South San Francisco City Council
July 13, 2022

RESPONSES TO COMMENTS ON THE

DRAFT ENVIRONMENTAL IMPACT REPORT

SOUTHLINE SPECIFIC PLAN

CITY OF SOUTH SAN FRANCISCO, CALIFORNIA
STATE CLEARINGHOUSE NO. 2020050452
DRAFT EIR PUBLICATION DATE: SEPTEMBER 28, 2021
DRAFT EIR PUBLIC HEARING DATE: NOVEMBER 4, 2021
DRAFT EIR PUBLIC COMMENT PERIOD: SEPTEMBER 28– NOVEMBER 12, 2021 FINAL EIR CERTIFICATION DATE: JULY 13, 2022
May 2022
ICF. 2022. Southline Specific Plan. Responses to Comments on the Draft Environmental Impact Report. May. (ICF 00082.20.) San Francisco, CA.

Prepared for City of South San Francisco, South San Francisco, CA.

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Contents
List of Tables.......................................................................................................................................... iv List of Figures.......................................................................................................................................... v Chapter 1 Introduction...................................................................................................................... 1-1

1.1 Environmental Review Process ..............................................................................................1-1

1.2 Document Organization .........................................................................................................1-2 Chapter 2 Comments and Responses................................................................................................. 2-1

2.1 Introduction............................................................................................................................2-1

2.2 Responses to Comments........................................................................................................2-1 Letter A-BART: Tim Chan, San Francisco Bay Area Rapid Transit District (November 22, 2021).......................................................................................................2-4 Response to Comment A-BART-1 ....................................................................................2-4 Response to Comment A-BART-2 ....................................................................................2-4 Letter A-PC: Planning Commission Hearing (November 4, 2021) ..........................................2-8 Response to Comment PC-1 ............................................................................................2-8 Response to Comment PC-2 ............................................................................................2-9 Response to Comment PC-3 ............................................................................................2-9 Response to Comment PC-4 ..........................................................................................2-10 Response to Comment PC-5 ..........................................................................................2-10 Response to Comment PC-6 ..........................................................................................2-10 Response to Comment PC-7 ..........................................................................................2-10 Response to Comment PC-8 ..........................................................................................2-11 Letter A-PG&E#1: Plan Review Team, PG&E (September 30, 2021)....................................2-18 Response to Comment A-PG&E#1-1..............................................................................2-18 Response to Comment A-PG&E#1-2..............................................................................2-18 Letter A-PG&E#2: Justin Newell, PG&E (November 17, 2021).............................................2-20 Response to Comment PG&E#1-1 .................................................................................2-20 Letter A-San Bruno: Hae Won Ritchie, City of San Bruno (November 12, 2021) .................2-33 Response to Comment A-San Bruno-1 ..........................................................................2-33 Response to Comment A-San Bruno-2 ..........................................................................2-33 Response to Comment A-San Bruno-3 ..........................................................................2-33 Response to Comment A-San Bruno-4 ..........................................................................2-34 Response to Comment A-San Bruno-5 ..........................................................................2-34 Response to Comment A-San Bruno-6 ..........................................................................2-34 Response to Comment A-San Bruno-7 ..........................................................................2-39 Response to Comment A-San Bruno-8 ..........................................................................2-39 City of South San Francisco Contents
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Response to Comment A-San Bruno-9 ..........................................................................2-39 Response to Comment A-San Bruno-10 ........................................................................2-39 Response to Comment A-San Bruno-11 ........................................................................2-40 Response to Comment A-San Bruno-12 ........................................................................2-41 Response to Comment A-San Bruno-13 ........................................................................2-41 Response to Comment A-San Bruno-14 ........................................................................2-41 Response to Comment A-San Bruno-15 ........................................................................2-42 Response to Comment A-San Bruno-16 ........................................................................2-42 Response to Comment A-San Bruno-17 ........................................................................2-43 Response to Comment A-San Bruno-18 ........................................................................2-43 Response to Comment A-San Bruno-19 ........................................................................2-43 Response to Comment A-San Bruno-20 ........................................................................2-44 Response to Comment A-San Bruno-21 ........................................................................2-44 Response to Comment A-San Bruno-22 ........................................................................2-44 Response to Comment A-San Bruno-23 ........................................................................2-45 Response to Comment A-San Bruno-24 ........................................................................2-45 Response to Comment A-San Bruno-25 ........................................................................2-45 Response to Comment A-San Bruno-26 ........................................................................2-46 Response to Comment A-San Bruno-27 ........................................................................2-46 Response to Comment A-San Bruno-28 ........................................................................2-46 Response to Comment A-San Bruno-29 ........................................................................2-47 Response to Comment A-San Bruno-30 ........................................................................2-47 Response to Comment A-San Bruno-31 ........................................................................2-47 Response to Comment A-San Bruno-32 ........................................................................2-47 Response to Comment A-San Bruno-33 ........................................................................2-50 Response to Comment A-San Bruno-34 ........................................................................2-50 Letter A-SFO: Nupur Sinha, San Francisco International Airport (November 11, 2021)..............................................................................................................................2-53 Response to Comment A-SFO-1.....................................................................................2-53 Response to Comment A-SFO-2.....................................................................................2-53 Response to Comment A-SFO-3.....................................................................................2-53 Response to Comment A-SFO-4.....................................................................................2-53 Response to Comment A-SFO-5.....................................................................................2-54 Letter I-Lee: Samuel Lee (October 25, 2021)........................................................................2-56 Response to Comment I-Lee-1.......................................................................................2-56 Letter I-Richardson: Mina Richardson (October 29, 2021) ..................................................2-59 Response to Comment I-Richardson-1 ..........................................................................2-59 City of South San Francisco Contents
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Response to Comment I-Richardson-2 ..........................................................................2-59 Response to Comment I-Richardson-3 ..........................................................................2-59 Response to Comment I-Richardson-4 ..........................................................................2-59 Response to Comment I-Richardson-5 ..........................................................................2-60 Response to Comment I-Richardson-6 ..........................................................................2-60 Response to Comment I-Richardson-7 ..........................................................................2-60 Response to Comment I-Richardson-8 ..........................................................................2-60 Chapter 3 Revisions to the Draft EIR.................................................................................................. 3-1

3.1 Global Draft EIR Revisions......................................................................................................3-1

3.1.1 Final Water Supply Assessment ................................................................................3-1

3.1.2 Reduced Underground Parking Alternative ..............................................................3-2

3.2 Specific Draft EIR Revisions ....................................................................................................3-3 Appendices
⚫ Appendix A: Revised Appendix 4.15-1, Revised Transportation Impact Analysis ⚫ Appendix B: Revised Appendix 4.17-1, Final Water Supply Assessment ⚫ Appendix C: New Appendix 2.1, Revised Southline Specific Plan City of South San Francisco Contents
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Tables
Table 2-1 Comparison of BAAQMD’s Additional Recommended Construction Mitigation Measures and the Draft EIR’s Construction Mitigation Measures for Air Quality.................................................................................................................2-35 Table 2-2 Relevancy of Mills Park Center Project to Draft EIR Cumulative Analysis by Topic...............................................................................................................................2-48 Table 4.2-5 Phase 1 Emergency Generator Technical Specifications and Testing Schedules.........................................................................................................................3-8 Table 4.2-14 Phase 1 Cancer and Chronic Hazard Risks and PM2.5 Concentrations during Construction.....................................................................................................................3-9 Table 4.2-15 Phase 1 Cancer and Chronic Hazard Risks and PM.5 Concentrations during Operation.......................................................................................................................3-10 Table 4.2-16 Mitigated Cumulative Health Risks from Phase 1..........................................................3-11 Table 4.11-16 Modeled Traffic Noise Impacts on Existing Land Uses ..................................................3-14 Table 4.11-18 Modeled Cumulative Traffic Noise Impacts...................................................................3-17 Table 4.15-4 Person-Trip Generation, Project Buildout .....................................................................3-18 Table 4.15-7 Weekday AM and PM Peak-Hour 95th-Percentile Queues – Project............................3-19 Table 5-1 Comparison of Proposed Project Features to the Alternatives.....................................3-27 Table 5-4 Phase 1 Precise Plan Square Footage under Alternative D ...........................................3-33 Table 5-5 Phase 1 Precise Plan Land Use Square Footage Summary under Alternative D ...........3-33 Table 5-9 Estimated Average Daily Unmitigated Operational Emissions from the Specific Plan under Alternative D (pounds/day)............................................................3-39 Table 5-10 Estimated Average Daily Unmitigated Operational Emissions from Phase 1 under Alternative D (pounds/day).................................................................................3-41 Table 5-11 Unmitigated Operational Average Daily Emissions from Phase 1 under Alternative D – Comparison of Generator Testing Scenarios (pounds/day) .................3-42 Table 5-12 Mitigated Operational Average Daily Emissions from Phase 1 under Alternative D – Comparison of Generator Testing Scenarios (pounds/day) .................3-43 Table 5-13 Phase 1 Cancer and Chronic Hazard Risks and PM.5 Concentrations during Construction Under Alternative D .................................................................................3-45 Table 5-14 Phase 1 Cancer and Chronic Hazard Risks and PM.5 Concentrations during Operation Under Alternative D......................................................................................3-45 Table 5-17 Estimated Annual Unmitigated Phase 1 Operational GHG Emissions under Alternative D (metric tons) ............................................................................................3-54 Table 5-18 Revised Specific Plan Alternative Trip Generation (Office Scenario).............................3-64 Table 5-19 Comparison of Proposed Project’s Significant Impacts to Alternatives’ Impacts...........................................................................................................................3-67 Table 5-20 Ability of Alternatives to Meet Project Objectives ........................................................3-70 City of South San Francisco Contents
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Figures
Figure 5-4. Reduced Underground Parking Alternative—Life Sciences Scenario....................................3-31 Figure 5-5. Reduced Underground Parking Alternative—Office Scenario...............................................3-32 Revised Figure 4.17-2. Existing and Proposed Wastewater Infrastructure .............................................3-72 This Page Intentionally Left Blank
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Chapter 1
Introduction
The purpose of this responses-to-comments (RTC) document is to present comments submitted on the draft environmental impact report (draft EIR) for the Southline Specific Plan (Specific Plan) and associated off-site improvements (proposed project), to respond in writing to comments on environmental issues, and revise the draft EIR as necessary to provide additional clarity. Pursuant to the California Environmental Quality Act (CEQA), Public Resources Code Section 21091(d)(2)(A) and (B), the South San Francisco Planning Division considered the comments received, evaluated the environmental issues raised, and provided written responses that fully address the comments on significant environmental issues raised by the commenters. This RTC document also provides limited responses, for informational purposes, to general comments on the draft EIR received during the public review period that were not related to environmental issues. Where appropriate, this RTC document also includes EIR text changes made in response to the comments or at the initiation of the City of South San Francisco (City).

The draft EIR and this RTC document constitute the final environmental impact report (final EIR) for the proposed project, in fulfillment of CEQA requirements and consistent with CEQA Guidelines Section 15132.

1.1 Environmental Review Process
This EIR has been prepared by the South San Francisco Planning Division for the City of South San Francisco, the Lead Agency for the proposed project, in compliance with the provisions of CEQA and the CEQA Guidelines (California Public Resources Code Section 21000 et seq. and California Code of Regulations Title 14, Section 15000 et seq. [CEQA Guidelines]). The draft EIR was published and posted on the City’s website on September 28, 2021. A Notice of Availability was distributed to state and local agencies, neighbors, and other interested parties to solicit public comment. The draft EIR was available for public comment from September 28, 2021, to November 12, 2021. The notice solicited comments on the adequacy and accuracy of information presented in the draft EIR.

Comments were made in written form during the public comment period and as oral testimony at the public hearing on the draft EIR before the Planning Commission held on November 4, 2021. The comments received during the public review period are the subject of this RTC document, which addresses all substantive written and oral comments on the draft EIR. Minutes from the public hearing on the draft EIR as well as written comments are included in their entirety in this document.

The final EIR will consist of the draft EIR and this RTC document, which includes comments received during the public review period, responses to the comments on environmental issues, and any revisions to the draft EIR that resulted from staff-initiated text changes or text changes in the responses.

The information provided in the responses and the revisions to the draft EIR clarifies and amplifies the analysis presented in the draft EIR. No significant new information, as defined by CEQA Guidelines Section 15088.5, was added that would trigger recirculation of the draft EIR. Specifically, there are no new significant environmental impacts. No substantial increase in the severity of any City of South San Francisco Introduction
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significant impact has been identified, and no new alternatives or mitigation measures were identified in the comments or responses that were not already identified in the draft EIR.

The City has distributed this RTC document to the Planning Commission and City Council. The Planning Commission anticipates to hold a hearing on June 2, 2022, to consider the adequacy of the final EIR. If the Planning Commission finds that the EIR has been completed in compliance with CEQA and that it reflects the City’s independent judgment, pursuant to the requirements of CEQA Guidelines Section 15090, it will recommend certification of the document as a final EIR to the City Council. The City anticipates that certification of the final EIR will be considered by the City Council on July 13, 2022. The City decision-makers will consider the certified final EIR, along with other information received during the public review process, to determine whether to approve, modify, or disapprove the proposed project and specify the mitigation measures that will be required as conditions of project approval in a Mitigation Monitoring and Reporting Program.

If City decision-makers decide to approve the proposed project, even though significant environmental impacts identified in the final EIR have not been avoided or reduced to less-than-significant levels, they must indicate that such unavoidable significant impacts are acceptable because of overriding economic, legal, social, technological, or other considerations, as described in CEQA Guidelines Section 15093. This is known as a Statement of Overriding Considerations, in which the City balances the benefits of a proposed project against its unavoidable environmental risks. If the benefits of a project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered acceptable (CEQA Guidelines Section 15093). If an agency adopts a Statement of Overriding Considerations, the statement must be included in the record of project approval.

1.2 Document Organization
This RTC document consists of the following chapters:
⚫ Chapter 1, Introduction, discusses the purpose of the RTC document, the environmental review process for the EIR, and the organization of the RTC document. ⚫ Chapter 2, Comments and Responses, presents comments from the public hearing held on November 4, 2021 and written comments to the draft EIR. The comments are organized by agencies (A) and individuals (I) in alphabetical order and coded in the following way:
 Comments from agencies are designated by “A-” and an acronym of the agency’s name.  Comments from individuals are designated by “I-” and the commenter’s last name.

A number at the end of the code keys each comment to the order of the comments presented within each written communication or item in the Planning Commission minutes. Thus, each discrete comment has a unique comment code.

Following the Planning Commission minutes and each comment letter are the City’s responses.

The responses generally clarify the draft EIR text. They may also reference revisions or additions to the draft EIR shown in Chapter 3, Revisions to the Draft EIR. ⚫ Chapter 3, Revisions to the Draft EIR, presents text changes to the draft EIR made as a result of the responses to the comments as well as staff-initiated text changes identified by City staff members to update, correct, or clarify the draft EIR text. New text is underlined and deleted text is shown in strikethrough. The final Water Supply Assessment (WSA) for the project which City of South San Francisco Introduction
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replaces the draft WSA in Appendix 4.17-1 of the draft EIR is included as Appendix B in this document. This chapter also includes revisions to Chapter 5, Alternatives, of the draft EIR to include an analysis of a new alternative – the Reduced Underground Parking Alternative – which has been identified as the environmentally superior alternative and as the Recommended Alternative proposed for adoption. In addition, Appendix 4.15-1 of the draft EIR (Transportation Impact Analysis) has been replaced in its entirety with an updated Transportation Impact Analysis (Appendix A), Appendix 2.1, has been replaced with the Revised Southline Specific Plan (Appendix C) which reflects the Reduced Underground Parking Alternative. ⚫ Appendices, including revised draft EIR appendices and a new appendix, as described above.  Appendix A: Revised Appendix 4.15-1, Revised Transportation Impact Analysis replaces Appendix 4.15-1, Transportation Impact Analysis, of the draft EIR.  Appendix B: Revised Appendix 4.17-1, Draft Final Water Supply Assessment replaces Appendix 4.17-1, Draft Water Supply Assessment, of the draft EIR.  Appendix C: New Appendix 2.1, Revised Southline Specific Plan has been added. (Specific Plan for Alternative D, Reduced Underground Parking Alternative).

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Chapter 2
Comments and Responses

2.1 Introduction
This chapter contains responses to the Commissioner comments from the November 4, 2021 South San Francisco Planning Commission hearing and to written comments received on the draft EIR. The City of South San Francisco received six letters or emails commenting on the draft EIR during the comment period and one letter commenting on the draft EIR after the comment period. No public comments were presented at the Planning Commission hearing.

The comments are organized by agencies (A) and individuals (I) in alphabetical order as follows. • A-BART: Tim Chan, San Francisco Bay Area Rapid Transit District (November 22, 2021) • A-PC: Planning Commission Hearing (November 4, 2021)
• A-PG&E#1: Plan Review Team, PG&E (September 30, 2021) • A-PG&E#2: Justin Newell, PG&E (November 17, 2021)
• A-San Bruno: Hae Won Ritchie, City of San Bruno (November 12, 2021) • A-SFO: Nupur Sinha, San Francisco International Airport (November 11, 2021) • I-Lee: Samuel Lee (October 25, 2021)
• I- Richardson: Mina Richardson (October 29, 2021)
Where revisions to the draft EIR are appropriate to respond to comments, such changes are noted in the responses and shown in full in Chapter 3, Revisions to the Draft EIR. These include changes in response to comments and staff-initiated changes.

2.2 Responses to Comments
This section includes comments on the draft EIR and responses to those comments. Comments from the South San Francisco Planning Commission hearing and comments in letters and emails that raise environmental issues are bracketed and numbered; each comment is followed by responses to the comments raised.

Where revisions to the draft EIR are appropriate to respond to comments, such changes are referenced in the response and shown in full in Chapter 3, Revisions to the Draft EIR. Staff-initiated text changes regarding typographical and other minor errors are also presented in Chapter 3. In other cases, where not otherwise specified, the information provided in the responses is deemed adequate in itself, and modification of the draft EIR text is not necessary. 2021
Mark Foley

PRESIDENT
Rebecca Saltzman

VICE PRESIDENT
Robert Powers

GENERAL MANAGER

DIRECTORS
Debora Allen
1ST DISTRICT
Mark Foley
2ND DISTRICT
Rebecca Saltzman
3RD DISTRICT
Robert Raburn, Ph.D.
4TH DISTRICT
John McPartland
5TH DISTRICT
Elizabeth Ames
6TH DISTRICT
Lateefah Simon
7TH DISTRICT
Janice Li
8TH DISTRICT
Bevan Dufty
9TH DISTRICT
www.bart.gov
November 22, 2021
Adena Friedman, Principal Planner
City of South San Francisco
Economic and Community Development Department
315 Maple Street
South San Francisco, CA 94080
RE: BART Comments on the Draft Environmental Impact Report for the Southline Specific Plan Dear Ms. Friedman,
The San Francisco Bay Area Rapid Transit District (BART) appreciates the opportunity to comment on the Draft Environmental Impact Report (DEIR) for the Southline Specific Plan. We also appreciate that most of our previous NOP comments on the project impacts to the BART system and roadway users have been evaluated in the DEIR.

We do have one comment on the project impact on BART train crowding. Our passenger load threshold for "crowded" conditions is 115 passengers per car on average, which approximates passengers per square meter, or in this case, 5.4 square feet per passenger. On that basis, the development would not appear to cause 'crowding' on BART trains.

On the other hand, the DEIR is not clear on the trade-off of peak weekday travel via San Bruno Station. Does the report say that a majority of people entering at this station would actually travel southbound in the morning and northbound in the evening? We’re not seeing support for that claim. Likewise, it does not address the effects of the project on the Richmond-Millbrae and Antioch-San Francisco International Airport line loading eastbound through downtown San Francisco in the AM and westbound in the PM. Please let us know if we missed this analysis.

In summary, we don't foresee a problem strictly based on the numbers of trips generated, but we would like to see more discussion in the Final EIR of the peak link loads on the Richmond-Millbrae and Antioch-San Francisco International Airport lines through San Francisco.

Thank you for the opportunity to comment on this DEIR. Please call me if you have any questions.

Sincerely,
Tim Chan
Group Manager – Station Area Planning
San Francisco Bay Area Rapid Transit District

SAN FRANCISCO BAY AREA RAPID TRANSIT DISTRICT
300 Lakeside Drive, P.O. Box 12688
Oakland, CA 94604-2688
(510) 464-6000 A-BART
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Letter A-BART: Tim Chan, San Francisco Bay Area Rapid Transit District (November 22, 2021)
Response to Comment A-BART-1
The comment expresses appreciation from the San Francisco Bay Area Rapid Transit District (BART) for the opportunity to comment on the draft EIR and notes that most of the comments that BART provided on the notice of preparation (NOP) were addressed in the draft EIR. Comment noted. The comment does not contain questions or concerns regarding the adequacy of the draft EIR analysis.

No revisions to the draft EIR are required.

Response to Comment A-BART-2
The comment refers to the analysis in Impact TR-5a in Section 4.15, Transportation and Circulation, of the draft EIR (pages 4.15-47 through 4.15-49). The comment requests clarification on assumptions related to peak hour travel and states that the draft EIR analysis did not address the effects of the project on the Richmond-Millbrae and Antioch-San Francisco International Airport line loading eastbound through downtown San Francisco in the AM and westbound in the PM.

Impact TR-5a describes the project’s effects on BART ridership. As an office development, the project would mostly generate BART ridership traveling southbound from San Francisco during the AM peak period, then returning northbound to San Francisco during the PM peak period. This travel pattern represents the reverse-peak commute direction for BART on the Peninsula, as most travel occurs northbound into San Francisco during the AM peak period, then returns southbound to the Peninsula during the PM peak period. Consequently, BART has available capacity to accommodate the project in its reverse-peak trains. This is described on page 4.15-48 of the draft EIR.

As stated on page 4.15-48 of the draft EIR, about 13 percent of BART passengers are anticipated to travel from the East Bay during the AM peak period and return to the East Bay during the PM peak period. These passengers would overlap with BART’s peak direction of travel via the Transbay tube (westbound during the AM peak period and eastbound during the PM peak period); however, the project’s contribution to passenger volumes in the Transbay Tube would be less than one percent.

The project’s contribution to BART’s traditional peak direction of travel on the Peninsula would be low: about 65 passengers during the AM peak period in the northbound/eastbound direction, and about 105 passengers during the PM peak period in the southbound/westbound direction, as shown in Table 4.15-11 on page 4.15-48 of the draft EIR. Consequently, the project’s effects on the Richmond-Millbrae and Antioch-San Francisco International Airport lines in the southbound/eastbound direction through San Francisco in the AM and northbound/westbound in the PM would be negligible – about 8 to 13 passengers per train on average, which represents a fraction of a percentage of existing volumes.

No revisions to the draft EIR are required.

Southline Specific Plan
Planning Commission Draft EIR Comment Hearing
November 4, 2021
Meeting Minutes
2:10:30 - Adena Friedman (AF) from Planning Division provides staff report on project. - No vote tonight. City will provide response to public and Commission comments in the FEIR. - Application is for specific plan for entire 26-acre project area. - Draft EIR (DEIR) review period runs from Sept. 28 – Nov. 12. This hearing is for Commission and public comments on the DEIR.
- 3 areas (Air Quality, Noise, Transportation) had significant and unavoidable impacts. - Recent precedent in Bay Area suggests that these impacts could be reduced to less than significant, but not guaranteed; thus impacts are determined to be significant and unavoidable. - Staff’s recommendation is to take public comments and provide comments to staff on DEIR. 2:25:45 - Marcus Gilmour (MG) from Lane Partners provides project introduction. - Existing Conditions (2:27:25)
- Specific Plan Overview (2:31:12)
2:31:12 – Dawn Jedkins (DJ) provides Specific Plan Overview - 2:38:45 – Project Renderings
2:41:39 – Chair Michele Evans (ME) opens floor to questions from the Commission. 2:41:50 – Commissioner Tzang, Commissioner Fernandez, Commissioner Funes, Commissioner Faria with hands raised.
2:42:00 – Commissioner Alex Tzang (AT) – “Thank you for presenting such a comprehensive project. I really like the end product, even though it’s just the beginning. We’re not here to make any recommendations, just to provide comments. As a commissioner, I cannot say yay let’s do this without addressing the bigger questions which is the CEQA. Apparently the way the CEQA shows is there are 3 significant and unavoidable things (Noise, Pollution, Traffic). This tells me the project is too aggressive, too big, or too big in the short period of time it needs to phase out. I’m an architect myself, and I want to have the biggest project, but I see the CEQA telling me these kinds of things, I won’t be able justify it without those coming close to resolvable. Again, in the report it says that yes, it’s not guaranteed there might be methods we could mitigate to a less superior situation, I do understand, but definitely no decision can be made off of unproven comment or these kind of promises. Another thing that I want to make note, this site location is right next to our neighbor San Bruno. I’m very near where this site is.

When we make a recommendation or if we make a recommendation that approves a fairly significant CEQA impact that is right adjacent to San Bruno, that is being a pretty bad neighbor as well. I do want to make this comment – I love the project, the mission, but the CEQA has to look a lot better before I can fully support. Today it’s not about me supporting, but I have to spell this out. Normally I’m pretty supportive but this is alarming.”
2:45:00 – Commissioner Luis De Paz Fernandez (DF) – “I don’t want to be too redundant, commissioner Tzang hit on all of the points, beautiful design so I want to echo that. It’s right next to the BART, so it A-PC
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would allow a better commute, and encourage public transportation. CEQA is very alarming, especially when we heard from staff that there are areas that can’t be reduced to a lesser impact.” 2:45:40 – Commissioner Sarah Funes (SF) – “I want to echo what previous commissioners brought up – I like that you guys are thinking about cleaning up the environmental issues on the site, if it were to come to fruition that is great. A lot of us on the commission care about the environment. I like that it’s near public transportation, that there’s retail, parklets, and the idea of food trucks. Trying to get local business in is important everywhere to get jobs for young people, either in high school, college, or after college would be very helpful. Those are my comments.”
2:46:25 – Chair ME – “I would echo the commissioners’ concerns – I don’t think we’re foreclosing on the project, it’s the EIR that we would like to see some more definitive solutions that can be addressed and taken off the table so we can move forward with this.”
2:46:58 – Commissioner Norm Faria (NF) – “Along the same sentiments, I do agree with what Commissioner Tzang said, it is a large project, it will clean up the area, but I have concerns because the property acquisition will be a major necessity, the EPA, the conditions of some of these existing properties would have to be taken into consideration. Such as Tanforan Avenue, we are talking residents of San Bruno, and there will be massive construction on a 2-lane road, which Commissioner Tzang did address. We have the surface streets that Adena addressed that are down in San Bruno, which will impact San Bruno. I was glad to hear that the developer has done public outreach to San Bruno on entities that will overlap into them. Again, I do have one question – have they been successful in acquiring this property and much of the existing buildings? Because I know some of those had been existing uses we did approve for their current use, maybe a few years back, and that will be interesting with how the project proceeds, because I know you only have two buildings planned right now.” 2:48:20 – MG – “We currently own all 26.5 acres. So we have acquired all of the sites.” 2:48:30 – NF – “That makes it easy, that makes it good. I’d be curious as you start evolving and what you find out there, the land and ground waste and what comes naturally as you start developing an area, but anyway it’s cleaning up the area and it’s good for the environment, but it is a large project. I’ll be glad to see how this evolves.”
2:48:55 – JulieAnn Murphy (JM) – “I had a question for staff, just because it’s on my mind from our previous presentation, is that how does this align with our preferred land use map for the new general plan?”
2:49:15 – AF – “This is consistent with the existing general plan. The existing general plan designation I believe the zoning is business and professional office and the future general plan is as well. And what the applicant is proposing is consistent with both the existing and future general plan designation. The applicant would be proposing and what staff would be recommending is a rezone to a specific plan to enact development controls and design guidelines that align with this project. But the land use is all consistent with what is in place now and with the preferred land use alternative.” 2:50:00 – JM – “And just thinking for developments we have entitled recently, we have a large amount of housing going off of Noor, I believe would be a nice companion to the plan we are seeing tonight. I wonder if the tides of research and dev needs change in the term of this phase project, if there’s a way that a precise plan could address potentially offering more housing on the site in the future, if that’s a 2 Con't
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tool that could be used if that were to ever potentially be a possibility. I’m just thinking this location is great for transit, but adding 2 million square feet of research and development is also going to have an effect on the housing needs of South San Francisco.”
2:51:00 – AF – “I can speak to that. Housing is currently not permitted in this location, and would not be permitted in the general plan. If the city in the future were to rezone this land to be residential, then a developer could come in and develop residential as well. As it’s currently contemplated, the city doesn’t envision that. The developer can speak better to this, but there are significant challenges with the cleanup that would be involved. And about half of the site is within the airport 70 dB noise contour as well. So there are some residential challenges there. That said we can’t predict the future. But for now the site is zoned for commercial purposes.”
2:52:15 – Chair ME – “There is no action for us to do. This is just a study session for us.” 2:52:20 – Claire Lai (CL), Assistant City Attorney – “I’ll just make it clear for the record, if there are any public comments, I do not see.”
2:52:30 – Tony Rozzi (TR), Chief Planner – “there are no hands raised at the moment, no further emails or calls received than the ones transmitted earlier today via email or posted on our website.” 2:53:10 – Chair ME commends developer for the scope of their project and what they are undertaking. 8 Con't
City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-8
May 2022
ICF 00082.20
Letter A-PC: Planning Commission Hearing (November 4, 2021) Response to Comment PC-1
The comment expresses concerns about the size of the project and the significant and unavoidable air quality, noise, and transportation impacts identified in the draft EIR. The comment inquires whether additional mitigation can be imposed to mitigate the project’s significant impacts to a lessthan-significant level.

The significant and unavoidable impacts identified in the draft EIR analysis are summarized in Chapter 6, Other CEQA Considerations. As discussed, the draft EIR identifies numerous rigorous mitigation measures that would mitigate all of the project’s significant impacts to a less-thansignificant level. For example, the following mitigation measures are required to mitigate the project’s significant air quality and noise impacts:
• Mitigation Measure AQ-1: Require Fugitive Dust Best Management Practices (All Phases) • Mitigation Measure AQ-2: Require at Least Tier 4 Final Engines on Construction Equipment (All Phases)
• Mitigation Measure AQ-3: Require Use of Diesel Trucks with 2010-Compliant Model Year Engines (Future Phases Only)
• Mitigation Measure AQ-4: Require Construction Fleet to Use Renewable Diesel (Future Phases Only)
• Mitigation Measure AQ-5: Require Low-VOC Coatings during Construction (Future Phases Only)
• Mitigation Measure AQ-6: Purchase of Mitigation Credits for Construction Emissions Exceeding BAAQMD’s Daily Pollutant Thresholds (Future Phases Only) • Mitigation Measure AQ-7: Purchase of Mitigation Credits for Operational Emissions Exceeding BAAQMD’s Daily Pollutant Thresholds (All Phases) • Mitigation Measure AQ-8: Limit the Number of Phase 1 Emergency Generators Tested to One Generator Per Day (Phase 1 Only)
• Mitigation Measure AQ-9: Require Future Projects within 1,000 Feet of Sensitive Receptors to Perform a Health Risk Assessment (Future Phases Only) • Mitigation Measure NOI-1a: Construction Noise Control Plan to Reduce Noise Outside Standard Construction Hours in the City of South San Francisco (All Phases) • Mitigation Measure NOI-1b: Construction of Temporary Noise Barrier along Tanforan Avenue (Phase 1 Only)
• Mitigation Measure NOI-1c: Mechanical Equipment Noise Reduction Plan (All Phases) Analysis provided in the draft EIR establishes that implementation of these mitigation measures would potentially mitigate the impacts of future development under the Specific Plan to a less-thansignificant level. However, CEQA prohibits speculation, and it is not possible at this time to identify City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-9
May 2022
ICF 00082.20
the specific construction or operational details of future projects, or to say with certainty that offset programs will be available in the types and amounts necessary to offset future pollutants. Therefore, even though the mitigation measures could mitigate impacts to a less-than-significant level, the City is required under CEQA to make a finding that impacts would be “significant and unavoidable.” With respect to transportation impacts, the draft EIR identified one significant and unavoidable impact related to signal warrants at the Huntington Avenue/Herman Street/Forest Avenue intersection; this impact would occur even without the Project, although the Project would contribute to the impact under full buildout conditions. As discussed on pages 4.15-45 through 4.15- 46 in Section 4.15, Transportation and Circulation, of the draft EIR, installation of a traffic signal at the Huntington Avenue/Herman Street/Forest Avenue intersection, which is located in the City of San Bruno, would reduce the impact to a less-than-significant level. Accordingly, the project’s contribution to the impact could be fully mitigated by paying a fair-share contribution toward installation of a traffic signal at this intersection. However, this traffic signal is not presently included in a capital improvement or fee program adopted by the City of San Bruno, and therefore, the City of San Bruno does not have a mechanism for funding this mitigation and cannot ensure this mitigation will be implemented. Moreover, assuming that this traffic signal were to be included in a capital improvement or fee program adopted by the City of San Bruno, because the intersection and any such fee program would be under the control and jurisdiction of San Bruno, the City of South San Francisco as lead agency would not be able to guarantee that this mitigation measure would be implemented. CEQA requires mitigation to be feasible and to be within the control of the lead agency to implement. Therefore, while mitigation exists that could reduce the impact on this intersection to a less-than-significant level, the City is required under CEQA to make a finding that impacts would be significant and unavoidable. Notwithstanding this conclusion, outside of the CEQA process, the City of San Bruno may determine that capital improvements at the Huntington Avenue/Herman Street/Forest Avenue intersection are warranted and elect to undertake those improvements or require them as conditions of approval for projects occurring within San Bruno. As of preparation of this EIR, the project applicant is engaged in discussions with San Bruno staff regarding potential completion of, or funding for, the identified improvements.

The comment does not contain questions or concerns regarding the adequacy of the draft EIR analysis. No revisions to the draft EIR are required.

Response to Comment PC-2
The comment reiterates statements made in Comment PC-1 and notes that the proposed project would be in proximity to public transit. See Response to Comment PC-1.

The comment does not contain questions or concerns regarding the adequacy of the draft EIR analysis. No revisions to the draft EIR are required.

Response to Comment PC-3
The comment reiterates statements made in Comment PC-1 and notes that the proposed project would remediate existing environmental hazards on-site, would be in proximity to public transit, and would create new jobs. See Response to Comment PC-1.

Section 4.8, Hazards and Hazardous Materials, of the draft EIR provides information on the existing hazards and hazardous materials that are known to occur within the project site. Identified hazards City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-10 May 2022
ICF 00082.20
and hazardous materials include soil contaminants, groundwater contaminants, subsurface vapors, and asbestos-containing materials and lead-based paint in existing structures. As discussed in Section 4.8, Hazards and Hazardous Materials, impacts associated with the identified hazards would be mitigated to a less-than-significant level with implementation of the following mitigation measures:
• Mitigation Measure HAZ-2a: Prepare a Soil Management Plan Prior to Issuance of Grading Permit (All Phases);
• Mitigation Measure HAZ-2: Engineering Controls to Address Vapor Encroachment Conditions (Future Phases that Include the Property at 325 South Maple Avenue); • Mitigation Measure HAZ-2c: Conduct a Hazardous Building Materials Survey prior to Demolition Activities and Hazardous Building Material Handing (All Phases); and • Mitigation Measure HWQ-1: Require Groundwater Monitoring and Sampling Prior to Dewatering Activity (All Phases).

The comment does not contain questions or concerns regarding the adequacy of the draft EIR analysis. No revisions to the draft EIR are required.

Response to Comment PC-4
The comment reiterates statements made in Comment PC-1. See Response to Comment PC-1.

Response to Comment PC-5
The comment reiterates statements made in Comment PC-1. See Response to Comment PC-1. The comment also requests clarification on whether the project applicant has acquired all properties within the Specific Plan area. The project applicant currently owns all properties comprising the

26.5-acre Specific Plan area.

Response to Comment PC-6
The comment notes that the proposed project is large and includes general statements regarding land and ground waste at the project site. See Response to Comment PC-1 and Response to Comment PC-3.

Response to Comment PC-7
The comment asks how the project would align with the preferred land use map for the new general plan. As detailed on p. 4.10-35 in Section 4.10, Land Use and Planning, of the draft EIR, the project was found to be consistent with the relevant land use and planning-related policies from the existing general plan. As explained in the analysis in the draft EIR, and in staff responses at the Planning Commission meeting, the project is generally consistent with the General Plan’s goals for the Specific Plan area and includes provisions to update the General Plan and Zoning Ordinance consistent with state law to ensure internal consistency. The General Plan Update, Shape SSF 2040 General Plan, which is currently underway but has not yet been adopted, proposes to maintain the existing land use designation for the bulk of the Specific Plan area in the preferred land use scenario, which would ultimately serve as the basis for the updated Land Use Element, although it renames the designation City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-11 May 2022
ICF 00082.20
from Office to Business and Professional Office. Therefore, should the preferred land use scenario be adopted, the proposed project would also be consistent with the General Plan Update.

Response to Comment PC-8
The comment expresses concern regarding how the project would affect housing needs in the City of South San Francisco and inquires whether the Specific Plan area could be used for residential uses in the future.

A Residential Alternative was considered in the draft EIR but rejected based on its infeasibility and inability to meet the basic project objectives. Refer to pages 5-11 through 5-12 in Chapter 4, Alternatives, of the draft EIR. As discussed therein, residential use is not consistent with the current General Plan land use designation or zoning designation for the Specific Plan area. As discussed in Response to Comment PC-7, the pending General Plan Update would maintain the existing land use designation. Further, although residential uses in San Bruno are located to the south, the Specific Plan area generally is not well suited for residential development as it is an existing industrial site where existing hazards and hazardous materials are known to occur (see Response to Comment PC3). Further, approximately half of the Specific Plan area is in the 2012 SFO Airport Land Use Compatibility Plan (ALUCP)’s 70 decibel (db) noise contour, which the ALUCP identifies as incompatible for residential uses. Therefore, the City determined that the Specific Plan area is not suited for residential use.

With regard to housing needs, as detailed in Section 4.12, Population and Housing, of the draft EIR, the proposed project would not directly generate new population or households. Population and housing growth indirectly generated by project employees was estimated in the draft EIR and was determined to be within the Association of Bay Area Government’s forecasted growth for the City, the San Francisco-Oakland-Hayward core-based statistical area, and the Bay Area. In addition, the project would be required to pay the Affordable Housing Commercial Linkage Fee, which would contribute to the development of affordable housing in other locations within the City. Refer to pages 4.12-13 through 4.12-17 of the draft EIR.

Plan Review Team
Land Management
[email protected]
PG&E Gas and Electric Facilities Page 1
September 30, 2021
Adena Friedman
City of South San Francisco
PO Box 711
South San Francisco, CA 94083
Ref: Gas and Electric Transmission and Distribution
Dear Adena Friedman,
Thank you for submitting the Southline NOA plans for our review. PG&E will review the submitted plans in relationship to any existing Gas and Electric facilities within the project area.

If the proposed project is adjacent/or within PG&E owned property and/or easements, we will be working with you to ensure compatible uses and activities near our facilities.

Attached you will find information and requirements as it relates to Gas facilities (Attachment 1) and Electric facilities (Attachment 2). Please review these in detail, as it is critical to ensure your safety and to protect PG&E’s facilities and its existing rights.

Below is additional information for your review:

1. This plan review process does not replace the application process for PG&E gas or electric service your project may require. For these requests, please continue to work with PG&E Service Planning: https://www.pge.com/en_US/business/services/buildingand-renovation/overview/overview.page.

2. If the project being submitted is part of a larger project, please include the entire scope of your project, and not just a portion of it. PG&E’s facilities are to be incorporated within any CEQA document. PG&E needs to verify that the CEQA document will identify any required future PG&E services.

3. An engineering deposit may be required to review plans for a project depending on the size, scope, and location of the project and as it relates to any rearrangement or new installation of PG&E facilities.

Any proposed uses within the PG&E fee strip and/or easement, may include a California Public Utility Commission (CPUC) Section 851 filing. This requires the CPUC to render approval for a conveyance of rights for specific uses on PG&E’s fee strip or easement. PG&E will advise if the necessity to incorporate a CPUC Section 851filing is required.

This letter does not constitute PG&E’s consent to use any portion of its easement for any purpose not previously conveyed. PG&E will provide a project specific response as required.

Sincerely,
Plan Review Team
Land Management
A-PG&E #1
1 2
PG&E Gas and Electric Facilities Page 2
Attachment 1 – Gas Facilities
There could be gas transmission pipelines in this area which would be considered critical facilities for PG&E and a high priority subsurface installation under California law. Care must be taken to ensure safety and accessibility. So, please ensure that if PG&E approves work near gas transmission pipelines it is done in adherence with the below stipulations. Additionally, the following link provides additional information regarding legal requirements under California excavation laws: https://www.usanorth811.org/images/pdfs/CA-LAW-2018.pdf

1. Standby Inspection: A PG&E Gas Transmission Standby Inspector must be present during any demolition or construction activity that comes within 10 feet of the gas pipeline. This includes all grading, trenching, substructure depth verifications (potholes), asphalt or concrete demolition/removal, removal of trees, signs, light poles, etc. This inspection can be coordinated through the Underground Service Alert (USA) service at 811. A minimum notice of 48 hours is required. Ensure the USA markings and notifications are maintained throughout the duration of your work.

2. Access: At any time, PG&E may need to access, excavate, and perform work on the gas pipeline. Any construction equipment, materials, or spoils may need to be removed upon notice.

Any temporary construction fencing installed within PG&E’s easement would also need to be capable of being removed at any time upon notice. Any plans to cut temporary slopes exceeding a 1:4 grade within 10 feet of a gas transmission pipeline need to be approved by PG&E Pipeline Services in writing PRIOR to performing the work.

3. Wheel Loads: To prevent damage to the buried gas pipeline, there are weight limits that must be enforced whenever any equipment gets within 10 feet of traversing the pipe.

Ensure a list of the axle weights of all equipment being used is available for PG&E’s Standby Inspector. To confirm the depth of cover, the pipeline may need to be potholed by hand in a few areas.

Due to the complex variability of tracked equipment, vibratory compaction equipment, and cranes, PG&E must evaluate those items on a case-by-case basis prior to use over the gas pipeline (provide a list of any proposed equipment of this type noting model numbers and specific attachments).

No equipment may be set up over the gas pipeline while operating. Ensure crane outriggers are at least 10 feet from the centerline of the gas pipeline. Transport trucks must not be parked over the gas pipeline while being loaded or unloaded.

4. Grading: PG&E requires a minimum of 36 inches of cover over gas pipelines (or existing grade if less) and a maximum of 7 feet of cover at all locations. The graded surface cannot exceed a cross slope of 1:4.

5. Excavating: Any digging within 2 feet of a gas pipeline must be dug by hand. Note that while the minimum clearance is only 12 inches, any excavation work within 24 inches of the edge of a pipeline must be done with hand tools. So to avoid having to dig a trench entirely with hand tools, the edge of the trench must be over 24 inches away. (Doing the math for a 24 inch PG&E Gas and Electric Facilities Page 3
wide trench being dug along a 36 inch pipeline, the centerline of the trench would need to be at least 54 inches [24/2 + 24 + 36/2 = 54] away, or be entirely dug by hand.) Water jetting to assist vacuum excavating must be limited to 1000 psig and directed at a 40° angle to the pipe. All pile driving must be kept a minimum of 3 feet away.

Any plans to expose and support a PG&E gas transmission pipeline across an open excavation need to be approved by PG&E Pipeline Services in writing PRIOR to performing the work.

6. Boring/Trenchless Installations: PG&E Pipeline Services must review and approve all plans to bore across or parallel to (within 10 feet) a gas transmission pipeline. There are stringent criteria to pothole the gas transmission facility at regular intervals for all parallel bore installations.

For bore paths that cross gas transmission pipelines perpendicularly, the pipeline must be potholed a minimum of 2 feet in the horizontal direction of the bore path and a minimum of 12 inches in the vertical direction from the bottom of the pipe with minimum clearances measured from the edge of the pipe in both directions. Standby personnel must watch the locator trace (and every ream pass) the path of the bore as it approaches the pipeline and visually monitor the pothole (with the exposed transmission pipe) as the bore traverses the pipeline to ensure adequate clearance with the pipeline. The pothole width must account for the inaccuracy of the locating equipment.

7. Substructures: All utility crossings of a gas pipeline should be made as close to perpendicular as feasible (90° +/- 15°). All utility lines crossing the gas pipeline must have a minimum of 12 inches of separation from the gas pipeline. Parallel utilities, pole bases, water line ‘kicker blocks’, storm drain inlets, water meters, valves, back pressure devices or other utility substructures are not allowed in the PG&E gas pipeline easement.

If previously retired PG&E facilities are in conflict with proposed substructures, PG&E must verify they are safe prior to removal. This includes verification testing of the contents of the facilities, as well as environmental testing of the coating and internal surfaces. Timelines for PG&E completion of this verification will vary depending on the type and location of facilities in conflict.

8. Structures: No structures are to be built within the PG&E gas pipeline easement. This includes buildings, retaining walls, fences, decks, patios, carports, septic tanks, storage sheds, tanks, loading ramps, or any structure that could limit PG&E’s ability to access its facilities.

9. Fencing: Permanent fencing is not allowed within PG&E easements except for perpendicular crossings which must include a 16 foot wide gate for vehicular access. Gates will be secured with PG&E corporation locks.

10. Landscaping: Landscaping must be designed to allow PG&E to access the pipeline for maintenance and not interfere with pipeline coatings or other cathodic protection systems. No trees, shrubs, brush, vines, and other vegetation may be planted within the easement area.

Only those plants, ground covers, grasses, flowers, and low-growing plants that grow unsupported to a maximum of four feet (4’) in height at maturity may be planted within the easement area.

PG&E Gas and Electric Facilities Page 4

11. Cathodic Protection: PG&E pipelines are protected from corrosion with an “Impressed Current” cathodic protection system. Any proposed facilities, such as metal conduit, pipes, service lines, ground rods, anodes, wires, etc. that might affect the pipeline cathodic protection system must be reviewed and approved by PG&E Corrosion Engineering.

12. Pipeline Marker Signs: PG&E needs to maintain pipeline marker signs for gas transmission pipelines in order to ensure public awareness of the presence of the pipelines.

With prior written approval from PG&E Pipeline Services, an existing PG&E pipeline marker sign that is in direct conflict with proposed developments may be temporarily relocated to accommodate construction work. The pipeline marker must be moved back once construction is complete.

13. PG&E is also the provider of distribution facilities throughout many of the areas within the state of California. Therefore, any plans that impact PG&E’s facilities must be reviewed and approved by PG&E to ensure that no impact occurs which may endanger the safe operation of its facilities.

PG&E Gas and Electric Facilities Page 5
Attachment 2 – Electric Facilities
It is PG&E’s policy to permit certain uses on a case by case basis within its electric transmission fee strip(s) and/or easement(s) provided such uses and manner in which they are exercised, will not interfere with PG&E’s rights or endanger its facilities. Some examples/restrictions are as follows:

1. Buildings and Other Structures: No buildings or other structures including the foot print and eave of any buildings, swimming pools, wells or similar structures will be permitted within fee strip(s) and/or easement(s) areas. PG&E’s transmission easement shall be designated on subdivision/parcel maps as “RESTRICTED USE AREA – NO BUILDING.”

2. Grading: Cuts, trenches or excavations may not be made within 25 feet of our towers.

Developers must submit grading plans and site development plans (including geotechnical reports if applicable), signed and dated, for PG&E’s review. PG&E engineers must review grade changes in the vicinity of our towers. No fills will be allowed which would impair ground-toconductor clearances. Towers shall not be left on mounds without adequate road access to base of tower or structure.

3. Fences: Walls, fences, and other structures must be installed at locations that do not affect the safe operation of PG&’s facilities. Heavy equipment access to our facilities must be maintained at all times. Metal fences are to be grounded to PG&E specifications. No wall, fence or other like structure is to be installed within 10 feet of tower footings and unrestricted access must be maintained from a tower structure to the nearest street. Walls, fences and other structures proposed along or within the fee strip(s) and/or easement(s) will require PG&E review; submit plans to PG&E Centralized Review Team for review and comment.

4. Landscaping: Vegetation may be allowed; subject to review of plans. On overhead electric transmission fee strip(s) and/or easement(s), trees and shrubs are limited to those varieties that do not exceed 15 feet in height at maturity. PG&E must have access to its facilities at all times, including access by heavy equipment. No planting is to occur within the footprint of the tower legs. Greenbelts are encouraged.

5. Reservoirs, Sumps, Drainage Basins, and Ponds: Prohibited within PG&E’s fee strip(s) and/or easement(s) for electric transmission lines.

6. Automobile Parking: Short term parking of movable passenger vehicles and light trucks (pickups, vans, etc.) is allowed. The lighting within these parking areas will need to be reviewed by PG&E; approval will be on a case by case basis. Heavy equipment access to PG&E facilities is to be maintained at all times. Parking is to clear PG&E structures by at least 10 feet.

Protection of PG&E facilities from vehicular traffic is to be provided at developer’s expense AND to PG&E specifications. Blocked-up vehicles are not allowed. Carports, canopies, or awnings are not allowed.

7. Storage of Flammable, Explosive or Corrosive Materials: There shall be no storage of fuel or combustibles and no fueling of vehicles within PG&E’s easement. No trash bins or incinerators are allowed.

PG&E Gas and Electric Facilities Page 6

8. Streets and Roads: Access to facilities must be maintained at all times. Street lights may be allowed in the fee strip(s) and/or easement(s) but in all cases must be reviewed by PG&E for proper clearance. Roads and utilities should cross the transmission easement as nearly at right angles as possible. Road intersections will not be allowed within the transmission easement.

9. Pipelines: Pipelines may be allowed provided crossings are held to a minimum and to be as nearly perpendicular as possible. Pipelines within 25 feet of PG&E structures require review by PG&E. Sprinklers systems may be allowed; subject to review. Leach fields and septic tanks are not allowed. Construction plans must be submitted to PG&E for review and approval prior to the commencement of any construction.

10. Signs: Signs are not allowed except in rare cases subject to individual review by PG&E.

11. Recreation Areas: Playgrounds, parks, tennis courts, basketball courts, barbecue and light trucks (pickups, vans, etc.) may be allowed; subject to review of plans. Heavy equipment access to PG&E facilities is to be maintained at all times. Parking is to clear PG&E structures by at least 10 feet. Protection of PG&E facilities from vehicular traffic is to be provided at developer’s expense AND to PG&E specifications.

12. Construction Activity: Since construction activity will take place near PG&E’s overhead electric lines, please be advised it is the contractor’s responsibility to be aware of, and observe the minimum clearances for both workers and equipment operating near high voltage electric lines set out in the High-Voltage Electrical Safety Orders of the California Division of Industrial Safety (https://www.dir.ca.gov/Title8/sb5g2.html), as well as any other safety regulations.

Contractors shall comply with California Public Utilities Commission General Order 95 (http://www.cpuc.ca.gov/gos/GO95/go_95_startup_page.html) and all other safety rules. No construction may occur within 25 feet of PG&E’s towers. All excavation activities may only commence after 811 protocols has been followed.

Contractor shall ensure the protection of PG&E’s towers and poles from vehicular damage by (installing protective barriers) Plans for protection barriers must be approved by PG&E prior to construction.

13. PG&E is also the owner of distribution facilities throughout many of the areas within the state of California. Therefore, any plans that impact PG&E’s facilities must be reviewed and approved by PG&E to ensure that no impact occurs that may endanger the safe and reliable operation of its facilities.

City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-18 May 2022
ICF 00082.20
Letter A-PG&E#1: Plan Review Team, PG&E (September 30, 2021) Response to Comment A-PG&E#1-1
The comment states that PG&E will review the project and site plans in relation to any existing PG&E facilities in the project area. Comment noted. The comment does not raise any questions or concerns about the adequacy of the draft EIR. The Phase 1 applicant and applicants of future projects affecting PG&E properties and easements will be required to consult with PG&E and obtain all necessary approvals from PG&E prior to construction and operation of the subject projects.

Response to Comment A-PG&E#1-2
The comment summarizes the role of PG&E in relation to the proposed project, and the PG&Erelated approvals and applications required for the project. The comment also states that the CEQA document should identify any required future PG&E services. Comment noted. See Response to Comment PG&E#1-1. The draft EIR notes that the project would be served by existing PG&E gas and electric infrastructure. Project impacts on PG&E gas and electric infrastructure are evaluated in Section 4.17, Utilities and Service Systems, pages 4.17-38 through 4.17-39. As discussed, impacts would be less than significant and no mitigation is required. The comment does not contain questions or concerns regarding the adequacy of the draft EIR analysis. No revisions to the draft EIR are required.

Plan Review Team
Land Management
[email protected]
PG&E Gas and Electric Facilities Page 1
November 17, 2021
Adena Friedman
City of South San Francisco
PO Box 711
South San Francisco, CA 94083
Re: Southline DEIR Notice of Availability
30 Tanforan Avenue, South San Francisco, CA 94080
Dear Adena:

Thank you for giving us the opportunity to review the subject plans. The proposed Southline DEIR is within the same vicinity of PG&E’s existing facilities that impact this property.

The proposed will require the relocation of multiple PG&E facilities and assets. I can confirm that the applicant has submitted applications for these relocations with PG&E and initiated to relocation process. The applicant will need to continue to work with our teams to continue their development.

Please contact the Building and Renovation Center (BRSC) for facility map requests by calling 1-877-743-7782 and PG&E’s Service Planning department at www.pge.com/cco for any modification or relocation requests, or for any additional services you may require.

As a reminder, before any digging or excavation occurs, please contact Underground Service Alert (USA) by dialing 811 a minimum of 2 working days prior to commencing any work. This free and independent service will ensure that all existing underground utilities are identified and marked on-site.

If you have any questions regarding our response, please contact me at [email protected].

Sincerely,
Justin Newell
Land Management
916-594-4068
A-PG&E #2
1 City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-20 May 2022
ICF 00082.20
Letter A-PG&E#2: Justin Newell, PG&E (November 17, 2021) Response to Comment PG&E#1-1
The comment states that there are existing PG&E facilities in the project area, and that the project applicant has initiated coordination with PG&E for the proposed relocations of these facilities.

Comment noted. See Response to Comment PG&E#1-1 and Response to Comment PG&E#1-2. The comment does not raise any questions or concerns about the adequacy of the draft EIR. No revisions to the draft EIR are required.
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34 City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-33 May 2022
ICF 00082.20
Letter A-San Bruno: Hae Won Ritchie, City of San Bruno
(November 12, 2021)
Response to Comment A-San Bruno-1
The comment summarizes the role of the City of San Bruno in relation to the proposed project (i.e., as a responsible agency under CEQA), the off-site improvements located in San Bruno’s jurisdiction, and the approvals required from the City of San Bruno for the project. The comment states that the City of San Bruno’s comments are focused on the environmental effects of the proposed off-site improvements located in San Bruno’s jurisdiction, as well as other effects on San Bruno residences, businesses, or infrastructure.

Comment noted. The list of off-site improvements located in San Bruno’s jurisdiction and the list of San Bruno approvals required for the project are consistent with information presented in Chapter 3, Project Description, of the draft EIR (e.g., see Table 3-5 on pages 3-21 through 3-23 and section 3.7 on pages 3-44 through 3-46). The comment does not raise any issues about the adequacy of the draft EIR. No revisions to the draft EIR are required.

Response to Comment A-San Bruno-2
The comment correctly notes that the air quality-related comments in the City of San Bruno’s response to the NOP were not described in the draft EIR. This editorial error has been corrected in Chapter 3, Revisions to the Draft EIR. However, all of the air-quality related comments raised in San Bruno’s response to the NOP were substantively addressed in the draft EIR analysis; therefore, no further revisions to the draft EIR are required.

Response to Comment A-San Bruno-3
The comment states that BAAQMD provides in its CEQA Air Quality Guidelines (CEQA Guidelines) Table 8-3, Additional Construction Mitigation Measures Recommended for Projects with Construction Emissions Above the Threshold. BAAQMD recommends incorporating the measures in Table 8-3 for projects when construction-generated air pollutants would exceed BAAQMD thresholds. 1 Because
construction emissions from Phase 1 and the proposed project would exceed BAAQMD daily emissions thresholds, the comment recommends that the draft EIR be revised to incorporate BAAQMD’s additional construction mitigation measures.

The comment inaccurately states that “construction of Phase I would result in NOx emissions above the corresponding BAAQMD threshold.” In fact, as disclosed in Table 4.2-7 of the draft EIR, Phase 1 construction emissions will have a less-than-significant impact with implementation of Mitigation Measure AQ-1. Moreover, to the extent that the comment indicates that project or Phase 1 impacts from fugitive dust will be significant, this is inaccurate, as fugitive dust impacts are mitigated to lessthan-significant through Mitigation Measure AQ-1. However, the comment correctly notes that overall construction emissions associated with project buildout, not including Phase 1, would be significant and unavoidable.
1 Bay Area Air Quality Management District. 2017. 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: December 1, 2021.

City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-34 May 2022
ICF 00082.20
BAAQMD’s CEQA Guidelines is a guidance document, and its recommended mitigation measures are recommendations, not requirements. In its discretion as lead agency, the City of South San Francisco has determined that the mitigation measures included in the draft EIR are equivalent to, and in most cases more stringent than, the additional construction mitigation measures provided in Table 8-3 of BAAQMD’s CEQA Guidelines. Additional discussion is provided in Table 2-1 below, which compares each of BAAQMD’s additional construction mitigation measures to the corresponding mitigation measure from the draft EIR. The City also notes that BAAQMD was provided the opportunity to review the draft EIR and did not submit comments on the draft EIR. Therefore, no revisions to the draft EIR are required.

Response to Comment A-San Bruno-4
The comment requests that Mitigation Measure AQ-2, which is on page 4.2-42 of the draft EIR, be revised to clarify the enforcement process by stating that “All contractors would be required to submit a list of equipment and associated Engine Identification Numbers (EINs) to the California Air Resources Board for Tier 4 verification.” This mitigation measure has been revised to include the requested text, as shown in Chapter 3, Revisions to the Draft EIR.

Response to Comment A-San Bruno-5
The comment describes Mitigation Measure AQ-8 on page 4.2-52 in Section 4.2, Air Quality, of the draft EIR, and notes that the mitigation would not fully mitigate significant impacts related to Phase 1 generator operations. This is consistent with the analysis on page 4.2-50 of the draft EIR. The draft EIR identifies additional mitigation, Mitigation Measure AQ-7, which requires the payment of mitigation fees to fund offsets for operational emissions exceeding BAAQMD’s daily pollutant thresholds, to mitigate this impact to the extent feasible. As described on page 4.2-50, it is reasonable to assume that such offset programs will be available to mitigate these impacts, but operational impacts for Phase 1 are conservatively assumed to be significant and unavoidable because it cannot be concluded that offset programs will always be available at the time and in the amounts needed to mitigate annual emissions. No revisions to the draft EIR are required.

The comment expresses concerns regarding the noise impacts that could result from implementation of Mitigation Measure AQ-8. See Response to Comment A-San Bruno-11 for a response to this portion of the comment.

Response to Comment A-San Bruno-6
The comment notes that prior to mitigation, construction of Phase 1 would result in a significant impact related to cancer risk and annual PM2.5 concentrations for the maximally exposed individual receptor, per Table 4.2-14 on page 4.2-59 of the draft EIR. The comment further notes that implementation of Mitigation Measures AQ-1 and AQ-2 would mitigate these impacts to a less-thansignificant level, also per Table 4.2-14, which shows a reduction of approximately 95 percent. The comment questions the accuracy of this reduction, referencing that (1) Mitigation Measure AQ-1 only requires 95 percent of construction equipment to be Tier 4, and (2) Tier 4 equipment has emissions that are between 90 and 93 percent lower than the default emissions used in CalEEMod.

Accordingly, the comment notes that cancer risks and annual PM2.5 concentrations could be reduced by as little as 85.5 percent (i.e., 95 multiplied by 90). The comment requests clarification on how the difference between unmitigated and mitigated results was calculated.

City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-35 May 2022
ICF 00082.20
Table 2-1. Comparison of BAAQMD’s Additional Recommended Construction Mitigation Measures and the Draft EIR’s Construction Mitigation Measures for Air Quality
#
BAAQMD Additional Recommended Measure
(CEQA Guidelines Table 8-3) Draft EIR Equivalent Measure – Phase 1 Draft EIR Equivalent Measure –
Project
1 All exposed surfaces shall be watered at a
frequency adequate to maintain minimum soil
moisture of 12 percent. Moisture content can be
verified by lab samples or moisture probe.

This measure would reduce fugitive dust
emissions. Phase 1’s significant fugitive dust
impacts would be mitigated to a less-thansignificant level with implementation of Mitigation Measure AQ-1, which requires
implementation of fugitive dust BMPs in
BAAQMD’s basic construction mitigation
measures. Therefore, additional fugitive dust
mitigation is not required.

This measure would reduce fugitive
dust emissions. The project’s
significant fugitive dust impacts would
be mitigated to a less-than-significant
level with implementation of Mitigation
Measure AQ-1, which requires
implementation of fugitive dust BMPs
in BAAQMD’s basic construction
mitigation measures. Therefore,
additional fugitive dust mitigation is
not required.
2 All excavation, grading, and/or demolition
activities shall be suspended when average wind
speeds exceed 20 mph.

Same response as #1. Same response as #1.
3 Wind breaks (e.g., trees, fences) shall be installed
on the windward side(s) of actively
disturbed areas of construction. Wind breaks
should have at maximum 50 percent air porosity.

Same response as #1. Same response as #1.
4 Vegetative ground cover (e.g., fast-germinating
native grass seed) shall be planted in disturbed
areas as soon as possible and watered
appropriately until vegetation is established.

Same response as #1. Same response as #1.
5 The simultaneous occurrence of excavation,
grading, and ground-disturbing construction
activities on the same area at any one time shall
be limited. Activities shall be phased to reduce the
amount of disturbed surfaces at any one time.

Same response as #1. Same response as #1.
6 All trucks and equipment, including their tires,
shall be washed off prior to leaving the site.

Same response as #1. Same response as #1.

City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-36 May 2022
ICF 00082.20
#
BAAQMD Additional Recommended Measure
(CEQA Guidelines Table 8-3) Draft EIR Equivalent Measure – Phase 1 Draft EIR Equivalent Measure –
Project
7 Site accesses to a distance of 100 feet from the
paved road shall be treated with a 6 to 12 inch
compacted layer of wood chips, mulch, or gravel.

Same response as #1. Same response as #1.
8 Sandbags or other erosion control measures shall
be installed to prevent silt runoff to public
roadways from sites with a slope greater than one
percent.

Same response as #1. Same response as #1.
9 Minimizing the idling time of diesel powered
construction equipment to two minutes.

This measure would reduce criteria pollutant
emissions from construction equipment. Phase
1 would result in a significant impact related
to NOX emissions during construction (see
Table 4.2-6 on page 4.2-40 of the draft EIR).

Other criteria pollutant emissions would not
exceed BAAQMD daily emissions thresholds.

Phase 1’s significant NOX impact would be
mitigated to a less-than-significant level with
implementation of Mitigation Measure AQ-2,
which requires Tier 4 Final engines in
construction equipment (see Table 4.2-7 on
page 4.2-41 of the draft EIR). Therefore,
additional mitigation for criteria pollutants
during Phase 1 construction is not required.

Furthermore, Mitigation Measure AQ-2 would
result in much greater emissions reductions
(e.g., Tier 4 Final engines decrease NOx
emissions by more than 90 percent) than the
BAAQMD measure, which would eliminate
emissions from only a small duration of total
equipment activity. Therefore, the draft EIR
measure is more stringent than the BAAQMD
measure.

This measure would reduce criteria
pollutant emissions from construction
equipment. Construction of future
development projects under the
Specific Plan could generate criteria
pollutant emissions that exceed
BAAQMD’s daily emissions thresholds
for ROG, NOX, and PM. Implementation
of Mitigation Measure AQ-2, which
requires the uses of Tier 4 Final
engines in construction equipment, and
Mitigation Measure AQ-4, which
requires the use of renewable diesel in
construction equipment, would result
in much greater emissions reductions
(e.g., Tier 4 Final engines decrease NOx
emissions by more than 90 percent)
than the BAAQMD measure, which
would eliminate emissions from only a
small duration of total equipment
activity. Therefore, the draft EIR
measures are more stringent than the
BAAQMD measure.
10 The project shall develop a plan demonstrating
that the off-road equipment (more than 50
horsepower) to be used in the construction
project (i.e., owned, leased, and subcontractor
vehicles) would achieve a project wide fleetSame response as #9. Same response as #9.

City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-37 May 2022
ICF 00082.20
#
BAAQMD Additional Recommended Measure
(CEQA Guidelines Table 8-3) Draft EIR Equivalent Measure – Phase 1 Draft EIR Equivalent Measure –
Project
average 20 percent NOX reduction and 45 percent
PM reduction compared to the most recent CARB
fleet average. Acceptable options for reducing
emissions include the use of late model engines,
low-emission diesel products, alternative fuels,
engine retrofit technology, after-treatment
products, add-on devices such as particulate
filters, and/or other options as such become
available.
11 Use low VOC (i.e., ROG) coatings beyond the local
requirements (i.e., Regulation 8, Rule 3:

Architectural Coatings).

This measure would reduce VOC emissions
during construction. Phase 1 would result in a
less-than-significant impact related to VOC
emissions during construction (see Table 4.2-6
on page 4.2-40 of the draft EIR). Therefore,
additional VOC mitigation is not required.

This measure would reduce VOC
emissions during construction. This
measure is incorporated in the draft
EIR as Mitigation Measure AQ-5, which
would be required for future phases
under the Specific Plan (not including
Phase 1).
12 Requiring that all construction equipment, diesel
trucks, and generators be equipped with Best
Available Control Technology for emission
reductions of NOX and PM.

Same response as #9. Same response as #9. In addition to the measures noted in #9, implementation
of Mitigation Measure AQ-3, which
requires the use of diesel trucks with
2010-compliant model year engines,
would further reduce exhaust
emissions from diesel trucks.

Therefore, the draft EIR measures are
more stringent than the BAAQMD
measure.
13 Requiring all contractors use equipment that
meets CARB’s most recent certification standard
for off-road heavy duty diesel engines.

Same response as #9. Same response as #9.

Source: Bay Area Air Quality Management District. 2017. 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: December 1, 2021.

City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-38 May 2022
ICF 00082.20
The comment correctly identifies an editorial error in Table 4.2-14 of the draft EIR. While the modeling outputs in Appendix 4.2-1, Air Quality, Greenhouse Gas, and Energy Modeling Results, of the draft EIR are correct (see pages 398-399), the values were incorrectly transcribed to the corresponding draft EIR table. The text of Table 4.2-14 of the draft EIR has been corrected in Chapter 3, Revisions to the Draft EIR. As shown, the unmitigated cancer risk at the maximally exposed individual receptor has been revised from 89.6 to 139.1. The mitigated cancer risk has been revised from 4.5 to 9.7 and remains below the threshold of 10.0. Therefore, no new significant impact would occur, and recirculation of the draft EIR pursuant to CEQA Guidelines Section 15088.5 is not required.

The corrected mitigated cancer risk is a 93 percent reduction from the unmitigated cancer risk, rather than a 95 percent reduction. Two example calculations and provided below that demonstrate how Mitigation Measure AQ-2, which requires at least 95 percent of off-road equipment to operate with Tier 4 engines, can result in a 93 percent reduction in the unmitigated and mitigated construction equipment PM2.5 emissions.

Example 1: a 120-horsepower crawler tractor in construction year 2022 with a 93 percent reduction in the PM2.5 mitigated emission factor compared to the default CalEEMod unmitigated emission factor.
• PM2.5 emission factor without mitigation = 0.375 (g/bhp-hr)2 • Mitigated PM2.5 emission factor with Tier 4 Final engine = 0.008 (g/bhp-hr)3 • Mitigated PM2.5 emission factor with 95 percent penetration of Tier 4 Final engines = 0.375 * 5% + 0.008 * 95% = 0.02635 (g/bhp-hr)
• Percent reduction in PM2.5 emission factor between mitigated and unmitigated = (0.02635-

0.375)/0.375 = -93%
Example 2: a 50-horsepower crane in construction year 2021 with a 94 percent reduction in the PM2.5 mitigated emission factor compared to the default CalEEMod unmitigated emission factor.
• PM2.5 emission factor without mitigation = 0.581 (g/bhp-hr)4 • Mitigated PM2.5 emission factor with Tier 4 Final engine = 0.008 (g/bhp-hr)5 • Mitigated PM2.5 emission factor with 95 percent penetration of Tier 4 Final engines = 0.581 * 5% + 0.008 * 95% = 0.03666 (g/bhp-hr)
• Percent reduction in PM2.5 emission factor between mitigated and unmitigated = (0.03666-

0.581)/0.581 = -94%
2 South Coast Air Quality Management District. 2021. CalEEMod Appendix D – Default Data Tables. Available:
http://www.aqmd.gov/docs/default-source/caleemod/user-guide-2021/appendix-d2020-4-0-fullmerge.pdf?sfvrsn=12. Accessed: December 1, 2021. 3 Ibid.
4 Ibid.
5 Ibid.

City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-39 May 2022
ICF 00082.20
Response to Comment A-San Bruno-7
The comment requests that the text in Mitigation Measure CR-2b in Section 4.4, Cultural Resources, of the draft EIR be revised to clarify that the City of San Bruno must be notified and consulted in the event that potential archaeological resources are discovered during construction within San Bruno’s jurisdiction. This mitigation measure has been revised to include the requested text, as shown in Chapter 3, Revisions to the Draft EIR.

Response to Comment A-San Bruno-8
The comment reiterates statements made in the City of San Bruno’s response to the NOP, specifically that temporary and permanent increases in noise during construction and operation could affect the nearby sensitive receptors, and that construction-related vibration could have an impact of adjacent buildings.

pertaining to noise included concerns related to construction and operational noise. A reference to the vibration-related NOP comment has been added to the EIR, as shown in Chapter 3, Revisions to the Draft EIR. The topics identified in the comment (i.e., construction and operational noise, construction vibration) were evaluated in Section 4.11, Noise and Vibration, of the draft EIR.

Response to Comment A-San Bruno-9
The comment states that the predicted noise levels shown in Table 4.11-16 on page 4.11-38 and Table 4.11-18 on page 4.11-57 in Section 4.11, Noise and Vibration, of the draft EIR are incorrectly calculated. The comment is accurate, in that some calculated changes in noise levels are misstated by 0.1 dB as a result of rounding errors. These numbers have been corrected in Chapter 3, Revisions to the Draft EIR, and footnotes noting that values have been rounded have been added to the tables.

These revisions do not affect any of the significance conclusions in the draft EIR.

Response to Comment A-San Bruno-10
The comment states that the one-hour average peak-hour noise level of 58.2 dBA Leq derived from modeled traffic noise levels should not be used to determine a nighttime noise threshold for heating, ventilation, and air conditioning (HVAC) equipment because it may be too high. As stated on page

4.11-9 in Section 4.11, Noise and Vibration, of the draft EIR, because of state and local COVID-19 shelter-in-place orders that were in effect when the draft EIR was prepared, modeling of existing noise levels was based on traffic data from 2019 rather than noise measurements taken in the field.

Traffic noise is usually the dominant source of overall ambient noise in urban areas. Fieldwork conducted during the shelter-in-place orders would not accurately capture typical traffic noise levels given that many schools and businesses were closed and many people were working remotely, thereby decreasing traffic volumes. The analysis of HVAC noise impacts on pages 4.11-39 through 4.11-42 of the draft EIR finds that HVAC noise impacts would be significant based on the potential for project HVAC equipment to increase nearby ambient noise levels by 10 dB or more.

This conclusion would not change if lower ambient noise levels are used. Further, Mitigation Measure NOI-1c is a performance-based mitigation measure that requires noise measurements to be taken once equipment models, design features, and specific locations are identified to demonstrate that HVAC equipment would not result in a 10 dB increase over actual ambient levels at nearby City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-40 May 2022
ICF 00082.20
sensitive uses (in addition to ensuring other applicable thresholds are met). Thus, using a lower ambient noise measurements for purposes of the EIR analysis would not affect the impact conclusion or required mitigation. As shown in Chapter 3, Revisions to the Draft EIR, a sentence has been added to Mitigation Measure NOI-1c to clarify that ambient noise levels must be identified by conducting field noise measurements.

The comment also states that the draft EIR’s analysis of HVAC noise is inadequate because it fails to estimate and compare nighttime noise levels with implementation of Mitigation Measure NOI-1c to an appropriate threshold. As stated above, Mitigation Measure NOI-1c is a performance-based mitigation measure that provides a menu of options to reduce noise, with the requirement that compliance with applicable thresholds be demonstrated prior to the issuance of building permits.

Because it is not possible to know which methods of noise reduction would be implemented at this time, it is not possible to quantify post-mitigation noise levels. However, building permits would not be issued until compliance with applicable thresholds is demonstrated in a Noise Reduction Plan pursuant to Mitigation Measure NOI-1c. No further revisions to the draft EIR are required.

Response to Comment A-San Bruno-11
The comment states that the analysis of generator noise on pages 4.11-42 through 4.11-45 in Section 4.11, Noise and Vibration, of the draft EIR implies that generators would be tested simultaneously. Although the noise analysis does not rule out this possibility, the modeling results demonstrate that the testing of a single generator would result in noise levels in excess of applicable thresholds, as stated on page 4.11-44. This is the basis of the draft EIR’s determination that noise impacts related to generator testing would be significant, requiring implementation of Mitigation Measure NOI-1d.

Similar to Comment A-San Bruno-10, the comment states that the draft EIR’s analysis of generator noise is inadequate because it fails to estimate and compare noise levels with implementation of Mitigation Measure NOI-1d to an appropriate threshold. In addition, the comment states that ambient noise level cited in the analysis is not appropriate for the approximation of daytime ambient noise levels in the project area. See Response to Comment A-San Bruno-10. Similar to Mitigation Measure NOI-1c, Mitigation Measure NOI-1d is a performance-based mitigation measure that requires noise measurements to be taken once equipment models, design features, and specific locations are identified to demonstrate that generators would not result in a 10 dB increase over actual ambient levels at nearby sensitive uses (in addition to ensuring other applicable thresholds are met). Thus, using a lower ambient noise measurement for purposes of the EIR analysis would not affect the impact conclusion or required mitigation. As shown in Chapter 3, Revisions to the Draft EIR, a sentence has been added to Mitigation Measure NOI-1d to clarify that ambient noise levels must be identified by conducting field noise measurements.

In addition, the comment refers to Mitigation Measure AQ-8, which requires that no more than one Phase 1 emergency generator be tested in any 24-hour period. The comment expresses concern that implementation of Mitigation Measure AQ-8 would result in elevated noise levels for more days than would occur if the generators were all tested on the same day. As stated in the EIR, the threshold of significance for the analysis of generator noise impacts is whether noise from generator testing would exceed applicable thresholds at any given time. If an exceedance would occur, a significant impact is identified and mitigation is prescribed (as is the case in the draft EIR). The threshold does not account for the cumulative duration of the exceedance or the number of times the exceedance would occur. While some receptors could experience increased disturbance if generator testing City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-41 May 2022
ICF 00082.20
occurs on multiple days, this would not affect the impact determination under CEQA. Mitigation Measure NOI-1d would reduce the impact from emergency generators to a less-than-significant level, regardless of the number of days per month on which testing may occur.

Response to Comment A-San Bruno-12
The comment summarizes the transportation-related comments that the City of San Bruno provided in response to the project’s NOP. Impacts related to intersections, traffic volumes, VMT, and site geometry are addressed in Section 4.15, Transportation and Circulation, of the draft EIR. In addition, although not required for CEQA analysis, a level of service (LOS) analysis was included for informational purposes in Appendix 4.15-1 of the draft EIR.

Response to Comment A-San Bruno-13
The comment suggests that a bulbout be incorporated into the southwest corner of the South Maple Avenue/Huntington Avenue/Sneath Lane/Southline Avenue intersection to discourage cars in the southbound right turn pocket on the Maple Avenue approach from accidentally or intentionally going through the intersection from the right turn lane. The proposed right turn only lane allows for only right turn movements and is not aligned with the through movement; moreover, the right turn only lane would be appropriately signed and striped consistent with the City’s applicable design standards for roadway configuration. Consequently, this proposed lane configuration is not expected to pose any conflicts at the intersection. The comment does not raise any issues about the adequacy of the draft EIR. No revisions to the draft EIR are required.

Response to Comment A-San Bruno-14
The comment states that no driveways should be located within 150 feet of a proposed intersection.

As described in Impact TR-3A beginning on page 4.15-37 in Section 4.15, Transportation and Circulation, of the draft EIR, there are two existing driveways and one proposed driveway within 150 feet of the new intersection that are necessary to maintain access to the SamTrans Transit Center and San Bruno BART station. The project’s proposed new intersection at Huntington Avenue/Sneath Lane/Southline Avenue/Maple Avenue would change access to several adjacent driveways associated with the SamTrans Transit Center and BART operations and maintenance facility:
• Access to the BART maintenance facility driveway on the north side of Huntington Avenue would remain in the westbound direction but would be restricted in the eastbound direction.

BART vehicles would retain a right-in, right-out access. • Eastbound access to the SamTrans Transit Center for buses would not change; buses would continue to use the driveway for ingress only. A majority of buses accessing the transit center are expected to continue using this driveway.
• Northbound bus ingress from Huntington Avenue to the SamTrans Transit Center would be relocated to a signalized bus-only left turn to the south of the proposed intersection from the existing unsignalized left turn. About five buses per hour are expected to use this signalized driveway.

The project would not otherwise close or limit access to the SamTrans Transit Center or BART operations and maintenance facility; doing so would adversely impact existing transit operations. As City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-42 May 2022
ICF 00082.20
each driveway would be used by professional drivers only from these transit agencies with relatively low volumes, use of these driveways would not pose a design hazard and would be consistent with applicable design standards. No revisions to the draft EIR are required.

Response to Comment A-San Bruno-15
The comment states that the new proposed intersection must connect to existing signalized intersections to the west and south of the new intersection so that these three signals can communicate and have coordinated signal timing for safety and efficiency reasons. As documented in Specific Plan Chapter 3 Circulation and Mobility, the new traffic signals along Southline Avenue (Huntington Avenue, project entrance, South Linden Avenue) and the rail crossing would be connected to existing nearby signals; signalization of the intersections described in the comment are included in the project.

Response to Comment A-San Bruno-16
The comment suggests updates to the regulatory framework discussion in Section 4.15, Transportation and Circulation, of the draft EIR to include additional Caltrans policy and guidance documents including the Caltrans Vehicle Miles Traveled-Focused Transportation Impact Study Guide and Traffic Safety Bulletin 20-02-R1. The draft EIR includes an assessment of VMT impacts consistent with the Technical Advisory on Evaluating Transportation Impacts in CEQA that provides guidance on evaluating VMT impacts, as developed by the Governor’s Office of Planning and Research (OPR). The draft EIR also includes assessment of safety impacts. The approach to VMT and safety impact assessment is summarized below.

As the lead agency, the City of South San Francisco has authority to determine its thresholds of significance and analysis methodology under CEQA and neither of the Caltrans documents are binding on the City. As noted on page 3 of the Caltrans Vehicle Miles Traveled-Focused Transportation Impact Study Guide referenced in the comment, the document is “not binding on public agencies and is intended to be a reference and informational document”; regarding the Caltrans Traffic Safety Bulletin 20-02-R1: Interim Local Development Intergovernmental Review Safety Review Practitioners Guidance document referenced in the comment, that document states on page 2 that “local agencies may use this guidance at their own discretion.” With regard to Caltrans facilities, the draft EIR addresses topics raised in Caltrans’ response to the project’s NOP.

Caltrans did not provide comments on the draft EIR.

An analysis of the project’s effects on VMT consistent with Public Resources Code Section 21099, City of South San Francisco Resolution 77-2020 and CEQA Guidelines Section 15064.3, and the Caltrans Vehicle Miles Traveled-Focused Transportation Impact Study Guide is provided in Impact TR-2 beginning on page 4.15-35 of the draft EIR. These documents establish a presumption of less than significant for VMT impacts related to qualifying land use projects within a transit priority area (TPA), defined as an area within 0.5 mile of an existing or planned major transit stop, such as a rail transit station, a ferry terminal served by transit, or the intersection of two or more major bus routes. The Specific Plan area is within 0.5 mile of two major transit stops, including the San Bruno BART station and a frequent bus route (i.e., the SamTrans ECR route, which operates every 15 minutes), as stated in the draft EIR.

City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-43 May 2022
ICF 00082.20
An analysis of the project’s effects on safety is included in Impacts TR-3A (site design hazards), TR3B (freeway off-ramp hazards), TR-3C (rail crossing hazards), TR-3D (traffic signal warrants), and TR-5B (bicycle and pedestrian facilities) beginning on page 4.15-37 of the draft EIR. Topics identified on pages 6 and 7 of the Caltrans Traffic Safety Bulletin 20-02-R1 are covered in these impact analyses, including the project’s effects on degrading the walking and bicycling environment and experience, new pedestrian and bicyclist desire lines, multimodal conflict points, change in traffic composition, driveway or intersection spacing, and queueing on roadways and freeway ramps.

No revisions to the draft EIR are required.

Response to Comment A-San Bruno-17
The comment asks for clarification regarding why the person trips for public amenity visitors during peak hours are different under Phase 1 and the project, while daily persons trips are the same, as described in Tables 4.15-2 and 4.15-4 in Section 4.15, Transportation and Circulation, of the draft EIR. Tables 4.15-2 and 4.15-4 present trip generation data for external project trips. These differences were presented due to a rounding error in Table 4.15-4 and have been revised in Chapter 3, Revisions to the Draft EIR.

Response to Comment A-San Bruno-18
The comment states that, regarding vehicle trip generation rates for Phase 1 and project buildout as stated in draft EIR Tables 4.15-3 and 4.15-5, it appears that vehicle trip generation estimates were calculated using average trip rates rather than the fitted curve equation, and states a preference for average trip rates. Tables 4.15-3 and 4.15-5 in Section 4.15, Transportation and Circulation, of the draft EIR note that the fitted curve equation was used for the calculation of existing trip generation only, while average rates were used for proposed project land uses. Use of the fitted curve for existing land uses is consistent with ITE 10th Edition guidance. No revisions to the draft EIR are required.

Response to Comment A-San Bruno-19
The comment states that the freeway ramp discussion included in the draft EIR under Impact TR-3a analyzes off-ramp queuing analysis but should be updated to include other on-ramps in the surrounding area that are metered or may become metered during buildout of the project, as well as that a ramp capacity analysis should be performed. Impact TR-3B beginning on page 4.15-40 in Section 4.15, Transportation and Circulation, of the draft EIR analyzes whether the project would increase hazards due to freeway ramp queuing, and addresses freeway off-ramps where projectgenerated traffic volumes may cause a queue to spill back onto the mainline per Caltrans guidance and comments raised by Caltrans in response to the project’s NOP. Queueing on freeway on-ramps does not typically cause a safety hazard and is not documented in Caltrans Traffic Safety Bulletin 20- 02-R1. Analysis of on-ramp capacity and queues are primarily a measure of automobile delay; per CEQA Guidelines Section 15064.3, a project's effect on automobile delay shall not constitute a significant environmental impact as described in Response to Comment A-San Bruno-16. For these reasons, the City has not adopted thresholds of significance for onramp queues. No revisions to the draft EIR are required.

City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-44 May 2022
ICF 00082.20
Response to Comment A-San Bruno-20
The comment states that analysis conducted for the San Bruno Avenue/Northbound 101 off-ramp intersection needs to provide an explanation as to why the intersection would operate at LOS C while experiencing long queues at the off-ramp. As shown in Chapter 3, Revisions to the Draft EIR, the analysis of 95th percentile queues has been updated in Table 4.15-7 of the draft EIR to reflect fully optimized signal timing for the 2040 Future Baseline and 2040 Project Buildout Scenarios. By optimizing signal timing, the 95th percentile queue for the northbound left turn lane would be approximately 201 feet during the AM peak hour under 2040 Future Baseline conditions and 305 feet under 2040 Project Buildout conditions, which is consistent with an off-ramp that experiences low to moderate delay (LOS C).

Response to Comment A-San Bruno-21
The comment asks for clarification as to why the project would cause a large increase in queue length at the northbound left turn lane of the San Bruno Avenue/I-280 northbound off-ramp intersection in comparison with existing conditions where the queue is only 93 feet, when traffic on the northbound left turn lane would travel away from the project. As discussed in Response to Comment A-San Bruno-20 and shown in Chapter 3, Revisions to the Draft EIR, the analysis of 95th percentile queues has been updated in Table 4.15-7 of the draft EIR to reflect fully optimized signal timing for the 2040 Future Baseline and 2040 Project Buildout Scenarios. By optimizing signal timing, the 95th percentile queue for the northbound left turn lane would be approximately 225 feet during the PM peak hour under 2040 Future Baseline conditions and 426 feet under 2040 Project Buildout conditions. The 95th percentile queue for the northbound through/left/right turn would be approximately 1,372 under 2040 Future Baseline conditions and 1,391 under 2040 Project Buildout conditions.

As discussed in Response to Comment A-San Bruno-19, Impact TR-3B in Section 4.15, Transportation and Circulation, of the draft EIR analyzes whether the project would increase hazards due to freeway ramp queuing. The analysis shows vehicle queues increasing at this northbound off-ramp during the PM peak hour under Phase 1 and Project Buildout conditions due to the optimization of signal timing associated with a net increase in eastbound and westbound volumes serving project-generated trips and diverted trips. However, the project is not anticipated to increase traffic volumes at the off-ramp itself, as it represents the reverse-peak direction of travel at an off-ramp location that is less convenient to the project compared to the other freeway ramps for U.S. 101, I-280 and I-380 that serve the project. Since project-related traffic volumes would not add to vehicle queues for the northbound off-ramp, the impact would be less than significant and no mitigation is required.

Response to Comment A-San Bruno-22
The comment requests that a freeway segment LOS analysis be conducted pursuant to the C/CAG CMP Technical Guidelines. Per CEQA Guidelines Section 15064.3, a project's effect on automobile delay shall not constitute a significant environmental impact as described in Response to Comment A-San Bruno-16. The C/CAG CMP Technical Guidelines have not been updated since adoption of SB 743 which amended CEQA Guidelines Section 15064.3 to establish an alternative to automobile delay. Therefore, notwithstanding prior guidance provided in the C/CAG CMP Technical Guidelines, City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-45 May 2022
ICF 00082.20
a freeway segment LOS analysis is not required. For these reasons, the City has not adopted thresholds of significance for onramp queues. No revisions to the draft EIR are required.

Response to Comment A-San Bruno-23
The comment pertains to the LOS analysis conducted for the project, which was included for informational purposes in Appendix 4.15-1 of the draft EIR. Per CEQA Guidelines Section 15064.3, a project's effect on automobile delay shall not constitute a significant environmental impact. The City no longer utilizes LOS significance thresholds in connection with CEQA analysis; on June 10, 2020, the City of South San Francisco adopted Resolution 77-2020 establishing VMT thresholds and methodology effective July 1, 2020 consistent with CEQA Guidelines Section 15064.3, as discussed further in Section 4.15, Transportation and Circulation, of the draft EIR. No revisions to the draft EIR are required.

Response to Comment A-San Bruno-24
See Response to Comment A-San Bruno-23.

Response to Comment A-San Bruno-25
The comment states that the project’s effects on BART and Caltrain capacity should be analyzed under 2040 cumulative conditions, and not based on 2019 passenger counts. Impact TR-5A beginning on page 4.15-47 in Section 4.15, Transportation and Circulation, of the draft EIR analyzes the project’s effects on the performance of transit services including potential delay and overcrowding. The analysis of overcrowding focuses on 2019 conditions as it represents an observed and quantifiable baseline condition, and illustrates the project’s potential contribution to this baseline. The analysis shows that although the project would result in a large increase in BART ridership at San Bruno Station, the increase in ridership would generally occur in the reverse-peak direction in which BART has ample capacity. Some increase in Caltrain ridership would also occur, but would be distributed across two stations served by trains traveling in both directions.

The project’s contribution to transit ridership would be similar under 2040 cumulative conditions compared to 2019 conditions, while the percent contribution relative to overall transit ridership and capacity would be lower. Plan Bay Area includes projects to expand the frequency of BART and Caltrain service in the coming decades. BART service would expand to every 12 minutes on each line, increasing service levels at San Bruno Station from eight to ten trains per hour, per direction during peak periods, representing a 25 percent increase in capacity. Caltrain service would expand from six trains per hour per direction after the Peninsula Corridor Electrification Project to eight trains per hour, per direction, representing a 33 percent increase in capacity. As transit ridership and service levels increase over time, the project’s percent contribution to potential overcrowding would decrease. Therefore, the analysis of 2019 conditions provides a reasonable estimation of the project’s potential effects, and the lack of project contribution to overcrowding under 2019 conditions is also indicative of potential 2040 conditions. BART did not request an analysis of transit capacity under 2040 cumulative conditions in their comments on the NOP or draft EIR. Caltrain did not comment on the NOP or draft EIR. No revisions to the draft EIR are required.

See also Response to Comment A-BART-2.

City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-46 May 2022
ICF 00082.20
Response to Comment A-San Bruno-26
The comment requests a figure showing the proposed location of the emergency vehicle access route during construction of the new Southline Avenue and intersection for review by the San Bruno Police Department and Fire Department. Figures 4.15-1 and 4.15-6 in Section 4.15, Transportation and Circulation, of the draft EIR depict the proposed site plan in relation to surrounding areas, illustrating the circulation network that will serve the project, including the new Southline Avenue street connection between Sneath Lane and South Linden Avenue and street changes near the San Bruno police station at 1177 Huntington Avenue. The proposed site plan would not decrease existing emergency vehicle routes: emergency vehicles would retain the ability to travel both with and against the flow of traffic on Sneath Lane and Huntington Avenue. The addition of Southline Avenue and implementation of the new Huntington Avenue/Sneath Lane/Southline Avenue intersection will enable emergency vehicle travel directly between Sneath Lane/Huntington Avenue and areas to the east of Huntington Avenue, including residential and employment areas in the City of San Bruno and City of South San Francisco. Emergency vehicles would retain the ability to access Tanforan Avenue and would have a shorter path of travel from the west via Southline Avenue. No revisions to the draft EIR are required.

Response to Comment A-San Bruno-27
The comment states that the Decima Allen Elementary School project should be included in the cumulative transportation analysis. As stated on page 4.1-9 in Section 4.1, Approach to Environmental Analysis, of the draft EIR, the projects utilized for the draft EIR’s list-based cumulative analyses are projects for which applications had been filed with the City as of publication of the project’s NOP (May 22, 2020) but construction had not begun by that date, and/or projects that the City has otherwise determined are reasonably foreseeable. The Decima Allen Elementary School was proposed after issuance of the project’s NOP and was not reasonably foreseeable at the time the cumulative project list was developed. As the lead agency the City retains the discretion to determine a reasonable cutoff date for identifying which projects to include in an EIR’s cumulative analysis.

As discussed in Section 4.15.4.2 beginning on page 4.15-24 of the draft EIR, cumulative analysis included land use growth covered in Plan Bay Area 2040 plus any growth beyond Plan Bay Area 2040, including the Bayhill Specific Plan and additional employment growth in the East of 101 Area in South San Francisco. Given the Decima Allen Elementary School project would result in relatively minor land use changes that are consistent with Plan Bay Area 2040, it is reasonably captured within the Plan Bay Area 2040 land use forecasts. No revisions to the draft EIR are required.

Response to Comment A-San Bruno-28
The comment questions of the South Linden Avenue grade crossing and associated closure of Scott Street is included in the cumulative transportation analysis. As described in Section 4.15.4.2 beginning on page 4.15-24 of the draft EIR, the grade separation of South Linden Avenue and associated closure of Scott Street was not included in the cumulative analysis as construction of this project is not yet fully funded or included in the Regional Transportation Plan. The proposed grade separation project would be subject to a separate CEQA review and approval process. As discussed in Impact TR-3A and Impact TR-3C in the draft EIR, the project’s design is compatible with the City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-47 May 2022
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preferred hybrid grade separation design at South Linden Avenue and street closure at Scott Street.

No revisions to the draft EIR are required.

Response to Comment A-San Bruno-29
The comment states that regardless of the jurisdiction (i.e., the City of San Bruno or the City of South San Francisco) all costs associated with replacing or upsizing utilities will be assumed by the project applicant. The applicant will be responsible for paying all required utility construction costs. Section

4.17, Utilities and Service Systems, of the draft EIR provides information on the existing utilities found at the project site. In addition, the section details which utilities the project would be required to be upsized, replaced, or relocated. The comment does not contain questions or concerns regarding the adequacy of the draft EIR analysis. No revisions to the draft EIR are required.

Response to Comment A-San Bruno-30
The comment states that City of San Bruno has no comments on the project-level analysis of utilities and service systems impacts provided in the draft EIR. Comment noted. The comment does not contain questions or concerns regarding the adequacy of the draft EIR analysis. No revisions to the draft EIR are required.

Response to Comment A-San Bruno-31
The comment requests that any below-ground construction work in the vicinity of utilities that service the City of San Bruno, including fiber optic cables, will require the project applicant to pothole and accurately locate and identify all fiber optic cables to ensure that construction does not damage these cables or interrupt service. The project applicant and the City will work with the City of San Bruno to ensure that no utilities are damaged or interrupted. The comment does not contain questions or concerns regarding the adequacy of the draft EIR analysis. No revisions to the draft EIR are required.

Response to Comment A-San Bruno-32
The comment states that the draft EIR’s cumulative impact analysis appropriately includes the Bayhill Specific Plan but should also account for the Mills Park Center project. The Mills Park Center project, as of summer 2020 (i.e., when the NOP was released), is a proposed mixed-use residential and commercial project located approximately 0.75 mile south of the Specific Plan area in the City of San Bruno; no more recent publicly available information is available regarding this project. As described in Section 4.1.6, Approach to Cumulative Impact Analysis, the cumulative impact analysis for the EIR generally employs either a list-based approach or a projections approach, depending on which approach appropriately captures the cumulative context for the individual resource topic being analyzed. Cumulative analyses for topics that tend to be highly localized (e.g., biological resources, cultural resources, geology and soils, and construction impacts) use a list-based approach that includes nearby future projects anticipated in the project vicinity (i.e., within approximately 0.5 mile of the project site). Other impacts can affect existing conditions on a citywide or regional scale (e.g., air quality, GHG emissions, public services, population growth). These topics employ a projections approach towards evaluating cumulative impacts.

City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-48 May 2022
ICF 00082.20
Table 2-2 provided below for informational purposes summarizes the relevancy of the Mills Park Center project to the cumulative impact analysis for each environmental topic evaluated in detail in the draft EIR. With respect to projections-based impact analyses (i.e., the air quality, greenhouse gas emissions, population and housing, and transportation and circulation sections), the Mills Park Center project is already included within such analysis. Specifically, as discussed on page 4.2-61 in Section 4.2, Air Quality, of the draft EIR, the cumulative geographic context for air quality impacts in the San Francisco Bay Area Air Basin (SFBAAB); the Mills Park Center project is located in the SFBAAB and is therefore included in the draft EIR analysis of cumulative air quality impacts. In addition, as discussed on page 4.7-44 in Section 4.7, Greenhouse Gas Emissions, of the draft EIR, climate change is a global problem, and the GHG analysis is inherently cumulative, and therefore, the draft EIR’s cumulative GHG analysis accounts for the Mills Park Center project. In Section 4.12, Population and Housing, as discussed on page 4.12-20, of the draft EIR, the cumulative geographic context for impacts related to population and housing is the San Francisco-Oakland-Hayward corebased statistical area, which comprises Alameda, Contra Costa, Marin, San Francisco, and San Mateo counties, including the Mills Park Center project. Further, in Section 4.15.4.2 beginning on page 4.15- 24 in Section 4.15, Transportation and Circulation, of the draft EIR, the cumulative transportation analysis includes land use growth covered in Plan Bay Area 2040, which includes the Mills Park Center project.

With respect to the environmental topics provided in Table 2-2 below that utilized the list-based impact analyses, the Mills Park Center project is not sufficiently close to the project site to warrant inclusion in the cumulative impacts analysis for this project. As detailed in Table 2-2, no revisions to the draft EIR are required.

Table 2-2. Relevancy of Mills Park Center Project to Draft EIR Cumulative Analysis by Topic CEQA Topic Summary
Biological
Resources
As discussed on page 4.3-26 in Section 4.3, Biological Resources, of the draft EIR, the cumulative geographic context for 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. Given the distance between the Mills Park Center project and the proposed project, and the separation provided by I-380, the projects would not have the potential to combine and create cumulative impacts on biological resources.

Cultural
Resources
As discussed on pages 4.4-28 and 4.4-29 in Section 4.4, Cultural Resources, of the draft EIR, the cumulative geographic context for historical resources is the potential South San Francisco industrial historic district area. 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 Mills Park Center project is located in the City of San Bruno, outside the potential historic district area. Given the distance between the Mills Park Center project and the proposed project, the projects would not have the potential to combine and create cumulative impacts on cultural resources.

Energy The Mills Park Center project is located in San Bruno and is served by different natural gas and electricity providers than the project. Therefore, there would be no cumulative impact on energy.

City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-49 May 2022
ICF 00082.20
CEQA Topic Summary
Geology and Soils In general, a project’s potential impacts related to geology and soils are individual and localized, depending on the project site and underlying soils. Given the distance between the Mills Park Center project and the proposed project, the projects would not have the potential to combine and create cumulative impacts on localized geology and soils resources.

Hazards and
Hazardous
Materials
As discussed on page 4.8-39 in Section 4.8, Hazards and Hazardous Materials, of the draft EIR, the cumulative context for hazards and hazardous materials is the project site and nearby properties in the immediate vicinity. Given the distance between the Mills Park Center project and the proposed project, the projects would not have the potential to combine and create cumulative impacts on hazards and hazardous materials resources.

Hydrology and
Water Quality
As discussed on page 4.9-42 in Section 4.9, Hydrology and Water Quality, of the draft EIR, the cumulative geographic context for impacts related to surface water hydrology and water quality is the Colma Creek-Frontal San Francisco Bay Estuaries Watershed (approximately 32 square miles). The cumulative geographic context for impacts related to groundwater hydrology and water quality is the Westside Groundwater Basin (approximately 40 square miles). The Mills Park Center project is located in the Colma Creek-Frontal San Francisco Bay Estuaries Watershed and Westside Groundwater Basin, and is therefore included in the draft EIR analysis of cumulative hydrology and water quality impacts.

Land Use and
Planning
The Mills Park Center project is located in San Bruno and is subject to the local plans and policies of San Bruno. With regard to regional land use plans, the draft EIR analysis determines that the project would have a less-than-significant impact. Therefore, there would be no cumulative impact on land use and planning.

Noise and
Vibration
As discussed on page 4.11-54 in Section 4.11, Noise, of the draft EIR, the cumulative geographic context for construction noise and vibration and operational stationary noise is the immediate vicinity of the project site. The cumulative geographic context for vehicular traffic noise includes the roadway segments near the project site, which includes traffic increases from all growth in the project area, as predicted in the traffic model. Given the distance between the Mills Park Center project and the proposed project, the projects would not have the potential to combine and create cumulative impacts with respect to construction noise and vibration and operational stationary noise. As discussed below, the cumulative transportation analysis includes land use growth covered in Plan Bay Area 2040, which includes the Mills Park Center project. Therefore, the Mills Park Center project is included in the draft EIR analysis of cumulative traffic noise impacts.

Public Services The Mills Park Center project is located in San Bruno and is served by different fire, police, school, library, and childcare providers than the project. Therefore, there would be no cumulative impact on public services.

Recreation The Mills Park Center project is located in San Bruno and is served by different parks and recreational facilities than the project. Therefore, there would be no cumulative impact on recreation.

Tribal Cultural
Resources
Given the distance between the Mills Park Center project and the proposed project, and the separation provided by I-380, the projects would not have the potential to combine and create cumulative impacts on localized tribal cultural resources.

City of South San Francisco Comments and Responses
Southline Specific Plan
Responses to Comments 2-50 May 2022
ICF 00082.20
CEQA Topic Summary
Utilities and
Service Systems
The Mills Park Center project is located in San Bruno and is served by different water, wastewater, solid waste, stormwater, natural gas, and electricity providers than the project. Therefore, there would be no cumulative impact on utilities and service systems.

Response to Comment A-San Bruno-33
The comment states that City of San Bruno has no comments on the alternatives analysis provided in the draft EIR. Comment noted. The comment does not contain questions or concerns regarding the adequacy of the draft EIR analysis. No revisions to the draft EIR are required.

Response to Comment A-San Bruno-34
The comment provides the City of San Bruno’s contact information, and requests that responses to the comments they provided are shared with the City of San Bruno at least 10 days prior to the certification of the EIR. Comment noted. Responses to all comments on the draft EIR will be circulated at least 10 days prior to certification of the EIR, and the City of San Bruno will be notified when the final EIR document is available.

November 10, 2021
Adena Friedman TRANSMITTED VIA E-MAIL and U.S. MAIL
Principal Planner [email protected]
City of South San Francisco
Economic and Community Development Department
315 Maple Street
South San Francisco, California 94080
Subject: EIR Comments: Southline Specific Plan
Dear Adena Friedman:

The San Francisco International Airport (SFO or the Airport) staff has reviewed the Draft Environmental Impact Report (DEIR) for the Southline Specific Plan (the Project), located primarily in the jurisdiction of South San Francisco. We appreciate this opportunity to provide comments on the Project DEIR.

The 26.5-acre Project site is located approximately two miles north-northwest of the Airport terminals, at the intersection of South Maple Avenue and Tanforan Avenue. The Project includes demolition of all existing on-site uses and construction of commercial office/research and development buildings; a fourstory supportive amenities building; up to approximately 3,064 underground parking spaces; a 9-story parking structure; a new east-west connection road; supportive utilities and infrastructure; and approximately 341,800 square feet of open space. Total building area would be up to 2.8 million square feet. The structures would be approximately 75 - 120 feet tall, above a ground elevation ranging from 24 to 26 feet above the North American Vertical Datum of 1988 (NAD88). Rooftop protrusions, including mechanical screens, would be at a maximum elevation of 142 feet above NAVD88 at specific locations on Building B7, as identified in the Project sponsor’s communications to the Airport.

The Project site is inside Airport Influence Area B as defined by the Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport (ALUCP). As shown in the DEIR (Chapter 4.10, Land Use and Planning), the entire Project site is within the 65 decibel (dB) Community Noise Equivalent Level (CNEL) contour, while the southwestern half of the site is also within the 70 dB CNEL contour. The noise contours are meant to minimize the exposure of residents and occupants of future noise-sensitive development to excessive noise. According to the ALUCP, commercial land uses, including office, business, and professional, and general retail uses, in addition to industrial and production uses, are considered compatible uses within the 65 – 75 dB CNEL areas.

However, the DEIR notes that an auditorium would be part of Building 2. This use is conditionally compatible provided that sound insulation is provided to reduce interior noise levels from exterior course to CNEL 45 dB or lower and that an avigation easement is granted to the City and County of San Francisco as operator of SFO.

The southwest corner of the Project is within Safety Compatibility Zone 4 (Outer Approach/Departure Zone). The ALUCP defines safety compatibility zones to protect public health and safety by minimizing the public’s exposure to the risk associated with potential aircraft accidents. In this zone, Biosafety Level 3 and 4 facilities, children’s schools, large child day care centers, hospitals, nursing homes, stadiums, and arenas are considered incompatible and should not be permitted. Additionally, hazardous uses (other than 









 




A-SFO
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3 Adena Friedman, City of South San Francisco
November 10, 2021

Biosafety Level 3 and 4 facilities) and critical public utilities should be avoided unless no feasible alternative is available. The project includes a basketball court and auditorium in Building 2, located in the southwest portion of the Project. However, these spaces are outside of Zone 4, and therefore the proposed site plan is compatible with the ALUCP.

Regarding height, the structures as proposed would be at least 0.08 feet (less than one inch) below the lowest critical airspace surface and therefore compatible with the ALUCP. Please note that the height of the completed structure is measured to its highest point, which includes all parapets, elevator overruns, and other mechanical uses, none of which can extend beyond this roughly 142-foot clearance. This leaves no margin for error for surveying and construction, as the maximum elevations must not be exceeded.

This determination does not negate the requirement for the Project proponent to undergo Federal Aviation Administration review as described in 14 Code of Federal Regulations Part 77 for both the permanent structures and any cranes or other equipment taller than the permanent buildings which would be required to construct those structures.

We note that in Chapter 4.10 of the DEIR, it states that:
…there is a contour to establish a limit of 125 feet above ground level running northeast-southwest located south of the Specific Plan area and a contour to establish a limit of 150 feet north of the Specific Plan area. As also shown in Figure 4.10-2, p. 4.10-11, the Specific Plan area falls within the 100 to 150 feet above ground level range for SFO’s critical aeronautical surfaces.

Because projects may change the ground level over time, using the existing ground level as a reference is inadequate to ensure the protection of critical airspace surfaces around SFO. Rather than 100 to 150 feet above ground level, the DEIR should state that the critical airspace above the Project site ranges from 139 to 152 feet above mean sea level as measured from the NAVD88 vertical datum origin. While the aeronautical surfaces are described incorrectly, the elevations of the structures as proposed in the DEIR are compatible with the ALUCP.
* * *
The Airport appreciates your consideration of these comments. If I can be of assistance, please do not hesitate to contact me at (650) 821-9464 or at [email protected].

Sincerely,
Nupur Sinha
Director of Planning and Environmental Affairs
San Francisco International Airport
cc: Susy Kalkin, ALUC
Audrey Park, SFO, Acting Environmental Affairs Manager










 




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Letter A-SFO: Nupur Sinha, San Francisco International Airport (November 11, 2021)
Response to Comment A-SFO-1
The comment states that the San Francisco International Airport (SFO) has reviewed the draft EIR, and provides a summarized description of the proposed project. Comment noted. The comment does not contain questions or concerns regarding the adequacy of the draft EIR analysis. No revisions to the draft EIR are required.

Response to Comment A-SFO-2
The comment states that the project site is inside Airport Influence Area B as defined by the Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport (ALUCP), that the entire project site is within the 65 CNEL contour for SFO, and that the southwestern half of the site is within the 70 CNEL contour. The SFO noise contours in relation to the project site are shown in Figure 4.10-3 in Section 4.10, Land Use and Planning, of the draft EIR.

The comment also states that most of the allowable land uses under the Specific Plan (e.g., commercial, office, business, retail, etc.) are considered compatible with noise levels in the 65 to 75 dBA CNEL range, with the exception of auditoriums, which are considered conditionally compatible provided that interior noise levels can be reduced to below 45 dBA. As discussed in Chapter 3, Project Description, of the draft EIR, Phase 1 proposes a 13,800-square-foot auditorium/event space with associated ancillary space. An acoustically well-insulated masonry building with windows and doors closed can provide 30 to 35 dB of noise attenuation, while more-conventional light frame construction provides 20 to 25 dB of noise reduction with windows closed. 6 Achieving sufficient
interior noise levels in an auditorium (e.g., reducing noise to below 45 dBA) would therefore be attainable for this use, and would be required as a condition of approval if an auditorium/event space is carried forth in the Phase 1 Precise Plan application.

Response to Comment A-SFO-3
The comment states that a portion of the project site is found within Safety Compatibility Zone 4 under the ALUCP, which includes more restrictive land uses, but that the proposed site plan is compatible with the ALUCP. This is consistent with the analysis on page 4.10-33 in Section 4.10, Land Use and Planning, of the draft EIR. The comment does not raise any questions or concerns about the adequacy of the draft EIR. No revisions to the draft EIR are required.

Response to Comment A-SFO-4
The comment confirms that building heights under the Specific Plan would be consistent with the height limitations established by the ALUCP. This is consistent with the analysis on page 4.10-33 in Section 4.10, Land Use and Planning, of the draft EIR. Also, as stated on page 4.10-31 of the draft EIR, under federal law, the project applicant is required to comply with all notifications and other requirements described in 14 CFR Part 77. The comment also cites a statement on page 4.10-9 of the 6 Federal Highway Administration (FHWA). Highway Traffic Noise: Analysis and Abatement Guidance, Washington, DC, December 2011. Available: fhwa.dot.gov/ENVIRONMENT/noise/measurement/fhwahep18065.pdf City of South San Francisco Comments and Responses
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draft EIR in reference to Figure 4.10-2 on page 4.10-11 of the draft EIR. Figure 4.10-2 depicts Exhibit IV-17 from the ALUCP, which shows the project site as being located within the 100-150 range for “Height of Critical Aeronautical Surfaces, Feet Above Ground Level (AGL).” The statement on page

4.10-9 of the draft EIR is consistent with this language. In making its determination of consistency with the ALUCP, the Airport Land Use Commission will maintain discretion to apply its standard measurement methodology.

Response to Comment A-SFO-5
The comment provides the San Francisco International Airport’s Director of Planning and Environmental Affairs contact information. Comment noted. The comment does not contain questions or concerns regarding the adequacy of the draft EIR analysis. No revisions to the draft EIR are required.

From: Samuel Lee
To: Planning Commission Comments
Subject: Southline Specific Plan Project Electronic Comment Date: Monday, October 25, 2021 7:36:48 AM
Importance: High
[NOTICE: This message originated outside of City of South San Francisco -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.] To whom this may concern:

I fully support this project to move forward and looking forward to this new development and its positive impact on our community.

Thank you
Samuel Lee, P.E.

President
Grand Electric & Construction Co.
133 Tanforan Ave. San Bruno, CA 94066
Tel : (650) 588-5678, Fax : (650) 588-6678
Cell : (415) 830-2020
I-Lee
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Letter I-Lee: Samuel Lee (October 25, 2021)
Response to Comment I-Lee-1
The comment expresses support for the project. Comment noted. The comment does not contain questions or concerns regarding the adequacy of the draft EIR analysis. No revisions to the draft EIR are required.

City of So. San Francisco October 29, 2021
400 Grand Ave.

So. San Francisco, Ca 94080
Project Title: Southline Specific Plan (EIR)
RE: Impact to Resident(s) of So San Francisco, Calif.

Comment Period
ATTN: ADENA Friedman, Sr. Planner
SSF Planning Division - [email protected]
Dear Ms. Friedman:

As a member of this community for over 40 years, this writing is to record my opposition to a plan that would alter the City of South San Francisco General Plan in order to tear down old warehouse businesses to put yet more bio-science labs, .1 mile from transit and West of Hwy 101.

The justification for such a project is not made in this plan or any part of this report as described, appears unjustified and unnecessary but as “just because the City can”. It will be more building where a community is experiencing building fatigue. I live in proximity to the San Bruno BART transit .3 miles in one of the oldest neighborhoods in South San Francisco, Mayfair Village. This project would impact my neighborhood and neighboring districts of Francisco Terrace, Brentwood and 2 local schools: Los Cerritos Elementary School and South San Francisco High School campuses. They are in proximity within 2 miles from the proposed project.

It is not clear whether my opposition counts as reason not to proceed with amending the City General Plan but I have several. Some are financial and some are quality of living concerns and questions.

Placing bio-labs on the west side of Hwy 101 in proximity to neighborhoods encompassing 2 cities of San Bruno, and South San Francisco, expose residents to hazards as the bio-medical industry transfer of bio-hazardous waste through neighborhoods periodically pose a risk to the health, in air quality and safety to residents, unless the bio-labs are for bio-medical equipment. This is not mentioned in this report. Will my property insurance increase as a result? What will residents suffer in the event of an accident involving the transport of bio-lab waste materials? Residents are left with the questions and the clean-up.

Another concern is the cost of toxic clean-up in the area of the warehouses in this report. The environmental impacts are significant and unavoidable. The report lists 3 hazardous sites under The Cortese List. 160 South Linden Avenue, 30 Tanforan Ave and 50 Tanforan Ave. The clean-up and cost to the City (and Taxpayer) is unescapable pursuant to CEQUA. As in past recent projects such as the Oyster Point Marina (former Dump), the City was forced to consider its liability risk to the community and has taken a $10M insurance policy. The Southline Specific Plan is a burdensome expense to the community’s taxpayer, by developing a site that poses financial and health risk unnecessarily.

This type of project has a tendency to render the cost of living to spiral out of control and represents unbridled growth. As current housing units near or at completion do not appear to deliver the desired result and solutions to the community’s shortage for affordable housing as a majority of the units are I-Richardson
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not occupied and appear to fail to remediate acute housing needs, due to unaffordability, while commuters swell the community daily to 100K, taxing local police and fire services.

The Cadence, a 160-unit development cannot fill its expensive lease units, reaching its 3rd year. This is not responsible planning, as housing needs continues.

The Southline Specific Plan project and others East of 101 at Oyster Point Marina are against the wishes of many in the community because it adds to the infrastructure load and high cost of living for City residents. The Oyster Point development under construction removed once enjoyable vistas of the marina. Every year for the past 5 years sewer fees ,trash, sales tax increases has caused the South San Francisco Community to become unaffordable. Adding the cost of new bio-since labs is not a good idea, fit, and irresponsible in the name of growth. The only reason to continue appears to keep City staff busy.

When the So. San Francisco General Plan was approved, the community agreed it was to be implemented in 20 years, yet the speed it is being implemented, by building thousands of units in less than 10 years, has caused construction fatigue. The Southline Specific Plan hopes to amend the General Plan for more unnecessary intrusive building in the lives of a small town that wants to remain a small town. We are losing that small town feel, that jams this small community with more traffic, noise, poor air quality further contributing to aircraft noise from nearby San Francisco Airport and from noisy 24 hr. 7 day science lab operation that permeates the skies further diminishing the quality of living of a community that continues to is disappear with every development the City embarks upon. It is a harbinger of things to come that the quiet life of suburban living won’t be achieved living in South San Francisco. This is not a good sign for the City.

Best,
Mina Richardson,
Resident
127 Cherry Ave
So. San Francisco, Ca 94080
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Letter I-Richardson: Mina Richardson (October 29, 2021) Response to Comment I-Richardson-1
The comment expresses opposition to the proposed project, and states that the project would alter the General Plan. As discussed on p. 4.10-35 in Section 4.10, Land Use and Planning, of the draft EIR, the project, including Phase 1, was found to be consistent with the relevant land use and planning related policies in the City’s existing General Plan. In addition, as explained in the analysis throughout the draft EIR, the project is generally consistent with the General Plan’s goals for the Specific Plan area and includes provisions to update the General Plan and Zoning Ordinance consistent with state law to ensure consistency. See Table 4.10-1 beginning on page 4.10-44 of the draft EIR for a detailed evaluation of the project’s consistency with relevant General Plan goals and policies. See also Response to Comment PC-7. No revisions to the draft EIR are required.

Response to Comment I-Richardson-2
The comment states that draft EIR does not justify why the project is necessary, and that it would impact nearby neighborhoods and schools. Potential impacts to nearby neighborhoods as a result of project implementation are discussed throughout the draft EIR document. Specifically, impacts to public services, which includes schools, are discussed in Section 4.13, Public Services, of the draft EIR. The section concluded that the proposed project would result in less than significant impacts on schools. In addition, the purpose of the draft EIR and the CEQA process is not to provide justification for the project, but to objectively discuss and disclose, to the greatest extent possible, potential environmental impacts that may result from construction and implementation of the proposed project. No revisions to the draft EIR are required.

Response to Comment I-Richardson-3
The comment expresses opposition to the project, including financial and quality of living concerns.

CEQA does not consider financial or the quality of life as an environmental impact. The comment does not contain questions or concerns regarding the adequacy of the draft EIR analysis. No revisions to the draft EIR are required.

Response to Comment I-Richardson-4
The comment expresses concern about the hazards and hazardous materials impacts that may result from project implementation. Section 4.8, Hazards and Hazardous Materials, of the draft EIR provides information on the existing hazards and hazardous materials found at the project site, as well as details regarding the possible hazards related to the handling of hazardous materials, including biomedical materials and waste, that may occur during operation of the project’s R&D uses. Specifically, Impact HAZ-1 of the draft EIR (pages 4.8-28 through 4.8-30) details how construction and operation of both the proposed project and Phase 1 would not create a significant hazard to the public through the routine transport, use, or disposal of hazardous materials. In addition, the section details how the project, with implementation of mitigation measures HAZ-2a, HAZ-2b, and HAZ-2c, would mitigate any potential impacts related to hazardous materials. See also Response to Comment PC-1. Health risk impacts that would result from project-generated pollutants are discussed in Section 4.2, Air Quality, of the draft EIR. The comment also questions whether City of South San Francisco Comments and Responses
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property insurance rates would increase as a result of the project; this topic is beyond the scope of CEQA, which is intended to analyze potential environmental impacts. No revisions to the draft EIR are required.

Response to Comment I-Richardson-5
The comment request information on how land and ground waste at the project site would be cleaned up and the financial implications to do so. See Response to Comment I-Richardson-4 and Response to Comment PC-1.

Response to Comment I-Richardson-6
The comment expresses concern regarding how the project would affect housing needs in the City of South San Francisco, and the cost of living impacts it would have. Under the General Plan, housing and residential uses are not permitted at the project site. As detailed in section 4.12, Population and Housing, of the draft EIR, the proposed project would not directly generate new population or households. Population and housing growth indirectly generated by project employees would be within the Association of Bay Area Government’s forecasted growth for the City. See also Response to Comment PC-8. Further, to the extent the comment asserts that the project could contribute to housing costs, these comments are beyond the scope of CEQA, which is intended to analyze potential environmental impacts. No revisions to the draft EIR are required.

Response to Comment I-Richardson-7
The comment expresses concern regarding how the project would affect the housing needs in the City of South San Francisco, and the cost of living impacts it would have. Section 4.13, Public Services, and Section 4.17, Utilities and Service Systems, of the draft EIR provide detailed information and analysis of the proposed project’s impacts related to additional demand placed on public service providers and utility infrastructure providers, respectively. See Response to Comment I-Richardson6 and Response to Comment PC-8.

Response to Comment I-Richardson-8
The comment states that the proposed project is not consistent with the growth envisioned under the General Plan (by building thousands of units in less than 10 years rather than over 20 years), would result in additional traffic, noise, and air quality impacts, and would not contribute to the City’s “small town feel.” As a clarification, the existing General Plan was adopted over 20 years ago, in 1999, and is currently undergoing a comprehensive update to cover the next 20-year period. See Response to Comment PC-7 and Response to Comment I-Richardson-6. In addition, impacts related to traffic, noise, and air quality are discussed in section 4.2, Air Quality, section 4.11, Noise and Vibration, and section 4.15, Transportation and Circulation, of the draft EIR, respectively. As explained in response to comment I-Richardson-2, the purpose of the draft EIR and the CEQA process is not to provide justification for the project, but to objectively discuss and disclose, to the greatest extent possible, potential environmental impacts that may result from construction and implementation of the proposed project. No revisions to the draft EIR are required.

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Chapter 3
Revisions to the Draft EIR
This section lists revisions that have been made to the draft EIR following the 45-day public comment period. Revisions were made either in response to comments received on the draft EIR or as staff-initiated changes to correct typographical errors. Staff-initiated text changes are indicated by an asterisk (*).

These changes and minor errata do not result in significant new information with respect to the proposed project, including the level of significance of project impacts or any new significant impacts. Therefore, recirculation of the draft EIR pursuant to CEQA Guidelines Section 15088.5 is not required.

3.1 Global Draft EIR Revisions
This section includes staff-initiated global revisions that were not raised in comments on the draft EIR but are relevant to the final EIR.

3.1.1 Final Water Supply Assessment
As discussed on page 4.17-9 in Section 4.17, Utilities and Service Systems, of the draft EIR, the proposed project meets the definition of a “project” requiring a Water Supply Assessment (WSA) pursuant to SB 610 (California Water Code Section 10910(a) and 10912(a)(3)). California Water Code Section 10910(g)(1) provides that the governing body of the public water system shall submit a WSA to the requesting city or county not later than 90 days from the date on which the request was received. Pursuant to California Water Code Section 10910(c)(1), the City requested a WSA for the proposed project from California Water Service (Cal Water) in April 2020. Cal Water provided a draft WSA to the City and project applicant in September 2020 and a revised draft WSA in December 2020. In March 2021, Cal Water informed the City and project applicant that Cal Water would be revising the WSA again to include updated language regarding the reliability of wholesale water supplies and provided another draft WSA to the City and project applicant in July 2021. The draft EIR analysis was based on the July 2021 draft WSA, which was included in Appendix 4.17-1 of the draft EIR. Based on information provided by Cal Water, the final WSA conclusions were anticipated to remain consistent as stated in the July 2021 WSA.

Cal Water provided a final WSA to the City and project applicant in December 2021, after the public comment period for the draft EIR was completed. The following summarizes the main changes made to the WSA:
• The draft WSA stated that the findings of the WSA were contingent upon the project’s successful completion of the requirements that were anticipated to be included in Cal Water’s pending Water Neutral Development Policy. The final WSA specifies that the findings of the WSA are contingent upon either the successful development of supplemental water supplies and/or the implementation of conservation/demand management measures to offset any net new demands from qualifying projects in specified Cal Water districts under the Water Neutral Development Policy.

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• The draft WSA stated that Cal Water had adopted its Water Neutral Development Policy, which Cal Water anticipated to have completed by the time it issued a final WSA. The final WSA clarifies that the Water Neutral Development Policy is under development but has not yet been adopted by Cal Water.
• The draft WSA stated that the implementation of the Bay-Delta Plan Amendment was under negotiation, through Voluntary Settlement Agreement negotiations between the San Francisco Public Utilities Commission (SFPUC) and the State Water Resources Control Board (SWRCB). However, as explained in the final WSA, as of October 2021, these negotiations have ceased, and no agreement has been reached. The final WSA removes references to the Voluntary Settlement Agreement negotiations.

Minor revisions have been made to the analysis in Section 4.17, Utilities and Service Systems, of the draft EIR to ensure the draft EIR discussion is consistent with the final WSA. The revisions are shown below in Section 3.2, Specific Draft EIR Revisions. The revisions to the final WSA or to Section

4.17 do not result in any changes to conclusions or mitigation in the draft EIR. The draft WSA in Appendix 4.17-1 has been replaced by the final WSA, which is attached to this RTC document as Appendix B.

3.1.2 Reduced Underground Parking Alternative
As discussed in Chapter 5, Alternatives, of the draft EIR, the City considered nine alternatives during the scoping process for the draft EIR. Six were rejected from further consideration based on their infeasibility, inability to meet the basic project objectives, and/or inability to reduce or avoid the significant impacts of the project. Three were selected for evaluation in the draft EIR alternatives analysis: the No Project Alternative (Alternative A), as required by CEQA, the No Intersection Alternative (Alternative B), and the Reduced Project Alternative (Alternative C). The draft EIR identified Alternative C as the environmentally superior alternative.

After the draft EIR was released for public review, the City identified a new alternative: the Reduced Underground Parking Alternative, based in part on comments raised during the public comment period. The City reviewed the new alternative and determined that it would be feasible to implement, would meet the basic objectives of the project, and would have the potential to reduce or avoid some of the significant impacts of the project. Accordingly, an analysis of the Reduced Underground Parking Alternative (Alternative D) has been added to the final EIR. The revisions are shown below in Section 3.2, Specific Draft EIR Revisions. The revisions include a description of the Reduced Underground Parking Alternative, an analysis of the potential impacts that would result from the Reduced Underground Parking Alternative, and a comparison of the alternative’s impacts to those of the project.

CEQA Guidelines Section 15088.5 requires recirculation of an EIR when “significant new information” is added after publication of the draft EIR but before certification. CEQA Guidelines Section 15088.5(a) states that new information added to an EIR is not “significant” unless “the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project proponents have declined to implement.” CEQA Guidelines Section 15088.5(a) further defines “significant new information,” in part, as a disclosure that notes that “a new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented” or a disclosure that notes City of South San Francisco Revisions to the Draft EIR
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that “a substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted to reduce the impact to a level of insignificance.” CEQA Guidelines section 15088.5(b) states that recirculation is not required if “new information in the EIR merely clarifies or amplifies or makes insignificant modifications in an adequate EIR.” As shown below in Section 3.2, Specific Draft EIR Revisions (see revisions to Chapter 5, Alternatives), the Reduced Underground Parking Alternative would not result in new significant environmental impacts or impacts of increased in severity that were not already disclosed in the draft EIR. In fact, the Reduced Underground Parking Alternative would avoid Phase 1’s significant air quality impacts (Impact AQ-2b and C-AQ-2), and would reduce (but not avoid) all of the project’s remaining significant and unavoidable impacts to below the proposed project’s level of impact, with the exception ofthe significant impact related to meeting traffic signal warrants at the Huntington Avenue/Herman Street/Forest Lane intersection, which would be similar to the project’s level of impact. Accordingly, the Reduced Underground Parking Alternative has been identified as the environmentally superior alternative and as the Recommended Alternative proposed for adoption.

Furthermore, the project applicant has not declined to implement the Reduced Underground Parking Alternative. Therefore, recirculation of the EIR pursuant to CEQA Guidelines Section 15088.5 is not required.

3.2 Specific Draft EIR Revisions
Table of Contents
* The following correction has been made to page vi in the Table of Contents of the draft EIR (new text is underlined and deleted text is strikethrough).

Appendix 4.17-1 Draft Final Water Supply Assessment
Chapter 2, Executive Summary
The following text has been added to Mitigation Measure AQ-2 in Table 2-1, Summary of Project Impacts and Mitigation Measures, on page 2-6 of the draft EIR (new text is underlined).

Mitigation Measure AQ-2: Require at Least Tier 4 Final Engines on Construction Equipment (All Phases)
All applicants proposing development of projects within the project site, including the Phase 1 applicant, shall require their contractors, as a condition of contract, to reduce constructionrelated exhaust emissions by ensuring that all off-road equipment operates with at least EPAapproved Tier 4 Final or newer engines. Exemptions can be made for specialized equipment when Tier 4 engines are not commercially available within 200 miles of the project site. The construction contract must identify these pieces of equipment, document their unavailability, and ensure that they operate on no less than an EPA-approved Tier 3 engine. At least 95 percent of off-road equipment must operate with at least an EPA-approved Tier 4 Final or newer engine.

All contractors shall be required to submit a list of equipment and associated Engine Identification Numbers to the California Air Resources Board for Tier 4 verification.

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The following text has been added to Mitigation Measure CR-1 in Table 2-1, Summary of Project Impacts and Mitigation Measures, on page 2-25 of the draft EIR (new text is underlined and deleted text is strikethrough).

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 issuance of a demolition building 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:

The following text has been added to Mitigation Measure CR-2b in Table 2-1, Summary of Project Impacts and Mitigation Measures, on page 2-27 of the draft EIR (new text is underlined).

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 find and immediately notify the City of South San Francisco Economic and Community Development Director if the resource was discovered in South San Francisco’s jurisdiction, or the San Bruno City Planning Manager and Public Works Director if the resource was discovered in San Bruno’s jurisdiction. A qualified archaeologist, in consultation with the City in which the resource was discovered, 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.

The following text has been added to Mitigation Measure NOI-1c, Mechanical Equipment Noise Reduction Plan (All Phases), on page 2-46 of the draft EIR (new text is underlined).

Mitigation Measure NOI-1c: Mechanical Equipment Noise Reduction Plan (All Phases) To reduce potential noise impacts resulting from project heating, cooling, and ventilation equipment, the Phase 1 applicant and applicants of future Precise Plans shall conduct a noise analysis to estimate noise levels of project-specific mechanical equipment based on the City of South San Francisco Revisions to the Draft EIR
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selected equipment models and design features, and create a Noise Reduction Plan to ensure noise levels of equipment, once installed, are below the applicable criteria described below.

The Noise Reduction Plan shall include any necessary noise reduction measures required to reduce project-specific mechanical equipment noise to a less-than-significant level. The plan shall also demonstrate that with the inclusion of selected measures, noise from equipment would be below the significance thresholds. Feasible noise reduction measures to reduce noise below the significance threshold include, but are not limited to, selecting quieter equipment, utilizing silencers and acoustical equipment at vent openings, siting equipment farther from the roofline, and/or enclosing all equipment in a mechanical equipment room designed to reduce noise. This analysis shall be conducted and the results and final Noise Reduction Plan shall be provided to the City prior to the issuance of building permits for each phase.

The noise analysis and Noise Reduction Plan shall be prepared by persons qualified in acoustical analysis and/or engineering. The Noise Reduction Plan shall demonstrate with reasonable certainty that noise from mechanical equipment selected for the project, including the attenuation features incorporated into the project design, will not exceed the City of South San Francisco property plane threshold of 60 dBA during daytime hours or 55 dBA during nighttime hours for nearby multi-family residential uses, 65 dBA during daytime hours or 60 dBA during nighttime hours for nearby commercial uses, or the City of San Bruno threshold of 10 dB above the ambient noise level, as identified through field noise measurements, at the property plane.

The Phase 1 applicant and applicants of future Precise Plans shall incorporate all feasible methods to reduce noise identified above and any other feasible recommendations from the acoustical analysis and Noise Reduction Plan into the building design and operations as necessary to ensure that noise sources meet applicable requirements of the respective noise ordinances at receiving properties.

The following text has been added to Mitigation Measure NOI-1d, Emergency Generator Noise Reduction Plan (All Phases), on page 2-47 of the draft EIR (new text is underlined).

Mitigation Measure NOI-1d: Emergency Generator Noise Reduction Plan (All Phases) Prior to approval of a building permit for any proposed development under the Specific Plan, including Phase 1, the Phase 1 applicant and applicants of future Precise Plans shall conduct a noise analysis to estimate noise levels from the testing of project-specific emergency generators, and create a Noise Reduction Plan to ensure noise levels of generator testing are below the applicable criteria This analysis and Noise Reduction Plan may be incorporated together with the analysis described in MM-NOI-1c. This analysis shall be conducted and the Noise Reduction Plan shall be created based on the analysis results. The results, methods, and final Noise Reduction Plan shall be provided to the City prior to the issuance of building permits for each phase. The analysis shall account for proposed noise attenuation features, such as specific acoustical enclosures and mufflers or silences, and the final Noise Reduction Plan shall demonstrate with reasonable certainty that proposed generator(s) will not exceed the City of South San Francisco property plane threshold of 60 dBA for residential uses and 65 dBA for commercial uses during daytime hours, or 55 dBA for residential uses and 60 dBA for commercial uses during nighttime hours, and the City of San Bruno threshold of 10 dB above the ambient noise level, as identified through field noise measurements. Acoustical treatments may include, but are not limited to:

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⚫ Enclosing generator(s);
⚫ Installing relatively quiet model generator(s);
⚫ Orienting or shielding generator(s) to protect noise-sensitive receptors to the greatest extent feasible;
⚫ Installing exhaust mufflers or silencers;
⚫ Increasing the distance between generator(s) and noise-sensitive receptors; and/or ⚫ Placing barriers around generator(s) to facilitate the attenuation of noise.

In addition, all project generator(s) shall be tested only between the hours of 7:00 a.m. and 8:00 p.m.

The Phase 1 applicant and applicants of future Precise Plans shall incorporate all recommendations from the acoustical analysis into the building design and operations to ensure that noise sources meet applicable requirements of the noise ordinance.

Chapter 3, Project Description
* The following correction has been made to Table 3 5, Summary of Off-Site Infrastructure Improvements, on page 3-23 of the draft EIR (deleted text is strikethrough).

Improvement Agencies with Jurisdictiona Project Phase
Where
Described in
EIR
Upsize sewer mains on
Tanforan Avenue and Shaw
Road
City of South San Francisco Phase 1 Section

3.6.2.11, Figure

4.17-2
* The following correction has been made to the second sentence in the first paragraph under Section

3.6.2.8, Vehicle Parking, on page 3-31 of the draft EIR (new text is underlined).

Pursuant to the development standards shown in Table 3-7, p.3-26, parking would be provided at a maximum ratio of 2.2 spaces per 1,000 square feet of commercial use, with an option to incorporate a valet parking strategy within this range. * The following correction has been made to the first sentence in the second paragraph under Section

3.6.2.8, Vehicle Parking, on page 3-31 of the draft EIR (new text is underlined and deleted text is strikethrough).

As shown in Table 3-9, p.3-32, an estimated 4,291 3,420 to 5,769 parking spaces would be provided depending on the total amount of development and parking ratios applied. * The following correction has been made to the last full paragraph on page 3-35 of the draft EIR (deleted text is strikethrough).

As shown in Figure 4.17-2 in Section 4.17, Utilities and Service Systems, several public sewer mains that directly serve the Specific Plan area would be upsized during Phase 1 to account for the additional sanitary sewer flow generation. The proposed project would upsize an existing 24-inch main on Tanforan Avenue from South Maple Avenue/Huntington Avenue east to an existing pump station on Shaw Road (FLS-11). The upsized main would range in size from 27 to City of South San Francisco Revisions to the Draft EIR
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33 inches. During Phase 1, the proposed project also would relocate a segment of an existing 8- inch sanitary sewer line along South Linden and Dollar Avenues to conform with the proposed realignment of the intersection and proposed reconfiguration of the existing at-grade rail crossing at South Linden Avenue (refer to Section 3.6.2.7). The proposed project would also install a new 8-inch sewer main to proposed development south to Tanforan Avenue. Sanitary sewer improvements anticipated for future phases include upgrading 18-inch mains to 24-inch mains in the northerly portion of South Maple Avenue and from South Maple Avenue to Lowrie Avenue.
* The following correction has been made to the last bullet on page 3-38 of the draft EIR (deleted text is strikethrough).
• Water, sewer, and storm infrastructure replacements in Tanforan Avenue, Shaw Road, South Linden Avenue, Dollar Avenue, and Huntington Avenue
Chapter 4, Environmental Setting, Impacts and Mitigation Section 4.2, Air Quality
The following correction has been made to the second paragraph under Section 4.2.1, Introduction, on page 4.2-1 of the draft EIR (new text is underlined and deleted text is strikethrough).

Issues identified in response to the Notice of Preparation (NOP) (Appendix 1) were considered in preparing this analysis. No questions or concerns related to air quality were raised in the responses to the NOP. The NOP comments pertaining to air quality include comments from the City of San Bruno and the Bay Area Air Quality Management District (BAAQMD). The City of San Bruno identified their air quality policies and recommended use of the BAAQMD air quality significance thresholds. The City of San Bruno also requested an analysis of construction and operation impacts associated with fugitive dust, criteria air pollutants, and toxic air contaminants. The City of San Bruno also requested an analysis of health impacts on nearby sensitive receptors, including single-family residences along Tanforan Avenue and Huntington Avenue, from exposure to toxic air contaminants and particulate matter. The BAAQMD comments recommended analysis of local and regional air quality, analysis of consistency with the 2017 Clean Air Plan, analysis of health risks, incorporation of design features and mitigation measures that reduce air quality impacts, consultation with BAAQMD for permitting for back-up diesel generators, and use of BAAQMD’s tools and resources that help analyze air quality impacts. These issues are addressed below in Section 4.2.4, Impacts and Mitigation Measures. * The following text has been deleted from the second paragraph on page 4.2-30 under Air Dispersion Modeling in Section 4.2.4.2, Approach to Analysis (deleted text is strikethrough).

Operational emissions from testing of the new diesel emergency backup generators were characterized as a separate vertical point source (POINT). The location of the generators was estimated, based on the project site plan, and the urban dispersion option was assumed. The modeling of emissions from generator activities utilized a 12-hour testing window per day (7:00 a.m. to 7:00 p.m.) because testing was assumed to occur during daytime hours. Variables, including release height (from 2.85 to 3.73 meters) and stack diameter (from 0.178 to 0.353 meter), were based on the horsepower of the generators (from 500 to 1,250 horsepower), taken from comprehensive modeling information provided by CARB for a range of different generators they tested.

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* The following revisions have been made to Table 4.2-5, Phase 1 Emergency Generator Technical Specifications and Testing Schedules, on page 4.2-31 of the draft EIR (new text is underlined and deleted text is strikethrough).

Table 4.2-5. Phase 1 Emergency Generator Technical Specifications and Testing Schedules Generator Building1
HP
Bin2
Max Hours per
Testing Day
(Normal Testing
Scenario)3
Max Hours per
Testing Day (Full
Load Testing
Scenario)4
Average
Hours
per
Year5
Max
Hours
per
Year56
1 1 1,700 0.5 4 7.33 50
2 1 1,700 0.5 4 7.33 50
3 2 700 0.5 4 7.33 50
4 7 1,700 0.5 4 7.33 50
5 7 1,700 0.5 4 7.33 50
Total 2.5 20 36.65 250
HP = horsepower; max = maximum
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 Specific Plans, but their locations and specifications are unknown at this time.
2 The project applicant provided the kilowattage (kW) of each generator. The kW was converted into HP and then conservatively rounded up into the appropriate HP bin used by CalEEMod for calculating generator emissions. 3 During the normal testing scenario, each generator would be tested for 30 minutes on the same day. The normal testing scenario would occur once a month.
4 During the full load testing scenario, each generator would be tested for 4 hours on the same day. The full load testing scenario would occur once every 36 months (3 years). 5Average hours per year calculated based on normal testing scenario hours per year (30 minutes every month equals 6 hours per year) plus full load testing hours per year (4 hours every 3 years equals 1.33 hours per year). 6 CARB’s Airborne Toxic Control Measure for Stationary Compression Ignition Engines and Section 330.3 of BAAQMD Regulation 9, Rule 8, restricts annual generator operation to 50 hours per year. * The following text has been inserted after the last sentence in the paragraph under Mitigation Measure AQ-2 on page 4.2-42 of the draft EIR (new text is underlined).

Mitigation Measure AQ-2: Require at Least Tier 4 Final Engines on Construction Equipment (All Phases)
All applicants proposing development of projects within the project site, including the Phase 1 applicant, shall require their contractors, as a condition of contract, to reduce constructionrelated exhaust emissions by ensuring that all off-road equipment operates with at least EPAapproved Tier 4 Final or newer engines. Exemptions can be made for specialized equipment when Tier 4 engines are not commercially available within 200 miles of the project site. The construction contract must identify these pieces of equipment, document their unavailability, and ensure that they operate on no less than an EPA-approved Tier 3 engine. At least 95 percent of off-road equipment must operate with at least an EPA-approved Tier 4 Final or newer engine.

All contractors shall be required to submit a list of equipment and associated Engine Identification Numbers to the California Air Resources Board for Tier 4 verification. * The following revisions have been made to the second paragraph under Construction on page 4.2-58 (new text is underlined and deleted text is strikethrough).

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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 receptor (MEIR)within 1,000 feet of Phase 1 construction activities. The construction MEIR is located closest to the residential property of 31 Tanforan Avenue (coordinates of 551583.92, 4166008.02). 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 receptorMEIR. 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. * The following corrections have been made to Table 4.2-14, Phase 1 Cancer and Chronic Hazard Risks and PM2.5 Concentrations during Construction, on page 4.2-59 of the draft EIR (new text is underlined and deleted text is strikethrough).

Table 4.2-14. Phase 1 Cancer and Chronic Hazard Risks and PM2.5 Concentrations during Construction
Unmitigated Mitigateda
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 Receptorb

89.6 137.9 0.1 0.40.4

4.5 9.8
< 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 bolded. 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.
* The following revisions were made to the second paragraph under Operation on page 4.2-59 (new text is underlined and deleted text is strikethrough).

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. Based on applicant-provided information, Ggenerators were assumed to would operate for an average of 7.3350 hours per year (see Table 4.2-5, p. 4.2-59), 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 City of South San Francisco Revisions to the Draft EIR
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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.

The operations MEIR is located closest to the residential property of 771 Tanforan Avenue (coordinates of 551708.92, 4166058.02). 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. * The following revisions were made to Table 4.2-15, Phase 1 Cancer and Chronic Hazard Risks and PM2.5 Concentrations during Operation, and the paragraph following the table on pages 4.2-59 and

4.2-60 (new text is underlined and deleted text is strikethrough).

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 2.70.2 < 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 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 is combined with (approximately three cases per million, per Table 4.2-14, p. 4.2-59) and the risk from the 30-year-long operational period.

Note that the MEIR for the combined risk happens to be the same receptor identified for the construction period risk (located closest to the residential property of 31 Tanforan Avenue) but not the same receptor identified for the operational period risk. (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 (9.84) is equal to the sum of the construction period cancer risk (9.77) plus the operational period cancer risk (0.07). The combined cancer risk would not exceed BAAQMD’s threshold of 10.0 cases per million. Therefore, this impact would be less than significant with mitigation.
* The following sentence has been added to the second paragraph on page 4.2-64 under Localized Criteria Pollutants and Toxic Air Contaminants (new text is underlined).

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 City of South San Francisco Revisions to the Draft EIR
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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. Note that the MEIR for the cumulative risk is neither the MEIR identified for the construction period risk nor the MEIR identified for the operational period risk. This is because the cumulative MEIR’s proximity to the high-risk ambient sources (i.e., the railway and an existing stationary source) is a greater factor in determining its cumulative risk than its proximity to the lower-risk Phase 1 sources of construction and operation. The MEIR is located closest to the residential property of 1275 Herman Street (coordinates of 551733.92, 4166058.02). 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. * The following revisions were made to Table 4.2-16, Mitigated Cumulative Health Risks from Phase 1, on page 4.2-64 (new text is underlined and deleted text is strikethrough).

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 21 < 0.1 0.1
Contribution from Phase 1 Operation
Maximally Exposed Individual Receptor < 12 < 0.1 < 0.1
Cumulative Totals
Existing + Phase 1 Construction 298 < 0.1 9.9
Existing + Phase 1 Operation 279 < 0.1 9.8
Existing + Phase 1 Construction and Operation 2930 < 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. b Contributions from Phase 1 construction reported with implementation of Mitigation Measures AQ-1 and AQ2.

Section 4.4, Cultural Resources
The following revision has been made to the third paragraph of Mitigation Measure CR-1 on page

4.4-25 of the draft EIR (new text is underlined and deleted text is strikethrough).

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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 issuance of a demolition building 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:

The following addition has been made to the first paragraph of Mitigation Measure CR-2b on pages

4.4-26 and 4.4-27 of the draft EIR (new text is underlined).

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 find and immediately notify the City of South San Francisco Economic and Community Development Director if the resource was discovered in South San Francisco’s jurisdiction, or the San Bruno City Planning Manager and Public Works Director if the resource was discovered in San Bruno’s jurisdiction. A qualified archaeologist, in consultation with the City in which the resource was discovered, 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.

Section 4.7, Greenhouse Gas Emissions
* The following correction has been made to the second sentence in the second paragraph under Section 4.7.1, Introduction, on page 4.7-1 of the draft EIR (new text is underlined and deleted text is strikethrough).

No questions or concerns related to GHG emissions were raised in the responses to the NOP. The NOP comments pertaining to GHG emissions include comments from the Bay Area Air Quality Management District (BAAQMD). The BAAQMD comments recommended analysis of consistency with various GHG-related planning documents, legislation, and executive orders; incorporation of design features and mitigation measures that reduce GHG impacts; and use of BAAQMD’s tools and resources that help analyze GHG impacts. These issues are addressed below in Section 4.7.4, Impacts and Mitigation Measures.

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Section 4.11, Noise and Vibration
The following correction has been made to the second paragraph on page 4.11-1 of the draft EIR (new text is underlined).

Issues identified in response to the Notice of Preparation (NOP) (Appendix 1) were considered in preparing this analysis. NOP comments pertaining to noise include concerns related to construction noise and vibration, as well as operational noise issues. These issues are addressed below in Section 4.11.4, Impacts and Mitigation Measures.

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The following corrections have been made to Table 4.11-16, Modeled Traffic Noise Impacts on Existing Land Uses, on page 4.11-38 of the draft EIR (new text is underlined and deleted text is strikethrough).

Table 4.11-16. Modeled Traffic Noise Impacts on Existing Land Uses Roadway Segment
2040
Without
Project
(dB Ldn)
2040
With
Project
(dB Ldn)
ProjectRelated
Increase
(dB)
Most
Sensitive
Adjacent
Land Use
Type
City in
Which
Segment Is
Located
Applicable
Compatibility
Standard
Exceeds
Compatibility
Standard?
Allowable
Increase
Exceeds
Allowable
Increase?
Sneath Lane Between I-280 and Cherry
Avenue

67.3 67.7 0.4 MFR SB 65 Yes 3 No
Sneath Lane Between Cherry Avenue and El
Camino Real

70.0 70.7 0.7 C/O/I SB 70 Yes 3 No
El Camino Real Between Sneath Lane and I38071.9 72.2 0.3 C/O/I SB 70 Yes 3 No El Camino Real Between I-380 on-/off-ramps 72.3 72.6 0.3 NA SB NA NA NA NA Sneath Lane Between El Camino Real and
Huntington Avenue

65.4 67.1 1.7 C/O/I SB 70 No 5 No
Huntington
Avenue
Between San Bruno Ave and
Forest Lane

64.7 65.1 0.45 SFR SB 60 Yes 3 No
Huntington
Avenue
Between Forest Lane/Herman
Street and Sneath Lane

64.4 64.8 0.4 SFR SB 60 Yes 3 No
Tanforan Avenue Huntington Avenue and Dollar
Avenue

59.8 55.4 -4.45 SFR SB 60 No 5 No
Dollar Avenue/
Herman Street
Between Tanforan Avenue and
Scott Street

62.1 62.3 0.2 SFR SB 60 Yes 3 No
San Mateo Avenue Between South Linden and
South Airport Boulevard

67.9 68.7 0.8 C/O/I SSF 70 No 5 No
South Linden
Avenue
Between Grand Avenue and
San Mateo Avenue

67.6 69.1 1.5 SFR SSF 65 Yes 3 No
South Linden
Avenue
Between Dollar Avenue and
San Mateo Avenue

61.8 64.7 2.9 C/O/I SSF 70 No 5 No
South Maple
Avenue
Tanforan Avenue and Victory
Avenue

61.7 64.6 2.93.0 C/O/I BOTH 70 No 5 No
Source: Traffic volumes provided by Fehr & Peers. Modeling conducted using a spreadsheet that was based on the FHWA Traffic Noise Model, version 2.5, at a fixed distance of 33 feet from the roadway centerline.

Note: The calculated increases between scenarios are rounded.

NA: Not applicable because the area between the I-380 ramps is undeveloped.

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The following text has been added to Mitigation Measure NOI-1c, Mechanical Equipment Noise Reduction Plan (All Phases), on page 4.11-42 of the draft EIR (new text is underlined).

Mitigation Measure NOI-1c: Mechanical Equipment Noise Reduction Plan (All Phases) To reduce potential noise impacts resulting from project heating, cooling, and ventilation equipment, the Phase 1 applicant and applicants of future Precise Plans shall conduct a noise analysis to estimate noise levels of project-specific mechanical equipment based on the selected equipment models and design features, and create a Noise Reduction Plan to ensure noise levels of equipment, once installed, are below the applicable criteria described below.

The Noise Reduction Plan shall include any necessary noise reduction measures required to reduce project-specific mechanical equipment noise to a less-than-significant level. The plan shall also demonstrate that with the inclusion of selected measures, noise from equipment would be below the significance thresholds. Feasible noise reduction measures to reduce noise below the significance threshold include, but are not limited to, selecting quieter equipment, utilizing silencers and acoustical equipment at vent openings, siting equipment farther from the roofline, and/or enclosing all equipment in a mechanical equipment room designed to reduce noise. This analysis shall be conducted and the results and final Noise Reduction Plan shall be provided to the City prior to the issuance of building permits for each phase.

The noise analysis and Noise Reduction Plan shall be prepared by persons qualified in acoustical analysis and/or engineering. The Noise Reduction Plan shall demonstrate with reasonable certainty that noise from mechanical equipment selected for the project, including the attenuation features incorporated into the project design, will not exceed the City of South San Francisco property plane threshold of 60 dBA during daytime hours or 55 dBA during nighttime hours for nearby multi-family residential uses, 65 dBA during daytime hours or 60 dBA during nighttime hours for nearby commercial uses, or the City of San Bruno threshold of 10 dB above the ambient noise level, as identified through field noise measurements, at the property plane.

The Phase 1 applicant and applicants of future Precise Plans shall incorporate all feasible methods to reduce noise identified above and any other feasible recommendations from the acoustical analysis and Noise Reduction Plan into the building design and operations as necessary to ensure that noise sources meet applicable requirements of the respective noise ordinances at receiving properties.

The following text has been added to Mitigation Measure NOI-1d, Emergency Generator Noise Reduction Plan (All Phases), on page 4.11-45 of the draft EIR (new text is underlined).

Mitigation Measure NOI-1d: Emergency Generator Noise Reduction Plan (All Phases) Prior to approval of a building permit for any proposed development under the Specific Plan, including Phase 1, the Phase 1 applicant and applicants of future Precise Plans shall conduct a noise analysis to estimate noise levels from the testing of project-specific emergency generators, and create a Noise Reduction Plan to ensure noise levels of generator testing are below the applicable criteria This analysis and Noise Reduction Plan may be incorporated together with the analysis described in MM-NOI-1c. This analysis shall be conducted and the Noise Reduction Plan shall be created based on the analysis results. The results, methods, and final Noise Reduction Plan shall be provided to the City prior to the issuance of building permits for each City of South San Francisco Revisions to the Draft EIR
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phase. The analysis shall account for proposed noise attenuation features, such as specific acoustical enclosures and mufflers or silences, and the final Noise Reduction Plan shall demonstrate with reasonable certainty that proposed generator(s) will not exceed the City of South San Francisco property plane threshold of 60 dBA for residential uses and 65 dBA for commercial uses during daytime hours, or 55 dBA for residential uses and 60 dBA for commercial uses during nighttime hours, and the City of San Bruno threshold of 10 dB above the ambient noise level, as identified through field noise measurements. Acoustical treatments may include, but are not limited to:
⚫ Enclosing generator(s);
⚫ Installing relatively quiet model generator(s);
⚫ Orienting or shielding generator(s) to protect noise-sensitive receptors to the greatest extent feasible;
⚫ Installing exhaust mufflers or silencers;
⚫ Increasing the distance between generator(s) and noise-sensitive receptors; and/or ⚫ Placing barriers around generator(s) to facilitate the attenuation of noise.

In addition, all project generator(s) shall be tested only between the hours of 7:00 a.m. and 8:00 p.m.

The Phase 1 applicant and applicants of future Precise Plans shall incorporate all recommendations from the acoustical analysis into the building design and operations to ensure that noise sources meet applicable requirements of the noise ordinance.

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The following corrections have been made to Table 4.11-18, Modeled Cumulative Traffic Noise Impacts, on page 4.11-57 of the draft EIR (new text is underlined and deleted text is strikethrough).

Table 4.11-18. Modeled Cumulative Traffic Noise Impacts Roadway Segment
Most
Sensitive
Adjacent
Land Use
Type
Existing
(dB Ldn)
Cumulative
No Project
(dB Ldn)
Cumulative
Plus Project
(dB Ldn)
Applicable
Compatibility
Standard (dB
Ldn)
Exceeds
Compatibility
Standard?
Allowable
Increase
(dB)
Cumulative
Plus Project
Minus
Existing
(dB)
c
Potential
Cumulative
Impact?
Sneath Lane Between I-280 and Cherry Avenue1 MFR 66.5 67.3 67.7 65 Yes 3 1.2 No Sneath Lane Between Cherry Avenue and El Camino Reala C/O/I 69.7 70.0 70.7 70 Yes 3 1.01 No El Camino Real Between Sneath Lane and I-380a C/O/I 71.3 71.9 72.2 70 Yes 3 0.9 No El Camino Real Between I-380 on-/off-rampsa NA 71.7 72.3 72.6 NA NA NA 0.9 No Sneath Lane Between El Camino Real and Huntington Avenuea C/O/I 64.9 65.4 67.1 70 No 5 2.2 No Huntington Avenue Between San Bruno Ave and Forest Lanea SFR 63.9 64.7 65.1 60 Yes 3 1.2 No Huntington Avenue Between Forest Lane/Herman Street and Sneath Lanea SFR 63.6 64.4 64.8 60 Yes 3 1.2 No San Mateo Avenue Between South Linden and South Airport Boulevardb C/O/I 67.6 67.9 68.7 70 No 5 1.1 No South Linden Avenue Between Grand Avenue and San Mateo Avenueb SFR 67.1 67.6 69.1 65 Yes 3 2.01 No South Linden Avenue Between Dollar Avenue and San Mateo Avenueb C/O/I 60.5 61.8 64.7 70 No 5 4.2 No Tanforan Avenue Huntington Avenue and Dollar Avenuea SFR 58.6 59.8 55.4 60 No 5 -3.2 No South Maple Avenue Tanforan Avenue and Victory Avenuea,b C/O/I 60.5 61.7 64.6 70 No 5 4.1 No Dollar Avenue/Herman Street Between Tanforan Avenue and Scott Streeta SFR 60.8 62.1 62.3 60 Yes 3 1.5 No Notes:
a. Segment is located in the city of San Bruno.
b. Segment is located in the city of South San Francisco. c. The calculated increases between scenarios are rounded.

N/A indicates that there would be no potential cumulative impact and, thus, no cumulatively considerable increase attributable to the proposed project.

Source: Traffic volumes provided by Fehr & Peers. Modeling conducted using a spreadsheet that was based on the FHWA Traffic Noise Model, version 2.5, at a fixed distance of 33 feet from the roadway centerline.

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Section 4.15, Transportation and Circulation
The following correction has been made to the first and second sentences in the second paragraph under Trip Generation Results, on page 4.15-29 of the draft EIR (new text is underlined and deleted text is strikethrough).

The project at buildout would generate approximately 28,461 28,460 daily person trips and 16,876 vehicle trips. These totals include 3,918 3,963 AM peak-hour person trips, 2,150 net new AM peak-hour vehicle trips, 3,528 3,554 PM peak-hour person trips, and 1,952 PM peak-hour vehicle trips.

The following corrections have been made to Table 4.15-4, Person-Trip Generation, Project Buildout, on page 4.15-32 of the draft EIR (new text is underlined and deleted text is strikethrough).

Table 4.15-4. Person-Trip Generation, Project Buildout
Mode
Mode
Share
AM Peak
Hour
PM Peak
Hour Daily
Drive alone 55% 2,105 1,879 15,984
Carpool 8% 306 273 2,317
BART 23% 880 786 5,394
Caltraina 10% 383 342 2,345
SamTrans 2% 77 68 469
Walking/bicyclingb 2% 77 68 469
Total Person Trips Monitored by TDM Ordinance 100% 3,828 3,416 26,978 Person trips, public amenity visitors —
90 135
112
138
1,483
1,482
Total Person Trips —
3,918
3,963
3,528
3,554
28,461
28,460
Notes:
a. Based on travel demand data from high-intensity “tech” office mode-share and person-trip generation surveys from downtown Redwood City near the Redwood City Caltrain station as well as requirements from the City TDM Ordinance.
b. Mode-share estimates based on City TDM surveys and assignment to transit providers, based on local context and expected travel patterns.

Source: Fehr & Peers, 2020.

The following corrections have been made to Table 4.15-7, Weekday AM and PM Peak-Hour 95thPercentile Queues – Project, on page 4.15-41 of the draft EIR (new text is underlined and deleted text is strikethrough).

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Table 4.15-7. Weekday AM and PM Peak-Hour 95th-Percentile Queues – Project Approach Lanes
Storage Distance
(feet)
2040 Future Baseline 2040 Project Buildout
Queue Length Queue Length

AM PM AM PM
I-280 Southbound Off-Ramp at Rollingwood Drive and Sneath Lane Left/through 1,200 105 215 118 230
Right 150 74 91 104 103
I-280 Southbound Off-Ramp at San Bruno Avenue*
Left 120 232 179 243 195
Left/through 840
221 102 227 120
Through/right 3,615
Right 80 68 68 74 79
I-280 Northbound Off-Ramp at San Bruno Avenue*
Left 230 93 405 225 419 415 240 426
Through/left/right 1,335 394 1,015 818 1,372 1,171 959 778 1,391 U.S. 101 Southbound Off-Ramp at San Bruno Avenue*
Left 280 115 87 65 88
Left/through 960 116 87 65 89
Right 280 26 138 26 138
U.S. 101 Northbound Off-Ramp at San Bruno Avenue*
Left/through 2,600 277 201 603 424 2,299 305 1,040 478
Right 560 324 335 961 498
I-380 Westbound Off-Ramp at El Camino Real*
Left 980 253 212 250 217
Right 980 331 668 359 637
I-380 Eastbound Off-Ramp at El Camino Real*
Left 520 157 294 234 378
Through/left/right 1,760 170 271 271 312
Right 330 160 252 242 273
U.S. 101 Southbound Off-Ramp at Airport Boulevard
Left 430 278 253 360 270
Through 720 282 307 368 318
U.S. 101 Southbound Off-Ramp at Produce Avenue
Left 620 208 182 272 226
Right 100 63 43 63 45
U.S. 101 Northbound Off-Ramp at South Airport Boulevard Left/Through 740 526 283 514 274
Right 740 46 39 47 39
Notes: Ramps analyzed using Synchro software.
“*” indicates additional analysis with Simtraffic software.

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Storage distance and queues in feet per lane. While some queues exceed available storage, project-related traffic does not contribute to the queues for these lanes.

Source: Fehr & Peers, 2021.

Section 4.17, Utilities and Service Systems
* The following revisions were made to the first bullet point on page 4.17-1 of the draft EIR (new text is underlined and deleted text is strikethrough).
• Water Supply Assessment for the Southline Specific Plan, South San Francisco District, California Water Service – Draft Final (WSA), prepared for the proposed project by EKI Environment & Water, Inc. in July December 2021 (Appendix 4.17-1); * Footnote 1 on page 4.17-2, Footnote 7 on page 4.17-3, Footnote 15 on page 4.17-11, Footnote 41 on page 4.17-23, Footnote 47 on page 4.17-30, Footnote 52 on page 4.17-31, Footnote 63 on page 4.17- 41, and Footnote 64 on page 4.17-45 of the draft EIR all have the following revisions (new text is underlined and deleted text is strikethrough).

EKI Environment & Water Inc. Water Supply Assessment for the Southline Specific Plan – DraftFinal, South San Francisco District California Water Service. July December 2021. * The following text has been added to the fourth paragraph of page 4.17-3 of the draft EIR under Regional (new text is underlined).

The SWRCB has stated that it intends to implement the Bay-Delta Plan Amendment on the Tuolumne River by the year 2022, assuming all required approvals are obtained by that time.

However, implementation of the Bay-Delta Plan Amendment is uncertain for multiple reasons, as summarized below (bullets are excerpted from a detailed discussion provided by SFPUC to water agencies in support of 2020 UWMP development).
* The following text has been added to Footnote 8 on page 4.17-4 of the draft EIR (new text is underlined).

Ibid. As of October 29, 2021, state regulators announced that the Voluntary Agreement negotiations process has ceased, with no agreement reached. San Francisco Chronicle, “California Drought: Key Talks Over Water Use Break Down, SF May Face Tighter Regulation,” available at https://www.sfchronicle.com/sf/article/California-drought-Key-talks-over-wateruse-16576132.php. Accessed December 3, 2021. * The following revisions have been made to the source lines for Tables 4.17-1, 4.17-2, 4.17-3, and

4.17-4 on pages 4.17-5, 4.17-6, 4.17-7, and 4.17-9 of the draft EIR (new text is underlined and deleted text is strikethrough).

Source: EKI Environment & Water Inc. Water Supply Assessment for the Southline Specific Plan—DraftFinal, South San Francisco District California Water Service. July December 2021. * The following text was removed from Table Note a in Tables 4.17-2, 4.17-3, and 4.17-4 on pages

4.17-6, 4.17-7, and 4.17-9 of the draft EIR (deleted text is strikethrough). a Future demand estimates are from Cal Water’s 2020 UWMP for the South San Francisco District (June 2021). As discussed in Section 4.17.3 below, the future demand estimates presented in the 2020 UWMP account for an estimated demand of 527 AFY associated with the City of South San Francisco Revisions to the Draft EIR
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project. The project’s WSA (Appendix 4.17-1) deducts 527 AFY from the future demand estimates for the South San Francisco District under the assumption that the project would comply with Cal Water’s pending Water Neutral Development Policy. However, as discussed in Section 4.17.4 below, as of the date of publish of this Draft EIR, Cal Water has not adopted a Water Neutral Development Policy. Therefore, this analysis conservatively does not deduct the project’s demand from future demand estimates for the South San Francisco District. * The following revisions were made to the last paragraph under Specific Plan Area, Including Phase 1 Site on page 4.17-11 of the draft EIR (new text is underlined and deleted text is strikethrough).

Based on available metered data, historical water use for the existing uses within the Specific Plan area, inclusive of the Phase 1 site, was approximately 11 13 AFY between 2018 2017 and 20202019.
* A period was added to the last sentence on page 4.17-11 under Regional in the draft EIR (new text is underlined).

To accommodate peak wet-weather flows, the WQCP is in the process of conducting facility improvements, which would include installation of a new storage basin to retain excess flows during wet-weather.
* The following revisions were made to the text under Senate Bill 610 and Southline Specific Plan Water Supply Assessment on pages 4.17-19 and 4.17-20 of the draft EIR (new text is underlined and deleted text is strikethrough). The deleted footnotes are Footnotes 39 and 40 in the draft EIR.

Senate Bill (SB) 610 requires cities and counties to confirm through a WSA that sufficient water supply sources are available before certain large developments are approved (see California Water Code Sections 10910 through 10915). The WSA for a project must be included in that project’s CEQA documentation. A WSA must be prepared if a project includes, among other things: (1) the equivalent demand of 500 residential units; or (2) a shopping center or business establishment that employs more than 1,000 persons or has a floor space of more than 500,000 square feet; or (3) a commercial office building that employees more than 1,000 persons or has a floor space of more than 250,000 square feet. The proposed project would result in a maximum of approximately 10,745 net new employees at the project site under the Office Scenario and would include an office/research and development (R&D) campus with a maximum anticipated building area of 2.8 million square feet, which would be greater than the 1,000 persons or 250,000 square feet of floor space associated with a business establishment or commercial office building use under SB 610. Therefore, the proposed project meets the definition of a “project” requiring a WSA pursuant to SB 610 (California Water Code Section 10910(a) and 10912(a)(3)).

California Water Code Section 10910(g)(1) provides that the governing body of the public water system shall submit a WSA to the requesting city or county not later than 90 days from the date on which the request was received. Pursuant to California Water Code Section 10910(c)(1), the City requested a WSA for the proposed project from Cal Water in April 2020. Cal Water provided a draft final WSA to the City and project applicant in December 2021September 2020 and a revised draft WSA in December 2020. In March 2021, Cal Water informed the City and project applicant that Cal Water would be revising the WSA again to include updated language regarding the reliability of wholesale water supplies and provided another draft WSA to the City and project applicant in July 2021. This Draft EIR analysis is based on the July 2021 WSA, which is included in Appendix 4.17-1. Notwithstanding the passage of the statutory 90-day period to City of South San Francisco Revisions to the Draft EIR
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complete a WSA, Cal Water has stated that it intends to finalize the WSA following preparation of a Water Neutral Development Policy for the South San Francisco District, which is anticipated to occur by the end of 2021.1 The final WSA is anticipated to be included in the Final EIR, together with a Water Neutral Development Policy, if it has been adopted, as an Appendix B.

Based on information provided by Cal Water, the final WSA conclusions are anticipated to remain consistent as stated in the July 2021 WSA. The EIR analysis is based on the December 2021 WSA.

The WSA states that in July 2021, Cal Water began development of a Water Neutral Development Policy for its three Peninsula Districts, which share the same SFPUC supply allocation. The stated purpose of the Water Neutral Development Policy is to ensure that there is enough water at all times to meet the basic needs of the community and increase drought resiliency, among other things. The WSA describes the potential Water Neutral Development Policy based on what Cal Water anticipates will be included in the policy and assumes that the project will be required to comply with a final adopted policy.2 According to the WSA:

As currently drafted, Tthe Water Neutral Development Policy [will require] any new residential, commercial, or industrial development within the South San Francisco District that is expected to use 100 AFY or more inexceed a specified amount of new demand to offset its net increase in water demand. The net increase in water demand associated with any new development [will be] calculated as the expected total water use due to the proposed development and/or expansion, minus the amount of existing water use, onsite credits (if available), and/or alternative sources of water supply. Alternative sources may include, but are not limited to: (1) reused graywater, (2) reused blackwater, (3) reused mixed gray/blackwater, (4) captured rainwater/stormwater, and (5) air conditioning condensate.

The offset amount [will be] determined using a detailed projection of total annual water demand resulting from the proposed development, excluding temporary demands such as those required for landscape establishment. The applicant may choose to comply with the defined offset amount by any combination of the following activities: (1) paying to the South San Francisco District the required offset amount calculated according to the offset costs table included in the policy, and/or (2) conducting offsite conservationother activities as defined in the policy. , or (3) conducting other pre-approved demand offset projects. … Cal Water will verify compliance with this Water Neutral Development Policy (i.e., ensure that all payments for offsets and/or conservation offset measures are completed) prior to establishing a water service connection. 1 Personal communication with Michael Hurley, Water Resources Manager, Cal Water, August 6, 2021. 2 Page 11 of the WSA (Appendix 4.17-1) states: “In July 2021, prior to the date of publish of this WSA, Cal Water adopted a Water Neutral Development Policy (or Policy) for its three Peninsula Districts, which share the same SFPUC supply allocation. A copy of this Policy is provided in Appendix B.” However, as of the date of publish of this Draft EIR, Cal Water has not adopted a Water Neutral Development Policy, and the policy is not included in Appendix B of the July 2021 draft WSA.

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* The following row was deleted from Table 4.17-5, Proposed Water, Wastewater, and Storm Drain Improvements, on page 4.17-32 in the draft EIR (deleted text is strikethrough). 24-inch and 27-inch
sewer main (South San
Francisco)
Tanforan Avenue and Shaw
Road
Upsize mains in Tanforan Avenue and
Shaw Road that flow to existing pump
station.
* The following text was deleted from the third paragraph under Wastewater Facilities on page 4.17- 35 of the draft EIR (deleted text is strikethrough).

As shown in Table 4.17-3, p. 4.17-7, and Figure 4.17-2, p. 4.17-14, the proposed project would upgrade the 24-inch and 27-inch sewer main in Tanforan Avenue and Shaw Road that flows to an existing pump station; relocate the existing 24-inch sewer main east to avoid conflict a with the Huntington Avenue intersection improvements; relocate the existing 8-inch sewer main at Dollar Avenue to connect to the proposed development south to Tanforan Avenue; upsize the 8-inch sewer main in the northerly portion of South Maple Avenue and the main that runs from South Maple Avenue through an easement to Lowrie Avenue; and relocate all existing interior sewer connections by installing new service connections to each building within the Specific Plan area.
* The following text was deleted from the paragraph under Wastewater Facilities on page 4.17-39 of the draft EIR (deleted text is strikethrough).

As noted in the project analysis above, the Sanitary Sewer Technical Study, included as Appendix 4.17-3 of this EIR, evaluates the sufficiency of the local wastewater conveyance system to serve the project’s estimated wastewater flow, including Phase 1, and determines that the sewer demands of the proposed project would still be within the anticipated SSMP levels for future demands for the project area. In addition, the wastewater facility improvements to upgrade the 24-inch and 27-inch sewer main in Tanforan Avenue and Shaw Road, as shown in Figure 4.17-2, p. 4.17-14, would be completed as part of Phase 1. All other improvements to wastewater facilities would be completed during subsequent phases of the project. Therefore, for the reasons stated above in the project analysis, Phase 1 would not require or result in the relocation or construction of new or expanded wastewater facilities beyond the facilities already included in the Project Description and evaluated in this EIR, the construction or relocation of which could cause significant environmental effects. This impact would be less than significant.

No mitigation is required.
* The following revisions were made to the first sentence in the second paragraph under Projected Water Demand on page 4.17-41 of the draft EIR (new text is underlined and deleted text is strikethrough).

As shown in Table 4.17-6, below, the proposed project, inclusive of Phase 1, would require up to approximately 557 555 AFY of water for each year through 2045 based on the demand factors described above.

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* The following revisions were made to Table 4.17-6, Anticipated Water Demand for Project Buildout (Life Sciences Scenario), Including Phase 1, on page 4.17-42 of the draft EIR (new text is underlined and deleted text is strikethrough).

Table 4.17-6. Anticipated Water Demand for Project Buildout (Life Sciences Scenario), Including Phase 1
Water Use Area (sf)
Demand
Factor
(gpd/sf)
Total Water Demand (AFY)
2025 2030 2035 2040 2045
R&D 1,936,850 0.21 456 456 456 456 456
Amenity Building
Restaurant/ Dining 16,400 0.47 8.7 8.7 8.7 8.7 8.7
Cafeteria 9,000 0.80 8.1 8.1 8.1 8.1 8.1
Fitness Center 49,000 0.75 41 41 41 41 41
Auditorium/Other 13,800 0.10 1.5 1.5 1.5 1.5 1.5
Irrigation 260,400 0.070 20 20 20 20 20
Distribution System
Losses1a
-- -- 33 33 33 33 33
Existing Site Demand2b -- -- -1311 -1311 -1311 -1311 -1311 Total Annual Water Demand3c 557555 557555 557555 557555 557555 Source: EKI Environment & Water Inc. Water Supply Assessment for the Southline Specific Plan—DraftFinal, South San Francisco District California Water Service. July December 2021. sf = square feet; gpd = gallons per day; AFY = acre-feet per year 1a Estimated distribution system water loss is calculated using the 2019 DWR Water Audit Report percent water loss (i.e., 5.8% of project demands), and includes both real and apparent losses. 2b Existing demands are subtracted from total projected water demands to show the incremental increase in demands associated with the project. Existing demands are estimated as the average of three years of water use at the Specific Plan area based on available metered data (2017−2019). 3c Total may not sum due to rounding.
* The following revisions were made to the first paragraph under Projected Water Supply on page

4.17-43 of the draft EIR (new text is underlined and deleted text is strikethrough).

The demand estimate in the 2020 UWMP includes an estimated demand of 527 AFY for the project, including Phase 1. As shown in Table 4.17-6, the project’s estimated demand at full buildout would be 557 555 AFY. Although this is a conservative estimate, as discussed above, the estimated demand in the project’s WSA exceeds the assumed project demand in the 2020 UWMP, and excess supplies are not forecasted during normal year conditions. As discussed in Section 4.17-3, Cal Water has stated that it intends to adopt a Water Neutral Development Policyin the coming months, which would require any new residential, commercial, or industrial development within the South San Francisco District that is expected to use 100 AFY or more inexceed a specified amount of new demand to offset its net increase in water demand. * The following revision was made to a sentence in the third paragraph under Projected Water Supply on page 4.17-32 of the draft EIR (new text is underlined and deleted text is strikethrough).

The project’s projected increased demand of up to 557 555 AFY (up to 527 AFY with implementation of Mitigation Measure UTIL-1) would exacerbate existing projected shortages during dry year conditions and assuming implementation of the Bay-Delta Plan Amendment.

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* The following revisions were made to Footnote 65 on page 4.17-45 of the draft EIR (new text is underlined and deleted text is strikethrough).

For office use: 612,715 SF x 0.13 gpd/sf = 79,563 gpd (89 AFY). 89 AFY + 59.3 AFY (amenity building demand, Table 4.17.6) +20 AFY (irrigation demand, Table 4.17.6) + 33 AFY (distribution system loss, Table 4.17.6) – 11 13 AFY (existing site demand, Table 4.17.6) = 190.3188.3 AFY. Note that irrigation demand and distribution system loss estimates are for the project at buildout, and therefore applying these estimates to Phase 1 alone is conservative. * The following corrections were made to two sentences in the second paragraph under Construction on pages 4.17-48 and 4.17-49 of the draft EIR (new text is underlined and deleted text is strikethrough).

All existing development onin the Specific Plan area would be removed during Phase 1, totaling approximately 343,800 square feet of building demolition.

Any demolition and construction debris remaining after recycling would then be transported to the Corinda Los Trancos (Ox Mountain) Sanitary Landfill or the Newby Island Sanitary Landfill. * The following revision was made to a sentence in the second paragraph under Operation on page

4.17-49 of the draft EIR (new text is underlined and deleted text is strikethrough).

As described in Approach to Analysis, above, the Office Scenario is evaluated here as the worst caseworst-case scenario, with a maximum of 10,745 net new employees.

Chapter 5, Alternatives
* The second and third paragraphs under Section 5.1, Introduction, on page 5-1 of the draft EIR were revised as follows (new text is underlined and deleted text is strikethrough).

Nine Ten alternatives to the project were considered, including the required No Project Alternative. To determine which of the alternatives should be evaluated in this EIR, each alternative was screened to determine whether it would meet most of the objectives of the project, reduce any of the significant impacts identified in the EIR, and be potentially feasible.

This chapter provides a description of the six alternatives considered but rejected, followed by an analysis of the No Project Alternative (Alternative A) and twothree additional alternatives selected for evaluation: the No Intersection Alternative (Alternative B) and), the Reduced Project Alternative (Alternative C), and the Reduced Underground Parking Alternative (Alternative D).
* The following text was added to Footnote 3 on page 5-12 of the draft EIR (new text is underlined).

City of South San Francisco, 2021. Shape SSF Preferred Alternative. Available:
https://shapessf.com/ preferredalternative/. Accessed: September 7, 2021; see also SSF public review draft of the 2040 General Plan, dated February 2022, available:
https://shapessf.com/wpcontent/uploads/2022/03/SSFGPU_PublicDraft2022_03_Ammended.pdf. Accessed April 21, 2022.

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* In Section 5.4, Alternatives Selected for Further Review, a fourth bullet point reading “Alternative D— Reduced Underground Parking Alternative” was added to the bullet list on page 5-14 and the following text was added to the first paragraph on page 5-15 of the draft EIR (new text is underlined).

Under Alternative D— Reduced Underground Parking Alternative, the Specific Plan Area would incorporate the property located at 80 Tanforan Avenue. The existing building at 80 Tanforan Avenue would be demolished and a six-level above-grade parking structure (Parking Structure D) would be constructed, eliminating all subterranean parking south of Southline Avenue, which was included in the proposed project.
* On page 5-15 of the draft EIR, the reference to Table 5-4, p. 5-43 was revised to Table 5-19, p. 5-74. * Table 5-1, Comparison of the Proposed Project Features to the Alternatives, on pages 5-16 and 5-17 was revised as follows (new text is underlined and deleted text is strikethrough).

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Table 5-1. Comparison of Proposed Project Features to the Alternatives Proposed Projecta
Alternative A- No
Project
Alternative BNo IntersectionaAlternative C –
Reduced Project
Alternative DReduced
Underground
Parkingf
Total Allowable
Building Area
(Office, R&D, and
Amenity) (sf)b
2,800,000 Same as existing 2,800,000 1,404,880 2,800,000 Number of New
Buildings
Nine buildings, one
above-grade parking
structure (Parking
Structure C)
None (existing
buildings to remain)
Nine buildings, one
above-grade parking
structure (Parking
Structure C)
Nine buildings, one
above-grade parking
structure (Parking
Structure C)
Nine buildings, two
above-grade parking
structures (Parking
Structure C and
Parking Structure D)
Building Heights Four stories (60 feet
above grade) to seven
stories (115 feet
above grade)
Same as existing Four stories (60 feet
above grade) to seven
stories (115 feet
above grade)
Four stories (80 feet
above grade)
Three stories (60 feet
above grade) to seven
stories (115 feet
above grade)
Total Building
Footprint (sf) and
Building Lot
Coverage
543,315 (49 percent) Same as existing 543,315 (49 percent) 543,315 (49 percent) 605,315 (50 percent) Total Impervious
Surface Area
Including Buildings
and Hardscape (sf)
897,691 Same as existing 897,691 897,691 987,447
Total Area of Ground
Disturbance (sf)
1,435,737 None 1,359,837 1,435,737 1,523,121
Total Excavation
volume (cy)c
688,400 None 682,800 189,800 435,200
Maximum Depth of
Excavation (feet
below grade surface)
31 None 31 18 27.5
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Proposed Projecta
Alternative A- No
Project
Alternative BNo IntersectionaAlternative C –
Reduced Project
Alternative DReduced
Underground
Parkingf
Building Area to be
Demolished (sf)
343,800 (all existing
buildings in Specific
Plan area)
None 343,800 (all existing
buildings in Specific
Plan area)
343,800 (all existing
buildings in Specific
Plan area)
386,184 (all existing
buildings in Specific
Plan area including 80
Tanforan)
Trees to be Removed 162 (all existing trees
in Specific Plan area)d
None 162 (all existing trees
in Specific Plan area)d
162 (all existing trees
in Specific Plan area)d
175d
Trees to be Planted 581e None 581e 581e 591 e
a Where feature differs between the Office Scenario and Life Sciences Scenario, the greater or more impactful value is presented. Refer to Table 3-2 in Chapter 3, Project Description, of this EIR for additional detail. b sf = square feet
c cy = cubic yards; volumes are inclusive of off-site improvement areas. d For the proposed project, Alternative C, and Alternative D, up to 19 additional tree removals in the off-site improvement areas (within both the cities of South San Francisco and San Bruno) may be required; such removals would be required to comply with any applicable local regulations. Alternative D would also require the removal of up to 13 additional trees on the 80 Tanforan Avenue property (in the City of South San Francisco). For Alternative B, no tree removals in San Bruno would be required.
e For the proposed project, Alternative C, and Alternative CD, additional trees may be planted in the off-site improvement areas, subject to each city’s tree replacement requirements (South San Francisco Municipal Code Chapter 13.30, San Bruno Municipal Code Chapters 8.24 and 8.25). For Alternative B, additional trees may be planted in the off-site improvement areas in South San Francisco, but no trees would be planted in San Bruno. f Under Alternative D, the Phase 1 Precise Plan would include a total square footage of 684,710 sf compared to 700,915 sf under the proposed project. Consistent with the proposed project, under Alternative D, the Specific Plan would allow a total buildout of 2.8 million square feet. The remaining development allocation under Alternative D would be consistent with Specific Plan permitted land uses and may not exceed 2.8 million square feet. Although the specific land use mix for future phases of development is not known at this time, all subsequent development within the Specific Plan area requires approval of project-level Precise Plan approval by the City, which is a discretionary approval requiring consistency with the Specific Plan and compliance with CEQA.

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* References to Table 5-5, p. 5-47 on pages 5-19, 5-26, and 5-34 of the draft EIR were revised to refer to Table 5-20, p. 5-75.
* The third paragraph in Section 5.7.1, Description, on page 5-29 of the draft EIR was revised (new text is underlined and deleted text is strikethrough).

Under Alternative C, future phases of the project would be allowed to develop up to approximately 955,1201,404,880 square feet of new office or R&D uses could be developed in the Specific Plan area, in comparison to the up to 2,800,000 square feet of uses that would be developed under the proposed project (Office Scenario). * Section 5.8, Alternative D – Reduced Underground Parking Alternative, was added to Chapter 5. The text of Section 5.8 is provided below (new text is underlined).

Section 5.8, Alternative D – Reduced Underground Parking Alternative Section 5.8.1, Description
Alternative D— Reduced Underground Parking Alternative would expand the Specific Plan area to incorporate the property located at 80 Tanforan Avenue while eliminating all subterranean parking associated with Phase 1 and constructing an above-ground parking structure. At the time of publication of the Draft EIR and close of the public comment period, the applicant did not have site control over the 80 Tanforan Avenue parcel. As such, alternative site plan layouts incorporating that area had not been explored. Since that time, the applicant acquired rights to purchase 80 Tanforan Avenue, which enabled consideration of Alternative D.

Under Alternative D, the existing industrial warehouse building at 80 Tanforan Avenue, which was constructed in 1986, would be demolished and a parking structure (Parking Structure D) with six levels of above-grade parking would be constructed. With the incorporation of Parking Structure D, the two levels of subterranean parking associated with buildout of Phase 1 under the proposed project would be eliminated, resulting in a reduction of 253,200 cubic yards (cy) of excavation volume. That is, under Alternative D, none of the subterranean development south of Southline Avenue that is proposed under the project would be constructed. In addition, Alternative D would eliminate development of the Parking Structure C located north of Southline Avenue during the Phase 1 project; development of Parking Structure C would still occur under the project buildout condition. Lastly Alternative D would result in slight revisions in the square footages and uses of the Phase 1 Buildings 1, 7, and 2 (amenities building).

Alternative D was selected for evaluation based on its potential to reduce impacts related to construction air quality, construction toxic contaminants (TACs), and construction noise. Figure 5-4 on the following page provides a conceptual site plan of Alternative D at full project buildout under the Life Sciences Scenario. Figure 5-5 on the following page provides a conceptual site plan of Alternative D at full project buildout under the Office Scenario.

In general, Alternative D would construct the same land use program for both Phase 1 and the proposed project. The same Specific Plan and zoning designations would apply to this alternative. Alternative D would implement the same design features, sustainability features, and open space and pedestrian connections within the Specific Plan area as the proposed project, with the exception that the open space proposed as part of the Tanforan Community Parklet would be expanded by approximately 11,545 square feet compared with the proposed City of South San Francisco Revisions to the Draft EIR
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project. However, under Alternative D, the Specific Plan area would increase by approximately

2.1 acres for a total area of approximately 28.6 acres.

SOUTHLINE PLANNING COMMISSION PUBLIC HEARING 11.04.21
0’ 30’ 60’ 120’
SCALE: 1” = 120’-0”
0’ 30’ 60’ 120’
South San Francisco City Limit
San Bruno City Limit

CONCEPTUAL SITE PLAN - LIFE SCIENCES SCENARIO
Source: DES Architects/Engineers and Lane Partners, 2022.

Graphics … 104077 (3-9-2022) JC
Figure 5-4
Reduced Underground Parking Alternative—Life Sciences Scenario SOUTHLINE PLANNING COMMISSION PUBLIC HEARING 11.04.21
0’ 30’ 60’ 120’
SCALE: 1” = 120’-0”
0’ 30’ 60’ 120’
South San Francisco City Limit
San Bruno City Limit

CONCEPTUAL SITE PLAN - OFFICE SCENARIO
Source: DES Architects/Engineers and Lane Partners, 2022.

Graphics … 104077 (3-9-2022) JC
Figure 5-5
Reduced Underground Parking Alternative—Office Scenario City of South San Francisco Revisions to the Draft EIR
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As compared to the proposed project, Alternative D would revise the square footages of Buildings 1, 7, and 2 (amenities building); eliminate all subterranean parking associated with buildout of Phase 1; construct a new above-grade parking structure (Parking Structure D) on the 80 Tanforan Avenue property; and eliminate development of the Parking Structure C located north of Southline Avenue during the Phase 1 project (development of Parking Structure C would still occur under the project buildout condition). In addition, the amenities building would be reduced from four stories to three stories, while the total building area for Buildings 1 and 7 would increase by approximately 2,285 sf from approximately 612,715 sf to approximately 615,000 sf. The overall Phase 1 square footage would decrease by 16,205 sf from 700,915 sf to 684,710 sf due to the decrease in height of the amenities building (see Table 5-4, below). Overall, Alternative D includes the following approximate square footage changes: a 2,300 sf increase in office space, a 4,600 sf decrease in public restaurant/retail space, a 13,900 sf decrease in tenant amenity space, and a 11,545 sf increase in open space.

Table 5-4. Phase 1 Precise Plan Square Footage under Alternative D Building
1 (sf)
Building 2
(Amenities
Building)
(sf)
Building
7 (sf)
Total Phase
1 (sf)
Phase 1 (Proposed Project) 317,495 88,200 295,220 700,915 Phase 1 (Reduced Underground
Parking Alternative)
318,380 69,710 296,620 684,710
Change in Square Footage 885 -18,490 1,400 -16,205
sf = square feet
Table 5-5. Phase 1 Precise Plan Land Use Square Footage Summary under Alternative D Land Use Proposed Project (sf)
Reduced Underground
Parking Alternative (sf)
Office/R&D 612,715 615,000
Ground Floor
Restaurant/Retail
16,400 11,786
Food/Beverage (Private)a 9,000 5,027
Fitness Center (Private)a 49,000 27,949
Otherb 13,800 24,948
Total Active Land Uses 700,915 684,710
Total Open Spacec 25,700 37,245
Notes:
a The fitness center and food/beverage uses would only be available for use by the tenants of the proposed buildings under Phase 1, and not the general public.
b Other land uses including a community room, bike repair kiosk, lobby areas, facilities management office, building circulation (e.g., stairwells), and associated back of house areas. c Tanforan Community Parklet, which would be constructed during Phase 1, would be expanded by approximately 11,545 sf with incorporation of the 80 Tanforan Avenue parcel under Alternative D.

As detailed in the Draft EIR, the proposed project would allow for vehicle parking to be provided at a ratio of a maximum of 2.2 spaces per 1,000 square feet of commercial use. However, after City of South San Francisco Revisions to the Draft EIR
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release of the Draft EIR, the Specific Plan parking development standards were reduced to 1.65 striped spaces per 1,000 square feet of commercial use, with an option to incorporate valet parking up to 2.0 spaces per 1,000 square feet of commercial use. Alternative D would adhere to the reduced allowable parking Specific Plan development standards. Under Alternative D, Phase 1 would include the construction of a total of approximately 1,095 parking spaces, including 972 parking spaces in Parking Structure D, and 103 above-grade spaces in Building 2. Approximately 20 additional surface parking spaces would be located south of Southline Avenue. The long, eastern portion of the “L-shaped” campus Parking Structure C would no longer be developed as part of Phase 1, but would be constructed in future phases. In addition, unlike the proposed project, Alternative D would not include any below-grade parking levels associated with buildout of Phase 1. Phase 1 under Alternative D would provide approximately 1,095 parking spaces at or above grade in comparison to the 1,379 below-grade total parking spaces that would be provided in Phase 1 under the proposed project. Access to Parking Structure D would be provided from Southline Avenue, the same as the proposed project, but would lead to the above-ground parking structure, rather than the below-grade parking proposed under the project. Overall, reduced amounts of subterranean development would occur under Alternative D, and the total lot coverage would increase in comparison with the proposed project with the addition of the 80 Tanforan Avenue property. The total amount of impervious surfaces within the Specific Plan area would increase by approximately 89,756 sf with incorporation of the 80 Tanforan Avenue property, from approximately 897,691 sf under the proposed project to 987,447 sf under Alternative D due to the increase in the size of the Specific Plan area through incorporation of the 80 Tanforan Avenue, which is presently developed with an existing industrial warehouse building and surface parking. However, under the Alternative D proposed landscape improvements, the amount of impervious surfaces within the 80 Tanforan Avenue property would be comparable to existing conditions on the property (i.e., approximately 90 percent impervious surfaces). Overall, the amount of impervious surface area in the Specific Plan area would decrease from approximately 93 percent under existing conditions to approximately 79 percent under proposed conditions based on incorporation of proposed landscape improvements.

All other features of Alternative D would be the same as, or substantially similar to, those of the proposed project, including the potential office or R&D use, open space improvements, building design, TDM program, sustainability features, infrastructure improvements, and the proposed circulation and transportation infrastructure improvements, including the connection of Sneath Lane and Southline Avenue, the extension of Centennial Way Trail, and access improvements to the BART Station, consistent with the adopted policies of the City, City of San Bruno, C/CAG, BART, and MTC.

The construction schedule for Alternative D would be the same duration as the proposed project. In addition, the construction activities for Alternative D would be similar to the proposed project, however, there would be a few key differences. Under Alternative D, the construction of Parking Structure C would be included as part of buildout of future phases of the project rather than Phase 1. In addition, Alternative D would require substantially less subsurface disturbance overall compared to the proposed project because no subterranean parking would be provided in Phase 1, resulting in a reduction of approximately 253,200 cubic yards (cy) of excavation volume and approximately 14,000 haul truck trips (one-way). Overall, Alternative D would result in a substantially reduced construction program.

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Table 5-6 below provides estimates of the amount of new development that could be constructed at buildout under Alternative D.

Table 5-6. Projected 2030 Development under the Reduced Underground Parking Alternative Square footage (sf)
Existing Building Area Total 386,184
Industrial/Warehouse 381,733
Office 4,451
Existing to be Removed
Phase 1 (2024) 386,184
Remaining Specific Plan Buildout 0
Total to be Removed 386,184
Total Existing to Remain 0
Proposed New Construction
Phase 1 (2024) 684,710
Remaining Specific Plan Buildout 2,115,290
Total New Construction Proposed 2,800,000
Like the proposed project, Alternative D would require certain discretionary approvals for implementation, including: Specific Plan adoption, general plan amendments, zoning map and text amendments, TDM plan approval, design review, development agreement, Transportation Demand Management Plan, and precise plan(s) approval. Alternative D would also require standard City engineering, building, fire, and protected tree removal permits, along with other agency approvals (e.g., City of San Bruno, BART, Bay Area Regional Water Quality Control Board, BAAQMD, City/County Association of Governments Airport Land Use Commission, and Federal Aviation Administration).

Section 5.8.2, Ability to Meet Project Objectives
Table 5-20, p. 5-78 provides a summary of the ability of this alternative to meet the objectives of the proposed project. As shown in the table, Alternative D— Reduced Underground Parking would meet the underlying purpose of the project to create a state-of-the-art, transit-oriented commercial campus, including professional offices, R&D (including life science) uses, and supporting amenities (e.g., retail, fitness, restaurants, etc.) in proximity to BART and Caltrain stations. Alternative D would also fully meet all of the project objectives, as it would allow the same land use program and same extent of office/R&D development in the same transitoriented location, while avoiding the need to provide underground parking in Phase 1.

Alternative D would also implement the off-site improvements proposed under the project, consistent with the project objective to promote the City’s ongoing development of transitaccessible corridors with high-quality development. For the same reasons, Alternative D would meet General Plan policies that encourage redevelopment and infrastructure improvements in the Lindenville Planning Sub-Area and would optimize high-quality transit-accessible development in the Specific Plan area, which is uniquely located within the Lindenville Planning Sub-Area proximate to high-quality public transit, including the San Bruno BART station and the San Bruno Caltrain station. Additionally, Alternative D would result in increased public open space with the expansion of the Tanforan Community Parklet.

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Section 5.8.3, Impacts
The impact analysis below evaluates the potential environmental impacts of Alternative D and compares them to the impacts of the proposed project for each of the topics evaluated in Chapter 4, Environmental Setting, Impacts, and Mitigation, of this EIR. This analysis includes project impacts that were found to be significant and unavoidable, less than significant with mitigation, and (for informational purposes) less than significant with no mitigation required.

This analysis does not evaluate topics for which the project was found to have no impact, as discussed in Section 4.18, Impacts Found Not to be Significant, of this EIR. Cumulative impacts are discussed for the cumulative impacts that were found to be significant and unavoidable for the project or Phase 1 (i.e., Impacts C-AQ-2, C-AQ-3, C-NOI-1, and C-TR-3d). Phase 1 impacts are discussed for the Phase 1 impacts that were found to be significant and unavoidable (Impact AQ2b and Impact NOI-1a). Unless otherwise noted, the same mitigation measures identified for impact topics for the proposed project would apply to any impacts under Alternative D.

Section 5.8.3.1, Air Quality
Consistency with Applicable Air Quality Plan
The same project goals, policies, and development standards identified in 2017 Clean Air Plan would apply to Alternative D. Alternative D would generally develop the same mix of land uses as the proposed project, albeit with less subterranean parking and slightly more open space area within Tanforan Community Parklet. Alternative D would include the same sustainability features as the project. As such, Alternative D would support the 2017 Clean Air Plan and would not conflict with its implementation. This impact would be the same as that of the project and would be less than significant. No mitigation would be required.

Construction Emissions
• Specific Plan
Like the proposed project, because the timing and intensity of future development projects are not known at this time, the precise effects of construction activities associated with buildout of the Specific Plan area under Alternative D cannot be accurately quantified. Alternative D would result in a substantially reduced construction program due to the elimination of the subterranean parking garages under Phase 1, which would reduce the overall quantity of construction emissions. However, this alternative would not eliminate the project’s significant and unavoidable construction impacts, which are due to the uncertainty around future development that could occur under the Specific Plan. Thus, Mitigation Measures AQ-1 through AQ-6 would continue to apply to Alternative D. Project-level and cumulative-level impacts associated with construction criteria air pollutant emissions (Impact AQ-2a and Impact C-AQ-2) would remain significant and unavoidable under this alternative because, similar to the project, it cannot be concluded that offset programs (as required by Mitigation Measure AQ-6) would always be available in the future at the time and in the amount needed for any given future development under the Specific Plan. However, construction emission impacts would be reduced compared to the proposed project.

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Phase 1
Construction of Phase 1 under Alternative D would differ compared to the proposed project, as stated in Section 5.8.1, Description. The following key differences would affect the amount of construction emissions.
• The long, eastern portion of the “L-shaped” campus Parking Structure C would no longer be developed as part of Phase 1, but would be constructed with buildout of future phases • The two levels of below-grade parking under Phase 1 would no longer be developed • The existing building at 80 Tanforan Avenue would be demolished • Parking Structure D with six levels of above-grade parking would be constructed Construction emissions of Phase 1 under Alternative D were quantified using the same methodology used for the proposed project. Assumptions regarding construction activities, equipment, and vehicles were updated based on the development characteristics of Alternative D. Construction dates were also updated based on the status of the EIR and anticipated entitlement schedule at the time the Alternative D analysis was conducted. Estimated unmitigated criteria pollutant emissions are presented in Table 5-7, p. 5-44.

Table 5-7. Estimated Unmitigated Criteria Pollutant Average Daily Emissions from Construction of Phase 1 under Alternative D (pounds/day) Construction Year ROG NOx CO
PM10 PM2.5
Dust Exhaust Dust Exhaust
2022 9 95 54 17 4 5 3
2023 17 90 100 16 4 6 4
2024 37 18 26 12 1 3 1
BAAQMD Threshold 54 54 None BMPs 82 BMPs 54
Exceed Threshold? No Yes N/A — No — No
Source: See Appendix 4.2-1 for construction modeling outputs.

Notes:

Exceedances of BAAQMD thresholds are bolded and underlined.

ROG = reactive organic gases; NOX = nitrogen oxide; CO = carbon monoxide; PM10 = particulate matter no more than 10 microns in diameter; PM2.5 = particulate matter no more than 2.5 microns in diameter; BAAQMD = Bay Area Air Quality Management District; BMPs = best management practices.

As shown in Table 5-7, construction of Phase 1 would generate NOx emissions in excess of BAAQMD’s significance threshold (a maximum of 95 pounds per day) during two years of construction and result in a potentially significant air quality impact. This impact would be reduced by approximately 25% compared to the impact for Phase 1 under the proposed project, which would also result in NOx emissions in excess of BAAQMD’s significance threshold (a maximum of 127 pounds per day) during two years of construction. Thus, Mitigation Measure AQ-2 requiring the use of at least Tier 4 final engines on construction equipment would continue to apply to Alternative D. Estimated mitigated criteria pollutant emissions are presented in Table 5-8, p. 5-44.

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Table 5-8. Estimated Mitigated Criteria Pollutant Average Daily Emissions from Construction of Phase 1 under Alternative D (pounds/day)
Construction Year ROG NOx CO
PM10 PM2.5
Dust Exhaust Dust Exhaust
2022 3 30 56 12 < 1 3 < 1
2023 8 39 88 11 < 1 4 < 1
2024 36 11 25 12 < 1 3 < 1
BAAQMD Threshold 54 54 None BMPs 82 BMPs 54
Exceed Threshold? No No N/A — No — No
Source: See Appendix 4.2-1 for construction modeling outputs.

Notes:

ROG = reactive organic gases; NOX = nitrogen oxide; CO = carbon monoxide; PM10 = particulate matter no more than 10 microns in diameter; PM2.5 = particulate matter no more than 2.5 microns in diameter; BAAQMD = Bay Area Air Quality Management District; BMPs = best management practices.

As shown in Table 5-8, with mitigation, construction of Phase 1, with a maximum of 39 pounds per day, would not generate emissions in excess of BAAQMD’s significance threshold. This is approximately 17% less than the mitigated impact for Phase 1 under the proposed project (a maximum of 47 pounds per day). Lastly, Mitigation Measure AQ-1, required for Phase 1 under the proposed project to comply with BAAQMD’s CEQA Guidelines regarding fugitive dust BMPs, would also apply to Phase 1 under Alternative D. Therefore, Phase 1-level impacts associated with construction criteria air pollutant emissions (Impact AQ-2a and Impact C-AQ-2) would be less than significant with mitigation under this alternative, and reduced compared to the proposed project.

Operation Emissions
Specific Plan
Operation of the Specific Plan, including Phase 1, under Alternative D would differ compared to the proposed project, as stated in Section 5.8.1, Description. The following key differences would affect the amount of operation emissions.
• Area and energy source emissions for Phase 1 would decrease slightly due to adjustments in land uses.
• Stationary source emissions would decrease as the emergency diesel generators associated with Phase 1 would be reduced from five to four (i.e., removal of generator #3 listed in Table 4.2-5 in Section 4.2, Air Quality) and would use Tier 4 engines instead of higher emission-intensity standard model engines. Generator #3 would not be needed for Alternative D because ventilation fans would not be required for subterranean parking in Phase 1 given that all subterranean parking would be eliminated under the Alternative D Phase 1 development.
• Mobile source emissions and vehicle miles travelled would be comparable or slightly decrease as the expected daily traffic would decrease, as discussed in 5.8.3.14, Transportation and Circulation.

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Operation emissions under Alternative D were quantified using the same methodology used for the proposed project except for the use of Tier 4 engine emission factors.3 Table 5-8, p. 5-45, summarizes daily area-, energy-, mobile-, and stationary-source emissions generated under existing conditions (2018) and 2030 conditions with and without the Specific Plan under Alternative D. To evaluate the magnitude of the change in the air quality environment due to implementation of the Specific Plan, emissions under Specific Plan buildout in 2030 are compared to 2030 emissions without the Specific Plan.

Table 5-9. Estimated Average Daily Unmitigated Operational Emissions from the Specific Plan under Alternative D (pounds/day)
Condition/Source ROG NOX CO PM10 PM2.5
Existing (2018)
Area Sources 8 < 1 < 1 < 1 < 1
Energy Sources < 1 < 1 < 1 < 1 < 1
Mobile Sources 176 268 1,369 300 83
Stationary Sourcesa — — — — —
Total Existingb 184 268 1,369 300 83
2030 Without Specific Plan
Area Sources 8 < 1 < 1 < 1 < 1
Energy Sources < 1 < 1 < 1 < 1 < 1
Mobile Sources 91 117 797 298 81
Stationary Sourcesa — — — — —
Total 2030 Without Projectb 99 117 797 298 81
2030 With Specific Plan
Area Sources 68 < 1 1 < 1 < 1
Energy Sources 2 14 12 1 1
Mobile Sources 172 222 1,512 566 153
Stationary Sourcesc, d 60 30 154 1 1
Total 2030 With Projectb 302 266 1,679 569 156
Net Increase with Specific Plan
2030 With Project v. 2030 Without Projectb 203 149 882 270 75 Thresholds 54 54 — 82 54
Source: See Appendix 4.2-1 for operations modeling outputs.

Notes:
a. No stationary sources were identified as part of existing conditions. b. Values may not add up because of rounding.
c. Does not include emissions from generators under future Precise Plans (other than Phase 1), which are unknown at this time. Conservatively assumes the full load testing scenario for Phase 1 shown in Table 4.2- 5, p. 4.2-31.
d. Conservatively assumes the full load testing scenario for Phase 1 shown in Table 4.2-5, p. 4.2-31 As shown in Table 5-9, p. 5-46, the net increase in emissions with the Specific Plan under Alternative D would exceed BAAQMD’s project-level thresholds, similar to the proposed project. 3 DieselNet. 2022. United States: Nonroad Diesel Engines. Available:
https://dieselnet.com/standards/us/nonroad.php. Accessed: April 2022.

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However, Alternative D would result in less ROG, NOx, and PM emissions and more CO emissions (due to the Tier 4 engines in generators) as compared to the proposed project. This would reduce operation-related emissions impact overall, but would not eliminate the impacts.

Mitigation Measure AQ-7 would continue to apply to Alternative D, but similar to the project, there is no guarantee that sufficient offsets would be available to mitigate impacts to a less-thansignificant level. Therefore, Project-level and cumulative-level impacts associated with operations criteria air pollutant emissions (Impact AQ-2b and Impact C-AQ-2) would be significant and unavoidable, although their levels would be reduced compared to the proposed project’s significant and unavoidable impact.

Phase 1
Operation of Phase 1 under Alternative D would differ compared to Phase 1 under the proposed project, as stated in Section 5.8.1, Description. The same key differences outlined above for the Specific Plan (i.e., reduction in land use area, generator usage, and vehicle traffic) would also apply to Phase 1. Table 5-10, p. 5-47, summarizes daily area-, energy-, mobile-, and stationarysource emissions generated under existing conditions (2018) and 2024 conditions with and without Phase 1 under Alternative D. Stationary source emissions include emissions from the testing of Phase 1’s four generators and are conservatively based on the full load testing scenario of 16 hours per day (which would occur once every 36 months, as shown in Table 4.2-5, p. 4.2- 31). To evaluate the magnitude of the change in the air quality environment due to implementation of Phase 1, emissions in 2024 under Phase 1 buildout in are compared to emissions in 2024 without Phase 1.

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Table 5-10. Estimated Average Daily Unmitigated Operational Emissions from Phase 1 under Alternative D (pounds/day)
Condition/Source ROG NOX CO PM10 PM2.5
Existing (2018)
Area Sources 8 < 1 < 1 < 1 < 1
Energy Sources < 1 < 1 < 1 < 1 < 1
Mobile Sources 176 268 1,369 300 83
Stationary Sourcesa — — — — —
Total Existingb 184 268 1,369 300 83
2024 Without Phase 1
Area Sources 8 < 1 < 1 < 1 < 1
Energy Sources < 1 < 1 < 1 < 1 < 1
Mobile Sourcesc 114 140 951 298 81
Stationary Sourcesa — — — — —
Total 2024 without Phase 1b 122 140 951 298 81
2024 With Phase 1
Area Sources 17 < 1 < 1 < 1 < 1
Energy Sources < 1 4 3 < 1 < 1
Mobile Sources 121 149 1,011 317 86
Stationary Sources, d 60 30 154 1 1
Total 2024 with Phase 1b 198 182 1,168 319 88
Net Increase with Phase 1
2024 With Phase 1 v. 2024 Without Phase 1b 77 42 217 21 7 Threshold 54 54 — 82 54
Exceeds Threshold? Yes No No No
Source: See Appendix 4.2-1 for operation modeling outputs.

Notes:
a. No stationary sources were identified as part of existing conditions. b. Values may not add up because of rounding.
c. Mobile source emissions in 2024 are lower than those in 2018 due to forecasted improvements in vehicle engine technologies and emission standards.
d. Conservatively assumes the full load testing scenario for Phase 1 of 16 hours per day.

Table 5-11, p. 5-48, compares daily operational emissions from Phase 1 under Alternative D’s generator testing scenarios (i.e., 16 hours per day versus 2 hours per day), to assist in understanding the role of generator testing in Phase 1’s operational emissions profile.

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Table 5-11. Unmitigated Operational Average Daily Emissions from Phase 1 under Alternative D – 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 122 140 951 298 81
2024 With Phase 1 – Full Load Testing Scenario (16 hours/day)b Non-Stationary Sources 138 152 1,014 318 86
Stationary Sources 60 30 154 1 1
Total 2024 With Phase 1 (16-hour)a 198 182 1,168 319 88 2024 With Phase 1 v. 2024 Without Phase 1 (16-hour) a 77 42 217 21 7 Threshold 54 54 — 82 54
Exceeds Threshold? Yes No No No
2024 With Phase 1 – Normal Testing Scenario (2 hours/day)c Non-Stationary Sources 138 152 1,014 318 86
Stationary Sources 8 4 19 < 1 < 1
Total 2024 With Phase 1 (2-hour)a 145 156 1,033 318 86
2024 With Phase 1 v. 2024 Without Phase 1 (2-hour) a 24 16 83 19 6 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 5-10, p. 5-47, operation of Phase 1 under the full load (16-hour per day) generator testing scenario would result in a net increase of ROG emissions that would exceed BAAQMD’s project-level thresholds. This impact would be slightly less than the impact for Phase 1 under the proposed project, which would exceed not only the ROG emission threshold but also the NOx threshold.

Under the normal (2-hour per day) generator testing scenario, operation of Phase 1 would not exceed BAAQMD’s project-level thresholds under Alternative D. This impact would be less than the impact for Phase 1 under the proposed project, which would exceed both the ROG and NOx emission thresholds. Nonetheless, on the infrequent days when full load generator testing would occur, operation of Phase 1 under Alternative D would exceed BAAQMD’s project-level thresholds, and operational criteria pollutant emissions would be potentially significant.

Mitigation Measure AQ-8, which limits the testing of Phase 1 emergency generators to one generator per day, would continue to apply to Alternative D. Estimated mitigated criteria pollutant emissions are presented in Table 5-12, p. 5-45.

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Table 5-12. Mitigated Operational Average Daily Emissions from Phase 1 under Alternative D – 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 122 140 951 298 81
2024 With Phase 1 – Full Load Testing Scenario (4 hours/day) Non-Stationary Sources 138 152 1,014 318 86
Stationary Sources 15 7 38 < 1 < 1
Total 2024 With Phase 1 (4-hour)a 153 160 1,053 318 87
2024 With Phase 1 v. 2024 Without Phase 1 (4-hour) a 31 20 102 20 6 Threshold 54 54 — 82 54
Exceeds Threshold? No No No No
2024 With Phase 1 – Normal Testing Scenario (0.5 hours/day) Non-Stationary Sources 138 152 1,014 318 86
Stationary Sources 2 1 5 < 1 < 1
Total 2024 With Phase 1 (0.5-hour)a 140 153 1,019 318 86 2024 With Phase 1 v. 2024 Without Phase 1 (0.5-hour) a 18 13 68 19 5 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 5-12, p. 5-49, with implementation of Mitigation Measure AQ-8, operation of Phase 1 under both the normal and full load generator testing scenarios would not result in an exceedance of any of BAAQMD’s project-level thresholds under Alternative D. In contrast, the proposed project would result in exceedances of the ROG and NOx thresholds after implementation of mitigation. Therefore, Alternative D would avoid the significant impact related to Phase 1 generator emissions that would occur under the proposed project (Impact AQ-2b and Impact C-AQ-2).

Localized Criteria Pollutants
Construction of the Specific Plan under Alternative D, inclusive of Phase 1, would generate localized fugitive dust. This impact would be the same as that of the project and would be less than significant with implementation of Mitigation Measure AQ-1.

Operation of the Specific Plan under Alternative D, inclusive of Phase 1, would elevate localized CO concentrations from continuous engine exhaust. As discussed in Section 5.8.3.14, Transportation and Circulation, traffic volumes at affected intersections would be slightly reduced compared to the proposed project, which would not exceed the CAAQS (see Table 4.2- 12 and Table 4.2-13 in Section 4.2, Air Quality). Therefore, this impact (Impact AQ-3 and Impact C-AQ-3) would be slightly less than that of the project and would be less than significant.

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Toxic Air Contaminants
Construction of the Specific Plan under Alternative D, inclusive of Phase 1, could disperse particulates containing asbestos-containing material (ACM) adjacent to the locations of sensitive receptors. Regulatory mechanisms regarding management of ACM would apply to demolition activities and ensure that impacts from ACM, if present during demolition activities, would be less than significant. Therefore, this impact would be the same as that of the project and would be less than significant.

Specific Plan
Construction of the Specific Plan under Alternative D would generate DPM that could expose adjacent receptors to significant health risks. Like the proposed project, because the timing and intensity of future development projects are not known at this time, the precise health risks of construction activities associated with buildout of the Specific Plan area under Alternative D cannot be accurately quantified. Alternative D would result in a substantially reduced construction program due to the elimination of the subterranean parking garages under Phase 1, which would reduce the overall quantity of construction emissions. However, this alternative would not eliminate the Project’s significant and unavoidable construction impacts, which are due to the uncertainty around future development that could occur under the Specific Plan.

Thus, Mitigation Measures AQ-1 through AQ-4, AQ-6, and AQ-9 would continue to apply to Alternative D. Project-level and cumulative-level impacts associated with construction criteria air pollutant emissions (Impact AQ-3 and Impact C-AQ-3) would remain significant and unavoidable under this alternative because, similar to the project, Mitigation Measure AQ-9 (which requires future projects within 1,000 feet of sensitive receptors to prepare health risk assessments) does not ensure that all future impacts can be mitigated to a less-than-significant level. However, construction TAC impacts would be reduced compared to the proposed project.

Operation of the Specific Plan under Alternative D would generate various ROG emissions from solvents and chemicals used in wet laboratories and process boilers in R&D buildings under the Life Sciences Scenario. Operation would also generate DPM and PM2.5 emissions from dieselfueled generators that could expose adjacent receptors to significant health risks. This impact would be the same as that of the proposed project and would be significant and unavoidable with implementation of Mitigation Measure AQ-9.

Phase 1
Construction of Phase 1 would generate DPM and PM2.5 emissions that could expose adjacent receptors to significant health risks. Table 5-13, p. 5-51, presents the unmitigated and mitigated construction-related health risk for the maximally exposed individual receptor (MEIR) within 1,000 feet of Phase 1 construction activities. The construction MEIR is located closest to the residential property of 31 Tanforan Avenue.

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Table 5-13. Phase 1 Cancer and Chronic Hazard Risks and PM.5 Concentrations during Construction Under Alternative Da
Unmitigated Mitigateda
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 Receptor 83.0 0.1 0.4 8.4 < 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 bolded and underlined. a The Phase 1 mitigated results account for BAAQMD thresholds regarding fugitive dust (Mitigation Measure AQ-1) and 95 percent of offroad equipment with Tier 4 engines (Mitigation Measure AQ-2) (see Impact AQ2a).

In an unmitigated scenario, construction of Phase 1 would result in a significant increase in cancer risk and annual PM2.5 concentrations 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. With implementation of Mitigation Measure AQ-1 and AQ2 this impact would be reduced to less than significant and health risks would be less than those associated with the proposed project.

Operation of Phase 1 would generate DPM emissions from emergency generators that could expose adjacent receptors to significant health risks. Table 5-14, p. 5-51, presents the operations-related health risk for the MEIRwithin 1,000 feet of Phase 1 operations activities.

The operations MEIR is located closest to the residential property of 57 Tanforan Avenue.

Table 5-14. Phase 1 Cancer and Chronic Hazard Risks and PM.5 Concentrations during Operation Under Alternative D
Receptor
Cancer Riska
(cases per million)
Non-Cancer Hazard
Index
Annual PM2.5
Concentration (µg/m3)
Maximally Exposed
Individual Receptor 0.1 < 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 No mitigation measures are applicable to these operational results.

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 is combined with the risk from the 30-year-long City of South San Francisco Revisions to the Draft EIR
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operational period. Note that the MEIR for the combined risk happens to be the same receptor identified for the construction period risk (located closest to the residential property of 31 Tanforan Avenue) but not the same receptor identified for the operational period risk. The combined cancer risk (8.47) is equal to the sum of the construction period cancer risk (8.41) plus the operational period cancer risk (0.05); numbers may not sum due to rounding. The combined cancer risk would not exceed BAAQMD’s threshold of 10.0 cases per million.

Therefore, this impact would be less than significant with mitigation, and slightly reduced from the proposed project’s less than significant impact.

Existing nearby DPM and PM2.5 sources within 1,000 feet of the project site, along with the construction and operation at the Phase 1 site, could contribute to a cumulative health risk for existing and future sensitive receptors adjacent to and within the project site. 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 5-15, p. 5-52. The methods used to quantify risks are the same as those used for the proposed project. Note that the MEIR for the cumulative health risk analysis is different from the MEIR identified for the construction period risk and the MEIR identified for the operational period risk. This is because the cumulative MEIR’s proximity to the higher-risk ambient sources (i.e., the railway and an existing stationary source) is a greater factor in determining its cumulative risk than its proximity to the lower-risk Phase 1 sources of construction and operation. The MEIR is located closest to the residential property of 1275 Herman Street.

Table 5-15. Mitigated Cumulative Health Risks from Phase 1 Under Alternative D Source
Cancer Risk
(cases per
million, rounded)
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 8 < 0.1 0.1
Contribution from Phase 1 Operation
Maximally Exposed Individual Receptor < 1 < 0.1 < 0.1
Cumulative Totals
Existing + Phase 1 Construction 35 < 0.1 10.1
Existing + Phase 1 Operation 28 < 0.1 9.8
Existing + Phase 1 Construction and Operation 36 < 0.1 10.1 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.
b Contributions from Phase 1 construction reported with implementation of Mitigation Measures AQ-1 and AQ-2.

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As shown in Table 5-14, p. 5-52, 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. This impact (Impact C-AQ-3) would be the same as that of the proposed project.

Odor Emissions
Similar to the project, Alternative D would not result in any odor-generating land uses and would not violate BAAQMD Regulation 7. Accordingly, odor impacts under Alternative D would be the same as under the project (Impact AQ-4) and would be less than significant. No mitigation would be required.

Section 5.8.3.2, Biological Resources
Alternative D would be located on the same project site as the proposed project with the addition of the approximately 2.1-acre property located at 80 Tanforan Avenue. The existing property at 80 Tanforan Avenue is developed with an approximately 40,000 sf industrial warehouse with 13 trees and limited landscaping.4 Eight of the 13 trees are considered protected under the City of South San Francisco’s Tree Preservation Ordinance.5 With the addition of the 80 Tanforan Avenue property, there are 175 existing trees on the project site, including 10 protected trees.

Alternative D would require slightly more demolition and tree removal than the proposed project with the addition of the 80 Tanforan property. However, no sensitive natural communities, wetlands, streams, or other aquatic features are present on 80 Tanforan that differ from the project site; 80 Tanforan is a developed parcel with approximately 78,884 sf developed with impervious surfaces of the total 87,384 sf parcel. Therefore, there would be no impacts to riparian habitat or other sensitive natural communities; state or federally protected wetlands; the movement of fish species, the use of wildlife corridors or native wildlife nursery sites for fish and terrestrial, non-avian species; or provisions of an adopted habitat conservation plan, natural community conservation plan, or other approved local, regional, or state habitat conservation plan similar to the proposed project. No mitigation would be required.

Additionally, impacts on movement of terrestrial, non-avian species would be the same as the proposed project and would be less than significant for Alternative D.

Under Alternative D, there would be slightly increased amounts of tree removal and structure demolition than the proposed project. Therefore, impacts on peregrine falcon, roosting specialstatus bat species, and resident and migratory nesting birds protected under state and federal laws, and impacts on native wildlife nursery sites for birds and bats would be similar, but 4 Urban Tree Management, Inc. 2022. Arborist Report—80 Tanforan Avenue, South San Francisco, CA, 94080.

January 25, 2022.
5 Ibid.

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slightly greater than, the proposed project and would be less than significant with mitigation for Alternative D. Thus, Mitigation Measures BIO-1a and BIO-1b would continue to apply to Alternative D. Additionally, Alternative D would comply with the South San Francisco Municipal Code and San Bruno Municipal Code when conducting tree removal; therefore, impacts on local policies or ordinances protecting biological resources would be the same as that of the proposed project and would be less than significant for Alternative D.

Under Alternative D, building size, building surfaces, and operational lighting of buildings would be substantially similar as the proposed project. Therefore, impacts on the movement of migratory birds and the use of the site as a migratory bird corridor would be the same as the proposed project and would be less than significant with mitigation. Thus, Mitigation Measures BIO-2a and BIO-2b would continue to apply to Alternative D. Overall, biological resources would be less than significant with mitigation under Alternative D but slightly greater than those of the proposed project due to the 13 additional tree removals and the additional demolition proposed.

Section 5.8.3.3, Cultural Resources
Alternative D includes additional demolition and above-grade construction compared to the proposed project. Specifically, Alternative D would include the demolition of the existing building at 80 Tanforan and the construction of a six level above-grade parking structure (Parking Structure D) in its place. The existing building at 80 Tanforan was constructed in 1986 and therefore not age-eligible for consideration as a historical resource. Therefore, Alternative D’s impacts on historic resources and the potential historic district would be less than significant with implementation of Mitigation Measure CR-1 and the same as those of the proposed project.

Under Alternative D the Phase 1 subterranean parking garages would not be constructed, thereby resulting in substantially less ground disturbance compared to the proposed project.

Although the depth of ground disturbance and volume of excavation would be significantly less, the overall footprint of the project would be expanded and the subterranean parking garages in future phases would still be constructed. Therefore, potential impacts to archaeological resources and human remains would still occur under Alternative D, and implementation of Mitigation Measures CR-2a, CR-2b, and CR-3, would continue to apply to this alternative. Overall, impacts would be less than significant with mitigation and reduced compared to the proposed project.

Section 5.8.3.4, Energy
Unlike the proposed project, Alternative D would also include the demolition of the existing building located at 80 Tanforan Avenue and the construction of a six-level, above-grade parking structure (Parking Structure D) in its place. With Parking Structure D, the two-levels of subterranean parking associated with buildout of Phase 1 under the proposed project would be eliminated, and the entirety of Parking Structure C would be constructed in future phases, rather than partially constructed during Phase 1, as proposed under the project. Accordingly, total construction activity under Phase 1 would be reduced, which would reduce the amount of energy consumed during construction-related activities. Specifically, construction of Phase 1 would require approximately 749 mBTUs of electricity under Alternative D, compared to the approximately 789 mBTUs of electricity that would be consumed under the proposed project.

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eliminate the impact entirely, thus, Mitigation Measure GHG-1 would still apply. Overall, construction of Alternative D would consume less energy and would have a lesser impact than the proposed project’s project-level and cumulative-level energy impacts, which would be less than significant with mitigation.

Operation of Alternative D would result in similar operations-related energy usage and consumption compared to the proposed project given that the total developed square footage remains the same under Alternative D and the project. As with the project, Alternative D would be designed to meet LEED version 4 Silver rating, water efficient devices and landscaping, passive heating and cooling design strategies, on-site recycling and composting facilities, electric vehicle charging infrastructure, and TDM measures. Overall building square footage would be comparable or slightly reduced, as would operational vehicle trip generation. Consequently, project-level and cumulative-level operational energy impacts under Alternative D would be slightly reduced compared to the impacts of the proposed project, and still less than significant.

No mitigation would be required.

Section 5.8.3.5, Geology and Soils
Under Alternative D the Phase 1 subterranean parking garages would not be constructed, resulting in substantially less ground disturbance compared to the proposed project. Although, the depth of ground disturbance and volume of excavation would be significantly less, the overall footprint of the project would be expanded and the subterranean parking garages in future phases would still be constructed.

Because Alternative D would be constructed at the same location as the proposed project, with only a slight extension to the south, the distance to seismic sources and underlying sediments would be the same as for the proposed project. Therefore, impacts related to surface fault rupture, strong seismic ground shaking, and seismic-related ground failure, including liquefaction and landslide, would be the same as the proposed project. In addition, because Alternative D would be constructed on the same underlying sediments as the proposed project, impacts related to expansive soils would be the same as the proposed project.

Because Alternative D would be constructed at the same general location and groundwater is close to ground surface, even though Alternative D would involve shallower excavation in the Phase 1 site, it would nevertheless encounter groundwater and require temporary dewatering and shoring during construction. The extent of dewatering and shoring would be less under Alternative D than under the proposed project. Because Alternative D would be constructed on the same underlying sediments as the proposed project, there would be a potential for static settlement. While structural loads are not currently known for Parking Structure D, they are expected to be typical of similar structures, and due to the onsite soil composition, potential for significant differential seismic settlement is considered low.6 Alternative D, like the proposed project, would connect to South San Francisco’s sewer and stormwater collection and treatment system and would not involve use of septic tanks or alternative wastewater disposal system. The impact relating to soils incapable of supporting alternative wastewater systems would be the same as under the proposed project. 6 Cornerstone Earth Group. 2022. Preliminary Geotechnical Investigation, Southline Development Parcel 8, 80 Tanforan Avenue, South San Francisco California. Project Number 129.3.9. January 12, 2022.

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As Alternative D would not include the Phase 1 subterranean parking garages, and Parking Structure D would be constructed at-grade, this alternative would involve excavation to a shallower maximum depth than the proposed project, although it would include a larger overall footprint. Because the sensitive Colma Formation extends to a shallow depth, and 80 Tanforan is also known to be underlain by Colma Formation,7 this alternative has potential to disturb paleontological resources. However, because Alternative D would involve shallower excavation than the proposed project, it has correspondingly less likelihood of encountering these resources. The same mitigation to reduce impacts on paleontological resources would be required under Alternative D as under the proposed project.

Overall, project-level and cumulative impacts related to geology, soils, and seismicity as well as impacts on paleontological resources would be less than significant with mitigation under Alternative D, and reduced compared to those of the proposed project.

Section 5.8.3.6, Greenhouse Gas Emissions
Construction Emissions
Specific Plan
Like the proposed project, because the timing and intensity of future development projects are not known at this time, the precise effects of construction activities associated with buildout of the Specific Plan area under Alternative D cannot be accurately quantified. Alternative D would result in a substantially reduced construction program, which would reduce the overall quantity of construction emissions. 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 with statewide emissions goals. Therefore, construction-related GHG emissions from the Specific Plan under Alternative D would be required to comply with Mitigation Measure GHG-1, which would reduce construction emissions, consistent with BAAQMD guidance and statewide emission reduction goals, to less than significant. This impact (Impact GHG-1a) would be less than significant with mitigation, similar to the proposed project, but would be reduced compared to the project due to the reduction in overall emissions (refer to Phase 1 analysis below).

Phase 1
Construction of Phase 1 under Alternative D would differ compared to the proposed project, as stated in Section 5.8.1, Description. The following key differences would affect the amount of construction emissions.
• The long, eastern portion of the “L-shaped” campus Parking Structure C would no longer be developed as part of Phase 1, but would be constructed with buildout of future phases • The two levels of below-grade parking under Phase 1 would no longer be developed • The existing building at 80 Tanforan Avenue would be demolished • Parking Structure D with six levels of above-grade parking would be constructed 7 Atlas. ND. Limited Phase II Environmental Site Assessment Report: 80 Tanforan Avenue, South San Francisco, California, Atlas Project No. NPGS2129. July 28, 2020.

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Construction emissions of Phase 1 under Alternative D were quantified using the same methodology used for the proposed project. Assumptions regarding construction activities, equipment, and vehicles were updated based on the development characteristics of Alternative D. Construction dates were also updated based on the status of the EIR and anticipated entitlement schedule at the time the Alternative D analysis was conducted. Estimated unmitigated GHG emissions are presented in Table 5-15, p. 5-56.

Table 5-15. Estimated Construction GHG Emissions from Phase 1 under Alternative D (metric tons)
Construction Year CO2 CH4 N2O CO2e
2022 1,958 < 1 < 1 2,012
2023 2,767 1 < 1 2,818
2024 768 < 1 < 1 780
Totala 5,492 1 < 1 5,610
Source: Refer to Appendix 4.2-1 for construction modeling outputs.

Notes:
a. Totals may not add up because of rounding.

While GHG emissions from construction of Phase 1 under Alternative D would be less than the proposed project, BAAQMD has not established a quantitative threshold for assessing construction related GHG emissions and therefore the emissions quantity is not relevant to the impact analysis. Rather, the air district recommends evaluating whether construction activities would conflict with statewide emission reduction goals and implementing feasible BMPs.

Construction-related GHG emissions from Phase 1 under Alternative D would be mitigated to less than significant with implementation of Mitigation Measure GHG-1. Therefore, constructionrelated GHG emissions from the Specific Plan under Alternative D would be required to comply with Mitigation Measure GHG-1, which would reduce construction emissions, consistent with BAAQMD guidance and statewide emission reduction goals, to less than significant. This impact (Impact GHG-1a) would be less than significant with mitigation, similar to the proposed project, but would be reduced compared to the project due to the reduction in overall emissions.

Operation Emissions
Specific Plan
Operation of the Specific Plan, including Phase 1, under Alternative D would differ compared to the proposed project, as stated in Section 5.8.1, Description. The following key differences would affect the amount of operation emissions.
• Energy source emissions for Phase 1 would decrease slightly due to adjustments in land uses.
• Stationary source emissions would decrease as the emergency diesel generators associated with Phase 1would be reduced from five to four (i.e., removal of generator #3 listed in Table

4.2-5 in Section 4.2, Air Quality)
• Mobile source emissions and vehicle miles travelled would be comparable or slightly decrease as the expected daily traffic would decrease, as discussed in 5.8.3.14, Transportation and Circulation
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Operation emissions under Alternative D were quantified using the same methodology used for the proposed project. Table 5-16, p. 5-58, summarizes daily area-, energy-, mobile-, and stationary-source emissions generated under existing conditions (2018) and 2030 conditions with and without the Specific Plan under Alternative D. Emissions under Specific Plan buildout in 2030 are compared to 2030 emissions without the Specific Plan.

Table 5-16. Estimated Annual Specific Plan Operational GHG Emissions under Alternative D (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 346 < 1 < 1 347 0.9%
Mobile sources 37,643 2 2 38,282 98.2%
Stationary sourcesa 0 0 0 0 0.0%
Waste generation 63 4 < 1 155 0.4%
Water consumption 117 2 < 1 196 0.5%
Land use -128 0 0 -128 -0.4%
Total existingb 38,169 8 2 38,981 —
2030 without Project
Area sources < 1 < 1 < 1 < 1 < 0.1%
Energy sources 140 < 1 < 1 141 0.5%
Mobile sources 30,126 1 1 30,567 99.0%
Stationary sourcesa 0 0 0 0 0.0%
Waste generation 63 4 < 1 155 0.5%
Water consumption 55 2 < 1 134 0.4%
Land use -128 0 0 -128 -0.4%
Total 2030 without Specific Planb 30,384 7 1 30,998 —
2030 with Project
Area sources < 1 < 1 < 1 < 1 < 0.1%
Energy sources 2,880 < 1 < 1 2,897 4.6%
Mobile sources 57,172 2 3 58,009 92.6%
Stationary sources 177 < 1 < 1 178 0.3%
Waste generation 591 35 < 1 1,464 2.3%
Water consumption 125 13 < 1 537 0.9%
Land use < 1 < 1 < 1 -432 < 0.1%
Total 2030 with Specific Planb 60,946 50 3 62,653 —
Net Increase with Project
2030 with Project vs. 2030 without Project 30,689 43 < 1 31,784 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. Values may not add up because of rounding.

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Operation of the Specific Plan under Alternative D would result in comparable or slightly reduced operation-related GHG emissions compared to the proposed project (36,818 MT CO2e per year versus 37,739 MT CO2e per year). Furthermore, emissions from emergency generator testing (178 MT CO2e per year) would be well below BAAQMD’s stationary-source threshold (10,000 MT CO2e per year). Accordingly, Project-level and cumulative-level operations GHG impacts under Alternative D (Impact GHG-1b and Impact C-GHG-1) would be less than significant and less than those of the proposed project. No mitigation would be required.

Phase 1
Operation of the Phase 1 under Alternative D would differ compared to the proposed project, as stated in Section 5.8.1, Description. The same key differences outlined above for the Project (i.e., reduction in land use area, generator usage, and vehicle traffic) would also apply to Phase 1.

Table 5-17, p. 5-61, summarizes by source emissions generated under existing conditions (2018) and 2024 conditions with and without Phase 1.

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Table 5-17. Estimated Annual Unmitigated Phase 1 Operational GHG Emissions under Alternative D (metric tons)
Condition/Source CO2 CH4 N2O CO2e
% of Total
CO2e
Existing (2018)
Area sources < 1 < 1 < 1 < 1 < 0.1%
Energy sources 346 < 1 < 1 347 0.9%
Mobile sources 37,643 2 2 38,282 98.2%
Stationary sourcesa 0 0 0 0 0.0%
Waste generation 63 4 < 1 155 0.4%
Water consumption 117 2 < 1 196 0.5%
Land use -128 0 0 -128 -0.4%
Total existingb 38,169 8 2 38,981 —
2024 without Phase 1
Area sources < 1 < 1 < 1 < 1 < 0.1%
Energy sources 182 < 1 < 1 183 0.5%
Mobile sources 33,045 2 2 33,544 99.3%
Stationary sourcesa 0 0 0 0 0.0%
Waste generation 63 4 < 1 155 0.5%
Water consumption 68 2 < 1 147 0.4%
Land Use -237 0 0 -237 -0.7%
Total 2024 without Phase 1b 33,121 8 2 33,793 —
2024 with Phase 1
Area sources < 1 < 1 < 1 < 1 < 0.1%
Energy sources 735 < 1 < 1 739 2.0%
Mobile sources 35,142 2 2 35,673 96.5%
Stationary sources 177 < 1 < 1 178 < 0.1%
Waste generation 195 12 < 1 483 1.3%
Water consumption 30 3 < 1 131 < 0.1%
Land Use -237 0 0 -237 -0.6%
Total 2024 with Phase 1b 36,280 16 2 36,967 —
Net Increase with Phase 1
2024 with Phase 1 vs. 2024 without Phase 1b 2,922 9 < 1 3,173 — 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. Values may not add up because of rounding.

Operation of Phase 1 under Alternative D would result in comparable or slightly reduced operation-related GHG emissions compared to the proposed project (8,081 MT CO2e per year versus 10,912 MT CO2e per year). Furthermore, emissions from emergency generator testing (178 MT CO2e per year) would be well below BAAQMD’s stationary-source threshold (10,000 MT CO2e per year). Accordingly, Phase 1-level and cumulative-level operations GHG impacts under Alternative D (Impact GHG-1b and Impact C-GHG-1) would be less than significant and less than those of the proposed project. No mitigation would be required.

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Consistency with Applicable GHG Plans
As stated in Section 5.8.1, Description, Alternative D would implement the same design features, sustainability features, and open space and pedestrian connections within the Specific Plan area as the proposed project. The Project would be consistent with the applicable GHG plans with implementation of Mitigation Measure GHG-1 and Mitigation Measure AQ-4. Phase 1 would be consistent with the applicable GHG plans with implementation of Mitigation Measure GHG-1.

These impacts (Impact GHG-2) would be the same as those of the proposed project.

Section 5.8.3.7, Hazards and Hazardous Materials
Alternative D would have a larger footprint than the proposed project, increasing by 2.1 acres; however, the alternative would have the same utility and road improvements and same permitted land use options as the proposed project. Excavation under Alternative D would be shallower and less extensive, as all the subterranean parking associated with Phase 1 would be eliminated, and Parking Structure D would be constructed at-grade. Although Alternative D would require less ground disturbance, it would still require the routine handling of hazardous materials. As such, handling of hazardous materials would still be subject to applicable regulations for both construction and operation. Furthermore, operational use of hazardous materials under the Life Sciences Scenario would be similar to the proposed project.

Therefore, Life Science/R&D tenants would still be required adhere to all applicable federal, state and local regulations and apply for applicable permits for regulated substances. Impacts associated with the routine transport, use, or disposal of hazardous materials would be less than significant.

Although excavation would be shallower and less extensive, Alternative D would be constructed within the larger footprint than the proposed project and therefore, the potential to encounter contaminated soil and/or groundwater during ground disturbance and hazardous building materials during demolition would still exist, although to a lesser extent given reduction in subterranean excavation compared to the project. As with the proposed project, future development associated with Alternative D would be required to implement recommendations included in various site-specific investigations conducted within the project footprint (prior investigations are detailed in Section 4.8, Hazards and Hazardous Materials, of this EIR). A Phase II Environmental Site Assessment (ESA) prepared for the parcel at 80 Tanforan Avenue identified risks associated with potential soil and groundwater contamination, similar to the known hazards present on the remaining project site.8 As there is a potential for exposure to contaminated soil, contaminated groundwater and hazardous building materials under Alternative D, including within the 80 Tanforan Avenue parcel, implementation of Mitigation Measures HAZ-2a through HAZ-2c and HWQ-1 would still be required. Development would also be required to adhere to deed restrictions and DTSC oversight as part of 160 South Linden Avenue. Impacts associated with foreseeable upset and accident conditions involving the release of hazardous materials and Alternative D being located on a Cortese List site would be less than significant.

Alternative D would be implemented in the same general area as the proposed project. As shown in Figure 4.10-1, ALUCP Safety Compatibility Zones, 80 Tanforan Avenue, like the vast 8 Atlas. ND. Limited Phase II Environmental Site Assessment Report: 80 Tanforan Avenue, South San Francisco, California, Atlas Project No. NPGS2129. July 28, 2020.

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majority of the Project Site, is not located within any identified Safety Compatibility Zone.

Development would be subject to the same ALUCP compatibility criteria as the proposed project, including noise and height restrictions described under Impact HAZ-5 in Section 4.8, Hazards and Hazardous Materials, of this EIR. Impacts associated with aviation hazards and excessive noise as a result of Alternative D being located near an airport would be less than significant.

Construction activities would be similar in nature to the proposed project, and thus, construction under Alternative D would still require compliance with City requirements regarding circulation and access and would also require a final inspection by the South San Francisco Fire Department prior to use of the buildings. Similar to the proposed project, R&D tenants under the Life Sciences Scenario under Alternative B would be required to adhere to all applicable regulations (as described under Impact HAZ-6 in Section 4.8, Hazards and Hazardous Materials, of this EIR). Adherence to applicable regulations and plans would ensure proper emergency response and evacuation if a release of hazardous materials would occur. Moreover, off-site improvements would also occur as part of Alternative D – consisting of roadways, sidewalks, and utility easements along roadways surrounding the project site – and would improve roadway circulation and adjacent intersections, resulting in improved access to the project site and the surrounding area. Therefore, impacts associated with impairment or interference of an adopted emergency response plan or emergency evacuation plan would be less than significant.

Alternative D would be developed within a slightly larger footprint than the proposed project.

Thus, Alternative D would be constructed in a highly developed industrial area, with no wildlands nearby and would not be susceptible to significant risk of loss, injury or death involving wildland fires. No impact involving wildland fires would occur.

Overall, like the proposed project, project-level and cumulative impacts to hazards and hazardous materials would be less than significant with mitigation under Alternative D, and reduced compared to the proposed project due to the reduced extent of ground disturbance.

Section 5.8.3.8, Hydrology and Water Quality
Under Alternative D, excavation would be shallower and less extensive, as the two levels of subterranean parking south of Southline Avenue would no longer be required for buildout of Phase 1 in comparison to the proposed project. In addition, the overall footprint of the project would be expanded slightly to incorporate the 80 Tanforan Avenue property. New stormwater facilities associated with Phase 1 development would be constructed along a portion of the proposed Southline Avenue, and would connect to the existing 42-inch storm drain within Tanforan Avenue through a new public storm drain line and easement to be installed with buildout of Phase 1. With this improvement, proposed stormwater facilities under the proposed project would no longer connect from Dollar Avenue to the existing facilities within Tanforan Avenue. In addition, with the development of Parking Structure D, the drainage pattern on site would change slightly and more drainage would occur in the northern portion of the project site as shown in Figure 4-3: Conceptual Storm Drainage Improvement Plan of the revised Specific Plan. Otherwise, Alternative D would have the same general footprint as well as the same utility improvements and roads as the proposed project. In addition, Alternative D would be constructed at the same location as the proposed project, along with addition of the 80 Tanforan Avenue property. Furthermore, Alternative D would be subject to the same hydrology and water City of South San Francisco Revisions to the Draft EIR
Southline Specific Plan
Responses to Comments 3-57 May 2022
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quality regulatory requirements as the proposed project. Therefore, based on the Alternative D site location and proposed improvements, impacts related to conflicting or obstructing a water quality control plan or sustainable groundwater management plan would be the same as the proposed project.

Because Alternative D would be constructed at the same location as the proposed project, surface water features, water quality conditions, the underlying groundwater basin and conditions, and flood hazards would be the same as for the proposed project. The total amount of impervious surfaces within the Specific Plan area would increase by approximately 89,756 sf with incorporation of the 80 Tanforan Avenue property, from approximately 897,691 sf under the proposed project to 987,447 sf under Alternative D. This is due to the increase in the size of the Specific Plan area. However, with the proposed landscape improvements, the proposed amount of impervious surfaces within the 80 Tanforan Avenue property would be comparable to existing conditions on the property (i.e., approximately 90 percent impervious surfaces).

Overall, the amount of impervious surface area in the Specific Plan area would decrease from approximately 93 percent under existing conditions to approximately 79 percent under proposed conditions. In addition, Alternative D would be subject to the same BMPs, LID, and hydrology and water quality regulatory requirements as the proposed project. Therefore, impacts related to water quality, alterations in drainage patterns, flooding, or release of pollutants due to project inundation would be less than significant and similar to the proposed project
Although Alternative D would involve less excavation than the proposed project, it would be constructed at the same location as the proposed project, where groundwater is close to the ground surface (i.e., approximately 8 to 27 feet below ground surface). It is likely that groundwater would be encountered and require temporary dewatering during construction of Alternative D. The extent of dewatering would be less under Alternative D than under the proposed project, as Phase 1 would no longer require dewatering since no subterranean parking garages would be constructed (dewatering would still be required during future phases).

However, the same mitigation as the proposed project would be required to reduce impacts on groundwater quality during construction dewatering. Therefore, with implementation of Mitigation Measure HWQ-1, impacts on water quality under Alternative D would be less than significant with mitigation and reduced compared to the proposed project. Under Alternative D, Mitigation Measure HWQ-1 would only be required during future phases proposing subterranean parking.

In addition, because infrastructure improvements associated with Alternative D would be similar to those described for the proposed project, impacts related to changes in impervious cover, groundwater recharge, peak storm drain flow, and flood hazards would also be the same.

Alternative D, like the proposed project, would connect to South San Francisco’s stormwater collection and treatment system. The impact relating to alterations in drainage patterns resulting in erosion or flooding or exceeding the drainage system capacity would be the same as under the proposed project.

Overall, project-level and cumulative impacts to hydrology and water quality would be less than significant with mitigation under Alternative D, and reduced compared to the impacts of the proposed project due to the reduced extent of ground disturbance and excavation.

City of South San Francisco Revisions to the Draft EIR
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Section 5.8.3.9, Land Use and Planning
The existing building at 80 Tanforan is an approximately 43,000 sf industrial warehouse located on an approximately 2.1-acre parcel that is designated as an office use under the City’s General Plan and zoned Business Professional Office (BPO), which is consistent with the designations and general uses of the other existing properties on the project site.

Alternative D would have the same land use impacts with incorporation of the property located at 80 Tanforan Avenue into the Specific Plan area. The Reduced Underground Parking Alternative would slightly reduce the density at which the program would occur under Phase 1, but would still involve the same land use program and permitted uses for both Phase 1 and future phases proposed under the Specific Plan. With the incorporation of the 80 Tanforan Avenue property, the proposed project would not result in a new impact related to the physical division of a community as the overall project layout would remain the same and there are no existing residential or community uses associated with the building at 80 Tanforan Avenue.

Alternative D would help to further certain City of South San Francisco General Plan policies aimed at maximizing land uses and enhancing transportation capacity, such as policies 2-G-2, 2- G-3, 2-G-8, or 4.2-G-1 (see Section 4.10.3.4, in Section 4.10, Land Use and Planning, of the Draft EIR for a full description of land use policies), as it would continue to incorporate the same circulation and connectivity infrastructure improvements as the proposed project, while maximizing land uses. Therefore, Alternative D would not result in an environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. Alternative D impacts related to land use and planning would be less than significant, and similar to those of the proposed project.

Section 5.8.3.10, Noise and Vibration
Daytime Construction Noise. Alternative D would involve the expansion of the Specific Plan buildout area to incorporate the property at 80 Tanforan Avenue. Although the footprint of the overall construction activities would change, construction activities would take place no closer to off-site sensitive land uses (e.g., near residences south of Tanforan Avenue) than would occur under the project. In addition, the types of equipment required and the intensity of construction activity near off-site noise-sensitive uses would also be similar, and the construction schedule for Alternative D would be shorter than the proposed project due to the substantial reduction in excavation required under this alternative. As is the case with the proposed project, construction that occurs during the “daytime hours” defined by the City of San Bruno and the City of South San Francisco would comply with local standards and would result in less-thansignificant noise impacts for Alternative D.

Non-Daytime Construction Noise. Since construction outside of defined “daytime hours” for San Bruno and South San Francisco would be expected for Alternative D (as is the case with the proposed project), construction noise for the Specific Plan and for Phase 1 during nighttime hours may be in excess of the applicable criteria for both jurisdictions. As is the case for the proposed project, nighttime construction noise impacts would be considered significant for Alternative D during Phase 1 and for the project as a whole. Implementation of Mitigation Measure NOI-1a, which includes measures to reduce construction noise levels, but not to a lessthan-significant level for the reasons stated in the project analysis in Section 4.11, Noise, of this EIR. Therefore, Alternative D would reduce but would not avoid the significant and unavoidable City of South San Francisco Revisions to the Draft EIR
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project-level and cumulative impacts associated with construction noise for Phase 1 and the project (Impact NOI-1a and Impact C-NOI-1).

Construction Haul Truck Noise. With regard to construction haul truck noise, Alternative D would result in approximately 14,000 fewer haul truck trips (one-way) than the proposed project and would use the same haul routes as the project. In addition, on a worst-case day, the expected daily haul trucks for Alternative D would be similar to the number expected for the project. Therefore, as is the case with the proposed project, temporary noise impacts related to haul truck use for the Specific Plan and for Phase 1 would be less than significant and less than the impacts of the proposed project.

Loading Activity Noise. Loading dock activity under Alternative D would be similar to loading dock activity under the project, with up to 12 heavy trucks using the Phase 1 loading bays (i.e., the closest loading docks to off-site sensitive uses) for loading/unloading activities on a given day. As with the project, it is estimated that up to four loading or unloading activities would occur per day at each loading bay. With the Project, it was assumed that up to eight total per day could occur at the Building 2 loading bays because of the existence of 2 bays at this dock. Since the two loading bays located at Building 1 under the project would no longer be located adjacent to one another, activity at each of these loading docks would be halved as compared to the project (i.e., half of the 8 trips occurring at each of the two bays). As with the project, it is unlikely that there would be more than one truck loading or unloading at a given loading dock during a single hour.

Note that under existing conditions, part of the southernmost portion of the project site is currently occupied by a warehouse and distribution center (Watchpoint Logistics, Inc.). This use involves much higher volumes of daily loading and unloading activities at these existing loading docks near Tanforan Avenue than would occur with the proposed project or Alternative D implementation. Specifically, approximately ten loading bays for large trucks are currently located less than 200 feet north of the nearest residence along Tanforan Avenue. More frequent loading occurs at this location under existing conditions than would occur with project implementation or Alternative D implementation. In addition, this warehouse and distribution center is currently accessed from a driveway along Tanforan Avenue. With project implementation or Alternative D implementation, vehicles (including trucks) would no longer travel along Tanforan Avenue (south of the Project site) to access the project site. They would instead access the project loading bays via Southline Avenue (to the north of the Phase 1 area).

In addition to the above warehouse and distribution center, a used car buying and selling company (Shift) is located near Watchpoint Logistics, Inc. along the southern perimeter of the project site under existing conditions. This use also is accessed from a driveway along Tanforan Avenue and involves the frequent entrance and exit of automobiles from the project site to Tanforan Avenue throughout a given day, which generates noise. Watchpoint Logistics and Shift would no longer be located on the Project site under project or Alternative D conditions.

Under Alternative D, the two loading bays associated with Building 1 would be relocated such that they are slightly closer to off-site residences south of Tanforan Avenue as compared with the project. Under the project, the nearest sensitive receptor to the Building 1 loading bays (2 bays located at a single dock) would be located more than 250 feet from the loading dock. Under Alternative D, one of the loading bays at Building 2 loading dock would be located approximately 230 feet north of the nearest residences along Tanforan Avenue, and one at Building 1 would be located approximately 100 feet north of these residences. As described City of South San Francisco Revisions to the Draft EIR
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previously, approximately half of the volume of loading activity would occur at each bay under Alternative D than would occur under the Project (since two bays were located at a single loading dock under the Project). In addition, under both the project and Alternative D, far fewer loading and unloading activities would occur in this area than currently occur under existing conditions.

Regarding the Building 2 loading dock under Alternative D, the location for this dock is fully shielded by Building 2 from the nearest off-site residences. Noise from this loading dock would not be expected to result in substantial increases to the ambient noise level at the nearest residences. In addition, although the Building 1 loading dock under Alternative D would be located closer to residences than analyzed under the Project, daily loading activities at this loading bay would be half of what is expected at the Building 1 loading bays with proposed project’s implementation (an estimated 4 activities per day instead of 8).

Overall, as is the case for the proposed project, although there may be a direct line of sight between some nearby residences and some loading dock areas, the temporary loading and unloading activities at the Phase 1 buildings (up to 4 heavy trucks per day per dock) would be short term and occur intermittently and occurring only during daytime hours when people are generally less sensitive to noise. In addition, more frequent loading and unloading activities currently occur at the existing site due to the existence of the Watchpoint Logistics warehouse and distribution use, in addition to the adjacent car distribution use. Therefore, project and Alternative D implementation would not result in an increase in loading and unloading activities at the site, and would instead result in a decrease in these activities at the site. For these reasons, and as was the case for the proposed project, the temporary and short-term increases in noise from project loading activities would not be considered substantial. Impacts related to loading dock noise from Alternative D would be less than significant.

Operational Traffic Noise. During operations, Alternative D is expected to generate a similar, though slightly lower, number of vehicle trips as the proposed project. Therefore, traffic noise impacts from Alternative D would be comparable or slightly reduced to those disclosed for the project. As project-related traffic noise impacts were determined to be less than significant, traffic noise impacts from Alternative D would also be less than significant.

Operational Noise from Gathering Spaces. Noise from outdoor gathering spaces during project operations would be the same as the proposed project and would be less than significant, as there would be no changes to the proposed land uses or outdoor gathering areas that could host outdoor events. Furthermore, these areas would remain screened by surrounding proposed buildings. The expansion of Tanforan Community Parklet would not result in greater noise impacts since that space would be used for passive recreation uses.

Mechanical Equipment Noise. Under Alternative D, the types and amount of mechanical equipment (e.g., heating, cooling and ventilation equipment, etc.) would be similar. In addition, Parking Structure D would have a mechanical equipment room with relatively similar equipment to that evaluated under the Project (i.e., pumps and electrical equipment). However, the equipment would be no closer to adjacent sensitive land uses than analyzed under the project, and would therefore result in similar noise levels at nearby sensitive uses to those presented in the project analysis.

Although the makes and models of the equipment at Parking Structure D, and at other Specific Plan buildings, is not known with certainty at this time, noise from this equipment would be City of South San Francisco Revisions to the Draft EIR
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similar to that evaluated for proposed project. As is the case with the proposed project, noise mechanical equipment at the project site may exceed the daytime and nighttime thresholds outlined in the Municipal Codes of the City of South San Francisco and the City of San Bruno and at nearby buildings. Implementation of project Mitigation Measure NOI-1c, which requires a mechanical equipment noise reduction plan for equipment installed under all phases, would be required under Alternative D and would reduce this impact to less than significant levels for this alternative.

Parking Garage Activity. Alternative D would include the development of Parking Structure D (in lieu of the Phase 1 subterranean parking and partial development of Parking Structure C), located in the southeast portion of the Phase 1 area. Access to Parking Structure D would be provided by Southline Avenue. The garage will utilize gate arms with card key access, and is anticipated to be open 24 hours per day and 7 days a week to Specific Plan tenants, but the typical operation of the garage is anticipated to occur during normal business hours with limited after-hours usage. According to the Project traffic engineer,9 it is estimated that during a peak hour, up to 450 vehicles may enter or exit the garage. Traffic-related noise associated with Parking Structure D can be estimated based on this information.

The nearest noise-sensitive land uses are the residences located approximately 100 feet south of the southern perimeter of Parking Structure D, or approximately 200 feet from the center of the parking structure. The distance to the center of the parking structure is used because it represents the average location of all vehicles circulating in and out of the structure at any given time.

According to FTA’s Transit Noise and Vibration Impact Assessment Manual, 10 1,000 cars in a peak
activity hour would generate a sound equivalent level (SEL) of 92 dBA at 50 feet. This value was converted to an hourly Leq (average) noise level and used to calculate the Leq noise level of a maximum of 450 vehicles per hour using the parking garage. At a distance of 50 feet, 450 vehicles using the garage per hour (conservatively assuming all vehicles were located close to one another within the multi-story structure) would result in an hourly Leq noise level of 53 dBA Leq. At a distance of 200 feet, the distance to the nearest residential land use from the approximate center of the structure, this would be reduced to 41 dBA Leq without accounting for shielding from intervening buildings. A two- to eight-foot-tall crash wall would be located around the perimeter of the garage, as would decorative panels and screens (along Tanforan and Dollar Avenue frontages), as well as landscaping. In areas where a solid perimeter wall is located at a given floor of the parking structure, noise from automobiles in the garage is anticipated to be further reduced.

These noise levels associated with Parking Structure operations are well below all estimated existing ambient noise levels in the project area, as shown in Table 4.11-6, p. 4.11-10 in Section 4.11, Noise. For example, the existing ambient noise along Huntington Avenue south of Sneath Lane (estimated from traffic noise levels) was approximately 64 dBA Ldn and along Dollar Avenue near Tanforan Avenue was estimated from traffic volumes to be approximately 60.8 Ldn.

Existing ambient noise along Tanforan Avenue was estimated to be 58.6 Ldn. Parking lot noise in 9 Jacobson, Daniel. Pers. Comm. Email to Heidi Mekkelson on February 15, 2022. 10 Federal Transit Administration, Transit Noise and Vibration Impact Assessment, FTA Report No. 0123, 2018, https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-noise-and-vibrationimpact-assessment-manual-fta-report-no-0123_0.pdf, accessed August 10, 2020.

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this area from Parking Structure D activity would therefore be below the estimated existing ambient noise levels. Because parking structure noise would not be expected to perceptibly increase ambient noise levels at nearby sensitive receptors under Alternative D, parking garage activity noise impacts would be less than significant for Alternative D.

Emergency Generator Testing Noise. With regard to emergency generator testing, Alternative D would include one fewer emergency generator. However, the Building 1 generator may be relocated to be slightly closer to the residences south of Tanforan Avenue. Specifically, the proposed location for the 1,250 kW Building 1 generator under Alternative D would be approximately 130 feet north of the nearest residences. Therefore, unattenuated noise levels from intermittent emergency generators would be slightly higher under this alternative than the levels presented for the project. As with the proposed project, even though the testing of emergency generators would be short term (i.e., 30 minutes each time) and intermittent (i.e., approximately once per month), the testing of emergency generators under the Specific Plan and Phase 1 would result in noise levels in excess of applicable municipal code criteria in both San Bruno and South San Francisco. Noise impacts from emergency generator testing would be significant under this alternative, and mitigation would be required. Implementation of project Mitigation Measure NOI-1d would reduce this potentially significant impact related to emergency generator testing noise to a less-than-significant level in both jurisdictions for the project, and for Alternative D.

Construction Vibration. With regard to damage and annoyance-related vibration impacts, since the proximity of construction activities to nearby residences would be similar under this alternative (e.g. along the western terminus of Tanforan Avenue and the southern perimeter of the project site) and since equipment proposed for use would be similar, vibration impacts during construction would also be similar. Specifically, nighttime construction activities would all occur at least 100 feet from the nearest residences and would generate vibration levels well below the “barely perceptible” level. Daytime construction activities would generally occur at the same approximate distances from off-site residential or commercial/office and industrial buildings. Therefore, as is the case with the proposed project, construction activities for Alternative D would result in vibration levels below the applicable damage and annoyance criteria for nearby buildings and sensitive uses. Annoyance and damage-related vibration impacts would be less than significant for Alternative D.

Conclusion. Overall, construction noise impacts under Alternative D (Impact NOI-1a and Impact C-NOI-1) would remain significant and unavoidable and would be similar to those of the project.

Alternative D would reduce but would not avoid the significant and unavoidable project-level and cumulative impacts associated with construction noise for Phase 1 and the project.

Operational noise impacts under Alternative D would be less than significant with mitigation, which is the same conclusion as Phase 1 and the project.

Section 5.8.3.11, Population and Housing
Alternative D would have the same population and housing impacts as the proposed project. The existing property at 80 Tanforan Avenue is an industrial warehouse, and does not include any housing units. Therefore, with the inclusion of this property, Alternative D would not displace existing housing units or people, and no replacement housing would be needed. In addition, a six-level, above-grade parking structure (Parking Structure D) would be constructed under Alternative D, and total building size (approximately 2,800,000 sf) would remain the same as City of South San Francisco Revisions to the Draft EIR
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Responses to Comments 3-63 May 2022
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the proposed project. Therefore, Alternative D would be expected to generate the same number of direct and indirect employees, households, and residents as the proposed project.

Consequently, Alternative D impacts related to population and housing would be the same as that of the proposed project and would be less than significant and less than cumulatively considerable.

Section 5.8.3.12, Public Services
Alternative D would have the same public services impacts as the proposed project. Under Alternative D, building size would be the same as the proposed project, and approximately 2,800,000 sf would be developed. Therefore, Alternative D would be expected to generate the same number of direct and indirect employees, households, and residents as the proposed project that would be added to the City’s police, fire, school, childcare, and library service populations. Therefore, Alternative D impacts related to public services would be the same as that of the proposed project and would be less than significant and less than cumulatively considerable.

Section 5.8.3.13, Recreation
Alternative D would have the same recreation impacts as the proposed project. Under Alternative D, building size would be the same as the proposed project and would offer the same amenities and open spaces such as the Tanforan Avenue Community Parklet (which would be increased in size by 11,545 sf compared with the proposed project), and Southline Commons.

Therefore, impacts related to recreation would be less than significant under Alternative D, the same as under the proposed project. Cumulative impacts related to recreation would also be the same under Alternative D as under the proposed project for the same reasons stated above.

Therefore, cumulative impacts would be less than significant for Alternative D, the same as under the proposed project.

Section 5.8.3.14, Transportation and Circulation11
Alternative D would include the same types of land uses as the proposed project, although at a slightly reduced density. The Reduced Underground Parking Alternative would implement all transportation infrastructure changes identified in Phase 1, including the connection of Sneath Lane and Southline Avenue, the extension of the Centennial Way Trail, and access improvements to the BART Station, consistent with the adopted plans and policies of the City, the City of San Bruno, C/CAG, BART, and MTC. Therefore, Alternative D would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicyclist, and pedestrian facilities, and impacts would be less than significant.

As shown in Table 5-18, p. 5-68, Alternative D would result in a slight reduction in total trip generation compared to the project.
11 The transportation and circulation analysis prepared for Alternative D is based on the Southline Transportation Impact Analysis (TIA) prepared by Fehr & Peers (April 2022), which was updated to incorporate an analysis for the proposed Alternative D. See Appendix 4.15-1 for the updated TIA.

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Table 5-18. Revised Specific Plan Alternative Trip Generation (Office Scenario) Scenario
Phase 1 Buildout
Project
Reduced
Underground
Parking
Alternative Project
Reduced
Underground
Parking
Alternative
Office / R&D 612,700 615,000 2,711,800 2,730,300
Public Restaurant/Retail 16,400 11,800 16,400 11,800
Other Amenities 71,800 57,900 71,800 57,900
Total Active Land Use 700,900 684,700 2,800,000 2,800,000 Vehicle Parking Stalls
(# south of Southline
Avenue)
1,103 to 1,379
(1,103 to 1,194)
1,095
(1,095)
4,594 to 5,395
(1,194)
4,586 to 5,111
(1,095)
Vehicle Trip
Generation
AM 656 617 2,321 2,281
PM 605 565 2,102 2,061
Daily 5,458 4,986 18,380 17,909
Net New
Vehicle Trip
Generation
AM 485 446 2,150 2,110
PM 455 415 1,952 1,911
Daily 3,954 3,482 16,786 16,405
Source: Fehr & Peers, 2022.

Like the project, given its proximity to transit and location on an infill site, Alternative D would qualify for a presumption of less-than-significant impacts to VMT. Total VMT impacts would be less than significant and comparable or slightly reduced compared to those of the proposed project due to the slight reduction in trip generation. Impacts to freeway queuing, hazards at atgrade rail crossings, and transit and pedestrian crowding, all of which would be less than significant under the proposed project, would remain the same under Alternative D.

Alternative D would not substantively change circulation within the Specific Plan area, and therefore, would not pose any design hazards. The primary change associated with the Reduced Underground Parking Alternative would be extending the park walkway along Tanforan Avenue to Dollar Avenue. Otherwise, project driveways would remain in the same locations under Alternative D, including a single right in/right out driveway for Building 2 (the amenities building), a signalized driveway connecting Southline Avenue as the primary garage entrance, and an unsignalized driveway connecting Dollar Avenue as the secondary garage entrance.

Alternative D would have the same access plan as the proposed project. Under Alternative D, access to the shuttle and mobility hubs would occur at the Southline Avenue and Dollar Avenue driveways, along with pedestrian connections to adjacent buildings. No new driveways or other changes to circulation patterns would occur under Alternative D. Therefore, impacts related to design hazards and emergency access would be less than significant, as with the proposed project.

Like the project, Alternative D would result in the Huntington Avenue/Herman Street/Forest Lane intersection meeting the peak hour signal warrant during PM peak hour for both Phase 1 and Specific Plan buildout. Phase 1 would add 11 PM peak hour trips, and Specific Plan buildout would add approximately 301 PM peak hour trips, the same number of trips as the project.

Although Alternative D’s changes related to buildout of Phase 1 would unlikely change the City of South San Francisco Revisions to the Draft EIR
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intersection’s operations, buildout of Alternative D and future phases may exacerbate the risk of collisions at this multi-lane stop-controlled intersection. Therefore, Impact TR-3d and Impact CTR-3d would remain significant and unavoidable under Alternative D, similar to the proposed project at buildout.

Section 5.8.3.15, Tribal Cultural Resources
Alternative D includes similar construction activities as the proposed project with incorporation of Parking Structure D. However, the depth and amount of ground disturbance associated with Alternative D is substantially less than the proposed project. Under Alternative D, with incorporation of Parking Structure D, the two levels of subterranean parking associated with buildout of Phase 1 would be eliminated. The depth of ground disturbance associated with Phase 1 would be significantly less, and therefore impacts to tribal cultural resources impacts would be less than those compared to the proposed project.

However, the overall footprint of the project and associated construction remains similar to the proposed project. Therefore, potential impacts to archaeological resources and human remains that would occur under the proposed project would also occur under Alternative D. These resources can also be considered tribal cultural resources; thus implementation, of Mitigation Measures CR-2a, CR-2b, and CR-3 would continue to apply to Alternative D. Overall, tribal cultural resources impacts would be less than significant with mitigation, and less than those compared to the proposed project.

Section 5.8.3.16, Utilities and Service Systems
The total amount of square footage constructed under Alternative D would be comparable or slightly reduced compared to the project. Therefore, Alternative D would be expected to generate the same or slightly reduced demand for utilities and service systems as the proposed project. Thus, Mitigation Measures UTIL-1 and UTIL-2 would continue to apply to Alternative D.

Alternative D would construct the same utility improvements as the proposed project.

Therefore, with construction of the proposed improvements, additional construction or relocation of utility infrastructure would not be required to serve Alternative D. Overall, impacts to utilities and service systems under Alternative D would be less than significant with mitigation, less than cumulatively contributable with mitigation, and comparable or slightly reduced compared to the project.
* Section 5.8, Comparison of Alternatives, in the draft EIR was renumbered in the final EIR to be Section 5.9. Section 5.9 was revised as follows (new text is underlined and deleted text is strikethrough).

CEQA Guidelines Section 15126.6 requires a comparison of the alternatives to the project (presented above), and suggests that a matrix may be used to summarize the comparison.

Table 5-4, p. 5-43Table 5-19, p. 5-72, compares the significant and less than significant with mitigation impacts of the proposed project to those of the alternatives. Table 5-5, p. 5-47Table 5-20, p. 5-77, compares the ability of the alternatives to meet the objectives of the proposed project.

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* Section 5.9, Environmentally Superior Alternatives in the draft EIR was renumbered in the final EIR to be Section 5.10. The third paragraph of Section 5.10 on page 5-77 was revised as follows (new text is underlined and deleted text is strikethrough).

As shown in Table 5-4,Table 5-19, p. 5-71, Alternative C, Reduced Project Alternative, would reduce, but would not avoid, all of the project’s significant and unavoidable impacts. Alternative C also would not result in any new significant and unavoidable impacts. Alternative D, the Reduced Underground Parking Alternative, would avoid Phase 1’s significant air quality impact related to generator testing (Impact AQ-2b and Impact C-AQ-2), and would also reduce (but would not avoid) all of the project’s remaining significant and unavoidable impacts to below the proposed project’s level of impact, with the exception of significant impacts related to meeting traffic signal warrants at the Huntington Avenue/Herman Street/Forest Lane intersection, which would be similar to the project’s level of impact. Therefore, Alternative CD is the environmentally superior alternative.
* Table 5-4, Comparison of Proposed Project’s Significant Impacts to Alternatives’ Impacts, in the draft EIR was renumbered in the final EIR to be Table 5-19. Table 5-5, Ability of Alternatives to Meet Project Objectives, in the draft EIR was renumbered in the final EIR to be Table 5-20. The tables were revised as follows (new text is underlined and deleted text is strikethrough).

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Table 5-419. Comparison of Proposed Project’s Significant Impacts to Alternatives’ Impacts Potential Environmental Impacts Proposed Project
Alternative A — —No Project
Alternative
Alternative B —No
Intersection Alternative
Alternative C —Reduced
Project Alternative
Alternative D—Reduced
Underground Parking Alternative
Significant and Unavoidable Impacts
Impact AQ-2a: Construction of future Precise Plans under the Specific Plan, not including Phase 1, could result in a cumulatively considerable net increase in criteria pollutants for which the project region is classified as a nonattainment area under an applicable federal (ozone) or state (ozone and particulate matter [PM]) ambient air quality standard during construction.

Significant and Unavoidable No Impact (Less than Project) Significant and Unavoidable (Less than Project)
Significant and Unavoidable
(Less than Project)
Significant and Unavoidable (Less
than Project)
Impact AQ-2b: Project operation, including operation of Phase 1, could result in a cumulatively considerable net increase in criteria pollutants for which the project region is classified as a nonattainment area under an applicable federal or state ambient air quality standard during operation.

Significant and Unavoidable* No Impact (Less than Project) Significant and Unavoidable (Greater than Project)*
Significant and Unavoidable
(Less than Project)*
Significant and Unavoidable (Less
than Project)
Impact AQ-3: The project and Phase 1 could expose sensitive receptors to substantial pollutant concentrations.

Significant and Unavoidable No Impact (Less than Project) Significant and Unavoidable (Similar to Project)
Significant and Unavoidable
(Less than Project)
Significant and Unavoidable (Less
than Project)
Impact C-AQ-2: The project, 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.

Significant and Unavoidable* No Impact (Less than Project) Significant and Unavoidable (Construction: Less than
Project; Operations: Greater
than Project)*
Significant and Unavoidable
(Less than Project)*
Significant and Unavoidable (Less
than Project)
Impact C-AQ-3: The project, inclusive of Phase 1, together with cumulative project identified, could expose sensitive receptors to substantial pollutant concentrations.

Significant and Unavoidable No Impact (Less than Project) Significant and Unavoidable (Less than Project)
Significant and Unavoidable
(Less than Project)
Significant and Unavoidable (Less
than Project)
Impact NOI-1a: Project construction would generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance or applicable standards of other agencies.

Significant and Unavoidable* No Impact (Less than Project) Significant and Unavoidable (Less than Project)*
Significant and Unavoidable
(Less than Project)*
Significant and Unavoidable (Less
than Project)*
Impact C-NOI-1: The project, inclusive of Phase 1, together with the cumulative projects identified would not result in the generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance or applicable standards of other agencies.

Significant and Unavoidable* No Impact (Less than Project) Significant and Unavoidable (Less than Project)*
Significant and Unavoidable
(Less than Project)*
Significant and Unavoidable (Less
than Project)*
Impact TR-3d: The project would contribute to existing hazardous conditions due to project-related traffic, leading to unsignalized intersections meeting signal warrants.

Significant and Unavoidable No Impact (Less than Project) Significant and Unavoidable (Greater than Project)*
Significant and Unavoidable
(Less than Project)
Significant and Unavoidable (Similar
to Project)*
Impact C-TR-3D: The project, together with the cumulative projects identified would contribute to existing hazardous conditions due to project-related traffic, leading to unsignalized intersections meeting signal warrants.

Significant and Unavoidable No Impact (Less than Project) Significant and Unavoidable (Greater than Project)*
Significant and Unavoidable
(Less than Project)
Significant and Unavoidable (Similar
to Project)*
Significant Impacts That Can Be Mitigated to a Less-Than-Significant Level Impact BIO-1:* The project would not have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations or by CDFW or USFWS.

Less than Significant with
Mitigation
No Impact (Less than Project) Less than Significant with Mitigation (Similar to Project)
Less than Significant with
Mitigation (Similar to Project)
Less than Significant with Mitigation
(Greater than Project)
City of South San Francisco Revisions to the Draft EIR
Southline Specific Plan
Responses to Comments 3-68
May 2022
ICF 00082.20
Potential Environmental Impacts Proposed Project
Alternative A — —No Project
Alternative
Alternative B —No
Intersection Alternative
Alternative C —Reduced
Project Alternative
Alternative D—Reduced
Underground Parking Alternative
Impact BIO-4:* The project would not interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.

Less than Significant with
Mitigation
No Impact (Less than Project) Less than Significant with Mitigation (Similar to Project)
Less than Significant with
Mitigation (Similar to Project)
Less than Significant with Mitigation
(Similar to Project)
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.

Less than Cumulatively
Considerable with Mitigation
No Impact (Less than Project) Less than Cumulatively
Considerable with Mitigation
(Similar to Project)
Less than Cumulatively
Considerable with Mitigation
(Similar to Project)
Less than Cumulatively Considerable
with Mitigation (Greater than
Project)
Impact CR-1:* The project would not cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5.

Less than Significant with
Mitigation
No Impact (Less than Project) Less than Significant with Mitigation (Less than Project)
Less than Significant with
Mitigation (Less than Project)
Less than Significant with Mitigation
(Similar to Project)
Impact CR-2:* The project would not cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5.

Less than Significant with
Mitigation
No Impact (Less than Project) Less than Significant with Mitigation (Less than Project)
Less than Significant with
Mitigation (Less than Project)
Less than Significant with Mitigation
(Less than Project)
Impact CR-3:* The project would not disturb any human remains, including those interred outside of formal cemeteries.

Less than Significant with
Mitigation
No Impact (Less than Project) Less than Significant with Mitigation (Less than Project)
Less than Significant with
Mitigation (Less than Project)
Less than Significant with Mitigation
(Less than Project)
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.

Less than Cumulatively
Considerable with Mitigation
No Impact (Less than Project) Less than Cumulatively
Considerable with Mitigation
(Less than Project)
Less than Cumulatively
Considerable with Mitigation
(Less than Project)
Less than Significant with Mitigation
(Less than Project)
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 project construction.

Less than Significant with
Mitigation
No Impact (Less than Project) Less than Significant with Mitigation (Construction: Less
than Project; Operations:

Greater than Project)
Less than Significant with
Mitigation (Less than Project)
Less than Significant with Mitigation
(Less than Project)
Impact GEO-6:* The project would not directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

Less than Significant with
Mitigation
No Impact (Less than Project) Less than Significant with Mitigation (Less than Project)
Less than Significant with
Mitigation (Less than Project)
Less than Significant with Mitigation
(Less than Project)
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.

Less than Cumulatively
Considerable with Mitigation
No Impact (Less than Project) Less than Cumulatively
Considerable with Mitigation
(Less than Project)
Less than Cumulatively
Considerable with Mitigation
(Less than Project)
Less than Cumulatively Considerable
with Mitigation (Less than Project)
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.

Less than Significant with
Mitigation
No Impact (Less than Project) Less than Significant with Mitigation (Construction: Less
than Project; Operations:

Greater than Project)
Less than Significant with
Mitigation (Less than Project)
Less than Significant with Mitigation
(Less than Project)
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.

Less than Significant with
Mitigation
No Impact (Less than Project) Less than Significant with Mitigation (Construction: Less
than Project; Operations:

Greater than Project)
Less than Significant with
Mitigation (Less than Project)
Less than Significant with Mitigation
(Less than Project)
Impact HAZ-2:* The project would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.

Less than Significant with
Mitigation
No Impact (Less than Project) Less than Significant with Mitigation (Less than Project)
Less than Significant with
Mitigation (Less than Project)
Less than Significant with Mitigation
(Similar to Project)
Impact HAZ-4:* The project would not be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, create a significant hazard to the public or the environment.

Less than Significant with
Mitigation
No Impact (Less than Project) Less than Significant with Mitigation (Similar to Project)
Less than Significant with
Mitigation (Similar to Project)
Less than Significant with Mitigation
(Similar to Project)
City of South San Francisco Revisions to the Draft EIR
Southline Specific Plan
Responses to Comments 3-69
May 2022
ICF 00082.20
Potential Environmental Impacts Proposed Project
Alternative A — —No Project
Alternative
Alternative B —No
Intersection Alternative
Alternative C —Reduced
Project Alternative
Alternative D—Reduced
Underground Parking Alternative
Impact HWQ-1:* The project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality.

Less than Significant with
Mitigation
No Impact (Less than Project) Less than Significant with Mitigation (Less than Project)
Less than Significant with
Mitigation (Surface Water:

Similar to Project;
Groundwater: Less than
Project)
Less than Significant with Mitigation
(Surface Water: Greater than Project;
Groundwater: Less than Project)
Impact C-HWQ-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 hydrology and water quality.

Less than Cumulatively
Considerable with Mitigation
No Impact (Less than Project) Less than Cumulatively
Considerable with Mitigation
(Less than Project)
Less than Significant with
Mitigation (Surface Water:

Similar to Project;
Groundwater: Less than
Project)
Less than Significant with Mitigation
(Surface Water: Greater than Project;
Groundwater: Less than Project)
Impact NOI-1b:* Project operation would not generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance or applicable standards of other agencies.

Less than Significant with
Mitigation
No Impact (Less than Project) Less than Significant (Greater than Project)
Less than Significant (Mobile
Noise: Less than Project;
Stationary Noise: Greater than
Project)
Less than Significant with Mitigation
(Similar to Project)
Impact TR-3b: The project would not substantially increase hazards due to freeway ramp queuing.a
Less than Significant No Impact (Less than Project) Significant and Unavoidable (Greater than Project)
Less than Significant (Similar to
Project)
Less than Significant (Similar to
Project)
Impact TR-5b: The project would not have a detrimental impact on bicycle or pedestrian facilities.a
Less than Significant No Impact (Less than Project) Significant and Unavoidable (Greater than Project)
Less than Significant (Similar to
Project)
Less than Significant (Similar to
Project)
Impact TCR-1:* The project would not cause a substantial adverse change in the significance of a tribal cultural resource, defined in PRC Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe and that is listed or eligible for listing in the CRHR or in a local register of historical resources, as defined in PRC Section 5020.1(k), or is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of PRC Section 5024.1.

Less than Significant with
Mitigation
No Impact (Less than Project) Less than Significant with Mitigation (Less than Project)
Less than Significant with
Mitigation (Less than Project)
Less than Significant with Mitigation
(Less than Project)
Impact C-TCR-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 tribal cultural resources.

Less than Cumulatively
Considerable with Mitigation
No Impact (Less than Project) Less than Cumulatively
Considerable with Mitigation
(Less than Project)
Less than Cumulatively
Considerable with Mitigation
(Less than Project)
Less than Significant with Mitigation
(Less than Project)
Impact UTIL-2: The project would not have insufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years.

Less than Significant with
Mitigation
No Impact (Less than Project) Less than Significant with Mitigation (Similar to Project)
Less than Significant with
Mitigation (Less than Project)
Less than Significant with Mitigation
(Less than Project)
* = Impact is also significant for Phase 1.
a
As discussed in Section 5.6, Impact TR-3b, Freeway Queueing, and Impact TR-5b, Crowding at Pedestrian and Bicycle Facilities, would be significant and unavoidable for Alternative B. These impacts would not occur under the proposed project.

City of South San Francisco Revisions to the Draft EIR
Southline Specific Plan
Responses to Comments 3-70
May 2022
ICF 00082.20
Table 5-520. Ability of Alternatives to Meet Project Objectives Project Objective
Alternative A — No Project
Alternative
Alternative B —No Intersection
Alternative
Alternative C — Reduced Project
Alternative
Alternative D — Reduced
Underground Parking Alternative
Create a commercial campus development consistent with the General Plan designation for the Specific Plan area.

No Yes Yes, but reduced compared to project Yes
Promote the City’s ongoing development of its transit-accessible corridors with high-quality development.

No Yes, but reduced compared to project Yes, but reduced compared to project Yes Establish a commercial campus development with sophisticated, unified architectural and landscape design and site planning, resulting in a distinctive campus identity and strong sense of place.

No Yes Yes, but reduced compared to project Yes
Allow for well-designed, flexible buildings and floor plates that can accommodate a variety of commercial building uses over time to ensure that the Specific Plan is responsive to market conditions and demands.

No Yes Yes, but reduced compared to project Yes
Establish flexibility to build the proposed project in phases that respond to market conditions.

No Yes Yes, but reduced compared to project Yes
Redevelop underutilized parcels within the Specific Plan area to realize the highest and best use of the land by increasing the intensity of land uses.

No Yes No Yes
Provide a positive fiscal impact on the local economy through the creation of jobs, enhancement of property values, and generation of property tax and other development fees.

No Yes Yes, but reduced compared to project Yes
Provide well-designed retail and publicly available open spaces to increase local participation and usage of the Specific Plan area.

No Yes Yes Yes
Create new publicly accessible open spaces, including plazas, courtyards, and green spaces within the Specific Plan area.

No Yes Yes Yes
Provide an extensive pedestrian network that links buildings and outdoor recreational spaces through paving, wayfinding signage, street furniture, and lighting.

No Yes Yes Yes
Promote alternatives to automobile transportation to further the City’s transportation objectives by emphasizing public transit linkages, TDM, and pedestrian access and ease of movement between buildings.

No Yes, but reduced compared to project Yes Yes
Create convenient and safe pedestrian and bike access from the Specific Plan area to the San Bruno BART station and the Centennial Way Trail.

No No Yes Yes
Construct a new east-west public street through the Specific Plan area to improve site access and regional roadway circulation, in furtherance of City General Plan policies.

No No Yes Yes
Enhance vehicular, bicycle, and pedestrian circulation and access in the area surrounding the Specific Plan area.

No No Yes Yes
Work cooperatively with relevant agencies to implement off-site improvements with planned regional circulation and safety improvements.

No Yes, but reduced compared to project Yes Yes
Design roadways within and adjacent to the Specific Plan area to ensure that all police, fire, and emergency medical service vehicles can safely and efficiently navigate.

No Yes, but reduced compared to project Yes Yes
Incorporate sustainable and environmentally sensitive design and equipment, energy conservation features, water conservation measures and drought-tolerant or equivalent landscaping, and sustainable stormwater management features.

No Yes Yes Yes
City of South San Francisco Revisions to the Draft EIR
Southline Specific Plan
Responses to Comments 3-71 May 2022
ICF 00082.20
Figures
Figure 4.17-2 in Section 4.17, Utilities and Service Systems, of the draft EIR has been revised. The revised figure is shown on the following page.

ICF Graphics … 00082.20 (12/28/21) JC
Revised Figure 4.17-2
Existing and Proposed Wastewater Infrastructure
Source: Lane Partners, Kimley-Horn & Associates, DES Architects, BKF Engineers, 2021.

City of South San Francisco Revisions to the Draft EIR
Southline Specific Plan
Responses to Comments 3-73 May 2022
ICF 00082.20
Appendices
Revised Appendix 4.15-1, Revised Transportation Impact Analysis Appendix 4.15-1, Transportation Impact Analysis, of the draft EIR, has been replaced in its entirety with the Southline Transportation Impact Analysis prepared for the project by Fehr & Peers in April 2022. The appendix has been renamed Revised Transportation Impact Analysis. The Revised Transportation Impact Analysis includes a new analysis for Alternative D (Reduced Underground Parking Alternative), revisions to Table 7, and new text clarifying that the Traffic Operations Analysis Memorandum accounts for Alternative D.

The revised Appendix 4.15-1 is included in Appendix A of this RTC document.

Revised Appendix 4.17-1, Draft Final Water Supply Assessment As discussed in Section 3.1.1, Appendix 4.17-1, Draft Water Supply Assessment, of the draft EIR, has been replaced in its entirety with the Water Supply Assessment for the Southline Specific Plan, South San Francisco District, California Water Service – Final, prepared for the project by EKI Environment & Water, Inc. in December 2021. The appendix has been renamed Final Water Supply Assessment.

The revised Appendix 4.17-1 is included in Appendix B of this RTC document.

New Appendix 2.1, Revised Southline Specific Plan
The Draft Southline Specific Plan included in Appendix 2 of the draft EIR has been updated to align with Alternative D (Reduced Underground Parking Alternative). The revised Specific Plan has been added to the EIR as new Appendix 2.1 (it does not replace Appendix 2 of the draft EIR). The new appendix is named Revised Southline Specific Plan.

The new Appendix 2.1 is included in Appendix C of this RTC document.

This Page Intentionally Left Blank
Appendix A:

Revised Appendix 4.15-1, Revised Transportation
Impact Analysis

Southline
Transportation Impact Analysis
Prepared for:

City of South San Francisco and ICF
April 2022
SF20-1089
Table of Contents

1. Project Description ................................................................................................................... 1

1.1 Transportation Demand Management Program......................................................................................................6

2. Existing Conditions ................................................................................................................... 7

2.1 Environmental Setting.........................................................................................................................................................7

2.2 Transit Facilities and Service.............................................................................................................................................9

2.2.1 Regional Transit and Shuttle Service.................................................................................................................9

2.3 Pedestrian and Bicycle Facilities....................................................................................................................................12

3. Analysis Methodology............................................................................................................ 16

3.1 Recent Changes to CEQA ................................................................................................................................................16

3.2 Significance Criteria ...........................................................................................................................................................17

3.2.1 Vehicle Miles Traveled (VMT).............................................................................................................................17

3.2.2 Design Hazards ........................................................................................................................................................18

3.2.3 Emergency Vehicle Access ..................................................................................................................................18

3.2.4 Bicycle, Pedestrian, and Transit .........................................................................................................................18

3.3 Analysis Scenarios...............................................................................................................................................................19

3.3.1 Existing Conditions (Pre-COVID-19)................................................................................................................19

3.3.2 2024 Baseline............................................................................................................................................................19

3.3.3 2024 Baseline Plus Project Phase 1 Conditions...........................................................................................20

3.3.4 Cumulative 2040 Conditions ..............................................................................................................................20

3.3.5 Cumulative 2040 Plus Project Conditions .....................................................................................................21

3.4 Travel Demand Model Methodology .........................................................................................................................21

3.5 Trip Generation, Distribution, and Assignment ......................................................................................................21

3.5.1 Trip Generation........................................................................................................................................................22

3.5.2 Project Vehicle Trip Distribution, and Project Vehicle Trip Assignment ...........................................27

3.6 Multimodal Analysis Methodology .............................................................................................................................38

4. Transportation Analysis.......................................................................................................... 39

4.1 Plan & Policy Consistency Review................................................................................................................................39

4.1.1 City of South San Francisco Plans and Policies ...........................................................................................39

4.1.2 City of San Bruno Plans and Policies ...............................................................................................................42

4.1.3 Regional Plans and Policies.................................................................................................................................44

4.1.4 Policy Consistency Analysis.................................................................................................................................45

4.2 VMT Analysis ........................................................................................................................................................................46

4.3 Site Plan Analysis ................................................................................................................................................................48

4.3.1 Multimodal Analysis...............................................................................................................................................48

4.3.2 Signal Warrant Analysis ........................................................................................................................................53

4.3.3 Phase 1 At-Grade Rail Crossing Analysis .......................................................................................................53

4.4 Offsite Transportation Analysis .....................................................................................................................................55

4.4.1 Signal Warrant Analysis ........................................................................................................................................55

4.4.2 Freeway Ramp Queuing Analysis .....................................................................................................................56

4.4.3 Transit Performance Analysis .............................................................................................................................59

4.4.4 Bicycle and Pedestrian Analysis.........................................................................................................................62

4.4.5 Emergency Vehicle Analysis................................................................................................................................62

5. Impacts and Mitigations......................................................................................................... 63

5.1 Vehicular Traffic...................................................................................................................................................................63

5.1.1 Vehicle Miles Traveled ..........................................................................................................................................63

5.2 Design Hazards....................................................................................................................................................................64

5.2.1 Geometric Design Hazards..................................................................................................................................64

5.2.2 Freeway Ramp Queuing .......................................................................................................................................64

5.2.3 At-Grade Rail Crossings........................................................................................................................................64

5.2.4 Traffic Signal Warrant............................................................................................................................................65

5.3 Emergency Vehicle Access ..............................................................................................................................................66

5.4 Bicycle, Pedestrian, and Transit.....................................................................................................................................67

6. Partial Circulation Network Alternative ............................................................................... 69

6.1 Plan and Policy Consistency Analysis..........................................................................................................................69

6.2 VMT Analysis ........................................................................................................................................................................69

6.3 Site Plan Analysis ................................................................................................................................................................70

6.3.1 Design Hazards ........................................................................................................................................................70

6.3.2 Signal Warrant Analysis ........................................................................................................................................70

6.3.3 At-Grade Rail Crossing Analysis ........................................................................................................................70

6.4 Offsite Transportation Analysis .....................................................................................................................................73

6.4.1 Signal Warrant Analysis ........................................................................................................................................73

6.4.2 Freeway Ramp Queueing Analysis ...................................................................................................................73

6.4.3 Transit Performance Analysis .............................................................................................................................76

6.4.4 Bicycle and Pedestrian Analysis.........................................................................................................................76

6.4.5 Emergency Vehicle Analysis................................................................................................................................78

6.5 Impacts and Mitigations ..................................................................................................................................................78

6.5.1 Vehicular Traffic .......................................................................................................................................................78

6.5.2 Design Hazards ........................................................................................................................................................78

6.5.3 Bicycle, Pedestrian, and Transit .........................................................................................................................82

7. Reduced Underground Parking Alternative......................................................................... 85

7.1 Plan and Policy Consistency Analysis..........................................................................................................................86

7.2 VMT Analysis ........................................................................................................................................................................86

7.3 Site Plan Analysis ................................................................................................................................................................86

7.3.1 Signal Warrant Analysis ........................................................................................................................................87

7.3.2 At-Grade Rail Crossing Analysis ........................................................................................................................87

7.4 Offsite Transportation Analysis .....................................................................................................................................87

7.4.1 Signal Warrant Analysis ........................................................................................................................................87

7.4.2 Freeway Ramp Queueing Analysis ...................................................................................................................89

7.4.3 Transit Performance Analysis .............................................................................................................................89

7.4.4 Bicycle and Pedestrian Analysis.........................................................................................................................89

7.4.5 Emergency Vehicle Analysis................................................................................................................................89

7.5 Impacts and Mitigations ..................................................................................................................................................89

7.5.1 Vehicular Traffic .......................................................................................................................................................89

7.5.2 Design Hazards ........................................................................................................................................................90

7.5.3 Bicycle, Pedestrian, and Transit .........................................................................................................................93 Appendices
• Vehicle Miles Traveled Analysis for Greenhouse Gas Analysis • Traffic Operations Analysis Memorandum
• Traffic Operations Reports
List of Figures
Figure 1-1. Project Location & Study Area.................................................................................................................................3 Figure 1-2. Project Site Plan – Phase 1.........................................................................................................................................4 Figure 1-3. Project Site Plan – Buildout.......................................................................................................................................5 Figure 2-1. Transit Facilities........................................................................................................................................................... 11 Figure 2-2. Bicycle Facilities........................................................................................................................................................... 14 Figure 2-3 Pedestrian Circulation Barriers ............................................................................................................................... 15 Figure 3-1. Vehicle Trip Distribution – Summary by County............................................................................................ 28 Figure 3-2. Phase 1 Trip Distribution/Assignment – AM Peak Hour............................................................................. 29 Figure 3-3. Phase 1 Trip Distribution/Assignment – PM Peak Hour............................................................................. 30 Figure 3-4. Project Buildout Trip Distribution/Assignment – AM Peak Hour............................................................ 31 Figure 3-5. Project Buildout Trip Distribution/Assignment – PM Peak Hour............................................................ 32 Figure 3-6. Phase 1 Volume Difference – AM Peak Hour.................................................................................................. 33 Figure 3-7. Phase 1 Volume Difference – PM Peak Hour.................................................................................................. 34 Figure 3-8. Project Buildout Volume Difference – AM Peak Hour................................................................................. 35 Figure 3-9. Project Buildout Volume Difference – PM Peak Hour ................................................................................. 36 Figure 3-10. Study Locations ........................................................................................................................................................ 37 Figure 4-1. South San Francisco General Plan (1999) – Proposed Streets.................................................................. 39 Figure 4-2 Project Improvement Locations ............................................................................................................................ 50 Figure 4-3. Pedestrian Space during AM and PM Peak Hours........................................................................................ 51 Figure 6-1. Partial Circulation Network Alternative Site Plan .......................................................................................... 71 Figure 6-2. Pedestrian Space during AM and PM Peak Hours, Project Buildout with Partial Circulation Network Alternative ................................................................................................................................................ 77 Figure 7-1. Reduced Underground Parking Alternative Site Plan.................................................................................. 88 List of Tables
Table 1-1. Project Land Use by Phase, Office Scenario .........................................................................................................2 Table 2-1. BART and SamTrans Service at the San Bruno BART Station ..................................................................... 10 Table 3-1. Person Trip Generation | Phase 1 .......................................................................................................................... 24 Table 3-2. Vehicle Trip Generation | Phase 1.......................................................................................................................... 25 Table 3-3. Person Trip Generation | Project Buildout.......................................................................................................... 26 Table 3-4. Vehicle Trip Generation | Project Buildout......................................................................................................... 27 Table 4-1. VMT Effects of Southline Avenue Extension within South San Francisco and San Bruno .............. 48 Table 4-2: Pedestrian Space Crowding Scale ......................................................................................................................... 49 Table 4-3: Signal Warrant Analysis ............................................................................................................................................. 53 Table 4-4. Queuing at Linden Avenue At-Grade Rail Crossing – 2040 Project Buildout ...................................... 55 Table 4-5. Existing and 2024 Weekday AM and PM Peak Hour 95th Percentile Queues..................................... 57 Table 4-6. 2040 Weekday AM and PM Peak Hour 95th Percentile Queues .............................................................. 58 Table 4-7. Average ECR Travel Times between El Camino Real and the San Bruno BART Station................... 60 Table 4-8. Project Buildout Effect on Total Activity at San Bruno BART Station...................................................... 61 Table 6-1. Queuing at Linden Avenue At-Grade Rail Crossing – Partial Circulation Network Alternative (2040 Project Buildout)........................................................................................................................................... 72 Table 6-2. Queuing at Scott Street At-Grade Rail Crossing – Partial Circulation Network Alternative (2040 Project Buildout) ....................................................................................................................................................... 73 Table 6-3. Weekday AM and PM Peak Hour 95th Percentile Queues – Partial Circulation Network Alternative (Phase 1) ............................................................................................................................................... 74 Table 6-4. Cumulative Weekday AM and PM Peak Hour 95th Percentile Queues - Partial Circulation Network Alternative (Project Buildout)............................................................................................................ 75 Table 7-1. Phase 1 Project vs. Reduced Underground Parking Alternative ............................................................... 85 Appendix Table: VMT Totals for GHG Analysis...................................................................................................................... 96 Southline Specific Plan
Transportation Impact Analysis
April 2022
1 1. Project Description
This transportation impact analysis (TIA) evaluates potential transportation effects associated with the Southline Specific Plan and associated transportation infrastructure changes (“Project”). The Project would redevelop a 26.5-acre industrial site in the City of South San Francisco’s Lindenville District, adjacent to the San Bruno Bay Area Rapid Transit (BART) rail station. The Project would demolish all existing on-site uses and construct a transit-oriented office/research and development (R&D) campus with a maximum anticipated building area of 2.8 million square feet. New development would include about 2.8 million square feet of office/R&D and amenity space serving up to about 11,000 employees; approximately 4,594 to 5,769 parking spaces; a new east-west street connection between Sneath Lane and South Linden Avenue (referred to as “Southline Avenue”); supportive utilities and related infrastructure; and open space. The Project would also modify off-site transportation infrastructure including constructing a new intersection connecting Sneath Lane, Huntington Avenue, Maple Avenue, and Southline Avenue; extending the Centennial Way Trail to the San Bruno BART Station; providing a signalized driveway to the SamTrans Transit Center; and enhancing pedestrian access to the San Bruno BART station with new bulbouts and high visibility crosswalks. Most of this off-site transportation infrastructure is located within the City of South San Francisco; however, certain improvements, including portions of the new intersection connecting Sneath Lane, Huntington Avenue, and Maple Avenue, are located in the City of San Bruno.

Development associated with the Project would be implemented under the proposed Southline Specific Plan, which would establish new land use development standards and design guidelines for development within the Specific Plan extents. A phased development process for buildout of the Specific Plan is anticipated. Phase 1 would include construction of the new Southline Avenue east-west connection road described above and the following development, most of which will be development south of the new Southline Avenue: two new office/R&D buildings with a total building area of up to approximately 613,000 square feet; the four-story, approximately 88,000-square foot amenity building (with some ground floor uses open to the public); approximately 1,103 to 1,379 parking spaces in a combination of below-grade parking and the eastern portion of a parking structure (located north of the new Southline Avenue); and landscaping and open space amenities. Phase 1 also includes the majority of the onsite and off-site infrastructure, roadway and pedestrian/bicycle circulation improvements. The remaining development allowed under the Specific Plan is anticipated to occur in later phases.

As a transit-oriented development fully within a ½ mile walkshed of the San Bruno BART Station and SamTrans ECR bus route, the Project is presumed to have a less than significant vehicle miles traveled (VMT) impact under the City of South San Francisco’s adopted VMT Thresholds (City Council Resolution 77-2020).

VMT analysis is presented in Section 4.2.

Project land use and infrastructure by development Phase 1s shown in Table 1-1. The Project location and study area, Phase 1 Project site plan, and Project Buildout site plan are shown in Figure 1-1, Figure 1-2, and Figure 1-3, respectively.

Southline Specific Plan
Transportation Impact Analysis
April 2022
2 Table 1-1. Project Land Use by Phase, Office Scenario Scenario Phase 1 Future Phases Total at Buildout
Office / R&D 612,715 2,099,085 2,711,800
Public Restaurant/Retail 16,400 0 16,400
Cafeteria (Private) 9,000 0 9,000
Fitness Center (Private) 49,000 0 49,000
Auditorium/Other (Private) 13,800 0 13,800
Total Active Land Use 700,915 2,099,085 2,800,000
Vehicle Parking Stalls 1,103 to 1,379 3,491 to 4,390 4,594 to 5,769 Long-Term Bicycle Parking Spaces 188 572 760
Short-Term Bicycle Parking Spaces 18 42 60
Notes:

1. The Project includes two land use scenarios – an office use and a life science use. For purposes of this analysis, the office use was analyzed to reflect a land use with a higher trip generation and more employees.

2. The ground floor restaurant/retail would be a public use. All other amenity uses would be for the private use of Project tenants.

Source: ICF, 2020.

Crestmoor
Canyon
3101
West Orange Avenue
Chestnut Av
South Airport Boulevard
Westborough Bl
El Camino Real
San Bruno Avenue West
y Wr obr aH
South Linden Avenue El Camino Real
Orange Avenue
Grand Avenue
Huntington Av
North Mcdonnell Road
Country Club Drive
DubuqueAv
Utah Avenue
Gateway Bl
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Linden Av
San Bruno Avenue East
South Spruce Avenue
ProduceAv
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Avalon Drive
Mitchell Avenue
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27 18 19 22
23 11 16
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\\Fpsf03.fpainc.local\data\Projects\2020_Projects\SF20-1089_Southline EIR\Graphics\GIS\MXD\CA_Template_LetterPortrait.mxd Project Location
Figure 1-1
Project Site
New Street - Southline Avenue
City Boundary
Caltrain Station
BART Station
South Maple
Avenue
Hun�ngton Avenue
Sea
Sco� St
Miller Av
Baden Av
Biscuit Av
Airport Bl
San Mateo Av
San
Bruno
South
San Francisco

DOWNTOWN

DOWNTOWN

LINDENVILLE

BAYHILL
Tanforan
Shopping
Center
Orange
Memorial
Park

0.5 mi
Site Plan
Figure 1-2
\\Fpsf03.fpainc.local\data\Projects\2020_Projects\SF20-1089_Southline EIR\Graphics\GIS\MXD\CA_Template_LetterPortrait.mxd Project Buildout Site Plan
Figure 1-3
\\Fpsf03.fpainc.local\data\Projects\2020_Projects\SF20-1089_Southline EIR\Graphics\GIS\MXD\CA_Template_LetterPortrait.mxd Southline Specific Plan
Transportation Impact Analysis
April 2022
6 1.1 Transportation Demand Management Program
The Project includes a transportation demand management (TDM) program designed to reduce the Project’s single-occupancy vehicle trips and parking demand consistent with the goals set forth in the City’s municipal code. The Project Sponsor has developed a Preliminary TDM program designed to achieve a 45 percent alternative mode share, consistent with City requirements for projects proposing a floor area ratio (FAR) up to 2.5 (per Chapter 20.400 of the City’s Zoning Ordinance). The preliminary TDM Plan includes a number of program measures to build upon the proposed infrastructure and on-site facilities in order to reduce single-occupancy vehicle trips to meet the required 45 percent alternative mode share target. The specific measures have not been determined as they will depend significantly on tenant needs, market and technological conditions at the time of development, and in some instances, review and approval of other agencies. Project-specific Draft TDM Plans will be required for each project phase as part of the entitlements approval, and Final TDM Plans will be provided as part of the building permit process. TDM measures may include:
• Direct Access to Transit – The Project’s access improvements to the San Bruno BART Station and SamTrans Transit Center enable convenient use of BART and bus service. • Shuttle Service to Caltrain – The TDM program may provide first/last mile shuttle service for employees to the South San Francisco and/or San Bruno Caltrain stations. • Carpooling & Vanpooling Services – The TDM program would offer ride-matching services for carpools and vanpools users thorough 511.org and/or other programs; and provide reserved parking spaces for such vehicles.
• Other TDM program features – The TDM program would include a range of features such as a computer app-based commute monitoring system, carshare program; guaranteed ride home program; onsite kiosks and information boards displaying transportation options available for employees; onsite showers and changing rooms; and TDM coordinator(s).

As required by the City of South San Francisco Municipal Code, the Final TDM Plan would include requirements for monitoring and auditing the performance of the measures, which may be revised or amended as needed to meet the TDM performance objectives. Implementation of the Final TDM Plan would be monitored annually and adjusted accordingly, if necessary, in order to meet the required mode share targets. Leases for all tenants would include provisions regarding the mandatory TDM measures and appointment of a TDM coordinator (which may be shared among multiple tenants).

Southline Specific Plan
Transportation Impact Analysis
April 2022
7 2. Existing Conditions
This section describes the existing transportation and circulation setting in the vicinity of the Project site:
the existing roadway network, transit network and service, pedestrian conditions, and bicycle conditions.

Descriptions provided in this section reflect conditions prior to changes associated with the COVID-19 pandemic, which has resulted in reduced travel and changes to transit services.

2.1 Environmental Setting
The Project site is transit-oriented, located within proximity to the San Bruno BART station (across Huntington Avenue) and the South San Francisco and San Bruno Caltrain stations (both within one mile of the Project site). The Project site is located at the northeast corner of the Sneath Avenue and Huntington Avenue intersection in the City of South San Francisco at the city’s boundary with the City of San Bruno.

Under existing conditions, the Project site is not accessible from Huntington Avenue, as there is no vehicular connection to Tanforan Avenue. Instead, regional access to the site under existing conditions is provided via US-101 and I-380, with vehicles connecting to Maple Avenue, Dollar Avenue, or South Linden Avenue via surface streets. Figure 1-1 shows the Project location and the surrounding roadway system. The Project includes construction of a new street (Southline Avenue) connecting the Project site to Huntington Boulevard at the intersection with Sneath Avenue.

Key local roadways in the vicinity of the Project are described below:
• I-380 is an approximately 1.7-mile eight-lane freeway linking I-280 to the west and US-101 to the east. I-380 is located approximately one half-mile south of the Project site and provides the closest freeway access to the Project via El Camino Real (SR-82). Near the Project, I-380 carries about 170,000 vehicles per day.
• I-280 is an eight-lane north-south freeway connection between San Francisco to San Jose that follows the western urbanized edge of the San Francisco Peninsula. At the freeway’s north and south endpoints, the route directly serves Daly City, Colma, and southwestern San Francisco neighborhoods. I-280 is located approximately 1.25 miles west of the Project site. Near the Project, I-280 carries about 200,000 vehicles per day. I-280 may be accessed via ramps at Sneath Lane and San Bruno Avenue.
• US-101 is an eight-lane freeway and principle north-south roadway connection between San Francisco, San Jose, and intermediate San Francisco Peninsula cities. US-101 is located approximately one half-mile east of the Project site. Near the Project, US-101 carries about 265,000 vehicles per day. US-101 may be accessed via ramps at San Bruno Avenue, Produce Avenue/South Airport Boulevard, and Grand Avenue.
• El Camino Real (SR-82) is a north-south arterial roadway and State Highway that spans the San Francisco Peninsula between San Francisco and San Jose. It has six travel lanes in the vicinity of the Southline Specific Plan
Transportation Impact Analysis
April 2022
8 Project site and connects with I-380 approximately one half mile from the Project site, providing regional vehicle access in all directions. El Camino Real carries about 45,000 vehicles per day. • Huntington Avenue is a north-south arterial and local roadway within the City of San Bruno that parallels the Caltrain corridor between Sneath Lane to the north San Felepe Avenue to the south.

The San Bruno General Plan classifies the roadway as an arterial between Sneath Lane and San Mateo Avenue and as a local street south of San Mateo Avenue. Huntington Avenue East is a oneway residential street that runs alongside Huntington Avenue. • South Linden Avenue is a north-south collector roadway within the City of South San Francisco that connects Downtown South San Francisco to the north at Airport Boulevard with the Lindenville Area and the City of San Bruno to the south at San Mateo Avenue. South Linden Avenue includes an atgrade rail crossing of Caltrain. • Sneath Lane is an east-west local and arterial roadway within the City of San Bruno that connects Sweeny Ridge open space to the west and Huntington Avenue to the East. The road intersects and provides access to three major north-south regional roadways: Skyline Boulevard (SR-35), I-280, and El Camino Real (SR-82) and is one of the primary Project access roadways. The City of San Bruno General Plan classifies the roadway as an arterial east of SR-35 and a local street to the west of SR-35.
• San Bruno Avenue is a four-lane east-west arterial roadway within the City of San Bruno. San Bruno Avenue provides freeway access to both I-280 and US 101. • South Maple Avenue is a two lane north-south collector street within South San Francisco that primarily provides access to destinations within the Lindenville industrial district between South Canal Street to the north and Tanforan Avenue to the south. The roadway will provide direct access to the Project site’s northern and western edges and connect with Southline Avenue and Huntington Avenue.
• Dollar Avenue and Herman Street comprise a two lane north-south collector street within the City of South San Francisco and City of San Bruno, respectively, alongside the Caltrain railroad corridor and eastern edge of the Project site. Dollar Avenue and Herman Street function as the primary connection between Lindenville and the City of San Bruno to the west of the Caltrain railroad corridor, connecting to South Linden Avenue and Huntington Avenue. • Scott Street is a two lane, east-west local street in the City of San Bruno connecting Herman Street and San Mateo Avenue. Scott Street includes an at-grade rail crossing of Caltrain. • Tanforan Avenue is a two lane, local street at the border of South San Francisco and San Bruno that connects Maple Avenue and Dollar Avenue/Herman Street. Tanforan Avenue serves a mix of local residential trips and truck traffic to industrial sites in Lindenville. • Southline Avenue (South Linden Avenue Extension) is identified in the City of South San Francisco’s General Plan as a new, approximately 1,500-foot long roadway connection between Sneath Lane and South Linden Avenue. The Project includes the roadway alignment as envisioned in the General Plan.

Southline Specific Plan
Transportation Impact Analysis
April 2022
9 2.2 Transit Facilities and Service
The Project site is directly served by the San Bruno BART station located across Huntington Avenue, and SamTrans buses at the San Bruno BART Transit Center, which is within one half mile from all buildings on the Project site. The Project is within about three-quarters of one mile of the San Bruno Caltrain station and

1.5 mile of the South San Francisco Caltrain station as well. The existing transit services are shown on Figure 2-1 and described in detail below.

2.2.1 Regional Transit and Shuttle Service
The following transit services operate within the City of South San Francisco and City of San Bruno:
• Bay Area Rapid Transit (BART) provides regional rail service between the East Bay, San Francisco, and San Mateo County, connecting between San Francisco International Airport and Millbrae Intermodal Station to the south, San Francisco to the north, and Oakland, Richmond, Pittsburgh/Bay Point, Dublin/Pleasanton and Fremont in the East Bay. The San Bruno Station is located adjacent to the Project site. During weekday peak commute periods, the station is served by the RichmondMillbrae and Antioch-San Francisco International Airport lines, both of which operate on 15-minute headways with a combined headway of 7.5 minutes throughout the day. During off-peak periods, the station is served by the Antioch-San Francisco International Airport line which operates every 20 minutes.
• Caltrain provides passenger rail service on the Peninsula between San Francisco and San Jose, and limited service trains to Morgan Hill and Gilroy during weekday commute periods. Caltrain operates five trains per hour, per direction during peak periods. The Peninsula Corridor Electrification Project is currently under construction to increase Caltrain service levels to six trains per hour per direction during peak periods, to provide faster, more frequent service. The Peninsula Corridor Electrification Project is anticipated to be completed by 2022. The Project site is near two Caltrain stations:
◦ South San Francisco Caltrain Station: The station is currently located approximately 1.5 mile north of the Project site at 590 Dubuque Avenue, on the east side of US-101, immediately north of East Grand Avenue. In 2021, Caltrain plans to open a relocated South San Francisco Caltrain Station near the Grand Avenue/Airport Boulevard intersection. The South San Francisco Caltrain station will be served by 23 northbound and 23 southbound local or limited trains during a typical weekday. Service is expected to increase upon completion of the Peninsula Corridor Electrification Project in 2022.
◦ San Bruno Caltrain Station: The station is located approximately three-quarter miles directly south of the Project site at the intersection of San Bruno Avenue and Huntington Avenue, within Downtown San Bruno. The station is served by 26 northbound and 26 southbound local or limited trains during a typical weekday. Service is expected to increase upon completion of the Peninsula Corridor Electrification Project in 2022.
• SamTrans provides bus service in San Mateo County and serves the Project site. The SamTrans Transit Center is located at the San Bruno BART station, located adjacent to the Project site. The Southline Specific Plan
Transportation Impact Analysis
April 2022
10 SamTrans Transit Center is located less than one-half mile from all proposed buildings at the Project site and is served by routes ECR, 140, 141, and 398. A shuttle to the San Bruno Bayhill Office Park also operates during peak periods. The SamTrans service span and average peak hour frequencies are summarized in Table 2-1.

Table 2-1. BART and SamTrans Service at the San Bruno BART Station Route Service Endpoints Service Span Average Peak Hour
Frequency
BART Red Line Richmond Station-Millbrae Station via
Oakland and San Francisco
5:15 AM to 12:00 AM (NB)
6:00 AM to 1:30 AM (SB) 15 minutes
BART Yellow Line
Pittsburg Bay Point & Antioch Stations-San
Francisco International Airport Station via
Oakland and San Francisco
5:15 AM to 12:00 AM (NB)
6:00 AM to 1:30 AM (SB) 15 minutes
SamTrans ECR Daly City BART / Palo Alto Transit Center via El Camino Real 5:15 AM to 1:00 AM 15 minutes
SamTrans 140 Pacifica / San Francisco International Airport 6:30 AM to 12:00 AM 30 minutes SamTrans 141 Shelter Creek (San Bruno) / Airport & Linden (South San Francisco) 6:45 AM to 7:45 PM 30 minutes
SamTrans 398 Redwood City Transit Center / Downtown
San Francisco 5:00 AM to 11:00 PM 60 minutes
Bayhill Shuttle San Bruno BART Station to Bayhill Office Park
7:00 AM to 10:00 AM,
4:00 PM to 6:40 PM 15 Minutes
Notes: Table summarizes conditions prior to COVID-19. The Bayhill Shuttle is operated independently through SamTrans’ shuttle program and is open to the public.

Source: Fehr & Peers; SamTrans, 2020.

Southline Specific Plan
Transportation Impact Analysis
April 2022
12 2.3 Pedestrian and Bicycle Facilities
This section reviews existing pedestrian and bicycle conditions. Pedestrian facilities include sidewalks, crosswalks, trails, and pedestrian signals. Bicycle facilities consist of separated bikeways, bicycle lanes, routes, trails, and paths, as well as bike parking, bike lockers, and showers for cyclists. Caltrans recognizes four classifications of bicycle facilities:
• Class I – Shared-Use Pathway: Provides a completely separated right-of-way for the exclusive use of cyclists and pedestrians.
• Class II – Bicycle Lane: Provides a striped lane for one-way travel on a street or highway. May include a “buffer” zone consisting of a striped portion of roadway between the bicycle lane and the nearest vehicle travel lane.
• Class III – Bicycle Route: Provides for shared use with motor vehicle traffic; however, are often signed or include a striped bicycle lane.
• Class IV – Separated Bikeway: Provides a right-of-way designated exclusively for bicycle travel adjacent to a roadway and which are protected from vehicular traffic. Types of separation include, but are not limited to, grade separation, flexible posts, inflexible physical barriers, or on-street parking.

The following pedestrian and bicycle facilities are present near the Project site. Existing and proposed bicycle facilities are shown on Figure 2-2.
• Sneath Lane in San Bruno has sidewalk on both sides of the street and intermittent Class II bike lanes. Bike lanes are present west of El Camino and along a two-block segment between Sea Biscuit Avenue to Huntington Avenue, but a gap occurs between El Camino Real and Sea Biscuit Avenue. • The Centennial Way Trail is a Class I shared pedestrian and bicycle pathway in South San Francisco along the BART tunnel alignment. It connects the South San Francisco BART Station with schools, parks, and neighborhoods within the City. It presently terminates adjacent to the Project site about 400 feet north of the San Bruno BART Station.
• Huntington Avenue is a designated Class III bicycle route in San Bruno and South San Francisco and has sidewalks on both sides of the street.
• Tanforan Avenue is a designated Class III bicycle route and has sidewalks on both sides of the street. • South Linden Avenue is a designated Class III bicycle route with sidewalks on both sides of the street. • Dollar Avenue/Herman Street is a designated Class III bicycle route and has sidewalks on the west side of the street only.
• Maple Avenue is not designated as a bicycle facility and has a sidewalk along the east side of the street only alongside the Project site.

Under existing conditions, the Project site is located in a mostly auto-oriented industrial and commercial area with several barriers to walking and bicycling, shown in Figure 2-3. Specifically, the following challenges to bicycle and pedestrian circulation exist:

Southline Specific Plan
Transportation Impact Analysis
April 2022
13 • Access barriers to the San Bruno BART Station: When exiting the San Bruno BART Station walking or biking toward the Project site, pedestrians and bicyclists encounter Huntington Avenue, a wide multilane arterial street with narrow sidewalks and no dedicated bicycle facilities. There is no marked crosswalk directly connecting the BART Station entrance and the eastern sidewalk along Huntington Avenue, so pedestrians instead must cross two legs of the intersection to walk across the street. Both crosswalks have actuated pedestrian crossings, which add delay to pedestrians by defaulting to a “Don’t Walk” signal during a green light unless a button is pushed in advance. • Centennial Way Trail Gap: The Centennial Way Trail terminates 400 feet north of the San Bruno BART station and connects to the narrow sidewalk on the east side of Huntington Avenue.

Pedestrians and bicyclists share this narrow sidewalk space, which meanders alongside Huntington Avenue and Huntington Avenue East with relatively abrupt changes in grade. • Narrow sidewalks with obstructions, limited pedestrian-scaled lighting, unmarked crosswalks, and lack of accessible curb ramps: Although sidewalks are present on most streets, pedestrians contend with indirect routes along narrow facilities that at times are inaccessible to mobility-impaired pedestrians. Areas of particular concern related to the Project include: the grade changes for the narrow eastern sidewalk along Huntington Avenue, the lack of curb ramps and marked crosswalks across Tanforan Avenue and Maple Avenue, the lack of a direct pedestrian and bicycle crossing between the Centennial Way Trail and SamTrans Transit Center at the San Bruno BART Station, and the omission of a southern crosswalk across Huntington Avenue at the San Bruno BART Station entrance. Pedestrian conditions are illustrated on Figure 2-3. • Lack of bicycle connectivity: While some bike trail and bike lane facilities are present near the Project site as shown in Figure 2-2. However, there is limited connectivity between dedicated bicycle facilities and to major destinations. For example, bike lanes along Sneath Lane do not connect to the Centennial Way Trail; the Centennial Way Trail does not connect to the San Bruno BART Station or elsewhere in San Bruno; and there is no dedicated connection between the Project site and downtown South San Francisco. Consequently, bicyclists who seek to access the Project site must share street space with cars and trucks operating on streets with posted speed limits of 25 to 30 MPH.

Crestmoor
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West Orange Avenue
Chestnut Av
South Airport Boulevard
Westborough Bl
El Camino Real
San Bruno Avenue West
y Wr obr aH
South Linden Avenue El Camino Real
Orange Avenue
Grand Avenue
Huntington Av
North Mcdonnell Road
Country Club Drive
DubuqueAv
Utah Avenue
Gateway Bl
Sneath Lane
Linden Av
San Bruno Avenue East
South Spruce Avenue
ProduceAv
EastGrandAv
eunevA oet a MnaS
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\\Fpsf03.fpainc.local\data\Projects\2020_Projects\SF20-1089_Southline EIR\Graphics\GIS\MXD\CA_Template_LetterPortrait.mxd Bicycle Facilities
Figure 2-2
Project Site
Class II Bicycle Lane
Class I Shared Path Class I Shared Path
Class II Bicycle Lane
Class III Bicycle Route Class III Bicycle Route
Class IV Separated Bikeway
New Street - Southline Avenue
City Boundary
Existing Bikeways Planned Bikeways
San
Bruno
South
San Francisco

DOWNTOWN

DOWNTOWN

LINDENVILLE

BAYHILL
Tanforan
Shopping
Center
Orange
Memorial
Park
South Maple
Avenue
Hun�ngton Avenue
Sea
Sco� St
Miller Av
Baden Av
Biscuit Av
Airport Bl
San Mateo Av
N:\Projects\2020_Projects\SF20-1089_Southline EIR\Graphics Pedestrian Circulation Barriers
Figure 2-3
Slip-lane and
indirect crosswalk
configuration
Crosswalk and
ramp from
Centennial Trail to
project site needs
improvement
Centennial Trail
transitions to
narrow crosswalk
Narrow sidewalk
Unmarked crosswalk to
BART Station Entrance
Missing crosswalks
Missing ramps
Lack of accessible
crosswalk to
Centennial Way Trail
Project Site
Southline Specific Plan
Transportation Impact Analysis
April 2022
16 3. Analysis Methodology

3.1 Recent Changes to CEQA
Senate Bill (SB) 7431, codified in Section 21099 of the California Public Resources Code, intends to better align California Environmental Quality Act (CEQA) transportation impact analysis practices and mitigation outcomes with the State’s goals to reduce greenhouse gas (GHG) emissions, encourage infill development, and improve public health through more active transportation. SB 743 creates several key statewide changes to CEQA as described below.

First, SB 743 requires the Governor’s Office of Planning and Research (OPR) to establish new metrics for determining the significance of transportation impacts of Projects within transit priority areas (TPAs)2 and allows OPR to extend use of these metrics beyond TPAs. OPR selected vehicle miles traveled (VMT) as the preferred transportation impact metric and applied their discretion to require its use statewide.

Second, SB 743 establishes that aesthetic and parking impacts of a residential, mixed-use residential, or employment center Projects
3 on an infill site4 within a TPA shall not be considered significant impacts on the environment.

Third, the new CEQA Guidelines that implement SB 743 requirements state that vehicle level of service (LOS) and similar measures related to auto delay shall not be used as the sole basis for determining the significance of transportation impacts, and that as of July 1, 2020, this requirement applies statewide. Prior to that date, lead agencies were permitted to elect to rely on VMT rather than LOS to analyze transportation impacts.

Finally, SB 743 establishes a new CEQA exemption for a residential, mixed-use, or employment center Project that is a) within a transit priority area, b) consistent with a specific plan for which an EIR has been certified, and c) consistent with a Sustainable Communities Strategy (SCS). This exemption requires further review if the Project or circumstances changes significantly.
1 Full text of SB 743: https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201320140SB743 2 “Transit priority area” means an area within one-half mile of a major transit stop that is existing or planned, if the planned stop is scheduled to be completed within the planning horizon included in a Transportation Improvement Program adopted pursuant to Section 450.216 or 450.322 of Title 23 of the Code of Federal Regulations . (PRC 21099(a)(7))
3 “Employment center Project” means a Project located on property zoned for commercial uses with a floor area ratio of no less than 0.75 and that is located within a transit priority area. (PRC 21099(a)(1)) 4 “Infill site” means a lot located within an urban area that has been previously developed, or on a vacant site where at least 75 percent of the perimeter of the site adjoins, or is separated only by an improved public right-of-way from, parcels that are developed with qualified urban uses. (PRC 21099(a)(4)) Southline Specific Plan
Transportation Impact Analysis
April 2022
17 The City of South San Francisco has adopted VMT thresholds (Resolution 77-2020) in accordance with OPR’s Technical Advisory on Evaluating Transportation Impacts in CEQA.

3.2 Significance Criteria
The impacts of the proposed Project related to transportation would be considered significant if any of the following Standards of Significance are exceeded, in accordance with Appendix G of the CEQA Guidelines:
• The Project or its effects conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities; • The Project or its effects conflicts with or is inconsistent with CEQA Guidelines section 15064.3, subdivision (b);
• The Project substantially increases hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); or • The Project results in inadequate emergency access.

Thresholds of significance used in this document are based on Appendix G criteria as well as local considerations from adopted policies by the City of South San Francisco and City of San Bruno. Neither the City of South San Francisco nor the City of San Bruno has adopted a standard set of thresholds of significance for transportation impact analyses beyond the Appendix G criteria.

3.2.1 Vehicle Miles Traveled (VMT)
Pursuant to City of South San Francisco Resolution 77-2020 and CEQA Guidelines Section 15064.3, subdivision (b)(1), the following screening criteria applies to land use projects:

Presumption of Less Than Significant Impact Near Transit Stations: CEQA Guideline Section 15064.3, subdivision (b)(1), states that lead agencies generally should presume that certain projects (including residential, retail, and office projects, as well as projects that are a mix of these uses) proposed within ½ mile of an existing major transit stop or an existing stop along a high quality transit corridor will have a less-than-significant impact on VMT. This presumption would not apply, however, if Project-specific or location-specific information indicates that the Project will still generate significant levels of VMT. For example, the presumption might not be appropriate if the Project:
▫ Has a Floor Area Ratio (FAR) of less than 0.75
▫ Includes more parking for use by residents, customers, or employees of the Project than required by the jurisdiction (if the jurisdiction requires the Project to supply parking)
▫ Is inconsistent with the applicable Sustainable Communities Strategy (as determined by the lead agency, with input from the Metropolitan Planning Organization) ▫ Replaces affordable residential units with a smaller number of moderate- or highincome residential units Southline Specific Plan
Transportation Impact Analysis
April 2022
18 If a land use Project is not presumed to have a less than significant impact, the following criteria applies:
• A significant impact would occur if development of the Project would generate per-employee vehicle miles traveled (VMT) greater than the City’s adopted threshold of greater than 15 percent below the regional average.

For transportation infrastructure Projects (such as a street extension), the following criteria applies:
• A significant impact would occur if the Project would result in a net increase in Total VMT.

3.2.2 Design Hazards

3.2.2.1 Geometric Design Hazards
• A significant impact would occur if the Project substantially increases hazards to street users due to a design feature or land uses incompatible with the surrounding street network.

3.2.2.2 Vehicle Queueing at Freeway Ramps
• A significant impact would occur if 95th-percentile vehicle queues were to extend beyond the available storage space and substantially exacerbate a risk of collision.

3.2.2.3 Queueing Across an At-Grade Rail Crossing
• A significant impact would occur if 95th percentile vehicle queues extend beyond available storage and may substantially exacerbate risk of collisions.

3.2.2.4 Traffic Signal Warrant
• A significant impact would occur if Project-related vehicle traffic at an unsignalized intersection or driveway would increase baseline volumes to meet peak hour or pedestrian volume signal warrant criteria levels, and Project-related traffic volumes may substantially increase risk of collisions.

3.2.3 Emergency Vehicle Access
• A significant impact would occur if the Project results in inadequate emergency access

3.2.4 Bicycle, Pedestrian, and Transit

3.2.4.1 Consistency with Adopted Bicycle, Pedestrian, or Transit Plans & Policies • A significant impact would occur if the Project conflicts with adopted policies, plans, or programs regarding transit, bicycle, or pedestrian facilities.

3.2.4.2 Bicycle, Pedestrian, and Transit Performance & Safety • A significant impact would occur if the project were to cause a detrimental impact on the performance of transit services.

Southline Specific Plan
Transportation Impact Analysis
April 2022
19 • A significant impact would occur if the project were to cause a detrimental impact on the performance or safety of bicycle or pedestrian facilities.

3.3 Analysis Scenarios
The impacts of the proposed Project to the surrounding transportation system were evaluated for the five scenarios listed below:
• Scenario 1: Existing Conditions
• Scenario 2: 2024 Baseline (No Project)
• Scenario 3: 2024 Baseline Plus Project Phase 1 Conditions • Scenario 4: Cumulative 2040 Conditions
• Scenario 5: Cumulative 2040 Plus Project Buildout Conditions A description of the methods used to estimate the amount of traffic and VMT generated by the proposed Project is provided below.

3.3.1 Existing Conditions (Pre-COVID-19)
Existing conditions represent the baseline condition upon which Project impacts are measured. The existing condition reflects 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. Instead, to establish a representative existing condition, this analysis utilized local traffic data collected in 2017 and 2018 and transit service levels prior to the COVID-19 pandemic (including Caltrain service levels of five trains per hour, per direction). This approach enables analysis of an observed condition and no major developments have since been completed in the immediate Project area that might substantially affect traffic patterns; however, there is inherently some uncertainty in the data’s representation of existing conditions due to its age and the unusual circumstances of the COVID-19 pandemic.

3.3.2 2024 Baseline
The 2024 Baseline condition represents a near-term condition after the COVID-19 pandemic is presumed to have ended, in which travel patterns have returned to pre-COVID-19 status. The 2024 Baseline condition includes prorated local and regional growth consistent with the 2040 forecasts, reflecting the 2017/2018 conditions plus the addition of roughly one quarter of total growth between the 2017/2018 condition and 2040 forecasts. There remains substantial uncertainties around the COVID-19 pandemic’s effects on travel behavior and the duration of these effects; this approach assumes travel behavior returns to typical conditions and the effects of the pandemic are short term in nature. The 2024 Baseline also includes the completion of the Caltrain Electrification Project, a Project currently under construction that will increase Caltrain service levels to six trains per hour, per direction.

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Transportation Impact Analysis
April 2022
20 3.3.3 2024 Baseline Plus Project Phase 1 Conditions
The 2024 Baseline Plus Phase 1 conditions represent the 2024 condition with the addition of Phase 1 of the Project based on the anticipated Phase 1 construction schedule. Phase 1 of the Project includes several major transportation network improvements, including the construction of Southline Avenue; constructing a new intersection connecting Sneath Lane, Huntington Avenue, Maple Avenue, and Southline Avenue; providing a signalized driveway to the SamTrans Transit Center; and extension of various bicycle and pedestrian facilities, including extending the Centennial Way Trail to the San Bruno BART station and enhancing pedestrian access to the San Bruno BART station with new bulbouts and high visibility crosswalks.

As such, under 2024 Baseline Plus Phase 1 conditions, traffic volumes reflect the existing traffic volumes, some redistribution of traffic to the new Southline Avenue, and traffic associated with the land uses in Phase 1 of the Project.

3.3.4 Cumulative 2040 Conditions
Cumulative 2040 conditions include transportation demand resulting from reasonably foreseeable land use changes and conditions associated with planned transportation Projects. Cumulative conditions are based on forecasted land use and transportation conditions included in Plan Bay Area 2040, as represented in the C/CAG Model. Forecasts for cumulative conditions include several adjustments to reflect reasonably foreseeable Projects affecting the study area, including completion of all approved employment Projects within the City of South San Francisco as of May 2020,
5 and completion of the Bayhill Specific Plan in the
City of San Bruno (a plan that may be considered reasonably foreseeable even though it is not yet approved). Along the Caltrain railroad corridor, cumulative conditions include the operation of 12 trains per hour, per direction during peak periods; this service level reflects completion of the California High Speed Rail Project to operate four high speed trains per hour, per direction (as described in Plan Bay Area) as well as the Caltrain Business Plan’s adopted service vision of operating eight trains per hour, per direction during peak periods.

Cumulative conditions do not assume completion of the South Linden and Scott Street grade separations since these Projects are not yet fully funded or included in the regional transportation plan. As of September 2020, both South San Francisco and San Bruno have provided direction to proceed with studying a hybrid approach for the South Linden Avenue grade crossing that involves partially raising the railway and lowering the roadway, along with closing Scott Street to vehicles and maintaining a crossing for pedestrians and bicyclists.
5 The total land use approvals for employment Projects in the City of South San Francisco exceeds Plan Bay Area forecasts, so the difference in employment growth has been added to Plan Bay Area forecasts. Projects included in this cumulative analysis include major developments such as the Cove, Gateway of the Pacific, the Oyster Point Development, and other projects in the East of 101 Area.

Southline Specific Plan
Transportation Impact Analysis
April 2022
21 3.3.5 Cumulative 2040 Plus Project Conditions
Cumulative plus Project conditions represent the cumulative condition with the addition of the complete Project buildout to determine the extent to which the proposed Project would contribute to long-term cumulative transportation impacts.

3.4 Travel Demand Model Methodology
The City/County Association of Governments of San Mateo County Travel Demand Model (C/CAG Model) was used as a basis for analyzing travel behavior, including trip distribution and vehicle miles traveled (discussed in Section 4.2). The C/CAG Model is a trip-based regional travel demand model that considers regional land use patterns, approximated highway congestion, and connecting transit service within the nine-county Bay Area region. As part of the ongoing City of South San Francisco General Plan Update study, the C/CAG model was reviewed, and updated through a series of diagnostic tests to assess the model’s performance and reasonableness, and a series of refinements were made to the model inputs for land use, roadway network and transit service within South San Francisco.6 These updates improve the C/CAG model’s effectiveness in reasonably estimating current travel patterns and changes in travel patterns in response to Project land use and transportation network changes.

To further enhance the reasonableness of trip assignment from the C/CAG Model, the City of South San Francisco’s sub-area model was applied using Project trip generation and trip distribution from the C/CAG Model. The sub-area model, developed for the City of South San Francisco General Plan Update, reflects origin-destination patterns consistent with the C/CAG Model and incorporates refinements to the level of detail in the local street network. The sub-area model, developed in the Visum software platform, provides a more detailed representation of traffic circulation and operational performance of the roadway network in the vicinity of the Project and within the San Francisco and San Bruno areas. The roadway network in the sub-area model was refined to include most streets and major driveways in South San Francisco. The traffic assignment process in the sub-area model incorporates details such as signal timings, intersection lane geometries, and turning movement delays, allowing for a more realistic representation of existing traffic patterns and those associated with the Project land use and proposed street extension.

3.5 Trip Generation, Distribution, and Assignment
The amount of traffic added to the roadway system by the proposed Project was estimated using a threestep process: (1) trip generation, (2) trip distribution, and (3) trip assignment. The first step, trip generation, estimates the amount of traffic that would be generated once the proposed Project was built and fully occupied. The second step, trip distribution, estimates the direction of travel to and from the Project. The 6 The updates to model were based on relevant national guidance including the 2017 Regional Transportation Plan Guidelines for Metropolitan Transportation Planning Organizations, CTC, 2017 and Travel Model Validation and Reasonableness Checking Manual, Second Edition, TMIP, FHWA, 2010.

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Transportation Impact Analysis
April 2022
22 third step, trip assignment, assigns the proposed Project trips to specific street segments and intersection turning movements. The results are described below.

3.5.1 Trip Generation
Project person trip and vehicle trip forecasts were developed to capture the multimodal nature of Project travel as a transit-oriented development. Person trip generation represents trips by one person in any mode of transportation, whereas vehicle trip generation represents trips by one vehicle. Vehicle trip estimates include trips associated with single occupancy vehicles, taxis, ride-hailing companies (like Uber and Lyft), carpools, and shuttles.

The Project includes two land use alternatives – an office use and a life science use. For purposes of this analysis, the office use was analyzed to reflect a land use condition with an employee density – typically offices have one employee per 250 square feet, compared to one employee per 450 square feet for life science uses.7 Therefore, the Office Alternative would have a larger effect on the surrounding environment when compared to the Life Sciences Alternative. As such, this section analyzes the Office Alternative when considering project impacts under the buildout scenario.

Trip generation estimates were prepared for the Phase 1 Project (701,000 square feet), inclusive of the approximately 16,400 square foot publicly-accessible ground floor uses in the amenities buildings, in addition to the Project Buildout (up to 2,800,000 square feet). The higher parking scenario was analyzed (2.2 spaces per 1,000 square feet).

As described in Section 1.1, the Project is subject to the City’s Transportation Demand Management ordinance. The Project will be required to comply with a maximum drive alone mode share of 55 percent.

Under the Transportation Demand Management ordinance, the Project must comply with standard monitoring practices to enforce these mode share requirements. A Preliminary TDM Plan has been prepared for the Project, which is applicable to the entire Project site.

3.5.1.1 Office Trip Generation
Office trip generation was calculated using local data from comparable sites, as further described below, based on the ITE Trip Generation Manual, 10th Edition recommendation for using local data for similar atypical developments like the proposed Project, which is very large in scale, adjacent to high frequency transit service, has a reduced parking supply, and is subject to stringent transportation demand management requirements. Based on the ITE recommendation, this analysis estimates person trip and vehicle trip rates based on observed counts and mode share surveys for comparable high intensity technology office uses in Downtown Redwood City near the Redwood City Caltrain Station, as analyzed in the Redwood City Moves Transportation Plan. Based on a review of comparable trip generation and mode share data for other transit-oriented office sites located in San Francisco, Oakland, and San Mateo, the 7 San Jose Market Overview and Employment Lands Analysis, City of San Jose, 2016.

Southline Specific Plan
Transportation Impact Analysis
April 2022
23 Downtown Redwood City location was selected based on land use, transit, and TDM characteristics that most closely resemble the Project. These person trip and vehicle trip rates from the Downtown Redwood City data were adjusted to reflect the Project’s mode share requirements consistent with the City of South San Francisco’s TDM ordinance – a maximum peak period drive alone rate of 55 percent including singleoccupancy vehicles and single-passenger trips via ride-hailing companies or taxis, as compared to an observed peak period drive-alone rate of 50 percent in the downtown Redwood City surveys.8 Person trip generation for non-auto modes was based on transit, carpool, and active transportation data from South San Francisco TDM surveys and the proximity of the Project to transit services and active transportation facilities. An estimated 23 percent of peak hour trips would occur via BART, 10 percent via Caltrain, eight percent via Carpool, two percent via SamTrans buses, and two percent via bicycling. Trips via BART and SamTrans would require walking from the Project to the San Bruno BART Station or SamTrans bus transit center, while trips via Caltrain would connect via first/last mile shuttles or via biking.

3.5.1.2 Amenity Uses
Trip generation for the Project’s publicly accessible restaurant/retail uses were estimated using the High Turnover Restaurant classification from the Trip Generation Manual, 10th Edition. Since the publicly accessible amenities are generally expected to draw pedestrian trips from elsewhere within the Project site and adjacent areas, the High Turnover Restaurant classification provides a conservative assessment of vehicle trips that is typically more reflective of a more automobile-oriented use.

Amenity uses accessible only to tenants of the Project such as an employee cafeteria, fitness center, basketball court, auditorium would not generate external vehicle trips, but would generate employeerelated person trips for individuals employed at these services. Trip generation for these internal private amenities was estimated at about one quarter of office rates based on anticipated employee densities and mix of staffed and unstaffed uses9. Trip generation for the public and private amenity uses were included in both the Phase 1 Project and Project Buildout.

3.5.1.3 Trip Internalization
In mixed use developments, some trips between different land uses are “internalized” onsite – occurring by walking rather than driving elsewhere. The project proposes to include a mix of office and amenity uses that would facilitate some internalization (such as an office employee walking to a fitness center, cafeteria, and café or retail space). Internalization rates of 3 percent (AM peak hour) and 2 percent (PM peak hour) were 8 City of South San Francisco’s TDM ordinance establishes required alternative mode share of 45 percent based on Project floor area ratio.
9 Based on the San Mateo County Linkage Fee Nexus Study, restaurant and service uses typically have half of the employee density of office uses. About half of the Project amenity spaces were identified to be actively staffed restaurant and service uses; therefore, the employee density and trip generation was assumed to be one-quarter of office uses. Office trip generation typically reflect mostly trips by employees, so the ratio of amenity density to office density was applied to trip generation to determine amenity trip generation rates.

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Transportation Impact Analysis
April 2022
24 applied to all vehicle trips during the respective peak hours, based on the Mixed-Use Trip Generation Model (MXD) + Model, a weighted average of the U.S. Environmental Protection Agency’s MXD and the National Cooperative Highway Research Program’s 684 methodology.

3.5.1.4 Credit for Existing Trip Generation
The project’s net change in the number of vehicle trips was calculated to reflect the estimated number of vehicle trips occurring at the Specific Plan area under existing conditions. Because of the atypical travel patterns associated with the COVID-19 shelter-in-place order, driveway counts at existing uses were not conducted. Instead, trip generation for existing uses within the Specific Plan area was estimated based on land use characteristics and Trip Generation Manual recommendations. Existing land uses include approximately 344,000 square feet of light industrial and office uses, about 85 percent of which is occupied.

All of the existing land uses would be demolished as part of Phase 1; therefore, both Phase 1 and project buildout trip generation include the full trip credit associated with existing land uses. In total, existing uses generate an estimated 1,504 daily vehicle trips, including 171 AM peak-hour vehicle trips and 150 PM peakhour vehicle trips.

3.5.1.5 Trip Generation Results
Phase 1 of the Project would generate approximately 7,930 daily person trips and 3,954 daily vehicle trips.

These totals include 1,043 AM peak hour person trips, 485 net new AM peak hour vehicle trips, 950 PM peak hour person trips, and 455 net new PM peak hour vehicle trips. Table 3-1 and Table 3-2 show person trip and vehicle trip generation estimates for Phase 1, respectively.

Table 3-1. Person Trip Generation | Phase 1
Mode Mode Share AM Peak
Hour
PM Peak
Hour Daily
Drive Alone 55% 499 447 3,837
Carpool 8% 73 65 550
BART 23% 209 187 1,281
Caltrain1 10% 91 81 557
SamTrans 2% 18 16 111
Walk/Bike2 2% 18 16 111
Total Person Trips Monitored by TDM Ordinance 100% 908 812 6,448 Person Trips, Public Amenity Visitors - 135 138 1,482
Total Person Trips - 1,043 950 7,930
Notes:

1. Based on travel demand data from high intensity tech office mode share and person trip generation surveys from Downtown Redwood City near the Redwood City Caltrain Station as well as requirements from City of South San Francisco TDM Ordinance.

2. Mode share estimates based on City of South San Francisco TDM Surveys and analysis based on local context.

Source: Fehr & Peers, 2020.

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Transportation Impact Analysis
April 2022
25 Table 3-2. Vehicle Trip Generation | Phase 1
Land Use Size (KSF)
AM Peak Hour PM Peak Hour Daily
Rate (per
KSF) In Out Total Rate (per KSF) In Out Total
Rate
(per
KSF)
Total
Office1 613 0.81 464 35 499 0.73 58 387 445 6.16 3,774
Private Amenities2 72 0.23 15 1 16 0.20 2 13 15 1.72 124 Public Amenities3 16 9.94 87 72 159 9.77 97 59 156 115 1,840 Internalization Adjustment
(3% AM / 2% PM) -15 -3 -18 -3 -8 -11 -280
Project Trips 551 105 656 154 451 605 5,458
Existing Office4 11 ITE
Equation -10 -2 -12 ITE Equation -2 -12 -14 9.74 -125
Existing Light Industrial5 278 ITE
Equation -140 -19 -159 ITE Equation -18 -118 -136 4.96 -1,379 Net New Project Trips 401 84 485 134 321 455 3,954
Notes:

1. Based on travel demand data from high intensity tech office mode share and vehicle trip generation surveys from Downtown Redwood City near the Redwood City Caltrain Station as well as requirements from City of South San Francisco TDM Ordinance. Values rounded in table.

2. Includes external trips associated with employee commutes and deliveries only, assumed to be 72 percent less than the office trip generation rate based upon expected uses and employee densities.

3. Source: ITE 932 High Turnover Restaurant, Institute of Transportation Engineers. Trip Generation Manual, 10th ed. Values rounded in table.

4. Source: ITE 710, General Office Building, Institute of Transportation Engineers. Trip Generation Manual, 10th ed. Fitted curve equation used for individual land uses. Includes occupied spaces only as of March 2020. Values rounded in table. All existing uses are assumed to be removed with the Phase 1 Project.

5. Source: ITE 110, General Light Industrial, Institute of Transportation Engineers. Trip Generation Manual, 10th ed. Fitted curve equation used for individual land uses. Includes occupied spaces only as of March 2020. Values rounded in table. All existing uses are assumed to be removed with the Phase 1 Project.

Source: Fehr & Peers, 2020.

The Project Buildout would generate approximately 28,461 daily person trips and 16,876 vehicle trips. These totals include 3,918 AM peak hour person trips, 2,150 net new AM peak hour vehicle trips, 3,528 PM peak hour person trips, and 1,952 PM peak hour vehicle trips. Table 3-3 and Table 3-4 show person trip and vehicle trip generation estimates for the Project Buildout respectively.

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Transportation Impact Analysis
April 2022
26 Table 3-3. Person Trip Generation | Project Buildout Mode Mode Share AM Peak Hour PM Peak Hour Daily
Drive Alone 55% 2,105 1,879 15,984
Carpool 8% 306 273 2,317
BART 23% 880 786 5,394
Caltrain1 10% 383 342 2,345
SamTrans 2% 77 68 469
Walk/Bike2 2% 77 68 469
Total Person Trips Monitored by TDM Ordinance 100% 3,828 3,416 26,978 Person Trips, Public Amenity Visitors - 90 112 1,483
Total Person Trips - 3,918 3,528 28,461
Notes:

1. Based on travel demand data from high intensity tech office mode share and person trip generation surveys from Downtown Redwood City near the Redwood City Caltrain Station as well as requirements from City of South San Francisco TDM Ordinance.

2. Mode share estimates based on City of South San Francisco TDM Surveys and assignment to transit providers based on local context and expected travel patterns.

Source: Fehr & Peers, 2020.

Southline Specific Plan
Transportation Impact Analysis
April 2022
27 Table 3-4. Vehicle Trip Generation | Project Buildout Land Use Size (KSF)
AM Peak Hour PM Peak Hour Daily
Rate (per
KSF) In Out Total Rate (per KSF) In Out Total
Rate
(per
KSF)
Total
Office1 2,712 0.81 2,053 155 2,208 0.73 256 1,713 1,969 6.16 16,696 Private Amenities2 72 0.23 15 1 16 0.20 2 13 15 1.72 124 Public Amenities3 16 9.94 87 72 159 9.77 97 59 156 115 1,840 Internalization Adjustment
(3% AM / 2% PM) -56 -6 -62 -6 -32 -38 -280
Project Trips 2,099 222 2,321 349 1,753 2,102 18,380
Existing Office4 11 ITE
Equation -10 -2 -12 ITE Equation -2 -12 -14 9.74 -125
Existing Light Industrial5 278 ITE
Equation -140 -19 -159 ITE Equation -18 -118 -136 4.96 -1,379 Net New Project Trips 1,949 201 2,150 329 1,623 1,952 16,876 Notes:

1. Based on travel demand data from high intensity tech office mode share and vehicle trip generation surveys from Downtown Redwood City near the Redwood City Caltrain Station as well as requirements from City of South San Francisco TDM Ordinance. Values rounded in table.

2. Includes external trips associated with employee commutes and deliveries only, assumed to be 72 percent less than the office trip generation rate based upon expected uses and employee densities.

3. Source: ITE 932 High Turnover Restaurant, Institute of Transportation Engineers. Trip Generation Manual, 10th ed. Values rounded in table.

4. Source: ITE 710, General Office Building, Institute of Transportation Engineers. Trip Generation Manual, 10th ed. Fitted curve equation used for individual land uses. Includes occupied spaces only as of March 2020. Values rounded in table.

5. Source: ITE 110, General Light Industrial, Institute of Transportation Engineers. Trip Generation Manual, 10th ed. Fitted curve equation used for individual land uses. Includes occupied spaces only as of March 2020. Values rounded in table.

Source: Fehr & Peers, 2020.

3.5.2 Project Vehicle Trip Distribution, and Project Vehicle Trip Assignment Figure 3-1 displays vehicle trip distribution by county based on the C/CAG Model. Approximately 65 percent of vehicle trips would travel between the Project and other locations in San Mateo County. About 21 percent of trips would travel between the Project and San Francisco County. The remainder of trips would be split between Alameda County, Santa Clara County, and elsewhere in the East Bay and North Bay. This summary does not include trip distribution associated with non-auto trips.

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Transportation Impact Analysis
April 2022
28 Figure 3-1. Vehicle Trip Distribution – Summary by County Figure 3-2 through Figure 3-5 illustrate Phase 1 and Project Buildout trip distribution and assignment based on the City’s sub-area model, depicting street segments with greater than 25 Project-generated trips.

Vehicle trip distribution from the Project is shown in green, while volumes assigned to individual streets are illustrated proportionally in blue. The Project’s location and access to multiple freeway ramps would result in drivers using several different routes to access US-101, I-380, and I-280. Because 2040 freeway conditions are projected to be highly congested, some Project trips may travel somewhat longer distances via parallel corridors such as El Camino Real or Junipero Serra Boulevard. Approximately 56 percent of Projectgenerated trips would travel via San Bruno, and 44 percent via South San Francisco.

Figure 3-6 through Figure 3-9 illustrate the total difference in volumes associated with the Phase 1 Project and Project Buildout (the Phase 1 and Project Buildout trip assignment plus the rerouting of trips associated with the new street connection). Change in trips is illustrated proportionally with increases shown in red and decreases shown in green. By adding the Southline Avenue connection between Sneath Lane/Huntington Avenue and South Linden Avenue, the Project would shift vehicle trips from other routes, resulting in a net decrease in traffic volumes on parallel routes like Spruce Avenue and Scott Street. 2024 conditions generally mirror those shown in 2040 with lower traffic volumes associated with Phase 1.

The vehicle trip assignment served as the basis for selecting study locations for freeway ramps (Figure 3-10) as well as simulation of local transportation conditions, described in the following section.

San Mateo
County, 65%
San Francisco County, 21%
Alameda County, 4%
Santa Clara
County , 4%
Other, 5%
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Figure 3-2
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Figure 3-3
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\\fpsf03\Data\Projects\2020_Projects\SF20-1089_Southline EIR\Analysis\Model\Plots Project Trip Distribution & Assignment - AM Peak Hour
Figure 3-4
30% 14%
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\\fpsf03\Data\Projects\2020_Projects\SF20-1089_Southline EIR\Analysis\Model\Plots Project Trip Distribution & Assignment - PM Peak Hour
Figure 3-5
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\\fpsf03\Data\Projects\2020_Projects\SF20-1089_Southline EIR\Analysis\Model\Plots Southline - Existing Plus Phase 1
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Figure 3-6
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Study Locations
Project Site
New Street - Southline Avenue
City Boundary
Caltrain Station
BART Station
Microsimulation Network
Freeway Intersections
South Maple
Avenue
Hun�ngton Avenue
Sea
Sco� St
Miller Av
Baden Av
Biscuit Av
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San Francisco

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Tanforan
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Center
Orange
Memorial
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0.5 mi
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Southline Specific Plan
Transportation Impact Analysis
April 2022
38 3.6 Multimodal Analysis Methodology
The Vissim software program was used as the basis for evaluating the congestion and multimodal traffic conditions around the Project. Vissim analyzes traffic by simulating and capturing the interactions between individual cars, trucks, buses, pedestrians and bicycles. In addition to vehicular LOS, Vissim enables evaluation of vehicle queuing, transit and emergency vehicle delays, pedestrian and bicycle delays, and pedestrian density (via the Viswalk module). When analyzing new and modified traffic signals in the Project, traffic signal timing was optimized to balance minimizing conflicts between pedestrians and vehicles and reducing delay for all users.

Synchro and SimTraffic software were used to evaluate vehicle queueing at freeway ramps. Synchro was used as the primary analysis tool to identify potentially congested locations, while SimTraffic was used to refine the queueing analysis at congested locations.

Southline Specific Plan
Transportation Impact Analysis
April 2022
39 4. Transportation Analysis
This section includes analysis and findings of the Project’s environmental effects on transportation services and facilities related to walking, biking, driving, and riding transit. Topics covered include:
• Plan & Policy Consistency Review
• VMT Analysis
• Trip Generation, Distribution, and Assignment
• Site Plan Analysis
• Offsite Analysis

4.1 Plan & Policy Consistency Review
This section reviews the Project’s consistency with adopted plans and policies by local and regional jurisdictions.

4.1.1 City of South San Francisco Plans and Policies

4.1.1.1 General Plan Policies
The Project site is located within the Lindenville Planning Sub-Area under the General Plan. The General Plan includes a number of policies that encourage redevelopment and infrastructure improvements in the Lindenville Planning Sub-Area, such as providing better connectivity to San Bruno BART station, including via an extension of Sneath Lane through the Project site. The General Plan contemplates that a new eastwest street that would bisect the Project site and create a connection between Sneath Lane and South Linden Avenue to serve as the gateway between Downtown and San Bruno BART Station, as shown in Figure 4-1.

Figure 4-1. South San Francisco General Plan (1999) – Proposed Streets Southline Specific Plan
Transportation Impact Analysis
April 2022
40 The following City of South San Francisco General Plan policies relate to the Project and walking, biking, and transit.10 A new 2040 General Plan (Shape SSF) is currently being prepared by the City, but the City has not yet adopted new policies.
• 3.2-G-2 Develop new streets and through connections to facilitate truck movement; improve access to U.S. 101, and provide better connectivity between the proposed San Bruno BART station and Downtown.
• 3.2-G-3 Enhance the appearance of the area by undertaking streetscape and other improvements. • 3.2-I-14 Provide new street extensions in Lindenville as outlined in Chapter 4: Transportation.. including extension of South Linden Avenue to the San Bruno BART station • 4.2-G-2 Improve connections between different parts of the city. • 4.2-G-8 Use the Bicycle Master Plan to identify, schedule, and implement roadway improvements that enhance bicycle access.
• 4.2-G-9 Use the Pedestrian Master Plan to identify, schedule, and implement roadway improvements that enhance pedestrian access.
• 4.2-G-10 Make efficient use of existing transportation facilities and, through the arrangement of land uses, improved alternate modes, and enhanced integration of various transportation systems serving South San Francisco, strive to reduce the total vehicle-miles traveled. • 4.2-G-13 Integrate Complete Streets infrastructure and design features into street design and construction to create safe and inviting environments for people to walk, bicycle, and use public transportation.
• 4.2-I-2 Undertake street improvements [including the] South Linden Avenue extension to Sneath Lane.
• 4.2-I-10 In planning, designing, and constructing Complete Streets:
◦ Include infrastructure that promotes a safe means of travel for all users along the right of way, such as sidewalks, shared use paths, bicycle lanes, and paved shoulders. ◦ Include infrastructure that facilitates safe crossing of the right of way, such as accessible curb ramps, crosswalks, refuge islands, and pedestrian signals; such infrastructure must meet the needs of people with different types of disabilities and people of different ages. ◦ Ensure that sidewalks, crosswalks, public transportation stops and facilities, and other aspects of the transportation right of way are compliant with the Americans with Disabilities Act and meet the needs of people with different types of disabilities, including mobility impairments, vision impairments, hearing impairments, and others. Ensure that the South San Francisco ADA Transition Plan includes a prioritization method for enhancements and revise if necessary. 10 The City of South San Francisco General Plan includes policies related to automobile LOS for certain locations, however, General Plan Policy 4.2-G-17 exempts development within one-quarter mile of a Caltrain or BART station, or a City-designated ferry terminal, from LOS standards, which applies to the Project. Moreover, under SB 743, LOS or similar measures of traffic congestion are no longer considered a significant impact under CEQA, Southline Specific Plan
Transportation Impact Analysis
April 2022
41 ◦ Prioritize incorporation of street design features and techniques that promote safe and comfortable travel by pedestrians, bicyclists, and users of public transportation, such as traffic calming circles, additional traffic calming mechanisms, narrow vehicle lanes, raised medians, dedicated transit lanes, transit priority signalization, transit bulb outs, road diets, high street connectivity, and physical buffers and separations between vehicular traffic and other users. ◦ Ensure use of additional features that improve the comfort and safety of users: Provide pedestrian-oriented signs, pedestrian-scale lighting, benches and other street furniture, bicycle parking facilities, and comfortable and attractive public transportation stops and facilities.

Encourage street trees, landscaping, and planting strips, including native plants where possible, in order to buffer traffic noise and protect and shade pedestrians and bicyclists. Reduce surface water runoff by reducing the amount of impervious surfaces on the streets. • 4.2-I-11 In all street projects, include infrastructure that improves transportation options for pedestrians, bicyclists, and users of public transportation of all ages and abilities. ◦ Ensure that this infrastructure is included in planning, design, approval, construction, operations, and maintenance phases of street projects.
◦ Incorporate this infrastructure into all construction, reconstruction, retrofit, maintenance, alteration, and repair of streets, bridges, and other portions of the transportation network. • 4.3-I-14 Undertake a program to improve pedestrian connections between the rail stations—South San Francisco and San Bruno BART stations and the Caltrain Station—and the surroundings.

Components of the program should include:
◦ Installing handicapped ramps at all intersections as street improvements are being installed; ◦ Constructing wide sidewalks where feasible to accommodate increased pedestrian use; • Providing intersection “bulbing” to reduce walking distances across streets in Downtown, across El Camino Real and Mission Road, and other high use areas; ◦ Continuing with the City’s current policy of providing pedestrian facilities at all signalized intersections;
◦ Providing landscaping that encourages pedestrian use

4.1.1.2 Bicycle and Pedestrian Master Plans
The City of South San Francisco’s Bicycle Master Plan and Pedestrian Master Plan identify improvements to provide safer walking and biking to make active transportation an integral part of the City’s transportation system. Near the Project site, the Bicycle Master Plan identifies Class III bicycle routes on South Linden Avenue and Dollar Avenue. Both plans are currently being updated in the Active South City Bicycle and Pedestrian Master Plan in connection with the City’s General Plan Update in progress (Shape SSF), which has not yet been adopted.

Southline Specific Plan
Transportation Impact Analysis
April 2022
42 4.1.1.3 South San Francisco Transportation Demand Management Ordinance The City’s Transportation Demand Management (TDM) Ordinance, which is specified in Title 20 of the City’s Municipal Code in Chapter 20.400, Transportation Demand Management, seeks to reduce the amount of traffic generated by nonresidential development and minimize drive-alone commute trips. The TDM ordinance establishes a performance target for minimum alternative mode share for all nonresidential projects resulting in more than 100 average daily trips and identifies higher thresholds for projects that will be developed at increased intensity. For the Project, the minimum alternative mode share is 45 percent, based on the requested FAR.

Per the TDM ordinance, all projects are required to submit annual mode share surveys. Projects seeking a FAR bonus are also required to submit triennial reports assessing project compliance with the required alternative mode share target. Where targets are not achieved, the report must include program modification recommendations and City officials may impose administrative penalties should subsequent triennial reports indicate mode share targets remain unachieved.

4.1.2 City of San Bruno Plans and Policies
This section summarizes City of San Bruno policies as they relate to the portion of the Project’s proposed infrastructure improvements within its jurisdiction. The Project EIR is intended to provide CEQA clearance for subsequent discretionary approvals required by other agencies, including the City of San Bruno, for proposed offsite improvements located outside of the City of South San Francisco’s jurisdiction. Analysis regarding these City of San Bruno policies is included here for that purpose; however, these policies do not apply to the Project overall.

4.1.2.1 General Plan Policies
The following City of San Bruno General Plan policies are relevant to the Project’s proposed offsite improvements within San Bruno.
11 • T-A Provide for efficient, safe, and pleasant movement for all transportation modes—vehicles, bicycles, transit, and pedestrians.
• T-E Focus San Bruno’s efforts on improvements to the non-motorized transportation system (i.e., bicycles, pedestrians, strollers, etc.) adjacent to transit corridors and stations, and their connections to those systems.
• T-F Provide efficient local transit—such as a shuttle system—to the BART and Caltrain stations to avoid dependence on individual motor vehicles.
11 The City of San Bruno General Plan includes policies related to automobile LOS, including Policy T-B stating that acceptable levels of service for vehicular movement along the city’s street network should be maintained, and that “[a]cceptable level of service could vary based on characteristics of the area under consideration.” Under SB 743, LOS or similar measures of traffic congestion are no longer considered a significant impact under CEQA.

Southline Specific Plan
Transportation Impact Analysis
April 2022
43 • T-I Develop and maintain a comprehensive bicycle network within San Bruno, providing connections to BART and Caltrain, surrounding cities, employment and shopping areas, and natural areas.
• T-J Develop a safe, convenient, and continuous network of sidewalks and pedestrian paths within the city.
• T-2 Ensure that all transportation improvements— roadway, transit, bicycle, and pedestrian—are designed and constructed according to Americans with Disabilities Act standards. Improve existing facilities so they are compliant with American Disability Act standards. • T-43 Create a “pedestrian-friendly” environment surrounding the BART and Caltrain stations by installing additional street trees, lighting, signage, and widening sidewalks along streets adjacent to these stations.
• T-47 Improve multi-modal access—specifically for pedestrians, cyclists, and transit passengers—to the BART and Caltrain stations through improvements along Huntington Avenue. • T-70 Identify funding for and implement as a priority bicycle/pedestrian paths along the BART and Caltrain track alignments (Huntington Avenue and Herman Avenue) within the city limits.

Coordinate with the Linear Park planned in South San Francisco and Millbrae.

4.1.2.2 Transit Corridors Plan Policies
The City of San Bruno Transit Corridors Plan articulates the community's vision for revitalized commercial corridors in proximity to the San Bruno Avenue Caltrain Station. The following policies are relevant to the Project’s proposed offsite improvements within San Bruno:
• TRANS-B Ensure increased transit connectivity within and to/from the Transit Corridors Area and provide for transit amenities at stops and stations that increase the visibility of stops/stations and improve the comfort and convenience for transit riders. • TRANS-C Encourage improved bicycle connectivity and enhanced bicycle parking opportunities within the Transit Corridors Area linking the surrounding land uses and future Caltrain station. ◦ TRANS-C.1 Provide Class II bicycle lanes on Huntington Avenue north of San Bruno Avenue. • TRANS-D Facilitate pedestrian access and safety through pedestrian enhancements, including the provision of enhanced crosswalks at all intersections and wider sidewalks and pedestrian amenities along the transit corridors.
◦ TRANS-D.1 Provide enhanced crosswalks at all crossings in Transit Corridors Area. As appropriate, enhanced crosswalks should include pedestrian bulbouts, median refuge islands or special paving treatments.
• TRANS-E Develop and implement a parking management strategy for the Plan area that makes efficient use of the City’s parking supply through shared parking strategies and that provides the lowest number of parking spaces while still maintaining the viability of the Plan through efficient use of the parking supply within the Plan Area.

Southline Specific Plan
Transportation Impact Analysis
April 2022
44 • TRANS-F Develop and implement a Transportation Demand Management (TDM) Program that reduces the amount of peak period motor vehicle traffic and encourages the use of modes other than the single-occupant vehicle.

4.1.2.3 Walk ‘n Bike Plan
The City of San Bruno Walk ‘n Bike Plan identifies improvements to support safe, comfortable, and convenient walking and biking within the City. The Plan identifies specific improvements including streetscape enhancements and a Class IV separated bikeway along Huntington Avenue, gap closures of Class II bicycle lanes along Sneath Lane, and a Class III bicycle route along Herman Street.

4.1.3 Regional Plans and Policies
This section summarizes regional policies that relate to the Project.

4.1.3.1 MTC/ABAG Plan Bay Area 2040
Plan Bay Area is the Bay Area’s Regional Transportation Plan and Sustainable Communities Strategy. Plan Bay Area 2040 is a state-mandated, integrated long-range transportation and land use plan intended to meet greenhouse gas reduction targets. Plan Bay Area 2040 identifies various action items related to achieving these targets. The following action items relate to the Project:
• Increase transportation access to growing and potential job centers; • Support regional growth by balancing housing, transit-oriented jobs, and industrial uses.

4.1.3.2 San Mateo City/County Association of Governments Congestion Management Program The San Mateo City/County Association of Governments (C/CAG) is the Congestion Management Agency (CMA) for San Mateo County and is authorized to set State and federal funding priorities for improvements affecting the San Mateo County Congestion Management Program (CMP) roadway system. The C/CAGdesignated CMP roadway system in South San Francisco includes State Route (SR) 82 (El Camino Real), U.S. 101, Interstate I-380, and I-280.12
C/CAG has adopted guidelines to reduce the number of net new vehicle trips generated by new land development. These guidelines apply to all developments that generate 100 or more net new peak hour vehicular trips on the CMP network and are subject to CEQA review. C/CAG calls for projects that meet the criteria to determine if a combination of acceptable measures is possible that has the capacity to “fully reduce,” through the use of a trip credit system, the demand for net new trips that a project is anticipated to generate on the CMP roadway network (including the first 100 trips). C/CAG has published a list of 12 C/CAG sets LOS standards for the CMP network, but these LOS standards do not apply to CEQA per SB-743.

Southline Specific Plan
Transportation Impact Analysis
April 2022
45 mitigation options in a memorandum that also outlines a process for obtaining C/CAG approval of the Transportation Demand Management (TDM) Plan.

4.1.3.3 BART Transit-Oriented Development Policy
BART’s Transit Oriented Development (TOD)13 Policy informs BART’s internal and external approach to development near BART stations. The following goals and strategies are relevant to the Project:
• Goal B Sustainable Communities Strategy. Lead in the delivery of the region’s land use and transportation vision to achieve quality of life, economic, and greenhouse gas reduction goals. • Goal E Transportation Choice. Leverage land use and urban design to encourage non-auto transportation choices both on and off BART property, through enhanced walkability and bikeability, and seamless transit connectivity.
• Strategy B1 Support Transit-Oriented Districts: Proactively support local jurisdictions in creating station area plans and land use policies that: a) encourage transit-supportive, mixed-use development on and around station properties, b) enhance the value of BART land, and c) enhance the performance of the BART system as a whole.
• Strategy B2 Form partnerships with public agencies, developers and landowners, community development organizations, finance entities, and consider strategic land acquisition to help build TOD both on and off BART property.
• Strategy C1 Utilize BART’s TOD Guidelines to ensure future development and investments seamlessly connect BART stations with surrounding communities • Strategy C3 Utilize strategies including mixed-use development, transportation demand management, and pedestrian-friendly urban design to encourage reverse-commute, off-peak, and non-work trips on BART and other modes of non-auto transportation, thereby reducing greenhouse gas emissions.

4.1.4 Policy Consistency Analysis
The Project, including the associated proposed offsite improvements, is consistent with applicable adopted transit, bicycling, and walking policies within the Cities of South San Francisco and San Bruno. The Project and associated proposed offsite improvements would improve connectivity between the San Bruno BART Station and the Lindenville neighborhood; provide more direct pedestrian routes; add Class II bike lanes on Southline Avenue, in addition to Class I and Class III bike facilities within the Project area; extend the Centennial Way Trail; and provide a range of amenities and features within the Project site, including bicycle parking, showers, and changing facilities, among other features. The new Southline Avenue/Sneath Lane/Huntington Avenue/Maple Avenue intersection would include a signalized trail and pedestrian crossings with high-visibility crosswalks. Near the San Bruno BART Station, the Project includes circulation 13 BART Transit-Oriented Development Policy, Amended April 23 2020 https://www.bart.gov/sites/default/files/docs/BART%20Transit-Oriented%20Development%20Policy_Amended2020-04-23.pdf Southline Specific Plan
Transportation Impact Analysis
April 2022
46 enhancements to Huntington Avenue, including widening sidewalks, upgrading curb ramps, providing highvisibility crosswalks, adding bulbouts, and extending the Centennial Way Trail. The Project supports public transit ridership by providing enhanced connectivity to BART and SamTrans, a dedicated signalized bus entrance to the SamTrans transit center, and offering a shuttle service to Caltrain. The Project includes a TDM program to meet a 45 percent mode share target required by the City.

The Project is also consistent with regional plans including Plan Bay Area, C/CAG’s Congestion Management Program, and BART’s TOD Policy. While the Project site was not specifically identified as a Priority Development Area in Plan Bay Area (adjacent sites in the City of San Bruno were identified), its location in a Transit Priority Area near the San Bruno BART Station is consistent with Plan Bay Area’s goals to better integrate land use and transportation planning as well as BART’s goals to encourage reverse-commute trips to employment centers near stations. The Project’s Preliminary TDM program and associated circulation improvements are intended to fulfill C/CAG trip reduction requirements and is consistent with the above described goals by BART and C/CAG to encourage transit ridership and reduce vehicle trips.

4.2 VMT Analysis
This section analyzes VMT for the Project in relation to the criteria in section 3.2.1. The Project would affect VMT in two ways: the addition of Project-related travel from land use changes, and the effect of the Southline Avenue extension on travel patterns within the surrounding area. These topics are analyzed below.

4.2.1.1 VMT Screening – Land Use Project
SB 743 applies to the Project, which is a qualifying employment center Project located on an infill site within a transit priority area, as those terms are defined under Section 21099 of the Public Resources Code. As discussed in Sections 3.1 and 3.2.1, CEQA Guidelines Section 15064.3(b)(1), implementing SB 743, establishes a presumption of less than significance for VMT impacts related to qualifying land use Projects.

The Project is located within a qualifying transit priority area, as it is located within one-half mile of a major transit stop, including the San Bruno BART station and a frequent bus route (the SamTrans ECR route, which operates every 15 minutes), as shown in Figure 2-1. Both the San Bruno BART station and ECR route stops are considered major transit stops per Section 21099 of the Public Resources Code.

A project qualifies for a presumption of a less than significant impact provided that project-specific and location-specific information supports this presumption. The following Project-specific and location-specific information supports a presumption of less than significant impact:
• The Project’s proximity to BART provides a high-frequency regional transit connection to San Francisco, the East Bay, and northern San Mateo County, and its proximity to the SamTrans ECR route provides a frequent local transit connection within San Mateo County. Employee access to Caltrain via a shuttle service may further enable a regional transit connection to San Francisco, the Peninsula, and the South Bay.

Southline Specific Plan
Transportation Impact Analysis
April 2022
47 • The Project includes infrastructure improvements to support direct connections to transit and active transportation, including widening sidewalks and extending the Centennial Way Trail to the San Bruno BART Station, adding pedestrian bulbouts and high-visibility crosswalks, and providing a shuttle service to connect to Caltrain.
• The Project would allow for development of up to 2,800,000 SF (a maximum FAR of 2.4), which is substantially more dense than surrounding land uses as well as the existing land use at the Project site. The Project density is consistent with transit supportive development for station areas as defined in BART TOD Guidelines, which calls for medium to high density development that is greater than the community average within a 5 to 10-minute walk of stations. • The Project’s parking supply is below the City of South San Francisco requirements applicable to the existing zoning district and comparable office/R&D uses. The project, inclusive of Phase 1, would include vehicle parking up to a maximum of 2.2 parking spaces per 1,000 square feet of office space, which is less than the City’s standard requirement of 2.9 spaces per 1,000 square feet for similar business/professional office and R&D developments. The Project includes a TDM program to require that at least 45 percent of trips occur via transit, active transportation, and carpooling.
• The Project is consistent with the goals of Plan Bay Area to provide transit-oriented employment growth.

Based on these features in combination with its transit-oriented location, both Phase 1 of the Project as well as the Project Buildout meet OPR’s criteria for a presumption of less than significant VMT impact.

4.2.1.2 VMT Analysis – Southline Avenue Extension
The addition of Southline Avenue connecting Sneath Lane/Huntington Avenue and South Linden Avenue, a new street extension of approximately one quarter mile in length, would provide additional capacity for east-west travel in the Project area. Under existing conditions, there is no direct access between South Linden Avenue and Sneath Lane; this connection requires detouring about 1.3 miles either to the south on Huntington Avenue to Herman Avenue/Dollar Avenue, or detouring north on Huntington Avenue to South Spruce Avenue and Victory Avenue.

To assess the effect of the new connection on local VMT, the City of South San Francisco Travel Model was used. The City’s model provides greater detail in the local transportation network compared to the C/CAG Model and allows for dynamic assignment of vehicles to the most efficient route, therefore accounting for changes in travel behavior due to new connections and roadways.

Overall, the Southline Avenue extension is expected to result in a modest reduction in VMT produced by vehicles traversing the Project area, specifically affecting local traffic patterns by shifting east-west trips from South Spruce Avenue, San Bruno Avenue, and Scott Street toward the new shorter and more direct route. This modified circulation results in a slight reduction in VMT. Results are shown in Table 4-1.

Southline Specific Plan
Transportation Impact Analysis
April 2022
48 Table 4-1. VMT Effects of Southline Avenue Extension within South San Francisco and San Bruno
Area Existing Daily Roadway
Network VMT
Daily Roadway Network VMT
with Southline Avenue Extension Difference
VMT in South San Francisco
and San Bruno 5,077,500 5,072,600 -4,900
Source: Fehr & Peers, 2020

4.3 Site Plan Analysis
This section analyzes the Project Buildout’s effects on local circulation within the extents of the Project site and related offsite improvement areas. Similarities and differences between the Project Buildout and Phase 1 Project are noted where applicable. Project Buildout conditions are analyzed in the Cumulative 2040 context, while Phase 1 Project conditions are analyzed in the 2024 context, reflecting anticipated construction timing.

The Project’s site plan provides a preliminary design of building layouts and transportation infrastructure.

Project-related infrastructure changes include the Southline Avenue extension, driveways, sidewalks, traffic signals, the Centennial Way Trail extension, reconfiguration of bus and pedestrian access to the San Bruno BART Station, and the realignment of the at-grade rail crossing of Caltrain. These components would be finalized over the course of the Phase 1 and Project Buildout design processes and designed to applicable standards.

4.3.1 Multimodal Analysis
The following sections evaluate the Project’s proposed changes to existing circulation and transportation infrastructure, as shown in Figure 4-2. As detailed in this analysis, the proposed circulation and transportation improvements associated with the Phase 1 Project and Project Buildout would sufficiently accommodate the change in land use associated with an office/R&D campus in a manner consistent with applicable Caltrans and Highway Design Manual design standards, and would not introduce any design hazards.

4.3.1.1 Phase 1 Centennial Way Trail Extension and BART Station Access The Project would extend the Centennial Way Trail to the San Bruno BART Station, providing a 15- to 17- foot-wide multi-use path along the west side of Huntington Avenue. The path intends to serve both pedestrians and bicyclists in a shared use condition similar to the Centennial Way Trail to the north while retaining the bioswale area adjacent to the SamTrans Transit Center.

Viswalk was used to analyze potential conflicts between pedestrians and bicyclists along the Centennial Way trail extension during AM and PM peak hours. The analysis simulates pedestrian and bicycle behavior, interactions, and usage of space. Pedestrian and bicycle trips were distributed to reflect the proposed Southline Specific Plan
Transportation Impact Analysis
April 2022
49 Project’s travel demand, particularly the trips between the Project and BART and SamTrans. During peak hours, the path would serve about 550 to 650 pedestrians per hour traveling to and from the BART Station as well as about 100 to 150 bicyclists. Pedestrian and bicycle flows exiting the BART station were metered to reflect the BART train schedule during the AM and PM peak hours.

The Viswalk analysis evaluated “pedestrian space,” described as the average amount of area available for a pedestrian walking along a trail, sidewalk or crosswalk. Pedestrian space can also be expressed as the inverse of pedestrian density. The Highway Capacity Manual (HCM) 6th Edition provides a qualitative description of the pedestrian space that can be used to evaluate the performance of pedestrian facilities. Since pedestrians will comprise the vast majority of users on the Centennial Way Trail during peak hours, analyzing pedestrian space helps illustrate how much room remains for bicyclists to pass pedestrians as well as the potential for conflicts between modes. This scale is summarized in Table 4-2 shows a worst-case condition for pedestrian space experienced by users of the Centennial Way Trail during the AM and PM peak hours.

Table 4-2: Pedestrian Space Crowding Scale
Pedestrian Space
(square feet per pedestrian) Description
> 60 Ability to move in desired path, no need to alter movements > 40-60 Occasional need to adjust path to avoid conflicts > 24-40 Frequent need to adjust path to avoid conflicts > 15-24 Speed and ability to pass slower pedestrians restricted > 8-15 Speed restricted, very limited ability to pass slower pedestrians <= 8 Speed severely restricted, frequent contact with other users Notes: Based on the Highway Capacity Manual 6
th Edition
Source: Fehr & Peers, 2020.

The Viswalk results indicate that the proposed 15 to 17-foot-wide trail extension is sufficiently sized to accommodate forecasted pedestrian and bicycle volumes. The analysis identified hot spots for pedestrian space at the corners of the Huntington/BART and Huntington/Southline Avenue intersections, particularly the southwest corner of the Huntington/BART intersection during the AM peak hour due to the heavy pedestrian and bicycle flows existing the BART station. A visual inspection of the Viswalk simulation showed that while substantial crowding would occur at this corner as pedestrians wait for the ‘walk’ signal, the duration of the ‘walk’ signal and the lack of conflicts with vehicular movements would allow all pedestrians to cross in the same signal cycle. In essence, a high volume of pedestrians after a train arrival would control the speed of travel on the trail adjacent to the station, then spacing between pedestrians would increase walking farther from the station allowing bicyclists to comfortably pass. Therefore, the proposed design is unlikely to pose a hazardous condition.

Project Improvement Locations
Figure 1-3
\\Fpsf03.fpainc.local\data\Projects\2020_Projects\SF20-1089_Southline EIR\Graphics\GIS\MXD\CA_Template_LetterPortrait.mxd Centennial Way Trail
Extension and BART
Station Access
Huntington Ave/Sneath
Ln/Southline Ave/Maple Ave
Signalized Intersection
Southline Ave/South
Linden Ave/Dollar Ave
Signalized Intersection
A
B
C
D
E
Driveways
Re-aligned
at-grade crossing
Potential shuttle
stop locations
Southline Ave/
Central Project
Signalized
Intersection
Dedicated bus
signalized entrance
Driveways Analyzed
for Signal Warrants
X
Add pedestrian crossing
Add upgraded
pedestrian crossing
New cul-de-sac
ADA sidewalk
improvements
Traffic signal modifications
and new pedestrian crossing
New Southline
Avenue and Class II
Bike Lane
Location of southern mobility hub to be
adjusted to south side of Building 7; refer
to Project Description Figure 3-15
AM + PM Peak Hours
Pedestrian Spacing
Figure 4-3
>60
Pedestrian Space
(square feet per pedestrian)
Ability to move in desired path, no need to alter movements Signalized Intersection Occasional need to adjust path to avoid conflicts Frequent need to adjust path to avoid conflicts
Speed and ability to pass slower pedestrians restricted Speed restricted, very limited ability to pass slower pedestrians Speed severely restricted, frequent contact with other users Undefined
>40-60
>24-40
>15-24
>8-15
<=8
AM PM

HUNTINGTON AVENUE

SNEATH LANE

TANFORAN AVENUE

SOUTHLINE
AVENUE
Bus Transit
Center
BART Station
Entrance: ~250-ft

HUNTINGTON AVENUE

SNEATH LANE

TANFORAN AVENUE

SOUTHLINE
AVENUE
Bus Transit
Center
BART Station
Entrance: ~250-ft
\\Fpsf03.fpainc.local\data\Projects\2020_Projects\SF20-1089_Southline EIR\Graphics\AI Southline Specific Plan
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52 The Project would add a new crosswalk and pedestrian bulbout on the south side of the SamTrans Transit Center driveway to provide a more direct connection between the BART Station to the eastern sidewalk along Huntington Avenue. The eastern sidewalk would be rebuilt to achieve ADA compliance. Walking trips to and from the Project are likely to use both the eastern sidewalk and western trail along Huntington Avenue.

4.3.1.2 Huntington Avenue/Sneath Lane/Southline Avenue/Maple Avenue Intersection The Project would create a new signalized intersection between Huntington Avenue/Sneath Lane/Southline Avenue/Maple Avenue at the Project entrance. Huntington Avenue would be aligned with Maple Avenue, while Sneath Lane would be aligned with Southline Avenue. The western leg of the intersection would include a crossing for the Centennial Way Trail, while high visibility crosswalks would be provided on the remaining northern, southern, and eastern legs of the intersection. This trail crossing was analyzed as a protected phase without conflicting right-turn-on-red movements by southbound and eastbound vehicles.

The intersection would change access to several adjacent driveways. Access to the BART maintenance facility driveway on the north side of Huntington Avenue would remain in the westbound direction but would be restricted in the eastbound direction. Northbound bus access from Huntington Avenue to the SamTrans Transit Center would be relocated to a signalized bus-only left turn (serving about five buses per hour throughout the day). Eastbound access to the SamTrans Transit Center would remain.

Adding this intersection would also affect Tanforan Avenue. Tanforan Avenue would be separated from Maple Avenue while maintaining a connection with Huntington Avenue East. No vehicular Project access would occur on Tanforan Avenue. Consequently, traffic volumes would decline on Tanforan Avenue, particularly vehicle and truck traffic associated with industrial sites in Lindenville.

4.3.1.3 Southline Avenue/Central Project Driveway
The Southline Avenue/Central Project Driveway intersection (at Buildings 1, 3, 6, and 7) would experience very high pedestrian volumes during peak hours as a result of its location between Project buildings, parking facilities, shuttle stops, and amenities. Crosswalk volumes are expected to be in excess of 500 pedestrians per crosswalk leg. Consequently, a pedestrian scramble phase (in which pedestrians cross all legs of the intersection at the same time) was analyzed as the optimized condition to separate pedestrian and vehicle movements. With a pedestrian scramble phase, conflicts between modes are expected to be minimal.

4.3.1.4 Southline Avenue/South Linden Avenue/Dollar Avenue Intersection Southline Avenue would connect to a realigned intersection of South Linden Avenue/Dollar Avenue on the east side of the Project. The northern leg of South Linden Avenue would align with Dollar Avenue, while Southline Avenue would connect across a realigned at-grade rail crossing of Caltrain to San Mateo Avenue.

Eventually, it is anticipated that this crossing would be grade separated through a multi-agency planning and implementation process; both the cities of South San Francisco and San Bruno have recommended that planning efforts proceed under the “Alternative 1” design, which would partially lower South Linden Avenue and partially raise the railway. The Project’s design is compatible with the preferred Alternative 1 design.

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April 2022
53 The proposed grade separation project will be subject to a separate CEQA review and approval process not related to the Project; the grade separation project also requires public financing for implementation, which has not yet been obtained.

4.3.2 Signal Warrant Analysis
A signal warrant analysis to determine the potential need for traffic signals at unsignalized intersections was conducted for unsignalized Project intersections to assess potential hazards associated with Project-related vehicle and pedestrian volumes in accordance with criteria in the California Manual on Uniform Traffic Control Devices (CA-MUTCD). Signal warrants were tested for the five new full-access driveways, shown on Figure 4-2, on the Project based on the Peak Hour and Pedestrian Volume methodologies described in the CA-MUTCD, Section 4C.04 and 4C.05. As shown in Table 4-3, no driveways meet peak hour signal warrants under either Phase 1 or Project Buildout conditions. One driveway intersection at Maple Avenue (south of Building 4) would potentially meet pedestrian volume warrants; however, the Project’s proposed RapidRectangular Flashing Beacon is expected to provide sufficient prioritization for pedestrians crossing at this location to fulfill the anticipated need. Therefore, no signal warrants are met under Phase 1 Project and Project Buildout conditions.

Table 4-3: Signal Warrant Analysis
Driveway Driveway Location
Project Buildout Conditions
Peak Hour Signal Warrant Met Pedestrian Volume Warrant Met A South Linden Avenue No No
B
Maple Avenue, south of
Building 4 No No1
C
Maple Avenue, west of
Building 4 No No
D
Maple Avenue, east of
Building 5 No No
E Dollar Avenue No No
Notes:

Based on the CA-MUTCD
1Project would provide a Rapid-Rectangular Flashing Beacon to accommodate crossing needs Source: Fehr & Peers, 2020.

4.3.3 Phase 1 At-Grade Rail Crossing Analysis
The Project is located adjacent to the active rail corridor used by both Caltrain and limited evening freight activity. Under existing conditions, Caltrain operates five trains per hour, per direction during peak periods and one to two trains per hour, per direction during off-peak periods, while one to two trains per day operate during late evening hours. In 2022, the Peninsula Corridor Electrification Project will increase Caltrain service to six trains per hour, per direction during peak periods. By 2040, Caltrain plans to operate Southline Specific Plan
Transportation Impact Analysis
April 2022
54 eight trains per hour, per direction, while California High Speed Rail would operate four trains per hour, per direction, for a total of 12 trains per hour, per direction.

Vehicle traffic associated with the Project would increase the traffic volumes at the existing at-grade rail crossings at South Linden Avenue and at Scott Street; however, the Project (Phase 1 and Buildout) would not exacerbate potential safety hazards at these locations. as further described in Section 3.7.3.1 below.

While a grade separation is planned, the at-grade crossing condition was analyzed to reflect a worst-case scenario given that the grade separation currently is unfunded and not yet approved. The Project’s design of Southline Avenue maintains flexibility for a future grade separation; in the interim, it includes a reconfigured at-grade rail crossing to connect Southline Avenue with South Linden Avenue. No changes to the Scott Street at-grade rail crossing would occur with the Project.

4.3.3.1 South Linden Avenue At-Grade Rail Crossing
The rail crossing most directly affected by the Project is located on South Linden Avenue, immediately east of Dollar Avenue. The number of vehicles using this at-grade crossing increases due to both Project trips and the construction of Southline Avenue, which provides new east-west access connecting to Sneath Lane.

Operations affecting this railroad crossing and nearby intersections were modeled using the VISSIM traffic operations analysis software. Vissim analyzes traffic by simulating and capturing the interactions between individual cars, trucks, buses, trains, pedestrians, and bicycles and can provide detailed queuing information and indication of potential for vehicles to not clear an at-grade crossing.

Table 4-4 shows the storage space and simulated queuing activity under 2040 Plus Project Buildout conditions. With the Project Buildout, there is potential for queues exceeding available storage for the westbound movements at Southline Avenue and Dollar Avenue. However, by synchronizing the traffic signal with the at-grade crossing, the Project would minimize potential risk of conflicts since vehicles would be flushed out of the rail crossing prior to a train approaching. The inclusion of medians would also enhance safety by inhibiting vehicles from traveling around crossing gates. Consequentially, the risk of conflicts under either the Phase 1 Project or Project Buildout would not change substantially relative to the existing condition.

4.3.3.2 Scott Street At-Grade Rail Crossing
The second rail crossing potentially affected by the Project is located at Scott Street, located about 1,200 feet to the south of the Project. By adding Southline Avenue as a more direct connection between Huntington Avenue and San Mateo Avenue, the Project would decrease traffic volumes on Scott Street compared to No Project conditions. Because the total number of vehicles crossing the corridor at this location would decrease, the Phase 1 Project and Project Buildout would not exacerbate potential safety hazards at this location.

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April 2022
55 Table 4-4. Queuing at Linden Avenue At-Grade Rail Crossing – 2040 Project Buildout Intersection Movement Storage Space Average Queue
Length (ft)
95th Percentile
Queue Length (ft)
Queue exceeds
storage?
AM Peak Hour
Southline Avenue / Dollar
Avenue WBT 80 170 300 Yes
Southline Avenue / Dollar
Avenue WBL 60 160 290 Yes
Linden Avenue/ San Mateo
Avenue SBT 450 100 140 No
Linden Avenue/ San Mateo
Avenue SBL 450 190 250 No
PM Peak Hour
Southline Avenue / Dollar
Avenue WBT 80 530 600 Yes
Southline Avenue / Dollar
Avenue WBL 60 530 600 Yes
Linden Avenue/ San Mateo
Avenue SBT 450 190 250 No
Linden Avenue/San Mateo
Avenue SBL 450 320 390 No
Source: Fehr & Peers, 2020

4.4 Offsite Transportation Analysis

4.4.1 Signal Warrant Analysis
A signal warrant analysis was conducted for the intersection of Huntington Avenue/Herman Street/Forest Lane to assess potential hazards associate with Project-related vehicle volumes. This intersection, which is presently all-way stop controlled, was selected based on the volume of Project-related vehicle traffic added along multiple approaches (Huntington Avenue and Herman Street). Signal warrants were tested based on the Peak Hour methodology described in the CA-MUTCD Section 4C.04. There are no other unsignalized intersections in the study area where the Project is expected to add substantial volume on unsignalized approaches.

The Huntington Avenue/Herman Street/Forest Lane intersection meets the peak hour signal warrant under all analysis scenarios during the PM peak hour, including existing, 2024 No Project, 2024 plus Phase 1, 2040 No Project, and 2040 Plus Project Buildout conditions. The intersection experienced six injury collisions between 2015 and 2019. Phase 1 of the Project would add approximately 11 PM peak hour trips to the intersection during the PM peak hour, which is unlikely to materially change the intersection’s operations.

The Project Buildout would add approximately 301 PM peak hour trips, which would more substantially affect intersection operations. The addition of Project Buildout-related trips may exacerbate risk of collisions Southline Specific Plan
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April 2022
56 at this multi-lane stop-controlled intersection, which experienced eight reported injury collisions between 2014 and 2019 (five vehicle-vehicle collisions, two vehicle-pedestrian collisions, and one-vehicle-bicycle collision).14

4.4.2 Freeway Ramp Queuing Analysis
Ten freeway off-ramps were analyzed based on Project trip assignment patterns to assess conditions where the addition of Project trips may result in hazards to road users. The study locations are listed below and shown in Figure 3-10.

1. I-280 Southbound Off-Ramp at Rollingwood Drive & Sneath Lane

2. I-280 Southbound Off-Ramp at San Bruno Avenue

3. I-280 Northbound Off-Ramp at San Bruno Avenue

4. US-101 Southbound Off-Ramp at San Bruno Avenue

5. US 101 Northbound Off-Ramp at San Bruno Avenue

6. I-380 Westbound Off-Ramp at El Camino Real

7. I-380 Eastbound Off-Ramp at El Camino Real

8. US-101 Southbound Off-Ramp at Airport Boulevard

9. US-101 Southbound Off-Ramp at Produce Avenue

10. US-101 Northbound Off-Ramp at South Airport Boulevard Traffic counts were collected at the approaches and departures to the ten freeway on- and off-ramps during the morning (7:00 AM to 9:00 AM) and evening (4:00 PM to 6:00 PM) peak periods in 2017 and 2019 prior to the onset of the COVID-19 pandemic, as further described above. During all counts, weather conditions were generally dry, no unusual traffic patterns were observed, and local school districts were in regular session. Table 4-5 and Table 4-6. present weekday AM and PM peak hour vehicle queues at the ten US-101 off-ramp study locations under existing, 2024 (Phase 1), and 2040 (Project Buildout) conditions.

Due to the Project’s access to these ten freeway ramps for US-101, I-280, and I-380 via several roadways and driveways, Project-related traffic would distribute across a number of potential routes including arterials and other roadways. Consequently, Project-related traffic volumes would not result in queues exceeding the total ramp storage distance to the freeway mainline at any of the study locations under any scenarios.

As such, the Project is not expected to create or contribute to hazards resulting from speed differentials at off-ramp diverges on Caltrans facilities.
14 California Statewide Integrated Traffic Records System (SWITRS), 2014-2019, retrieved via the Transportation Injury Mapping System (TIMS)
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57 Table 4-5. Existing and 2024 Weekday AM and PM Peak Hour 95th Percentile Queues Approach Lanes Storage Distance (ft)
Existing 2024 No Project 2024 Plus Project (Phase 1)
Queue Length Queue Length Queue Length

AM PM AM PM AM PM

1. I-280 Southbound Off-Ramp at Rollingwood Drive & Sneath Lane Left/Through 1,200 65 190 68 197 77 203
Right 150 65 72 67 62 68 66

2. I-280 Southbound Off-Ramp at San Bruno Avenue*
Left 120 197 153 205 158 209 161
Left/Through 840
183 90 190 92 197 96
Through/Right 3,615
Right 80 54 51 58 51 62 57

3. I-280 Northbound Off-Ramp at San Bruno Avenue*
Left 230 405 225 415 426 230 405
Through/Left/Right 1,335 1,015 1,372 959 1,391 1,335 1,015

4. US-101 Southbound Off-Ramp at San Bruno Avenue*
Left 280 112 81 112 84 56 86
Left/Through 960 112 82 112 84 56 86
Right 280 24 130 24 136 24 140

5. US 101 Northbound Off-Ramp at San Bruno Avenue*
Left/Through 2,600 201 424 305 478 2,600 277 201

6. I-380 Westbound Off-Ramp at El Camino Real*
Left 980 246 303 248 303 248 303
Right 980 252 834 280 838 296 799

7. I-380 Eastbound Off-Ramp at El Camino Real*
Left 520 131 340 135 352 157 355
Through/Left/Right 1,760 96 263 105 287 151 306
Right 330 88 245 96 267 118 277

8. US 101 Southbound Off-Ramp at Airport Boulevard
Left 430 208 143 213 166 230 174
Through 720 209 224 220 240 230 254

9. US 101 Southbound Off-Ramp at Produce Avenue
Left 620 220 162 182 168 221 202
Right 100 69 40 58 40 59 42

10. US 101 Northbound Off-Ramp at South Airport Boulevard Left/Through 740 473 176 492 188 492 182
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58 Table 4-5. Existing and 2024 Weekday AM and PM Peak Hour 95th Percentile Queues Approach Lanes Storage Distance (ft)
Existing 2024 No Project 2024 Plus Project (Phase 1)
Queue Length Queue Length Queue Length

AM PM AM PM AM PM
Right 740 45 33 46 34 46 34
Notes: Ramps analyzed using Synchro software; * indicates additional analysis with SimTraffic software. Bold type indicates conditions where queue length exceeds storage capacity due to project volumes (none applicable). Queues do not take into account downstream spillover from adjacent intersections. Storage distance and queues in feet per lane.

Source: Fehr & Peers, 2020
Table 4-6. 2040 Weekday AM and PM Peak Hour 95th Percentile Queues Approach Lanes Storage Distance (ft)
2040 No Project 2040 Plus Project (Buildout)
Queue Length Queue Length

AM PM AM PM

1. I-280 Southbound Off-Ramp at Rollingwood Drive & Sneath Lane Left/Through 1200 105 215 118 230
Right 150 74 91 104 103

2. I-280 Southbound Off-Ramp at San Bruno Avenue*
Left 120 232 179 243 195
Left/Through 840
221 102 227 120
Through/Right 3615
Right 80 68 68 74 79

3. I-280 Northbound Off-Ramp at San Bruno Avenue*
Left 230 405 225 415 426
Through/Left/Right 1,335 1,015 1,372 959 1,391

4. US-101 Southbound Off-Ramp at San Bruno Avenue*
Left 280 115 87 65 88
Left/Through 960 116 87 65 89
Right 280 26 138 26 138

5. US 101 Northbound Off-Ramp at San Bruno Avenue*
Left/Through 2,600 201 424 305 478

6. I-380 Westbound Off-Ramp at El Camino Real*
Left 980 253 212 250 217
Right 980 331 668 359 637

7. I-380 Eastbound Off-Ramp at El Camino Real*
Left 520 157 294 234 378
Through/Left/Right 1,760 170 271 271 312
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59 Table 4-6. 2040 Weekday AM and PM Peak Hour 95th Percentile Queues Approach Lanes Storage Distance (ft)
2040 No Project 2040 Plus Project (Buildout)
Queue Length Queue Length

AM PM AM PM
Right 330 160 252 242 273

8. US 101 Southbound Off-Ramp at Airport Boulevard
Left 430 278 253 360 270
Through 720 282 307 368 318

9. US 101 Southbound Off-Ramp at Produce Avenue
Left 620 208 182 272 226
Right 100 63 43 63 45

10. US 101 Northbound Off-Ramp at South Airport Boulevard Left/Through 740 526 283 514 274
Right 740 46 39 47 39
Notes: Ramps analyzed using Synchro software; * indicates additional analysis with SimTraffic software . Bold type indicates conditions where queue length exceeds storage capacity due to project volumes (none applicable). Storage distance and queues in feet per lane.

Source: Fehr & Peers, 2020

4.4.3 Transit Performance Analysis
This section analyzes the Project’s effects on the performance of transit services, including delay to transit vehicles and effects on transit capacity.

4.4.3.1 Transit Delay
The Phase 1 Project and Project Buildout would generate vehicle trips in the vicinity of existing transit services, which could potentially contribute toward delays for transit operations. To assess the Project’s potential effects on transit travel times and delay to transit riders, the VISSIM traffic analysis software was used to report total travel times for the ECR SamTrans bus route, which diverts via Sneath Lane from El Camino Real to serve the San Bruno BART Station. This route was analyzed because it provides the most frequent service and would be most heavily exposed to Project-related delays; findings would also apply for portions of the 140 and 141 SamTrans bus routes that overlap with the ECR route. Table 4-7 shows travel times along these transit routes under 2040 No Project and 2040 Plus Project Buildout conditions. Travel times are taken for the portion of each route that travels from El Camino Real along Sneath Lane to the BART Station, then returning to El Camino Real; this represents around one mile worth of travel.

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60 Table 4-7. Average ECR Travel Times between El Camino Real and the San Bruno BART Station
Study Period
Round Trip Transit Travel Time (Minutes)
Existing 2040 No Project 2040 Plus Project Project Effect (2040) AM Peak Hour (ECR NB) 6 6 7 +1
AM Peak Hour (ECR SB) 7 7 8 +1
PM Peak Hour (ECR NB) 6 6 9 +3
PM Peak Hour (ECR SB) 8 8 11 +3
Notes: Travel times measured include the time needed to travel through the El Camino Real/Sneath Lane intersection via the route diversion through the San Bruno BART Station Transit Center. Values rounded to nearest minute. Based on Vissim simulation.

Source: Fehr & Peers, 2020
The Project Buildout would result in a change of transit travel times for the ECR route totaling about one minute each way in the AM peak hour and three minutes each way in the PM peak hour. During the PM peak hour, congestion associated with added vehicle trips at the split phase signal at the El Camino Real/Sneath Lane intersection represents the primary source of delay. Given the route operates every 15 minutes during the AM and PM peak periods, and has a one-way travel time of about 110 minutes, this change in travel time is unlikely to affect the route’s performance overall or require additional buses to maintain comparable headways. Since traffic volumes will be lower under Phase 1 Project conditions, the Phase 1 Project is also unlikely to affect the performance of bus services.

4.4.3.2 Transit Capacity and Crowding
The Phase 1 Project and Project Buildout are anticipated to add net new transit trips to both BART, Caltrain, and SamTrans during the AM and PM peak commute periods. BART and Caltrain currently experience peak period crowding along certain segments of key routes. A majority of transit trips would occur via BART (up to about 800 to 900 Project-related peak hour trips under Project Buildout conditions), while trips would also occur on Caltrain (300 to 400 peak hour trips) and SamTrans (70 to 80 peak hour trips). Phase 1 of the Project would add slightly less than one quarter of these Project Buildout totals.

Project-related BART trips would largely travel in the reverse-commute direction in which BART has ample capacity. Under existing conditions, about 60 to 65 percent of BART passengers riding between San Bruno and South San Francisco are traveling northbound during the AM peak hour and Southbound during the PM peak hour. San Bruno Station mirrors these patterns, with most passengers entering the station during the AM peak hour and exiting during the PM peak hour. The Project would shift these patterns to nearly balance segment volumes between South San Francisco and San Bruno, and would shift station access patterns at San Bruno Station such that a majority of passengers would exit the station during the AM peak hour and enter the station during the PM peak hour. However, the total number of passengers entering/exiting the station or waiting on the platform would be similar to existing conditions but would occur in a reverse commute direction. As an example, under Project Buildout conditions, the total number of PM station entries would be 926, around 200 more entries than the existing 718 station entries in the AM Southline Specific Plan
Transportation Impact Analysis
April 2022
61 peak hour. In both the AM and PM peak periods, BART trains and platforms at San Bruno Station maintain sufficient capacity to handle these increases in passenger volumes.

BART capacity is highly constrained on service segments through the Transbay Tube between Oakland and San Francisco. Based on existing ridership data, around 13 percent of BART riders entering or exiting the system at San Bruno, South San Francisco, and Millbrae Stations have an origin or destination in the East Bay and travel through the Transbay Tube (most stations in the East Bay are greater than 40 minutes away).

The Project Buildout is expected to have similar travel patterns, adding approximately 100 to 120 trips to the Transbay Tube during the peak hours. While capacity is highly constrained in these periods, this represents a less than one percent contribution to total ridership on this segment of the system under existing conditions and by extension under cumulative conditions as well. In addition, trips would be spread across multiple trains during each peak hour, with an expected increase of only 15 to 20 riders per train, representing one to two additional passengers in each BART car. Therefore, the Project Buildout and Phase 1 Project would not materially affect BART performance or crowding.

Table 4-8 summarizes the Project Buildout’s effect on total activity at San Bruno station, ridership on the segment nearest the Project, and ridership in the Transbay Tube.

Table 4-8. Project Buildout Effect on Total Activity at San Bruno BART Station Study
Period Direction Project Buildout BART Trip Generation
2019 Passenger
Count
2019 + Project
Buildout
San Bruno BART Station Passenger Volumes
AM Entries (Peak) 65 718 783
AM Exits (Reverse Peak) 816 187 1,003
PM Exits (Peak) 105 679 784
PM Entries (Reverse Peak) 678 248 926
San Bruno – South San Francisco Segment
AM Northbound (Peak) 65 2,102 2,167
AM Southbound (Reverse Peak) 816 1,267 2,083
PM Southbound (Peak) 105 2,013 2,118
PM Northbound (Reverse Peak) 678 1,073 1,751
Transbay Tube (Embarcadero – West Oakland Segment)
AM Westbound (Peak) 122 17,395 17,517
PM Eastbound (Peak) 102 15,839 15,941
Notes: In/out split for BART passengers assumed to be similar to vehicle trip generation. Source: BART, 2019, Fehr & Peers, 2020 Caltrain riders would access the Project via South San Francisco or San Bruno stations, depending on service schedules after completion of the Peninsula Corridor Electrification Project. Trip distribution via Caltrain is expected to roughly mirror existing conditions, with about two-thirds of Project-related travel traveling northbound in the AM peak period and southbound in the PM peak period. This distribution would result Southline Specific Plan
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April 2022
62 in approximately 233 northbound passengers during the AM peak period and 195 southbound passengers during the PM peak period. Spread across six trains per hour, per direction, the Project would add an average of about 30 to 40 passengers per train, or about five to six passengers per train car. Upon electrification, Caltrain would have capacity for 5,400 passengers per hour, per direction – about 900 passengers per train operating six trains per hour, per direction. Given the Project Buildout’s contribution to Caltrain capacity would be about four percent or less, it is anticipated that the Project Buildout and Phase 1 Project would have a relatively minor effect on Caltrain capacity.

A relatively small share of Project travel is expected to occur via SamTrans – about 70 to 80 peak hour trips, which would roughly translate to five to ten passengers per bus. SamTrans presently has sufficient capacity to handle this demand and is likely to be able to accommodate Project trips in the future.

4.4.4 Bicycle and Pedestrian Analysis
The project would add approximately 1,000 to 1,100 pedestrian and bicycle trips to and from the site during the AM and PM peak hours (of which 90 percent would be walking or biking to or from transit). In particular, the Project is likely to add bicycle trips along the Centennial Way Trail, Huntington Avenue, South Linden Avenue, and Sneath Lane, which are designated bicycle routes by the cities of South San Francisco and San Bruno.

The Project Buildout would also add vehicle trips along designated bicycle routes and in areas with high levels of pedestrian activity. Such areas would include Huntington Avenue, South Linden Avenue, Sneath Lane, San Bruno Avenue, and the edges of downtown San Bruno and downtown South San Francisco.

However, since Project traffic would be distributed across several routes accessing freeway ramps, walking and biking conditions are not expected to be adversely affected by Project Buildout or Phase 1 traffic volumes relative to No Project conditions.

4.4.5 Emergency Vehicle Analysis
The Project’s primary potential to affect emergency vehicle access would be through design features that do not fully accommodate emergency vehicles, or through Project-generated vehicle traffic that would cause emergency vehicles to be slowed or unable to access the site or surrounding areas. The Phase 1 Project and Project Buildout would increase vehicular delay on several roadways and at several nearby intersections; however, this delay is not bidirectional, and emergency vehicles retain the ability to utilize other traffic lanes to circumvent traffic congestion. In particular, the San Bruno Police Station at 1177 Huntington Avenue would retain the ability to travel both with and against the flow of vehicle traffic should an emergency response be necessary directly from the station (emergency responses from police vehicles usually occur from the field). In addition, the Project provides an additional route for emergency vehicles to access the Project vicinity through construction of the new intersection at Sneath Lane, Huntington Avenue, and Southline Avenue. Consequently, the Phase 1 Project and Project Buildout are not anticipated to adversely affect emergency vehicle operations.

Southline Specific Plan
Transportation Impact Analysis
April 2022
63 5. Impacts and Mitigations

5.1 Vehicular Traffic

5.1.1 Vehicle Miles Traveled
Impact TRANS-1A: Development of the proposed Phase 1 Project would have a less-than-significant impact on vehicle miles traveled due to the Project’s location, transit-oriented nature, and other characteristics. (Less-than-Significant) Impact TRANS-1B: Development of the proposed Project Buildout would have a less-than-significant impact on vehicle miles traveled due to the Project’s location, transit-oriented nature, and other characteristics. (Less-than-Significant) As documented in Section 4.2, the proposed Project meets the criteria set by the California Governor’s Office of Planning and Research and CEQA statute to establish the presumption of a less-than-significant impact on VMT. Specifically, the Project is an employment center located within ½ 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, and Project elements designed to encourage transit use and reduce the number of automobile trips to and from the site. As such, the Phase 1 Project and Project Buildout would have a lessthan-significant impact on VMT, and no mitigation is required.

Mitigation Measures: None required.

Impact TRANS-2A: Development of the proposed Southline Avenue extension under Phase 1 would have a less-than-significant impact on vehicle miles traveled due to its short distance, and nature as a connector rather than a regional roadway facility. (Lessthan-Significant) Impact TRANS-2B: Development of the proposed Southline Avenue extension under Project Buildout would have a less-than-significant impact on vehicle miles traveled due to its short distance, and nature as a connector rather than a regional roadway facility. (Lessthan-Significant) As documented in Section 4.2, the proposed Southline Avenue extension is not expected to increase VMT as a street extension one quarter mile in length with mostly local circulation effects. Therefore, the Southline Avenue extension associated with the Phase 1 Project and Project Buildout would have a less-thansignificant impact on VMT, and no mitigation is required.

Mitigation Measures: None required.

Southline Specific Plan
Transportation Impact Analysis
April 2022
64 5.2 Design Hazards

5.2.1 Geometric Design Hazards
Impact TRANS-3A: Development of the proposed Phase 1 Project would not increase hazards to street users due to a design feature or land uses incompatible with the surrounding street network. (Less-than-Significant)
Impact TRANS-3B: Development of the proposed Project Buildout would not increase hazards to street users due to a design feature or land uses incompatible with the surrounding street network. (Less-than-Significant)
As documented in Section 4.3.1, the Phase 1 Project and Project Buildout include a range of improvements to vehicle, pedestrian, bicycle, and transit infrastructure that would be consistent with design standards and compatible with the intensity of proposed employment uses. Therefore, the Phase 1 Project and Project Buildout would have a less-than-significant impact on design hazards, and no mitigation is required.

Mitigation Measure: None required.

5.2.2 Freeway Ramp Queuing
Impact TRANS-4A: Development of the proposed Phase 1 Project would not add vehicle trips to existing freeway off-ramp vehicle queues that exceed storage capacity resulting in a potentially hazardous condition, and as such would have a less than significant impact on freeway ramp queuing. (Less-than-Significant) Impact TRANS-4B: Development of the proposed Project Buildout would not add vehicle trips to existing freeway off-ramp vehicle queues that exceed storage capacity resulting in a potentially hazardous condition, and as such would have a less than significant impact on freeway ramp queuing. (Less-than-Significant) As documented in Section 4.4.2, neither the Phase 1 Project vehicle trips nor the Project Buildout vehicle trips would exceed ramp storage capacities at any of the intersections studied, and would not lead to potential hazardous interference with the freeway mainline. Therefore, the Phase 1 Project and Project Buildout would have a less-than-significant impact on freeway ramp queuing, and no mitigation is required.

Mitigation Measures: None required

5.2.3 At-Grade Rail Crossings
Impact TRANS-5A: Development of the proposed Phase 1 Project would increase vehicle queues beyond available storage at the South Linden Avenue grade crossing but would not exacerbate risk of collisions; therefore, it would have a less than significant impact on at-grade rail crossing hazards. (Less-than-Significant) Southline Specific Plan
Transportation Impact Analysis
April 2022
65 Impact TRANS-5B: Development of the proposed Project Buildout would increase vehicle queues beyond available storage at the South Linden Avenue grade crossing but would not exacerbate risk of collisions; therefore, it would have a less than significant impact on at-grade rail crossing hazards. (Less-than-Significant) The Project would result in substantial increased traffic volumes at the realigned at-grade rail crossing at South Linden Avenue. As discussed in section 4.3.3 this increase in traffic volumes would lengthen vehicle queues across available storage area. However, the synchronization of traffic signals and presence of medians would limit the risk of collisions associated with Project-related traffic. Synchronized traffic signals included in the Project would minimize potential risk of conflicts since vehicles would be flushed out of the rail crossing prior to a train approaching. The inclusion of medians enhances safety by inhibiting vehicles from traveling around crossing gates through provision of a physical barrier to doing so. Therefore, the Project would have a less-than-significant impact on the South Linden Avenue at-grade rail crossing, and no mitigation is required.

Mitigation Measure: None required.

Impact TRANS-6A: Development of the proposed Phase 1 Project would decrease vehicle volumes, and therefore vehicle queues, at the Scott Street at-grade rail crossing and would not exacerbate risk of collisions, resulting in no impact to the at-grade rail crossing. (Less-than-Significant)
Impact TRANS-6B: Development of the proposed Project Buildout would decrease vehicle volumes, and therefore vehicle queues, at the Scott Street at-grade rail crossing and would not exacerbate risk of collisions, resulting in no impact to the at-grade rail crossing. (Less-than-Significant)
The Project would result in a net decrease in traffic volumes crossing the Caltrain corridor along Scott Street.

As discussed in Section 4.3.3, some vehicle traffic crossing the Caltrain corridor at Scott Street would shift to Southline Avenue, resulting in a net decrease in vehicle volumes and queues on Scott Street. As a result, the Phase 1 Project and Project Buildout would have a less-than-significant impact on the Scott Street atgrade rail crossing, and no mitigation is required.

Mitigation Measure: None required.

5.2.4 Traffic Signal Warrant
Impact TRANS-7A: Development of the proposed Phase 1 Project would not meet any traffic signal warrants within the Specific Plan area, and as such the Phase 1 Project results in a less than significant impact. (Less-than-Significant)
Impact TRANS-7B: Development of the proposed Project Buildout would not meet any traffic signal warrants within the Specific Plan area, and as such the Project Buildout results in a less than significant impact. (Less-than-Significant)
Southline Specific Plan
Transportation Impact Analysis
April 2022
66 As discussed in Section 4.3.2, none of the Project’s five unsignalized driveways meet peak hour signal warrants, and the Project provides appropriate pedestrian crossing treatments at unsignalized crossings. As a result, the Phase 1 Project and Project Buildout would have a less-than-significant impact on traffic signal warrants, and no mitigation is required.

Mitigation Measure: None required.

Impact TRANS-8A: Development of the proposed Phase 1 Project would meet Peak Hour Signal Warrant at the City of San Bruno’s Huntington Avenue/Herman Street/Forest Avenue Intersection; however, conditions would not change materially from existing conditions, and as such the Phase 1 Project results in a less than significant impact at this location. (Less-than-Significant)
Impact TRANS-8B: Development of the proposed Project Buildout would meet Peak Hour Signal Warrant at the Huntington Avenue/Herman Street/Forest Avenue Intersection, resulting in a significant impact. (Significant)
As documented in Section 4.4.1, the Project would result in a net increase of about 11 PM vehicle trips under Phase 1 conditions and 301 PM peak hour trips under Project Buildout conditions at the intersection of Huntington Avenue/Herman Street/Forest Avenue. This intersection meets CA-MUTCD peak hour signal warrant during the PM peak hour under Existing, 2024 No Project, and 2040 No Project conditions. The addition of Project Buildout traffic would substantially contribute to the need for a signal at this intersection; Phase 1 traffic would not materially change conditions relative to no Project conditions. As such, the Project Buildout would have a significant impact at this location, while Phase 1 would have a less than significant impact.

Mitigation Measures: The Project Sponsor should provide a fair share contribution towards implementation of a traffic signal at the intersection of Huntington Avenue/Herman Street/Forest Avenue to alleviate potential conflicts associated with Project Buildout-related traffic. However, the traffic signal is not presently included in a capital improvement or fee program adopted by the City of San Bruno, therefore, the City of San Bruno does not have a plan or mechanism for funding this mitigation and cannot ensure this mitigation occurs will be implemented. Therefore, while the proposed mitigation could reduce the Project Buildout impact on this intersection to a less-than-significant level, because a funding mechanism does not exist, the impact would be remain significant and unavoidable. (Significant and Unavoidable)

5.3 Emergency Vehicle Access
Impact TRANS-9A: Development of the proposed Phase 1 Project would not produce a detrimental impact to emergency vehicle access in the study area. (Less-than-Significant) Impact TRANS-9B: Development of the proposed Project Buildout would not produce a detrimental impact to emergency vehicle access in the study area. (Less-than-Significant) Southline Specific Plan
Transportation Impact Analysis
April 2022
67 As documented in Section 4.4.5, the Project would not include design elements that would hinder emergency access, and all roadways and facilities will be designed to accommodate emergency vehicles including fire trucks and fire engines. The Project would result in increased travel times and vehicular delay on Huntington Avenue and Sneath Lane near the Project, particularly for the portion of Sneath Lane between the Project and El Camino Real during the PM peak hour. While this increase in vehicular delay is expected to also affect emergency vehicles, Sneath Lane includes additional right of way in the form of the Class II Bicycle Lane that allows for vehicles to yield to emergency vehicles that have engaged sirens and flashers. Thus, while there may be some delay to emergency vehicles with the Project, it is not expected to adversely affect emergency vehicle access or response times. Therefore, the Phase 1 Project and Project Buildout would have a less than significant impact on emergency vehicle access and no mitigation is required.

Mitigation Measures: None required.

5.4 Bicycle, Pedestrian, and Transit
Impact TRANS-10A: Development of the proposed Phase 1 Project would not conflict with adopted policies, plans, or programs regarding transit, bicycle, or pedestrian facilities and results in a less than significant impact based on compliance with such plans and policies. (Less-than-Significant)
Impact TRANS-10B: Development of the proposed Project Buildout would not conflict with adopted policies, plans, or programs regarding transit, bicycle, or pedestrian facilities and results in a less than significant impact based on compliance with such plans and policies. (Less-than-Significant)
As documented in Section 4.1, the Project exhibits consistency with plans, policies, and programs adopted by the City of South San Francisco, City of San Bruno, C/CAG, BART, and MTC. The Project would provide employment near regional transit, would enhance bicycle and pedestrian facilities to support transit access, would connect local street networks, and would include a TDM program that meets City requirements.

Therefore, the Phase 1 Project and Project Buildout would not conflict with adopted policies, plans, or programs and would have a less than significant impact.

Impact TRANS-11A: Development of the proposed Phase 1 Project would increase travel times for some bus routes, but would not decrease the overall performance of transit service, and as such results in a less than significant impact on transit. (Less-than-Significant) Impact TRANS-11B: Development of the proposed Project Buildout would increase travel times for some bus routes, but would not decrease the overall performance of transit service, and as such results in a less than significant impact on transit. (Less-thanSignificant) Southline Specific Plan
Transportation Impact Analysis
April 2022
68 As documented in Section 4.4.3, the Project would increase average transit travel times on SamTrans ECR bus route (and portions of SamTrans routes 140 and 141) by one to three minutes, but is unlikely to affect the route’s performance overall or require additional buses to maintain comparable headways. No other routes operating in the Project vicinity would have increased average transit times due to the Project. The Project would also add transit ridership to BART, SamTrans, and Caltrain, but would not materially contribute to overcrowding. In addition, the Project delivers pedestrian infrastructure designed to enhance access to the SamTrans transit center and BART station. Therefore, the Phase 1 Project and Project Buildout would have a less than significant impact on transit performance and no mitigation is required.

Mitigation Measure: None required.

Impact TRANS-12A: Development of the proposed Phase 1 Project would not detrimentally affect the performance or safety of bicycle or pedestrian facilities, resulting in a less than significant impact. (Less-than-Significant)
Impact TRANS-12B: Development of the proposed Project Buildout would not detrimentally affect the performance or safety of bicycle or pedestrian facilities, resulting in a less than significant impact. (Less-than-Significant)
As documented in Section 4.4.4, the Project would not degrade the performance or safety of bicycle or pedestrian facilities. The Project would extend the Centennial Way Trail, enhance bicycle and pedestrian access to the San Bruno BART Station, and provide new bike lane and sidewalk facilities. Therefore, the Phase 1 Project and Project Buildout would have a less than significant impact on bicycle and pedestrian facilities, and no mitigation is required.

Mitigation Measure: None required.

Southline Specific Plan
Transportation Impact Analysis
April 2022
69 6. Partial Circulation Network
Alternative
The Partial Circulation Network Alternative considers the same Phase 1 and Project Buildout land use and TDM program but with fewer infrastructure changes associated with the Project. Specifically, the Partial Circulation Network Alternative would include a partial buildout of Southline Avenue but omit the new street connection between Huntington Avenue/Sneath Lane and Southline Avenue/Maple Avenue as well as pedestrian and bicycle improvements to enhance access to BART and SamTrans facilities and extend the Centennial Way Trail (referred to as the “Partial Circulation Network Alternative”; see Figure 6-1). This section analyzes the transportation and circulation effects of the Partial Circulation Network Alternative under both the Phase 1 Project and Project Buildout conditions.

6.1 Plan and Policy Consistency Analysis
The Partial Circulation Network Alternative would remain consistent with local and regional plans and policies. The Partial Circulation Network Alternative would not implement the connection of Sneath Lane and Southline Avenue, the extension of the Centennial Way Trail, and access improvements to the San Bruno BART Station consistent with adopted plans and policies by the Cities of South San Francisco and San Bruno, C/CAG, BART and MTC. However, the Partial Circulation Network Alternative would not necessarily preclude these changes in the future, and is therefore consistent with applicable plans and policies. The Partial Circulation Network Alternative would remain consistent with regional plans and policies given the Project’s proximity to transit (see Section 4.1).

6.2 VMT Analysis
The Partial Circulation Network Alternative would meet OPR’s criteria for a presumption of less than significant VMT impact based on the Project’s proximity to the San Bruno BART Station and the SamTrans ECR route (see Section 4.2). Transit access conditions would be more challenging under the Partial Circulation Network Alternative, although the Partial Circulation Network Alternative would implement a high-density land use in proximity to a high quality transit corridor, include a parking supply below City requirements for comparable projects, and implement a TDM program to achieve a 45 percent alternative mode share.

Without the Southline Avenue extension to Sneath Lane, the Partial Circulation Network Alternative would not realize the slight decrease in VMT associated with more direct trips between San Bruno and the Lindenville District in South San Francisco. However, this would not affect the presumption of less than significant VMT impact for the Project as a whole.

Project Buildout Partial Circulation Network Site Plan
Figure 6-1
\\Fpsf03.fpainc.local\data\Projects\2020_Projects\SF20-1089_Southline EIR\Graphics\GIS\MXD\CA_Template_LetterPortrait.mxd Southline Specific Plan
Transportation Impact Analysis
April 2022
72 Table 6-1. Queuing at Linden Avenue At-Grade Rail Crossing – Partial Circulation Network Alternative (2040 Project Buildout)
Intersection Movement Storage Space Average Queue
Length (ft)
95th Percentile
Queue Length (ft)
Queue exceeds
storage?
AM Peak Hour
Southline Avenue / Dollar
Avenue WBT 80 570 590 Yes
Southline Avenue / Dollar
Avenue WBL 60 560 580 Yes
Linden Avenue/ San Mateo
Avenue SBT 450 100 130 No
Linden Avenue/ San Mateo
Avenue SBL 450 200 240 No
PM Peak Hour
Southline Avenue / Dollar
Avenue WBT 80 230 470 Yes
Southline Avenue / Dollar
Avenue WBL 60 220 460 Yes
Linden Avenue/ San Mateo
Avenue SBT 450 190 420 No
Linden Avenue/San Mateo
Avenue SBL 450 320 390 No

6.3.3.2 Scott Street At-Grade Rail Crossing
Without the connection between Sneath Lane and Southline Avenue, the Partial Circulation Network Alternative would increase traffic volumes on the Scott Street at-grade rail crossing. However, queues are not expected to exceed available storage on Scott Street as shown in Table 6-2. Therefore, the Partial Circulation Network Alternative would have a less than significant impact on the Scott Street at-grade rail crossing.

Southline Specific Plan
Transportation Impact Analysis
April 2022
73 Table 6-2. Queuing at Scott Street At-Grade Rail Crossing – Partial Circulation Network Alternative (2040 Project Buildout)
Intersection Movement Storage Space Average Queue
Length (ft)
95th Percentile
Queue Length (ft)
Queue exceeds
storage?
AM Peak Hour
Scott Street / Herman
Street WB 360 60 120 No
Scott Street / San Mateo
Avenue EB 360 60 80 No
PM Peak Hour
Scott Street / Herman
Street WB 360 130 240 No
Scott Street / San Mateo
Avenue EB 360 40 90 No

6.4 Offsite Transportation Analysis

6.4.1 Signal Warrant Analysis
The Partial Circulation Network Alternative would result in the Huntington Avenue/Herman Street/Forest Lane intersection meeting the peak hour signal warrant during the PM peak hour for both the Phase 1 and Project Buildout conditions such that a Significant Impact would occur. Phase 1 would add 133 PM peak hour trips to this intersection, while Project Buildout would add approximately 571 PM peak hour trips.

Under the Partial Circulation Network Alternative, the addition of Phase 1 and Project Buildout-related trips may exacerbate the risk of collisions at this multi-lane stop-controlled intersection, which experienced eight reported injury collisions between 2014 and 2019 (five vehicle-vehicle collisions, two vehicle-pedestrian collisions, and one-vehicle-bicycle collision).15

6.4.2 Freeway Ramp Queueing Analysis
The Partial Circulation Network Alternative would result in queues exceeding the total ramp storage distance to the freeway mainline at one study location (I-280 Northbound Off-Ramp at San Bruno Avenue) under Project Buildout conditions such that a Significant Impact would occur. Under both the Phase 1 and Project Buildout conditions, the Partial Circulation Network Alternative would distribute Project-related vehicle trips across ten freeway ramps for US-101, I-280, and I-380, with slightly more trips using US-101 ramps and slightly fewer trips using ramps to I-380 and I-280. Phase 1 results are shown in Table 6-3, while Project Buildout results are shown in Table 6-4. In addition to the I-280 Northbound Off-Ramp at San Bruno 15 California Statewide Integrated Traffic Records System (SWITRS), 2014-2019, retrieved via the Transportation Injury Mapping System (TIMS)
Southline Specific Plan
Transportation Impact Analysis
April 2022
74 Avenue, queues may exceed storage distance at several other ramp approaches under Phase 1 and Project Buildout conditions, but there are no Phase 1- or Project-related trips added to these ramps.

Table 6-3. Weekday AM and PM Peak Hour 95th Percentile Queues – Partial Circulation Network Alternative (Phase 1)
Approach Lanes
Storage
Distance
(ft)
Existing 2024 No Project 2024 Plus Phase 1
(Partial Circulation)
Queue Length Queue Length Queue Length