have a significant impact on the environment during construction. (Project: Less than Significant with Mitigation; Phase 1: Less than Significant with Mitigation).
Project
Under both the Life Sciences Scenario and Office Scenario, construction associated with new land use developments under the Specific Plan and offsite improvements would result in the temporary generation of GHG emissions. Emissions would originate from construction equipment exhaust, vehicle exhaust, and the use of electricity in mobile trailers. Construction-related GHG emissions would vary substantially throughout buildout under the Specific Plan, depending on the level of activity, length of the construction period, specific construction operations, the types of equipment, and the number of workers.
Currently, the Phase 1 Precise Plan and related offsite improvements are the only project-level development proposals under the proposed Specific Plan. As discussed in Chapter 3, Project Description, the project applicant has identified additional phases for future development permitted under the Specific Plan. Because the timing and intensity of future development projects is not known, the precise effects of construction activities associated with buildout of the project site cannot be accurately quantified.
As noted previously, BAAQMD has not established a quantitative threshold for assessing construction related GHG emissions. Rather, the air district recommends evaluating whether construction activities would conflict with statewide emission reduction goals and implementing feasible BMPs. If a project does not implement feasible BMPs, it is anticipated that it would conflict City of South San Francisco
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with statewide emissions goals. Therefore, construction-related GHG emissions from the Specific Plan would be required to comply with Mitigation Measure GHG-1, which would reduce construction emissions, consistent with BAAQMD guidance and statewide emission reduction goals.
Note that BAAQMD’s recommended BMP to recycle and reuse at least 50 percent of construction waste or demolition materials is not as rigorous as the City’s applicable requirement that new construction submit a Waste Management Plan identifying how at least 65 percent of non-inert project waste materials and 100 percent of inert materials will be diverted from the landfill through recycling and salvage. Also, BAAQMD’s recommended BMP to use alternative fuel in 15 percent of the construction vehicles/equipment would be bolstered with implementation of Mitigation Measure AQ-4, which requires the construction fleet to use renewable diesel. Consequently, the impact from construction related GHG emissions would be less than significant with mitigation.
Phase 1
Construction of Phase 1 is scheduled to commence in late 2021 and end in early 2024. The types of construction emissions generated by Phase 1 would be similar to those described above for the Specific Plan. Construction activities would include the demolition of structures and parking lots on the project site (i.e., extending beyond the boundary of the Phase 1 site), excavation, grading, paving, utility installations, off-site area improvements, construction of three new buildings and a parking structure, and landscaping. These activities would require construction equipment and on-road vehicles such as haul trucks for demolition debris and concrete trucks for asphalt deliveries. Site grading and excavation would be required for building foundations, utilities, and pervious pavement and landscaping. Electricity would be consumed by the mobile trailers stationed on-site. Estimated construction GHG emissions are presented in Table 4.7-4, p. 4.7-25.
Table 4.7-4. Estimated Construction GHG Emissions from Phase 1 (metric tons) Construction Year CO2 CH4 N2O CO2e
2021 614 < 1 < 1 633
2022 3,973 1 < 1 4,083
2023 1,568 < 1 < 1 1,594
2024 4 < 1 < 1 4
Totala 6,159 1 < 1 6,314
Source: Refer to Appendix 4.2-1 for construction modeling outputs.
Notes:
a. Totals may not add up because of rounding.
As described above, BAAQMD has not established a quantitative threshold for assessing construction related GHG emissions. Rather, the air district recommends evaluating whether construction activities would conflict with statewide emission reduction goals and implementing feasible BMPs. Therefore, construction-related GHG emissions from Phase 1 would be mitigated to less than significant with implementation of Mitigation Measure GHG-1, which requires the use of the BMPs recommended by BAAQMD during construction, thereby avoiding any conflict with statewide emission reduction goals. Note that BAAQMD’s recommended BMP to recycle and reuse at least 50 percent of construction waste or demolition materials is not as rigorous as the City’s applicable requirement that new construction submit a Waste Management Plan identifying how at least 65 percent of non-inert project waste materials and 100 percent of inert materials will be City of South San Francisco
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diverted from the landfill through recycling and salvage. This impact would be less than significant with mitigation.
Mitigation Measure GHG-1: Require Implementation of BAAQMD-recommended Construction BMPs (All Phases)
The Phase 1 applicant and applicants of future Precise Plans shall require their contractors, as a condition in contracts, to reduce construction-related GHG emissions by implementing BAAQMD’s recommended BMPs, based on BAAQMD’s CEQA Guidelines:
⚫ Ensure that alternative-fuel (e.g., biodiesel, electric) construction vehicles/equipment make up at least 15 percent of the fleet,
⚫ Use local building materials (at least 10 percent) sourced from within 100 miles of the planning area, and
⚫ Recycle and reuse at least 50 percent of construction waste or demolition materials.
Impact GHG-1b. The project would not generate GHG emissions, either directly or indirectly, that would have a significant impact on the environment during operation. (Project: Less than Significant; Phase 1: Less than Significant).
Project
Operation of land uses under the Specific Plan would generate direct and indirect GHG emissions.
Sources of direct emissions include vehicles, emergency generators, natural gas combustion, and landscaping activities. Indirect emissions would be generated by waste and wastewater generation as well as water use.51 As discussed in Section 4.7.4.2, Approach to Analysis, the emissions estimate quantified the effect of the following: the Specific Plan’s requirement to utilize 100 percent carbonfree electricity for all operational electricity needs through participation in programs such as PG&E Solar Choice or Peninsula Clean Energy, weather-based irrigation controls, compliance with CALGreen (i.e., low-flow fixtures), the VMT reduction associated with the extension of Southline Avenue, and the 23 percent reduction in VMT associated with the project’s requirement to achieve an alternative mode share of 45 percent.52 Consistent with the capabilities of CalEEMod, this analysis does not quantify the emissions benefit from the following: vehicle fuel switching, LEED Silver-rated buildings, exterior electrical power infrastructure to support electric landscaping equipment, high-efficiency natural gas appliances, and a 10 percent improvement in energy performance compared with an ASHRAE 90.1-2010 reference baseline building.
Table 4.7-5, p. 4.7-27, summarizes annual area-, energy-, mobile-, stationary-, waste-, water-, and land use-related emissions generated under existing conditions (2018), 2030 conditions without the project (assuming no other development takes place in the Specific Plan area), and 2030 conditions with the project. Emissions under Specific Plan buildout in 2030 are compared to 2030 emissions without the Specific Plan.
51 The existing VMT on the roadways within the off-site improvement areas is captured by the larger, TAZ-level estimate of VMT based on C/CAG’s travel demand model (see Operational Mobile-Source Emissions above). The model does not provide data at a scale granular enough to disaggregate the TAZ-level VMT to only these select roadway segments, intersections, and rail-crossings.
52 Ibid.
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Table 4.7-5. Estimated Annual Specific Plan Operational GHG Emissions (Office Scenario) (metric tons) Condition/Source CO2 CH4 N2O CO2e
% of Total
CO2e
Existing (2018)
Area sources < 1 < 1 < 1 < 1 < 0.1%
Energy sources 312 < 1 < 1 313 0.9%
Mobile sources 33,714 2 < 1 33,761 98.6%
Stationary sourcesa 0 0 0 0 0.0%
Waste generation 55 3 < 1 137 0.4%
Water consumption 103 2 < 1 172 0.5%
Land useb < 1 < 1 < 1 -128 -0.4%
Total existingc 34,184 7 < 1 34,256 —
2030 without Project
Area sources < 1 < 1 < 1 < 1 < 0.1%
Energy sources 127 < 1 < 1 128 0.4%
Mobile sources 25,554 1 < 1 25,581 74.7%
Stationary sourcesa 0 0 0 0 0.0%
Waste generation 55 3 0 137 0.4%
Water consumption 49 2 0 118 0.3%
Land useb < 1 < 1 < 1 -128 -0.4%
Total 2030 without Specific Planc 25,785 7 < 1 25,835 — 2030 with Project
Area sources < 1 < 1 < 1 < 1 < 0.1%
Energy sources 3,045 < 1 < 1 3,063 4.8%
Mobile sources 58,572 2 < 1 58,634 92.2%
Stationary sources 196 0 < 1 196 0.3%
Waste generation 635 37 < 1 1,572 2.5%
Water consumption 126 13 < 1 541 0.9%
Land useb < 1 < 1 < 1 -432 -0.7%
Total 2030 with Specific Planc 62,573 53 < 1 63,574 —
Net Increase with Project
2030 with Project vs. 2030 without Project 36,789 46 < 1 37,739 Source: Refer to Appendix 4.2-1 for operation model outputs and mobile emissions calculations.
Notes: CO2 = carbon dioxide; CH4 = methane; N20 = nitrous oxide; CO2e = carbon dioxide equivalent a. No stationary sources were identified as part of existing conditions. b. The proposed project would result in a net gain of 419 trees (the 581 new trees to be planted minus 162 existing trees to be removed) and 1.81 acres of vegetation (4.86 acres proposed compared with 3.05 acres existing) at the project site, resulting in increases in carbon sequestration and therefore a net carbon decrease in the atmosphere. c. Values may not add up because of rounding.
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The following sections present the sector-by-sector analysis of GHG impacts, consistent with OPR, CARB, and BAAQMD guidance.
Area-Source Emissions
Area-source GHG emissions from the Specific Plan would be generated by landscaping-related sources involving fuel combustion, such as lawn mowers. The proposed project would incorporate exterior electrical power infrastructure to support electric landscaping equipment. It would also plant trees, install biotreatment areas, and plant native and drought-tolerant landscaping as opposed to grass, which would minimize the routine use of mowers and other landscaping equipment.
The Scoping Plan does not include specific measures or 2030 emissions reduction requirements for landscaping equipment. OPR guidance recommends that land use development projects should strive to avoid the use of fossil fuels.53Although a transition away from fossil-fueled equipment would be needed to achieve carbon neutrality by 2045, the Scoping Plan does not assume the use of all-electric landscaping equipment in the 2030 reduction analysis. The proposed landscaping would reduce landscaping emissions compared with emissions from buildings with grass areas. This is consistent with the Scoping Plan’s overall goal of reducing emissions from fossil-fueled landscaping equipment.
Energy Emissions
GHGs are emitted directly from buildings through the combustion of any type of fuel (e.g., natural gas for cooking). GHGs can also be emitted indirectly from the generation of electricity from fossil fuels. The 2017 Scoping Plan outlines strategies for reducing energy demand and fossil fuel use while increasing energy efficiency and renewable energy generation. These strategies include transitioning to cleaner fuels, ensuring greater efficiency in existing buildings, and the electrification of end uses in commercial sectors. Although OPR recommends that new buildings should avoid the use of fossil fuels, the Scoping Plan does not assume all-electric buildings in the 2030 reduction analysis.
The proposed project requires building design features that reduce energy consumption and increase renewable energy generation, consistent with the Scoping Plan. For example, the Specific Plan requires new construction to achieve LEED Silver certification. Furthermore, buildings would achieve a 10 percent improvement in energy performance compared with an ASHRAE 90.1-2010 reference baseline building. Emissions from electricity consumption would be eliminated through the Specific Plan’s requirement to purchase 100 percent carbon-free electricity. New construction would be encouraged to design all-electric buildings, and any new natural gas appliances in buildings that use natural gas will be high-efficiency units. Although the Specific Plan encourages an all-electric design, it does not prohibit buildings from including natural gas appliances and the City has not adopted such regulations through changes to the building code. Natural gas appliances may be needed for individual tenant operations, particularly for R&D uses and operation of retail and/or tenant-serving kitchen uses in the amenities building. Furthermore, although the Specific Plan would result in the generation of emissions from natural gas use, the proposed project’s implementation of sustainability features would offset the increase in emissions from natural gas. In 53 Office of Planning and Research. 2018. CEQA and Climate Change Advisory. Discussion draft. Available:
https://opr.ca.gov/docs/20181228-Discussion_Draft_Climate_Change_Adivsory.pdf. Accessed: November 11, 2020.
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particular, the Specific Plan’s requirement to purchase 100 percent carbon-free electricity would exceed the statewide mandates for renewable energy, as noted in Regulatory Framework, above. In the buildout year of 2030, the proposed project would use 100 percent carbon-free electricity; the statewide target for renewables would be 60 percent. As such, the proposed project would reduce emissions relative to the RPS target in 2030. The reduction would amount to 3,102 metric tons of CO2e, which is the difference between 100 percent renewables and 60 percent renewables, based on PG&E’s utility emission factor for 2030.
Although the proposed project’s natural gas use would result in a net increase in energy-related emissions (i.e., 2,935 metric tons of CO2e) (see Table 4.7-5, p. 4.7-27 [difference between existing and 2030 with Specific Plan]), this net increase in energy-related emissions would be more than offset by the Specific Plan’s requirement to purchase 100 percent carbon-free electricity.
Mobile-Source Emissions
As discussed in Section 4.15, Transportation and Circulation, of this EIR, the proposed project would meet the criteria set by OPR and CEQA statute to establish the presumption of a less-than-significant impact on VMT under SB 743. Specifically, the proposed project is an employment center within 0.5 mile of a major transit station and a high-quality transit corridor, with a parking ratio below what would otherwise be required by the City for projects of this type. Project elements would be designed to encourage transit use and reduce the number of automobile trips to and from the site.
Furthermore, the proposed Southline Avenue extension would not be expected to increase VMT, being a street extension 0.25 mile in length with mostly local circulation effects. As discussed in Section 4.7.4.2, Approach to Analysis, there is a nexus between SB 743 and the state’s goals to reduce GHG emissions; as such, if the proposed project is consistent with the SB 743 screening thresholds, it would be considered to have a less-than-significant GHG impact related to mobile emissions.
Furthermore, as an infill transit-oriented development, the proposed project is anticipated to achieve an alternative mode share of 45 percent under the City’s TDM Ordinance, resulting in a 23 percent reduction in project VMT.
54 The proposed project would include mobility hubs to
accommodate a range of nearby project-transit services and reduce the need for private vehicle use by tenants and visitors. The project would provide electric vehicle charging infrastructure on-site for 10 percent of the parking spaces. The project would also expand pedestrian and bicycle infrastructure within the project site by expanding sidewalks and providing short- and long-term bicycle parking with showers and lockers to accommodate long-term users; therefore, the proposed project would be consistent with SB 743 and state and local policies to encourage transit-oriented development and reduce transportation emissions, and would not conflict with the state’s long-term emissions reduction trajectory.
Stationary-Source Emissions
As shown in Table 4.7-5, p. 4.7-27, emergency generator testing would generate 196 metric tons of CO2e per year in 2030. This is well below BAAQMD’s stationary-source threshold of 10,000 metric tons of CO2e per year. The project would not include any other significant stationary sources of GHGs.
54 Ibid.
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Waste Emissions
Solid waste may be disposed of in landfills or diverted for recycling, composting, or reuse. GHG emissions from landfills are generated through the anaerobic breakdown of material. The Scoping Plan aims to reduce waste emissions by diverting waste away from landfills through waste reduction, reuse, composting, and material recovery. In addition, AB 341 requires mandatory recycling for certain commercial businesses.
During construction and demolition, at least 65 percent of non-inert project waste materials and 100 percent of inert materials would be diverted from the landfill through recycling and salvage, as required by the City’s municipal code (Chapter 15.60). The applicant would also submit a Waste Management Plan.
During operations, the Specific Plan would incorporate extensive recycling and composting facilities to divert organic materials away from landfills and incorporate dedicated space and waste collection infrastructure (i.e., for batteries, mercury-containing light fixtures, electronic waste). These features would be consistent with the 2017 Scoping Plan’s overall goal of reducing waste emissions and its specific strategy to avoid CH4 emissions at landfills by reducing the disposal of waste and organics in landfills. In addition, these features would support and comply with the mandatory recycling requirement of AB 341 and support the state’s goal to reduce landfill waste and thus GHG emissions.
Water and Wastewater Emissions
Indirect GHG emissions result from the production of the electricity used to convey, treat, and distribute water and wastewater. The amount of electricity required depends on the volume of water as well as the source of the water. Additional wastewater emissions include CH4 and N2O, although these are generated by wastewater treatment at individual wastewater treatment plants.
The proposed project does not include any new wastewater treatment plants.
The 2017 Scoping Plan outlines objectives and goals to reduce GHGs in the water sector. These include using and reusing water more efficiently through greater water conservation, using droughttolerant landscaping, implementing stormwater capture measures, and recycling water. Regulations have further targeted water supply and water conservation (e.g., SB X7-7) through building and landscaping efficiency (e.g., Title 24). The Specific Plan does not include any features that would conflict with these measures and programs. The Specific Plan would incorporate several water conservation features to reduce indoor and outdoor water use. Native and drought-tolerant landscaping would reduce overall exterior water needs. Drip irrigation, rotary sprays, and other efficient methods for delivering water for landscaping would be incorporated, as would targeted hydro-zoning to address species-specific water needs. Weather-based irrigation controls would be incorporated to reduce potable water use when weather conditions allow. Interior water fixtures would include high-efficiency toilets, urinals, showerheads, and lavatories to reduce indoor water usage, in compliance with CALGreen standards. Furthermore, the proposed project would comply with all other applicable water conservation (indoor and outdoor) measures, including Title 24, Part 6, the California Energy Code baseline standard requirements for energy efficiency, based on the 2019 Energy Efficiency Standards, and the California Department of Water Resources Model Water Efficient Landscape Ordinance. These features are consistent with the Scoping Plan’s overall goal of reducing water emissions and serve to support ongoing regulatory programs (e.g., SB X7-7, Title 24) that aim to reduce GHG emissions associated with conveying and distributing water.
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Land Use Emissions
The Specific Plan would result in a net gain of 419 trees (which equals the 581 new trees to be planted minus the 162 existing trees to be removed) and 1.81 acres of vegetation (which equals the
4.86 acres proposed minus the 3.05 acres existing) in the Specific Plan area. The Specific Plan would thus be consistent with the Scoping Plan’s overall goal of avoiding losses in carbon sequestration and assist with meeting the state’s goals for climate neutrality (e.g., EO B-55-18) beyond 2030.
Conclusion
As described above, stationary-source emissions would be below BAAQMD’s stationary-source threshold. The proposed Specific Plan’s sustainability features represent a robust suite of strategies (i.e., BMPs) that are consistent with applicable policies from the Scoping Plan and other regulatory programs for the area, electricity, mobile, waste, and water sectors. The Specific Plan would also be consistent with the Scoping Plan’s overall goal of avoiding losses in carbon sequestration and limiting land use emissions. Finally, the Specific Plan would exceed statewide RPS targets by 40 percent in 2030 by purchasing 100 percent carbon-free electricity. Although the Specific Plan would involve the use of natural gas, the Specific Plan’s requirement to purchase carbon-free electricity would more than offset the net increase in emissions from energy sources between the Specific Plan in 2030 and existing conditions. Therefore, operational GHG impacts would be less than significant.
No mitigation is required.
Phase 1
The types of operational GHG emissions for Phase 1 would be similar to those described above for the Specific Plan. The analysis includes emissions benefits from the same sustainability design features described for the Specific Plan. Table 4.7-6, p. 4.7-32, summarizes by source emissions generated under existing conditions (2018) and 2024 conditions with and without Phase 1.
The following sections present the sector-by-sector analysis of GHG impacts, consistent with OPR, CARB, and BAAQMD guidance. Because Phase 1 would be in operation in 2024, the 2017 Scoping Plan, which outlines reduction targets through 2030, is the most relevant regulatory document for evaluating Phase 1.
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Table 4.7-6. Estimated Annual Unmitigated Phase 1 Operational GHG Emissions (metric tons) Condition/Source CO2 CH4 N2O CO2e
% of Total
CO2e
Existing (2018)
Area sources < 1 < 1 < 1 < 1 < 0.1%
Energy sources 312 < 1 < 1 313 0.9%
Mobile sources 33,714 2 < 1 33,761 98.6%
Stationary sourcesa 0 0 0 0 0.0%
Waste generation 55 3 < 1 137 0.4%
Water consumption 103 2 < 1 172 0.5%
Land useb < 1 < 1 < 1 -128 -0.4%
Total existingc 34,184 7 < 1 34,256 —
2024 without Phase 1
Area sources < 1 < 1 < 1 < 1 < 0.1%
Energy sources 165 < 1 < 1 166 0.4%
Mobile sources 28,549 1 < 1 28,582 71.8%
Stationary sourcesa 0 0 0 0 0.0%
Waste generation 55 3 < 1 137 0.3%
Water consumption 60 2 0 129 0.3%
Land Useb < 1 < 1 < 1 -128 -0.3%
Total 2024 without Phase 1c < 1 —
2024 with Phase 1
Area sources < 1 < 1 < 1 < 1 < 0.1%
Energy sources 880 < 1 < 1 885 2.2%
Mobile sources 38,184 2 < 1 38,228 96.1%
Stationary sources 196 < 1 < 1 196 0.5%
Waste generation 238 14 < 1 590 1.5%
Water consumption 31 3 < 1 134 0.3%
Land Useb < 1 < 1 < 1 -237 -0.6%
Total 2024 with Phase 1c 39,529 19 < 1 39,797 —
Net Increase with Phase 1
2024 with Phase 1 vs. 2024 without Phase 1c 10,701 12 < 1 10,912 — Source: Refer to Appendix 4.2-1 for operation model outputs and mobile emissions calculations.
Notes: CO2 = carbon dioxide; CH4 = methane; N20 = nitrous oxide; CO2e = carbon dioxide equivalent a. No stationary sources were identified as part of existing conditions. b. Phase 1 would result in a net gain of 149 trees (the 311 new trees to be planted minus 162 existing trees to be removed) and 0.92 acre of vegetation (3.97 acres proposed compared with 3.05 acres existing) at the project site, resulting in increases in carbon sequestration and therefore a net carbon decrease in the atmosphere. c. Values may not add up because of rounding.
Area-Source Emissions
Area-source GHG emissions from Phase 1 would be generated by landscaping-related sources involving fuel combustion, such as lawn mowers. Phase 1 would incorporate exterior electrical power infrastructure to support electric landscaping equipment. Phase 1 would also plant trees, City of South San Francisco
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install biotreatment areas, and plant native and drought-tolerant landscaping as opposed to grass, which would minimize the routine use of mowers and other landscaping equipment.
As noted above for the project analysis, the Scoping Plan does not include specific measures or 2030 emissions reduction requirements for landscaping equipment. The proposed landscaping would reduce landscaping emissions compared with emissions from buildings with grass areas and include a project feature (i.e., exterior electrical power infrastructure) to encourage further emissions reductions. This is consistent with the Scoping Plan’s overall goal of reducing emissions from fossilfueled landscaping equipment.
Energy Emissions
Phase 1 requires building design features that reduce energy consumption and increase renewable energy generation, consistent with the Scoping Plan. For example, all Phase 1 buildings would achieve LEED Silver certification. Buildings would also achieve a 10 percent improvement in energy performance compared with an ASHRAE 90.1-2010 reference baseline building. Emissions from electricity consumption would be eliminated by the Specific Plan’s requirement to purchase 100 percent carbon-free electricity. Any new natural gas appliances would be high-efficiency units.
Although OPR recommends that new buildings should avoid the use of fossil fuels, the Scoping Plan does not assume all-electric buildings in the 2030 reduction analysis. However, although Phase 1 would result in the generation of emissions from natural gas use, the implementation of sustainability features would offset the increase in emissions from natural gas. In particular, the requirement to purchase 100 percent carbon-free electricity would exceed statewide mandates for renewable energy, as noted in the Regulatory Framework, above. Phase 1 development would use 100 percent carbon-free electricity. The statewide target for renewables in 2024 (the opening year) would be 40 percent and in 2030 (the next statutory milestone) would be 60 percent. As such, Phase 1 would reduce emissions relative to the RPS target in 2030 by 1,097 metric tons CO2e, which is the difference between 100 percent renewables and 60 percent renewables, based on PG&E’s utility emissions factor for 2030.
Although natural gas use under Phase 1 would result in a net increase in energy-related emissions amounting to 719 metric tons of CO2e (see Table 4.7-6, p. 4.7-32 [difference between existing and 2024 with Phase 1]), this net increase in energy-related emissions would be more than offset by the requirement for Phase 1 to purchase 100 percent carbon-free electricity.
Mobile-Source Emissions
As discussed in Section 4.15, Transportation and Circulation, Phase 1 meets the criteria set by OPR and CEQA statute to establish the presumption of a less-than-significant impact on VMT under SB 743. Specifically, Phase 1 is part of an employment center within 0.5 mile of a major transit station and high-quality transit corridor, with a parking ratio below what would otherwise be required by the City for projects of this type. Project elements are designed to encourage transit use and reduce the number of automobile trips to and from the site. Furthermore, the proposed Southline Avenue extension would not be expected to increase VMT, being a street extension 0.25 mile in length with mostly local circulation effects. As discussed in Section 4.7.4.2, Approach to Analysis, there is a nexus between SB 743 and the state’s goals to reduce GHG emissions; as such, because Phase 1 is consistent with SB 743 screening thresholds, it would be considered to have a less-than-significant GHG impact from mobile emissions. Phase 1 would not conflict with the state’s long-term emissions reduction trajectory for the transportation sector.
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Stationary-Source Emissions
As shown in Table 4.7-6, p. 4.7-32, emergency generator testing would generate 196 metric tons of CO2e per year in 2024. This is below BAAQMD’s stationary source threshold of 10,000 metric tons of CO2e per year.
Waste Emissions
Phase 1 would incorporate extensive recycling and composting facilities to divert organic materials away from landfills and incorporate dedicated space and waste collection infrastructure for batteries, mercury-containing light fixtures, and electronic waste. During construction and demolition, at least 65 percent of non-inert project waste materials and 100 percent of inert materials would be diverted from the landfill through recycling and salvage, as required by the City’s municipal code (Chapter 15.60). The applicant would also submit a Waste Management Plan. These features would be consistent with the Scoping Plan’s overall goal of reducing waste emissions and its specific strategy to avoid landfill CH4 emissions by reducing the disposal of waste and organics in landfills. In addition, these features would support and comply with the mandatory recycling requirement of AB 341 as well as the state’s goal of reducing waste in landfills and thus GHG emissions.
Water Emissions
Phase 1 does not include any features that would conflict with the state’s measures and programs related to water conservation, water supply, drought-tolerant landscaping, stormwater capture, and water recycling. Phase 1 would incorporate several water conservation features that would reduce indoor and outdoor water use. Native and drought-tolerant landscaping would reduce overall exterior water needs. Drip irrigation, rotary sprays, and other efficient methods of delivering water for landscaping would be incorporated, as would targeted hydro-zoning to address species-specific water needs. Weather-based irrigation controls would be incorporated to reduce potable water use when weather conditions allow. Interior water fixtures would include high-efficiency toilets, urinals, showerheads, and lavatories to reduce indoor water usage, in compliance with CALGreen standards.
Furthermore, the proposed project would comply with all other applicable water conservation (indoor and outdoor) measures, including Title 24, Part 6, the California Energy Code baseline standard requirements for energy efficiency, based on the 2019 Energy Efficiency Standards, and the California Department of Water Resources Model Water Efficient Landscape Ordinance. These features would be consistent with the Scoping Plan’s overall goal of reducing water emissions and serve to support ongoing regulatory programs (e.g., SB X7-7, Title 24) that aim to reduce GHG emissions associated with conveying and distributing water.
Land Use Emissions
Phase 1 would result in a net gain of 149 trees (which equals the 311 new trees to be planted minus the 162 existing trees to be removed) and 0.93 acres of vegetation (which equals the 3.97 acres proposed minus the 3.05 acres existing) at the project site. Therefore, Phase 1 would be consistent with the Scoping Plan’s overall goal of avoiding losses in carbon sequestration and assist with meeting the state’s goals for climate neutrality (e.g., EO B-55-18) beyond 2030.
Conclusion
As described above, stationary-source emissions would be below BAAQMD’s stationary-source threshold. The Phase 1 sustainability features represent a robust suite of strategies (i.e., BMPs) that City of South San Francisco
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are consistent with the applicable policies from the Scoping Plan and other regulatory programs for the area, electricity, mobile, waste, and water sectors. Phase 1 would also be consistent with the Scoping Plan’s overall goal of avoiding losses in carbon sequestration and limiting land use emissions. Finally, Phase 1 would exceed the statewide RPS targets by 40 percent in 2030 (and 60 percent in 2024) by purchasing 100 percent carbon-free electricity. Although Phase 1 would involve the use of natural gas, the carbon-free electricity commitment would more than offset the net increase in emissions from energy sources between Phase 1 and existing conditions. Therefore, operational GHG impacts would be less than significant.
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 during construction and operation. (Project: Less than Significant with Mitigation; Phase 1: Less than Significant with Mitigation)
AB 32, SB 32, EO-S-3-05, and EO B-55-18
AB 32 and SB 32 outline the state’s GHG emissions reduction targets for 2020 and 2030, respectively. Although not legislatively adopted, EO S-03-05 establishes the state’s long-term goal to reduce GHG emissions by 80 percent from 1990 levels by 2050. EO B-55-18 sets a more ambitious state goal of net-zero GHG emissions by 2045.
CARB adopted the 2008 Scoping Plan and 2014 first update as a framework for achieving AB 32. The Scoping Plan and first update outline a series of technologically feasible and cost-effective measures to reduce statewide GHG emissions. CARB adopted the Climate Change Scoping Plan in November 2017 as a framework for achieving the 2030 GHG reduction goal described in SB 32. There is currently no state plan for addressing GHG reductions beyond 2030.
Based on CARB’s 2017 Scoping Plan, many of the reductions needed to meet the 2030 target will come from state regulations, including cap-and-trade requirements, the requirement for increased renewable energy sources in California’s energy supply, updates to Title 24, and increased emission reduction requirements for mobile sources. The 2017 Scoping Plan indicates that reductions would need to come in the form of changes pertaining to vehicle emissions and mileage standards, changes pertaining to sources of electricity and increased energy efficiency at existing facilities, and state and local plans, policies, or regulations to lower GHG emissions relative to business-as-usual conditions.
The 2017 Scoping Plan carries forward GHG reduction measures from the first update as well as new potential measures to help achieve the state’s 2030 target across all sectors of the California economy, including transportation, energy, and industry.
Project
Most GHG emissions generated by the construction activities would be short term and would cease once construction is complete. Implementation of Mitigation Measure GHG-1 would result in lessthan-significant impacts during construction. Therefore, construction activities under the Specific Plan would not conflict with or obstruct implementation of an applicable plan, policy, or regulation adopted for the purpose of reducing emissions of GHGs, and impacts would be less than significant with mitigation.
As described in Impact GHG-1b, stationary-source emissions would be below BAAQMD’s stationary-source threshold. The Specific Plan sustainability features represent a robust suite of strategies that are consistent with applicable policies from the Scoping Plan and regulatory City of South San Francisco
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programs for the area, electricity, mobile, waste, and water sectors. The Specific Plan would also be consistent with the Scoping Plan’s overall goal of avoiding losses in carbon sequestration and limiting land use emissions. These project features would assist the state with meeting its reduction targets under SB 32 as well as its carbon neutrality goal under EO B-55-18. Although the use of natural gas in future development would result in GHG emissions that would not be entirely consistent with OPR’s applicable guidance, the Specific Plan’s requirement to purchase 100 percent carbon-free electricity would exceed statewide RPS targets by 40 percent in 2030. As such, because the proposed project would go beyond the statewide mandates for renewable energy, a net increase in emissions from energy sources would not occur (see Energy Emissions in Impact-GHG-1b above), which is consistent with the state’s overarching climate goals. Therefore, the GHG impacts of the proposed project would be less than significant because the project would be consistent with state goals to reduce GHG emissions.
Phase 1
Phase 1 construction activities would also be short term and would cease once construction is complete. As discussed in Impact GHG-1, implementation of Mitigation Measure GHG-1 would result in less-than-significant impacts during construction. Therefore, construction activities under Phase 1 would not conflict with or obstruct implementation of an applicable plan, policy, or regulation adopted for the purpose of reducing emissions of GHGs. This impact would be less than significant with mitigation.
As described in Impact GHG-1b, stationary-source emissions would be below BAAQMD’s stationary-source threshold. Phase 1 sustainability features represent a robust suite of strategies that are consistent with applicable policies from the Scoping Plan and other regulatory programs for the area, electricity, mobile, waste, and water sectors. Phase 1 would also be consistent with the Scoping Plan’s overall goal of avoiding losses in carbon sequestration and limiting land use emissions. These project features would assist the state with meeting its reduction targets under AB 32 and SB 32 as well as its carbon neutrality goal under EO B-55-18. Although the use of natural gas in Phase 1 operations would result in GHG emissions would not be entirely consistent with OPR’s applicable guidance, the Specific Plan’s requirement to purchase 100 percent carbon-free electricity would exceed statewide RPS targets by 40 percent in 2030. As such, because Phase 1 would go beyond the statewide mandates for renewable energy, a net increase in emissions from energy sources would not occur (see Energy Emissions in Impact-GHG-1b above), which is consistent with the state’s overarching climate goals. Therefore, the GHG impacts of Phase 1 would be less than significant because the project would be consistent with state goals to reduce GHG emissions.
SB 375 and Plan Bay Area
Climate protection and transportation system effectiveness are two of seven goals addressed in MTC’s Plan Bay Area. Plan Bay Area provides a long-range framework to minimize transportation impacts on the environment, improve regional air quality, protect natural resources, and reduce GHG emissions. The plan supports smart growth principles, promotes infill development, and proactively links land use, air quality, and transportation needs in the region. Plan Bay Area is consistent with SB 375, which requires MTC to adopt an SCS that outlines policies to reduce perservice-population GHG emissions from automobiles and light-duty trucks. The SCS policies include a mix of strategies that encourage compact growth patterns, mixed-use designs, alternative transportation, transit, mobility and access, network expansion, and transportation investment.
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Implementation of the SCS is intended to improve the efficiency of the transportation system and support a variety of land use types throughout the Bay Area that meet market demands in a balanced and sustainable manner. The proposed project would be built around the concept of sustainability. Mixed-use development would be promoted, and green-building and transit-oriented development would be encouraged, as would energy efficiency, water conservation, and waste reductions.
The project, including Phase 1, would allow development that would help accommodate forecasted growth within the site. Plan Bay Area aims to increase average densities and infill development within Transit Priority Areas (TPAs) as a means to increase accessibility to quality transit which can reduce VMT and associated GHGs. Consistent with MTC goals, the project would be a transitoriented infill project with accessible pedestrian and bicycle infrastructure. The Specific Plan area is designated as a TPA under Plan Bay Area because it is within 0.5 mile of a major transit station and high-quality transit corridor.55 Furthermore, the proposed project is anticipated to achieve an alternative mode share of 45 percent under the City’s TDM Ordinance, resulting in a 23 percent reduction in VMT.
56 These sustainability design features would support alternative transportation within the site, which could help reduce per-service-population GHG emissions from passenger vehicles, consistent with Plan Bay Area. Therefore, the project would be consistent with the goals of SB 375 and Plan Bay Area. This impact would be less than significant.
South San Francisco Climate Action Plan
As discussed above, the City has not adopted a qualified GHG reduction plan beyond 2020 for the purposes of showing consistency with the 2030 SB 32 target. Thus, project-level tiering per CEQA Guidelines Section 15183.5 is not an applicable methodology for assessing the proposed project’s GHG impacts. Nonetheless, the City’s 2014 CAP measures and development requirements still apply to projects constructed and operated after 2020. As such, the analysis below evaluates the proposed project’s consistency with the CAP to determine whether the project would conflict with this local plan adopted for the purpose of reducing the emissions of GHGs.
The impacts of the proposed project are analyzed at a program level, and the impacts of Phase 1 are analyzed at a project level. In Appendix E of the CAP, the City offers a Development Review Checklist that provides project-level measures relevant to new development. Phase 1 was analyzed to determine whether it would conflict with the measures in the Development Review Checklist. As the impacts of the proposed project are analyzed at a program level, instead of using the project-level Development Review Checklist, the proposed project is analyzed to determine whether it would conflict with the CAP’s emission reduction measures.
Project
Table 4.7-7, p. 4.7-38, presents the consistency analysis of the proposed project and the applicable CAP emission reduction measures. With implementation of Mitigation Measure AQ-4, the project construction fleet would be required to use renewable diesel fuel, thereby being consistent with CAP Measure 2.2. The proposed project would be consistent with all the other CAP emission reduction 55 Metropolitan Transportation Commission (MTC). 2019. Transit Priority Areas (2017). Available:
https://opendata.mtc.ca.gov/datasets/d97b4f72543a40b2b85d59ac085e01a0_0?geometry=- 122.493%2C37.625%2C-122.330%2C37.649. Accessed: February 3, 2021. 56 Ibid.
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measures without mitigation. Therefore, this impact would be less than significant with mitigation.
Table 4.7-7. Consistency Analysis of Proposed Project with CAP Measures # Measure Consistent Explanation
1.1 Expand active transportation
alternatives by providing
infrastructure and enhancing
connectivity for bicycle and
pedestrian access.
Yes Class 2 bike lanes would be constructed on
Southline Avenue. As part of the off-site
improvements to circulation, a shared bicyclepedestrian path would be constructed on the east side of Huntington Avenue and on the west
side of Huntington Avenue from Southline
Avenue to the BART stations. Short- and longterm bicycle parking would be installed with showers and lockers. The proposed project also
includes improvements to the Centennial Way
Trail. The TDM Plan would offer subsidies for
transit and micromobility for employee
commute trips (such as bus, rail, ferry, bikeshare, and scooter-share).
1.2 Support expansion of public
and private transit programs
to reduce employee commutes.
Yes The proposed project’s TDM Plan is designed to
achieve a 45 percent alternative mode share as a
result of direct access to transit (BART and
SamTrans), onsite amenities for bicycle and
pedestrian access, shuttle service to Caltrain,
carpool and vanpool facilities and services, mode
shift incentives, and a mobility hub.
1.3 Integrate higher-density
development and mixed-use
development near transit
facilities and community
facilities and reduce
dependence on autos through
smart parking practices.
Yes The project will provide higher-intensity
office/R&D uses adjacent and connected to
nearby transit (Caltrain, BART, and SamTrans
buses along El Camino Real). An amenities
building (Building 2) would include a public
restaurant, a private cafeteria for campus
tenants, a private gym for campus tenants, and
an auditorium/event space to complement the
office uses of the surrounding buildings.
2.1 Expand the use of alternativefuel vehicles.Yes At least ten percent of onsite parking spaces would be installed with electric vehicle charging
infrastructure.
2.2 Reduce emissions from offroad vehicles and equipment.Yes Buildings would be installed with exterior electrical power infrastructure to support
electric landscaping equipment. Mitigation
Measure AQ-4 would require the construction
fleet to use renewable diesel fuel.
3.1 Maximize energy efficiency in
the built environment through
standards and the plan review
process.
Yes All buildings would achieve a LEED version 4
Silver rating and a 10 percent improvement in
energy performance compared with ASHRAE
90.1-2010 reference baseline building.
Additional energy efficiency measures include
energy-efficient windows, additional insulation,
external and internal shade structures, LED
lighting, daylighting and occupancy controls, and
efficient space heating and cooling systems.
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# Measure Consistent Explanation
3.2 Support retrofits to existing
residential structures.
N/A The proposed project does not involve retrofits
to existing residential structures.
3.3 Encourage energy efficiency
retrofits to the existing
nonresidential building stock
that reduce operating costs
and increase industry
competitiveness.
N/A The proposed project does not involve retrofits
to existing nonresidential structures.
3.4 Address heat island issues and
expand the urban forest.
Yes Vehicle parking would be provided in belowand above-ground parking structures instead of surface parking, avoiding the heat island impacts
associated with surface asphalt parking. The
Specific Plan includes design guidelines to
encourage use of light-colored or reflective
roofing materials. The proposed project would
result in a net gain of 419 trees (which equals
the 581 new trees to be planted minus the 162
existing trees to be removed) and 1.81 acres of
vegetation (4.86 acres proposed compared with
3.05 acres existing).
3.5 Promote energy information
and sharing and educate the
community about energyefficient behaviors and
construction.
N/A The City would implement this measure, which
is not applicable to individual development
projects.
4.1 Promote installation of
alternative energy facilities.
Yes The proposed project would not require on-site
renewable energy systems. However, the
Specific Plan would require the purchase of 100
percent carbon-free electricity for all
operational electricity needs through
participation in programs such as PG&E Solar
Choice or Peninsula Clean Energy.
4.2 Reduce the cost of alternative
energy installations.
N/A The City would implement this measure, which
is not applicable to individual development
projects.
4.3 Support green industries. N/A The City would implement this measure, which is not applicable to individual development
projects.
5.1 Develop a waste reduction
strategy to increase recycling
and reuse of materials to
achieve a 75 percent diversion
of landfilled waste by 2020.
N/A The City would implement this measure, which
is not applicable to individual development
projects.
5.2 Reduce landfill emissions. N/A See #5.1.
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# Measure Consistent Explanation
6.1 Reduce water demand. Yes The proposed project would comply with the 2019 CALGreen standards, as interior water
fixtures would include high-efficiency toilets,
urinals, showerheads, and lavatories, reducing
indoor water use. Stormwater runoff from the
project site will be treated with LID methods,
which may consist of bioretention basins, flow
through planters, pervious permeable
pavements. Native and drought-tolerant
landscaping would reduce overall exterior water
needs. Drip irrigation, rotary sprays, and other
efficient methods for delivering water for
landscaping would be incorporated, as would
targeted hydro-zoning to address speciesspecific water needs. Weather-based irrigation controls would be incorporated to reduce
potable water use when weather conditions
allow. Selected tree species will be climateappropriate to reduce water use.
6.2 Provide alternative water
resources for irrigation.
Yes The proposed project would include a
stormwater management plan and implement
engineered controls to allow stormwater
filtering, storage, and flood control. The
proposed project would also be required to
comply with the City’s water efficient
landscaping regulations, per the City’s Municipal
Code (Chapter 20.300.007).
7.1 Promote energy efficiency
policies at municipal facilities.
N/A The City would implement this measure, which
is not applicable to individual development
projects.
7.2 Conserve municipal water. N/A The City would implement this measure, which is not applicable to individual development
projects.
7.3 Reduce municipal waste. N/A The City would implement this measure, which is not applicable to individual development
projects.
7.4 Establish budgeting and
administrative practices that
support the CAP.
N/A The City would implement this measure, which
is not applicable to individual development
projects.
Source: City of South San Francisco. 2014. Climate Action Plan. Available:
https://www.ssf.net/home/showpublisheddocument?id=5640. Accessed: February 3, 2021.
Phase 1
Table 4.7-8, p. 4.7-41, presents the consistency analysis of Phase 1 and the CAP’s Development Review Checklist for new development. The proposed project would be consistent with nearly all of the Development Review Checklist’s measures, except for a potential inconsistency with a measure related to exceeding CALGreen standards for water fixture flow rates and another measure related to capturing rainwater for irrigation (see Table 4.7-8, p. 4.7-41, for more details). Even with this potential inconsistency, Phase 1 is consistent with the CAP’s Development Review Checklist as a City of South San Francisco
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whole, given its consistency with all other measures. Therefore, this impact would be less than significant.
Table 4.7-8. Consistency Analysis of Phase 1 with CAP Development Review Checklist # Measure Consistent Explanation
1 Does the project include
bicycle facilities (e.g.,
bicycle lanes, parking,
lockers)?
Yes Class 2 bike lanes would be constructed on Southline Avenue. As part of the off-site improvements to
circulation, a shared bicycle-pedestrian path would be
constructed on the east side of Huntington Avenue
and on the west side of Huntington Avenue from
Southline Avenue to the BART stations. Short- and
long-term bicycle parking would be installed with
showers and lockers. Phase 1 also includes
improvements to the Centennial Way Trail.
2 Will the project support
bike sharing/rental
programs?
Yes The TDM Plan would offer subsidies for transit and
micromobility for employee commute trips (such as
bus, rail, ferry, bike-share, and scooter-share).
3 Will there be a commute
shuttle or public transit
stop on-site or within 500
feet?
Yes The southwest boundary of the Phase 1 site is within 500 feet of the San Bruno BART station. The Phase 1
site is approximately 4,000 feet from the San Bruno
Caltrain station, and approximately 6,000 feet from
the South San Francisco Caltrain station. An onsite
mobility hub would accommodate shuttle, ride share,
and other passenger loading.
4 Is the project within ¼
mile of a Caltrain or BART
stop?
Yes See #3.
5 Will the project include
high-density housing and
a diverse range of
housing?
N/A Phase 1 would not include housing.
6 Will the project provide
traffic calming
treatments?
Yes See #1. In addition, as part of the off-site
improvements to circulation, new pedestrian/ADAcompliant ramps would be installed at the improved intersections. Bulb-outs and high-visibility crosswalks would be constructed at the BART station garage
intersection. Construction of a cul-de-sac on Tanforan
Avenue will also support traffic calming.
7 Is the project paying a
traffic impact fee to fund
bicycle and pedestrian
improvements?
Yes Phase 1 is required to pay a pedestrian and bicycle impact fee, per the City’s Municipal Code (Chapter
8.68).
8 Will the project provide
shared or reduced
parking?
Yes Onsite parking would be reduced by approximately 25 percent compared to the parking requirements for the
existing Business and Professional Office zoning
district.
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# Measure Consistent Explanation
9 Will the project provide
designated parking
spaces for electric
vehicles, carpool vehicles,
or other low-emissions
vehicles?
Yes Ten percent of onsite parking spaces (83 spaces)
would be installed with electric vehicle charging
infrastructure.
10 Will the project have any
ground-level commercial
space?
Yes An amenities building (Building 2) would include
publicly accessible ground floor dining/retail space.
11 Does the project include
any alternative-fuel
stations?
Yes See #9.
12 Will the project have any
pre-wiring or conduit
constructions to easily
add electric vehicle
charging stations or
alternative energy
facilities at a later date?
Yes See #9.
13 If this project is replacing
an existing building, is the
building being replaced
more than 30 years old?
Yes The existing uses include a variety of office, industrial, warehouse, and storage facilities that were largely
constructed in the 1940s and 1950s. All buildings
would be demolished during Phase 1.
14 Will certification of the
building be sought under
LEED or other green
building criteria?
Yes All Phase 1 buildings would achieve a LEED version 4 Silver rating.
15 Will the project include
any high-reflectivity
(“cool”) roof or surface
paving?
Yes Vehicle parking would be provided in below- and
above-ground parking structures instead of surface
parking, avoiding the heat island impacts associated
with surface asphalt parking. The Specific Plan
includes design guidelines to encourage use of lightcolored or reflective roofing materials. 16 Will there be a net
increase in the number of
mature trees on-site once
the project is completed?
Yes Phase 1 would result in a net gain of 149 trees (which equals the 311 new trees to be planted minus the 162
existing trees to be removed).
17 Will any renewable
energy system be
installed as part of this
project?
Yes Phase 1 would not be required to install any on-site renewable energy systems. However, the Specific Plan
would require the purchase of 100 percent carbonfree electricity for all operational electricity needs through participation in programs such as PG&E Solar
Choice or Peninsula Clean Energy. This requirement
would be applicable to Phase 1.
18 Is the project a new
nonresidential
conditioned space of
5,000 square feet or
more?
Yes Phase 1 includes multiple nonresidential conditioned spaces exceeding 5,000 square feet.
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# Measure Consistent Explanation
19 Will the project use
renewable energy
generated off-site?
Yes See #17.
20 Will there be composting
collection on-site?
Yes As required by AB 1826, Phase 1 would include
extensive recycling and composting facilities to divert organic materials away from landfills and incorporate
dedicated space and waste collection infrastructure
(i.e., for batteries, mercury-containing light fixtures, electronic waste).
21 Will any water fixtures
exceed CALGreen
standards?
Unknown Phase 1 would comply with current 2019 CALGreen standards. Interior water fixtures would include highefficiency toilets, urinals, showerheads, and lavatories, reducing indoor water use. Phase 1 does not
specifically require water fixtures to exceed CALGreen
standards, therefore it is unknown as to whether the
project’s water fixtures would exceed any CALGreen
standards related to flow rate requirements for water
fixture installations.
22 Will the project
incorporate low-impact
development (LID)
practices?
Yes Consistent with C.3 requirements in the MRP and the City of South San Francisco requirements, stormwater
runoff from the Phase 1 site will be treated through
LID methods, which may consist of bioretention
basins, flow through planters, pervious permeable
pavements, and other site design features intended to
manage stormwater runoff flows from the Phase 1 site
and to reduce stormwater pollution.
23 Will any xeriscaping be
installed?
Yes Native and drought-tolerant landscaping would
reduce overall exterior water needs. Drip irrigation,
rotary sprays, and other efficient methods for
delivering water for landscaping would be
incorporated, as would targeted hydro-zoning to
address species-specific water needs. Weather-based
irrigation controls would be incorporated to reduce
potable water use when weather conditions allow.
Selected tree species will be climate-appropriate to
reduce water use and the need for fertilizer.
24 Will captured rainwater
or graywater be used for
irrigation?
No Phase 1 would not include rainwater or graywater
irrigation. While the City has an existing recycled
water distribution system, it does not connect to the
Phase 1 site, and there are no future plans for it to be expanded to the area.
Source: City of South San Francisco. 2014. Climate Action Plan. Available:
https://www.ssf.net/home/showpublisheddocument?id=5640. Accessed: February 3, 2021.
Consistency with Other State Regulations
As discussed above, systemic changes will be required at the state level to achieve California’s future GHG reduction goals. Regulations, such as future amendments to the low-carbon fuel standard, updates to the state’s Title 24 standards, and implementation of the state’s SLCP Reduction Strategy, including forthcoming regulations for composting and organics diversion, will be necessary to attain the magnitude of reductions required for the state’s goals. The project, including Phase 1, would be City of South San Francisco
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required to comply with these regulations in new construction (in the case of updated Title 24 standards) or be directly affected by the outcomes (vehicle trips and energy consumption would be less carbon intensive because of statewide compliance with future low-carbon fuel standard amendments and increasingly stringent RPS). Therefore, for the foreseeable future, the Specific Plan would not conflict with any other state-level regulations pertaining to GHGs in the post-2020 era.
This impact would be less than significant.
Implementation of Mitigation Measure GHG-1, discussed above under Impact GHG-1, would reduce the project, including Phase 1, impact related to consistency with GHG plans to a less-thansignificant level. This impact would be less than significant with mitigation.
4.7.4.4 Cumulative Impacts
Climate change is a global problem, and GHGs are global pollutants, unlike criteria air pollutants (e.g., ozone precursors), which are primarily pollutants of regional and local concern. Given the long atmospheric lifetimes, GHGs emitted by sources worldwide accumulate in the atmosphere. No single emitter of GHGs is large enough to trigger global climate change on its own. Rather, climate change is the result of the individual contributions of countless past, present, and future sources. Therefore, GHG emissions impacts are inherently cumulative. The analysis above is inclusive of cumulative impacts.
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4.8 Hazards and Hazardous Materials
4.8.1 Introduction
This section evaluates the potential impacts related to construction and operation of the Southline Specific Plan and off-site improvements (proposed project), including the first phase of development under the proposed project (Phase 1), on hazards and hazardous materials. This section also describes the existing conditions at the project site, including the Phase 1 site, as well as the regulatory framework for this analysis. The impacts of the proposed project are generally analyzed at a program level, and the impacts of Phase 1 are analyzed at a project level. Impacts resulting from implementation of the proposed project, impacts resulting from implementation of Phase 1, and cumulative impacts are described. Feasible mitigation measures, where applicable, are also described. Relevant technical documentation used in this analysis includes multiple hazardous materials technical reports prepared for properties within the Specific Plan area, including Phase I and Phase II Environmental Site Assessments (ESAs) (Appendix 4.8-1). Although the subject properties of the hazardous materials technical reports do not include the off-site improvement areas, the environmental database searches conducted for the Phase I ESAs, which generally cover a one-mile radius from the subject site, included the off-site improvement areas. Therefore, this analysis assumes that conditions, impacts, and recommendations identified for the Specific Plan area also generally apply to the off-site improvement areas, with exceptions for site specific conditions described in this section.
Issues identified in response to the Notice of Preparation (NOP) (Appendix 1) were considered in preparing this analysis. The NOP comments pertaining to hazards and hazardous materials include the proper handling of hazardous materials. This issue is addressed below in Section 4.8.4, Impacts and Mitigation Measures.
4.8.2 Environmental Setting
This section provides a discussion of the existing conditions related to hazards and hazardous materials on the project site.
4.8.2.1 Regional Setting
The City of South San Francisco is largely composed of single-use areas, with industry in the eastern and southeastern portions of the City and single-family homes to the north and west. Much of the City is urbanized, with little vacant land. Land uses surrounding the project site include commercial, industrial, and warehouse facilities, located to the north and east; residential uses to the south; and the San Bruno Bay Area Rapid Transit (BART) station and The Shops at Tanforan and San Bruno Towne Center to the west.
4.8.2.2 Project Site
The project site comprises the Specific Plan area and the off-site improvement areas. Existing uses within the Specific Plan area, which encompasses seven parcels, include a variety of occupied and unoccupied office, industrial, warehouse, and storage facilities that were largely constructed in the 1940s and 1950s. Six of the parcels contain 15 buildings and/or structures, 11 of which were City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Hazards and Hazardous Materials
Southline Specific Plan EIR 4.8-2September 2021
ICF 0082.20
constructed more than 45 years ago. The seventh parcel is a vacant right-of-way that formerly contained an SPRR spur. The existing structures within the Specific Plan area total nearly 344,000 square feet and include approximately 380 surface parking spaces. Surface parking lots and storage areas are interspersed among the buildings. The off-site improvement areas consist of rights-of-way and easements developed with roadway, sidewalk, and utility improvements in the Cities of South San Francisco and San Bruno. The off-site improvement areas do not include any developed land uses. The topography of the project site and surrounding area is relatively flat, with a slight slope toward the northeast.
Specific Plan Area
Hazardous Materials Identified in Previous Environmental Investigations The Specific Plan area has a history of contamination related to its use over the years for various industrial, warehouse, and storage facilities uses; a series of recent environmental investigations have been conducted to evaluate the subsurface conditions within the Specific Plan area. Multiple reports were prepared between 2017 and 2020 for various locations within the Specific Plan area, including the Phase 1 site. The technical reports, included in Appendix 4.8-1 of this EIR, are listed below and grouped by address (an asterisk indicates that the address falls within the Phase 1 site). ⚫ 240 Dollar Avenue*
Phase I ESA of Mini Warehouses, 240 Dollar Avenue, ATC Group Services LLC, 2018. Limited Phase II ESA Report, 240 Dollar Avenue, ATC Group Services LLC, 2018. ⚫ 240 Dollar Avenue and 180 South Linden Avenue*
Pre-Renovation Hazardous Materials Survey, 240 Dollar Avenue and 180 South Linden Avenue, ATC Group Services LLC, 2018.
⚫ 160 South Linden Avenue*
Phase I ESA, Compass Transportation, 160 South Linden Avenue, ATC Group Services LLC, 2018
Pre-Renovation Hazardous Materials Survey, Multi-Tenant 3-Story Building, Maintenance Building, and Bus Wash, 160 South Linden Avenue, ATC Group Services LLC, 2018 ⚫ 54 Tanforan Avenue*
Supplemental Site Assessment Report, 54 Tanforan Avenue, ATC Group Services LLC, 2020. ⚫ 50 Tanforan Avenue*
Phase I ESA of Mainfreight, 50 Tanforan Avenue, ATC Group Services LLC, 2018. Limited Phase II ESA Report, 50 Tanforan Avenue, ATC Group Services LLC, 2018. Pre-Renovation Polychlorinated Biphenyl (PCB) Survey, 2018. ⚫ 30, 40, 46 Tanforan Avenue and 335, 347, 349 South Maple Avenue* Phase I ESA of Malaspina Property, 30, 40, 46 Tanforan Ave & 335, 347, 349 S. Maple Avenue, ATC Group Services LLC, 2017.
City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Hazards and Hazardous Materials
Southline Specific Plan EIR 4.8-3September 2021
ICF 0082.20
⚫ 30 and 40 Tanforan Avenue*
Pre-Renovation Hazardous Materials Survey, 30 & 40 Tanforan Avenue, ATC Group Services LLC, 2017.
⚫ 325 South Maple Avenue
Phase I ESA of 325 Maple Avenue and 325 South Maple Avenue, ATC Group Services LLC, 2019. In addition to 325 South Maple Avenue, the Phase I ESA also includes the properties at 315 and 319 South Maple Avenue.
Former Sludge Pond Soil Sampling Report, 325 South Maple Avenue, ATC Group Services LLC, 2019. This report is not summarized below as its conclusions were taken into consideration in the Phase I ESA’s findings.
The following section summarizes the objectives, findings, and recommendations as presented in each report. The following defined terms are used in the summary below:
⚫ Recognized environmental conditions (RECs): The American Society for Testing and Materials (ASTM) defines recognized environmental conditions as the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: (1) due to any release to the environment; (2) under conditions indicative of a release to the environment; or (3) under conditions that pose a material threat of a future release to the environment. o Historical recognized environmental condition (HREC) - a past release of any hazardous substances or petroleum products that has occurred in connection with the property and has been addressed to the satisfaction of the applicable regulatory authority or meeting unrestricted use criteria established by a regulatory authority, without subjecting the property to any required controls (for example, property use restrictions, activity and use limitations, institutional controls, or engineering controls). Before calling the past release a HREC, the environmental professional (EP) must determine whether the past release is a REC at the time the assessment is conducted (for example, if there has been a change in the regulatory criteria). o Controlled recognized environmental condition (CREC) - a recognized environmental condition resulting from a past release of hazardous substances or petroleum products that has been addressed to the satisfaction of the applicable regulatory authority, with hazardous substances or petroleum products allowed to remain in place subject to the implementation of required controls (property use restrictions, activity and use limitation, institutional controls, or engineering controls).
⚫ Business environmental risks: refers to a risk which can have a material environmental or environmentally-driven impact on the business associated with the current or planned use of a parcel of commercial real estate, not necessarily limited to those environmental issues required to be investigated per the ASTM standard.
⚫ De minimis conditions: is a condition that generally does not present a threat to human health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of the appropriate governmental agencies.
RECs, CRECs or HRECs were identified for 240 Dollar Avenue, 50 Tanforan Avenue, the Malaspina Property and 325 Maple Avenue sites. The specific findings and conclusions, along with any recommendations are detailed below.
City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Hazards and Hazardous Materials
Southline Specific Plan EIR 4.8-4September 2021
ICF 0082.20
240 Dollar Avenue
2018 Phase I ESA of Mini Warehouses, 240 Dollar Avenue
ATC Group Services LLC (ATC) performed a Phase I ESA of the property at 240 Dollar Avenue. The objective of the Phase I ESA was to identify RECs in connection with the property.
Findings
One REC was identified associated with the property:
⚫ Trench drains were identified in the property’s maintenance building. The discharge location of the drains was unknown and based on the historical use of the property (automotive repair), the unknown discharge point was considered a REC.
Several business environmental risks were also identified:
⚫ DuPont manufacturing operated on-site until at least the late 1980s when the property operations changed. At the time of the operations change, soil samples were collected in representative areas throughout the property. The soil samples did not identify evidence of constituents of concern or COCs (COCs are defined as specific chemicals that are identified for evaluation in the site assessment process) on-site above laboratory detection limits and/or regulatory action levels for commercial/industrial land use. However, no groundwater samples were collected. The absence of groundwater samples given the historical industrial and maintenance activities at the property were identified as a business environmental risk as groundwater was not characterized.
⚫ An adjoining site (to the north) associated with 160 South Linden Avenue, historically operated one 4,000-gallon thinner underground storage tank (UST), which was reportedly removed in 1985. A prior investigation not related to the proposed project (and identified in the Phase I ESA) conducted in the vicinity of the former UST identified petroleum constituents in groundwater 25 feet from the 240 Dollar Avenue site. Benzene and naphthalene in groundwater were reported in excess of the commercial exposure scenario vapor intrusion carcinogenic risk according to the OSWER Vapor Intrusion Assessment Groundwater Concentration to Indoor Air Concentration (GWC-IAC), June 2017 Regional Screening Levels (RSLs) or the Regional Water Quality Control Board (RWQCB) Environmental Screening Levels (ESLs) for indoor air impact in a commercial/industrial land use. The potential for vapor migration was considered a business environmental risk based on the use of the property at the time as warehouse storage space. ⚫ Due to construction date of on-site buildings (1930s and 1950s), Asbestos Containing Materials and Lead-Based Paint may be present.
The following de minimis conditions were also identified:
⚫ Oil staining was observed in a maintenance building and in the parking area around stored vehicles and discarded vehicle engines.
⚫ An open pipe or drain was observed outside the warehouse building. The feature appeared to be steel with no cover. Oil staining was observed on the concrete next to as well as inside the observed feature. Absorbent material had been placed on a portion of the stained area.
City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Hazards and Hazardous Materials
Southline Specific Plan EIR 4.8-5September 2021
ICF 0082.20
2018 Limited Phase II ESA Report, 240 Dollar Avenue
ATC performed a Phase II ESA on the property at 240 Dollar Avenue. ATC advanced five soil borings on May 3 and 4, 2018, three of which were used for groundwater sampling. Soil samples were collected at depths of 5, 10, and 15 feet below ground surface (bgs). Groundwater samples were taken at a depth ranging from approximately 12 to 14 feet bgs. The Phase II ESA investigation was conducted to supplement prior site characterizations conducted in October 2017 and March of 2018. All three sampling events were conducted to assess potential environmental concerns associated with historical (paint manufacturing) and current (bus maintenance) activities at the property. The following results were observed:
Soil
⚫ No gasoline or VOCs were reported above Environmental Screening Levels (ESLs). ⚫ Arsenic ranged in concentrations of 1.8 milligrams per kilogram (mg/kg) to 19 mg/kg, which are considered within normal background levels.
⚫ Chromium ranged from 32 to 54 mg/kg in the soil samples analyzed, which is within normal background levels for this area.
According to the Phase II ESA, soil sample results indicated that soil in the areas assessed did not represent an environmental risk.
Groundwater
⚫ No gasoline was reported above ESLs.
⚫ Naphthalene was reported in the four groundwater samples in concentrations ranging from 2.0 to 2.1 micrograms per liter (µg/L), which were below the ESLs for Groundwater Vapor Intrusion Human Health Risk Levels for Shallow Groundwater at Commercial Sites (170 µg/L). ⚫ Metals in groundwater were reported above the ESL for Direct Exposure Maximum Contaminant Level (MCL) Priority (Drinking Water); however, groundwater samples were unfiltered and deemed as not appropriate for comparison to MCL-based ESLs.
According to the Phase II ESA, concentrations of metals and naphthalene detected in groundwater are unlikely to materially impact the future use or development of the property as shallow groundwater is unlikely to be used as source of drinking water and naphthalene was not detected in concentrations indicating the source was on-site. In addition, sampling results indicated an absence of historical petroleum-related releases into groundwater at the property.
The Phase II ESA recommendation included further delineation of trench drain lines to verify where historical waste liquid may have discharged, as was also identified as a REC during the Phase I ESA. summarized above.
240 Dollar Avenue and 180 South Linden Avenue
2018 Pre-Renovation Hazardous Materials Survey, 240 Dollar Avenue and 180 South Linden Avenue ATC performed a pre-renovation hazardous materials survey of the buildings located at 240 Dollar Avenue and 180 South Linden Avenue on August 29, 2018. The purpose of the survey was to determine the presence of asbestos-containing materials (ACMs), asbestos-containing construction materials (ACCMs), lead-based paint (LBP), lead-containing paint (LCP), and PCBs within on-site City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Hazards and Hazardous Materials
Southline Specific Plan EIR 4.8-6September 2021
ICF 0082.20
buildings. Materials containing asbestos and lead-containing materials were identified in buildings located at both 240 Dollar Avenue and 180 South Linden Avenue.
The survey recommended removal of ACMs and ACCMs to be disturbed prior to any demolition activities. In addition, the removal and/or stabilization of building materials containing LBP would also be required prior to demolition.
160 South Linden Avenue
2018 Phase I ESA of Compass Transportation, 160 South Linden Avenue ATC performed a Phase I ESA of the property at 160 South Linden Avenue.
Findings
One controlled REC was identified associated with the property:
⚫ The 160 South Linden Avenue site has a history of contaminated soil and groundwater due to historic land uses associated with a DuPont paint manufacturing plant (on-site from 1934 to 1982). According to the Phase I ESA, a San Mateo County Groundwater Protection Program Case Closure Memorandum dated December 21, 2010 stated that the extent of hydrocarbonimpacted groundwater had been adequately defined, and although residual concentrations exceeded drinking water ESLs, no exposure pathway to human or environmental receptors existed. A commercial deed restriction1 was recorded for the 160 South Linden Avenue site at the time. The Phase I ESA suggested that dissolved-phase plume is decreasing with time, and residual concentrations should reach drinking water screening levels within a reasonable amount of time. On September 6, 2011, San Mateo County Environmental Health issued a no further action letter (NFA) relating to the petroleum releases at the 160 South Linden Avenue site. Due to the risk-based closure for soil and groundwater and the implementation of deed restrictions at the site, the Phase I ESA determined this to be a controlled REC. The 160 South Linden Avenue site was identified as part of the Department of Toxic Substances Control (DTSC)’s Cleanup Sites database and thus is considered a Cortese List site. Cortese List sites are discussed in more detail below.
The Phase I ESA identified several business environmental risks:
⚫ In 2007, a groundwater sampling event indicated constituent levels exceeded RWQCB ESLs for groundwater at several sample locations on-site and the adjacent property at 150 South Linden Avenue; however, none of the groundwater sample results exceeded the Site-Specific Target Levels (SSTL) developed for the DuPont facility or the RWQCB ESLs for indoor air impacts for commercial/industrial land uses. The Vapor Encroachment Concern (VEC) associated with the aforementioned constituents in groundwater were considered a business environmental risk. ⚫ Four violations were issued to the site during an April 2018 pursuant to San Mateo County Environmental Health Services inspection: open 55-gallon containers of oil and oil filters; failure to maintain and operate the facility to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents (used oil dripping around the used oil tank and poor maintenance practices); evidence of a spill 1 Development of the property was restricted to industrial and commercial land use. In addition, no uses or development of the property that would disturb soil were to be permitted without a Soil Management Plan and Health and Safety Plan submitted to the San Mateo County Environmental Health prior to disturbance.
City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Hazards and Hazardous Materials
Southline Specific Plan EIR 4.8-7September 2021
ICF 0082.20
or leak from a used oil tank; and failure to properly label hazardous materials. San Mateo County Environmental Health Services required that these conditions be addressed by May 2018.
However, observations made during the preparation of the Phase I ESA indicated that the violations had not been resolved; the Phase 1 ESA concluded that these conditions were considered a business environmental risk as they were still outstanding at the time. ⚫ Due to the construction date of the on-site buildings (1934), ACMs and LBP may be present.
The following de minimis conditions were also identified:
⚫ Several aboveground storage tanks (ASTs) were identified within a maintenance building and contained used oil, coolant, and automatic transmission fluid. Staining was observed on and around the ASTs. No drains were present in the vicinity of the ASTs and the concrete was observed in good condition, with no evidence of cracks or deterioration. ⚫ ATC observed diesel-staining within the secondary containment area of a 13,000-gallon AST fueling dispenser, on the concrete next to the dispenser, on a secondary containment pallet, and on a 55-gallon drum. The concrete around the dispenser island and the presence of steel secondary containment were in good condition.
⚫ Petroleum staining was observed on and around the containers (drums of varying capacity) of used product (oil, coolant, etc.) in the maintenance building. The containers were not stored in secondary containment. Oil staining and spills were observed on the concrete throughout the interior of the maintenance building and within a service pit. Oil staining was also observed on and around the air compressors in the maintenance building’s exterior. Based on the good condition of the concrete and the absence of drains or exposure pathways, oil staining described was considered a de minimis condition.
⚫ Discarded miscellaneous materials were observed on exposed soil next to on-site dumpsters.
Oil-stained soil (approximately 10 square feet) was observed on the ground surface in this area. 2018 Pre-Renovation Hazardous Materials Survey, Multi-Tenant 3-Story Building, Maintenance Building, & Bus Wash, 160 South Linden Avenue
ATC performed a pre-renovation hazardous materials survey of the buildings located at 160 South Linden Avenue on August 29, 2018. The purpose of the survey was to determine the presence of ACMs, ACCMs, LBP, LCP, and PCBs within the on-site buildings. Materials containing asbestos and lead-containing materials were identified in buildings located at 160 South Linden Avenue.
Asbestos, lead-containing, and Excluded PCB Product materials were identified during the hazardous materials survey. ATC recommended removal of ACMs and ACCMs to be disturbed prior to any demolition activities. Removal and/or stabilization of building materials containing LBP would also be required prior to demolition. For Excluded PCB Product materials, ATC recommended removal prior to any demolition activities. In addition, ATC recommended that bulk samples be collected to further characterize PCB content of window caulk. 54 Tanforan Avenue
2020 Supplemental Site Assessment Report, 54 Tanforan Avenue The Supplemental Site Assessment was conducted by ATC in January 2020 in response to a letter dated January 7, 2020 from the San Mateo County Groundwater Protection Program (SMCGPP) City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Hazards and Hazardous Materials
Southline Specific Plan EIR 4.8-8September 2021
ICF 0082.20
regarding a prior Supplemental Site Assessment Report, dated September 17, 2019. In the letter, SMCGPP requested the following:
⚫ The vertical extent of lead in soil at specific locations (at historical soil boring locations HA3, HA11 and HA12) should be defined.
⚫ Groundwater samples should be collected adjacent to historical soil borings B3, B4, and B5 to define the lateral extent of dissolved metals in groundwater.
Prior Site Assessments Summarized
During prior site assessments (conducted in 2010, 2018 and 2019), petroleum hydrocarbons within the diesel range, and select heavy metals in soil were detected at concentrations in excess of Commercial and/or Construction Worker ESLs in a former railroad spurs area and former northern aboveground oil storage area. Foundry-related waste materials were also identified in these areas.
Groundwater in the vicinity of a former aboveground oil storage area and the northern portion of a former foundry building indicated petroleum hydrocarbons in excess of the Drinking Water ESL predominantly within the diesel to oil range. Carbon tetrachloride was the only VOC detected in groundwater at concentrations in excess of Groundwater vapor intrusion ESLs. 2020 Supplemental Site Assessment
As mentioned, the objective of this site assessment was to confirm the vertical extent of lead in soil and to define lateral extent of dissolved metals in groundwater. Thirteen soil samples were collected and analyzed for lead. Lead was detected at concentrations equal to or exceeding the laboratory method detection limit (MDL) in each of the soil samples at concentrations ranging from 2.07 mg/kg (B14-12) to 9.37 mg/kg (B13-5.5). All of the lead concentrations were below the Commercial/Industrial ESL (320 mg/kg) and Construction Worker ESL (160 mg/kg). Based on these results, ATC concluded that the vertical extent of site-wide lead impacted soil at concentrations in excess of the Commercial/Industrial and Construction Worker ESL as well as lead characterized as California hazardous waste is most likely limited to a depth of less than 5 feet bgs.
Three groundwater samples were also collected and analyzed for metals. Cobalt was detected in one sample at a concentration of 9.68 µg/L and in another at a concentration of 7.79, exceeding the Drinking Water ESL (6.0 µg/L). The detected concentration of cobalt in groundwater was flagged as a J-value by the laboratory. A J-value indicates a result that is less than the laboratory reporting limit but greater than the MDL, thus, the reported concentration is considered an estimated value. No other constituents detected in the groundwater samples indicated concentrations equal to or exceeding applicable drinking water ESLs. ATC concluded that the presence of cobalt in groundwater is not considered to materially impact potential beneficial groundwater uses as shallow groundwater is not used as a drinking water source. The lateral extent of site-wide dissolved metals in groundwater was determined to be adequately defined. 50 Tanforan Avenue
2018 Phase I ESA of Mainfreight, 50 Tanforan Avenue
ATC performed a Phase I ESA of the property at 50 Tanforan Avenue.
City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Hazards and Hazardous Materials
Southline Specific Plan EIR 4.8-9September 2021
ICF 0082.20
Findings
One REC was identified associated with the site:
⚫ Review of the historical documents indicated that the property has been utilized for industrial operations since the 1940s. Prior on-site use consisted of a bunk house, private garages, and an oil house associated with the northern adjoining industrial facility. The property was redeveloped with the existing industrial building in 1959. A potential previously unidentified release from historical activities in 1963 was identified to the east of the on-site building during preparation of the Phase I ESA. The potential subsurface impacts associated with long-term industrial operations and the potential release identified in 1963 were considered a REC.
One historical REC was identified associated with the property:
⚫ A review of the regulatory records indicated one 10,000-gallon diesel UST was formerly located on the east side of the property building. The UST was registered in 1988 and was removed in 1994. Petroleum-containing soil and groundwater were identified during subsequent sampling events. Remediation activities included the removal of approximately 250 cubic yards of diesel-containing soil and approximately 1,300-gallons of groundwater from the property. A letter was reportedly issued from the County on October 10, 1995, stating soil had been remediated to the satisfaction of the county; however, groundwater monitoring was still required. By the fifth quarter of groundwater sampling, no significant concentrations of hydrocarbon compounds were reported and closure was requested.
Case closure was granted by the San Mateo County Department of Health Services pending the abandonment of the on-site monitoring wells in a letter dated November 5, 1996. Due to regulatory closure, the former UST and associated release were considered a historical REC. As the site was listed in the LUST database, it is also considered a Cortese List site.
Cortese List sites are described in more detail below.
2018 Limited Phase II ESA Report, 50 Tanforan Avenue
ATC performed a Phase II ESA on the property at 50 Tanforan Avenue. The objective of the Phase II ESA was to characterize subsurface conditions at the 50 Tanforan Avenue site. ATC advanced six soil borings on August 2 and 3, 2018, all of which were used for groundwater sampling. Soil samples were collected at depths of 5, 10, and 15 feet bgs. Groundwater samples were taken at a depth ranging from approximately 8 to 10 feet bgs. The following results were observed:
Soil
⚫ No gasoline, diesel, oil or VOCs were reported above ESLs. ⚫ Arsenic ranged in concentrations of 2.5 mg/kg to 9.2 mg/kg, which are considered within normal background levels.
⚫ Chromium ranged from 7.5 to 69 mg/kg in the soil samples analyzed, which is within normal background levels for this area.
City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Hazards and Hazardous Materials
Southline Specific Plan EIR 4.8-10 September 2021
ICF 0082.20
⚫ Lead was reported above the ESLs for Soil Exposure/Construction Worker (86 mg/kg) at 170 mg/kg and 140 mg/kg in two different samples. However, both samples were below the Toxicity Characteristic Leaching Procedure (TCLP)2 threshold of 5 mg/L. ⚫ Concentrations of nickel samples ranged from 4 mg/kg to 59 mg/kg with one outlier sample detected at 170 mg/kg and above the ESLs for Soil Exposure/Construction Worker (160 mg/kg).
According to the Phase II ESA, soil sample results indicated that soil in the areas assessed did not represent an environmental risk.
Groundwater
⚫ Two groundwater samples contained diesel range organics above ESLs (at 150 and 270 µg/L, respectively).
⚫ Arsenic was reported at concentrations ranging from 17 to 21 µg/L, and thallium was reported at concentrations ranging from 25 to 28 µg/L. Both metals were reported above the ESL for Direct Exposure MCL Priority (Drinking Water) for arsenic (10 µg/L) and for thallium (2 µg/L).
According to the Phase II ESA, arsenic and thallium were reported in groundwater at similar concentrations at neighboring sites (54 Tanforan Avenue and 240 Dollar Avenue) and appear to represent background levels in ground water.
The Phase II ESA recommended that a soil management plan be prepared prior to initiating for future site development activities. The soil management plan should document specific dust mitigation, soil management, and waste characterization activities for excess soil generated during site development.
2018 Pre-Renovation PCB Survey, Mainfreight, 50 Tanforan Avenue ATC performed a pre-renovation PCB survey of the buildings located at 50 Tanforan Avenue on August 29, 2018. The purpose of the survey was to determine the presence of polychlorinated biphenyls within on-site buildings. PCB analytical results indicated that none of the sampled materials contained greater than the detection limit of PCBs and therefore, were not above the remediation or hazardous waste thresholds.
30, 40, 46 Tanforan Avenue & 335, 347, 349 S. Maple Avenue 2017 Phase I ESA of Malaspina Property, 30, 40, 46 Tanforan Ave & 335,3 347, 349 S. Maple Avenue ATC performed a Phase I ESA of the Malaspina site in April of 2017. The Malaspina site is shown in Figure 3.8-1, p. 4.8-11. In addition, ATC conducted a limited screening for potential VECs. One REC and one VEC were identified and are described below.
2 According to the EPA, the TCLP is an analytical procedure designed to determine the mobility of both organic and inorganic analytes present in liquid, solid, and multiphasic wastes. 3 335 S. Maple Avenue has since been demolished and is no longer present on the project site.
Figure 1
Malaspina Property and Surrounding Properties
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Building 4
(347 & 349 S Maple Ave)
Former Site of 335
S Maple Ave
South Maple Business Park
(315 - 325 S Maple Ave)
2 Building 3
(40 Tanforan Ave)
Building 1
(30 Tanforan Ave)
Mainfreight
(50 Tanforan Ave)
Loop Transportation
(54 Tanforan Ave)
Building 5 (Former)
(46 Tanforan Ave)
Malaspina Site
8 7
6 5
4 3
1 0 200
Feet
!( Properties
Malaspina Site
Specific Plan Area
1:2,500
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Note: Areas shown are based on information presented in the 2017 ATC Phase I ESA for the Former Malaspina Property 30, 40, 46 Tanforan Avenue and 335, 347, 349 S Maple Avenue.
City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Hazards and Hazardous Materials
Southline Specific Plan EIR 4.8-12 September 2021
ICF 0082.20
Findings
One REC was identified associated with the Malaspina site:
⚫ An open leaking underground storage tank (LUST) and open Non-LUST spill case (SLIC) were identified for the property (as the site was listed in the LUST database, it is also considered a Cortese List site. Cortese List sites are described in more detail below). The LUST listing relates to the presence of hydrocarbon affected soil observed in the vicinity of the former 500-gallon UST that was removed from the northwestern portion of the property in November 2014. The SLIC case relates to the detected presence of heavy metals in soil and groundwater that appear to be associated with the historic presence of rail spurs and sidings on the property. Soil sampling performed in the vicinity of the former UST indicated the presence of petroleum hydrocarbons and VOCs at concentrations in excess of San Francisco Regional Water Quality Control Board (SFRWQCB) ESLs. Groundwater samples obtained in the northeastern and southwestern portions of the property also contained petroleum hydrocarbons, VOCs, and metals at concentrations in excess of SFRWQCB ESLs. Shallow soil containing elevated concentrations of petroleum hydrocarbons, arsenic and/or lead was also identified in the vicinity of two former rail spurs running through the central portion of the property and along the eastern property boundary. Regulatory oversight of the UST and SLIC cases is provided by the San Mateo County Health Department under the Voluntary Cleanup Program. Remedial excavation in the vicinity of the former UST was performed. However, a report detailing the results of the remedial excavation activities had not been completed (as of the date of preparation of the Phase I ESA). The documented presence of petroleum hydrocarbons, VOCs, and metals in soil and/or groundwater was identified as a recognized environmental condition.
The Phase I ESA stated that additional assessment of potential groundwater impacts associated with documented site releases could be necessary.
One VEC was identified associated with the site:
⚫ Subsurface soil and groundwater had been impacted by a release of gasoline from a UST that was located on the northern portion of the site. Remedial excavation had occurred, however, the extent of residual soil and/or groundwater impacts had not yet been fully assessed and the LUST case remained open. The documented release from the former UST was considered to represent a VEC until definitive documentation is available to conclude that post-remediation concentrations of VOCs in soil and groundwater do not represent a VEC. 2017 Case Closure and Residual Contaminants Letters, Malaspina Property, 30 Tanforan Avenue4 A review of the State Water Resources Control Board’s GeoTracker website in July of 2021 identified the aforementioned LUST case as closed (December 2017). A Case Closure letter from the County of San Mateo Health System dated December 4, 2017 confirmed the completion of necessary site investigations and corrective action associated with the UST release.
A subsequent Residual Contaminants letter from the County of San Mateo Health System, also dated December 4, 2017, states that although site closure was granted, residual metals and fuel-affected soil and groundwater may exist at onsite locations. Based on analytical information, the contaminants did not appear to pose a risk under existing land use conditions, however, changes in 4 The Case Closure and Residual Contaminants letters referenced also include the properties at 29, 40 and 46 Tanforan Avenue and 335, 347 and 349 South Maple Avenue, the same footprint analyzed as part of the 2017 Phase I ESA of Malaspina Property, 30, 40, 46 Tanforan Ave & 335, 347, 349 S. Maple Avenue.
City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Hazards and Hazardous Materials
Southline Specific Plan EIR 4.8-13 September 2021
ICF 0082.20
land use or removal of soil and groundwater could create a contaminant exposure risk.
Consequently, any proposed change in land use or proposed soil or groundwater removal activity at or in close proximity to the subject site must be submitted to the San Mateo County Environmental Health Department Groundwater Protection Program (GPP) for review under Government Code section 65850.2.
As the Malaspina site has been granted a case closure status related to the UST release, the REC and VECs mentioned above are no longer considered significant risks. Notwithstanding, any proposed change in land use or soil and groundwater disturbance at or in close proximity to the Malaspina site would be evaluated by the San Mateo County Environmental Health Department GPP as required. 30 and 40 Tanforan Avenue
2017 Pre-Renovation Hazardous Materials Survey, 30 & 40 Tanforan Avenue ATC performed a pre-renovation hazardous materials survey of the buildings located at 30 & 40 Tanforan Avenue on May 18, 22 and 27, 2017. The purpose of the survey was to determine the presence of ACMs, ACCM, LBP and PCB containing materials within on-site buildings. ACM materials and ACCM were identified within building materials during the survey. Also, materials sampled during the pre-renovation hazardous materials survey and analyzed had detectable amounts of lead.
None of the sampled materials are considered to be PCB-contaminated. 325 South Maple Avenue
2019 Phase I ESA of 325 South Maple Avenue
ATC performed a Phase I ESA of the property at 325 South Maple Avenue.
Findings
Three RECs were identified associated with the site:
⚫ Known Chromium in Soil: A tanning business operated on the property from approximately 1942 to 1985. The company manufactured products for upholstery, in addition to lightweight leathers, utilizing steer hides tanned by a chrome process. Prior to 1954, all aqueous wastes associated with the tannery processes were discharged through a storm drain. After 1954, tannery effluent (e.g., wastes associated with cleaning, trimming, and removal of hair and flesh) was discharged into the sanitary sewer, while remaining tannery effluent, including chrome tan, tannin re-tanning wastes, and dye material, continued to be discharged via the storm drain. The business maintained on-site sludge holding ponds and/or sludge drying beds as part of the waste treatment and/or disposal process. Although this case received regulatory closure in 1987, standards have since changed to require speciation and analysis of both total and hexavalent chromium, which was not conducted at that time. ATC conducted a recent subsurface investigation and the results identified the presence of chromium and hexavalent chromium in shallow subsurface soil. To establish a reasonable approximation of the general boundaries and extent of the chromium impact soil in the former sludge pond and handling areas, the sampling results from 1987 and the current investigation were extrapolated over the site. Based on this methodology, ATC concluded that it is unlikely past historical uses have adversely impacted the groundwater beneath the property to any significant degree due to the results of subsurface investigation. However, the release of chromium to soil from on-site disposal ponds/drying beds remains a recognized environmental condition.