Unfortunately, it has been a challenge to work with the State on this, but we continue to persist, and of course we are still interested in early implementation of the TRVA.
Evaluating our Drought Planning Scenario in light of climate change Ever since the drought of 1987-92, we have been using a Drought Planning Scenario with a duration of 8.5 years as a stress test of our Regional Water System supplies. Some stakeholders have criticized this methodology as being too conservative. This fall we anticipate our Commission convening a workshop OUR MISSION: To provide our customers with high-quality, efficient and reliable water, power and sewer services in a manner that values environmental and community interests and sustains the resources entrusted to our care.
regarding our use of the 8.5-year Drought Planning Scenario, particularly in light of climate change resilience assessment work that we have funded through the Water Research Foundation. We look forward to a valuable discussion with our various stakeholders and the Commission.
Pursuing Alternative Water Supplies
The SFPUC continues to aggressively pursue Alternative Water Supplies to address whatever shortfall may ultimately occur pending the outcome of negotiation and/or litigation. The most extreme degree of Regional Water System supply shortfall is modeled to be 93 million gallons per day under implementation of the Bay-Delta Plan amendments. We are actively pursuing more than a dozen projects, including recycled water for irrigation, purified water for potable use, increased reservoir storage and conveyance, brackish water desalination, and partnerships with other agencies, particularly the Turlock and Modesto Irrigation Districts. Our goal is to have a suite of alternative water supply projects ready for CEQA review by July 1, 2023.
In litigation with the State over the Bay-Delta Plan Amendments On January 10, 2019, we joined in litigation against the State over the adoption of the Bay-Delta Water Quality Control Plan Amendments on substantive and procedural grounds. The lawsuit was necessary because there is a statute of limitations on CEQA cases of 30 days, and we needed to preserve our legal options in the event that we are unsuccessful in reaching a voluntary agreement for the Tuolumne River. Even then, potential settlement of this litigation is a possibility in the future.
In litigation with the State over the proposed Don Pedro FERC Water Quality Certification
The State Water Board staff raised the stakes on these matters by issuing a Water Quality Certification for the Don Pedro FERC relicensing on January 15, 2021 that goes well beyond the Bay-Delta Plan amendments. The potential impact of the conditions included in the Certification appear to virtually double the water supply impact on our Regional Water System of the Bay-Delta Plan amendments. We requested that the State Water Board reconsider the Certification, including conducting hearings on it, but the State Water Board took no action. As a result, we were left with no choice but to once again file suit against the State. Again, the Certification includes a clause that it could be replaced by a Voluntary Agreement, but that is far from a certainty.
I hope this makes it clear that we are actively pursuing all options to resolve this difficult situation. We remain committed to creating benefits for the Tuolumne River while meeting our Water Supply Level of Service Goals and Objectives for our retail and wholesale customers.
cc.: SFPUC Commissioners
Nicole Sandkulla, CEO/General Manager, BAWSCA
PO Box 927729, San Diego, CA 92192 • P: (858) 546-0888 • F: (858) 546-0999 May 26
th, 2022
Billy Gross
Principal Planner
[email protected]
Allison Knapp
Consulting Planner
[email protected]
Mitigation Measures for 121 East Grand Avenue, South San Francisco, CA City Project Numbers: ND21-0001 and EIR20-0003
Dear Mr. Gross and Ms. Knapp –
On behalf OCI San Fran, LLC., the owner of 121 E Grand Ave, South San Francisco, CA, (“Project”) and Phase 3 Real Estate Partners, Inc. (Sponsor), I am pleased to present the following Mitigation Measures that ownership will implement as part of the redevelopment of the site. The Project, a 17-story building, is an opportunity to deliver an iconic community and research-focused campus in the center of South San Francisco and adjacent to the newly constructed Caltrain station. These Mitigation Measures are proposed to ensure that the Project meets the City and State’s targets for thoughtful, sustainable, and high-quality redevelopment.
Sustainability:
The 121 East Grand Project will integrate sustainable design throughout the building to the extent that measures are technically and economically feasible. The approach will support the City of South San Francisco’s 2022 Climate Action Plan and the specific goals set forth in the plan. The general design approaches and strategies will include a wide variety of energy reduction, water conservation and renewable energy solutions.
The project has committed to an All-Electric Design for long term reduction of greenhouse gas emissions and the future ability to operate on 100% renewable energy provided by energy company partnerships.
In response to State Senate Bill 100 and the mandated decarbonization of the California electrical grid by 2045, the development will prioritize use of all-electric sources of energy. Common areas where natural gas have been traditionally used include HVAC, domestic hot water, cooking, and process uses (e.g., laboratory, R&D). In most, if not all, of these examples, cost effective and practical all-electric alternatives exist and will be prioritized for this development. Where there are technical impediments for all-electric design approaches or they are substantially more costly, life cycle cost analyses will be performed alongside assessment of relative energy / carbon performance to inform design decisions. This design decision is in alignment with SSF 2022 Climate Action Plan Goals CP-1 and CP-2. 121 E Grand Ave – Mitigation Measures
PO Box 927729, San Diego, CA 92192 • P: (858) 546-0888 • F: (858) 546-0999 The following items will also be considered to improve resiliency and reduce reliance on fossil fuels in accordance with the SSF Climate Action Plan Goals – CP-2:
• Review opportunities for installation of on-site renewable energy (e.g., PV, solar thermal). • Plan locations for future energy storage batteries to reduce peak loads and support grid harmonization.
• Prioritization of all-electric energy sources.
• Installation of electric vehicle charging stations.
• Reduce heat island effect of developments through use of high-albedo surfaces and / or similar technologies.
• Evaluate the purchase of off-site renewable energy to offset at least 50% of building energy use as calculated by building’s Title 24 modeled energy consumption. • Wire building to be solar-ready.
The following items will be considered to reduce the overall building energy use in accordance with the 2022 SSF Climate Action Plan Goals – CP-3-1:
• Optimize building envelopes to balance building energy uses (e.g., artificial lighting, heating, cooling, fans) while also providing healthy, productive spaces for building occupants (e.g. daylight, views, thermal comfort). This reduces the building’s energy use in alignment with CP-3-1 as well as creating better working environments and improving the well-being and overall productivity of the businesses.
• Use of passive design strategies to minimize reliance on active heating and cooling systems. • Selection of energy efficient HVAC system approaches and equipment. • Balance of ventilation and indoor air quality outcomes alongside energy efficiency considerations.
The following items will be considered to reduce the overall building water use in accordance with the SSF 2022 Climate Action Plan Goals – CP-8:
• Use of efficient water consuming devices (e.g. plumbing fixtures, appliances, cooling equipment) to minimize demand for water and manage energy consumption of domestic hot water systems. • Prioritize water efficient landscaping practices.
• Review opportunities to reuse water on-site (e.g. stormwater or greywater reuse) to minimize water consumption and manage site outflows.
• Undertake the following water efficiency measures as outlined by the CAP:
o Establishing a variable-speed pump exchange for water features. o Restricting hours of irrigation to occur between 3:00 a.m. and two hours after sunrise. o Installing irrigation controllers with rain sensors.
o Landscaping with native, water-efficient plants.
o Installing drip irrigation systems.
o Reducing impervious surfaces.
121 E Grand Ave – Mitigation Measures
PO Box 927729, San Diego, CA 92192 • P: (858) 546-0888 • F: (858) 546-0999 Biology:
Sponsor is committed to ensuring that tree removal minimizes its impact on the local population of native wildlife. In order to ensure this goal, the Project is committed to:
• Tree Removal Outside Nesting Season (approximately September 1 to February 28). Sponsor will obtain a tree permit as required per South San Francisco Municipal Code Section 13.30.030, which specifies: as: (1) Any tree with a circumference of forty-eight inches or more when measured fifty-four inches above natural grade; or (2) A tree or stand of trees so designated by the director based upon findings that it is unique and of importance to the public due to its unusual appearance, location, historical significance or other factor; or (3) A stand of trees in which the director has determined each tree is dependent upon the others for survival. Prior to removing trees, the Project Sponsor, or designated representativ shall contact the Parks Division to determine if a removal permit is needed.
• Tree Removal Within Nesting Season (approximately March 1 to August 31). Sponsor will retain a qualified biologist to conduct a pre-construction survey for protected birds on the site and in the immediate vicinity if Project construction activities occur during nesting season. No construction activities of any kind, including but not limited to tree and landscape removal, demolition, site grubbing, grading, etc shall occur until the survey is completed. The survey shall be done no more than 15 days prior to the initiation of tree removal and grading and other construction activities. In the event that nesting birds are found on the Project site or in the immediate vicinity, Project Sponsor, or designated representative shallnotify the City, locate and map the nest site(s) within three (3) days, submit a report to the City and the California Department of Fish and Wildlife ("CDFW"), establish a no-disturbance buffer of 250-ft, and conduct on-going weekly surveys to ensure the no-disturbance buffer is maintained. In the event of destruction of a nest with eggs, or if a juvenile or adult raptor should become stranded from the nest, injured or killed, the qualified biologist shall immediately notify the CDFW. The licensed biologist shall coordinate with the CDFW to have the injured bird either transferred to a raptor recovery center or, in the case of mortality, transfer it to the CDFW within 48 hours of notification.
Cultural:
Sponsor does not believe construction activities will encounter culturally significant soils or resources but there is always a remote possibility of a find. That being the case, prior to the start of ground-disturbing grading, demolition, or construction, a Worker Awareness Environmental Training (WAET) shall be conducted by a licensed archaeologist in the state of California. WAET training shall be required for all personnel participating in ground disturbing construction to alert them to the archaeological sensitivity of the Project area and provide protocols to follow in the event of a discovery of archaeological materials.
Additionally, the Archaeologist shall be on an “on-call” basis to review and identify any potential archaeological discoveries during ground disturbing grading, demolition and excavation operation. In the event of a discovery, work shall stop within 50 feet of the find. Archaeologist shall be contacted for identification, evaluation and further recommendations consistent with California Environmental Quality Act and City of South San Francisco requirements. The grading, demolition and any other plans that require soil disturbance shall note that there is a potential for exposing buried cultural resources including prehistoric Native American burials on the site. The Sponsor’s Archaeologist shall develop and distribute for job site posting an "ALERT SHEET" summarizing potential finds that could be exposed and the protocols to be followed as well as points of contact to alert in the event of a discovery. 121 E Grand Ave – Mitigation Measures
PO Box 927729, San Diego, CA 92192 • P: (858) 546-0888 • F: (858) 546-0999 Upon any discovery of culturally significant findings Sponsor will stop work and contact the on-call archaeologist. If the Archaeologist determines that any cultural resources exposed during construction constitute a historical resource and/or unique archaeological resource under CEQA, the Archaeologist shall notify the appropriate parties of the evaluation and recommend mitigation measures to mitigate to a less-than significant impact in accordance with California Public Resources Code Section 15064.5.
Mitigation measures may include avoidance, preservation in-place, recordation, additional archaeological testing and data recovery among other options. The completion of a formal Archaeological Monitoring Plan (AMP) and/or Archaeological Treatment Plan (ATP) that may include data recovery may be recommended by the Professional Archaeologist if significant archaeological deposits are exposed during ground disturbing construction. Development and implementation of the AMP and ATP and treatment of significant cultural resources will be determined by the project proponent in consultation with any regulatory agencies.
The treatment of human remains, and any associated or unassociated funerary objects discovered during any soil-disturbing activity within the Project site shall follow the requirements of section 5097.99 of the Public Resources Code. The Project Sponsor shall immediately notify of the appropriate county Coroner/Medical Examiner, Project Sponsor and the City of South San Francisco. A Monitoring Closure Report shall be filed with the Applicant/Project Sponsor/designated representative and the City at the conclusion of ground disturbing construction if archaeological and Native American monitoring of excavation was undertaken.
Geology and Soils:
Sponsor will update the Geocon April 2021 report and provide to the City for peer review prior to any issuance of building, grading, grubbing or tree removal permits. The updated report shall address the revised Project description and include all design measures required to be compliant with the California Building Code. The updated report shall also include at a minimum, structural design and construction specifications, including but not limited to, undergrounding of utilities addressing any construction requirements for potentially and/or corrosive soils, grading, site stabilization, drainage, utility and infrastructure design and placement, foundation design, retaining wall specifications, and soil compaction requirements and design.
Downtown Station Area Specific Plan (DSASP):
Sponsor is familiar with the Downtown Station Area Specific Plan and will incorporate the following mitigations:
• DSASP Mitigation Measure 4.6-1: HVAC Mechanical Equipment Shielding. Prior to the approval of building permits for non-residential development, the applicant shall submit a design plan for the Project demonstrating that noise from the operation of mechanical equipment will not exceed the exterior noise level limits for a designated receiving land use category, as specified in Noise Ordinance Section 8.32.030. Noise control measures may include, but are not limited to, the selection of quiet equipment, equipment setbacks, silencers, and/or acoustical barriers. • DSASP Mitigation Measure 4.6-2: Site-Specific Acoustic Analysis – Nonresidential Development. Prior to the approval of building permits for new non-residential land uses where exterior noise level exceeds 70 dBA CNEL, an acoustic analysis shall be performed to determine appropriate noise reduction measures such that exterior noise levels shall be reduced below 70 dBA CNEL, unless a higher noise compatibility threshold (up to 75 dBA CNEL) has been 121 E Grand Ave – Mitigation Measures
PO Box 927729, San Diego, CA 92192 • P: (858) 546-0888 • F: (858) 546-0999 determined appropriate by the City of South San Francisco. The analysis shall detail the measures that will be implemented to ensure exterior noise levels are compatible with the proposed use.
Measures that may be implemented to ensure appropriate noise levels include, but are not limited to, setbacks to separate the proposed non-residential structure from the adjacent roadway or construction of noise barriers on site.
• DSASP Mitigation Measure 4.6-4: Construction Vibration. For all construction activities within the study area, the construction contractor shall implement the following measures during construction:
▪ The construction contractor shall provide, at least three weeks prior to the start of construction activities, and written notification to all residential units and non-residential tenants within 115 feet of the construction site informing them of the estimated start date and duration of vibration-generating construction activities. ▪ Stationary sources, such as temporary generators, shall be located as far from off-site receptors as possible.
▪ Trucks shall be prohibited from idling along streets serving the construction site. • DSASP Mitigation Measure 4.6-5: Rail Line Groundborne Vibration. The Project shall implement the current FTA and Federal Railroad Administration (FRA) guidelines, where appropriate, to limit the extent of exposure that sensitive uses may have to ground-borne vibration from trains.
Specifically, Category 1 uses (vibration-sensitive equipment) within 300 feet from the rail line, Category 2 uses (residences and buildings where people normally sleep) within 200 feet, and Category 3 uses (institutional land uses) within 155 feet of the rail line shall require a site-specific ground-borne vibration analysis conducted by a qualified ground-borne vibration specialist in accordance with the current FTA and FRA guidelines prior to obtaining a building permit.
Vibration control measures deemed appropriate by the site-specific ground-borne vibration analysis to meet 65 VdB, 72 VdB, and 75 VdB, respectively for Category 1, Category 2, and Category 3 uses, shall be implemented by the project applicant and approved by the City prior to receiving a building permit.
Gathering Spaces:
To promote Policy Goal LU-2 of SHAPE SSF, the Project is incorporating gathering spaces near mobility hubs. Specifically, the Project is including:
• multiple outdoor plazas (with upscale lighting features). • meeting spaces (with upscale seating features).
• retail options.
• a gym/wellness studio.
• public restrooms.
• a restaurant/café.
Traffic:
Sponsor has been and will continue to work collaboratively with the city on the surrounding traffic issues.
Sponsor has provided funding for the 2021 Access Study completed by Fehr & Peers. Sponsor will participate with the neighboring projects to implement the findings of the access study and has committed to significant funding contribution for improvements around the Caltrain station. 121 E Grand Ave – Mitigation Measures
PO Box 927729, San Diego, CA 92192 • P: (858) 546-0888 • F: (858) 546-0999 Utility-Water:
Project Sponsor is aware of Cal Water’s Net Neutral Policy. As a requirement to receive water service the project will need need to implement the policy which will be complete by either (1) paying to the SSF District the required offset amount calculated according to the offset costs included in the Policy, and/or (2) conducting other activities as defined in the Policy.
Federal Aviation Administration (FAA)
Sponsor applied for and secured review and approval from the FAA to exceed the permitted height identified in the Airport Land Use Plan (C/CAG, 2012). On September 9, 2021 FAA published a ‘Determination of No Hazard to Air Navigation.’ (FAA (Public Notice August 8, 2021, and Final Determination September 9, 2021, ASN 2021-AWP-7652-OE / Aeronautical Study Numbers 2021-AWP7644-OE through 2021-AWP-7655-OE. Project Sponsor is aware of and will comply with the following requirements of the FAA.
• The structure is to be marked/lighted in accordance with FAA Advisory circular 70/7460-1 M, Obstruction Marking and Lighting, red lights-Chapters 4, 5 (Red) and 15. • Any failure or malfunction that lasts more than thirty (30) minutes and affects a top light or flashing obstruction light, regardless of its position, should be reported immediately to (877) 487-6867 so a Notice to Airmen (NOTAM) can be issued. As soon as the normal operation is restored, notify the same number.
• An FAA Form 7460-2, Notice of Actual Construction or Alteration is required to be e-filed within five days after the construction reaches its greatest height (7460-2, Part 2).
Phase 3 Real Estate Partners, Inc. is excited to partner with South San Francisco to deliver another worldclass iconic project that serves both the community and the research and development companies that call the City home.
The following are our goals for the Project:
• Design and build an iconic building that honors South San Francisco as the birthplace of Biotechnology;
• Connect and celebrate the East and West areas of the City and the Caltrain Station; • Provide a community gathering space with vibrant indoor and outdoor areas that are safe, comfortable, lighted, usable, landscaped with the environment in the forefront of design and punctuated with world-class art;
• Create an ecosystem that supports scientists in their discovery of the life-changing technologies of the future; and,
• Be a good partner and neighbor to the City of South San Francisco.
Sincerely,
Michael Gerrity, President
Phase 3 Real Estate Partners, Inc.
OCI San Fran, LLC