South San Francisco City Council
September 14, 2022

City of South San Francisco
Planning Division
180 El Camino Real/Steelwave Project
Addendum
August 2022
Prepared by
1501 Sports Drive, Suite A, Sacramento, CA 95834
180 El Camino Real/Steelwave Project
Addendum to an Adopted Environmental Impact Report
Lead Agency:

City of South San Francisco, Planning Division
315 Maple Avenue
South San Francisco, CA 94080
Contact:

Billy Gross, Principal Planner
(650) 877-8535
Prepared By:

Raney Planning and Management, Inc.
1501 Sports Drive, Suite A
Sacramento, CA 95834
(916) 372-6100
Contact:

Nick Pappani
Vice President
August 2022
180 El Camino Real/Steelwave Project
Addendum
Page i
August 2022

TABLE OF CONTENTS
A. INTRODUCTION AND BACKGROUND ......................................................................... 1 B. SUBSEQUENT ENVIRONMENTAL REVIEW................................................................. 1 C. CEQA ANALYSIS APPROACH...................................................................................... 2 D. PROJECT DESCRIPTION .............................................................................................. 3 E. ENVIRONMENTAL IMPACT COMPARISON ...............................................................23 I. AESTHETICS. ......................................................................................... 25 II. AGRICULTURE AND FORESTRY RESOURCES. ................................. 28 III. AIR QUALITY. ......................................................................................... 30 IV. BIOLOGICAL RESOURCES. .................................................................. 40 V. CULTURAL RESOURCES. ..................................................................... 45 VI. ENERGY.................................................................................................. 47 VII. GEOLOGY AND SOILS........................................................................... 52 VIII. GREENHOUSE GAS EMISSIONS.......................................................... 60 IX. HAZARDS AND HAZARDOUS MATERIALS. ......................................... 63 X. HYDROLOGY AND WATER QUALITY. .................................................. 75 XI. LAND USE AND PLANNING. .................................................................. 81 XII. MINERAL RESOURCES. ........................................................................ 84 XIII. NOISE...................................................................................................... 86 XIV. POPULATION AND HOUSING. ............................................................ 101 XV. PUBLIC SERVICES............................................................................... 103 XVI. RECREATION. ...................................................................................... 107 XVII. TRANSPORTATION.............................................................................. 109 XVIII. TRIBAL CULTURAL RESOURCES....................................................... 123 XIX. UTILITIES AND SERVICE SYSTEMS................................................... 125 XX. WILDFIRE.............................................................................................. 131 XXI. MANDATORY FINDINGS OF SIGNIFICANCE. .................................... 133 F. SOURCES ..................................................................................................................................136 Appendices:

Appendix A: Air Quality and Greenhouse Gas Modeling Results Appendix B: Arborist Report
Appendix C: Design-Level Geotechnical Investigation
Appendix D: Phase I ESA and Phase I ESA Update
Appendix E: Technical Noise Study and ALUC Environmental Noise Analysis Appendix F: Transportation Impact Analysis
180 El Camino Real/Steelwave Project
Addendum

August 2022
A. INTRODUCTION AND BACKGROUND
In 2009, a General Plan Amendment (GPA) was proposed to add a new land use designation, El Camino Real Mixed Use, into the City of South San Francisco General Plan. The designation would accommodate high-intensity active uses and mixed-use development in the South El Camino Real area. Under the GPA, properties with frontages along El Camino Real within the South El Camino Real GPA Planning Area would be required to be devoted to active uses, i.e., uses that are accessible to the public and generate walk-in pedestrian clientele and contribute to a high level of pedestrian activity.

In order to evaluate the environmental impacts associated with the proposed South El Camino Real GPA Project, an Environmental Impact Report (EIR) was prepared pursuant to CEQA. On February 10, 2010, the City Council adopted Resolution 19-2010, certifying the South El Camino Real GPA EIR (2009 EIR) (State Clearinghouse [SCH] #2009062070). By certifying the 2009 EIR, the City determined that the 2009 EIR adequately evaluated the environmental impacts of introducing the El Camino Real Mixed Use land use designation and buildout of the South El Camino Real GPA Planning Area (Planning Area) according to the land use designations.

The project site is designated by the General Plan as El Camino Real Mixed Use. As a result, buildout of the project site with uses allowed in the El Camino Real Mixed Use land use designation was generally evaluated within the 2009 EIR. As presented in Tables 2.4-1 and 2.4- 2 of the 2009 EIR, the EIR evaluated buildout of the Planning Area with 840 housing units and approximately 300,000 square feet (sf) of non-residential development. The 180 El Camino Real/Steelwave Project (proposed project) would involve the development of approximately 183 housing units and up to 797,069 sf of non-residential development on a site located within the Planning Area. Therefore, the proposed project would involve a greater non-residential development intensity compared to what was already analyzed in the 2009 EIR. Other non-residential development has not been implemented on other sites within the Planning Area to date, and the development of 300,000 sf of non-residential development was previously approved upon certification of the 2009 EIR. Thus, this document evaluates whether the net addition of up to 497,069 sf of non-residential development would result in any additional impacts beyond those that were identified in the 2009 EIR.

B. SUBSEQUENT ENVIRONMENTAL REVIEW
This Addendum to the 2009 South El Camino Real GPA EIR has been prepared in accordance with the California Environmental Quality Act (CEQA) of 1970, Public Resources Code (PRC) Section 21000 et seq., as amended and the Guidelines for Implementation of the California Environmental Quality Act, California Code of Regulations (CCR) Title 14, Section 15000 et seq. (CEQA Guidelines). Per Section 15164(a) of the CEQA Guidelines, the lead agency or responsible agency shall prepare an Addendum to a previously certified EIR if some changes or additions are necessary but none of the conditions described in Section 15162 calling for preparation of a Subsequent EIR (SEIR) or Negative Declaration have occurred. Per Section 15164(b), an Addendum to a certified EIR may be prepared if only minor technical changes or additions are necessary. The analysis within this document will demonstrate that the proposed modifications to the 2009 South El Camino Real GPA Project will not trigger the criteria set forth 180 EL CAMINO REAL/STEELWAVE PROJECT

ADDENDUM
180 El Camino Real/Steelwave Project
Addendum

August 2022
in Section 15162, and thus, an Addendum is the appropriate CEQA document. See Section C, below, for further information.

Scope of the Addendum
This Addendum includes the following sections that will address various aspects about the proposed project:
• Introduction and Project Background;
• CEQA Analysis Approach;
• Project Description; and
• Environmental Impact Comparison to the 2009 South El Camino Real GPA EIR, using the criteria established by the current CEQA Guidelines.

C. CEQA ANALYSIS APPROACH
In the case of a project proposal requiring discretionary approval by the City for which the City has certified an EIR for the overall project, the City must determine whether an SEIR is required.

The CEQA Guidelines provide guidance in this process by requiring an examination of whether, since the certification of the EIR and approval of the proposed project, changes in the project or conditions have been made to such an extent that the proposal may result in new significant impacts not previously identified or a substantial increase in severity of previously identified significant impacts. If so, the City would be required to prepare an SEIR. The examination of impacts is the first step taken by the City in reviewing the CEQA treatment of the project. The following review proceeds with the requirements of CEQA Guidelines Section 15162 in mind.

Section 15162 is discussed in detail below.

An Addendum to a certified EIR may be prepared if only minor technical changes or additions are required, and none of the conditions identified in CEQA Guidelines Section 15162 are present.

The following identifies the standards set forth in Section 15162(a) as they relate to the project:
(1) Substantial changes are proposed in the project which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;
(2) Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or (3) New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete or the negative declaration was adopted, shows any of the following:
(a) The project will have one or more significant effects not discussed in the previous EIR or negative declaration;
(b) Significant effects previously examined will be substantially more severe than shown in the previous EIR [or negative declaration];
180 El Camino Real/Steelwave Project
Addendum

August 2022
(c) Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or
(d) Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.

Section 15162 provides that the lead agency’s role in project approval is completed upon certification of the EIR or Negative Declaration and approval of the project, unless further discretionary action is required. The approvals requested as part of the project are considered discretionary actions. Therefore, CEQA review is required.

Confirmation of Addendum
The following discussion confirms that the project has been evaluated for significant impacts pursuant to CEQA. The discussion is meaningfully different than a determination that the project is “exempt” from CEQA review, which is not the case. Rather, the determination here is that the project’s impacts have been considered in a previous CEQA document (i.e., the 2009 EIR) that was reviewed and certified by the South San Francisco City Council and deemed a sufficient and adequate analysis of the environmental impacts of the proposed project. The discussion concludes that the conditions set forth in Section 15162 are not present. As such, an addendum is the appropriate environmental document for the proposed project, pursuant to CEQA Guidelines Section 15164.

D. PROJECT DESCRIPTION
The following provides a description of the proposed project, including the project site’s current location and setting, as well as a discussion of the project components and necessary discretionary actions.

Project Location and Setting
The 11.21-acre, irregularly-shaped project site is located at 180 – 188 El Camino Real and 415 Spruce Avenue, in the City of South San Francisco, California (see Figure 1 and Figure 2). The site consists of a portion of the parcel identified by Assessor’s Parcel Number 014-183-110, and is bound by El Camino Real to the west, South Spruce Avenue to the north, and Huntington Avenue to the east. The project site was previously developed with an approximately 140,000-sf shopping center that has since been demolished, and currently consists of paved parking areas and 179 trees.

Surrounding existing land uses include a See’s Candies warehouse and single-family residences to the north, across South Spruce Avenue; two office buildings to the northeast; commercial and light industrial uses to the east, across Huntington Avenue; commercial businesses to the south; and commercial businesses and single-family residences to the west, across El Camino Real.

The project site is located within the San Francisco Airport Land Use Compatibility Plan Area. The City of South San Francisco General Plan designates the proposed project site as El Camino Real Mixed Use, and the site is zoned El Camino Real Mixed Use (ECRMX). 180 El Camino Real/Steelwave Project
Addendum

August 2022
Figure 1
Regional Project Location
180 El Camino Real/Steelwave Project
Addendum

August 2022
Figure 2
Project Site
180 El Camino Real/Steelwave Project
Addendum

August 2022
Project Components
In general, the proposed project would include the redevelopment of the project site into a life sciences campus. The proposed project would include three, six-story research and development (R&D) buildings, a seven-story parking structure, and a seven-story multi-family residential building. A new interior street would bisect the site, and the proposed project would include pedestrian and bike-friendly connections between all proposed buildings.

The proposed project would require approval of a Vesting Tentative Parcel Map, Conditional Use Permit (CUP), Transportation Demand Management (TDM) Plan, and Design Review. The requested entitlements for the project are discussed in the following sections. The proposed project will also require a compatibility review pursuant to the San Francisco Airport Land Use Compatibility Plan (ALUCP), as discussed below. As recommended by the Airport Land Use Commission (ALUC), a local agency override pursuant to Public Utilities Code Section 21676 and 21676.5 is required.

Vesting Tentative Parcel Map
The proposed project would require approval of a Vesting Tentative Parcel Map to subdivide the project site into three parcels (see Figure 3). Lot B would be 1.90 acres, Lot C would be 6.06 acres, and Lot D would be 3.25 acres. Lot A is the site of a separate, approved project, currently in the construction drawings phase, and is not a part of the project (NAPOT). Lot B would be dedicated for residential use, Lot C would be dedicated for R&D use, and Lot D would be used for parking.

Conditional Use Permit
Parking requirements are set forth in Table 20.330.004 of the South San Francisco Municipal Code (SSFMC). Under such standards, the required parking for the proposed project would be 2,401 spaces. The applicant has proposed a project-wide total of 1,903 spaces (refer to Table 3, Parking Summary). A reduction in parking spaces is allowable with City approval of a CUP, and implementation of a TDM Plan.

Pursuant to Section 20.090.004 of the SSFMC, approval of a CUP would also be required for the proposed building heights, discussed in more detail below. As noted therein, mixed-use buildings may be up to 120 feet in height, given implementation of a TDM Plan and other City-approved incentives.

Finally, pursuant to Section 20.490.002 of the SSFMC, approval of a CUP would be required to allow business operations and truck loading to occur between the hours of 12:00 AM and 6:00 AM.

Transportation Demand Management Plan
The project would include a TDM Plan intended to help alleviate congestion on local roadways and support a reduction in required on-site parking. TDM measures could include, but are not limited to, providing a designated transportation coordinator, provision of secure long-term bicycle parking, bike repair standards/kiosks, carpool/vanpool incentives, subsidized transit passes, car share programs, etc. The TDM is subject to review and approval by the City.

Site Plan - Design Review
Per Section 20.480.002 of the SSFMC, the proposed project would be subject to Design Review by the City.
180 El Camino Real/Steelwave Project
Addendum

August 2022
Figure 3
Vesting Tentative Map
180 El Camino Real/Steelwave Project
Addendum

August 2022
Specifically, the site plan would be analyzed based on the physical features of the proposed project, including, but not limited to, the following elements: building proportions and architectural details; site design, orientation location; size, location, and arrangement of on-site parking; exterior colors and materials; and location and type of landscaping. The purpose of the regulations is to ensure that development throughout the City is designed to support General Plan policies and to promote high-quality design, well-crafted and maintained buildings and landscaping, the use of high-quality building materials, and attention to the design and execution of building details and amenities in both public and private projects. The proposed site plan is explained in further detail below.

The proposed project would involve construction of three R&D buildings on Lot C, a parking structure on Lot D, and a multi-family residential building with covered parking on Lot B (see Figure 4). Computer renderings of the proposed project are included as Figure 5, Figure 6, and Figure 7, and a building summary is provided below:

Table 1
Building Summary
Structure Lot Stories Gross Square Footage
R&D Building 1 C 6 268,705
R&D Building 2 C 6 250,894
R&D Building 3 C 6 277,470
Parking Structure D 7 434,488
Multi-Family Residential Building B 7 277,866
R&D Buildings 1-3
Figure 8 presents the floor plan for each level of the R&D buildings. The buildings would be clustered around a central courtyard such that R&D Building 1 would be sited on the western portion of Lot C; R&D Building 2 would be located on the northern portion of Lot C; and R&D Building 3 would be located on the southern portion of Lot C. R&D Building 1 would include a basement parking level, as well as cafeteria space, a conference room, and fitness room on the first floor. The first floor of each building would include a lobby, with access provided from the central courtyard. Levels one through six of each building would include generally open office and laboratory space. Each R&D building would include an outdoor terrace above the first and second stories.

A four-truck loading dock for R&D Buildings 1 and 3 would be provided between the buildings, with access available from the south interior street. A loading dock that can accommodate two trucks for R&D Building 2 would be located between the building and the parking structure, and would be accessible from the north interior street. Loading would be allowed 24 hours per day, subject to approval of a CUP.

Multi-Family Residential Building
Figure 9 presents the floor plans for each level of the 183-unit multi-family residential building. As demonstrated therein, the first two levels of the proposed building would include central podium parking surrounded by podium apartments on the perimeter. Level one would also include a lobby and amenity space. Levels three through seven would include residential units oriented around a central courtyard.
180 El Camino Real/Steelwave Project
Addendum

August 2022
Figure 4
Site Plan – Ground Level
180 El Camino Real/Steelwave Project
Addendum

August 2022
Figure 5
Project Rendering – R&D Buildings
180 El Camino Real/Steelwave Project
Addendum

August 2022
Figure 6
Project Rendering – Parking Structure
180 El Camino Real/Steelwave Project
Addendum

August 2022
Figure 7
Project Rendering – Multi-Family Residential Building
180 El Camino Real/Steelwave Project
Addendum

August 2022
Figure 8
Floor Plans for R&D Buildings (Lot C)
180 El Camino Real/Steelwave Project
Addendum

August 2022
Figure 9
Floor Plans for Multi-Family Residential Building (Lot B) 180 El Camino Real/Steelwave Project
Addendum

August 2022
Building Heights
Section 20.090.004, Development Standards—ECRMX District, of the SSFMC specifies a base maximum building height of 80 feet, but a height up to 120 feet is allowable for mixed-use buildings that meet certain criteria, including but not limited to incorporation of a TDM Plan and other incentives, subject to approval of a CUP. Accordingly, the maximum allowable building height for the proposed project would be 120 feet upon approval of the CUP. Pursuant to 20.040.005(A2), building height is measured from the average level of the highest and lowest point of the property along El Camino Real to the highest point of the roof ridge, or parapet wall. The maximum proposed building heights for the project structures are shown in Table 2.

Table 2
Building Heights
Building Maximum Height
R&D Building 1 107’ 11”
R&D Building 2 106’ 11”
R&D Building 3 106’ 11”
Parking Structure 63’ 0”
Multi-Family Residential Building 67’ 9”
Parking
Table 3 presents a summary of the vehicle parking spaces provided throughout the project site.

In addition, 12-space bicycle racks would be provided at several locations throughout the project site; and indoor bicycle storage spaces would be provided in all three R&D buildings.

Table 3
Parking Summary
Building Parking Stalls Provided
R&D Building 1 89
R&D Building 2 0
R&D Building 3 0
Parking Structure 1,653
Multi-Family Residential Building 161
Total 1,903
Site Access
Access to the project site would be provided by a new internal driveway that would bisect the site and extend from El Camino Real to Huntington Avenue. Three marked crosswalks would be installed along the internal driveway to allow pedestrian and bicycle access between the R&D buildings and the proposed residential building and the future commercial development on the NAPOT Lot A.

In addition, a drop-off area would be provided on the southern side of the internal driveway.

Emergency vehicle access would be provided by a driveway that would extend along the southern and eastern borders of the site, with access from El Camino Real and Huntington Avenue.

Landscaping
The proposed project would provide landscaping improvements throughout the project site, including two courtyard areas associated with the R&D buildings, and an internal courtyard in the proposed residential building. All selected vegetation would be low-water use, compatible with local soil conditions, and trees would be selected from the City’s approved Tree Plan. 180 El Camino Real/Steelwave Project
Addendum

August 2022
The landscaping throughout the R&D area would include distinct spaces that each have a separate character (see Figure 10). The front courtyard would include large meadows with specimen oaks and formal groves of trees surrounding synthetic turf.

The “central canyon” area is a corridor linking the front courtyard, south of the internal drive, and the back courtyard, near the south end of the property. The corridor would contain pines, deciduous red maples, and London plane trees with an understory of ferns, native and adapted perennials, and shrubs. The back courtyard would feature a mix of flowering perennials, grasses, succulents and shrubs surrounding synthetic turf. Landscaping would also be provided on the second-floor roof terraces of R&D Buildings 2 and 3, and on the third-floor terrace of Building 1.

The residential area would be landscaped to include terrace planting around the perimeter of the building, as well as an entry garden, community garden, and quiet garden located at the interior courtyard (see Figure 11).

Along the new internal drive and El Camino Real, the planting areas would feature small and medium sized trees with an understory of tough and adapted shrubs, grasses and succulents.

The façade of the parking garage that abuts Huntington Avenue would be screened with tall pine trees. In addition, the existing hedgegrow along the project site’s southern boundary would be maintained, and would help screen the proposed buildings from the development to the south.

All landscaping improvements would be subject to the Landscape Design Principles set forth in Section C of Chapter 20.300.007 of the SSFMC and would be required to abide by the California Model Water Efficient Landscape Ordinance (MWELO).

Utilities and Service Systems
The following section describes sewer, stormwater, and water service at the project site. The Utility Plan is included as Figure 12.

Sewer
The City of South San Francisco owns and maintains the sanitary sewer system adjacent to the project site. As part of the approved Safeway project on Lot A, the existing on-site 10-inch sanitary sewer main is being upsized to a 15-inch main and relocated to an alignment through the site from El Camino Real to Huntington Avenue. The upsized and relocated main has been designed to accommodate discharge from the proposed project. The proposed project would install sanitary sewer pipeline connections from each building to the upsized sewer pipeline.

Water
The potable water distribution system in the project area is owned and operated by the California Water Service Company (Cal Water). A looped fire service line would be installed on-site, along with several new fire hydrants. The looped fire service line would tie into the existing water main in Huntington Avenue. New domestic water connections would be provided to each building, with a tie into the existing water main in South Spruce Avenue.

Stormwater
The City of South San Francisco also owns and maintains the existing storm drain system adjacent to the site, in Huntington Avenue, as well as the storm drain line that extends through the project site, in the internal driveway. All on-site and off-site storm drainage conveyance systems have been designed to accommodate the 10-year design storm. 180 El Camino Real/Steelwave Project
Addendum

August 2022
Figure 10
Landscaping Plan
180 El Camino Real/Steelwave Project
Addendum

August 2022
Figure 11
Landscaping Plan – Multi-Family Residential Building
180 El Camino Real/Steelwave Project
Addendum

August 2022
Figure 12
Utility Plan
180 El Camino Real/Steelwave Project
Addendum

August 2022
The proposed project would treat stormwater from the project site using a combination of pervious landscaping, permeable paving, bioretention basins, self-treating areas, and Silva Cell biotreatment systems (see Figure 13).

The project site is divided into 13 drainage management areas (DMAs), and stormwater from each DMA would be directed towards the identified treatment measure with eventual discharge to the City’s storm drain system. Stormwater runoff from DMAs 1, 2, 3, 8, 10, 11, and 12 would be directed towards associated Silva Cell biotreatment areas. Silva Cell is a pavement system that provides stormwater management and supports large tree growth by providing underground water retention. The retained stormwater is either used for watering by the supported tree or infiltrated through the soil and eventually discharged at the underdrain.

Runoff from DMAs 4, 5, 6, 7, and 9 would be directed towards each associated bioretention area.

The bioretention areas would include three to four inches of grass on a minimum of 18 inches of biotreatment soil mix, underlaid with Class II permeable materials. A four-inch perforated underdrain pipe would be placed at the bottom of the bioretention area to collect treated stormwater.

It is noted that the post-project impervious surface area would be less than the pre-project impervious surface area.

Off-Site Improvements
The proposed project would also include the following off-site improvements:
a. Construct new curb, gutter, sidewalk, and Americans with Disabilities Act (ADA) compliant curb ramps along the El Camino Real frontage of the project site, from the northern site entrance to the existing sidewalk approximately 50 feet south of the southern site entrance.
b. Perform base repairs and provide a two-inch grind and overlay (edge of pavement to the median island) of the asphalt concrete pavement on northbound El Camino Real, from the south entry of the project site to Spruce Avenue.
c. Install streetlights along the project street frontages on El Camino Real. The light poles and fixtures shall be ornamental streetlights to match City Standards. d. All electrical and communication lines serving the project site shall be placed underground within the project site being developed and directed to the nearest overhead facility or underground utility vault.

Airport Compatibility Considerations
The project site is located within Airport Influence Area B of the San Francisco International Airport (SFO), which is an area that is subject to formal review by the City/County Association of Governments of San Mateo County and the ALUC.

Public Utilities Code Sections 21676 and 21676.5 set forth standards in which a local agency may overrule determinations by the ALUC that a proposed action by the local agency is inconsistent with the adopted ALUCP. The following considerations related to the proposed project are anticipated to require City actions to address the recommendations of the ALUC during its June 23, 2022 hearing concerning the project’s consistency review:
.
180 El Camino Real/Steelwave Project
Addendum

August 2022
Figure 13
Preliminary Stormwater Plan
180 El Camino Real/Steelwave Project
Addendum

August 2022

1. Safety Compatibility: As depicted in Exhibit IV-8 of the SFO ALUCP, approximately one third of the project site falls within Safety Compatibility Zone 4 – Outer Approach/Departure Zone. Pursuant to SFO ALUCP Table IV-2, Safety Compatibility Criteria, Biosafety Level 3 and 4 facilities are considered incompatible within Zone 4. Biosafety Level 2 is not fully compatible and, pursuant to the ALUCP, should be avoided. The proposed R&D uses would fit in Biosafety Level 2. Therefore, the ALUC made a determination that locating Biosafety Level 2 in Safety Zone 4 should be avoided unless there is no feasible alternative, as outlined in the ALUCP. Per the ALUC’s recommendation, approval of the proposed project would necessitate that the City Council make a finding that there is no feasible alternative for the proposed project. A detailed discussion regarding the compatibility of the proposed Biosafety Level 2 facilities within Zone 4, and any potential hazards associated with such, is included in Section IX, Hazards and Hazardous Materials, of this Addendum.

2. Residential Noise Compatibility: As depicted in Exhibit IV-5 of the 2012 SFO ALUCP, the project site is located almost entirely within the 70-75 dB CNEL contour. Pursuant to SFO ALUCP Table IV-1, Noise/Land Use Compatibility Criteria, multi-family residential use is identified as "Not Compatible" within that contour. "Not Compatible" is further clarified in SFO ALUCP Noise Policy NP-2 to mean "that the proposed land use is incompatible with aircraft noise at the indicated CNEL level", regardless of proposed mitigation. Accordingly, the ALUC made a determination that the proposed project would not be consistent with the Noise Policies of the SFO ALUCP, because Lot B would be developed with a multifamily residential building. As a result, the City Council would be required to override the ALUC determination. A detailed discussion regarding the noise exposure at the project site, the compatibility with residential land uses, and suggested noise-reducing improvements are included in Section XIII, Noise, of this Addendum.

Discretionary Actions
Implementation of the proposed project would require City approval of the following entitlements:
• Vesting Tentative Parcel Map;
• CUP for Parking Reduction, Building Height, and Hours of Operation; • TDM Plan;
• Design Review; and
• A local agency override pursuant to Public Utilities Code Sections 21676 and 21676.5. 180 El Camino Real/Steelwave Project
Addendum

August 2022
E. ENVIRONMENTAL IMPACT COMPARISON
The purpose of the comparison is to evaluate the categories in terms of any “changes” or “new information” that may result in a changed environmental impact evaluation. A “no” answer does not necessarily mean that potential impacts do not exist relative to the environmental category, but that a relevant change would not occur in the condition or status of the impact due to its insignificance or its treatment in a previous environmental document.

The following provides an explanation of each impact evaluation category:

Environmental Issue Area: This column presents the environmental resource area to be discussed and the relevant CEQA Guidelines Appendix G questions to be analyzed.

Where Impact Was Analyzed in the Previous CEQA Documents: This column provides a reference to the page(s) of the 2009 EIR where information and analysis may be found relative to the environmental issue listed under each topic.

Do Proposed Changes Involve New or More Severe Impacts? Pursuant to Section 15162(a)(1) of the CEQA Guidelines, this column indicates whether the changes represented by the current project will result in new significant impacts that have not already been considered and mitigated by a previous EIR or that substantially increase the severity of a previously identified significant impact. If a “yes” answer is given and more severe impacts are specified, additional mitigations will be specified in the discussion section including a statement of impact status after mitigation.

Any New Circumstances Involving New or More Severe Impacts? Pursuant to Section 15162(a)(2) of the CEQA Guidelines, this column indicates whether there have been changes to the project site or the vicinity (environmental setting) that have occurred subsequent to the certification of an EIR, which would result in the current project having significant impacts that were not considered or mitigated by that EIR or which substantially increase the severity of a previously identified significant impact.

Any New Information Requiring New Analysis or Verification? Pursuant to Section 15162(a)(3) of the CEQA Guidelines, this column indicates whether new information is available requiring an update to the analysis of a previous EIR to verify that the environmental conclusions and mitigations remain valid. This also applies to any new regulations that might change the nature of analysis or the specifications of a mitigation measure. If additional analysis is conducted as part of this environmental impact comparison and the environmental conclusion remains the same, no new or additional mitigation is necessary. If the analysis indicates that a mitigation requires supplemental specifications, no additional environmental documentation is needed if it is found that the modified mitigation achieves a reduction in impact to the same level as originally intended.

Discussion: A discussion of the elements of the impact is provided for each impact statement in order to support the findings. The discussion provides information about the particular environmental issue, how the project relates to the issue, and the status of any mitigation that may be required or that has already been implemented.

Conclusion: A conclusion relating to the need for additional environmental documentation is contained in each section.
180 El Camino Real/Steelwave Project
Addendum

August 2022
The following provides an explanation of the mitigation categories:

Mitigation Measures from the Previous CEQA Document: Applicable mitigation measures from the previous CEQA document (i.e., the 2009 EIR) that apply to the changes or new information are referenced under each environmental category.

Additional Project-Specific Mitigation Measures: If changes or new information involve new impacts, additional mitigation measures, if available and feasible, are listed under each environmental category. As will be demonstrated below, no additional projectspecific mitigation measures have been identified for the proposed project.

Environmental Factors Potentially Affected
The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a new significant impact or a substantially more severe significant environmental impact than what was previously analyzed in the 2009 South El Camino Real GPA EIR, as indicated by the discussion on the following pages.  Aesthetics  Agriculture and Forest
Resources
 Air Quality
 Biological Resources  Cultural Resources  Energy
 Geology and Soils  Greenhouse Gas
Emissions
 Hazards and Hazardous
Materials
 Hydrology and Water Quality  Land Use and Planning  Mineral Resources  Noise  Population and
Housing
 Public Services
 Recreation  Transportation  Tribal Cultural Resources  Utilities and Service
Systems
 Wildfire  Mandatory Findings of
Significance
180 El Camino Real/Steelwave Project
Addendum

August 2022
I. AESTHETICS.

Would the project:

Where Impact Was
Analyzed in
Previous CEQA
Documents?
Do Proposed
Changes Involve
New or More
Severe Impacts?
Any New
Circumstances
Involving New or
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
a. Have a substantial adverse effect on a
scenic vista? 3.7-7 No No No
b. Substantially damage scenic
resources, including, but not limited to,
trees, rock outcroppings, and historic
buildings within a State scenic
highway?

3.7-6 No No No
c. In non-urbanized areas, substantially
degrade the existing visual character or
quality of public views of the site and its
surroundings? (Public views are those
that are experienced from publicly
accessible vantage point). If the project
is in an urbanized area, would the
project conflict with applicable zoning
and other regulations governing scenic
quality?

3.7-7 No No No
d. Create a new source of substantial light
or glare which would adversely affect
day or nighttime views in the area?

3.7-8 No No No
Discussion
Since the release of the 2009 EIR, substantial changes to the project site have not occurred. In addition, substantial changes in the environmental and regulatory settings related to aesthetic resources, or in circumstances that would affect the analysis in the 2009 EIR related to aesthetic resources, have not occurred. Project changes or circumstances that would adversely affect the analysis in the 2009 EIR related to aesthetic resources have not occurred. a,c. The 2009 EIR analyzed the potential for implementation of the proposed project to result in impacts to scenic vistas or to degrade the existing visual character of the Planning Area in Impact 3.7-1.1 As noted therein, new development allowed under the South El Camino Real GPA Project could affect scenic views of the San Bruno Mountains and Sign Hill from a few streets in the Planning Area. However, development standards and height limitations would ensure that views of the San Bruno Mountains and Sign Hill are maintained.

Additionally, according to the 2009 EIR, infill development and redevelopment along El Camino Real in the Planning Area is anticipated to have a beneficial impact on the visual and aesthetic characteristics of El Camino Real. Overall, the impact was determined to be less than significant.

Examples of typical scenic vistas include mountain ranges, ridgelines, or bodies of water as viewed from a highway, public space, or other area designated for the express purpose of viewing and sightseeing. In general, a project’s impact to a scenic vista would occur if development of the project would substantially change or remove a scenic vista. Public views of the San Bruno Mountains and Sign Hill are afforded to motorists traveling along El Camino Real. Compared to existing conditions, in which structures do not exist on the project site, development on the project site would be expected to interfere with views of such scenic resources. However, the project site has already been approved for development in the General Plan EIR and the 2009 EIR. The increase in non-residential 1 The Planning Area is depicted in Figure 2.1-2 of the 2009 EIR. 180 El Camino Real/Steelwave Project
Addendum

August 2022
development intensity associated with the proposed project is not anticipated to result in any changes in the level with which on-site structures would interfere with the viewshed.

As such, new or more severe impacts related to having a substantial adverse effect on a scenic vista would not occur.

As noted in the 2009 EIR, redevelopment along El Camino Real is anticipated to benefit the visual character of the Planning Area. As such, implementation of the project would not substantially degrade the existing visual character or quality of public views of the site.

However, the relevant CEQA question for projects located within an urbanized area, such as the project site, is whether the project would conflict with applicable zoning and other regulations governing scenic quality.

The proposed project would comply with the height limitations established in Section

20.090.004, Development Standards—ECRMX District, of the SSFMC, which specifies a base maximum building height of 80 feet, but a height up to 120 feet is allowable for mixeduse buildings that meet certain criteria. Given that the proposed project would meet the applicable criteria, the maximum allowable building height for the proposed project would be 120 feet with approval of the CUP. As presented in Table 2, the maximum building heights for the proposed structures would not exceed 120 feet.

Furthermore, per Section 20.480.002 of the SSFMC, the proposed project would be subject to Design Review by the City. The site plan would be analyzed based on the physical features of the proposed project, including, but not limited to, the following elements: building proportions and architectural details; site design, orientation location; size, location, and arrangement of on-site parking; exterior colors and materials; and location and type of landscaping. The Design Review process would ensure that the proposed project is 1) visually compatible with the project area and 2) complies with applicable regulations governing scenic quality. Thus, the project would not conflict with applicable zoning and other regulations governing scenic quality.

Based on the above information, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to scenic vistas or conflicts with applicable zoning and other regulations governing scenic quality beyond what were previously identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR.
b. The 2009 EIR analyzed the potential for implementation of the South El Camino Real GPA Project to result in impacts to scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings, within a State scenic highway and determined that no impact would occur because officially designated State scenic highways do not exist within the Planning Area.

Consistent with the information in the 2009 EIR, the closest officially designated State scenic highway to the project site is State Route (SR) 280, which is located approximately 4,700 feet west of the project site.2 The project site is not visible from SR 280 and, thus, implementation of the proposed project would not substantially damage any scenic resources visible from a State scenic highway.
2 California Department of Transportation. California State Scenic Highway System Map. Available at:
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057116f1aacaa.

Accessed May 2022.
180 El Camino Real/Steelwave Project
Addendum

August 2022
Based on the above information, the currently proposed project would not result in new significant impacts or substantially more severe impacts related to scenic resources within a State scenic highway beyond what were previously identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR. d. The 2009 EIR assessed the potential for the South El Camino Real GPA Project to create a new source of substantial light or glare that would adversely affect day or nighttime views in the area under Impact 3.7-2 and concluded that impacts would be less than significant.

The 2009 EIR notes that the Planning Area is already highly developed and includes many existing sources of light. Additionally, compliance with the SSFMC, which includes standards that control lighting, would ensure that impacts related to light and glare are reduced.

The proposed project would occur within a portion of the same development area that was evaluated in the 2009 EIR. However, the project would involve a more intensive level of non-residential development at the site, which could, in turn, result in additional sources of light. However, as noted in the 2009 EIR, compliance with the SSFMC would ensure that any impacts related to light and glare would be reduced to a less-than-significant level.

For instance, Item 4 under Section 20.300.008, Lighting and Illumination, of the SSFMC requires that all lighting fixtures be shielded such that obstructive glare does not spill into the public right of way or any adjoining properties. Compliance with this regulation, among others included in the SSFMC, would ensure that the new sources of light associated with the proposed project would not generate substantial light or glare which would adversely affect day or nighttime views in the area.

Based on the above information, the currently proposed project would not result in new significant impacts or substantially more severe impacts related to the creation of a new source of substantial light or glare which would adversely affect day or nighttime views in the area beyond what were previously identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR.

Conclusion
Based on the above and in accordance with the criteria outlined in Section 15162 of the CEQA Guidelines, the 180 El Camino Real/Steelwave Project would not result in any changes, new circumstances, or new information that would involve new significant impacts or substantially more severe significant impacts from what had been anticipated for the project site in the previous CEQA document related to aesthetics.

Mitigation Measure(s)
The proposed project would not require any mitigation related to aesthetic resources.

Mitigation Measures from the Previous CEQA Document
None required in the 2009 EIR.

Additional Project-Specific Mitigation Measures
None required.
180 El Camino Real/Steelwave Project
Addendum

August 2022
II. AGRICULTURE AND
FORESTRY RESOURCES.

Would the project:

Where Impact
Was Analyzed in
2009 EIR?
Do Proposed
Changes Involve
New or More
Severe
Impacts?
Any New
Circumstances
Involving New or
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
a. Convert Prime Farmland, Unique
Farmland, or Farmland of Statewide
Importance (Farmland), as shown on the
maps prepared pursuant to the
Farmland Mapping Program of the
California Resources Agency, to nonagricultural use?

3.8-7 No No No
b. Conflict with existing zoning for
agricultural use, or a Williamson Act
contract?

3.8-7 No No No
c. Conflict with existing zoning for, or
cause rezoning of, forest land (as
defined in Public Resources Code
section 12220(g)), timberland (as
defined by Public Resources Code
section 4526), or timberland zoned
Timberland Production (as defined by
Government Code section 51104(g))?

3.8-7 No No No
d. Result in the loss of forest land or
conversion of forest land to non-forest
use?

3.8-7 No No No
e. Involve other changes in the existing
environment which, due to their location
or nature, could individually or
cumulatively result in loss of Farmland to
non-agricultural use?

3.8-7 No No No
Discussion
Since adoption of the 2009 EIR, substantial changes to the project site have not occurred. In addition, substantial changes in the environmental and regulatory settings related to agricultural and forestry resources, or in circumstances that would affect the analysis in the 2009 EIR related to agricultural and forestry resources, have not occurred. Project changes or circumstances that would adversely affect the analysis in the 2009 EIR related to agricultural and forestry resources have not occurred.
a-e. As noted in Chapter 3.8, Land Use and Housing, of the 2009 EIR, the Planning Area does not contain agricultural land; therefore, Prime Farmlands, Unique Farmlands, Farmlands of Statewide Importance, or parcels under a Williamson Act contract do not exist in the Planning Area. The 2009 EIR concluded that no impacts related to agricultural and forestry resources would occur.

According to the California Department of Conservation Farmland Mapping and Monitoring Program (FMMP), the project site is designated entirely as “Urban and BuiltUp Land.”3 Given the site designation, development of the proposed project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to a non-agricultural use, or otherwise result in the loss of Farmland to non-agricultural use.

The City of South San Francisco General Plan designates the proposed project site as El 3 California Department of Conservation. California Important Farmland Finder. Available at:
https://maps.conservation.ca.gov/dlrp/ciff/app/. Accessed March 2022. 180 El Camino Real/Steelwave Project
Addendum

August 2022
Camino Real Mixed Use, and the site is zoned ECRMX. As such, the site’s land use and zoning designations are intended for urban development and do not allow for agricultural uses. Additionally, the project site is not under a Williamson Act contract. 4 Therefore, the
proposed project would not conflict with existing zoning for agricultural use or a Williamson Act contract. Finally, the project site is not considered forest land (as defined in PRC Section 12220[g]), timberland (as defined by PRC Section 4526), and is not zoned Timberland Production (as defined by Government Code Section 51104[g]). As such, the proposed project would not conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned Timberland, or result in the loss of forest land or conversion of forest land to non-forest use.

Based on the above, no new or more severe impacts would occur related to agriculture and forest resources, and the proposed project would be consistent with the conclusions of the 2009 EIR.

Conclusion
Based on the above and in accordance with Section 15162 of the CEQA Guidelines, the 180 El Camino Real/Steelwave Project would not result in any changes, new circumstances, or new information that would involve new significant impacts or substantially more severe significant impacts from what had been anticipated for the project site in the previous CEQA document related to agriculture and forestry resources.

Mitigation Measure(s)
The proposed project would not require any mitigation related to agriculture and forestry resources.

Mitigation Measures from the Previous CEQA Document
None required in the 2009 EIR.

Additional Project-Specific Mitigation Measures
None required.
4 Stanford Digital Repository. Williamson Act Contracted Lands: San Francisco Bay Area, California, 2006. Available at: https://purl.stanford.edu/hb456ch5128. Accessed March 2022. 180 El Camino Real/Steelwave Project
Addendum

August 2022
III.AIR QUALITY.

Would the project: Where Impact
Was Analyzed in
2009 EIR?
Do Proposed
Changes Involve
New or More
Severe Impacts?
Any New
Circumstances
Involving New or
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
a. Conflict with or obstruct implementation
of the applicable air quality plan?

3.3-18 to

3.3-23 No No Yes
b. Result in a cumulatively considerable
net increase of any criteria pollutant for
which the project region is nonattainment under an applicable federal or state ambient air quality standard?

3.3-24 to

3.3-25 No No Yes
c. Expose sensitive receptors to
substantial pollutant concentrations? 3.3-25 No No No
d. Result in other emissions (such as
those leading to odors) adversely
affecting a substantial number of
people?

3.3-26 No No No
Discussion
Since the release of the 2009 EIR, substantial changes to the project site or the environmental setting have not occurred. However, changes to the regulatory setting related to air quality since preparation of the 2009 EIR have occurred. The applicable air quality plan is now the 2017 Clean Air Plan, which was not adopted until April 19, 2017. The current Bay Area Air Quality Management District (BAAQMD) CEQA Guidelines were adopted in May 2017 and, accordingly, were not available at the time that the 2009 EIR was prepared. In addition, the California Emissions Estimator Model (CalEEMod) has been updated since preparation of the 2009 EIR.

Finally, several federal, statewide, and local regulations have been enacted since 2009. For example, the applicable building code is the 2019 California Building Standards Code (CBSC). It is noted, however, that the most recent regulations are generally more stringent than the regulations in place in 2009. As a result, a project built under the current regulations would result in fewer emissions compared to the same project built under the previous regulations.

Relative to the approved South El Camino Real GPA project, the proposed project would disturb only a portion of the development footprint, but would include development at a greater nonresidential development intensity. Thus, under the proposed project, construction intensity could be increased, and the emissions associated with project operations are anticipated to be higher, as compared to the approved project.
a,b. The City of South San Francisco is located at the northerly border of the San Francisco Bay Area Air Basin (SFBAAB), which is under the jurisdiction of the BAAQMD. The SFBAAB area is currently designated as a nonattainment area for the State and federal ozone, State and federal fine particulate matter 2.5 microns in diameter (PM2.5), and State respirable particulate matter 10 microns in diameter (PM10) ambient air quality standards (AAQS). The SFBAAB is designated attainment or unclassified for all other AAQS.

The applicable air quality plan at the time the 2009 EIR was prepared was the Bay Area 2005 Ozone Strategy. As noted in the 2009 EIR, quantification of air pollutant emissions was not necessary, as consistency with the Bay Area 2005 Ozone Strategy was determined through a qualitative discussion.

Today, the most recent State ozone plan is the 2017 Clean Air Plan, adopted on April 19, 2017. Adopted BAAQMD rules and regulations, as well as the thresholds of significance, 180 El Camino Real/Steelwave Project
Addendum

August 2022
have been developed with the intent to ensure continued attainment of AAQS, or to work towards attainment of AAQS for which the area is currently designated nonattainment, consistent with the applicable air quality plan. Thus, by exceeding the BAAQMD’s emission thresholds for construction or operational emissions, a project would be considered to conflict with or obstruct implementation of the BAAQMD’s air quality planning efforts. The BAAQMD has established significance thresholds for emissions of the ozone precursors reactive organic gases (ROG) and oxides of nitrogen (NOX), expressed in pounds per day (lbs/day) and tons per year (tons/yr), as well as for PM10 and PM2.5, expressed in lbs/day and tons/yr. The thresholds of significance are presented in Table 4.

Table 4
BAAQMD Thresholds of Significance
Pollutant
Construction Operational
Average Daily
Emissions
(lbs/day)
Average Daily
Emissions
(lbs/day)
Maximum Annual
Emissions
(tons/year)
ROG 54 54 10
NOX 54 54 10
PM10 (exhaust) 82 82 15
PM2.5 (exhaust) 54 54 10
Source: BAAQMD, CEQA Guidelines, May 2017.

Emissions of particulate matter can be split into two categories: fugitive emissions and exhaust emissions. The BAAQMD thresholds of significance for exhaust PM emissions are presented in Table 4. The BAAQMD does not maintain quantitative thresholds for fugitive emissions of PM10 or PM2.5; rather, BAAQMD requires all projects within the district’s jurisdiction to implement Basic Construction Mitigation Measures (BCMMs) related to dust suppression.

The BCMMs include the following, which would be required for the project by the City as conditions of approval (COA):

1. All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day.

2. All haul trucks transporting soil, sand, or other loose material off-site shall be covered.

3. All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.

4. All vehicle speeds on unpaved roads shall be limited to 15 mph.

5. All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.

6. Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to five minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of CCR). Clear signage shall be provided for construction workers at all access points.

7. All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified visible emissions evaluator.
180 El Camino Real/Steelwave Project
Addendum

August 2022

8. Post a publicly visible sign with the telephone number and person to contact at the lead agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s phone number shall also be visible to ensure compliance with applicable regulations.

For the analysis in this Addendum, the air quality emissions associated with construction and operations of the project site built out under the approved conditions and the proposed project were quantified and compared to the BAAQMD’s thresholds of significance. The Approved Conditions scenario refers to the buildout assumptions that were evaluated in the 2009 EIR. The emissions were quantified using the California Emissions Estimator Model (CalEEMod) software version 2020.4.0 – a statewide model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify air quality emissions, including greenhouse gas (GHG) emissions, from land use projects. The model applies inherent default values for various land uses, including construction data, trip generation rates, vehicle mix, trip length, average speed, etc. Where project-specific information is available, such information should be applied in the model. For instance, the project applicant provided specific information regarding construction phasing and equipment, and Fehr & Peers, the transportation consultant for the proposed project, provided anticipated trip generation values for each buildout scenario.

The following assumptions were made for the Approved Conditions scenario:
• Land uses would include 288,900 sf of R&D use, consistent with page 3.1-17 of the 2009 EIR;
5 • Construction was assumed to begin in September 2022; • 800 cubic yards (CY) of building material would be removed during demolition;6 and
• Trip generation rates were updated based on the project-specific analysis provided by Fehr & Peers.
7 The following assumptions were made for the proposed project scenario:
• Land uses would include:
o 183 multi-family residential units;
o 797,069 sf of R&D use;
o 250 basement parking spaces; and
o A 1,387-space parking garage;
• Construction was assumed to begin in September 2022 and occur over approximately 34 months;
5 The proposed project would result in an increase of approximately 479,069 sf from the 300,000 sf of non-residential development evaluated in the 2009 EIR and assumed for the analysis throughout this Addendum. Application of 288,900 sf, pursuant to page 3.1-17 of the 2009 EIR, as opposed to 300,000 sf, to the modeling conducted for the Approved Conditions scenario provides for a conservative comparison to the proposed project, as the resultant increase in square footage due to the proposed project is higher. Therefore, the modeling and results presented herein are conservative. 6 The building that previously existed on the project site has been demolished since initiation of this environmental review. As a result, the export of demolition materials and the associated emissions would not occur. Therefore, the modeling presented herein in conservative. 7 Fehr & Peers. Trip Generation Assessment for 180 El Camino Real/Steelwave. April 4, 2022. 180 El Camino Real/Steelwave Project
Addendum

August 2022
• 800 CY of building material would be removed during demolition;8 • 5,000 CY of soils/material would be exported during the grading phase; • Trip generation rates were updated based on the project-specific analysis provided by Fehr & Peers;9

• Three emergency generators would operate on-site; and • Based on applicant-provided information, the project would surpass the minimum required energy efficiency requirements established by Title 24 by 0.5 percent, one percent of total energy demand would be generated on-site, indoor water use would be reduced by 30 percent, and outdoor water use would be reduced by 50 percent.

All modeling results are included as Appendix A of this Addendum. The results of the analysis are discussed further below.

Construction Emissions
Construction emissions of criteria pollutants are evaluated under Impact 3.3-2 of the 2009 EIR. At the time that the 2009 EIR was released, the BAAQMD considered any project that implemented the required dust control measures to result in less-than-significant construction impacts. Therefore, because General Plan Policy 7.3-I-3 requires implementation of such measures, the 2009 EIR determined that the impact would be less than significant.

Table 5 presents the maximum unmitigated construction emissions associated with the Approved Conditions in comparison to the maximum unmitigated construction emissions associated with the proposed project.

Table 5
Maximum Unmitigated Construction Emissions:

Approved Conditions Compared to Proposed Project
ROG
(lbs/day)
NOX
(lbs/day)
PM10*
(lbs/day)
PM2.5*
(lbs/day)
Approved Conditions 12.16 38.89 1.64 1.50
Proposed Project 30.62 62.05 2.22 2.06
Net Difference 18.46 23.16 0.58 0.56
BAAQMD Threshold 54 54 82 54
Exceed? NO NO NO NO
Note:
* Denotes emissions from exhaust only. BAAQMD does not have adopted thresholds for fugitive PM emissions.

Source: CalEEMod, May 2022 (see Appendix A).

As presented in Table 5, the net increase in construction-related emissions would be below the applicable thresholds of significance for all criteria pollutants. Therefore, the proposed project would not result in any new or more severe significant impacts related to construction criteria pollutant emissions from what was previously analyzed in the 2009 EIR and approved for development on the project site.
8 See footnote 6. 9 Fehr & Peers. Trip Generation Assessment for 180 El Camino Real/Steelwave. April 4, 2022. 180 El Camino Real/Steelwave Project
Addendum

August 2022
Operational Emissions
The 2009 EIR evaluated whether the South El Camino Real GPA Project would be consistent with the applicable air quality plan during project operations under Impact 3.3-

1. The applicable air quality plan at the time that the 2009 EIR was prepared was the 2005 Bay Area Ozone Strategy. As noted in the 2009 EIR, the City’s General Plan is not consistent with the 2005 Bay Area Ozone Strategy because the vehicle miles traveled (VMT) in the City is projected to grow at a rate faster than the population. As part of the larger General Plan, the GPA is inherently part of a significant cumulative impact.

However, the GPA would allow infill mixed-used projects and high-density housing along El Camino Real, a major transportation corridor with bus lines and access to two BART stations. Such features are known to reduce VMT, as discussed in further detail in Section XVII, Transportation, of this Addendum. Thus, given that the GPA would reduce the significant impact identified for the General Plan, the 2009 EIR determined that the impact of the South El Camino Real GPA Project itself would not be cumulatively considerable.

Table 6 presents the maximum unmitigated operational emissions associated with the Approved Conditions in comparison to the maximum unmitigated operational emissions associated with the proposed project.

Table 6
Maximum Unmitigated Operational Emissions:

Approved Conditions Compared to Proposed Project
ROG NOX PM10* PM2.5*
lbs/day tons/yr lbs/day tons/yr lbs/day tons/yr lbs/day tons/yr Approved
Conditions 16.85 2.89 12.04 2.09 0.27 0.05 0.26 0.05
Proposed Project 44.05 7.36 21.00 3.61 3.73 0.14 3.72 0.14 Net Difference 27.20 4.47 8.96 1.52 3.46 0.09 3.46 0.09 BAAQMD
Threshold 54 10 54 10 82 15 54 10
Exceed? NO NO NO NO NO NO NO NO
Note:
* Denotes emissions from exhaust only. BAAQMD does not have adopted thresholds for fugitive PM emissions.

Source: CalEEMod, May 2022 (see Appendix A).

As presented in Table 6, operations of the proposed project would result in a net increase in criteria pollutant emissions as compared to operations of the Approved Conditions.

However, the net increase in emissions would not exceed the applicable thresholds of significance for each criteria pollutant. Overall, the proposed project would not result in any new or more severe significant impacts related to operational criteria pollutant emissions from what was previously analyzed in the 2009 EIR and approved for development on the project site.

Cumulative Emissions
Past, present, and future development projects contribute to the region’s adverse air quality impacts on a cumulative basis. By nature, air pollution is largely a cumulative impact. A single project is not sufficient in size to, by itself, result in nonattainment of AAQS. Instead, a project’s individual emissions contribute to existing cumulatively significant adverse air quality impacts. If a project’s contribution to the cumulative impact 180 El Camino Real/Steelwave Project
Addendum

August 2022
is considerable, then the project’s impact on air quality would be considered significant. In developing thresholds of significance for air pollutants, BAAQMD considered the emission levels for which a project’s individual emissions would be cumulatively considerable. The thresholds of significance presented in Table 4 represent the levels at which a project’s individual emissions of criteria air pollutants or precursors would result in a cumulatively considerable contribution to the SFBAAB’s existing air quality conditions. Because the net increase in criteria pollution emissions associated with the proposed project as compared to the Approved Conditions scenario would not generate criteria pollutant emissions above the applicable thresholds of significance, the project would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or State AAQS.

Conclusion
Based on the above, construction and operation of the proposed project would result in emissions of criteria pollutants that exceed the emissions anticipated to occur under the conditions that were evaluated in the 2009 EIR. However, the net increase in pollutants would not exceed the applicable thresholds of significance for any criteria pollutants.

Overall, the proposed project would not result in new significant impacts or substantially more severe significant impacts from what was previously analyzed in the 2009 EIR related to a conflict with or obstruction of implementation of an applicable air quality plan. c. The principal categories of pollutants of concern are carbon monoxide (CO), toxic air contaminants (TACs), and criteria pollutants. The proposed project’s potential to increase the aforementioned pollutant concentrations of concern from what was analyzed for the previous project is discussed in further detail below. The nearest sensitive receptors to the project site are the single-family residences located north of the project site, across South Spruce Avenue.

Under Impact 3.3-3, the 2009 EIR determined that compliance with existing regulations and applicable General Plan policies would ensure that impacts to sensitive receptors would be less than significant. The 2009 EIR notes that the nearest sensitive receptors to the Planning Area are South San Francisco High School and the residential uses to the east and west.

Localized CO
Localized concentrations of CO are related to the levels of traffic and congestion along streets and at intersections. High levels of localized CO concentrations are only expected where background levels are high, and traffic volumes and congestion levels are high.

Emissions of CO are of potential concern, as the pollutant is a toxic gas that results from the incomplete combustion of carbon-containing fuels such as gasoline or wood.

In order to provide a conservative indication of whether a project would result in localized CO emissions that would exceed the applicable threshold of significance, the BAAQMD has established screening criteria for localized CO emissions. According to BAAQMD, a proposed project would result in a less-than-significant impact related to localized CO emission concentrations if all of the following conditions are true for the project:
• The project is consistent with an applicable congestion management program established by the county congestion management agency for designated roads 180 El Camino Real/Steelwave Project
Addendum

August 2022
or highways, regional transportation plan, and local congestion management agency plans;
• The project traffic would not increase traffic volumes at affected intersections to more than 44,000 vehicles per hour; and
• The project traffic would not increase traffic volumes at affected intersections to more than 24,000 vehicles per hour where vertical and/or horizontal mixing is substantially limited (e.g., tunnel, parking garage, underpass, etc.).

With regard to the first point, the project site falls within the boundaries of the San Mateo County Congestion Management Program (CMP).10 The purpose of the CMP is to identify strategies to respond to future transportation needs, develop procedures to alleviate and control congestion, and promote countywide solutions. As noted in the CMP, the CMP was designed to be consistent with the growth projections included in Plan Bay Area, as developed by the Association of Bay Area Governments (ABAG) and the Metropolitan Transportation Commission (MTC). Considering the proposed project would be consistent with the land use designation and zoning for the project site, buildout of the site has been generally considered in the growth projections included in the Plan Bay Area and, thus, the CMP. Additionally, the proposed project would be an infill development project that includes implementation of a TDM Plan. Furthermore, the project would include a mix of land uses. Therefore, the proposed project would not conflict with the transportation and land use goals established in the San Mateo County CMP.

With regard to the second and third points, and as discussed in Section XVII, Transportation, of this Addendum, the proposed project is anticipated to generate approximately 1,979 net new daily trips, including 147 net new AM peak hour trips and 234 net new PM peak hour trips. Based on Figure C-1, Peak Hour Traffic Volumes and Land Configurations - Existing, of a Transportation Impact Analysis prepared for a nearby development project, traffic volumes at the intersections of El Camino Real and the I-380 westbound and eastbound off-ramps range between 4,385 and 5,589 trips per peak hour.
11 Therefore, the addition of 147 AM peak hour and 234 PM peak hour trips from the proposed project would not increase traffic volumes to more than 44,000 vehicles per hour at affected intersections, or to more than 24,000 vehicles per hour where vertical and/or horizontal mixing is limited. The same conclusion would apply to other affected intersections in the project area. Therefore, based on the BAAQMD criteria, the proposed project would result in a less-than-significant impact related to localized CO emissions concentrations and would not expose sensitive receptors to substantial concentrations of localized CO.

The 2009 EIR noted that CO concentrations are no longer a priority in most air districts throughout the State, and the South El Camino Real GPA Project would not contribute to an exceedance of the State and federal CO standards. Additionally, as noted above, the 2009 EIR concluded that implementation of the South El Camino Real GPA Project would result in a less-than-significant impact related to exposing sensitive receptors to substantial pollutant concentrations. Thus, the proposed project would not result in a new significant impact or substantially more severe significant impact related to localized CO than was previously identified in the 2009 EIR.
10 City/County Association of Governments of San Mateo County. San Mateo County Congestion Management Program 2021. December 2021. 11 Fehr and Peers. 1477 Huntington Administrative Draft Transportation Impact Analysis. December 17, 2021. 180 El Camino Real/Steelwave Project
Addendum

August 2022
TAC Emissions
Another category of environmental concern is TACs. The CARB’s Air Quality and Land Use Handbook: A Community Health Perspective (Handbook) provides recommended setback distances for sensitive land uses from major sources of TACs, including, but not limited to, freeways and high traffic roads, distribution centers, and rail yards.12 The proposed project would not include any such uses. Additionally, it is noted that the proposed project would include land uses that are already allowed on the project site and are consistent with the General Plan.

Short-term, construction-related activities could result in the generation of TACs, specifically diesel particulate matter (DPM), from on-road haul trucks and off-road equipment exhaust emissions. Construction is temporary and occurs over a relatively short duration in comparison to the operational lifetime of the proposed project. Health risks are typically associated with exposure to high concentrations of TACs over extended periods of time (e.g., 30 years or greater), whereas the construction period associated with the proposed project would likely be limited to approximately three years. Therefore, existing sensitive receptors in the project vicinity would not be exposed to constructionrelated emissions for an extended period of time and, accordingly, health risks are not anticipated.

All construction equipment and operation thereof for the proposed project would be regulated per the CARB In-Use Off-Road Diesel Vehicle Regulation, which is intended to help reduce emissions associated with off-road diesel vehicles and equipment, including DPM. Project construction would also be required to comply with all applicable BAAQMD rules and regulations, particularly associated with permitting of air pollutant sources. In addition, construction equipment would operate intermittently throughout the day and only on portions of the site at a time.

Because construction equipment on-site would not operate for long periods of time and would be used at varying locations within the site, associated emissions of DPM would not occur at the same location (or be evenly spread throughout the entire project site) for long periods of time. Due to the temporary nature of construction and the relatively short duration of potential exposure to associated emissions, the potential for any one sensitive receptor in the area to be exposed to concentrations of pollutants for a substantially extended period of time would be low. Therefore, construction of the proposed project would not be expected to expose any sensitive receptors to substantial pollutant concentrations.

The proposed project would include several diesel-powered emergency generators onsite, which are considered stationary sources of TACs. However, the generators would only be used as needed in emergency situations, one a month for a 30-minute test, and once a year for a 90-minute test. Given the limited use of the diesel generators, nearby sensitive receptors would not be exposed to substantial concentrations of DPM.

Criteria Pollutants
The BAAQMD thresholds of significance were established with consideration given to the health-based air quality standards established by the National AAQS (NAAQS) and California AAQS (CAAQS), and are designed to aid the district in achieving attainment of 12 California Air Resources Board. Air Quality and Land Use Handbook: A Community Health Perspective. April 2005. 180 El Camino Real/Steelwave Project
Addendum

August 2022
the NAAQS and CAAQS.
13 Although the BAAQMD’s thresholds of significance are intended to aid achievement of the NAAQS and CAAQS for which the SFBAAB is in nonattainment, the thresholds of significance do not represent a level above which individual project-level emissions would directly result in public health impacts.

Nevertheless, a project’s compliance with BAAQMD’s thresholds of significance provides an indication that criteria pollutants released as a result of project implementation would not inhibit attainment of the health-based regional NAAQS and CAAQS. Because the net increase in emissions associated with the proposed project would not exceed the BAAQMD’s thresholds and, thus, would not inhibit attainment of NAAQS and CAAQS, the criteria pollutants emitted during project implementation would not be anticipated to result in measurable health impacts to sensitive receptors. Accordingly, the proposed project would not expose sensitive receptors to excess concentrations of criteria pollutants, and a new or more severe impact beyond what was evaluated in the 2009 EIR would not occur.

Conclusion
Based on the above and consistent with the conclusion presented in the 2009 EIR, implementation of the proposed project would not result in significant impacts related to exposing sensitive receptors to substantial pollutant concentrations. Thus, the proposed project would not result in new significant impacts or substantially more severe significant impacts to sensitive receptors beyond what was identified in the 2009 EIR. d. Pollutants of principal concern include emissions leading to odors, visible emissions (including dust), or emissions considered to constitute air pollutants. Air pollutants have been discussed above. Therefore, the following discussion focuses on emissions of odors and visible emissions.

Under Impact 3.3-4, the 2009 EIR concluded that the South El Camino Real GPA Project would result in a less-than-significant impact with respect to other emissions, such as those leading to odors and visible emissions, that would affect a substantial number of people. As noted therein, future land uses allowed under the GPA include commercial and residential land uses, which are not known to generate substantial odors or dust.

The potential for the proposed project to result in increased impacts related to emissions of odors and visible emissions is discussed in further detail below.

Odors
Construction activities often include diesel-fueled equipment and heavy-duty trucks, which could create odors associated with diesel fumes that may be considered objectionable.

However, construction activities would be temporary, and hours of operation for construction equipment would be restricted per SSFMC Section 15.14.070, “Work Hours”.

Project construction would also be required to comply with all applicable BAAQMD rules and regulations, particularly associated with permitting of air pollutant sources. The aforementioned regulations would help to minimize emissions, including emissions leading to odors. Accordingly, substantial objectionable odors would not be expected to occur during construction activities.

Operations of the R&D buildings may involve the use of chemical materials, some of which may emit objectionable odors. However, as discussed in further detail in Section IX, 13 Bay Area Air Quality Management District. California Environmental Quality Act Air Quality Guidelines. May 2017. 180 El Camino Real/Steelwave Project
Addendum

August 2022
Hazards and Hazardous Materials, of this Addendum, the use of chemical materials would be regulated through local, State, and federal standards, and standard precautions, such as the use of fume hoods, would be required. Compliance with applicable regulations and the use of fume hoods would ensure that emissions of any objectionable odors during project operations would not affect nearby receptors.

Visible Emissions/Dust
With respect to dust, as noted previously, the proposed project would be required to implement BAAQMD’s BCMMs during project construction. The BCMMs would act to reduce construction-related dust by requiring that haul trucks with loose material are covered, reducing vehicle dirt track-out, and limiting vehicle speeds within the project site, among other methods, which would ensure that construction of the proposed project does not result in substantial emissions of dust. Following project construction, vehicles operating within the project site would be limited to paved areas of the site, and non-paved areas would be landscaped. Thus, project operations would not include sources of dust that could adversely affect a substantial number of people. Therefore, impacts related to visible emissions and dust would be similar under the proposed project as compared to the South El Camino Real GPA Project, and the conclusion of the 2009 EIR would remain the same.

Conclusion
Based on the above, the proposed project would not result in new significant impacts or substantially more severe significant impacts related to other emissions such as those leading to dust or odors that would affect a substantial number of people beyond what was identified in the 2009 EIR.

Conclusion
Overall, in accordance with Section 15162 of the CEQA Guidelines the 180 El Camino Real/Steelwave project would not result in any changes, new circumstances, or new information that would involve new significant impacts or substantially more severe significant impacts from what had been anticipated for the project site in the previous CEQA document related to air quality.

Mitigation Measure(s)
The proposed project would not require any mitigation related to air quality.

Mitigation Measures from the Previous CEQA Document
None required in the 2009 EIR.

Additional Project-Specific Mitigation Measures
None required.
180 El Camino Real/Steelwave Project
Addendum

August 2022
IV. BIOLOGICAL
RESOURCES.

Would the project:

Where Impact
Was Analyzed in
2009 EIR?
Do Proposed
Changes Involve
New or More
Severe
Impacts?
Any New
Circumstances
Involving New or
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
a. Have a substantial adverse effect, either
directly or through habitat modifications,
on any species identified as a candidate,
sensitive, or special status species in
local or regional plans, policies, or
regulations, or by the California
Department of Fish and Wildlife or U.S.

Fish and Wildlife Service?

3.9-6 to

3.9-7 No No No
b. Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional
plans, policies, and regulations or by the
California Department of Fish and
Wildlife or US Fish and Wildlife Service?

3.9-6 to

3.9-7 No No No
c. Have a substantial adverse effect on
state or federally protected wetlands
(including, but not limited to, marsh,
vernal pool, coastal, etc.) through direct
removal, filling, hydrological interruption,
or other means?

3.9-7 No No No
d. Interfere substantially with the
movement of any resident or migratory
fish or wildlife species or with
established resident or migratory wildlife
corridors, or impede the use of wildlife
nursery sites?

3.9-7 No No No
e. Conflict with any local policies or
ordinances protecting biological
resources, such as a tree preservation
policy or ordinance?

3.9-7 No No Yes
f. Conflict with the provisions of an
adopted Habitat Conservation Plan,
Natural Conservation Community Plan,
or other approved local, regional, or
state habitat conservation plan?

3.9-7 No No No
Discussion
Since the release of the 2009 EIR, substantial changes to the project site have not occurred. In addition, substantial changes in the environmental and regulatory settings related to biological resources, or in circumstances that would affect the analysis in the 2009 EIR related to biological resources, have not occurred. Project changes or circumstances that would adversely affect the analysis in the 2009 EIR related to biological resources have not occurred. a,b. The 2009 EIR notes that the Planning Area does not include any habitats that would support special-status species that have the potential to occur in the project region. For instance, the Planning Area is not near the coast, nor does it contain any wetlands, marshes or grassland. Additionally, sites identified as ecologically sensitive habitat are not located in the Planning Area. Therefore, under Impact 3.9-1-1, the 2009 EIR determined that the South El Camino Real GPA Project would result in no impact related to candidate, sensitive, or special-status plant or animal species.
180 El Camino Real/Steelwave Project
Addendum

August 2022
The project site is located within the South El Camino Real Planning Area and, thus, also does not include habitat types that would support special-status species or otherwise ecologically sensitive habitat. Rather, the project site has been previously developed and currently contains the building pad of the recently demolished shopping center building and paved parking areas. Therefore, implementation of the proposed project would result in no impact related to special-status species or sensitive natural communities.

Based on the above, the proposed project would not result in new significant impacts or substantially more severe significant impacts related to substantial adverse effects, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game (now known as the California Department of Fish and Wildlife [CDFW]) or U.S. Fish and Wildlife Service (USFWS), or on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by CDFW or USFWS, beyond what were previously identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR.
c. The 2009 EIR notes that protected wetlands do not exist within the Planning Area.

Therefore, under Impact 3.9-1-2, the 2009 EIR determined that the South El Camino Real GPA Project would result in no impact related to affecting State or federally protected wetlands.

The project site is located within the South El Camino Real Planning Area and, thus, does not include any protected wetlands. Rather, the project site has been previously developed and currently contains the building pad of the recently demolished shopping center building and paved parking areas. Therefore, implementation of the proposed project would result in no impact related to wetlands.

Based on the above information, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to substantial adverse effects on State- or federally-protected wetlands beyond what were previously identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR.
d. The 2009 EIR notes that the Planning Area is highly urbanized and does not contain any migratory wildlife corridors. Therefore, under Impact 3.9-1-2, the 2009 EIR determined that the South El Camino Real GPA Project would result in no impact related to substantial interference with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impeding the use of native wildlife nursery sites.

The project site is located within the South El Camino Real Planning Area and, thus, also within a highly urbanized area that does not provide migratory corridors or suitable wildlife nursery habitat. For instance, the project site is bound by roadways on all sides, which generally precludes the migration of wildlife across the project site.

Based on the above information, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to substantial interference with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impeding the use of 180 El Camino Real/Steelwave Project
Addendum

August 2022
native wildlife nursery sites beyond what were previously identified in the 2009 EIR.

Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR. e. The 2009 EIR determined that implementation of the South El Camino Real GPA Project would not change or conflict with the City’s Tree Preservation Ordinance and, thus, no impact would occur.

As defined in Chapter 13.30, Tree Preservation, of the SSFMC, a protected tree is defined as follows:
(1) Any upright, single-trunked tree of a species not considered to be a heritage tree as defined in subsection (3) below or a tree listed in subsection (2) below, with a circumference of forty-eight inches or more when measured fifty-four inches above natural grade; or (2) Any upright, single-trunked tree of the following species: Blue Gum (Eucalyptus globulus), Black Acacia (Acacia melanoxylon), Myoporum (Myoporum lactum), Sweetgum (Liquidambar styraciflua), Glossy Privet (Lingustrum lucidum), or Lombardy Poplar (Populus nigra) with a circumference of seventy-five inches or more when measured fifty-four inches above natural grade; or
(3) Any upright, single-trunked tree considered to be a heritage tree species, with a circumference of thirty inches or more when measured at fifty-four inches above natural grade. A heritage tree means any of the following:

California Bay (Umbellaria californica), Oak (Quercus spp.), Cedar (Cedrus spp.), California Buckeye (Aesculus californica), Catalina Ironwood (Lyonothamnus asplenifolium), Strawberry Tree (Arbutus spp.), Mayten (Maytenus boaria), or Little Gem Dwarf Southern Magnolia (Magnolia grandiflora “Little Gem”).
(4) A tree or stand of trees so designated by the director based upon findings that it is unique and of importance to the public due to its unusual appearance, location, historical significance or other factor; or (5) A stand of trees in which the director has determined each tree is dependent upon the others for survival.

An Arborist Report was prepared for the proposed project by HMH (see Appendix B).14 HMH conducted an inventory of 179 trees located within the project site and, for each tree, identified the species, noted the location on the site map, measured trunk circumference at 54 inches above grade, and evaluated the health and structure. The New Zealand Christmas trees constitute the largest percentage of trees (94 trees) on the site and are located on top of a retaining wall on the south property line. The second most abundant tree species is Black Acacia (38 trees), and the trees are located in both the parking lot tree islands and along the perimeter of the existing building.

The Arborist Report determined that the general health of most of the trees was observed to be moderate to poor. The Arborist Report provided recommendations for tree protection 14 HMH. Arborist Report: El Camino / Spruce Avenue, South San Francisco, CA. December 23, 2021. 180 El Camino Real/Steelwave Project
Addendum

August 2022
during construction, as well as maintenance recommendations for trees to remain, in order to ensure the survival of the existing trees that are planned for retention. Compliance with all recommendations included in the Arborist Report would be enforced as a condition of project approval.

In addition, of the 179 on-site trees surveyed, 59 are classified as protected trees, pursuant to the regulations established in Chapter 13.30. According to the preliminary demolition plan, approximately 62 on-site trees would be removed as part of the project.

Should any of the 59 protected trees require removal in order to accommodate the proposed project, the applicant would be required to comply with all provisions set forth in Section 13.30.060, Notices and Permits Required for Removal or Pruning of Protected Trees, and Section 13.30.080, Replacement of Protected Trees. As required therein, a permit shall be obtained for each protected tree to be removed. In addition, each protected tree that is removed shall be replaced with three 15-gallon-size or two 24-inch-boxminimum-size landscape trees. As presented in the Landscaping Plan (refer to Figure 10 and Figure 11), new trees would be planted along the frontages of each proposed building, as well as throughout the central corridor and internal pedestrian walkways. The Landscaping Plan is anticipated to satisfy the requirements of Section 13.30.060.

Because the proposed project would be required to comply with all applicable provisions of Chapter 13.30 of the SSFMC, the project would be consistent with the City’s Tree Preservation Ordinance. Therefore, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to conflicts with any local policies or ordinances protecting biological resources beyond what were previously identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR.
f. The 2009 EIR notes that the Planning Area is not located in an area subject to the San Bruno Mountain Habitat Conservation Plan (HCP). Therefore, under Impact 3.9-1-3, the 2009 EIR determined that the South El Camino Real GPA Project would result in no impact related to a conflict with an adopted HCP, NCCP, or other approved local, regional, or State habitat conservation plan.

The project site is located within the South El Camino Real Planning Area and, thus, also is not subject to the San Bruno Mountain HCP. Other applicable HCPs or NCCPs do not exist in the project area.

Based on the above information, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to conflicts with the provisions of an adopted HCP, NCCP, or other approved local, regional, or State habitat conservation plan beyond what were previously identified in the 2009 EIR.

Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR.

Conclusion
Based on the above and in accordance with Section 15162 of the CEQA Guidelines, the 180 El Camino Real/Steelwave Project would not result in any changes, new circumstances, or new information that would involve new significant impacts or substantially more severe significant impacts from what had been anticipated for the project site in the previous CEQA document related to biological resources.
180 El Camino Real/Steelwave Project
Addendum

August 2022
Mitigation Measure(s)
The proposed project would not require any mitigation related to biological resources.

Mitigation Measures from the Previous CEQA Document
None required in the 2009 EIR.

Additional Project-Specific Mitigation Measures
None required.
180 El Camino Real/Steelwave Project
Addendum

August 2022
V. CULTURAL RESOURCES.

Would the project: Where Impact
Was Analyzed
in 2009 EIR?
Do Proposed
Changes Involve
New or More
Severe
Impacts?
Any New
Circumstances
Involving New or
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
a. Cause a substantial adverse change in
the significance of a historical resource
pursuant to Section 15064.5?

3.9-15 No No No
b. Cause a substantial adverse change in
the significance of a unique
archaeological resource pursuant to
Section 15064.5?

3.9-15 No No No
c. Disturb any human remains, including
those interred outside of dedicated
cemeteries.

3.9-15 No No No
Discussion
Since the release of the 2009 EIR, substantial changes to the project site have not occurred.

Substantial changes in the environmental and regulatory settings related to cultural resources, or in circumstances that would affect the analysis in the 2009 EIR related to cultural resources, have not occurred. Project changes or circumstances that would adversely affect the analysis in the 2009 EIR related to cultural resources have not occurred. a. As noted under Impact 3.9-2-1, federal- or State-listed historic sites do not exist within the Planning Area. Additionally, the 1985-1986 South San Francisco Historic Preservation Survey does not identify any local historic resources within the Planning Area. Therefore, the 2009 EIR concluded that no impact would occur related to historic resources.

Consistent with the above, according to the South San Francisco Historic Preservation Program’s map of Historic Resources, identified historic resources do not exist on or within the vicinity of the project site.15 In addition, Figure 4.14-1, Designated Historic Resources, of the General Plan EIR, does not identify any protected historic resources on the project site.16 Therefore, known historic resources, pursuant to Section 15064.5, do not exist onsite, and development of the proposed project would not result in any impacts to such resources.

Based on the above information, the proposed project would not result in new significant impacts or substantially more severe significant impacts related to a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines Section 15064.5 beyond what were previously identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR. b,c. Impact 3.9-2-2 of the 2009 EIR evaluates potential impacts related to archeological resources and human remains. As noted therein, known archaeological resources or human remains are not located within the Planning Area. Furthermore, the recorded archeological resource, CA-SMA-299, identified in the General Plan is located outside of the Planning Area. Therefore, the 2009 EIR concluded that no impact would occur related to archeological resources and human remains.
15 South San Francisco Historic Preservation Program. South San Francisco Historic Sites. Available at:
https://www.ssf.net/home/showdocument?id=1800. Accessed March 2022. 16 South San Francisco. South San Francisco General Plan Update Draft Environmental Impact Report. June 1999. 180 El Camino Real/Steelwave Project
Addendum

August 2022
Considering that the project site has previously been heavily disturbed through development of the existing structures, the potential for encountering any significant cultural or archaeological resources or human remains during the on-site improvements associated with the project is relatively low. Although low, the potential does exist for previously unknown or unidentified cultural resources or human remains to be encountered below the surface that could be inadvertently damaged or lost during grading and construction of the project. However, the project would also be required to comply with California Health and Safety Code Sections 7050.5 and 7052, which address appropriate handling of human remains, and California PRC Section 5097, which addresses appropriate protection of archeological and historical sites. Compliance with such regulations would ensure that an adverse impact related to archaeological resources and/or human remains, including those interred outside of dedicated cemeteries, would not occur.

Based on the above information, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to the disturbance of any human remains, including those interred outside of formal cemeteries, beyond what were previously identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR.

Conclusion
Based on the above and in accordance with Section 15162 of the CEQA Guidelines, the 180 El Camino Real/Steelwave Project would not result in any changes, new circumstances, or new information that would involve new significant impacts or substantially more severe significant impacts from what had been anticipated for the project site in the previous CEQA document related to cultural resources.

Mitigation Measure(s)
The proposed project would not require any mitigation related to cultural resources.

Mitigation Measures from the Previous CEQA Document
None required in the 2009 EIR.

Additional Project-Specific Mitigation Measures
None required.
180 El Camino Real/Steelwave Project
Addendum

August 2022
VI. ENERGY.

Would the project: Where Impact
Was Analyzed in
2009 EIR?
Do Proposed
Changes Involve
New or More
Severe Impacts?
Any New
Circumstances
Involving New or
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
a. Result in potentially significant
environmental impact due to wasteful,
inefficient, or unnecessary consumption
of energy resources, during project
construction or operation?

3.6-17 to

3.6-19 No No No
b. Conflict with or obstruct a state or local
plan for renewable energy or energy
efficiency?

3.6-17 to

3.6-19 No No No
Discussion
Since the release of the 2009 EIR, substantial changes to the project site have not occurred.

However, changes to regulatory circumstances, outside of the physical condition of the project site, have occurred since the release of the 2009 EIR. In 2016, South San Francisco partnered with Peninsula Clean Energy (PCE), a Community Choice Aggregation, which allows the purchase of electricity from renewable sources through PG&E infrastructure.17 Both PG&E and PCE are working towards providing electricity from 100 percent renewable sources per the State’s Renewable Portfolio Standards (RPS). In addition, the 2019 Building Energy Efficiency Standards went into effect starting January 1, 2020. The 2019 standards provide for additional efficiency improvements beyond what was required by the standards in place in 2009, when the 2009 EIR was adopted. Furthermore, the City’s Energy Reach Codes were adopted through Ordinance 1623-2021 in 2021, and are defined in Sections 15.26.020 and 15.22.020 of the SSFMC. The City’s Energy Reach Codes require all newly constructed residential buildings to be “All-Electric Buildings,” defined as buildings that do not have natural gas or propane plumbing installed within the building property lines. Additionally, the Energy Reach Codes establish requirements related to the installation of electric vehicle (EV) charging stations.

Relative to what was previously approved for the project site, implementation of the proposed project would result in development at a greater non-residential building intensity. The increased non-residential building intensity could affect energy demand when compared to the approved project, as the currently proposed project would be expected to have a higher demand for energy.

Project changes or circumstances that would adversely affect the analysis in the 2009 EIR related to energy have not occurred.
a,b. Impact 3.6-1 evaluates the potential of the South El Camino Real GPA Project to increase per capita energy use. This metric directly correlates to a project’s efficiency and, thus, evaluates whether the project would result in an environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources. Because energy demand and consumption are projected to grow at the same rate as the population, per capita energy use remains constant for electricity and natural gas. Therefore, development considered under the South El Camino Real GPA Project could potentially increase the total demand for gas and electrical services. However, as presented in Table 3.6-5, Annual BTU18 Use and BTU per Capita Projections, of the 2009 EIR, the South El Camino Real GPA Project would accommodate a larger population and, therefore, would result in the consumption of fewer BTU per capita when compared to both the existing conditions and 17 City of South San Francisco. Community Choice Energy. Available at: https://www.ssf.net/departments/citymanager/sustainability/community-choice-energy#:~:text=South%20San%20Francisco%20has%20joinedinstea d%20of%20going%20through%20PG%26E. Accessed May 2022. 18 The British thermal unit, expressed as BTU, is a unit of heat energy. 180 El Camino Real/Steelwave Project
Addendum

August 2022
future no project conditions. Therefore, the 2009 EIR concluded that a less-than-significant impact would occur.

An analysis of the proposed project’s potential impacts related to energy during project construction and operations is provided in detail below.

Construction Energy
Construction of the proposed project would involve on-site energy demand and consumption related to the use of oil in the form of gasoline and diesel fuel for construction worker vehicle trips, hauling and material delivery truck trips, and operation of off-road construction equipment. Project construction would not involve the use of natural gas appliances or equipment. All construction equipment and operation thereof would be regulated per the CARB In-Use Off-Road Diesel Vehicle Regulation. The In-Use Off-Road Diesel Vehicle Regulation is intended to reduce emissions from off-road, heavy-duty diesel vehicles in California by imposing limits on idling, requiring all vehicles to be reported to CARB, restricting the addition of older vehicles into fleets, and requiring fleets to reduce emissions by retiring, replacing, or repowering older engines, or installing exhaust retrofits.

The In-Use Off-Road Diesel Vehicle Regulation would subsequently help to improve fuel efficiency and reduce GHG emissions. Finally, technological innovations and more stringent standards are constantly being researched at the global level, such as multifunction equipment, hybrid equipment, or other design changes; incorporation of such technologies could help to reduce demand on oil and emissions associated with construction.

The CARB prepared the 2017 Climate Change Scoping Plan Update (2017 Scoping Plan),19 which builds upon previous efforts to reduce GHG emissions and is designed to continue to shift the California economy away from dependence on fossil fuels. Appendix B of the 2017 Scoping Plan includes examples of local actions (municipal code changes, zoning changes, policy directions, and mitigation measures) that would support the State’s climate goals. The examples provided include, but are not limited to, enforcing idling time restrictions for construction vehicles, utilizing existing grid power for electric energy rather than operating temporary gasoline/diesel-powered generators, and increasing use of electric and renewable fuel-powered construction equipment. The regulations with which the proposed project must comply, such as the In-Use Off-Road Diesel Vehicle Regulation, would ensure that project construction would be consistent with the intention of the 2017 Scoping Plan and the recommended actions included in Appendix B of the 2017 Scoping Plan.

Given the increased building square footage, construction associated with the proposed project may be more intense or occur over a longer period of time as compared to the construction that would be required for what was previously approved on the project site.

However, as described above, project construction would be required to comply with all applicable regulations governing the use of construction equipment. Compliance with such regulations would ensure that construction activities are not wasteful or inefficient.

Furthermore, the current regulations are more stringent than those in place at the time that the 2009 EIR was prepared, and equipment technologies are more efficient than those available in 2009. For example, the fleet of heavy-duty construction equipment that would have been used in 2009 would be substantially less efficient than the fleet of heavy-duty 19 California Air Resources Board. The 2017 Climate Change Scoping Plan Update. January 20, 2017. 180 El Camino Real/Steelwave Project
Addendum

August 2022
construction equipment that is anticipated to be used for the proposed project. As a result, even if construction would be more intensive under the proposed project, the energy consumed for construction would be used more efficiently than it would have been under the approved project. In addition, construction is temporary, and would occur for only approximately three years. Even during the most intense period of construction, due to the different types of construction activities (e.g., site preparation, grading, building construction), only portions of the site would be disturbed at a time, with operation of construction equipment occurring at different locations on the project site, rather than a single location. Overall, project construction would not result in the wasteful, inefficient, or unnecessary consumption of energy resources, and would comply with all applicable plans for energy efficiency.

Based on the above, the temporary increase in energy use during construction of the proposed project would not result in any new significant impacts or substantially more severe significant impacts related to construction energy use.

Operational Energy
Energy use associated with operation of the proposed project would be typical of R&D and residential uses, requiring electricity for interior and exterior building lighting, mechanical equipment, operation of stoves, kitchen and cleaning appliances, security systems, and more. Maintenance activities during operations, such as landscape maintenance, would involve the use of electric or gas-powered equipment. In addition to on-site energy use, the proposed project would result in transportation energy use associated with vehicle trips generated by future employees, material distributors, and residents. Building energy usage and transportation energy usage associated with the proposed project are discussed in further detail below.

Building Energy
During operations, the proposed project would be required to adhere to the City’s Energy Reach Codes, which were adopted through Ordinance 1623-2021 on June 9, 2021, and are defined in Sections 15.26.020 and 15.22.020 of the SSFMC. The City’s Energy Reach Codes require all newly constructed residential buildings to be “All-Electric Buildings,” defined as buildings that do not have natural gas or propane plumbing installed within the building property lines, and instead use only electricity as the source of energy for space heating, water heating (including pools and spas), cooking appliances, and clothes drying appliances. As a result, the residential building would be all-electric. As noted above, South San Francisco has partnered with PCE, which allows the purchase of electricity from renewable sources through PG&E infrastructure. Therefore, future tenants would have access to electricity generated from renewable sources through PCE. Even if customers choose to opt out of PCE, the electricity supplied by PG&E would comply with the State’s RPS. Thus, a portion of the energy consumed during project operations would originate from renewable sources. In addition, new construction within the City is required to facilitate future installation and use of EV chargers. Specific requirements for the installation of EV chargers are set forth in Section 15.22.020 of the City Code.

Furthermore, the proposed project would be subject to all relevant provisions of the most recent update of the CBSC, including the Building Energy Efficiency Standards.

Adherence to the City’s Energy Reach Code and the most recent CALGreen Code and Building Energy Efficiency Standards would ensure that the proposed structures would consume energy efficiently.
180 El Camino Real/Steelwave Project
Addendum

August 2022
With respect to the 183 residential units, under the City’s Energy Reach Code, the multifamily development would be all-electric, and electricity used for the building would be at least partially renewable, given compliance with the State’s RPS requirements and the option to purchase electricity through PCE. As a result, the energy consumed by the residential component would not be considered wasteful.

The proposed project would involve the development of up to 797,069 sf of non-residential development, which is a net increase of up to 497,069 sf beyond what was evaluated in the 2009 EIR. The increased building square footage would result in an associated increase in demand for energy resources. However, the proposed non-residential building would be required to comply with the 2019 Building Energy Efficiency Standards, which are substantially more stringent as compared to the 2009 Building Energy Efficiency Standards that were applicable at the time the 2009 EIR was prepared. For example, nonresidential buildings built in compliance with the 2019 Building Energy Efficiency Standards are anticipated to use approximately 30 percent less energy compared to the 2016 Building Energy Efficiency Standards, primarily due to lighting upgrades.20 An even greater increase in energy efficiency would occur when comparing the 2019 Building Energy Efficiency Standards to the 2009 Building Energy Efficiency Standards.

Overall, the energy demand associated with the proposed buildings would not be considered wasteful, inefficient, or unnecessary, and the building design would be consistent with existing plans for renewable energy and energy efficiency.

Transportation Energy
When compared to the development that was evaluated in the 2009 EIR, implementation of the proposed project would generate approximately 1,979 net new daily trips. 21 As a
result, the proposed project is anticipated to generate greater VMT when compared to the approved South El Camino Real GPA Project.
22 Nonetheless, as discussed in further
detail in Section XVII, Transportation, of this Addendum, the proposed project would meet all criteria for VMT screening and, therefore, was determined to result in a less-thansignificant impact related to VMT. Although the proposed project would result in increased VMT, the increased demand for energy resources related to the use of vehicles associated with the project would be reduced due to the following project features and programs:
• Design of the project would be required to adhere to the EV parking space requirements included in the City’s Energy Reach Code, as set forth in Section

15.20.020 of the SSFMC. Adherence to such regulations would ensure that the proposed parking areas would include the infrastructure necessary to facilitate the ongoing use of EVs. By providing on-site EV charging spaces, the proposed project would promote the efficient use of energy in transportation by allowing future employees and residents to use alternatively fueled vehicles. • The proposed project includes implementation of a TDM Plan. The TDM Plan would be intended to increase the average vehicle ridership (i.e., increase the number of people within each vehicle by promoting carpooling, vanpooling, etc.), reduce VMT, and reduce the overall number of vehicle trips related to project operations. Implementation of the TDM Plan would ensure that transportation20 California Energy Commission. Title 24 2019 Building Energy Efficiency Standards FAQ. November 2018. 21 Fehr and Peers. Trip Generation Assessment for 180 El Camino Real/Steelwave. April 4, 2022. 22 Fehr and Peers. 180 El Camino Real/Steelwave Transportation Impact Analysis. June 29, 2022. 180 El Camino Real/Steelwave Project
Addendum

August 2022
related energy usage is reduced to the maximum extent practicable, and that transportation to and from the site occurs in an efficient manner. • The proposed project would include sustainability features which would reduce the potential demand for fuel and promote alternative modes of transportation. Such features include on- and off-site bicycle and pedestrian infrastructure, as well as on-site transit infrastructure. The inclusion of such features would promote active transportation and public transportation, which would generate a reduced demand for transportation-related energy.

Implementation of a TDM Plan and the promotion of active and public modes of transportation would ensure the energy demanded for project-related vehicle trips is not wasteful or inefficient, despite the anticipated increase in VMT associated with the project.

In addition, the mixture of residential and non-residential uses proposed under the project would allow an opportunity for future residents to walk or bike to work, should they work at the on-site R&D buildings. Accordingly, consistent with the conclusion presented in the 2009 EIR, the proposed project would not result in an inefficient, wasteful, or unnecessary consumption of energy.

Conclusion
Based on the above, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation or conflicting with or obstructing a State or local plan for renewable energy or energy efficiency beyond what were previously identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR.

Conclusion
Based on the above and in accordance with Section 15162 of the CEQA Guidelines, the 180 El Camino Real/Steelwave Project would not result in any changes, new circumstances, or new information that would involve new significant impacts or substantially more severe significant impacts from what had been anticipated for the project site in the previous CEQA document related to energy resources.

Mitigation Measure(s)
The proposed project would not require any mitigation related to energy resources.

Mitigation Measures from the Previous CEQA Document
None required in the 2009 EIR.

Additional Project-Specific Mitigation Measures
None required.
180 El Camino Real/Steelwave Project
Addendum

August 2022
VII. GEOLOGY AND SOILS.

Would the project: Where Impact
Was Analyzed
in 2009 EIR?
Do Proposed
Changes Involve
New or More
Severe
Impacts?
Any New
Circumstances
Involving New or
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
a. Directly or indirectly cause potential
substantial adverse effects, including the
risk of loss, injury, or death involving:
i. Rupture of a known earthquake
fault, as delineated on the most
recent Alquist-Priolo Earthquake
Fault Zoning Map issued by the
State Geologist for the area
based on other substantial
evidence of a known fault? Refer
to Division of Mines and Geology
Special Publication 42.

3.9-21 No No No
ii. Strong seismic ground shaking? 3.9-21 to

3.9-22 No No No
iii. Seismic-related ground failure,
including liquefaction?

3.9-21 to

3.9-22 No No Yes
iv. Landslides? 3.9-22 No No No
b. Result in substantial soil erosion or the
loss of topsoil?

3.9-22 to

3.9-23 No No No
c. Be located on a geologic unit or soil that
is unstable, or that would become
unstable as a result of the project, and
potentially result in on- or off-site
landslide, lateral spreading, subsidence,
liquefaction or collapse?

3.9-21 to

3.9-23 No No Yes
d. Be located on expansive soil, as defined
in Table 18-1B of the Uniform Building
Code (1994), creating substantial direct
or indirect risks to life or property?

3.9-22 to

3.9-23 No No Yes
e. Have soils incapable of adequately
supporting the use of septic tanks or
alternative wastewater disposal systems
where sewers are not available for the
disposal of wastewater?

3.9-22 No No No
f. Directly or indirectly destroy a unique
paleontological resource or site or
unique geologic feature?

3.9-15 No No No
Discussion
Since the release of the 2009 EIR, substantial changes to the project site have not occurred. In addition, substantial changes in the environmental and regulatory settings related to geology and soils, or in circumstances that would affect the analysis in the 2009 EIR related to geological resources have not occurred. Project changes or circumstances that would adversely affect the analysis in the 2009 EIR related to geology and soils have not occurred. ai-aii. The 2009 EIR evaluated impacts related to fault rupture under Impact 3.9-3-1, and concluded that a less-than-significant impact would occur because the Planning Area is not located within an Alquist-Priolo Earthquake Fault Zone, and active or potentially active faults do not traverse the Planning Area. The 2009 EIR evaluated impacts related to strong seismic ground shaking under Impact 3.9-3-2. As noted therein, although structures within the Planning Area would likely experience seismic ground shaking during their functional 180 El Camino Real/Steelwave Project
Addendum

August 2022
lifetime, future development in the Planning Area would be required to meet the requirements of the CBSC to help prevent extensive structural damage due to seismicrelated ground shaking. As a result, the 2009 EIR concluded that compliance with building codes, the SSFMC, and policies in the City’s General Plan would reduce impacts associated with seismic ground shaking to less than significant.

As noted above, the Planning Area and, thus, the project site, is not located within the boundaries of an Earthquake Fault Zone, as designated pursuant to the Alquist-Priolo Earthquake Fault Zoning Act, and known fault lines do not cross the project site. Therefore, fault rupture is unlikely to occur at the project site.23 Based on the proximity of the project site to local and regional faulting, as well as historical seismic activity, the project site is considered subject to relatively high ground shaking risk and related effects. However, the CBSC provides minimum standards to ensure that the proposed structures would be designed using sound engineering practices and appropriate engineering standards for the seismic area in which the project site is located.

Projects designed in accordance with the CBSC should be able to: 1) resist minor earthquakes without damage; 2) resist moderate earthquakes without structural damage, but with some non-structural damage; and 3) resist major earthquakes without collapse, but with some structural, as well as non-structural, damage. Although conformance with the CBSC does not guarantee that substantial structural damage would not occur in the event of a maximum magnitude earthquake, conformance with the CBSC can reasonably be assumed to ensure that the proposed structures would be survivable, allowing occupants to safely evacuate in the event of a major earthquake. Therefore, implementation of the project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking.

Based on the above information, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to the potential to directly or indirectly cause substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map, or strong seismic ground shaking beyond what were previously identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR.

The following project-specific discussion is based primarily on the Design-Level Geotechnical Investigation that was prepared for the project by Haley & Aldrich (see Appendix C).
24 The purpose of the Design-Level Geotechnical Investigation was to obtain geotechnical information on subsurface conditions at the project site and develop geotechnical design recommendations for the project. Preparation of the Design-Level Geotechnical Investigation included a review of previous geotechnical and geologic reports that included the project site, as well as a field investigation and subsequent laboratory analysis of six soil borings drilled to a depth of 17.5 feet below ground surface (bgs), one seismic cone 23 Haley & Aldrich, Inc. Design-Level Geotechnical Investigation: Research & Development, Residential Buildings, and Parking Structure, 180 El Camino Real South San Francisco, California. May 2022. 24 Haley & Aldrich, Inc. Design-Level Geotechnical Investigation: Research & Development, Residential Buildings, and Parking Structure, 180 El Camino Real South San Francisco, California. May 2022. aiii, aiv,
c, d.
180 El Camino Real/Steelwave Project
Addendum

August 2022
penetration test (CPT) advanced to 80 feet bgs, and two field infiltration tests. The location of all field work that has been conducted on the project site, including sampling conducted in previous studies, are presented in Figure 14. Based on the results of the subsurface exploration conducted for the Design-Level Geotechnical Investigation, approximately 1 to 13 feet of fill is present below the on-site asphalt concrete and aggregate base. In the northern portion of the project site, the subsurface conditions generally consist of interbedded medium dense to dense silty sand or sandy silt and stiff to very stiff sandy lean clay and clayey soils to depths of 20 to 25 feet bgs. The southern half of the project site is mostly underlain by stiff to very stiff clay. However, borings B-4, B-6, and soundings CPT-13 and SCPT-1 encountered silty sand to sandy silt to a depth of about 20 feet bgs, with interbedded sandy lean clay or lean clay layers from approximately 20 to 40 feet bgs, and a lower dense sand layer at about 65 to 80 feet bgs. The zone of medium dense and potentially liquefiable sand layers is present in the first layer that includes the approximately upper 20 feet of soil and in a second layer that extends between 20 and 40 feet bgs within the north and central portions of the site.

The proposed project’s potential effects related to landslides, lateral spreading, expansive soils, liquefaction, and subsidence/settlement are discussed in detail below. In addition, the evaluation and conclusions from the 2009 EIR are presented in each corresponding section below.

Landslides
Seismically-induced landslides are triggered by earthquake ground shaking. The risk of landslide hazard is greatest in areas with steep, unstable slopes.

The 2009 EIR evaluated risks related to landslides under Impact 3.9-3-3. As noted therein, ABAG designates the Planning Area as “flatland;” as a result, the 2009 EIR concluded that no impact would occur with respect to landslides.

The topography of the project site is considered flat, and the site is not located adjacent to any steep slopes. As a result, landslides are not likely to occur on- or off-site.

Lateral Spreading
Lateral spreading is horizontal/lateral ground movement of relatively flat-lying soil deposits towards a free face such as an excavation, channel, or open body of water; typically, lateral spreading is associated with liquefaction of one or more subsurface layers near the bottom of the exposed slope.

The 2009 EIR does not explicitly evaluate impacts related to lateral spreading. However, the Planning Area, including the project site, is not located near an excavation, channel, open body of water, or located at the bottom of an exposed slope. Per the Design-Level Geotechnical Investigation, given that the project site would be relatively flat after construction and that upper soils are predominantly composed of stiff clayey soil and dense sandy soil which will not experience significant liquefaction, the potential for lateral spreading to affect the site is low.
180 El Camino Real/Steelwave Project
Addendum

August 2022
Figure 14
Soil Sampling Locations
180 El Camino Real/Steelwave Project
Addendum

August 2022
Expansive Soils
Expansive soils are soils which undergo significant volume change with changes in moisture content. Specifically, such soils shrink and harden when dried and expand and soften when wetted, potentially resulting in damage to building foundations.

The 2009 EIR, under Impact 3.9-3-4, determined that the potential exists for future development to be subjected to soil expansion and settlement due to the high variability of soil types within the Planning Area. However, because the SSFMC requires that a soils engineering report is submitted with each grading permit application, the 2009 EIR concluded that the impact would be less than significant.

Consistent with the assumptions used in the 2009 EIR, and in compliance with the SSFMC, a soils engineering report has been prepared for the proposed project.

Laboratory test results from a previous report on the site (Geosphere Consultants, Inc., 2016) indicate that the near-surface fine-grained soils have very low expansion potential.

Given compliance with the recommendations included in the Design-Level Geotechnical Investigation and the very low potential for expansive soils on-site, impacts related to expansive soils would not occur.

Liquefaction
Liquefaction is the process in which saturated, cohesionless soil experiences a temporary loss of strength due to the buildup of excess pore water pressure during cyclic loading resulting from earthquake ground motions. The type of soils most susceptible to liquefaction are loose, clean, saturated, uniformly graded sand and silt that have low clay content. Flow failure, lateral spreading, differential settlement, loss of bearing strength, ground fissures, and sand boils are evidence of liquefaction.

The 2009 EIR evaluated impacts related to liquefaction in Impact 3.9-3-2. As discussed therein, liquefaction susceptibility maps prepared by ABAG indicate that the majority of the Planning Area, with the exception of a few parcels west of Colma Creek, has a very low liquefaction hazard. The 2009 EIR concluded that compliance with the existing building codes, the requirements of the SSFMC, and policies contained in the City’s General Plan would reduce liquefaction hazards to less-than-significant levels.

According to the California Geological Survey study for seismically induced hazards, the project site is mapped within a Seismic Hazard Zone that may have the potential for liquefaction. In addition, Haley & Aldrich performed laboratory analyses on soil borings from the project site. Based on the analyses, the plasticity indices from each of these samples indicate that the selected clayey soils are not susceptible to liquefaction. The silty and clayey soils and the silty sand on-site, if saturated or below groundwater, can be susceptible to liquefaction. However, compliance with the recommendations included in the Design-Level Geotechnical Investigation would ensure that impacts related to liquefaction would not occur.

Subsidence/Settlement
When subsurface earth materials move, the movement can cause the gradual settling or sudden sinking of ground. The phenomenon of settling or sinking ground is referred to as subsidence, or settlement. Seismically induced compaction or densification of nonsaturated granular soil (such as sand above the groundwater table) due to earthquake vibrations can result in settlement of the ground surface. 180 El Camino Real/Steelwave Project
Addendum

August 2022
Under Impact 3.9-3-4, the 2009 EIR states that future development within the Planning Area could be subject to settlement. For instance, differential settlement of loose soils would be a concern in areas that have not previously supported structures and where new structures would place loads heavier than the soils could tolerate. However, the 2009 EIR determined that, given mandatory compliance with the SSFMC, which required preparation of a soil engineering report, impacts would be reduced to less than significant.

As noted above, approximately 1 to 13 feet of fill is present on-site, and on-site soils have the potential for liquefaction. Table 7 presents the estimated potential of on-site soils for liquefaction settlement, cyclic densification settlement, and total seismic settlement. As presented therein, the project site is underlain by soil layers expected to be subject to up to 2.5 inches of total seismic settlement. However, compliance with the recommendations provided in the Design-Level Geotechnical Investigation, such as excavation of undocumented fill, compaction of fill material, and incorporation of reinforced foundations, would ensure that adverse impacts related to settlement would not occur.

Table 7
Estimated Settlement Potential
Exploration
No.4 Location
Maximum
Exploration
Depth
(ft)
Estimated
Liquefaction
Settlement
(inches)
Estimated
Cyclic
Densification
Settlement
(inches)
Estimated
Total
Seismic
Settlement
(inches)
CPT-1
Residential

43.9 0.9 0.1-1.0 1.0-1.9
CPT-2 42.5 0.7 0.1-0.8 0.8-1.5
CPT-3 43.2 0.5 0.2-1.6 0.7-2.1
CPT-4 46.6 0.2 0.1-0.9 0.3-1.1
CPT-9 R&D Building 1 28.9 01 0 01
CPT-10 44.2 0.3 0.2 0.5
CPT-11 Parking
Structure 19.6 (2.0) 0 02
CPT-13
R&D Building 3

30.6 01 0 01
CPT-15 23.9 01 0 01
CPT-16 24.7 01 0 01
SCPT-1 R&D Building 2 0-50 0.9 0.9-1.6 1.8-2.5
0-79.9 0.93 0.9-1.6 1.8-2.53
Notes:

1. CPTs have limited depths of exploration and reflect the cyclic densification, but only include a partial liquefaction evaluation. 2. CPTs have limited depths of exploration and reflect the cyclic densification but do not include any liquefaction evaluation. 3. No additional liquefaction settlement estimated from depth 50 to 79.9 feet. 4. Sampling locations are presented in Figure 14.

Source: Haley & Aldrich, Inc. 2022.

Conclusion
Based on the above discussion, and provided that the project would comply with all applicable recommendations set forth in the Design-Level Geotechnical Investigation, the proposed project is not anticipated to result in potential hazards or risks related to landslides, lateral spreading, expansive soils, liquefaction, and subsidence/settlement. As a result, the proposed project would not result in new significant impacts or substantially more severe significant impacts related to liquefaction, landslides, lateral spreading, 180 El Camino Real/Steelwave Project
Addendum

August 2022
subsidence, and expansive soils beyond what were previously identified in the 2009 EIR.

Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR. b. The 2009 EIR evaluated impacts related to erosion under Impact 3.9-3-4. Erosion hazards would be highest during construction activities. Construction activities such as excavation, backfilling, grading, and demolition can remove stabilizing vegetation and expose areas of loose soil that, if not properly stabilized during construction, can be subject to soil loss and erosion by wind and stormwater runoff. However, the 2009 EIR concluded that, with implementation of the required Storm Water Pollution Prevention Plan (SWPPP) and compliance with the National Pollutant Discharge Elimination System (NPDES) General Construction Permit, the impact related to erosion would be less than significant.

Impacts related to erosion are discussed in further detail in Section X, Hydrology and Water Quality, of this Addendum. In summary, the potential for erosion to occur during construction would be managed through the SWPPP and other applicable regulations.

During project operations, substantial erosion is not anticipated to occur.

Based on the above information, the proposed project would not result in new significant impacts or substantially more severe significant impacts related to resulting in substantial soil erosion or the loss of topsoil beyond what were previously identified in the 2009 EIR.

Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR. e. The 2009 EIR evaluated impacts related to the construction of septic systems under Impact 3.9-3-5. As noted therein, the Planning Area is currently served by the City’s municipal sewer system and future projects will continue to be required to be connected to the City’s system; thus, no impact would occur.

The proposed project would connect to the City’s existing sewer system. Thus, the construction or operation of septic tanks or other alternative wastewater disposal systems is not included as part of the project. Therefore, consistent with the conclusion presented in the 2009 EIR, no impact regarding the capability of soils to adequately support the use of septic tanks or alternative wastewater disposal systems would occur.

Based on the above information, the proposed project would not result in new significant impacts or substantially more severe significant impacts related to soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater beyond what were previously identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR.
f. The 2009 EIR assessed the potential to directly or indirectly destroy a unique paleontological resource under Impact 3.9-2-3 and concluded that no impact would occur.

According to the 2009 EIR, the lithology associated with known paleontological records in the City (Equus) is not located within the Planning Area.

The project site has already been developed and, therefore, has been subject to substantial ground disturbance. Therefore, implementation of the proposed project is not anticipated to result in the discovery of previously unknown unique geological or paleontological resources. Furthermore, a records search request for a nearby project along Huntington Avenue was submitted to the UC Berkeley Museum of Paleontology 180 El Camino Real/Steelwave Project
Addendum

August 2022
(UCMP) on December 23, 2021.25 According to UCMP, fossils have not been previously reported from the direct project area. The following two Pleistocene-aged paleobotanical deposits have been reported approximately 1.2 miles southwest of the project site: UCMP localities 165A and 165B. In San Mateo County, fossil vertebrates and invertebrates are primarily known from older Miocene and Pliocene sediments to the west; such rock units do not occur in the project area. Based on the records search and the level of previous on-site disturbance, it is reasonably anticipated that ground-disturbing activity, such as grading, trenching, or excavating associated with implementation of the proposed project, would not disturb or destroy any paleontological resources.

Based on the above information, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to a unique paleontological resource or unique geologic feature beyond what were previously identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR.

Conclusion
Based on the above and in accordance with Section 15162 of the CEQA Guidelines, the 180 El Camino Real/Steelwave Project would not result in any changes, new circumstances, or new information that would involve new significant impacts or substantially more severe significant impacts from what had been anticipated for the project site in the previous CEQA document related to geology and soils.

Mitigation Measure(s)
The proposed project would not require any mitigation related to geology and soils.

Mitigation Measures from the Previous CEQA Document
None required in the 2009 EIR.

Additional Project-Specific Mitigation Measures
None required.
25 Patricia Holroyd, Ph.D., Senior Museum Scientist at UC Berkeley Museum of Paleontology. Personal Communication [email] with Briette Shea, Senior Associate/Air Quality Technician at Raney Planning & Management, Inc. February 17, 2022.
180 El Camino Real/Steelwave Project
Addendum

August 2022
VIII. GREENHOUSE GAS
EMISSIONS.

Would the project:

Where Impact
Was Analyzed
in 2009 EIR?
Do Proposed
Changes
Involve New or
More Severe
Impacts?
Any New
Circumstances
Involving New
or More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
a. Generate greenhouse gas emissions,
either directly or indirectly, that may have
a significant impact on the environment?
N/A No No No
b. Conflict with an applicable plan, policy or
regulation adopted for the purpose of
reducing the emissions of greenhouse
gasses?
N/A No No No
Discussion
Since the release of the 2009 EIR, substantial changes to the project site have not occurred.

However, changes in the environmental and regulatory settings related to GHG emissions have occurred since 2009. For example, SB 32, enacted in 2016, codified the 2030 emissions reduction goal of Executive Order B-30-15 by requiring CARB to ensure that statewide GHG emissions are reduced to 40 percent below 1990 levels by 2030. In addition, as described previously, several local, State, and federal regulations have been enacted since 2009 which establish more stringent standards related to new building construction and motor vehicle emissions. As buildings and motor vehicles become increasingly more energy efficient, the implementation of development projects generates fewer GHG emissions. In other words, construction and operation of a project that complies with all relevant standards in 2009 would result in greater GHG emissions when compared to construction and operation of the same project that complies with the relevant standards in 2022.

Relative to the approved South El Camino Real GPA Project, the proposed project would disturb only a portion of the development footprint, but would include development at a greater intensity.

Thus, under the proposed project, construction intensity could be increased. In addition, given the increase in non-residential square footage and the associated increase in vehicle trip generation, the emissions associated with project operations are anticipated to be higher as compared to the approved project. However, as discussed in more detail below, the anticipated increase in GHG emissions associated with such development at greater intensity would be offset by more stringent GHG reduction measures required by current building regulations. a,b. GHG emissions were not addressed in the 2009 EIR. However, potential impacts related to GHG emissions do not constitute “new information of substantial importance” as defined by CEQA Guidelines section 15162, as GHG emissions were known as potential environmental issues before 2009, when the South El Camino Real GPA EIR was certified.
26 In Citizens for Responsible Equitable Environmental Development (CREED) v.

City of San Diego (2011) 196 Cal.App.4th 515, the Court of Appeal, Fourth Appellate District, concluded that the issue of GHG emissions and climate change could have been raised at the time that the original EIR was prepared (in 1994). For this reason, the lead agency was not required to prepare a Supplemental or Subsequent EIR. In the CREED case, the court noted that scientists and the government have been aware that GHG emissions could trigger climatic changes as early as the 1970’s, or before. Specifically, the Court of Appeal noted that in Massachusetts v. E.P.A. (2007) 549 U.S. 497, 507, the United States Supreme Court stated the following:
26 As explained in a series of cases, most recently in Concerned Dublin Citizens v. City of Dublin (2013) 214 Cal.

App. 4th 1301. Also see, Citizens of Responsible Equitable Development v. City of San Diego (2011) 196 Cal.App.4th 515.
180 El Camino Real/Steelwave Project
Addendum

August 2022
“In the late 1970’s, the Federal Government began devoting serious attention to the possibility that carbon dioxide emissions associated with human activity could provoke climate change. In 1978, Congress enacted the National Climate Program Act, 92 Stat. 601, which required the President to establish a program to ‘assist the Nation and the world to understand and respond to natural and man-induced climate processes and their implications[.]’ [citation] President Carter, in turn, asked the National Research Council, the working arm of the National Academy of Sciences, to investigate the subject. The Council’s response was unequivocal:
‘If carbon dioxide continues to increase, the study group finds no reason to doubt that climate changes will result and no reason to believe that these changes will be negligible. A wait-and-see policy may mean waiting until it is too late.’” The Court of Appeal concluded by stating that “[t]he effect of GHG emissions on climate could have been raised in 1994 when the City considered the FEIR.” In Concerned Dublin Citizens v. City of Dublin (2013) 214 Cal.App.4th 1301, the Court of Appeal for the Fourth Appellate District adopted this reasoning as its own, reaching exactly the same conclusion on similar facts.

Again, in Citizens Against Airport Pollution v. City of San Jose (2014) 227 Cal.App.4th 788, the Court of Appeal, Sixth Appellate District, considered whether the lack of GHG and climate change analysis in a 1997 EIR and 2003 SEIR precluded adoption of an addendum. The court relied on previous case law to conclude that the potential environmental impact of GHG emissions was known or could have been known at the time of certification of the 1997 EIR and 2003 SEIR. The court thus upheld the eighth addendum that the City of San Jose had prepared after having completed the 1997 and 2003 EIRs.

The conclusions that were made in the CREED, Dublin Citizens, and Citizens Against Airport Pollution cases can also be made regarding the 2009 EIR. Under the law, as set forth in these cases, the City may not undertake the preparation of a Supplemental or Subsequent EIR based solely on issues relating to climate change. Thus, the overall creation of GHG emissions from development within the project site cannot under the law constitute a new significant impact or new information of substantial importance.

It is noted that a number of regulations have been enacted since the 2009 EIR was approved for the purpose of, or with an underlying goal for, reducing GHG emissions, such as the California Green Building Standards Code (CALGreen Code) and the California Building Energy Efficiency Standards Code. The 2019 Building Energy Efficiency Standards is a portion of the CBSC, which expands upon energy efficiency measures from the 2016 Building Energy Efficiency Standards. Such regulations have become increasingly stringent since the 2009 EIR was adopted. Therefore, although the proposed project would involve an increase in non-residential building square footage compared to what was evaluated in the 2009 EIR, the anticipated increase in GHG emissions associated with such would be offset by the more stringent GHG reduction measures required by the current building regulations.

Furthermore, the City’s Energy Reach Codes were adopted through Ordinance 1623-2021 in 2021, and are defined in Sections 15.26.020 and 15.22.020 of the SSFMC. The City’s Energy Reach Codes require all newly constructed residential buildings to be “All-Electric Buildings,” defined as buildings that do not have natural gas or propane plumbing installed within the building property lines. Additionally, the Energy Reach Codes establish requirements related to the installation of EV charging stations. The proposed project 180 El Camino Real/Steelwave Project
Addendum

August 2022
would be required to comply with all applicable regulations associated with GHG emissions, including the CALGreen Code and California Building Energy Efficiency Standards Code.

Conclusion
Based on the above and in accordance with Section 15162 of the CEQA Guidelines, the 180 El Camino Real/Steelwave Project would not result in any changes, new circumstances, or new information that would involve new significant impacts or substantially more severe significant impacts from what has been anticipated for the proposed project in the previous CEQA documents related to GHG emissions.

Mitigation Measure(s)
The proposed project would not require any mitigation related to GHG emissions.

Mitigation Measures from the Previous CEQA Document
None required in the 2009 EIR.

Additional Project-Specific Mitigation Measures
None required.
180 El Camino Real/Steelwave Project
Addendum

August 2022
IX. HAZARDS AND
HAZARDOUS MATERIALS.

Would the project:

Where Impact
Was Analyzed
in 2009 EIR?
Do Proposed
Changes Involve
New or More
Severe
Impacts?
Any New
Circumstances
Involving New or
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
a. Create a significant hazard to the public
or the environment through the routine
transport, use, or disposal of hazardous
materials?

3.9-29 No No Yes
b. Create a significant hazard to the public
or the environment through reasonably
foreseeable upset and accident
conditions involving the likely release of
hazardous materials into the
environment?
N/A No No Yes
c. Emit hazardous emissions or handle
hazardous or acutely hazardous
materials, substances, or waste within
one-quarter mile of an existing or
proposed school?

3.9-29 No No No
d. Be located on a site which is included on
a list of hazardous materials sites
compiled pursuant to Government Code
Section 65962.5 and, as a result, would
it create a significant hazard to the public
or the environment?

3.9-29 No No Yes
e. For a project located within an airport
land use plan or, where such a plan has
not been adopted, within two miles of a
public airport or public use airport, would
the project result in a safety hazard or
excessive noise for people residing or
working in the project area?

3.9-30 No No Yes
f. Impair implementation of or physically
interfere with an adopted emergency
response plan or emergency evacuation
plan?

3.9-30 No No No
g. Expose people or structures, either
directly or indirectly, to the risk of loss,
injury or death involving wildland fires?

3.9-31 No No No
Discussion
Since the release of the 2009 EIR, substantial changes to the project site have not occurred. In addition, substantial changes in the environmental and regulatory settings related to hazards and hazardous materials, or in circumstances that would affect the analysis in the 2009 EIR related to hazards and hazardous materials have not occurred. Project changes or circumstances that would adversely affect the analysis in the 2009 EIR related to hazards and hazardous materials have also not occurred.
a. The 2009 EIR assessed the South El Camino Real GPA Project’s potential to create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials under Impact 3.9-4-1 and determined that no impact would occur because future land uses allowed under the GPA would include commercial and residential land uses, and hazardous materials handlers are not anticipated to be built under the South El Camino Real GPA Project.
180 El Camino Real/Steelwave Project
Addendum

August 2022
The residential component of the proposed project is a land use that is already allowed in the area. Maintenance and operation of the residential building may use common cleaning products, fertilizers, and herbicides on-site, any of which could contain potentially hazardous chemicals; however, such products would be expected to be used in accordance with label instructions. Due to the regulations governing use of such products and the amount anticipated to be used on the site, routine use of such products would not represent a substantial risk to public health or the environment.

Implementation of the proposed project would also result in development of R&D uses, laboratories, and other research facilities that are likely to use, store or require the transportation and disposal of hazardous materials. The amount and type of hazardous materials may vary over time, with changes in research and additions to hazardous materials lists. These hazardous materials could include but not necessarily be limited to inorganic and organic chemicals, chemical reagents and reaction products, solvents, radioisotopes, biohazards, fuels, oils, paints, and cleansers.

Implementation of the project would also result in an increase in the number of people that work and visit the project area, increasing the number of individuals potentially exposed to hazardous materials. The individuals most at risk would be those employees who work at locations where hazardous materials are found (laboratories, production and maintenance facilities and construction sites). Whether a person exposed to a hazardous substance at one of these locations may suffer adverse health effects depends upon a complex interaction of factors. Factors that determine the effects of exposure to hazardous materials include the exposure pathway (the route by which a hazardous material enters the body), the amount of material to which the person is exposed, the physical form (e.g., liquid, vapor) and characteristics (e.g., toxicity) of the material, the frequency and duration of exposure, and the individual's unique biological characteristics (e.g., age, gender, weight, and general health). Adverse health effects from exposure to hazardous materials may be short-term (acute) or long-term (chronic). Acute effects can include damage to organs or systems in the body and possibly death. Chronic effects, which may result from long-term exposure to a hazardous material, can also include organ or systemic damage, but chronic effects of particular concern include birth defects, genetic damage and cancer.

Off-site hazardous materials exposure could occur through limited circumstances, such as accidental spills or release during transport or use.

Regulatory Requirements
Future R&D/life science tenants must comply with the safety procedures mandated by applicable federal, State and local laws and regulations (e.g., Resource Conservation and Recovery Act, California Hazardous Waste Control Law and principles prescribed by the US Department of Health Services) to ensure that significant risks resulting from the routine use of hazardous materials and disposal of hazardous wastes do not occur.

Federal and State laws will be extended to all new facilities developed under the proposed project, as applicable. A summary of applicable regulations with which the proposed project would comply is included below.
180 El Camino Real/Steelwave Project
Addendum

August 2022
Use of Chemical Materials
Tenants are required to comply with all State, federal and local regulations that ensure that significant worker and/or public exposure to hazardous chemicals from improper or unsafe activities or from accidents does not occur.
1) To reduce the potential for exposure to airborne chemicals, workers shall take standard precautions such as working under fume hoods when using chemicals that could present exposure hazards. The chemical fume hood is a critical health and safety control in the laboratory setting, ensuring an adequate level of protection from possible harmful effects of chemicals. Proper use of fume hoods keeps exposure to TAC levels within indoor laboratories below levels required by the California Division of Occupational Safety and Health (Cal/OSHA) Permissible Exposure Levels.
2) To prevent exposure through skin contact, protective clothing such as laboratory coats, gloves and safety glasses, will be worn while handling hazardous materials.

Proper washing after handling chemicals is required. Eating, drinking and smoking are prohibited in laboratories and other areas where hazardous materials are used.

These procedures will be disclosed to all staff that work with hazardous materials.

Should an accident occur that could cause exposure of an individual to hazardous materials, required emergency equipment (e.g., fire extinguishers, eyewashes and safety showers) is also available.
3) Cal/OSHA requires all institutions that use hazardous materials to implement a Hazard Communication Program and to train employees that use hazardous chemicals in the safe use of those materials. Tenants will implement all safety procedures and conducts safety programs to ensure that these OSHA safety procedures are consistently followed. Title 8 of the CCR (Section 3203 of the General Industry Safety Orders) also requires every California employer to have a written Injury and Illness Prevention Program to provide a safe and healthful workplace. OSHA mandates methods of documenting, investigating and controlling accidents that result in skin penetration. Evidence presented during OSHA rule-making procedures indicates that these programs and methods are effective in reducing the number and severity of injuries and illness in the workplace.

Use of Radioactive Materials
Should radioactive materials be used at the site, they would be specifically subject to the conditions of a radioactive materials license issued and administered by the Radiologic Health Branch of the Department of Homeland Security (DHS). Radioactive materials licensing requirements include routine inspection and monitoring of areas where radioactive materials are used, to ensure that surfaces are not contaminated with radioactivity above background levels. Under the radioactive materials license, renovation or demolition of facilities using radioactive material requires decommissioning of the facilities. This involves radiation testing and conducting decontamination and waste handling activities in accordance with applicable regulations. 1) Use of radioactive materials will be monitored to ensure consistency with requirements of the radioactive materials license as issued and administered by the Radiologic Health Branch of the DHS. These licensing requirements articulate standards to maintain radiation exposure levels below applicable legal standards, thereby protecting users of radioactive materials.
180 El Camino Real/Steelwave Project
Addendum

August 2022
2) Like all hazardous materials, the effects of the routine use of radioactive materials are limited to areas where exposure may occur and decreases substantially with distance. For this reason, the individuals most at risk would be those specially trained in the use of radioactive materials, thereby reducing the likelihood for accidental exposure through improper handling techniques. All individuals who handle radioactive waste are required to wear a personal monitor that determines their cumulative exposure to radiation. If the monitor indicates that established safety levels might be exceeded, the individual is prevented from being exposed to potential sources of radiation until the monitor indicates that safety levels can be maintained.

Use of Biohazardous Materials
Tenants will comply with guidelines promulgated by the US Department of Health and Human Services (USDHHS), Centers for Disease Control and Prevention, and National Institutes of Health that determine the level of safety precautions that must be used for four tiers of relative hazards. Biosafety Level 1 is for the least hazardous biological agents, and Biosafety Level 4 is for the most hazardous biological agents. Biosafety Levels for infectious agents are based on the characteristics of the agent (virulence, ability to cause disease, routes of exposure, biological stability and communicability), the quantity and concentration of the agent, the procedures to be followed in the laboratory, and the availability of therapeutic measures and vaccines. Biosafety Level 1 agents pose minimal or no known potential hazards to individuals and the environment. Biosafety Level 2 agents are considered to be of ordinary potential hazard and may produce varying degrees of disease through accidental inoculation, but may be effectively contained by ordinary laboratory techniques and specific laboratory equipment. Biosafety Level 3 agents pose a more substantial risk, and work with these agents must be conducted in contained facilities for which airflow is directed into the laboratory and access is controlled separately from public areas.
1) Occupational and public safety is protected by selecting the appropriate biological and physical containment levels for each biological material handled. Standard microbiological practices, such as limiting facility access, washing hands after handling, de-contaminating work surfaces, wearing gloves and other safety equipment, using biosafety cabinets, and proper disposal reduce risks resulting from exposure to biohazardous materials.
2) Current state testing, monitoring and disposal regulations, pertaining to the management of biohazardous materials (including infectious agents), will further ensure that risks associated with use of biohazardous substances remain less than significant.
3) Medical wastes will be managed as a biohazardous material, in accordance with Section 117635 of the California Health and Safety Code and with USDHHS guidelines and DHS regulations. Biohazardous medical waste is generally regulated in the same manner as hazardous waste, except that special provisions apply to storage, disinfection, containment, transportation and disposal.

Disposal of Hazardous Materials
Tenants will dispose of hazardous wastes in compliance with Titles 8, 14, 17 and 22 of the CCR.
180 El Camino Real/Steelwave Project
Addendum

August 2022
1) Spent hazardous materials generated on a daily basis in research, production and maintenance facilities will be placed in special containers and are kept in specially designated and ventilated accumulation areas. These hazardous wastes will be collected and accumulated in designated and secured areas designed to prevent accidental release to the environment. Wastes are transported off- site by licensed hazardous waste transporters to permitted hazardous waste disposal facilities.

Biohazardous wastes are managed in the same way, though separately. 2) If radioactive materials are used on-site, in accordance with strict regulatory guidelines of the Department of Energy, the Nuclear Regulatory Commission, the U.S. Environmental Protection Agency and the California Radiation Control Law (California Health and Safety Code Sections 114960-114985), each tenant will collect, prepare and package its radioactive waste. Radioactive waste is then transported by a radioactive waste broker to a licensed radioactive waste disposal facility.

Hazardous Materials Transport
The California Highway Patrol and U.S. Department of Transportation strictly regulate the transportation of hazardous materials to and from the site. Procedures mandated by federal and State laws and regulations, including driver training and licensing, standardized hazard warning placards for vehicles, shipping manifest requirements and standards for classifying, handling and packaging hazardous materials, will ensure that the use, transport or disposal of hazardous materials does not expose employees, visitors or the nearby public to significant health or safety risks.

It is noted that, in addition to the foregoing federal and State regulations, the Environmental Health Services division of the San Mateo County Health Department oversees the use of hazardous materials throughout the County, including within the City of South San Francisco.

Conclusion
Compliance with the foregoing regulations governing the use of hazardous material would ensure that a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials would not occur. Accordingly, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to the routine transport, use, or disposal of hazardous materials beyond what were previously identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR. b. The 2009 EIR did not specifically discuss the potential for significant hazards to the public or the environment to occur through reasonably foreseeable upset and accident conditions; however, the summary table on page 3.9-24 notes that no impact would occur.

Additionally, under the Environmental Setting header on page 3.9-25, the 2009 EIR notes that three open cases of soil or groundwater contamination exist within the Planning Area:
• Chevron, Former Standard Oil Substation (972 El Camino Real) – Site Assessment for a Leaking Underground Storage Tank (LUST) as of 2008. • Tony’s Services (209 El Camino Real) – Remediation for LUST as of 2006. • Unocal #6980 (192 El Camino Real) – Site Assessment for a LUST as of 1993. 180 El Camino Real/Steelwave Project
Addendum

August 2022
The EIR determined that the land use for the three sites will continue to be designated commercial, and residential uses will not be allowed. It is noted that the site of Unocal #6980, at 192 El Camino Real, is the site of the proposed Safeway, located adjacent to the project site.

A Phase I Environmental Site Assessment (ESA) was prepared for the proposed project by Farallon Consulting, LLC (Farallon) in 2020 (see Appendix D).27 The purpose of the Phase I ESA was to identify recognized environmental conditions (RECs) on the project site and within the project area that have caused and/or may cause an adverse environmental impact, consistent with ASTM E1527-13. The study area for the Phase I ESA was the entire parcel, including the lot that is intended for future development with a Safeway as part of a separate project (see Figure 15).

According to the Phase I ESA, the project site contains remnants of former shopping center retail businesses, totaling approximately 140,000 sf. The westernmost corner of the study area, which is located immediately west of the project site, was formerly used as gasoline service station and auto repair facility. Remaining areas of the project site consist of asphalt-paved parking and landscaped areas.

Based on previous environmental studies in the project area, three gasoline underground storage tanks (USTs) were removed from the former gasoline service station. During UST removal, multiple soil samples were collected from the UST excavations, and petroleum hydrocarbons were detected in each set of soil samples. Various monitoring and remedial actions have been performed by the responsible party and, by mid- to late 2016, the removal of the automotive repair facility had been completed. An Agreement between Chevron Environmental Management Compact (EMC) and the site owner, dated September 8, 2017, indicates that EMC would pay for the implementation of a Revised Remedial Action Plan and other environmental costs within a specified time period. As of the date of the Phase I ESA, the former gasoline service station has not received regulatory closure for historical releases. The San Mateo County Environmental Health Groundwater Protection Program required this work no later than June 2020; however, additional information has not been submitted.

Based on the site reconnaissance conducted on November 23, 2020, the study area did not exhibit any odors, staining, corrosion, stressed vegetation, or other indicators of contamination. Four monitoring wells were observed on the study area, at the location of the former gas station and automotive service station. Pursuant to the Phase I ESA, the wells are assumed to contain vapor monitoring points which are part of the remediation activities.

Overall, the Phase I ESA determined that the release of hazardous substances or petroleum products in connection with historical operations at the former gasoline service station and automotive repair facility on the northwestern portion of the study area represents a REC. However, the foregoing REC is being overseen by the San Mateo County Environmental Health Groundwater Protection Program and includes ongoing remedial efforts. Additionally, the REC was already a known condition, and was considered as site Unocal #6980, in the 2009 EIR.
27 Farallon Consulting, LLC. Phase I Environmental Site Assessment Report, 170 through 192 El Camino Real, South San Francisco, California. December 14, 2020.
180 El Camino Real/Steelwave Project
Addendum

August 2022
Figure 15
Phase I ESA Study Area

STUDY BOUNDARY

PROJECT SITE
180 El Camino Real/Steelwave Project
Addendum

August 2022
Furthermore, the identified REC is not located on the project site, and the proposed project would not include any work on the site of the former USTs. The Phase I ESA did not identify any other RECs associated with the study area.

In order to determine whether any new RECs have occurred on the project site since preparation of the 2020 Phase I ESA, a Phase I ESA Update was prepared by Farallon in 2021 (see Appendix D).28 The Phase I ESA Update included a site reconnaissance on October 11, 2021. The observations made during the site reconnaissance conducted for the Phase I ESA Update were consistent with the observations made during the 2020 Phase I ESA reconnaissance. Five roll-off bins were identified on the northeastern portion of the study area, four of which were located inside plastic secondary containment structures. The bins had “Non-Hazardous Waste” labels indicating the contents were slurry, and indications that any of the waste had leaked from the roll-off bins was not available. A five-gallon drum of presumed waste oil was observed in the parking lot, along with indications of minor oil staining. However, Farallon determined that the minor oil staining is a de minimis condition requiring proper disposal and handling, but not having a material impact on the findings of the assessment. Overall, the Phase I ESA Update found that new RECs have not occurred on the project site, and the conclusions presented in the 2020 Phase I ESA remain applicable.

Based on the above information, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to creating 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, beyond what were previously identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR. c. According to the 2009 EIR, four public schools are located within 0.25-mile of the Planning Area. However, the 2009 EIR concluded that no impact would occur related to the release of hazardous materials within 0.25-mile of a school given the anticipate land uses and the regulations in place governing the use of hazardous materials.

With regard to the project site, specifically, the Parkside Day School is located approximately 600 feet northwest of the project site, and the South San Francisco High School is located approximately 1,200 feet to the north. However, as described above, regulations are in place to address concerns related to the use of hazardous materials onsite and would ensure that hazardous emissions of acutely hazardous materials, substances, or waste are not emitted.

Based on the above information, the proposed project would not result in new significant impacts or substantially more severe significant impacts related to emitting hazardous emissions or handling hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school beyond what were previously identified in the preceding environmental document.
d. As noted under Impact 3.9-4-3 of the 2009 EIR, the Planning Area does not include any sites that are on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. Thus, no impact would occur.
28 Farallon Consulting, LLC. Phase I Environmental Site Assessment Update, 170 through 192 El Camino Real, South San Francisco, California, Farallon PN: 2516-002. October 21, 2021. 180 El Camino Real/Steelwave Project
Addendum

August 2022
Government Code Section 65962.5 requires the California Environmental Protection Agency to annually develop an updated Cortese List. The project site is not located on the Department of Toxic Substances Control’s (DTSC’s) Hazardous Waste and Substances Site List, which is a component of the Cortese List.29 In addition, the project site is not located on any of the other components of the Cortese List (i.e., the list of leaking underground storage tank sites from the State Water Resources Control Board’s (SWRCB’s) GeoTracker database, the list of solid waste disposal sites identified by the SWRCB, and the list of active Cease and Desist Orders [CDO] and Cleanup and Abatement Orders [CAO] from the SWRCB).30 Thus, the project site is not located on a site that is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5.

Based on the above information, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to being located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and would not create a significant hazard to the public or the environment beyond what was previously identified in the 2009 EIR. e. As noted under Impact 3.9-4-4, the Planning Area is located north of San Francisco International Airport, and is located within the San Mateo County ALUC jurisdiction. The 2009 EIR states that all development allowed under the South El Camino Real GPA Project would be required to adhere to the airport-related height and safety limitations established in the most current ALUCP. Compliance with such regulations would ensure that a less than significant impact would occur.

The San Francisco International Airport is located approximately 1.7 miles southeast of the site. According to the SFO ALUCP, the project site falls within the boundaries for Airport Influence Areas A and B. Area B is a subset of, and thus within, Area A. For projects located within Area B, the ALUC must review and approve development proposals, and a real estate disclosure form must be prepared for future residents.

An Airspace Safety Analysis was prepared by Williams Aviation Consultants, Inc. in order to determine possible impacts on navigable airspace, flight procedures, and determine the maximum achievable structure elevation which will not adversely impact aeronautical operations at SFO.
31 The Airport Safety Analysis included a review of the following criteria to determine possible adverse impacts to aeronautical operations:

1. Public and private airports in the vicinity of the proposed structure;

2. Federal Aviation Regulation Part 77, Objects Affecting Navigable Airspace;

3. Terminal Instrument Procedures (TERPS) including instrument approach and departure procedures;

4. Visual Flight Rule Traffic Pattern Airspace;

5. One Engine Inoperative (OEI) Criteria; and

6. ALUCP Safety Compatibility Zones.
29 California Department of Toxic Substances Control. EnviroStor. Available at:
https://www.envirostor.dtsc.ca.gov/public/. Accessed July 2022. 30 California Environmental Protection Agency. Cortese List Data Resources. Available at:
https://calepa.ca.gov/sitecleanup/corteselist/. Accessed July 2022. 31 Williams Aviation Consultants, Inc. Airspace and Safety Analysis - 180 El Camino Real, South San Francisco, CA.

April 26, 2022.
180 El Camino Real/Steelwave Project
Addendum

August 2022
An analysis of CFR Part 77 Notice Requirements was conducted, and it was determined that the proposed project would require formal submission to the Federal Aviation Administration. The proposed R&D buildings would have an overall height of approximately 155 feet Above Mean Sea Level (AMSL), and the residential building would have an overall height of approximately 132 feet AMSL.32 The maximum height over the project site without affecting the Instrument Approach Procedures to SFO is approximately 385 feet AMSL to the southeast and approximately 415 feet AMSL to the northwest. The maximum height over the project site, without affecting Circle-to-Land to SFO is 660 feet AMSL. The maximum height over the project site without affecting the Visual Flight Rule Traffic Pattern to SFO is 363 feet AMSL. The maximum height over the project site without affecting the RWY 28R Departure Initial Climb Area is approximately 247 feet AMSL to the southeast and approximately 263 feet AMSL to the northwest. The maximum SFO OEI heights range from 160 to 164 feet AMSL. Therefore, the proposed building heights would not exceed any of the foregoing safety criteria, and an impact related to the project site being located within two miles of an airport would not occur.

As depicted in Exhibit IV-8 of the SFO ALUCP, approximately one third of the project site falls within Safety Compatibility Zone 4 – Outer Approach/Departure Zone. Pursuant to SFO ALUCP Table IV-2, Safety Compatibility Criteria, Biosafety Level 3 and 4 facilities are considered incompatible within Zone 4. The proposed project would not include any Biosafety Level 3 or 4 facilities. However, the proposed R&D uses would be considered Biosafety Level 2 facilities. Biosafety Level 2 is not fully compatible and, pursuant to the ALUCP, should not be permitted unless no feasible alternative is available. Where such a use is allowed, habitable structures shall be provided with at least 50 percent more exits than required by applicable codes. Pursuant to the Airspace Safety Analysis, Biosafety Level 1 and Biosafety Level 2 risk levels do not differ substantially, in that the organism handled in either would not cause harm above organisms already found in the community, are generally treatable, and the robust facility, engineering, biosafety practices and security control measures necessary to effectively contain them are not highly susceptible to human error. Illness and infections spreading into communities surrounding a Biosafety Level 1 or Biosafety Level 2 lab facility generally do not occur because research on highrisk agents and pathogens can only be performed in Biosafety Level 3 and Biosafety Level 4 laboratories. Therefore, the restrictions in Safety Compatibility Zone 4 at SFO should not restrict the use of Biosafety Level 2 facilities, and only Biosafety Level 3 and 4 facilities would be considered incompatible within Zone 4.

During their June 23, 2022 hearing regarding the project’s consistency review, the ALUC recommended that the City make a specific determination as to whether feasible alternatives to the proposed Biosafety Level 2 use exist. Accordingly, the City shall require the following conditions of project approval to ensure that the project complies with the Safety Policies of the SFO ALUCP:
• Prior to approval, the final land use decision-making body for the project (South San Francisco City Council, Planning Commission, etc.) shall make specific findings that there is no feasible alternative for the proposed inclusion of Biosafety Level 2 use on the site. • The City of South San Francisco shall ensure that any structure within the project that is located within Safety Zone 4 and that contains a use classified as Biosafety Level 2 shall be provided with at least 50 percent more exits than required by applicable codes. 32 The difference between the building heights presented herein and the building heights presented in Section D, Project Description, of this Addendum, can be accounted for by considering the elevation of the project site. 180 El Camino Real/Steelwave Project
Addendum

August 2022
Additionally, as noted previously, a City override would be required to allow the proposed residential component within the identified noise compatibility zone. Refer to Section XIII, Noise, of this Addendum, for further discussion of airport noise and the required Residential Noise Compatibility override.

Based on the above information, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to being located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, and result in a safety hazard or excessive noise for people residing or working in the project area, beyond what were previously identified in the 2009 EIR.
f. According to the 2009 EIR, under Impact 3.9-4-5, emergency response or evacuation plans are not in effect in the Planning Area vicinity. Additionally, the South El Camino Real GPA Project would not result in blocking access to roadways nor blocking emergency vehicle access. Thus, no impact would occur.

During construction of the proposed project, all construction equipment would be staged on-site so as to prevent obstruction of local and regional travel routes in the City that could be used as evacuation routes during emergency events.

During operation, the proposed project would provide adequate access for emergency vehicles and would not interfere with potential evacuation or response routes used by emergency response teams. For example, four driveways would provide access to the project site: two from El Camino Real and two from Huntington Avenue. In the event of an emergency, residents, patrons, or first responders would be able to access the site via any of the proposed driveways. In addition, vehicle trips generated by the proposed project would represent a very small percentage of overall daily and peak hour traffic on roadways and freeways in the area, and emergency access and evacuation in the project vicinity would not be substantially affected by traffic generated by the proposed project.

Additionally, the proposed project would not involve any operations or changes to the existing roadway network that would impair implementation or physically interfere with emergency access or evacuation. Finally, the proposed project would include the same land uses and components that are already allowed by the General Plan. Therefore, buildout of the site with the proposed uses has already been generally considered by the City and accounted for in emergency planning.

Based on the above information, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to an adopted emergency response plan or emergency evacuation plan beyond what were previously identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR.
g. Under Impact 3.9-4-6, the 2009 EIR evaluated impacts related to wildland fires. As noted therein, wildland fire risk areas do not exist in the vicinity of the Planning Area, and the Planning Area is not located within a fire hazard management unit identified in the 1999 General Plan. Therefore, no impact would occur.

According to the CAL FIRE Fire Hazard Severity Zone (FHSZ) Viewer, the project site is not located within or adjacent to a State or local Very High or High FHSZ. Additionally, the project would be required to comply with all applicable requirements of the California Fire 180 El Camino Real/Steelwave Project
Addendum

August 2022
Code, which would ensure that the proposed structures are constructed to adequately protect people from hazards related to fire. Furthermore, the urbanized nature of the surrounding area would preclude the uncontrolled spread of wildfire. Overall, the proposed project would not expose people or structures to a significant risk involving wildland fires.

Based on the above information, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to significant risk of loss, injury, or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands, beyond what were previously identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR.

Conclusion
Based on the above and in accordance with Section 15162 of the CEQA Guidelines, the 180 El Camino Real/Steelwave Project would not result in any changes, new circumstances, or new information that would involve new significant impacts or substantially more severe significant impacts from what had been anticipated for the project site in the previous CEQA document related to hazards and hazardous materials.

Mitigation Measure(s)
The proposed project would not require any mitigation related to hazards and hazardous materials.

Modified Mitigation Measures
None required.

Additional Project-Specific Mitigation Measures
None required.
180 El Camino Real/Steelwave Project
Addendum

August 2022
X. HYDROLOGY AND WATER
QUALITY.

Would the project:

Where Impact
Was Analyzed
in 2009 EIR?
Do Proposed
Changes Involve
New or More
Severe
Impacts?
Any New
Circumstances
Involving New or
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
a. Violate any water quality standards or
waste discharge requirements or
otherwise substantially degrade surface
or ground water quality?

3.9-37 No No No
b. Substantially decrease groundwater
supplies or interfere substantially with
groundwater recharge such that the
project may impede sustainable
groundwater management of the basin?

3.9-37 No No No
c. Substantially alter the existing drainage
pattern of the site or area, including
through the alteration of the course of a
stream or river or through the addition of
impervious surfaces, in a manner which
would:
i. Result in substantial erosion or
siltation on- or off-site; 3.9-38 No No No
ii. Substantially increase the rate or
amount of surface runoff in a
manner which would result in
flooding on- or offsite;

3.9-38 No No No
iii. Create or contribute runoff water
which would exceed the capacity
of existing or planned stormwater
drainage systems or provide
substantial additional sources of
polluted runoff; or

3.9-38 to

3.9-39 No No No
iv. Impede or redirect flood flows? 3.9-39 No No No
d. In flood hazard, tsunami, or seiche
zones, risk release of pollutants due to
project inundation?

3.9-39 No No No
e. Conflict with or obstruct implementation
of a water quality control plan or
sustainable groundwater management
plan?

3.9-37 No No No
Discussion
Since the release of the 2009 EIR, substantial changes to the project site have not occurred.

Substantial changes in the environmental and regulatory settings related to hydrology and water quality, or in circumstances that would affect the analysis in the 2009 EIR related to hydrology and water quality have not occurred. Project changes or circumstances that would adversely affect the analysis in the 2009 EIR related to hydrology and water quality have not occurred. a. Under Impact 3.9-5-1, the 2009 EIR determined that adherence to applicable federal, State, and local laws, including NPDES stormwater permits and stormwater management programs, would ensure that impacts related to water quality standards would be less than significant.

State and local regulations are in place to ensure that water quality impacts associated with the proposed project and the project that was evaluated in the 2009 EIR would be minimized to acceptable levels.
180 El Camino Real/Steelwave Project
Addendum

August 2022
Construction
During the early stages of construction activities, topsoil would be exposed due to demolition, grading and excavation of the site. After grading and prior to overlaying the ground surface with impervious surfaces and structures, the potential exists for wind and water erosion to discharge sediment and/or urban pollutants into stormwater runoff, which could adversely affect water quality downstream.

The SWRCB regulates stormwater discharges associated with construction activities where clearing, grading, or excavation results in a land disturbance of one or more acres.

The City’s NPDES permit requires applicants to show proof of coverage under the State’s General Construction Permit prior to receipt of any construction permits. The State’s General Construction Permit requires a SWPPP to be prepared for the site. A SWPPP describes Best Management Practices (BMPs) to control or minimize pollutants from entering stormwater and must address both grading/erosion impacts and non-point source pollution impacts of the development project. Because the proposed project would disturb greater than one acre of land, the proposed project would be subject to the requirements of the State’s General Construction Permit.

In addition, the project would be required to comply with Chapter 14.04, Stormwater Management and Discharge Control, of the SSFMC, which includes standards for managing stormwater runoff during construction and operation. Per Section 14.04.180, all construction sites within the City must implement year-round erosion control, run-on and runoff control, sediment control, active treatment systems (if appropriate), good site management, and non-stormwater management through all phases of construction until the site is stabilized. Due to the mandated compliance of project construction activities with the State’s General Construction Permit and Chapter 14.04 of the SSFMC, the proposed project would not discharge sediment or urban pollutants through soil erosion, violate any water quality standards or waste discharge requirements, or otherwise substantially degrade surface or ground water quality during construction.

The foregoing requirements would apply to the previously approved project as well as the proposed project, and the additional non-residential building square footage proposed as part of the project would not influence the efficacy of such.

Operation
The proposed buildings would not involve operations typically associated with the generation or discharge of polluted water. Thus, typical operations on the project site would not violate any water quality standards or waste discharge requirements, nor degrade water quality. However, the incorporation of impervious surfaces on the site would result in the generation of urban runoff, which could contain pollutants if the runoff encounters sources such as vehicle fluids on parking surfaces and/or landscape fertilizers or herbicides. It is noted that the project site is currently developed, and includes approximately 438,589 sf of impervious surface area. Following implementation of the proposed project the project site would include 351,787 sf of impervious surface area.

Thus, a net decrease in impervious surfaces would occur.

The County of San Mateo has adopted C.3 Stormwater Standards, which require new development and redevelopment projects that create or alter 10,000 or more sf of impervious area to contain and treat all stormwater runoff from the project site. The proposed project would replace a substantial amount of existing impervious surfaces on 180 El Camino Real/Steelwave Project
Addendum

August 2022
the project site. Thus, the project would be subject to the requirements of the C.3 Stormwater Standards related to stormwater treatment.

A preliminary Stormwater Plan has been prepared for the proposed project (refer to Figure 13) that demonstrates the project’s compliance with the most recent City and County guidelines. The proposed project would treat stormwater from the project site using a combination of pervious landscaping, permeable paving, bioretention basins, self-treating areas, and Silva Cell biotreatment systems. The project site would be divided into 13 DMAs. Stormwater runoff from DMAs 1, 2, 3, 8, 10, 11, and 12 would be directed towards associated Silva Cell biotreatment areas. The stormwater retained in the Silva Cell biotreatment area is either used for watering the supported tree or is infiltrated through the soil and eventually discharged at the underdrain. Runoff from DMAs 4, 5, 6, 7, and 9 would be directed towards each associated bioretention area. The bioretention areas would include three to four inches of grass on a minimum of 18 inches of biotreatment soil mix, underlaid with Class II permeable materials. A four-inch perforated underdrain pipe would be placed at the bottom of the bioretention area to collect treated stormwater.

Per the preliminary Stormwater Plan prepared for the proposed project, the pervious landscaping, permeable paving, bioretention basins, self-treating areas, and Silva Cell biotreatment systems would be sized to adequately handle all runoff from the proposed impervious surfaces within each DMA. Thus, the proposed project would comply with the City and County requirements and would meet the C.3 Standards related to stormwater treatment. During operation, the project would comply with all relevant water quality standards and waste discharge requirements, and would not degrade water quality.

Conclusion
Based on the above information, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to the violation of any water quality standards or waste discharge requirements or the substantial degradation of surface or groundwater quality beyond what were previously identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR.
b,e. The 2009 EIR discusses impacts related to groundwater under Impact 3.9-5-2, which explains that the Planning Area is built out and primarily consists of impermeable surfaces.

Groundwater recharge, however, generally occurs in near-stream or open space areas.

Thus, buildout within the Planning Area would not result in a substantial impact to groundwater supplies or groundwater recharge, and a less-than-significant impact would occur.

The proposed project would involve up to 497,069 sf of additional non-residential building square footage as compared to what has been previously approved for the Planning Area.

As such, the 2009 EIR analyzed buildout of the site at a lower intensity development than what is proposed. However, per the Cal Water 2020 Urban Water Management Plan (UWMP) for the South San Francisco District, groundwater currently accounts for approximately 20 percent of the District’s water supplies.33 The volume of groundwater pumped is planned to remain consistent over time in order to ensure sustainable groundwater maintenance. For example, the South Westside Basin Groundwater 33 California Water Service. 2020 Urban Water Management Plan, South San Francisco District [pg. 58]. June 2021. 180 El Camino Real/Steelwave Project
Addendum

August 2022
Management Plan notes that, while the overall water demand from the South San Francisco District service area is projected to increase, the demand will be met through a steady supply of 1,535 acre-feet per year (AFY) of groundwater and the remaining demand will be met through purchased surface water. The projected groundwater supply meets the projected groundwater demand of 1,535 AFY.34 As such, even though the water demand is anticipated to be higher with implementation of the proposed project as compared to what was previously planned for the site, the increased demand would not impact the volume of groundwater that is pumped. Refer to question ‘a,b,c’ of Section XIX, Utilities and Services Systems, of this Addendum, wherein water demand associated with the proposed project and the City’s surface water supply is discussed in further detail. As described therein, the net increase in water demand associated with implementation of the proposed project could be accommodated by the current water provider.

Groundwater recharge refers to the percolation of surface water, often stormwater, through pervious surfaces and into groundwater. Considering the project site is currently developed and covered primarily in impervious surfaces, the project site does not currently play a substantial role in groundwater recharge. Additionally, per the Sustainable Groundwater Management Act Basin Prioritization Dashboard, the Westside Groundwater Basin is considered Very Low Priority per the Department of Water Resources and, thus, implementation of the project would not adversely affect recharge of a high priority groundwater basin.35 Furthermore, because the proposed project would result in a net decrease in impervious surface area on the site, implementation of the proposed project would increase groundwater recharge as compared to existing conditions.

Therefore, the proposed project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the Westside Groundwater Basin. In addition, the project would not conflict with or obstruct implementation of a water quality control plan or the South Westside Basin Groundwater Management Plan.

Based on the above information, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to substantially decreasing groundwater supplies, interfering substantially with groundwater recharge such that the project could impede sustainable groundwater management of the basin, or conflicting with or obstructing implementation of a water quality control plan or sustainable groundwater management plan, beyond what were previously identified in the 2009 EIR.

Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR. ci-ciii. The 2009 EIR evaluated the potential for buildout of the Planning Area under the South El Camino Real GPA Project to substantially alter the existing drainage pattern of the site or area, or create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems, or substantially increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site under Impacts 3.9- 5-3 and 3.9-5-4. Considering the Planning Area is already built out and given the amount of impervious surfaces, the 2009 EIR concluded that future development would not result in a substantial physical change with respect to drainage patterns, and impacts on existing drainage patterns would be less than significant. In addition, future development would be 34 Regional Water System. South Westside Basin Groundwater Management Plan [pg. 3-19]. July 2012. 35 Department of Water Resources. Sustainable Groundwater Management Act Basin Prioritization Dashboard.

Available at: https://gis.water.ca.gov/app/bp-dashboard/final/. Accessed May 2022. 180 El Camino Real/Steelwave Project
Addendum

August 2022
required to submit a SWPPP and an Erosion Control Plan to the City Engineer and the Water Quality Control Division prior to the commencement of any grading or construction.

Implementation of such measures would prevent soil, dirt, and debris from entering the storm drain system. Overall, the 2009 EIR concluded that impacts related to substantially altering the existing drainage pattern of the area or contributing runoff water which would exceed the existing system would be less than significant.

The project site is currently developed and includes substantial paved, impervious areas.

As noted under question ‘a’, above, the project is required to comply with C.3 Standards.

Compliance with C.3 Standards would be sufficient to ensure that the proposed project does not exceed the capacity of existing storm drain infrastructure, cause flooding on- or off-site, or result in off-site erosion or siltation after development of the site. In addition, the net decrease in impervious area that would occur with implementation of the proposed project would serve to reduce the volume of stormwater runoff. Given that the project site is already developed and connected to the City’s storm drain infrastructure, and that the project would not result in a greater volume of stormwater runoff following implementation of the project as compared to existing conditions, the existing storm drain system would be adequate to continue serving the project site. It should be noted that, per the Countywide Hydromodification Control Area Map in the San Mateo County C.3 Stormwater Technical Guidance Appendix H, the proposed project would not be subject to Hydromodification Management requirements.36
Based on the above, the proposed project would not result in new significant impacts or substantially more severe significant impacts related to substantially altering the existing drainage pattern of the site or area, or creating or contributing runoff water which would exceed the capacity of existing or planned stormwater drainage systems, or substantially increasing the rate or amount of surface runoff in a manner that would result in flooding on- or off-site beyond what were previously identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR. civ,d. The 2009 EIR evaluates impacts related to flooding under Impact 3.9-5-5, and impacts related to inundation by seiche, tsunami, or mudflow under Impact 3.9-5-6. As discussed therein, the Planning Area is not located near a levy or a dam, and is not located in a 100- year flood hazard zone. Therefore, no impact would occur related to the placement of people or structures in a flood hazard area. While an earthquake could result in a tsunami or seiche in the Bay Area, the potential wave run-up of a 500-year tsunami would be approximately 6.0 feet above mean sea level. Considering the elevation in the Planning Area ranges from 20 to 70 feet AMSL, the potential for an impact from inundation by a tsunami or seiche would be less than significant.

According to the FEMA FIRM No. 06081C0043F, the project site is designated as an Area of Minimal Flood Hazard (Zone X).37 As such, consistent with the 2009 EIR, the site is not classified as a Special Flood Hazard Area or otherwise located within a 100-year or 500- year floodplain. While the project site is located relatively close to the Pacific Ocean (approximately one mile to the western border of the San Francisco Bay), the project site is not located within a Tsunami Inundation Area, as defined by the California Department 36 San Mateo Countywide Water Pollution Prevention Program. C.3 Regulated Project Guide [Page H-3]. January 2020. 37 Federal Emergency Management Agency. Flood Insurance Rate Map 06081C0043F. April 5, 2019. 180 El Camino Real/Steelwave Project
Addendum

August 2022
of Conservation.
38 Additionally, the elevation of the project site ranges between 28 and 52 feet39 and, thus, the site would not be subjected to inundation from the 500-year tsunami.

Additionally, while the effects of sea level rise on future residents is beyond the scope of CEQA, insofar as it pertains to the environment’s effect on the project, this issue has been addressed for informational purposes. According to Appendix B, Asset Exposure Maps, of the County of San Mateo Sea Level Rise Vulnerability Assessment, the project site is located outside of the projected High Scenario Sea Level Rise boundaries.40 The High Scenario shows the possible extent of flooding during a one percent chance annual storm plus 6.6 feet of sea level rise and is considered a worst-case scenario in the Vulnerability Assessment. As a result, the project would not be susceptible to impacts associated with sea level rise, and adaptation strategies to reduce the impacts of sea level rise are not required for the proposed project.

Based on the above, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to impeding or redirecting flood flows or flood hazard zones beyond what were previously identified in the 2009 EIR.

Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR.

Conclusion
Based on the above and in accordance with Section 15162 of the CEQA Guidelines, the 180 El Camino Real/Steelwave Project would not result in any changes, new circumstances, or new information that would involve new significant impacts or substantially more severe significant impacts from what had been anticipated for the project site in the 2009 EIR related to hydrology and water quality.

Mitigation Measure(s)
The proposed project would not require any mitigation related to hydrology and water quality.

Mitigation Measures from the Previous CEQA Document
None required in the 2009 EIR.

Additional Project-Specific Mitigation Measures
None required.
38 California Department of Conservation. Tsunami Inundation Map for Emergency Planning: State of California, County of San Mateo, San Francisco South Quadrangle. June 15, 2009. 39 Haley & Aldrich, Inc. Design-Level Geotechnical Investigation Research & Development, Residential Buildings, and Parking Structure, 180 El Camino Real, South San Francisco, California. May 2022. 40 County of San Mateo. County of San Mateo Sea Level Rise Vulnerability Assessment Final Report. March 2018. 180 El Camino Real/Steelwave Project
Addendum

August 2022
XI. LAND USE AND
PLANNING.

Would the project:

Where Impact
Was Analyzed
in 2009 EIR?
Do Proposed
Changes Involve
New or More
Severe
Impacts?
Any New
Circumstances
Involving New or
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
a. Physically divide an established
community? 3.8-7 No No No
b. Cause a significant 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?

3.8-9 No No No
Discussion
Since the release of the 2009 EIR, substantial changes to the project site have not occurred.

Substantial changes in the environmental and regulatory settings related to land use and planning, or in circumstances that would affect the analysis in the 2009 EIR related to land use and planning, have not occurred. Project changes or circumstances that would adversely affect the analysis in the 2009 EIR related to land use and planning have not occurred. a. A project risks dividing an established community if the project would introduce infrastructure or alter land use so as to change the land use conditions in the surrounding community, or isolate an existing land use.

As discussed under Impact 3.8-1 in the 2009 EIR, the South El Camino Real GPA Project would not physically divide any established community but, rather, would increase land use compatibility along El Camino Real and provide better linkages between the northern and southern part of El Camino Real and the surrounding communities. Thus, the 2009 EIR determined that a less-than-significant impact would occur.

The project site does not contain existing housing or other habitable structures. In addition, the proposed project would be compatible with the urban development that surrounds the project site, including commercial uses to the south and east and residential uses to the north and west. Considering the proposed project would introduce land use types that are already allowed by the approved South El Camino Real GPA Project, the proposed project would not alter the existing general development trends in the area or isolate an existing land use.

Based on the above information, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to the physical division of an established community beyond what were previously identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR.
b. The 2009 EIR evaluated the potential for the South El Camino Real GPA Project to conflict with the City’s General Plan or Zoning Ordinance under Impact 3.8-3 and determined that a less-than-significant impact would occur. Because the GPA would amend the existing General Plan designation, there would be no inconsistencies with any local plans.

Furthermore, adoption of a new zoning district and regulations concurrently would ensure that planning and implementation remain consistent.
180 El Camino Real/Steelwave Project
Addendum

August 2022
Per the City’s General Plan, the project site is designated El Camino Real Mixed Use and the site is zoned ECRMX. The El Camino Real Mixed Use land use designation is intended to accommodate high-intensity active uses and mixed-use development in the South El Camino Real area. The proposed project would be consistent with this intended use, and would comply with the development standards set forth in Table 2.3-1 of the 2009 EIR, including the maximum building height, FAR, and building density. In addition, the project would be consistent with the applicable guiding policies established for the El Camino Real Mixed Use land use designation. For example, Policy 3.4-G-5 states that the South El Camino area shall be developed as a “vibrant corridor with a variety of residential and non-residential uses to foster a walkable and pedestrian-scaled environment.” The proposed project would include both residential and non-residential uses, and the project design is intended to support pedestrian circulation.

As noted in Section 20.090.001 of the SSFMC, the purpose of the ECRMX zoning district is to:

A. Develop the South El Camino area as a vibrant corridor with a variety of residential and nonresidential uses to foster a walkable and pedestrian-scaled environment; B. Ensure that active uses are located along and oriented towards El Camino Real to provide an engaging pedestrian-scaled environment;
C. Ensure that new mixed-use development is designed to minimize traffic and parking impacts on surrounding residential neighborhoods and is appropriate to the physical characteristics of the site and the area where the project is proposed; D. Offer additional opportunities for housing for residents as well as improve access to a greater range of facilities and services for surrounding residential neighborhoods; and
E. Encourage the development of mixed-use projects that incorporate environmentally sensitive features and amenities to benefit the public as well as meet the needs of project occupants.

The project would support each of the foregoing goals by developing a mixed-use, pedestrian-friendly campus with a TDM Plan to reduce traffic-related impacts. The project would also include residential uses that would further support items A and D. In addition, the proposed land uses, including multi-unit residential and R&D, are allowable within the ECRMX District. As noted previously, the project would require approval of several CUPs (i.e., parking reduction, building height, and business operation/truck loading hours).

Given approval of the CUPs, the project would comply with all applicable development standards set forth in the SSFMC. Overall, the proposed project would be consistent with the site’s current land use and zoning designations.

Furthermore, as discussed throughout this Addendum, the proposed project would not result in any new significant impacts or a substantial increase in the severity of a previously identified impact. The project would not conflict with City policies and regulations adopted for the purpose of avoiding or mitigating an environmental effect, including, but not limited to, City policies and guidelines related to the City’s noise standards and all applicable SWRCB regulations related to stormwater.

Based on the above information, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to inconsistency with any applicable land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect beyond what were previously 180 El Camino Real/Steelwave Project
Addendum

August 2022
identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR.

Conclusion
Based on the above and in accordance with Section 15162 of the CEQA Guidelines, the 180 El Camino Real/Steelwave Project would not result in any changes, new circumstances, or new information that would involve new significant impacts or substantially more severe significant impacts from what had been anticipated for the project site in the previous CEQA document related to land use and planning.

Mitigation Measure(s)
The proposed project would not require any mitigation related to land use and planning.

Mitigation Measures from the Previous CEQA Document
None required in the 2009 EIR.

Additional Project-Specific Mitigation Measures
None required.
180 El Camino Real/Steelwave Project
Addendum

August 2022
XII. MINERAL RESOURCES.

Would the project: Where Impact
Was Analyzed in
2009 EIR?
Do Proposed
Changes Involve
New or More
Severe Impacts?
Any New
Circumstances
Involving New or
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
a. Result in the loss of availability of a
known mineral resource that would be of
value to the region and the residents of
the state?

3.9-40 No No No
b. Result in the loss of availability of a
locally-important mineral resource
recovery site delineated on a local
general plan, specific plan or other land
use plan?

3.9-40 No No No
Discussion
Since the release of the 2009 EIR, substantial changes to the project site have not occurred.

Substantial changes in the environmental and regulatory settings related to mineral resources, or in circumstances that would affect the analysis in the 2009 EIR related to mineral resources, have not occurred. Project changes or circumstances that would adversely affect the analysis in the 2009 EIR related to mineral resources have not occurred. a,b. Impacts related to mineral resources were evaluated in Chapter 3.9, Impacts Not Potentially Significant, of the 2009 EIR. As discussed therein, mineral resources of value to the region and the residents of the state have not been identified at the Planning Area.

Additionally, the Planning Area has not been delineated as a locally important mineral recovery site. Therefore, the 2009 EIR concluded that no impacts related mineral resources would occur.

As noted above, known mineral resources are not located in the Planning Area, which includes the project site. Therefore, implementation of the proposed project would not result in the loss of availability of a known mineral resource or of a locally important mineral resource recovery site.

Based on the above information, the proposed project would not result in new significant impacts or substantially more severe significant impacts related to the loss of availability of a known mineral resource that would be of value to the region and the residents of the State or the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan beyond what were previously identified in the preceding environmental document.

Conclusion
Based on the above and in accordance with Section 15162 of the CEQA Guidelines, the 180 El Camino Real/Steelwave Project would not result in any changes, new circumstances, or new information that would involve new significant impacts or substantially more severe significant impacts from what had been anticipated for the project site in the previous CEQA document related to mineral resources.

Mitigation Measure(s)
The proposed project would not require any mitigation related to mineral resources.

Mitigation Measures from the Previous CEQA Document
None required in the 2009 EIR.
180 El Camino Real/Steelwave Project
Addendum

August 2022
Additional Project-Specific Mitigation Measures
None required.
180 El Camino Real/Steelwave Project
Addendum

August 2022
XIII. NOISE.

Would the project result in: Where Impact
Was Analyzed
in 2009 EIR?
Do Proposed
Changes Involve
New or More
Severe
Impacts?
Any New
Circumstances
Involving New or
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
a. Generation of a substantial temporary
or permanent increase in ambient noise
levels in the vicinity of the project in
excess of standards established in the
local general plan or noise ordinance, or
applicable standards of other agencies?

3.2-15 to

3.2-17 No No Yes
b. Generation of excessive groundborne
vibration or groundborne noise levels? 3.2-20 No No Yes c. For a project located within the vicinity of
a private airstrip or an airport land use
plan or, where such a plan has not been
adopted, within two miles of a public
airport or public use airport, would the
project expose people residing or
working in the project area to excessive
noise levels?

3.2-17 to

3.2-18 No No Yes
Discussion
Since the release of the 2009 EIR, substantial changes to the project site have not occurred.

Substantial changes in the environmental and regulatory settings related to noise, or in circumstances that would affect the analysis in the 2009 EIR related to noise, have not occurred.

Project changes or circumstances that would adversely affect the analysis in the 2009 EIR related to noise have not occurred.
a. The following terms are referenced in the sections below:
• Decibel (dB): A unit of sound energy intensity. An A-weighted decibel (dBA) is a decibel corrected for the variation in frequency response to the typical human ear at commonly encountered noise levels. All references to dB in this report will be Aweighted unless noted otherwise. • Day-Night Average Level (Ldn): The average sound level over a 24-hour day, with a +10 decibel weighting applied to noise occurring during nighttime (10:00 PM to 7:00 AM) hours.
• Community Noise Equivalent Level (CNEL): The cumulative noise exposure over a 24-hour period. Weighting factors of +5 and +10 dBA are applied to the evening and nighttime periods, respectively, to account for the greater sensitivity of people to noise during those periods.
• Equivalent Sound Level (Leq): The average sound level over a given time-period. • Maximum Sound Level (Lmax): The maximum sound level over a given time-period. • Median Sound Level (L50): The sound level exceeded 50 percent of the time over a given time-period.

The 2009 EIR evaluated the potential for the South El Camino Real GPA Project to 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 under Impacts 3.2-1 and 3.2-

2. As discussed under Impact 3.2-1, ambient noise levels may temporarily increase during construction of projects in the Planning Area. However, the 2009 EIR determines that 180 El Camino Real/Steelwave Project
Addendum

August 2022
compliance with the limitations on construction activities and with the applicable noise standards established in the SSFMC would ensure that construction noise impacts remain less than significant. Impact 3.2-2 focuses on impacts associated with a permanent increase in ambient noise along El Camino Real associated with buildout of the South El Camino Real GPA Project. The 2009 EIR concluded that, because traffic noise along El Camino Real is expected to increase by less than three dB, the impact would be less than significant.

The noise environment in the project site vicinity is primarily defined by commercial aircraft overflights from SFO, and from vehicular traffic along El Camino Real and South Spruce Avenue. As part of the Technical Noise Study (Appendix F) prepared for the proposed project, noise measurements were conducted to quantify the existing noise environment.41 The measurements consisted of three long-term, 48-hour, measurements (Locations LT1, LT-2, and LT-3) and five short-term, 15 minute, measurements (Location ST-1 to ST5). The results of the short-term noise measurements are presented in Table 8.

Table 8
Short-Term Noise Measurement Results
Site Location Time Leq L50 CNEL
ST-1
Rockwood Drive &
Manor Drive,
5 feet above ground
4:03 PM –
4:19 PM
66 55 68
ST-2 Francisco Drive,
5 feet above ground
4:30 PM –
4:45 PM
65 54 68
ST-3
Setback of homes from
South Spruce Avenue,
5 feet above ground
4:49 PM –
5:04 PM
62 60 67
ST-4
Parking Lot along
Huntington Avenue,
5 feet above ground
5:36 PM –
5:51 PM
57 56 61
ST-5
Back of Golf Mart (470
Noor Avenue),
5 feet above ground
5:14 PM –
5:29 PM
60 58 64
Source: RGD Acoustics, 2022.

Construction Noise
Noise from demolition and construction activities would add to the noise environment in the project vicinity. The SSFMC established allowable construction hours, provided that noise from individual equipment does not exceed 90 dBA at 25 feet, and the noise at any point outside the property plane does not exceed 90 dBA. Typical noise levels for the construction equipment that is expected to be used for the project are presented in Table

9. Noise levels that would exceed the City’s noise ordinance criteria of 90 dBA at 25 feet are presented in gray. As presented in the table, certain pieces of construction equipment, such as a concrete saw, grader, concrete pump, and jackhammer, are calculated to exceed the noise ordinance limit of 90 dBA at a distance of 25 feet. 41 RGD Acoustics. Technical Noise Study For: 180 El Camino Real South San Francisco RGD Project #: 22-009.

July 12, 2022.
180 El Camino Real/Steelwave Project
Addendum

August 2022
Table 9
Construction Equipment Noise Levels
Construction Equipment
Reference Noise
Level at 50 feet
(dBA)
Calculated Noise
Level at 25 feet
(dBA)
Concrete/industrial saws 90 96
Excavators 81 87
Rubber Tired Dozers 82 88
Loaders 79 85
Graders 85 91
Backhoe 78 84
Compactor 83 89
Cranes 81 87
Man Lifts 75 81
Air Compressors 78 84
Concrete Pumps 90 96
Generator Sets 81 87
Welders 74 80
Pavers 77 83
Jackhammer 89 95
Rollers 80 86
Delivery Truck 74 80
Concrete Mixer Truck 79 85
Notes: Noise levels that would exceed the applicable nighttime L50 standards are presented in gray.

Source: FHWA, Roadway Construction Noise Model, 2006.

Furthermore, because the proposed buildings would be located within 50 feet of the property line, the use of certain pieces of construction equipment may generate noise levels that exceed 90 dBA at the property plane.

Table 10 has been included to disclose the calculated maximum instantaneous exterior noise levels from project-related construction equipment at the nearby land uses. The calculated exterior noise levels are based on the distances between the neighboring buildings and the nearest project building footprint where most construction activities are expected to occur using a factor of six dB per doubling of distance.

When construction equipment is operating near the middle of the site, the noise levels in Table 10 would reduce by 8 to 16 dBA (about half as loud) due to the additional distance between the equipment and receiver. Additionally, once the building exterior is completed, the project buildings will also provide some acoustical shielding and reduce construction noise to the neighboring receivers.

In summary, project construction activities could generate temporary noise levels in excess of the City’s noise standards.
180 El Camino Real/Steelwave Project
Addendum

August 2022
Table 10
Construction Equipment Noise Levels at Nearby Land Uses Construction
Equipment
Noise Level (Lmax), dBA
Single-Family
Residential to
the North
– 110 feet
Future Retail to
the North
– 57 feet
Single-Family
Residential to
the West –
140 feet
Existing
Commercial to
the South –
65 feet
Existing
Offices to the
Northeast
– 85 feet
Future MultiFamily Residential
to the East
– 70 feet
Concrete/Industrial saws 83 89 81 88 85 87
Excavators 74 80 72 79 76 78
Rubber Tired Dozers 75 81 73 80 77 79
Loaders 72 78 70 77 74 76
Graders 78 84 76 83 80 82
Backhoe 71 77 69 76 73 75
Compactor 76 82 74 81 78 80
Cranes 74 80 72 79 76 78
Forklifts 78 84 76 83 80 82
Scissorlifts 68 74 66 73 70 72
Air Compressors 71 77 69 76 73 75
Concrete Pumps 83 89 81 88 85 87
Generator Sets 74 80 72 79 76 78
Welders 67 73 65 72 69 71
Pavers 70 76 68 75 72 74
Jackhammer 82 88 80 87 84 86
Rollers 73 79 71 78 75 77
Delivery Truck 67 73 65 72 69 71
Concrete Mixer Truck 72 78 70 77 74 76
Source: RGD Acoustics, 2022.
180 El Camino Real/Steelwave Project
Addendum

August 2022
However, construction of similar uses is planned throughout the Planning Area, for which the 2009 EIR, under Impact 3.2-1, determined temporary construction noise would be less-than-significant due to compliance with the City’s construction noise standards established in the SSFMC (Section 8.32.050).42 The proposed project would also be required to comply with the City’s construction noise standards, and there is nothing atypical about the proposed on-site construction, when compared to other planned ECRMX uses within the Planning Area. Thus, no new significant impacts would occur as a result of the project’s construction, nor would a previously identified significant impact be subject to a substantial increase in severity.

The City would require compliance with the City’s construction noise standards as a project condition of approval through means including, but not limited to, the following construction noise reduction measures:
• All construction equipment shall be equipped with mufflers and sound control devices (e.g., intake silencers and noise shrouds) that are in good condition and appropriate for the equipment.
• Maintain all construction equipment to minimize noise emissions. • Stationary equipment shall be located on the site to maintain the greatest possible distance to the adjacent hotel and restaurant, where feasible. • Unnecessary idling of internal combustion engines should be strictly prohibited. • Provide advance notification to surrounding land uses disclosing the construction schedule, including the various types of activities that would be occurring throughout the duration of the construction period.
• The construction contractor shall provide the name and telephone number an onsite construction liaison. If construction noise is found to be intrusive to the community (complaints are received), the construction liaison shall investigate the source of the noise and require that reasonable measures be implemented to correct the problem.
• Schedule high noise-producing activities during times when they would be least likely to interfere with the noise sensitive activities of the neighboring land uses, when possible.

Operational Noise
The primary sources of operational noise associated with the proposed project would be from project-generated vehicular traffic, the proposed parking garage, loading dock activity, and mechanical equipment noise. The foregoing noise sources are discussed separately below.

Traffic Noise
For the purposes of this analysis, project-specific traffic volumes provided by Fehr & Peers were evaluated for associated noise levels under the Existing, Existing Plus Project, Cumulative, and Cumulative Plus Project scenarios. Refer to Section XVIII, Transportation, for additional information regarding each modeling scenario.

Neither CEQA nor the City’s General Plan specify a quantitative method for determining whether a project would cause a significant increase in noise. However, consistent with 42 City of South San Francisco. South El Camino Real General Plan Amendment Environmental Impact Report SCH# 2009062070 [pg 3.2-18]. November 2009.
180 El Camino Real/Steelwave Project
Addendum

August 2022
other CEQA documents in the City, and based on the General Plan’s Land Use Criteria for Noise-Impacted Areas (Table 9.2-1),43 for the purpose of this analysis, an increase in traffic noise is considered significant when:
• Increase of five dBA or greater, if future noise level is within the “Satisfactory” range according to the City’s Land Use Criteria table; or
• Increase of three dBA or greater, if future noise level is above the “Satisfactory” range according to the City’s Land Use Criteria table.

For the purposes of this analysis, the project’s contribution to future traffic noise is considered cumulatively considerable if the future increase in traffic noise due to the project is greater than 1 dBA, and as follows:
• Cumulative increase of five dBA or greater, if future noise level is within the “Satisfactory” range according to the City’s Land Use Criteria table; 44 or
• Cumulative increase of three dBA or greater, if future noise level is above the “Satisfactory” range according to the City’s Land Use Criteria table.

Table 11 presents the increase in traffic noise associated with the project under Existing Plus Project and Cumulative Plus Project conditions, as calculated using the Federal Highway Administration’s Traffic Noise Model. As presented in Table 11, implementation of the project would result in an increase in existing traffic noise levels by less than 1 dBA along the roadways in the project area. Therefore, the increase in traffic noise levels would not exceed the three dB threshold of significance. Additionally, the project’s contribution to the cumulative increase in traffic noise would be 0.2 dBA or less, which would not exceed the cumulatively considerable threshold of 1 dBA.

Parking Structure Noise
According to the project-specific transportation analysis, operations of the project would generate 774 total trips during the AM peak hour and 728 total trips during the PM peak hour. The Traffic Noise Model (TNM 2.5) module was used to model cars traveling to the inside of the parking structure. The model included vehicles scattered throughout the seven-story parking structure given that it was assumed that not all of the vehicles would park on the ground floor.

Because the noise associated with cars traveling in the parking structure is expected to occur for a cumulative period of more than 30 minutes in the peak hour, the L50 noise standard is used to assess the noise from cars traveling in the parking structure. According to SSFMC Table 8.32.030, the L50 standard is 60 dBA during daytime hours (7:00 AM to 10:00 PM) and 55 dBA during nighttime hours (10:00 PM to 7:00 AM). 45 43 City of South San Francisco. South San Francisco General Plan Noise Element [Table 9.2-1]. October 1999. 44 Ibid. 45 According to the SSFMC, maximum permissible sound levels from the project are determined by the land use category, as defined by the zoning district, of the receiving property, as presented in SSFMC Table 8.32.030.

These levels must not be exceed when measured at neighboring properties (i.e., at property lines). If the measured ambient noise level for any area is higher than the base noise level standard, the base noise level standard is adjusted upwards to match the ambient.
180 El Camino Real/Steelwave Project
Addendum

August 2022
Table 11
Existing Traffic Noise Increase with Project
Roadway Segment
Traffic CNEL at 50 feet, dBA
Existing
Existing
Plus Project Increase Cumulative
Cumulative
Plus Project Increase
South Spruce Avenue El Camino Real – Huntington Avenue 65.9 66.1 0.1 66.6 66.7 0.1 Huntington Avenue South Spruce – Noor Avenue 66.5 67.0 0.5 70.2 70.4 0.2 El Camino Real South Spruce – Noor Avenue 72.5 72.6 0.1 73.2 73.3 0.1 Source: RGD Acoustics, 2022.
180 El Camino Real/Steelwave Project
Addendum

August 2022
The closest sensitive receptor to the proposed parking structure is a proposed housing development to the east, located at 410 Noor Avenue.46 The calculated noise level at 410 Noor Avenue is a peak hour Leq of up to 63 dBA. The calculated noise level was adjusted upward by three dBA to account for acoustical reflections. Because the AM and PM peak traffic hours are expected to occur during “daytime” hours, the “daytime” L50 noise standard of 60 dBA is used to assess the parking structure noise impact. The calculated parking structure noise of 63 dBA would exceed the daytime L50 standard of 60 dBA. Therefore, Mitigation Measure XVIII-1 is required to ensure that impacts are reduced to a less-thansignificant level.

Loading Dock Noise
The proposed project would include operations of a loading dock between R&D Buildings 1 and 3 with access from the south interior street, and a loading dock between R&D Building 2 and the proposed parking structure. Loading would be allowed 24 hours per day, subject to approval of a CUP.

Noise associated with loading docks was modeled using SoundPLAN, which provided noise levels for truck brake air release, truck engines, and loading activities. Each noise source would occur briefly and, therefore, are compared to the City’s standards for noises occurring for less than one minute in an hour. Because the nearest neighboring land uses are all zoned ECRMX, the daytime and nighttime noise level limits are Lmax 75 dBA and 80 dBA, respectively. The limits include a 20 dBA upward adjustment, consistent with SSFMC Section 8.32.030.a.5. Table 12 shows the calculated noise levels from the loading dock noise at the nearest receivers

Table 12
Calculated Loading Dock Noise
Receiver
Loading Dock Noise Sources (dBA)
Truck Brake Air
Release Truck Engine
Loading
Activities
North of Building 2 Loading Dock
(Retail) 771 72 71
South of Building 1 and 3 Loading
Dock (Retail Commercial) 74 72 73
Notes: Noise levels that would exceed the applicable standards are presented in gray. 1 As previously discussed, CEQA Guidelines Section 15125(a)(1) generally directs the lead agency to describe the physical environmental conditions as they exist at the time environmental analysis is commenced, from both a local and regional perspective. At the time of commencement of this environmental analysis, the Safeway retail project has not yet been developed, though it is under construction. Therefore, technically, this noise analysis is not required to evaluate the project’s operational noise impacts upon the approved Safeway retail project. However, given that the Safeway retail project is anticipated to be built by the time the proposed project is operational, this noise analysis conservatively evaluates the proposed project’s effects on the Safeway retail project.

Source: RGD Acoustics, 2022.
46 According to CEQA Guidelines Section 15125(a)(1), “Generally, the lead agency should describe physical environmental conditions as they exist at the time the notice of preparation is published, or if no notice of preparation is published, at the time environmental analysis is commenced, from both a local and regional perspective.” At the time of commencement of this environmental analysis, the 410 Noor Avenue residential project has not yet been constructed. Therefore, technically, this noise analysis is not required to evaluate the project’s operational noise impacts upon the approved 410 Noor Avenue project. However, given that the 410 Noor Avenue project is anticipated to be built by the time the proposed project is operational, this noise analysis conservatively evaluates the proposed project’s effects on the 410 Noor Avenue project. 180 El Camino Real/Steelwave Project
Addendum

August 2022
Noise levels exceeding the nighttime standard are presented in gray. As shown in the table, truck engine and loading activities would not generate noise that exceeds the applicable standards. The noise from truck brake air release was calculated to meet the daytime noise standard of 80 dBA, but would exceed the nighttime noise standard of 75 dBA at the proposed Building 2 loading dock. Therefore, Mitigation Measure XVIII-1 is required to ensure that impacts are reduced to a less-than-significant level.

Mechanical Equipment Noise
For this analysis, noise from mechanical equipment was assessed against the most restrictive nighttime noise standard at each of the nearest receivers. The measured ambient noise level from the long-term monitoring locations was adjusted based on the distance from the roadway. Additional detail regarding calculating the appropriate threshold of significance is available in the Technical Noise Study included as Appendix F to this Addendum.

The proposed R&D buildings would include rooftop equipment such as cooling towers, air handling units (AHUs), laboratory exhaust fans, and pumps. The multi-family residential building would also include mechanical equipment associated with building ventilation, such as outdoor heat pumps.

Based on preliminary data available for the proposed AHUs, lab exhaust fans, and cooler towers, operational noise levels were calculated at the neighboring properties. The site plans indicate that the R&D buildings would include a mechanical screen on the rooftop; however, because the mechanical screen design has not been finalized (material, height, and whether the screen is solid/open), noise levels have been calculated both with and without a solid rooftop noise barrier. The condensing unit model for the residential building has not yet been determined; thus, the Technical Noise Study analyzed the residential rooftop noise using data from another similar project which used heat pumps by Carrier (CH16NA series).

Table 13 presents the calculated preliminary rooftop mechanical equipment noise levels at the neighboring land uses, both with and without a solid rooftop mechanical screen barrier, in comparison to the applicable nighttime noise standards at each receiving land use. Noise levels exceeding the nighttime L50 standard are presented in gray. As presented in the table, mechanical equipment noise may exceed the applicable nighttime noise limits and, as a result, Mitigation Measure XVIII-1 is required to ensure that impacts are reduced to a less-than-significant level.

Conclusion
Based on the above, given compliance with City regulations, construction of the proposed project would not generate a substantial temporary increase in ambient noise in excess of City standards. In addition, noise from project-generated traffic, during both Existing Plus Project and Cumulative Plus Project scenarios, would not exceed the applicable thresholds of significance. However, this noise analysis, which has used best available data for the proposed project’s design and operational details, estimates that operational noise associated with the proposed parking garage, loading docks, and mechanical equipment could exceed the applicable noise standards at those neighboring properties, as identified in Table 12 and Table 13.
180 El Camino Real/Steelwave Project
Addendum

August 2022
Table 13
Preliminary Mechanical Equipment Noise Levels
Neighboring Land Uses Zoning District
Applicable
Nighttime L50
Standard (dBA)
Without Solid
Rooftop Barrier
(dBA)
With Solid
Rooftop Barrier
(dBA)
East
410 Noor Avenue – Building A
(Multi-Family Residential) 1 ECRMX 55 59 54
1477 Huntington Avenue
(Proposed Multi-Family Residential)1 BC 552 58 56
1486 Huntington Avenue
(Existing Office Building) ECRMX 55 53 50
Southeast 410 Noor Avenue – Building B
(Multi-Family Residential) 1 ECRMX 55 62 57
South 470 Noor Avenue
(Existing Commercial) ECRMX 55 64 57
West Single-family homes along
El Camino Real RL-8 51 61 55
North
Single-family homes along
Francisco Drive RL-8 50 57 55
180 El Camino Real – Safeway
(Retail/Commercial)1 ECRMX 55 65 59
Notes: Noise levels that would exceed the applicable nighttime L50 standards are presented in gray. 1 As previously discussed, CEQA Guidelines Section 15125(a)(1) generally directs the lead agency to describe the physical environmental conditions as they exist at the time environmental analysis is commenced, from both a local and regional perspective. At the time of commencement of this environmental analysis, neither the Safeway retail project, 410 Noor Avenue project, nor the 1477 Huntington Avenue projects have not yet been developed. Therefore, technically, this noise analysis is not required to evaluate the project’s operational noise impacts upon these pending (1477 Huntington Avenue), approved (410 Noor Avenue), and under construction (Safeway retail) projects. However, given that these projects are anticipated to be built by the time the proposed project is operational, this noise analysis conservatively evaluates the proposed project’s effects on said projects. 2 The current zoning designation at 1477 Huntington Avenue is BC. However, if the proposed multi-family residential development is approved, then the zoning designation would be changed as part of the process. For the purpose of this analysis, the noise standard for the ECRMX district was used.

Source: RGD Acoustics, 2022.
180 El Camino Real/Steelwave Project
Addendum

August 2022
Accordingly, Mitigation Measure XVIII-1 is hereby incorporated as part of the proposed project, and would require the applicant to implement noise reduction measures consistent with those recommended by the acoustical engineer if the follow-up acoustic analysis indicates that the applicable noise level standards would be exceeded. Implementation of Mitigation Measure XVIII-1 would ensure that the potential impacts associated with the proposed parking garage, loading docks, and mechanical equipment are reduced to lessthan-significant levels.

Overall, with the implementation of Mitigation Measure XIII-1 (discussed in the Mitigation Measure(s) section below), impacts related to the generation of a substantial permanent increase in ambient noise levels in the vicinity of the project would not occur, consistent with the conclusions presented in the 2009 EIR. Thus, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to 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 beyond what were previously identified in the 2009 EIR. b. The 2009 EIR evaluated the potential for the project to generate excessive groundborne vibration or groundborne noise levels under Impact 3.2-4 and concluded that the project would result in a less-than-significant impact. As noted in the 2009 EIR, vibration could occur as a result of construction activities, or during operations of industrial uses or railways. Heavy industrial uses or railways would not occur in the Planning Area, and construction would be temporary in nature. Additionally, the 2009 EIR notes that future projects would require project-level CEQA analysis wherein specific impacts related to groundborne vibration would be evaluated. Accordingly, the project-specific analysis related to the proposed project’s potential to generate groundborne vibration is included below.

Operations of the proposed R&D and residential land uses are not anticipated to generate substantial groundborne vibration. Rather, the primary vibration-generating activities associated with the proposed project would occur during construction. Table 14 presents the calculated construction vibration levels that would occur at the nearest sensitive receptors.

As noted in the Technical Noise Study prepared for the proposed project, neither CEQA nor the City of South San Francisco specifies acceptable vibration levels from construction activities. Therefore, for the purposes of this assessment, the guideline criteria for building damage recommended by Caltrans is used. The construction vibration damage criteria is a Peak Particle Velocity (PPV) of 0.5 inches/second (in/sec) for new residential structures and modern industrial/commercial buildings. Based on the data presented in Table 14, construction vibration levels would not exceed the building damage threshold of 0.5 in/sec PPV.

Based on the above, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to the generation of excessive groundborne vibration or groundborne noise levels beyond what were previously identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR.
180 El Camino Real/Steelwave Project
Addendum

August 2022
c. As noted previously, the project site is located approximately 1.7 miles northwest of SFO.

The 2009 EIR includes a discussion of airport noise of sensitive receptors under Impact

3.2-3. As noted therein, the majority of the Planning Area is located within the CNEL 65 dB contour. Thus, the following policy included as part of the South El Camino Real GPA Project would ensure that sensitive receptors are not exposed to excessive noise:
• Policy 9-I-4: Ensure that project applications for all new noise-sensitive land uses (plans and specifications), including hospitals and residential units proposed within the CNEL 60 dB to CNEL 69 dB aircraft noise contour include an acoustical study, prepared by a professional acoustic engineer, that specifies the appropriate noise mitigation features to be included in the design and construction of these uses, to achieve an interior noise level of not more than CNEL 45 dB in any habitable room, based on the latest official SFIA noise contours and on-site measurement data.

The 2009 EIR determined that compliance with the foregoing policy, among other standard regulations, would ensure that a less-than-significant impact related to exposing sensitive receptors to excessive noise from airports would occur.

The proposed R&D uses are not considered a noise-sensitive use. Therefore, the following discussion focuses on the proposed multi-family residential land use.

The effect of airport noise on future residents is outside of the scope of CEQA as it concerns the effects of the environment on a project, rather than the effects of a project Table 14
Calculated Vibration Levels from Construction
Equipment
PPV (in/sec)
Commercial
Buildings to the
South
Office Building to
the Northeast
Future Retail to
the North
Multi-Family
Residential
Buildings
25 feet to
Project
Boundary
32 feet to Project
Boundary
19 feet to
Project
Boundary
28 feet to
Project
Boundary
Pile Driver
(Upper range) 0.36 0.43 0.44 0.41
Pile Driver
(Typical) 0.15 0.18 0.19 0.17
Vibratory
Roller 0.21 0.15 0.32 0.18
Hoe Ram 0.09 0.06 0.13 0.08
Large
Bulldozer 0.09 0.06 0.13 0.08
Caisson
Drilling 0.09 0.06 0.13 0.08
Loaded
Trucks 0.08 0.05 0.11 0.06
Jackhammer 0.04 0.02 0.05 0.03
Small
Bulldozer < 0.01 < 0.01 < 0.01 < 0.01
Source: RGD Acoustics, 2022.
180 El Camino Real/Steelwave Project
Addendum

August 2022
on the environment.
47 Notwithstanding, the following discussion is provided for informational purposes.

As disclosed in the 2009 EIR, airport operations and engine technology are constantly changing and, as a result, the applicable Noise Contours are often revised and are anticipated to move away from the Planning Area over time (see 2009 EIR pg. 9-2). In addition, specific construction techniques are feasible to reduce interior noise to CNEL 45 dB or less. As shown within the 2012 ALUCP, the project site is located within the 70 dB noise contour. Accordingly, the ALUC has found that the proposed project is not consistent with the Noise Policies of the SFO ALUCP.
48 As a result, to approve the project, the City
Council would be required to override the ALUC determination in accordance with Public Utilities Code Sections 21676 and 21676.5.

In support of the override, it is noted that updated noise data has been provided in a sitespecific ALUC Environmental Noise Analysis prepared by Charles M. Salter Associates (see Appendix E). According to the ALUC Environmental Noise Analysis, 2019 noise data indicates that the project site is currently within the 65-70 dB contour, which the ALUCP identifies as conditionally compatible for residential development. The ALUC Environmental Noise Analysis includes recommendations that would ensure indoor noise levels of CNEL 45 dB or less, consistent with the ALUCP Infill Criteria and consistent with the intent of General Plan Policy 9-I-11, of ensuring the protection of public health, safety and welfare.

Specifically, the City will require the following conditions of approval to ensure that the project meets the requirements of the Code criterion of CNEL 45 dB inside residences:49 • Rooms along Spruce: Sound Transmission Class (STC) ratings up to 43; • Rooms along the east and west facades: STC ratings up to 38; and • Rooms along the south façade: STC ratings up to 35.

The recommended STC ratings are for full window assemblies (glass and frame) rather than just the glass itself. Tested sound-rated assemblies should be used. For reference, typical construction-grade assemblies achieve an STC rating of 28. Where STC ratings above 32 are required, at least one pane will need to be laminated. STC ratings above 38 typically require insulated glass unit (IGU) greater than one-inch thick. This will vary depending on the window manufacturer. Because the windows need to be closed to 47 “[T]he purpose of an EIR is to identify the significant effects of a project on the environment, not the significant effects of the environment on the project.” (Ballona Wetlands Land Trust v. Town of Los Angeles, (2011) 201 Cal.App.4th 455, 473 (Ballona).) The California Supreme Court recently held that “CEQA does not generally require an agency to consider the effects of existing environmental conditions on a proposed project’s future users or residents. What CEQA does mandate… is an analysis of how a project might exacerbate existing environmental hazards.” (California Building Industry Assn. v. Bay Area Air Quality Management Dist. (2015) 62 Cal.4th 369, 392; see also Mission Bay Alliance v. Office of Community Investment & Infrastructure (2016) 6 Cal.App.5th 160, 197 [“identifying the effects on the project and its users of locating the project in a particular environmental setting is neither consistent with CEQA's legislative purpose nor required by the CEQA statutes”], quoting Ballona, supra, 201 Cal.App.4th at p. 474.) In the case of the proposed project, the impact of placing future residents within an area subjected to noise from the airport is considered an existing environmental condition that would affect future users/residents. 48 City/County Association of Governments of San Mateo County. Airport Land Use Committee (ALUC) Agenda [pg 81]. June 23, 2022. 49 It is noted that the calculations conducted by Charles M. Salter Associates were based on preliminary site drawings dated January 6, 2022.
180 El Camino Real/Steelwave Project
Addendum

August 2022
achieve an indoor Ldn of 45 dB, an alternative method of supplying fresh air (e.g., mechanical ventilation) should be provided.

Conclusion
Based on the above and in accordance with Section 15162 of the CEQA Guidelines, with the implementation of mitigation, the 180 El Camino Real/Steelwave Project would not result in any changes, new circumstances, or new information that would involve new significant impacts or substantially more severe significant impacts from what had been anticipated for the project site in the previous CEQA document related to noise.

Mitigation Measure(s)
The 2009 EIR did not include any mitigation measures related to noise. However, project-specific Mitigation Measure XIII-1 is hereby required as part of the project. Based on CEQA Guidelines Section 15162(a)(D), an SEIR would be required where new or modified mitigation measures from those included in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponent declines to adopt the mitigation measures.

Mitigation Measure XVIII-1 set forth below would be sufficient to reduce the impacts related to operational noise from the proposed parking garage, loading docks, and mechanical equipment to less-than-significant levels. In addition, the project applicant has agreed to implement the additional project-specific mitigation measure identified in this Addendum. Therefore, preparation of an SEIR pursuant to CEQA Guidelines Section 15162 is not required, and an Addendum pursuant to CEQA Guidelines Section 15164 remains the appropriate environmental document for the proposed project.

Mitigation Measures from the Previous CEQA Document
None required in the 2009 EIR.

Additional Project-Specific Mitigation Measures
Project-specific Mitigation Measure XIII-1 is required to ensure that impacts related to operational noise from the proposed parking garage, loading docks, and mechanical equipment, are reduced to less-than-significant levels.

XVIII-1 In conjunction with submittal of improvement plans, the project applicant shall submit a design-level acoustical analysis for the proposed project’s operational noise sources for review and approval by the City of South San Francisco. The acoustical report shall include:

1. A detailed analysis of noise from the project’s final mechanical equipment system design to confirm that the noise from mechanical equipment will comply with the SSFMC requirements. If the project would comply with the applicable standards, further mitigation shall not be required. If the project would not comply with the applicable standards, the qualified acoustical engineer shall submit recommended measures sufficient to reduce mechanical noise to a level below the applicable SSFMC standards, and said recommendations shall be incorporated into the project improvement plans. Measures could include modified parapet design and/or selection of different mechanical equipment.

2. A detailed analysis of noise from the project’s parking structure design to confirm that noise from the parking structure will comply with the SSFMC requirements. If the project would comply with the applicable standards, 180 El Camino Real/Steelwave Project
Addendum

August 2022
further mitigation shall not be required. If the project would not comply with the applicable standards, measures recommended by the acoustical consultant shall be incorporated into the project improvement plans to reduce noise levels below the applicable SSFMC standards. Measures could include solid exterior walls along the east and south elevations of the parking structure to reduce sound transfer to adjoining land uses.

3. A detailed analysis of noise from the project’s loading docks to confirm that noise from loading dock activities will comply with the SSFMC requirements. If the project would comply with the applicable standards, further mitigation shall not be required. If the project would not comply with the applicable standards, measures recommended by the acoustical consultant shall be incorporated into the project improvement plans to reduce noise levels below the appliable SSFMC standards. Measures could include a loading dock enclosure, property line noise barrier at the YMCA, or limiting the hours of use to daytime only (7:00 AM to 10:00 PM).

Proof of implementation of the foregoing measures shall be submitted to the City of South San Francisco Planning Department for review and approval. 180 El Camino Real/Steelwave Project
Addendum

August 2022
XIV. POPULATION AND
HOUSING.

Would the project:

Where Impact
Was Analyzed
in 2009 EIR?
Do Proposed
Changes
Involve New or
More Severe
Impacts?
Any New
Circumstances
Involving New
or More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
a. Induce substantial unplanned population
growth in an area, either directly (for
example, by proposing new homes and
businesses) or indirectly (e.g., through
projects in an undeveloped area or
extension of major infrastructure)?
5-1 to 5-2 No No No
b. Displace substantial numbers of existing
people or housing, necessitating the
construction of replacement housing
elsewhere?

3.8-7 to

3.8-8 No No No
Discussion
Since the release of the 2009 EIR, substantial changes to the project site have not occurred. In addition, substantial changes in the environmental and regulatory settings related to population and housing, as described in the 2009 EIR, have not occurred. Project changes or circumstances that would adversely affect the analysis in the EIR related to population and housing have not occurred.
a,b. The 2009 EIR generally discussed population growth in Chapter 5, CEQA Required Conclusions. As noted therein, the population growth that could occur under the South El Camino Real GPA Project would be less than one percent greater than the population growth forecasted for the City by ABAG. In addition, the 2009 EIR notes that the South El Camino Real GPA Project would accommodate slightly more population and job growth than under the previous General Plan, but the additional growth would occur through development densification and intensification rather than by expanding outward, which is consistent with the smart growth goals of ABAG. In addition, the 2009 EIR evaluated impacts related to displacing people or housing under Impact 3.8-2, and determined that a less-than-significant impact would occur because the overall South El Camino Real GPA Project would significantly increase the number of dwelling units in the Planning Area.

The 2009 EIR assumed buildout of the Planning Area with an additional 840 housing units, as compared to what was allowed under the 1999 General Plan. The proposed project would include the development of 183 multi-family residential units. The development of 183 residential units and the associated population increase was already included in the buildout assumptions used in the 2009 EIR, and new conditions that would affect the conclusions presented in the 2009 EIR do not exist.

The inclusion of 183 units of on-site housing will further help ensure that adequate housing is available for the project’s employees within the City of South San Francisco. The inclusion of residential uses on the project site would also provide opportunities to internalize a greater portion of project-related travel within the project site, particularly for trips between the project’s residential and commercial components.

The resulting effect would be less vehicle travel activity in the City when compared to a scenario where the proposed residential component would be constructed off-site (e.g., the construction of 183 dwelling units elsewhere in City or in other communities in the greater Bay Area region). Reduced VMT also translates into reduction of GHG emissions.

The 2009 EIR also assumed that buildout of the Planning Area would include 700 jobs. Using the same proportion of non-residential square footage to jobs as presented in the
180 El Camino Real/Steelwave Project
Addendum

August 2022
2009 EIR, the square footage associated with the proposed project could generate up to 2,142 jobs, or 1,442 net new jobs beyond what was planned for in the 2009 EIR. The increase in jobs could indirectly influence population growth in the region. However, this increase is within the 114,000-job employment growth projected to occur within San Mateo County in the Plan Bay Area 2050.50 As a result, the population growth would not be considered unplanned.

Based on the above, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts related to population and housing beyond what were previously identified in the preceding environmental documents.

Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR.

Conclusion
Based on the above and in accordance with Section 15162 of the CEQA Guidelines, the 180 El Camino Real/Steelwave Project would not result in any changes, new circumstances, or new information that would involve new significant impacts or substantially more severe significant impacts from what had been anticipated for the project site in the previous CEQA document related to population and housing.

Mitigation Measure(s)
The proposed project would not require mitigation related to population and housing.

Mitigation Measures from the Previous CEQA Document
None required in the 2009 EIR.

Additional Project-Specific Mitigation Measures
None required.
50 Association of Bay Area Governments and Metropolitan Transportation Commission. Forecasting and Modeling Report, Appendix 1: Growth Pattern. October 2021.
180 El Camino Real/Steelwave Project
Addendum

August 2022
XV. PUBLIC SERVICES.

Would the project result in substantial adverse
physical impacts associated with the provision
of new or physically altered governmental
facilities, need for new or physically altered
governmental facilities, the construction of
which could cause significant environmental
impacts, in order to maintain acceptable
service ratios, response times or other
performance objectives for any of the public
services:

Where Impact
Was Analyzed
in 2009 EIR?
Do Proposed
Changes
Involve New or
More Severe
Impacts?
Any New
Circumstances
Involving New
or More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
a. Fire protection? 3.5-16 to

3.5-17 No No No
b. Police protection? 3.5-16 to

3.5-17 No No No
c. Schools? 3.5-16 No No No
d. Parks? 3.4-9 No No No
e. Other Public Facilities? N/A No No No
Discussion
Since the release of the 2009 EIR, substantial changes to the project site have not occurred.

Substantial changes in the environmental and regulatory settings related to public services, as described in the 2009 EIR, have not occurred. Project changes or circumstances that would adversely affect the analysis in the 2009 EIR related to public services have not occurred.

Potential impacts related to public services that were addressed in the 2009 EIR and that would result from implementation of the proposed project are discussed below. The residential component of the project has already been considered for development in the Planning Area in the 2009 EIR, and is allowable on the project site. Thus, the following discussion focuses on impacts to public services from the proposed non-residential development.

Fire Protection Services
According to the 2009 EIR, the South San Francisco Fire Department (SSFFD) would be able to meet the current National Fire Protection Association standard of one firefighter per 1,000 residents at full buildout, and new facilities or an expansion of existing facilities would not be required. As a result, the 2009 EIR concluded that less-than-significant impacts related to fire services would occur.

The project site is located within Fire Station Response Area 61, which is serviced by Station 61, located at 480 North Canal Street, approximately 0.5-mile northeast of the site.

As of 2019, SSFFD staff includes 72 full-time equivalent firefighter and emergency medical employees and 19.8 hourly and contract employees.
51 Additionally, as of 2019, the SSFFD
has a current service ratio of 1.1 full-time firefighters and emergency medical personnel per 1,000 residents.

While the additional non-residential square footage and employee population attributable to the proposed project could increase demand for SSFFD equipment and personnel, the relevant CEQA question is whether the project would result in substantial adverse physical 51 City of South San Francisco. South San Francisco General Plan Update: Parks + Public Facilities Existing Conditions Report. November 2019.
a, b, c,
e.
180 El Camino Real/Steelwave Project
Addendum

August 2022
impacts associated with the need for new or physically altered fire facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives. The proposed project would be subject to payment of the Public Safety Impact Fee (Fund 821), which is a fee program intended to fund a new development’s fair share of new or expanded facilities and equipment for fire and police services. Furthermore, the project would include fire protection features, including fire alarm systems, fire extinguisher systems, fire sprinklers, and exit illumination, as required by the California Fire Code, adopted by the City pursuant to SSFMC Section 15.24.010. Because the project would contribute to the City’s Public Safety Impact Fee and would comply with all required fire protection features, the proposed project would not result in the need for new or physically altered fire protection facilities.

Police Protection Services
The 2009 EIR noted that the increase in population resulting from the South El Camino Real GPA Project may increase the demand for police assistance, and an additional four officers, compared to the current General Plan, would be required to maintain a law enforcement standard of 1.5 police officers per 1,000 residents at buildout. However, the 2009 EIR determined that the additional four officers would not require the construction of a new police station, and the continued implementation of General Plan policies would ensure that impacts on police service would be less than significant.

The South San Francisco Police Department (SSFPD) is principally responsible for providing police protection services within the jurisdictional limits of the City. As of 2019, the SSFPD had a total of 118 employees, with 83 sworn officers and 35 civilian positions.52 Additionally, as of 2019, the SSFPD has a current service ratio of 1.2 sworn officers per 1,000 residents, which is below the goal set forth in the General Plan. In 2018-2019, the SSFPD response times to Priority 1 (emergency) calls averaged 3:51 minutes and nonemergency Priority 2 and 3 calls averaged 5:35 and 7:31 minutes, respectively. The SSFPD considers such response times acceptable.53
The increase of non-residential square footage on the project site is not anticipated to result in a substantially increased demand for police protection. In addition, the project applicant would be required to pay the City’s Public Safety Impact Fee for the provision of public services. Therefore, the need for new or physically altered facilities would not be induced by the project.

School Services
As noted in the 2009 EIR, implementation of the South El Camino Real GPA Project is estimated to result in an increase in student population in the South San Francisco Unified School District (SSFUSD) by approximately 60 students, which would increase the projected enrollment to 9,300 students for the year 2022, which is below the 10,701 estimated capacity. Therefore, the SSFUSD is expected to have sufficient capacity to meet demand for school facilities, and the 2009 EIR determined that a less-than-significant impact would occur related to school facilities.
52 Ibid. 53 Ibid.
180 El Camino Real/Steelwave Project
Addendum

August 2022
The project site is within the SSFUSD, which has nine elementary schools, three middle schools, and three high schools, and serves approximately 8,182 students.54 According to the 2017 Municipal Services Assessment, the total SSFUSD capacity is 12,600 students, and the current utilization (as of 2017) is 70.3 percent.

As noted previously, the residential portion of the proposed project, which could directly influence the demand for school services, has already been entirely considered in the 2009 EIR. The increase in non-residential square footage on the project site is not anticipated to affect the demand for schools. Furthermore, the project would be required to pay statutory developer fees under SB 50, payment of which would be used to fund school facilities and accommodate increased demand. Proposition 1A/SB 50 (1999) prohibits local agencies from using the inadequacy of school facilities as a basis for denying or conditioning approvals of any “legislative or adjudicative act involving the planning, use, or development of real property.” (Government Code 65996[b]) Satisfaction of the Proposition 1A/SB 50 statutory requirements by a developer is deemed to be “full and complete mitigation.” (Id.) Therefore, according to SB 50, the payment of the necessary school impact fees for the project would be full and satisfactory CEQA mitigation. As such, consistent with the conclusion presented in the 2009 EIR, the proposed project would not adversely affect schools.

Other Public Facilities
Consistent with the discussions above, the increase in non-residential square footage on the project site is not anticipated to increase the demand for other public facilities. Future employees and visitors of the proposed project would have access to existing public facilities in the project area.

Conclusion
Based on the discussion above, the proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection, police protection, public schools, or other public facilities beyond what were previously identified in the 2009 EIR. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR.
d. Impacts related to parks and recreation are discussed in further detail in Section XVI, Recreation, below. As discussed therein, because the proposed project would include recreational amenities and would be subject to the City’s parkland impact fee, adverse impacts related to parks would not occur, consistent with the conclusion presented in the 2009 EIR.

Conclusion
Based on the above and in accordance with Section 15162 of the CEQA Guidelines, the 180 El Camino Real/Steelwave Project would not result in any changes, new circumstances, or new information that would involve new significant impacts or substantially more severe significant 54 Education Data Partnership. South San Francisco Unified. Available at: http://www.ed-data.org/district/SanMateo/South-San-Francisco-Unified. Accessed July 2022. 180 El Camino Real/Steelwave Project
Addendum

August 2022
impacts from what had been anticipated for the project site in the previous CEQA document related to public services.

Mitigation Measure(s)
The proposed project would not require mitigation related to public services.

Mitigation Measures from the Previous CEQA Document
None required in the 2009 EIR.

Additional Project-Specific Mitigation Measures
None required.
180 El Camino Real/Steelwave Project
Addendum

August 2022
XVI. RECREATION.

Would the project: Where Impact
Was Analyzed
in 2009 EIR?
Do Proposed
Changes
Involve New or
More Severe
Impacts?
Any New
Circumstances
Involving New
or More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
a. Would the project increase the use of
existing neighborhood and regional
parks or other recreational facilities such
that substantial physical deterioration of
the facility would occur or be
accelerated?
N/A No No No
b. Does the project include recreational
facilities or require the construction or
expansion of recreational facilities which
might have an adverse physical effect on
the environment?

3.4-9 No No No
Discussion
Since the release of the 2009 EIR, substantial changes to the project site have not occurred. In addition, substantial changes in the environmental and regulatory settings related to recreation, as described in the 2009 EIR, have not occurred. Project changes or circumstances that would adversely affect the analysis in the EIR related to recreation have not occurred. a,b. The 2009 EIR evaluated impacts related to parkland and recreational facilities under Impacts 3.4-1 and 3.4-2. As discussed therein, impacts would be less-than-significant because the increase in parkland required to achieve the ratio of 3.0 acres per 1,000 residents and 0.5 acre per 1,000 employees would be met through the proposed parkland in and around the Planning Area. As shown in Table 3.4-3 of the 2009 EIR, the proposed parkland in residential areas within one-half mile of the Planning Area totals 33.5 acres, which is adequate to meet the additional 29.5 acres of parkland needed at buildout.

The proposed project would result in development at a greater intensity as compared to what was anticipated to occur in the 2009 EIR. However, pursuant to SSFMC Chapter 8.67, Parks and Recreation Impact Fee, development projects within the City, including multifamily residential and non-residential projects, are subject to payment of a Parkland Acquisition Fee and Park Construction Fee to ensure that funds are available to maintain a desired parkland ratio. In addition, the proposed project would include open space areas and amenities for use by future patrons of the project. The project developer would be required to pay the appropriate Parkland Acquisition Fee and Park Construction Fee.

Based on the above information, the currently proposed project would not result in new significant impacts or substantially more severe significant impacts beyond what were previously identified in the 2009 EIR related to an increase in the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated, or the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment. Therefore, the proposed project would be consistent with the conclusions of the 2009 EIR.

Conclusion
Based on the above and in accordance with Section 15162 of the CEQA Guidelines, the 180 El Camino Real/Steelwave Project would not result in any changes, new circumstances, or new 180 El Camino Real/Steelwave Project
Addendum

August 2022
information that would involve new significant impacts or substantially more severe impacts from what had been anticipated for the project site in the previous CEQA document related to recreation.

Mitigation Measure(s)
The proposed project would not require mitigation related to recreation.

Mitigation Measures from the Previous CEQA Document
None required in the 2009 EIR.

Additional Project-Specific Mitigation Measures
None required.
180 El Camino Real/Steelwave Project
Addendum

August 2022
XVII.TRANSPORTATION.

Would the project: Where Impact
Was Analyzed in
2009 EIR?
Do Proposed
Changes Involve
New or More
Severe Impacts?
Any New
Circumstances
Involving New or
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
a. Conflict with a program, plan,
ordinance, or policy addressing the
circulation system, including transit,
roadway, bicycle, and pedestrian
facilities?

3.1-22 No No Yes
b. Conflict or be inconsistent with CEQA
Guidelines section 15064.3, subdivision
(b)?
N/A No No Yes
c. Substantially increase hazards due to a
geometric design feature (e.g., sharp
curves or dangerous intersections) or
incompatible uses (e.g., farm
equipment)?

3.1-21 No No Yes
d. Result in inadequate emergency
access? 3.1-22 No No Yes
Discussion
The 2009 EIR included a Level of Service (LOS) analysis for several roadway segments and intersections within the Planning Area. However, the law has changed with respect to how transportation-related impacts may be addressed under CEQA. Traditionally, lead agencies used LOS to assess the significance of such impacts, with greater levels of congestion considered to be more significant than lesser levels. Mitigation measures typically took the form of capacityincreasing improvements, which often had their own environmental impacts (e.g., to biological resources). Depending on circumstances, and an agency’s tolerance for congestion (e.g., as reflected in its general plan), LOS D, E, or F often represented significant environmental effects.

In 2013, however, the Legislature passed legislation with the intention of ultimately doing away with LOS in most instances as a basis for environmental analysis under CEQA. Enacted as part of Senate Bill (SB) 743 (2013), PRC Section 21099, subdivision (b)(1), directed the Governor’s Office of Planning and Research (OPR) to prepare, develop, and transmit to the Secretary of the Natural Resources Agency for certification and adoption proposed CEQA Guidelines addressing “criteria for determining the significance of transportation impacts of projects within transit priority areas. Those criteria shall promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses. In developing the criteria, [OPR] shall recommend potential metrics to measure transportation impacts that may include, but are not limited to, VMT, VMT per capita, automobile trip generation rates, or automobile trips generated. The office may also establish criteria for models used to analyze transportation impacts to ensure the models are accurate, reliable, and consistent with the intent of this section.” Subdivision (b)(2) of Section 21099 further provides that “[u]pon certification of the guidelines by the Secretary of the Natural Resources Agency pursuant to this section, automobile delay, as described solely by level of service or similar measures of vehicular capacity or traffic congestion shall not be considered a significant impact on the environment pursuant to [CEQA], except in locations specifically identified in the guidelines, if any.” (Italics added.) Pursuant to SB 743, the Natural Resources Agency promulgated CEQA Guidelines Section 15064.3 in late 2018. It became effective in early 2019. Subdivision (a) of that section provides that “[g]enerally, vehicle miles traveled is the most appropriate measure of transportation impacts.

For the purposes of this section, ‘vehicle miles traveled’ refers to the amount and distance of 180 El Camino Real/Steelwave Project
Addendum

August 2022
automobile travel attributable to a project. Other relevant considerations may include the effects of the project on transit and non-motorized travel. Except as provided in subdivision (b)(2) below (regarding roadway capacity), a project’s effect on automobile delay shall not constitute a significant environmental impact.”55
As of December 28, 2018, “automobile delay, as described solely by level of service or similar measures of vehicular capacity or traffic congestion shall not be considered a significant impact on the environment” under CEQA, except for roadway capacity projects. Thus, the former obligation under CEQA to address LOS in transportation analyses ceased to exist as of that date, except (at agencies’ discretion) with respect to transportation projects. EIRs for land use projects are therefore not required to address LOS issues, and “automobile delay,” as described in terms of LOS, “shall not be considered a significant impact on the environment.” Therefore, the following transportation analysis will focus on VMT, rather than LOS, to determine impact significance. As is required, other topics, such as emergency access, transit, bicycle, and pedestrian systems are evaluated.
a. The 2009 EIR explained that the South El Camino Real GPA Project supports the use of alternative transportation, including pedestrian, bicycle, and transit facilities. As a result, the 2009 EIR determined that the South El Camino Real GPA Project would not conflict with any adopted policies, plans, or programs supporting alternative transportation, and no impact would occur.

To assess the potential impacts related to pedestrian, bicycle, and transit facilities as well as impacts related to VMT associated with the proposed project, a Transportation Impact Analysis (TIA) was prepared by Fehr and Peers for the proposed project (see Appendix F of this Addendum).56 The amount of vehicle traffic that would be added to the roadway system as a result of the proposed project was estimated as part of the TIA. Vehicle trips from the approved uses evaluated in the 2009 EIR and the anticipated trips generated from the proposed project are shown in Table 15. As shown in the table, the project would generate approximately 1,148 net new vehicle trips per day. The estimated trip generation associated with the proposed project is included herein for informational purposes, given that LOS can no longer be relied upon to determine the significance of an impact under CEQA. An evaluation of CEQA question 'a’, in compliance with SB 743, is included below.

The following discussions address impacts related to conflicts with a program, plan, ordinance or policy addressing the circulation system, specifically as they relate to pedestrian, bicycle, and transit facilities associated with the currently proposed project.

Pedestrian and Bicycle Facilities
The following discussion describes the pedestrian and bicycle facilities in the project area, and then evaluates project impacts on such facilities.
55 Subdivision (b)(2) of section 15064.3 (“transportation projects”) provides that “[t]ransportation projects that reduce, or have no impact on, vehicle miles traveled should be presumed to cause a less than significant transportation impact. For roadway capacity projects, agencies have discretion to determine the appropriate measure of transportation impact consistent with CEQA and other applicable requirements. To the extent that such impacts have already been adequately addressed at a programmatic level, such as in a regional transportation plan EIR, a lead agency may tier from that analysis as provided in Section 15152.” 56 Fehr and Peers. 180 El Camino Real/Steelwave Transportation Impact Analysis. June 29, 2022. 180 El Camino Real/Steelwave Project
Addendum

August 2022
Table 15
Project Vehicle Trip Generation Summary
Land Use Size
Daily
Total
AM Peak Hour PM Peak Hour
In Out Total In Out Total
Residential1 183 DUs 831 16 53 69 44 28 72
Life Sciences/R&D2 797,069 sf 5,324 578 163 741 151 567 718 Internal Trip
Reductions3 - 238 26 10 36 21 41 62
Total project trips - 5,917 568 206 774 174 554 728
Approved South ECR
Non-residential Trips4 - 3,938 424 203 627 169 325 494
Approved South ECR
Residential Trips5 - 831 16 53 69 44 28 72
Net New Trips6 1,148 128 0 78 0 201 162
Notes:

1. Based on ITE 11th Edition (Land Use #221 – Multifamily Mid-Rise (Not Close to Rail Transit).

2. Based on local trip generation data for life science developments.

3. Based on MXD+ trip generation methodology which accounts for built environment factors such as density and diversity of land uses, design of the pedestrian and bicycle environment, site demographics, and accessibility of transit, among other factors. Internal trip reductions account for trips made between land uses on the site. This includes trips between R&D, residential, commercial uses, and excludes internal trips between commercial uses (supermarket and retail on Lot A).

4. South El Camino Real General Plan Amendment EIR - Table 3.1-7 Proposed Trip Generation. Nonresidential land uses previously approved include 75,840 sf of hotel, 180,010 sf of office, and 30,050 sf of retail.

5. South El Camino Real General Plan Amendment EIR – Table ES-1: Buildout of the Proposed Amendment. Previously approved land uses included 338 housing units.

6. Net new trips represent total project trips less previously approved So. ECR non-residential trips.

Source: Fehr & Peers, 2022.

Pedestrian Facility Setting
Pedestrian facilities include trails, sidewalks, crosswalks, and pedestrian signals.

Roadways within the project vicinity have continuous sidewalks, including both sides of El Camino Real, Huntington Avenue, and South Spruce Avenue. Additionally, continuous sidewalks exist between the San Bruno BART Station and the project site. Sidewalks on Huntington Avenue and South Spruce Avenue are generally in good condition, despite minor cracks in the pavement.

The Centennial Way Trail, which is a 2.85-mile rail-trail that begins north of the San Bruno BART Station along Huntington Avenue and continues north until the South San Francisco BART Station at Bart Road, runs parallel to Huntington Avenue near the project site and provides an approximately 10-foot-wide paved trail suitable for pedestrians and bicyclists.

The trail includes lighting for nighttime use. Residents and employees of the proposed project may access the Centennial Way Trail along South Spruce Avenue, approximately 500 feet east of the project site, and at the end of the trail on Huntington Avenue north of the San Bruno BART Station. In addition, a public access easement to connect to the Centennial Way Trail is planned for construction on the east side of Huntington Avenue.

Sidewalks along El Camino Real are generally in poor condition, and include cracked pavement, grade changes that result in portions of the sidewalk at roadway level, and light poles that narrow the sidewalk to approximately 3.5 feet. Along the project site perimeter on El Camino Real, sidewalk widths vary from 4.5 feet at the intersection of South Spruce 180 El Camino Real/Steelwave Project
Addendum