Exhibit A1 - GPU EIR Findings of Fact — South San Francisco City Council, October 12, 2022 (part 2 of 2)

Findings: Less than significant impact (Draft Program EIR, Page 3.13-31). No mitigation required.

Facts in Support of Findings: Development under the proposed project would result in additional residential and nonresidential development throughout the Planning Area, with the majority of residential uses located within 0.75 mile of an existing or proposed new park or recreational facility.

The proposed project anticipates approximately 14,312 net new housing units and approximately 42,297 net new employment opportunities by 2040, increasing the City’s population by approximately 40,068 (Chapter 2, Draft Program EIR). Development and growth in the City would increase demand for parks and recreational facilities. There may be a need to increase staffing and other resources, or expand or construct new parks and recreational facilities, to maintain existing parks and recreational facilities at acceptable service ratios. The environmental impacts from the construction of new parks and recreational facilities are discussed above under Impact REC-2.

Based on the City’s projected population of 107,203 by 2040, an additional 274 acres of park and open space would be needed by 2040 to achieve the City’s service standard of 5.5 acres of parkland per 1,000 residents. The proposed project includes new parks and recreational facilities to assist the City in meeting the park service standards. Additionally, the General Plan Update includes policies and actions to ensure that parks and recreational facilities keep pace with new development. Policy SA-16.3 requires the City to create new parks and open spaces in East of 101, including a public park within a ten-minute walk to any new residential development East of 101, a Colma Creek linear park featuring walking and cycling paths, and a recreational greenway between South Airport Boulevard and Littlefield Avenue. Action SA-31.1.1 requires the City to coordinate with Cal Water to purchase or lease land along Chestnut Avenue and Colma Creek to expand Orange Park. Policy PR-1.5 requires City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 80 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx the City to seek opportunities to use vacant and underutilized commercial and industrial buildings for recreational services, especially in disadvantaged communities. Policy PR-1.4 requires the City to ensure accessible public facilities and services are equitably distributed throughout the City and are provided in a timely manner to keep pace with new development. Policy PR-3.3 requires the City to create new public access points to Sign Hill, San Bruno Mountain State and County Park, and the San Francisco Bay Trail and parks. Policy PR-4.6 requires the City to work with other agencies, including PG&E, California Water Service, and SFPUC to convert public easements, such as utility corridors or unused rights of way, into parks and trails. Lastly, Policy PR-5.2 requires the City to seek opportunities to acquire property, including former Redevelopment Agency sites, utility right-of-way, and other vacant and underutilized properties to convert into parkland in the Downtown sub-area.

The South San Francisco Municipal Code contains rules and regulations related to parks and recreational facilities. Chapter 8.67 of the Municipal Code establishes a parks and recreation impact fee to acquire property in the City and provide three acres of parkland per 1,000 residents and onehalf acre of parkland per 1,000 new employees, mitigating the impact of development projects on park facilities. The City will review applications for development under the proposed project for compliance with the policies and actions of the General Plan Update to ensure that parks and recreational facilities keep pace with new development. In addition, development facilitated by the proposed project would be required to pay parks and recreation impact fees in accordance with Chapter 8.67 of the Municipal Code (Draft Program EIR, Page 3.13-30-31).

The proposed project's impacts related to public services and recreation would be less than significant with the implementation of applicable regulations, including new and revised General Plan Update policies and implementing actions. No mitigation is necessary.

Potential Effect
Impact REC-2 The proposed project could include parks or recreational facilities or require the construction or expansion of parks or recreational facilities, which may have an adverse physical effect on the environment (Draft Program EIR, Page 3.13-31-32).

Findings: Less than significant impact (Draft Program EIR, Page 3.13-31). No mitigation required.

Facts in Support of Findings: The proposed project could yield new parks, improved open space adjacent to State Route 35, and pedestrian and bicycle connections primarily east of US-101 and along the transit corridors. The proposed project also identifies planned and proposed parks and open spaces throughout the City, primarily within the Westborough, Orange Park, Lindenville, and East of 101 planning sub-areas. There could be environmental impacts associated with the construction of new or expanded parks and recreational facilities. However, project-specific environmental impacts cannot be assessed as the proposed project does not include specific plans for new or expanded park and recreation facilities. However, it can be expected that construction and operation of future new or expanded parks and recreational facilities would have similar impacts as would construction and operation of other types of new development under the proposed project. The City will review construction plans of new or expanded parks and recreational facilities for compliance with the policies and actions of the General Plan Update and the City’s Municipal Code (Draft Program EIR, Page 3.13-31-32). The proposed project's impacts related to public services City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 81
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx and recreation would be less than significant with the implementation of applicable regulations, including new and revised General Plan Update policies and implementing actions. No mitigation is necessary.

Cumulative Effects
The proposed project’s cumulative impacts related to public services and recreation would be less than significant (Draft Program EIR, Page 3.13-32-35).

Findings: Less than significant impact (Draft Program EIR, Page 3.13-35). No mitigation required.

Facts in Support of Findings: The geographic context for analysis of cumulative impacts related to public services generally includes the South San Francisco Planning Area and is delineated by the local service areas within the City, as described below in each service area discussion.

Fire Protection Services
The geographic context for the analysis of cumulative impacts related to fire protection facilities includes the SSFFD service area, which comprises the City of South San Francisco. A significant cumulative environmental impact would result if cumulative growth exceeded the ability of SSFFD to adequately serve its service area, thereby requiring construction of new facilities or modification of existing facilities. Development activity in the City provides revenue through impact fees, and license and permit fees. Additionally, SSFFD conducts a regular budgeting process where future facility and staffing needs are identified. All cumulative projects within the SSFFD service area would be required to comply with City ordinances and General Plan Update policies and actions that address fire protection services, including payment of public safety impact fees to provide funding for adequate fire equipment, vehicles, and facilities to meet the broad range of needs of South San Francisco residents and employees. Because past and present development will comply with all ordinances and policies, and there are mechanisms in place to ensure provision of adequate service, there would be no significant cumulative condition with respect to fire protection services.

Moreover, the proposed project’s incremental contribution to the less than significant cumulative impacts would not be significant. As discussed under Impact PUB-1, implementation of the proposed project would not create a need for new or physically altered facilities for the SSFFD to provide fire protection services to its service area.

As previously discussed, development facilitated by the proposed project would be required to comply with the policies and actions in the General Plan Update as well as the South San Francisco Municipal Code, to ensure that fire protection services are adequate as future development is proposed. Therefore, impacts of the proposed project on fire protection services are not cumulatively considerable.

Police Protection Facilities
The geographic context for the analysis of cumulative impacts related to police protection facilities includes the SSFPD service area, which comprises the City of South San Francisco. A significant cumulative environmental impact would result if this cumulative growth exceeded the ability of the SSFPD to adequately serve its service area, thereby requiring construction of new facilities or City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 82 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx modification of existing facilities. Development activity in the City provides revenue through impact fees and license and permit fees. Additionally, SSFPD conducts a regular budgeting process where future facility and staffing needs are identified. All cumulative projects within the SSFPD service area would be required to comply with City ordinances and General Plan Update policies and actions that address police protection services, including payment of public safety impact fees to provide funding for adequate police equipment, vehicles, and facilities to meet the broad range of needs of South San Francisco residents and employees. Because past and present development will comply with all ordinances and policies, and there are mechanisms in place to ensure provision of adequate service, there would be no significant cumulative condition with respect to police protection services.

Moreover, the proposed project’s incremental contribution to the less than significant cumulative impacts would not be significant. As discussed under Impact PUB-2, implementation of the proposed project would not create a need for new or physically altered facilities for the SSFPD to provide police protection services to its service area.

As previously discussed, development facilitated by the proposed project would be required to comply with the policies and actions in the General Plan Update as well as the South San Francisco Municipal Code, to ensure that police protection services are adequate as future development is proposed. Therefore, impacts of the proposed project on police protection services are not cumulatively considerable.

School Facilities
The geographic context for the analysis of cumulative impacts related to school facilities includes the SSFUSD and private schools that serve South San Francisco and surrounding cities. Regional growth resulting from past, present, and reasonably foreseeable projects would result in increased demand for additional school facilities within the SSFUSD. Schools are expected to receive development impact fees from cumulative development within other jurisdictions. The payment of school impact fees, per SB 50, would ensure that school facilities can accommodate future students.

Moreover, the proposed project’s incremental contribution to the less than significant cumulative impacts would not be significant. As discussed under Impact PUB-3, development facilitated by the proposed project would be required to pay the school impact fees adopted by each school district, per SB 50, and this requirement is considered to fully address the impacts of the proposed project on school facilities. Therefore, impacts of the proposed project on school facilities are not cumulatively considerable.

Library Facilities
The geographic context for analysis of cumulative impacts to library facilities includes the South San Francisco Public Library. A significant cumulative environmental impact would result if cumulative growth exceeded the ability of the South San Francisco Library to adequately serve people within its service area, thereby requiring construction of new facilities or modification of existing facilities. All cumulative projects would be required to comply with City ordinances and other policies that address library facilities and services, including library impact fees.

Other Public Facilities
The geographic context for analysis of cumulative impacts to other public facilities includes the Planning Area. Development and growth in the City would increase demand for other public facilities. A significant cumulative environmental impact would result if cumulative growth exceeded the ability of the City to adequately serve people within its service area, thereby requiring construction of new facilities or modification of existing facilities. All cumulative projects would be required to comply with City ordinances and other policies that address other public facilities.

Moreover, the proposed project’s incremental contribution to the less than significant cumulative impacts would not be significant. As discussed under Impact PUB-5, implementation of the proposed project would not create a need for other new or physically altered public facilities to maintain acceptable service ratios or other performance objectives. Therefore, impacts of the proposed on other public facilities are not cumulatively considerable.

Parks and Recreational Facilities
The geographic context for the analysis of cumulative impacts of parks and recreational facilities includes the Planning Area. A significant cumulative environmental impact would result if this cumulative growth resulted in an increase in the use of existing parks and recreational facilities, such that substantial physical deterioration of the parks or recreational facilities would occur or be accelerated, to require the construction of new parks and recreational facilities or modification of existing parks and recreational facilities. All cumulative projects would be required to comply with City ordinances and General Plan Update policies that address parks and recreational facilities, such as paying park in-lieu fees and maintaining adequate parkland ratios.

Moreover, the proposed project’s incremental contribution to less than significant cumulative impacts would not be significant. As discussed under Impact REC-1, implementation of the proposed project would not 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. As discussed under Impact REC-2, the construction or expansion of parks and other recreational facilities are not expected to result in an adverse physical effect on the environment. As such, development anticipated under the proposed project would not create substantial impacts related to parks and other recreational facilities.

Further, potential future impacts to South San Francisco parks and recreational facilities would be further reduced through the contribution of a parks and recreation impact fee to ensure facilities at these locations are adequately maintained and sufficient to accommodate growth associated with cumulative development. Therefore, impacts of the proposed project on parks and other recreational facilities are not cumulatively considerable (Draft Program EIR, Page 3.13-32-35).

City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 84 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx Accordingly, the proposed project's cumulative impacts related to public services and recreation would be less than significant with the implementation of applicable regulations, including new and revised General Plan Update policies and implementing actions. No mitigation is necessary.

1.5.14 - Transportation
Potential Effect
Impact TRANS-2 Implementation of the proposed project would not conflict with a program, plan, ordinance, or policy of the circulation system regarding bicycle or pedestrian facilities, or otherwise decrease the performance or safety of such facilities, that may have a significant impact on the environment (Draft Program EIR, Page 3.14- 41-44).

Findings: Less than significant impact (Draft Program EIR, Page 3.14-44). No mitigation required.

Facts in Support of Findings: Development under the proposed project would result in additional residential and nonresidential development throughout the Planning Area and may result in other private and public improvements throughout the City that have the potential for environmental effects related to bicycle and pedestrian facilities. Future potential development under the proposed project would contribute to and increase use of bicycle and pedestrian facilities in South San Francisco. The General Plan Update does not conflict with the Active South City Plan, which seeks to improve bicycle and pedestrian safety and improve mobility options in South San Francisco. The proposed circulation network enhances bicycle and pedestrian facilities citywide, improves connectivity, and shortens walking and biking distances.

While growth within South San Francisco would cumulatively contribute to and increase use of bicycle and pedestrian facilities, the General Plan Update includes policies and actions, listed on Pages 3.14-41-43 of the Draft Program EIR, that directly and indirectly result in improving the bicycle and pedestrian network and supporting programs to increase bicycle and pedestrian travel.

Implementation of these General Plan Update policies and actions of the proposed project would improve the bicycle and pedestrian network and support programs to increase bicycle and pedestrian travel and ensure that the proposed project would not conflict with a program, plan, ordinance, or policy of the circulation system regarding bicycle or pedestrian facilities, or otherwise decrease the performance or safety of such facilities.

Furthermore, actions identified in the Climate Action Plan, including Actions TL-2.5 (Development along Transit Corridors) and TL-2.6 (Complete Streets Policy), would enhance the bicycle and pedestrian network. Implementation of Action TL-2.5 would ensure that all new land use and transportation projects adhere to the City’s VMT Analysis Guidelines and qualitatively assess the project’s effect on multimodal access. Action TL-2.5 includes use of the development review process to identify opportunities to enhance bicycle, pedestrian, and transit connectivity. Implementation of Action TL-2.6 would ensure that all roadway and development projects are designed and evaluated to meet the needs of all street users and that development projects contribute to multimodal improvements in proportion to their potential impacts on VMT. Further, Action TL-2.6 includes the development of a Capital Improvement Program (CIP) prioritization criteria, including equity City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 85
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx considerations for SB 1000 neighborhoods, to strategically advance multimodal complete streets projects. Lastly, Action TL-2.6 would ensure that all capital improvements and development projects incorporate bicycle and pedestrian improvements identified in the Active South City Plan, such as trails, bikeways, bicycle detection at traffic signals, high-visibility crosswalks, and pedestrian-oriented site plans.

The South San Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of the proposed project, include rules and regulations that assist in reducing impacts related to bicycle and pedestrian facilities. Chapter 20.400 (Transportation Demand Management) (revised) promotes more efficient utilization of existing transportation facilities and ensures that new developments maximize transit, active transportation, carpooling, and vanpooling usage. Section 20.400.005 (Submittal Requirements and Approvals) (revised) requires that a project subject to the TDM Ordinance submit TDM documentation with the development application, which includes a completed TDM checklist of the trip reduction measures chosen by the applicant and a description of how the applicable performance requirements would be achieved and maintained over the life of the project. The trip reduction measures identified in Section 20.400.003 (Trip Reduction Measures and Requirements) (revised) related to bicycle and pedestrian facilities include the provision of bicycle storage, showers, and lockers, providing bicycle and pedestrian-oriented site access, providing on-site pedestrian-oriented amenities, providing active transportation subsidies, providing cash reward incentives for commuting via walking or biking, and providing a bicycle repair station.

Further, Section 20.330.007 (Bicycle Parking) (revised) establishes short-term and long-term bicycle parking requirements for new buildings and land uses, reconstruction, expansion, and change in the use of nonresidential buildings, additions and alterations to existing dwelling units, and alterations that increase the number of dwelling units (Draft Program EIR, Page 3.14-41-44). Therefore, related transportation impacts would be less than significant and no mitigation is necessary.

Potential Effect
Impact TRANS-3 Implementation of the proposed project would not conflict with a program, plan, ordinance, or policy of the circulation system regarding transit facilities, or otherwise decrease the performance or safety of such facilities, that may have a significant impact on the environment (Draft Program EIR, Page 3.14-44-47).

Findings: Less than significant impact (Draft Program EIR, Page 3.14-47). No mitigation required.

The General Plan Update includes policies and actions that directly and indirectly result in improving the transit network and supporting an increase in transit use. Implementation of these General Plan Update policies and actions would improve the transit network and support programs to increase travel by transit and would not conflict with a program, plan, ordinance, or policy of the circulation system regarding transit systems or otherwise decrease the performance or safety of such facilities.

City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 86 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx Actions identified in the Climate Action Plan, including Actions TL 2.5 and TL 2.6 as discussed above in Impact TRANS-2, as well as TL 2.8 (Improve Transit Station Access) would enhance the transit network. Implementation of Action TL 2.8 would include leveraging public-private partnerships to increase transit ridership and improve transit station access by incorporating first/last mile bus, shuttle, and active transportation connections between employment hubs and regional transit stations.

The South San Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of the proposed project, includes rules and regulations that would enhance transit facilities. These include Chapter 20.400, Section 20.400.005, and Section 20.400.003 as described above in Impact TRANS-2 (Draft Program EIR, Page 3.14-44-47). Accordingly, impacts would be less than significant and no mitigation is required.

Potential Effect
Impact TRANS-5 Implementation of the proposed project would not result in inadequate emergency access (Draft Program EIR, Page 3.14-50-52).

Findings: Less than significant impact (Draft Program EIR, Page 3.14-52). No mitigation required.

Facts in Support of Findings: Future potential development under the proposed project would alter land use patterns and increase travel demand on the transportation network that may influence emergency access. To accommodate the additional population and jobs, the proposed project includes 25 circulation improvements listed in Table 3.14-5 of the Draft Program EIR. The proposed improvements would increase connectivity in the network, which would promote improved emergency access. Additionally, new development that occurs pursuant to the proposed project would be subject to the provisions of the California Fire Code including those that pertain to emergency access. Multiple policies and actions in the Mobility Element and in other sections of the proposed project, listed on Pages 3.14-51-52 of the Draft Program EIR, support the maintenance of adequate emergency access.

Furthermore, actions identified in the Climate Action Plan would support the maintenance of adequate emergency access. Implementation of Action TL 2.3 would improve curb management by evaluating the current and best use of curb space in the City’s activity centers and repurposing space to maximize people served (i.e., for loading, bikeways, bike parking, bus lanes, EV charging, or parklets). Implementation of Action TL 2.6 would ensure that all roadway and development projects are designed and evaluated to meet the needs of all street users and that development projects contribute to multimodal improvements in proportion to their potential impacts on vehicle miles traveled.

The South San Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of the proposed project, include rules and regulations to reduce impacts related to emergency access including Chapter 20.400, Section 20.400.005, and Section 20.400.003, as discussed in Impact TRANS-2. Section 20.400.003 identifies trip reduction measures that promote carpooling and the use of transit, pedestrian and bicycle facilities, which would assist in reducing the number of vehicles on the road, thereby reducing traffic congestion throughout the City that could impede emergency City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 87
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx access (Draft Program EIR, Page 3.14-50-52). Accordingly, impacts would be less than significant and no mitigation is required.

1.5.15 - Utilities and Service Systems
Potential Effect
Impact UTIL-1 The proposed project would not require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which would cause significant environmental effects (Draft Program EIR, Page

3.15-28-30).

Findings: Less than significant impact (Draft Program EIR, Page 3.15-30). No mitigation required.

Facts in Support of Findings: Development under the proposed project would result in additional residential and nonresidential development throughout the Planning Area. The proposed project is expected to accommodate 40,068 new residents, 14,312 new housing units, 42,297 new jobs, and 14,100,523 new square feet of nonresidential building space at buildout. These increases would require additional water, wastewater treatment, storm drainage, electric power, natural gas, and telecommunication services which may require the construction or relocation of facilities which could cause significant environmental impacts. Each service is discussed separately below.

Water
As noted in Impact UTIL-2 of the Draft Program EIR, the General Plan Update includes policies and actions that would reduce water demand of future buildout. The CAP also includes actions that would reduce water demand of future buildout under the proposed project. Also described under Impact UTIL-2, both the Cal Water South San Francisco District and WWD project sufficient water supply availability under normal water years and require conservation measures under dry year conditions per the Cal Water Shortage Contingency Plan and WWD Water Shortage Contingency Plan. In addition, most new development accommodated under the proposed project is expected to be infill and would rely on the existing distribution network that has sufficient capacity to convey available water supplies. As such, implementation of the proposed project would not result in the need to construct or expand water supply and treatment facilities that have not already been described and accounted for the in the 2020 UWMPs.

Furthermore, each individual project would be required to demonstrate the availability of water to service the development, as required and applicable, in the form of will-serve letters or, for larger projects, preparation of a WSA per SB 610. If additional facilities were to be constructed, separate environmental analysis would be required. The City currently complies with the statutory requirements listed in the regulatory section, and the General Plan Update ensures that the City will continue to comply with the State and federal regulatory requirements. The General Plan Update encourages water conservation through Policies ES-5.3, ES-5.8, and ES-5.9. Policy ES-7.1 provides for ongoing partnerships with regional and local agencies to develop a comprehensive watershed management strategy that identifies programs, partnerships, actions, and incentives that the City and partners can take to protect the City’s water resources and Policy ES-7.2 calls for integration of City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 88 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx green irrigation infrastructure into City-owned landscapes. Additional policies focus on integrating green infrastructure for energy efficiency.

Cal Water’s 2020 UWMP and WWD’s 2020 UWMP state that there are currently no planned future water supply projects or programs that are expected to provide a quantifiable increase to the water supply. However, Cal Water is currently in the process of developing a regional water supply reliability study to create a long-term supply reliability strategy through 2050 for Cal Water districts in the Bay Area. It is anticipated this study will identify feasible water supply projects that may benefit the South San Francisco District. Individual infrastructure improvements that may occur under the applicable UWMPs would be subject to individual CEQA review and clearance to determine whether any would have significant environmental impacts. Therefore, the proposed project would not result in insufficient water supplies from Cal Water and WWD, and no new or expanded water treatment facilities would be needed under the proposed project.

Wastewater
As described under Impact UTIL-3, the General Plan Update includes policies and actions that would reduce the need for wastewater treatment. The CAP also includes actions that would reduce the need for wastewater treatment. In accordance with City requirements, new development that occurs pursuant to the proposed project would be subject to the latest adopted edition of the California Plumbing Code and CALGreen Code, including the provisions for water-efficient fixtures and toilets, which would reduce the amount of effluent entering the wastewater system. Further, as discussed under Impact UTIL-3, there is sufficient capacity at the South San Francisco/San Bruno WQCP and Daly City’s North San Mateo WQCP to accommodate wastewater collection and treatment generated by the proposed project.

Future development under the proposed project would be located within the urban framework of the City and near existing wastewater infrastructure. As such, implementation and buildout of the proposed project would not result in the need to construct or expand wastewater collection and treatment facilities that have not already been described and accounted for in the applicable Sewer System Master Plans. The City currently complies with the statutory requirements listed in the regulatory section, and the General Plan Update policies and actions ensure that the City will continue to comply with State and federal regulatory requirements related to wastewater. Therefore, the proposed project would not result in insufficient wastewater collection and treatment and no new or expanded wastewater treatment facilities would be needed.

Storm Drainage Capacity
In accordance with City requirements, new development that occurs pursuant to the proposed project would be required to install on-site storm drainage infrastructure that would detain stormwater and release runoff at a rate no greater than the pre-development condition of the project site. General Plan Policy ES-7.3 requires stormwater management practices for new and redevelopment projects. Policies ES-7.4 and ES-8.1 allow for groundwater recharge. Policy ES-8.2 implements potable water demand reduction measures. Additional policies require further water efficiency upgrades and measures. City requirements and policies would ensure that runoff would not inundate downstream storm drainage facilities such that new or expanded facilities would be required.

City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 89
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx Electric Power, Natural Gas, and Telecommunications
Electricity, natural gas, and telecommunications utilities respond to increased demands and prepare long-range plans to accommodate projected growth in their service areas. These planning efforts consider growth projections, including the growth under the proposed project. Because the proposed project would not result in unplanned growth, the majority of growth would be infill, and because the utility providers take into consideration all future growth projections in their planning efforts, the proposed project would not be expected to require or result in new or expanded electricity, natural gas, or telecommunications facilities beyond those already planned (Draft Program EIR, Page 3.15-28-30). The proposed project's impacts related to utilities and service systems would be less than significant with the implementation of applicable regulations, including new and revised General Plan Update policies and implementing actions. No mitigation is necessary Potential Effect
Impact UTIL-2 Sufficient water supplies would be available to serve the proposed project and reasonably foreseeable future development during normal, dry, and multiple dry years (Draft Program EIR, Page 3.15-30-35).

Findings: Less than significant impact (Draft Program EIR, 3.5-35). No mitigation required.

Facts in Support of Findings: The proposed project is expected to accommodate 40,068 new residents, 14,312 new housing units, 42,297 new jobs, and 14,100,523 new square feet of nonresidential building space at buildout. This increase in development would result in an increased demand for potable water. The City of South San Francisco receives most of its water supply from Cal Water, with a small area (the Westborough neighborhood) serviced by the WWD. A significant impact would occur if water demand for development facilitated by the proposed project could not be met by the providers’ existing entitlements and water supply resources.

The Westborough planning sub-area, which receives water from the WWD, is projected to see an increase of 524 residential units and 105 jobs as a result of the proposed project. Based on residential water demand factors provided by Cal Water in the absence of available data from WWD, the additional residences are expected to result in an increase of water demand within the Westborough planning sub-area of approximately to 23.8 MG per year. This increase in water demand represents 4.9 percent of total projected available supply (482 MG per year) within the WWD service area by 2040. WWD purchased only between 56 and 68 percent of its 482 MG per year, thus sufficient water is available. Because the proposed project is planned growth and because the WWDs UWMP and Water Shortage Contingency Plan consider future planned growth, sufficient water supplies are expected to be available in single and multiple dry years with the implementation of the Water Shortage Contingency Plan.

It is assumed that the remainder of the proposed project (13,788 residential units, 42,192 jobs) would receive water supplies from the Cal Water South San Francisco District. This growth would result in an increase of approximately 4,768 AFY water demand, which represents approximately 59 percent of total projected demand within the Cal Water South San Francisco District service area by 2040. Since Cal Water’s UWMP’s projected demand is based on general growth in its service area, the projected water demand from the proposed project, under normal water years, is accounted for City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 90 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx in the overall demand forecast. Because the project is planned growth and because Cal Water’s UWMP and Water Shortage Contingency Plan consider future planned growth, sufficient water supplies are expected to be available in single and multiple dry years with the implementation of the Water Shortage Contingency Plan.

In addition, with SB X7-7 and the State and County water conservation ordinances in place, each jurisdiction within the water service area is required to conserve its water use through establishing water efficiency measures. As required by the General Plan Update, the City of South San Francisco will continue to coordinate with regional water districts regarding water conservation efforts, demand management measures promoted by the water districts, compliance with current CALGreen measures and South San Francisco CAP measures promoting efficient indoor and outdoor water use.

These measures would serve to reduce water use and demand overall and especially during drought years.

Larger development projects within the Planning Area would be subject to SB 610 and SB 221, which require preparation of a WSA to confirm whether current and projected water supplies could accommodate the development as proposed. Other development projects would be required to obtain a will-serve letter from the water district.

Cal Water intends to adopt a Water Neutral Development Policy in the near future, requiring any new residential, commercial, or industrial development within the South San Francisco District that is expected to use 50 AFY or more in net new demand to offset its net increase in water demand.

Once adopted, future development consistent with the proposed project would be required to comply with the proposed Development Offset Program, which would help ensure that overall customer demand for water does not exceed available current or future supply under a range of hydrologic conditions. However, until the Development Offset Program is finalized it is too speculative to analyze.

Further, the General Plan Update includes policies and actions that would reduce water demand of future buildout. Policies ES-5.3, ES-5.8, ES-5.9, and ES-7.2 require and encourage water usage reduction strategies in landscaping design, including waterwise planting pallets, conservative irrigation systems, alternative irrigation water sources, and green infrastructure. Policy ES-7.4 and ES-8.1 encourage pervious surfaces and groundwater recharge. Policy ES-8.2 requires the implementation of potable water demand reduction measures. Policy CP-3.2 requires regular updates to the City’s building codes to improve the water efficiency of new construction and major renovation. Policy CP-4.1 aims to establish an energy and water efficiency upgrade program for existing buildings. Policy CP-8.3 requires the exploration of recycled water supply.

The CAP also includes actions that would reduce water demand from future buildout under the proposed project. Implementation of Action BE-1.2 would update zoning and building codes to require alterations or additions at least 50 percent the size of the original building to comply with minimum CALGreen requirements. Actions WW-1.1 through WW-1.4 would reduce outdoor water use through landscaping water requirements, alternative water sources, greywater systems, and landscaping plant lists. Actions WW-2.1 and WW-2.2 would reduce indoor water use through indoor water efficiency standards and the promotion of water conservation rebates. Action CL-1.1 and CL- City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 91
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1.2 would improve environmental efficiencies and performance of municipal buildings, facilities, landscaping and parks through minimum LEEDTM certification or equivalent for new buildings and benchmarking the environmental performance of municipal buildings and facilities, including water use (Draft Program EIR, Page 3.15-30—35). The proposed project's impacts related to utilities and service systems would be less than significant with the implementation of applicable regulations, including new and revised General Plan Update policies and implementing actions. No mitigation is necessary
Potential Effect
Impact UTIL-3 The wastewater treatment provider would have adequate capacity to serve the proposed project in addition to the provider’s existing commitments (Draft Program EIR, Page 3.15-35—38).

Findings: Less than significant impact (Draft Program EIR, Page 3.15-38). No mitigation required.

Facts in Support of Findings: The proposed project is expected to accommodate 40,068 new residents, 14,312 new housing units, 42,297 new jobs, and 14,100,523 new square feet of nonresidential building space at buildout. Additionally, the proposed project may result in other private and public improvements throughout the City with the potential for environmental effects related to wastewater treatment capacity. Development and growth in the City would increase demand for wastewater treatment capacity. As the demand for wastewater treatment capacity increases, there may be a need to increase wastewater conveyance and treatment facilities, the construction of which could cause environmental impacts.

The General Plan Update includes policies and actions to ensure that wastewater treatment capacity keeps pace with new development. Policies ES-8.3 and CP-3.2 encourage water consumption reduction measures which would, in turn, reduce wastewater generation. Policy CP-4.3 encourages greywater permitting to use for irrigation. Policy LU-8.10 ensures adequate infrastructure and utilities for all future development. Policy CP-8.1 requires the continuous evaluation and, as appropriate, system replacement at the wastewater treatment plant to reduce energy use. The CAP includes Action 1.2, which explores options at the South San Francisco/San Bruno WQCP for delivering non-potable, recycled water for reuse.

Based on the proposed project’s increase in population of 38,444 (outside the Westborough neighborhood) and the South San Francisco/San Bruno WQCP average per capita flow rate over the last 10 years of 79 gallons per day (gpd), an additional 3,037,076 gpd or 3.03 MGD of wastewater would be produced. Based on the proposed project’s increase in population of 1,624 within the Westborough neighborhood and using the average per capita flow rate of the South San Francisco/San Bruno WQCP as a proxy for the North San Mateo County Sanitation District, an additional 130,666 gpd or 0.13 MGD of wastewater would be produced.

In accordance with City requirements, new development that occurs pursuant to the proposed project would be required to connect to the municipal sewer system. New development would be subject to the latest adopted edition of the California Plumbing Code and CALGreen Code including City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 92 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx the provisions for water-efficient fixtures and toilets, which would reduce the amount of effluent entering the wastewater system.

The two wastewater treatment plants serving the City of South San Francisco have a combined capacity to treat up to 23.3 MGD and currently have additional dry weather capacity of approximately 14.6 MGD. The 3.13 MGD of wastewater generated by new development under the proposed project would represent 23.3 percent of total treatment capacity of the wastewater treatment plants. As shown in Table 3.15-11 of the Draft Program EIR, both wastewater treatment plants have capacity to handle the proposed project’s increase in wastewater.

Both the City of South San Francisco and the WWD maintain SSMPs as required under the Statewide General Waste Discharge Requirements for Sanitary Sewer Systems. The management plans are audited bi-annually and updated every 5 years. These updates allow for the consideration of development and redevelopment such as would occur under the proposed project. As such, the potential for increased wastewater generation and its need for transmission has been and will continue to be planned for by both the City of South San Francisco and the WWD. The City’s Sewer Capacity Charge reduces impacts caused by future development and redevelopment in the City by financing the replacement and renewal of existing sanitary sewer facilities and the upgrade and construction of new sanitary sewer facilities. Furthermore, the Storm Water Management Plans (SWMPs) include consideration of future growth in the City such as that of the proposed project.

Finally, the City’s Capital Improvement Plan includes projects covering both the wastewater system and the WQCP (Draft Program EIR, Page 3.15-35-38).

The proposed project's impacts related to utilities and service systems would be less than significant with the implementation of applicable regulations, including new and revised General Plan Update policies and implementing actions. No mitigation is necessary.

Potential Effect
Impact UTIL-4 The proposed project would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. In addition, the proposed project would comply with federal, State, and local statutes and regulations related to solid waste (Draft Program EIR, 3.15-38-40).

Findings: Less than significant impact (Draft Program EIR, Page 3.15-40). No mitigation required.

Facts in Support of Findings: Development under the proposed project would result in additional residential and nonresidential development throughout the Planning Area with the potential for environmental effects related to the generation of solid waste. Development and growth in the City would increase the generation of solid waste (both temporary construction and permanent operation waste) which could exceed State or local standards, exceed local infrastructure capacity, or otherwise impair the attainment of solid waste reduction goals.

The General Plan Update includes policies and actions to reduce and divert solid waste. Policy CP-5.4 requires 75 percent waste diversion for municipal construction and demolition projects. Policy CP- City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 93
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6.1 requires maintenance and regular updates of the City’s waste reduction plans and programs to ensure consistency with California’s waste reduction goals. Policy CP-6.2 develops education and technical assistance programs to help all residents and businesses to compost and recycle.

The CAP also includes actions to reduce and divert solid waste. Implementation of Action SW-1.1 would adopt an AB 1383 compliant zero-waste plan for municipal operations and the community.

Implementation of Action SW-1.2 entails the City continuing to work with SSF Scavenger to ensure implementation of waste reduction targets. Implementation of Action SW-1.3 establishes compliance pathways and enforcement mechanisms for mandatory organics and food waste diversion. Action SW-1.4 would develop educational and technical assistance programs to help all residents and businesses to compost and recycle. Implementation of Action CL 1.4 requires municipal construction projects to achieve 75 percent waste diversion from the landfill.

Development that occurs pursuant to the proposed project would be required by the City to be served with solid waste, recycling, and green waste services provided by the City’s franchise hauler (Municipal Code Chapter 8.16). Additionally, construction and demolition debris from new development would be required to be recycled (Municipal Code Chapter 15.60). Statewide ordinances, including AB 341, AB 939, SB 1016, and SB 1383 require waste reduction, recycling, and diversion and would also be applicable to development occurring pursuant to the proposed project.11
Construction waste would be temporary and would be required to be diverted from landfills in accordance with Municipal Code Chapter 15.60. Operationally, development under the proposed project would be estimated to generate approximately 59,014.2 tons or 42,153.0 cubic yards of solid waste at full buildout. For the solid waste that would be landfilled, the four landfills shown in Table

3.15-11 have a combined remaining capacity of 43.43 million cubic yards. The solid waste generated by the proposed project would represent approximately 0.09 percent of the remaining capacity of the servicing landfills. This capacity would be more than sufficient to accommodate the solid waste generated by implementation of the General Plan Update. Furthermore, as previously discussed, all future development projects proposed in the City would be consistent with federal, State, and local statutes and regulations related to solid waste, including the California Health and Safety Code, California Code of Regulations, California Public Resources Code, and City of South San Francisco General Plan and Municipal Code (Draft Program EIR, 3.15-38—40). The proposed project's impacts related to utilities and service systems would be less than significant with the implementation of applicable regulations, including new and revised General Plan Update policies and implementing actions. No mitigation is necessary.

Cumulative Effects
The proposed project’s cumulative impacts related to utilities and service systems would be less than significant (Draft Program EIR, Page 3.15-40-42).
11 City of South San Francisco. 2022. Ordinances and Laws. Website: https://www.ssf.net/departments/public-works/solidwasterecycling/ordinances-laws. Accessed April 12, 2022 City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 94 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx Findings: Less than significant impact (Draft Program EIR, Page 3.15-42). No mitigation required.

Facts in Support of Findings:

Water Supply
The geographic context for the analysis of cumulative impacts related to water supply includes the Cal Water South San Francisco District and WWD service areas. Overall, as described in detail above, cumulative water demands would neither exceed planned levels of supply nor require building new water treatment facilities or expanding existing facilities beyond what is currently planned under normal hydrologic years. Under single dry and multiple dry years, water supply availability is uncertain. However, each individual project would be required to demonstrate the availability of water to service the development. Cumulative projects would be required to demonstrate compliance with the statutory requirements listed in the regulatory section, and the General Plan Update would ensure that cumulative development in the City will continue to comply with the State and federal regulatory requirements. As discussed under Impact UTIL-2, if the water service providers should experience a shortage of supply during a drought, water use reduction plans and Water Shortage Contingency Plans are in place to reduce water consumption. These measures would be implemented in conjunction with other State, County, and local water conservation requirements and water efficiency measures. All cumulative projects would be subject to local, State, and federal permit requirements and would be required to comply with City/County ordinances and General Plan policies, as well as other regulations that address water supply. For these reasons, cumulative impacts are less than significant. The proposed project’s contribution to less than significant cumulative impacts would not be cumulatively considerable. Development facilitated by the General Plan would contribute to an increased cumulative demand for water supply, however, the growth within the water purveyor’s service areas has been considered in their UWMPs. Additionally, development consistent with the proposed project would be required to follow multiple water reduction policies outlined in the General Plan Update, CAP, and Municipal Code.

Required compliance with federal, State, and local policies that would reduce water supply impacts of development facilitated by the proposed project to less than significant levels. When applicable, any additional new development within the Planning Area would be subject, on a project-by-project basis, to independent CEQA review as well as policies in the General Plan, the Municipal Code, and compliance with current regulations, including and SB 610 and SB 221, which require WSAs for large development projects prior to approval. Accordingly, development consistent with the proposed project would have a less than significant contribution to cumulative impacts.

For these reasons, development consistent with the proposed project in conjunction with other cumulative projects would not be cumulatively considerable and the proposed project’s incremental contribution would be less than significant. Additionally, compliance with Cal Water’s anticipated future Water Neutral Development Policy, where new developers would pay a Development Offset Fee to offset their water demand with efficiency improvements elsewhere in the system, would further ensure that the proposed project’s incremental contribution to less than significant cumulative impacts would not be cumulatively considerable.

Additionally, the proposed project’s contribution to less than significant cumulative impacts would not be cumulatively considerable. While development facilitated by the proposed project would result in an increased demand for wastewater collection and treatment, such wastewater collection and treatment can be accommodated (see Impact UTIL-3). In addition, future projects within the Planning Area would be required to comply with requirements of the General Plan and Municipal Code that aim to reduce wastewater generation flows. Thus, impacts of the proposed project related to wastewater conveyance and treatment in conjunction with other cumulative development is not cumulatively considerable.

Solid Waste
The geographic context for the analysis of cumulative impacts related to solid waste includes the jurisdictions that are served by the Corinda Los Trancos and Newby Island Landfills. Cumulative development within other jurisdictions would contribute to an incremental increase in solid waste delivered to these landfills and other landfills in the region. Other future projects within the cumulative geographic context, would be required to comply with federal, State, and local laws and policies to address potential impacts related to solid waste.

Additionally, the proposed project’s contribution to less than significant cumulative impacts would not be cumulatively considerable. While development and growth in the City under the proposed project would result in an increased generation of solid waste, the affected landfills and other regional landfills have enough capacity to serve the City (see Impact UTIL-4). In addition, development facilitated by the proposed project would be required to comply with policies and programs of the General Plan and the regulations of the Municipal Code that aim to divert solid waste from the local landfill. The City would also be required to comply with existing and new federal, State, and local statutes and regulations related to solid waste (See UTIL-4). Therefore, as discussed, development consistent with the General Plan would have a less than significant contribution to cumulative impacts.

Storm Drainage
The geographic context for analysis of cumulative impacts to storm drain facilities includes the lands surrounding the Planning Area. Cumulative development contributes to an incremental increase in impervious surfaces that could increase stormwater runoff and impact existing storm drain facilities requiring relocated or new facilities. All cumulative projects would be required to comply with City/County ordinances and General Plan policies, as well as other regulations that minimize stormwater runoff, such as the CWA.

City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 96 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx As discussed under Impact UTIL-1, the proposed project’s contribution to less than significant cumulative impacts would not be cumulatively considerable. The General Plan Update contains policies and programs to reduce stormwater runoff. Likewise, the sections of the Municipal Code that protect water quality also minimize stormwater runoff, such as Chapter 11.17 and 11.18. All future development under the proposed project would also be required to comply with the CWA and regulations enforced by the RWQCB, which reduce stormwater runoff. Therefore, as discussed, development consistent with the General Plan would have a less than significant contribution to cumulative impacts (Draft Program EIR, Page 3.15-40-42). The proposed project's cumulative impacts related to utilities and service systems would be less than significant with the implementation of applicable regulations, including new and revised General Plan Update policies and implementing actions. No mitigation is necessary

1.5.16 - Wildfire
Potential Effect
Impact WILD-1 The proposed project would not expose people or structures, either directly or indirectly to a significant risk of loss, injury or death involving wildland fires (Draft Program EIR, Page 3.16-11-15).

Findings: Less than significant impact (Draft Program EIR, Page 3.16-15). No mitigation required.

Facts in Support of Findings: The Planning Area is not located in an FHSZ in an SRA or a VHFHSZ in a local, State, or federal responsibility area and the proposed project does not approve, propose, or authorize development in an SRA or FHSZ. Sign Hill Park is susceptible to wildfires and the Planning Area is adjacent to land identified as Moderate FHSZ within an SRA and High FHSZ within an SRA (San Bruno Mountain State Park). For properties that adjoin hillsides, and/or other non-developed open space fire-prone areas, new construction or rehabilitated landscapes require the submittal of a Standard Landscape Plan in accordance with Section 20.300.007 (Landscaping) (revised) of the South San Francisco Zoning Ordinance. The Standard Landscape Plan is required to include a landscape design plan in accordance with Section 492.6 of the Model Water Efficient Landscape Ordinance (MWELO). In particular, a landscape design plan for projects in fire-prone areas shall address fire safety and prevention, include a defensible space or zone around a building or structure per Public Resources Code Section 4291(a) and (b), and avoid fire-prone plant materials and highly flammable mulches.

New development or improvements under the proposed project in areas adjacent to San Bruno Mountain State Park or Sign Hill Park could expose people or structures to wildfire spread. However, land use designations in the vicinity of San Bruno Mountain State Park and Sign Hill Park are not being modified under the proposed project. As a result, the degree of exposure of people or structures, either directly or indirectly, to a risk of loss, injury, or death involving wildland fires would not substantially change with adoption of the proposed project, and current hazards would not be significantly increased.

The City of South San Francisco, San Mateo County, and SSFFD have plans, policies, actions, and ordinances in place to reduce the risks associated with wildland fires and future discretionary City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 97
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx projects facilitated by the proposed project will be evaluated for project-specific impacts at the time they are proposed.

The San Mateo–Santa Cruz County CWPP identifies recommendations aimed at preventing and reducing both infrastructure and ecosystem damage associated with wildland fires. The City of South San Francisco is located within the San Mateo Bayside Planning Area and adjacent to the San Mateo Interior Planning Area of the CWPP. General recommendations, listed on page 3.16-13 of the Draft Program EIR, have been identified for the San Mateo Bayside Planning Area, which would assist in reducing wildfire risk within the City of South San Francisco. Additionally, the San Mateo County LHMP provides recommendations, listed on page 3.16-13, to assist the County in reducing wildfire risk, which in turn can assist in reducing wildfire risk within the City of South San Francisco.

The San Mateo County EOP establishes policies and procedures and assigns responsibilities to ensure the effective management of emergency operations within the San Mateo County Operational Area, which includes the Planning Area. During an emergency or disaster, such as a wildfire, the San Mateo County EOP will accomplish actions listed on page 3.16-12 of the Draft Program EIR.

The SSFFD, Division of Fire Prevention, reviews architectural and development plans for compliance with Chapter 15.24 of the Municipal Code’s fire protection and emergency access requirements.

SSFFD will also review plans to ensure that fire sprinklers, fire alarms, and fire extinguishers are up to current code and appropriately located within proposed buildings or structures. Buildings and structures located adjacent to fire hazard areas (San Bruno Mountain State Park and Sign Hill Park), would be required to maintain the required hazardous vegetation and fuel management as well as defensible space as outlined in Government Code Sections 51175-51189 and local standards of the City of South San Francisco. The City enforces these standards through code enforcement.12 The General Plan Update contains policies and actions that reduce risks from wildland fires before development occurs. Specifically, Policy SA-32.8 requires the City to limit the amount of development allowed on the north side of Sign Hill (discretionary at one unit per acre maximum) and not permit excessive grading of this portion of the hill or clustering of development in the future.

Policy CR-5.1 requires the City to continue to implement Sign Hill wildfire mitigation measures (i.e., restoration and maintenance of native grass and scrubland habitat, removal of non-native trees and trees killed in October 2020 fire, removal of dead trees due to drought and disease and maintenance of existing trails to function as fire breaks). Policy CR-5.2 requires the City to maintain a comprehensive fire hazard management program to reduce fire hazards on other public lands. Policy CR-1.2 requires the City to participate in regional hazard planning initiatives. Action CR-1.3.3 requires the City to enact an ordinance to require real estate disclosures of all hazards identified in the Hazard Mitigation Plan, including hazards associated with wildfire for commercial and residential properties, including ownership and rental. Policy CR-1.4 requires the City to periodically adjust infrastructure design standards to address asset-specific vulnerabilities associated with the hazards, such as wildfire. Policy CR-1.5 requires that capital projects in high hazard areas adhere to risk assessment guidance and identify appropriate resilience strategies. 12 City of South San Francisco. 2022. Submit a Request. Website: https://www.ssf.net/departments/public-works/submit-a-request.

Accessed May 26, 2022.

City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 98 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx Implementation of the Climate Action Plan would also indirectly reduce wildfire risks. In particular, implementation of Action CS-3.1 which would enhance Colma Creek as an ecological corridor and expand existing marsh and wetland habitat, would assist in providing a fuel break in the event of a wildland fire. Implementation of Action WW-1.4, which would develop a landscaping plant list for efficiency and habitat/wildlife for new development and landscape retrofits, could include plants that are more resistant to wildland fires.

As the City would review development applications for subsequent development under the proposed project for compliance with the policies and actions of the General Plan Update to reduce the exposure of people or structures, either directly or indirectly, to a risk of loss, injury, or death involving wildland fires. In addition, the City’s Municipal Code, which implements the City’s General Plan, would be reviewed when development applications are received, including Chapter 15.08, California Building Code; Chapter 15.18, Dangerous Buildings Code; and Chapter 15.24, California Fire Code.

The proposed project's impacts related to wildfire would be less than significant with the implementation of applicable regulations, including new and revised General Plan Update policies and implementing actions. No mitigation is necessary.

Potential Effect
Impact WILD-2 The proposed project would not substantially impair an adopted emergency response plan or emergency evacuation plan (Draft Program EIR, Page 3.16-16-17).

Findings: Less than significant impact (Draft Program EIR, Page 3.16-17). No mitigation required.

Facts in Support of Findings: As described in HYD-1, the Planning Area is not located in an FHSZ in an SRA or a VHFHSZ in a local, State, or federal responsibility area and does not include plans for development in these areas. The Planning Area is adjacent to land identified as Moderate FHSZ within an SRA and High FHSZ within an SRA (San Bruno Mountain State Park), and Sign Hill Park is susceptible to wildfires as evidenced by a fire that occurred in 2020. Development under the proposed project would result in additional residential and nonresidential development throughout the Planning Area, some of which could occur in areas adjacent to San Bruno Mountain State Park or Sign Hill Park. Additionally, the proposed project may result in other private and public improvements throughout the City that have the potential for environmental effects related to wildfire should they be constructed near Sign Hill Park or San Bruno Mountain State Park. Therefore, subsequent development under the proposed project could affect adopted emergency response plans or emergency evacuation plans.

However, because South San Francisco is a fully built city, most of the development under the proposed project would occur as redevelopment within the urbanized areas of the City, outside of an SRA, thus proposed project would not materially overburden any designated evacuation routes nor substantially impair any emergency response plans or emergency evacuation plans.

Development proposed within the northern portions of the Sunshine Gardens, Sign Hill, Paradise Valley/Terrabay, and East of 101 sub-areas could be within 100 feet of land designated as Moderate City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 99
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx FHSZ within an SRA or High FHSZ within an SRA. Development authorized by the proposed project, including potential development closest to the SRA (within 100 feet) would not impair an adopted emergency response plan or emergency evacuation plan because policies and actions contained with the General Plan Update establish requirements for preventive measures and practices to minimize wildland fire hazards and maintain adequate evacuation and access routes for vehicles in the event of an emergency, including wildland fires. Policy CR-1.6 requires the City to strengthen emergency management capacity and coordination with the San Mateo County EOC. Action CR-1.6.5 requires the City to maintain and communicate evacuation route plans for businesses and residents. Policy CR-1.7 requires the City to expand the reach of the CERT program to strengthen community cohesion and emergency preparedness through community engagement efforts. Policy CR-5.1 requires the City to implement Sign Hill wildfire mitigation measures and Policy CR-5.2 requires the City to maintain a comprehensive fire hazard management program to reduce fire hazards on other public lands. Lastly, Policy CR-5.3 requires the City to increase community participation and understanding of evacuation and early warning software programs to minimize threat to life and be better prepared in case of a wildfire event.

Evacuation routes in the City are designed to accommodate development at buildout of the proposed project. In addition, the policies and actions in the General Plan Update are designed to facilitate and support the City’s emergency response and do not have any direct or indirect impact on the environment.

All development in the City will be required to demonstrate compliance with applicable codes and regulations. Development under the proposed project would require continued implementation of the San Mateo County LHMP and San Mateo County EOP. Further, the California Fire Code establishes requirements for emergency access for fire apparatus. Chapter 15.24 of the Municipal Code requires development to demonstrate compliance with applicable fire safety measures prior to the issuance of building permits. Ongoing compliance with safety measures are enforceable through the City’s code enforcement. As such, new development projects that occur pursuant to the proposed project would be assessed for compliance with applicable Fire Code requirements that pertain to emergency access as well as compliance with proposed policies and actions of the General Plan Update which would further enhance emergency response. By involving the Police and Fire Departments in the development review process, the City ensures adequate emergency vehicle access and ensures that development is designed and operated in a manner that minimizes fire hazards and maximizes the potential for responsive emergency services (Draft Program EIR, Page

3.16-16 – 17). The proposed project's impacts related to wildfire would be less than significant with the implementation of applicable regulations, including new and revised General Plan Update policies and implementing actions. No mitigation is necessary.

Potential Effect
Impact WILD-3 The proposed project would not, due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire (Draft Program EIR, Page 3.16-18-19).

Findings: Less than significant impact (Draft Program EIR, 3.16-19). No mitigation required.

City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 100 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx Facts in Support of Findings: There are no SRAs or Fire Hazard Severity Zones within the Planning Area (Exhibit 3.16-1). However, Sign Hill Park is susceptible to wildfires and the Planning Area is adjacent to land identified as Moderate FHSZ within an SRA and High FHSZ within an SRA (San Bruno Mountain State Park).

Therefore, the degree of wildland fire hazard would not substantially change with adoption of the proposed project, and current hazards would not significantly increase.

New development would primarily occur on parcels that already contain some existing homes or businesses, the majority which would occur over 0.25 mile from San Bruno Mountain State Park or Sign Hill Park and within the low-lying portions of the Planning Area adjacent to San Francisco Bay, which are less susceptible to wildland fires. If a fire were to occur in the more flat and urbanized areas of the City, the risk of the fire spreading rapidly would be less than in areas with steeper slopes. Nevertheless, smoke from wildfires occurring in remote parts of the State have at times resulted in poor air quality throughout the bay area.

Development under the proposed project would be consistent with the City of South San Francisco, San Mateo County, and SSFFD plans, policies, actions, and ordinances in place to reduce the risks associated with wildland fires. As described under Impacts WILD-1 and WILD-2, these existing plans, policies, actions, and ordinances reduce the potential for exposure to wildland fires. Reducing potential for fires to start and mitigating wildfire spread once started reduces exposure to smoke and air pollution. Safely evacuating people affected by wildfires also reduces exposure. Policy CR-6.4, which requires the City to maintain adequate cooling and warming centers that can be used as refuge during excessive heat and cold days, would also provide relief from the potential effects of wildfires on air quality, thus reducing the exposure of residents to pollutants (Draft Program EIR,

Page 3 ends

with the implementation of applicable regulations, including new and revised General Plan Update policies and implementing actions. No mitigation is necessary.

Potential Effect
Impact WILD-4 The proposed project would not require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment (Draft Program EIR, Page 3.16- 19-20).

Findings: Less than significant impact (Draft Program EIR, Page 3.16-20). No mitigation required.

Facts in Support of Findings: There are no SRAs or Fire Hazard Severity Zones within the Planning Area, thus no development under the proposed project would be located within an FHSZ. The majority of development under the proposed project, including other private and public City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 101
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx improvements throughout the City (see Chapter 2, Project Description, Section 2.5.2), would occur in urban and developed areas that contain required defensible space, existing roadways, fuel breaks, water sources, power lines, and other utilities. The Fire Department will review the installation and maintenance of fire department access roadways, access walkways to and around buildings, and hydrant quantity and placement as required by the CFC and CBC. As discussed under Impacts WILD-1 and WILD-2, compliance with the CBC and General Plan Update policies and actions, as well as review of all new structures as well as private and public improvements by the Police and Fire Departments, would ensure that fire risks are not exacerbated.

As discussed in Impact UTIL-1, development consistent with the proposed project would not require or result in the relocation or construction of new or expanded utilities and service systems, the construction or relocation of which could cause significant environmental effects. Most development under the proposed project is expected to occur in urbanized and developed areas where existing infrastructure are already in place. The proposed project would retain the existing roadway patterns and does not propose any new roadways. The City will review development applications for development, and private and public improvements, for compliance with the fire protection measures identified in the General Plan Update, California Fire Code, and the California Public Resources Code (Draft Program EIR, Page 3.16-19-20). The proposed project's impacts related to wildfire would be less than significant with the implementation of applicable regulations, including new and revised General Plan Update policies and implementing actions. No mitigation is necessary.

Potential Effect
Impact WILD-5 The proposed project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes (Draft Program EIR, Page 3.16-20- 21).

Findings: Less than significant impact (Draft Program EIR, Page 3.16-21). No mitigation required.

Facts in Support of Findings: As discussed above, there are no SRAs or FHSZs within the Planning Area. Sign Hill Park and San Bruno Mountain State Park contain sloping hillsides that are susceptible to landslides and flooding after fire has removed protective vegetative cover. These secondary hazards associated with wildfires are described in the San Mateo County LHMP.

As described under Impact WILD-1, new development or improvements under the proposed project in areas adjacent to San Bruno Mountain State Park or Sign Hill Park could expose people or structures to wildfire spread. However, land use designations in the vicinity of San Bruno Mountain State Park and Sign Hill Park are not being modified under the proposed project. Therefore, the degree of wildland fire hazard, including secondary hazards associated with wildfires, would not substantially change with adoption of the proposed project, and current hazards would not significantly increase.

As described in WILD-3 the majority of development under the proposed project would occur on parcels that already contain some existing homes or businesses over 0.25 mile from San Bruno Mountain State Park or Sign Hill Park and within the low-lying portions of the Planning Area (5 to 20 City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 102 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx feet above sea level) adjacent to San Francisco Bay. If a fire were to occur in the flatter areas of the City, the risk of flooding or landslides afterward would be negligible because of the nearly flat topography and because little soil would be exposed due to the developed conditions. Development under the proposed project would be subject to the rules and regulations of the South San Francisco Municipal Code and the policies and actions in the General Plan Update regarding development on unstable geologic soils and controlling stormwater runoff during and after construction. Specific policies related to the prevention of flooding, landslides, and drainage changes include Policy CR-4.3, which discourages development on steep hillside areas more than 30 percent grade; Policy ES-3.3, which requires no net new impervious surfaces in the areas surrounding Colma Creek; Policy ES-7.3, which requires stormwater management practices for new and redevelopment projects; and Policy ES-7.4, which encourages pervious surfaces in new developments. The San Mateo–Santa Cruz County CWPP and San Mateo County LHMP would continue to be implemented and architectural and development plans would be reviewed by the SSFFD (Draft Program EIR, Page 3.16-20-21).

Cumulative Impacts
The proposed project’s cumulative impacts related to wildfire would be less than significant (Draft Program EIR, Page 3.16-21-22).

Findings: Less than significant impact (Draft Program EIR, Page 3.16-22). No mitigation required.

Facts in Support of Findings: The geographic scope of the cumulative impact analysis for wildfire is the South San Francisco Planning Area as well as the surrounding cities of Brisbane, Daly City, Pacifica, San Bruno, and Millbrae.

The cities surrounding the Planning Area are largely urbanized, generally outside the SRA and VHFHSZs, and include roads and other fuel breaks, emergency water sources, emergency utilities and maintenance of other infrastructure that would reduce impacts from wildfires. All cumulative projects, including the installation and/or maintenance of associated infrastructure, would be subject to similar fire protection development standards and be required to comply with San Mateo County ordinances, General Plan policies, and plan review by the local fire department to assist in protecting life and property in the event of a wildfire. Development projects, including the installation and maintenance of associated infrastructure, within a hazardous fire area must be reviewed by the County Fire Warden to ensure that building materials, access, vegetative clearance from structures, fire flows and water supplies are adequate for fire protection purposes and in conformance to the fire policies of the San Mateo County General Plan. Additionally, development projects, including the installation and maintenance of associated infrastructure, would be required to comply with all policies in the California Fire Code, including the requirements for WUI fire areas.

All cumulative projects, including the installation and maintenance of associated infrastructure, would be covered under existing emergency response plans by San Mateo County. Lastly, implementation of the San Mateo–Santa Cruz County CWPP and the San Mateo County LHMP throughout the Planning Area and adjacent areas would reduce cumulative impacts related to wildfire.

Development could result in an incremental increase in exposure of people and structures to wildland fires and associated hazards, such as development near Sign Hill Park or San Bruno Mountain State Park. However, land use designations in the vicinity of San Bruno Mountain State Park and Sign Hill Park are not being modified under the proposed project. The adoption of the proposed project would not exacerbate any existing wildfire hazards because the degree of wildland fire hazard, including secondary hazards, would not substantially change.

Additionally, new development within the Planning Area would be required to comply with the fire protection measures identified in the General Plan Update, California Fire Code, and the California Public Resources Code. Action CR-1.3.1 directs the City to actively participate in the San Mateo County Hazard Mitigation Plan maintenance protocols and Countywide initiatives. Policy CR-1.6 requires the City to strengthen emergency management capacity and coordination with the San Mateo County EOP. The proposed project’s contribution to cumulative impacts would not be cumulatively considerable (Draft Program EIR, Page 3.16-21-22).

The proposed project's cumulative impacts related to wildfire would be less than significant with the implementation of applicable regulations, including new and revised General Plan Update policies and implementing actions. No mitigation is necessary.

1.6 - Potential Environmental Effects Which Can Be Mitigated Below a Level of Significance
The City of South San Francisco hereby finds that feasible mitigation measures have been identified in the Draft Program EIR that will avoid or substantially lessen the following potentially significant environmental impacts to a less than significant level. The potentially significant impacts, and the mitigation measures that will reduce them to a less than significant level, are as follows:

1.6.1 - Air Quality
Potential Effect
Impact AIR-3 The proposed project would not expose sensitive receptors to substantial pollutant concentrations (Draft Program EIR, Page 3.2-54-56).

Findings: Less than significant impact with mitigation incorporated. (Draft Program EIR, Page 3.2-56.) Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effects as identified in the EIR (State CEQA Guidelines § 15091(a)(1)).

City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 104 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx Mitigation Measures
MM AIR-1b Projects that may result in additional toxic air contaminants (TACs) that are located within 1,000 feet of a sensitive receptor(s) or would place sensitive receptors within 1,000 feet of uses generating TACs, such as roadways with volumes of 10,000 average annual daily trips or greater, shall implement Bay Area Air Quality Management District (BAAQMD) Guidelines and California Office of Environmental Health Hazard Assessment (OEHHA) policies and procedures requiring a Health Risk Assessment (HRA) for residential development and other sensitive receptors.

Screening area distances may be increased on a case-by-case basis if an unusually large source or sources of hazardous emissions are proposed or currently exist.

Based on the results of the HRA, identify and implement measures (such as air filtration systems) to reduce potential exposure to particulate matter, carbon monoxide, diesel fumes, and other potential health hazards. Measures identified in HRAs shall be included into the site development plan as a component of a proposed project.

Facts in Support of Findings: Within the SFBAAB, localized risks are primarily associated with exposure to TAC emissions. Common sources of TAC emissions are stationary sources, subject to BAAQMD permit requirements, on-road motor vehicles on high-volume roads, and off-road sources such as construction equipment and diesel-powered trains traveling on the Caltrain corridor.

Although the proposed project does not include specific plans for any new, large stationary sources of emissions, it could result in new sensitive receptors (primarily residential receptors) near existing sources of emissions.

Community Risk and Hazards–Plan Land Use Diagram Special Overlay Zones The proposed project consists of a General Plan Update, Climate Action Plan Update, and Zoning Code Amendment and would not directly result in construction of any development project. Projectspecific information for future individual land use development projects is unknown, thus potential impacts to sensitive receptors resulting from construction-generated TACs cannot be determined. If the proposed project’s land use diagram identifies special overlay zones around existing and planned sources of TACs, including special overlay zones of at least 500 feet on each side of all freeways and high-volume roadways (or another BAAQMD-approved modeled distance), and the plan identifies goals, policies, and objectives to minimize potentially adverse impacts, then the community risk and hazard impact would not be significant. This is consistent with BAAQMD’s CEQA Air Quality Guidelines for analyzing plan-level impacts to sensitive receptors. Page 3.2-55 of the Draft Program EIR lists sites for which the ARB Air Quality and Land Use Handbook recommends avoiding the siting of new sensitive land uses.

The proposed project does not contain a land use diagram which identifies special overlay zones around existing and planned sources of TACs. MM AIR-1b, detailed above, would be required to ensure that future development facilitated by the proposed project would result in less than significant impacts to sensitive receptors related to operational TACs.

General Plan Update policies and actions that target the use of alternative modes of transportation, such as bicycling, walking, or using public transit, include Action LU-1.1.3, Policy LU-2.1, Action LU2.1.2, Policy LU-4.4, and Policy CR-6.5. General Plan Update policies and actions that require the City to monitor and improve existing source of TACs include Policy PE-2.1, Action CHEJ-3.1.1, Action CHEJ-3.2, Action CHEJ-3.2.1, Policy CHEJ-3.2.2, Policy CHEJ-3.3, and Action CHEJ-3.3.1. Lastly, General Plan Update policies and actions that generally aim to reduce health impacts to residents in the City include Policy SA-17.4, Policy SA-32.5, Policy CHEJ-3.1, Action CHEJ-3.3.2, Policy CHEJ-3.5, and Policy CHEJ-3.6.

The South San Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of the proposed project, include Section 20.300.010 (Performance Standards), which establishes regulations related to air contaminants. Section 20.300.010 requires that sources of air pollution comply with rules identified by the EPA (Code of Federal Regulations, Title 40), the ARB, and the BAAQMD. The section further requires that operators of activities, processes, or uses that require “approval to operate” from the BAAQMD, shall file a copy of the permit with the Planning Division within 30 days of permit approval (Draft Program EIR, Page 3.2-54—56).

The City finds that MM AIR-1b is feasible, is adopted, and will further reduce impacts related to operational TACs. Accordingly, the City finds that, pursuant to Public Resources Code Section 21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project that mitigate or avoid the potentially significant impacts as identified in the EIR. Therefore, impacts associated with air quality would be less than significant with mitigation incorporated.

1.6.2 - Biological Resources
Potential Effect
Impact BIO-1 The proposed project could have a substantial adverse effect, either directly or through habitat modifications, on a 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 United States Fish and Wildlife Service (Draft Program EIR, Page 3.3-18-22).

Findings: Less than significant impact with mitigation incorporated. (Draft Program EIR, Page 3.3-22.) Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effects as identified in the EIR (State CEQA Guidelines § 15091(a)(1)).

City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 106 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx Mitigation Measures
MM BIO-1 Special-status Species, Migratory Birds, and Nesting Birds Special-status species are those listed as Endangered, Threatened or Rare, or as Candidates for listing by the United States Fish and Wildlife Service (USFWS) and/or California Department of Fish and Wildlife (CDFW), or as Rare Plant Rank 1B or 2B species by the California Native Plant Society (CNPS). This designation also includes CDFW Species of Special Concern and Fully Protected Species. Applicants or sponsors of projects on sites where potential special-status species, migratory birds, or nesting birds are present shall retain a qualified Biologist to conduct a focused survey per applicable regulatory agency protocols to determine whether such species occur on a given project site. The project applicant or sponsor shall ensure that, if development of occupied habitat must occur, species impacts shall be avoided or minimized, and if required by a regulatory agency or the CEQA process, loss of wildlife habitat or individual plants shall be fully compensated on the site. If off-site mitigation is necessary, it shall occur within the South San Francisco Planning Area whenever possible, with a priority given to existing habitat mitigation banks. Habitat mitigation shall be accompanied by a long-term management plan and monitoring program prepared by a qualified Biologist and include provisions for protection of mitigation lands in perpetuity through the establishment of easements and adequate funding for maintenance and monitoring.

Facts in Support of Findings: Forty-eight special-status plant species and 51 special-status animal species were recorded to occur within 5 miles or less of the South San Francisco Planning Area. The sensitive plant species are most likely to be found in the estuary habitats around San Francisco Bay.

San Bruno Mountain State Park contains critical habitat for Choris’ popcornflower. The special-status wildlife species are most likely to be found in parks within the City or in the surrounding hillsides.

Shorebirds and aquatic species can be found along the eastern edge of the City, in the estuaries surrounding San Francisco Bay. A few of these wildlife species, such as birds and bats, may find suitable nesting habitat within buildings and other human-made structures. The species most adapted to man-made habitats include the Alameda song sparrow, American peregrine falcon, and Townsend’s big-eared bat. San Bruno Mountain State Park contains critical habitat for the Bay checkerspot butterfly. Subsequent development under the proposed project could result in the direct/indirect loss or indirect disturbance of special-status plant or animal species or their habitats that are known to occur, or have potential to occur, in the region.

Significant impacts on special-status plant species associated with individual subsequent projects could include the direct loss of individual plants and of habitat areas associated with these specialstatus plant species. Indirect impacts to special-status plant species could include habitat degradation as a result of impacts to water quantity and quality. Significant impacts could include, but are not limited to, increased mortality caused by higher numbers of automobiles in new areas of development; direct mortality from the collapse of underground burrows, resulting from soil compaction; direct mortality resulting from the movement of equipment and vehicles through construction areas; direct mortality resulting from removal of trees with active nests; direct mortality or loss of suitable habitat resulting from the trimming or removal of obligate host plants; City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 107
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx direct mortality resulting from the filling of wetlands features; loss of breeding and foraging habitat resulting from the filling of seasonal or perennial wetlands; loss of breeding, foraging, and refuge habitat resulting from the permanent removal of riparian vegetation; loss of suitable habitat for vernal pool invertebrates resulting from the destruction or degradation of vernal pools or seasonal wetlands; abandonment of eggs or young and subsequent nest failure for special-status nesting birds, including raptors, and other non-special-status migratory birds resulting from constructionrelated noises; loss or disturbance of rookeries and other colonial nests; loss of suitable foraging habitat for special-status raptor species; loss of migration corridors resulting from the construction of permanent structures or features; and impacts to fisheries/species associated with waterways.

The Endangered Species Act and CESA generally prohibit the taking of protected plant and animal species or direct impacts to foraging or breeding habitat without a special permit. The General Plan Update Policy ES-2.1 requires the City to protect and expand existing marsh and wetland habitat to improve water quality, adapt to climate change, and provide habitat for wildlife. Policy ES-2.2 requires the City to maintain standards and guidelines for new construction within 150 feet of San Francisco Bay that support the health of the Bay, such as the installation of bioswales to treat runoff before it enters the Bay, use of low intensity lighting to reduce the amount of light reaching sensitive habitat, and requiring an assessment as part of the CEQA process to consider wildlife impacts before project approval to continue to protect special-status of species. Action ES-2.2.1 requires the City to develop a bird-safe design ordinance to minimize the adverse effects on native and migratory birds and require new development East of 101 to incorporate design measures. Policy ES-3.3 requires the City to maintain development standards and guidelines for new construction within 80 feet of Colma Creek, such as maintaining or increasing building setbacks to support habitat areas. Policy ES-6.1 requires the City to continue to catalog and update information on threatened and endangered wildlife and plant species in the review of project proposals. Policy ES-6.2 requires wildlife and plant assessments for new development in areas that could impact threatened or endangered species.

Policy ES-6.3 requires that permit applications for projects located within ecologically sensitive habitat areas prepare site-specific biological assessments for review and approval by City Planning staff, and incorporation of the recommended measures during construction to protect ecologically sensitive habitat areas.

The South San Francisco Zoning Ordinance Chapter 20.170 (existing) creates a Special ES Overlay District to protect areas of high biological value. Section 20.170.003 (Habitat and Biological Resource Conservation Areas) (existing) requires a site-specific assessment of biological resources for all development proposals in areas of the Special ES Overlay District that have been identified as ecologically sensitive habitat (such as Sign Hill Park, San Bruno Mountain State Park, and the saltmarshes along San Francisco Bay) as shown on a map or maps maintained by the City. Section

20.170.003 also requires that sensitive habitat areas be protected in the following order: (1) avoidance; (2) on-site mitigation; (3) off-site mitigation; and (4) purchase of mitigation credits.

Future development under the proposed project would be required to comply with the various federal and State laws and regulations and with requirements of the South San Francisco Zoning Ordinance and the General Plan Update policies and actions related to biological resources. To further enhance and ensure protection of threatened and endangered species, as well as nesting City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 108 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx and migratory birds, MM BIO-1 requires that focused surveys be conducted. Implementation of these requirements, policies, and actions will have both direct and indirect beneficial effects for species by avoiding the most biologically sensitive areas, concentrating development in previously disturbed areas, requiring surveys, and by emphasizing avoidance, minimization, and mitigation of impacts to habitats (Draft Program EIR, Page 3.3-18-22).

The City finds that MM BIO-1 is feasible, is adopted, and will further reduce impacts related to species and habitat. Accordingly, the City finds that, pursuant to Public Resources Code Section 21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project that mitigate or avoid the potentially significant impacts as identified in the EIR. Therefore, impacts associated with biology would be less than significant with mitigation incorporated.

Potential Effect
Impact BIO-3 The proposed project could 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 (Draft Program EIR, Page 3.3-23-25).

Findings: Less than significant impact with mitigation incorporated. (Draft Program EIR, Page 3.3-25.) Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effects as identified in the EIR. (State CEQA Guideline§ 15091(a)(1).)
Mitigation Measures
MM BIO-3 Assess Potential Wetland Impacts
Applicants or sponsors of projects on sites where potential jurisdictional wetlands or waterways are present shall retain a qualified Biologist/wetland regulatory specialist to conduct a site investigation and assess whether wetland or waterway features are jurisdictional with regard to the United States Army Corps of Engineers (USACE), Regional Water Quality Control Board (RWQCB), and/or California Department of Fish and Wildlife (CDFW). This investigation shall include assessing potential impacts to wetlands and other waters of the United States and/or State. If a feature is found to be jurisdictional or potentially jurisdictional, the project applicant or sponsor shall comply with the appropriate permitting process with each agency claiming jurisdiction prior to disturbance of the feature, and a qualified Biologist/wetland regulatory specialist shall conduct a detailed wetland delineation if necessary.

Facts in Support of Findings: Estuarine and marine wetlands line the City’s coastline and parts of Colma Creek and San Bruno Creek. A navigable slough is located south of Colma Creek in the southeastern portion of the City. Subsequent development under the proposed project, primarily adjacent to the San Francisco Bay, could result in direct or indirect effects on estuarine habitat and other sensitive marine communities. Federally protected wetlands and other waters of the United States and/or State could be affected through direct removal, filling, hydrological interruption City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 109
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx (including dewatering), alteration of bed and bank, and other construction-related activities, which could result in significant environmental impacts.

The General Plan Update Policy ES-2.1 requires the City to protect and expand existing marsh and wetland habitat to improve water quality, adapt to climate change, and provide habitat for wildlife.

Policy ES-2.2 requires the City to maintain standards and guidelines for new construction within 150 feet of San Francisco Bay that support the health of the Bay, such as requiring no net new impervious areas, maintaining (or increasing) building setbacks to support habitat areas, and requiring the installation of bioswales to treat runoff before it enters the Bay. Policy ES-3.3 requires the City to maintain development standards and guidelines for new construction within 80 feet of Colma Creek, such as requiring no net new impervious areas, maintaining, or increasing building setbacks to support habitat areas, and encouraging new construction to construct bioswales or similar features to treat runoff before it enters the creek. Policy ES-7.1 requires the City to partner with regional and local agencies to develop a comprehensive watershed management strategy that identifies programs, partnerships, actions, and incentives that the City and partners can take to protect the City’s water resources and aquatic areas.

The South San Francisco Zoning Ordinance Section 20.170.003 (Habitat and Biological Resource Conservation Areas) (existing) requires a site-specific assessment of biological resources for all development proposals in areas of the Special ES Overlay District that have been identified as ecologically sensitive habitat, such as the saltmarshes along San Francisco Bay. Section 20.170.003 (existing) requires that approval of a development permit for a project on a site located within an area identified as ecologically sensitive habitat shall not occur unless the applicable review body first finds that there has been “no net loss” of wetlands and that disturbed wetlands have been replaced with the same type of wetlands.

MM BIO-3 requires that a qualified Biologist/wetland regulatory specialist conduct a site investigation and assessment. Future development under the proposed project would comply with adopted State, federal, and local regulations for the protection of wetlands and waters of the United States and/or State, including Section 404 and 401 of the Clean Water Act (CWA). In addition, future projects would comply with requirements of the South San Francisco Zoning Ordinance and the General Plan Update policies and actions related to the protection of these biological resources.

Lastly, future development would be required to implement MM BIO-3 (Draft Program EIR, Page 3.3- 23-26).

The City finds that MM BIO-3 is feasible, is adopted, and will further reduce impacts related to wetlands and biological resources. Accordingly, the City finds that, pursuant to Public Resources Code Section 21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project that mitigate or avoid the potentially significant impacts as identified in the EIR. Therefore, impacts associated with biology would be less than significant with mitigation incorporated.

City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 110 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx Potential Effect
Impact BIO-4 The proposed project could interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors or impede the use of wildlife nursery sites. (Draft Program EIR, Page 3.3-26—27).

Findings: Less than significant impact with mitigation incorporated.

Mitigation Measures
Implement MM BIO-1 and MM BIO-3.

Facts in Support of Findings: The San Francisco Bay provides essential natural resources for migratory birds on the Pacific Flyway. Pockets of parks and open space within the City provide space for wildlife and Colma Creek, San Bruno Creek, and Navigable Slough of San Bruno Creek provide connections between these open areas. The City’s urban forest canopy can support the movement of a variety of migratory bird species, while creeks and drainages typically serve as movement corridors for wildlife.

Future development under the proposed project would comply with adopted State, federal, and local regulations for the protection of biological resources. Future projects would also comply with requirements of the South San Francisco Municipal Code and Zoning Ordinance and the General Plan Update policies and actions related to biological resources. MM BIO-1, which requires that focused surveys be conducted to determine whether special-status species, nesting birds, or migratory birds occur on a given project site, and that potential impacts to special-status species be avoided and minimized, would also protect wildlife movement corridors. MM BIO-3, which requires that a site investigation and assessment be conducted for projects on sites where potential jurisdictional wetlands or waterways are present, and compliance with the appropriate permitting process with each agency claiming jurisdiction prior to disturbance of the feature, would also protect wildlife movement corridors.

Many of the policies and actions already discussed above have both direct and indirect benefits of protecting movement habitat for wildlife, including Policy ES-1.1, Policy ES-1.2, Policy ES-1.3, Policy ES-1.4, Policy ES-2.1, Policy ES-3.1, and Action ES-2.2.1. Implementation of these policies and actions, as well as MMs BIO-1 and BIO-3, therefore, would have both direct and indirect beneficial effects for protecting regional wildlife linkages and facilitating wildlife movement.

The City finds that MM BIO-1 and MM BIO-3 are feasible, are adopted, and will further reduce impacts related to wildlife linkages and movement. Accordingly, the City finds that, pursuant to Public Resources Code Section 21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project that mitigate or avoid the potentially significant impacts as identified in the EIR. Therefore, impacts associated with biology would be less than significant with mitigation incorporated.

1.6.3 - Geology, Soils, and Seismicity
Potential Effect
Impact GEO-6 The proposed project could directly or indirectly destroy a unique paleontological resource or site or unique geologic feature. (Draft Program EIR, Page 3.6-28-29.) Findings: Less than significant impact with mitigation incorporated. (Draft Program EIR, Page 3.6-29.) Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effects as identified in the EIR (State CEQA Guidelines § 15091(a)(1)).

Mitigation Measures
MM GEO-6 Applicants, owners, and/or sponsors of all future development or construction projects shall be required to perform or provide paleontological monitoring for all proposed excavations in the Colma Formation and Merced Formation, including those buried in the shallow subsurface below Quaternary deposits, due to the high paleontological sensitivity for significant resources in these areas. Should significant paleontological resources (e.g., bones, teeth, well-preserved plant elements) be unearthed by the future project construction crew, the project activities shall be diverted at least 15 feet from the discovered paleontological resources until a professional vertebrate Paleontologist has assessed such discovered resources and, if deemed significant, such resources shall be salvaged in a timely manner. The applicant/owner/sponsor of said project shall be responsible for diverting project work and providing the assessment including retaining a professional vertebrate Paleontologist for such purpose. Collected fossils shall be deposited by the applicant/owner/sponsor in an appropriate repository (e.g., University of California Museum of Paleontology (UCMP), California Academy of Sciences) where the collection shall be properly curated and made available for future research.

Facts in Support of Findings: Any project involving earthmoving activity could potentially result in inadvertent discovery and disturbance of paleontological resources during grading and excavation work. The paleontological records search conducted for the proposed project indicates that the potentially fossiliferous areas in the Planning Area are the Merced Formation and the Colma Formation. As such, construction-related and earth-disturbing actions from development facilitated by the proposed project within the Merced Formation and Colma Foundation have the potential to damage or destroy fossils resulting in significant impacts on paleontological resources. With implementation of Mitigation Measure (MM) GEO-6, detailed above, potential impacts to paleontological resources would be reduced to less than significant.

The remaining portions of the Planning Area have a low paleontological sensitivity and low paleontological potential. Nonetheless, in the unlikely event that any earth-disturbing constructionrelated activities uncover significant paleontological resources, potential impacts to paleontological resources would be minimized through compliance with federal and State laws that protect paleontological resources. Section 5097 of the Public Resources Code specifies procedures to be followed in the event of unexpected discovery of paleontological resources. Compliance with Section City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 112 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx 5097 of the Public Resources Code would minimize the potential to impact paleontological resources directly and indirectly within the portions of the Planning Area that have a low paleontological sensitivity and low paleontological potential, and impacts would be less than significant (Draft Program EIR, Page 3.6-28-29).

The City finds that MM GEO-6 is feasible, is adopted, and will further reduce impacts related to paleontological resources. Accordingly, the City finds that, pursuant to Public Resources Code Section 21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project that mitigate or avoid the potentially significant impacts as identified in the EIR. Therefore, impacts associated with paleontological resources would be less than significant with mitigation incorporated.

1.6.4 - Noise
Potential Effect
Impact NOI-1 The proposed project could generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. (Draft Program EIR, Pages 3.11-24-32.)
Findings: Less than significant impact with mitigation incorporated. (Draft Program EIR, Page 3.11-

32.) Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effects as identified in the EIR (State CEQA Guidelines § 15091(a)(1)).

Mitigation Measures
MM NOI-1 Operational Noise Reduction Plan
Prior to issuance of building permits, the project applicant or sponsor shall implement the following measures to limit on-site operational stationary noise source impacts:

Any proposed development projects that include parking areas, terminals, or loading docks of commercial or industrial land uses within 300 feet of a residential receptor shall demonstrate compliance with Policies NOI-1.1 and NOI-1.2 of the City’s Noise Element by submitting a final acoustical report prepared to the satisfaction of the Planning Division that identifies design measures to adequately minimize the potential noise impacts of vehicles on the site to adjacent land uses. The report must be approved by the Planning Division prior to issuance of building permits.

For any future development project that would include exterior mechanical systems (such as mechanical ventilation systems) within 50 feet of a residential receptor, the project applicant or sponsor shall submit a final acoustical report prepared to the satisfaction of the Planning Division that demonstrates compliance of the project with Policies NOI-1.1 and NOI-1.2 of the City’s Noise Element. Noise reduction design features may include, but are not limited to, locating stationary noise sources City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 113
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx on the site to be shielded by structures (buildings, enclosures, or sound walls) or by using equipment that has a quieter rating. The report must be approved by the Planning Division prior to issuance of building permits.

Facts in Support of Findings: The proposed project could result in new residential and nonresidential uses within the Planning Area. Additionally, the proposed project may result in other private and public improvements throughout the City that have the potential for environmental effects related to noise. The General Plan Update includes policies that require preparation of acoustical studies for residential development where the existing noise levels exceed an exterior noise level of 65 dBA CNEL. Additionally, General Plan Update policies require that new office and commercial development be designed to reduce interior noise levels. Individual development projects would be required to demonstrate compliance with these standards during the design review process. The applicable chapters of the Municipal Code and Zoning Ordinance, including the revised chapters of the Zoning Ordinance that are part of the proposed project, reiterate compliance with the noise performance thresholds identified in the Municipal Code.

Construction activity can temporarily increase noise, while traffic and stationary noise sources related to future development projects can result in permanent noise increase. Potential temporary and permanent noise increase impacts from construction and operation of the proposed project are analyzed below.

Temporary Construction Noise Increases
A significant impact would occur if noise producing construction activities from the proposed project exceed noise performance standards during certain hours depending on land use as permissible by the City’s Municipal Code listed on page 3.11-25 of the Draft Program EIR. An exception to these standards may only be granted if an application for construction-related exception is submitted and considered by the City Manager or the manager’s designee in accordance with Section 8.32.060 of the Municipal Code.

The proposed project does not include specific development proposals, thus exact noise levels, locations, or time periods for construction of such projects cannot be determined. However, sites adjacent to areas where future development/redevelopment is anticipated to occur could expose people to construction noise throughout the construction period. Because construction is performed in discrete steps with unique noise characteristics, noise levels vary as construction progresses.

However, similarities in the dominant noise sources and patterns of operation allow construction noise ranges to be categorized by work phase. The site preparation phase, which includes excavation and grading activities, generate the highest noise levels. Typical noise levels of construction equipment as measured at a distance of 50 feet from the operating equipment are shown in Table

3.11-2 of the Draft Program EIR.

The City has not adopted numeric thresholds of significance for construction noise. However, the City has adopted mandatory requirements in the South San Francisco Municipal Code and General Plan Update that will ensure that construction noise associated with General Plan implementation remains less than significant. Municipal Code Section 8.32.050, as previously mentioned, regulates the time when construction activities may occur, and an exception may be granted to these hours City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 114 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx only if an application for construction-related exception is made to and considered by the City Manager or the City Manager’s designee. Section 8.32.050 of the Municipal Code is applied to all construction permits and compliance is mandatory and is monitored by City grading and building department personnel and is also monitored and addressed through reporting by members of the public when construction hours are not being observed. Furthermore, Policy NOI-1.2 of the Noise Element requires enforcement of the City’s Noise Ordinance noise performance standards. In addition, the Actions of Policy NOI-1.2 include the requirement to restrict construction activities to acceptable time periods and to consider constructing temporary sound walls surrounding construction sites during construction. This ensures that construction noise will not occur to a level beyond what is stipulated in the Municipal Code when residents are most vulnerable to noise disturbance.

This analysis identifies the worst-case, loudest phase of construction and identifies the compliance requirements that would reduce this worst-case impact to less than significant. Therefore, other phases of construction that would produce lower noise levels would similarly be reduced to less than significant with the same compliance requirements. Compliance with mandatory requirements of the Municipal Code and General Plan Update will ensure that construction noise occurs only at appropriate times of day and is minimized to acceptable levels.

Permanent Traffic Noise Increases
A significant impact would occur if traffic generated by the proposed project would result in a substantial increase in ambient noise levels compared with existing conditions. The County does not define “substantial increase.” For purpose of this analysis, a substantial increase is based on the following criteria. A characteristic of noise is that audible increases in noise levels generally refer to a change of 3 dBA or more, as this level has been found to be barely perceptible to the human ear in outdoor environments. A change of 5 dBA is considered the minimum readily perceptible change to the human ear in outdoor environments. Therefore, for purposes of this analysis, a significant impact would occur if the proposed project would cause the CNEL to increase by any of the amounts listed on page 3.11-27 of the Draft Program EIR.

As identified in Table 3.11-7 of the Draft Program EIR, noise environments with noise levels of up to 65 dBA CNEL are considered normally acceptable for residential land use developments, industrial and commercial land use development, and for open land use areas and schools.

The FHWA highway traffic noise prediction model (FHWA-RD-77-108) was used to evaluate existing and future traffic noise conditions with implementation of the proposed project along modeled roadway segments in the vicinity of the Planning Area. Traffic modeling was performed using the data provided by Fehr & Peers. The traffic noise modeling input and output files included in Appendix G of the Draft Program EIR. Table 3.11-8 of the Draft Program EIR shows a summary of the traffic noise levels for year 2040 projected traffic conditions without and with the proposed project, as measured at 50 feet from the centerline of the outermost travel lane. Several of the modeled roadway segments would experience a reduction in traffic noise levels with implementation of the proposed project, compared to conditions that would exist without the proposed project, due to lower anticipated average daily trips generated by the proposed land uses compared to the total development that could occur under the existing General Plan. The highest increase that would City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 115
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx occur along these modeled roadway segments would be a 1.7 dBA increase above conditions without the proposed project and would occur along Grand Avenue from Linden Avenue to Airport Boulevard. According to the significance impact criteria identified above, a 5 dBA increase would be considered significant for these conditions.

Although this analysis evaluates buildout of the proposed project against baseline conditions, it is important to note that the development contemplated by the proposed project is consistent with development already allowed under the existing General Plan. Accordingly, it is reasonable to assume that development consistent with the existing General Plan would potentially occur absent the adoption of the General Plan Update. While development envisioned by the proposed project would result in an incremental increase in development in the Planning Area, future development would be required to comply with requirements of the General Plan Update and City of South San Francisco Municipal Code protecting against noise impacts. Specifically, Policy 1-1 requires that all new development within the City complies with the Land Use/Noise Compatibility guidelines, along with associated Actions which require that projects must be assessed through the subdivision, site plan, conditional use permit, and other development review processes, and that such projects must incorporate conditions of approval and mitigation measures that ensure noise compatibility where appropriate. In addition, Section 20.300.009 (Performance Standards) (revised) of the Zoning Ordinance also establishes land use development requirements and limitations, as well as acoustic design requirements for development in noise impacted areas.

Permanent Stationary Source Noise Increases
A significant impact would occur if operational noise levels generated by stationary noise sources at development projects under the proposed project exceed noise performance standards listed on page 3.11-30 of the Draft Program EIR. Future development projects under the proposed project would include new stationary noise sources such as parking lot activities, and mechanical ventilation system equipment. These would be potential point sources of noise that could affect noise-sensitive receptors in the vicinity of the proposed project.

Parking Lot and Truck Loading/Unloading Activities
Typical parking lot activities generate noise levels ranging from approximately 60 dBA to 70 dBA Lmax at 50 feet. Noise levels from typical rooftop unit mechanical ventilation equipment range from 50 dBA to 60 dBA Leq at a distance of 25 feet. Typical maximum noise levels from truck loading and unloading activity are 70 dBA to 80 dBA Lmax as measured at 50 feet. These stationary source operational noise levels could exceed the City’s noise performance thresholds if they were to occur in areas adjacent to sensitive receptor land uses. With implementation of Mitigation Measure (MM) NOI-1, detailed above, impacts generated by future development projects under the proposed project would be reduced to less than significant.

Mechanical Equipment Operations
Noise levels from commercially available mechanical ventilation equipment range from 50 dBA to 60 dBA Leq at a distance of 25 feet. These stationary source operational noise levels could exceed the City’s thresholds if they were to occur in areas adjacent to sensitive receptor land uses. With implementation of MM NOI-1, detailed above, impacts generated by future development projects under the proposed project would be reduced to less than significant (Draft Program EIR, Pages 3.11- 24-3.11-32).

City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 116 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx The City finds that MM NOI-1 is feasible, is adopted, and will further reduce impacts related to noise impacts on sensitive receptors. Accordingly, the City finds that, pursuant to Public Resources Code Section 21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project that mitigate or avoid the potentially significant impacts as identified in the EIR. Therefore, impacts associated with noise would be less than significant with mitigation incorporated.

Potential Effect
Impact NOI-3 The proposed project could expose people residing or working in the plan area to excessive noise levels 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 (Draft Program EIR, Pages 3.11- 34-35).

Findings: Less than significant impact with mitigation incorporated. (Draft Program EIR, Page 3.11-

35.) Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effects as identified in the EIR (State CEQA Guidelines § 15091(a)(1)).

Mitigation Measures
MM NOI-3 Airport Noise Impact Reduction Plan
Prior to issuance of building permits, the project applicant or sponsor of proposed development projects shall implement the following measures to limit airport activity noise source impacts:
• Any proposed residential development project or any hotel, motel, or transient lodging land use development project, that would be located within the San Francisco International Airport (SFO) 65 A-weighted decibel (dBA) Community Noise Equivalent Level (CNEL) noise contours, shall demonstrate compliance with Policies NOI-1.1 and NOI-1.2 of the City’s Noise Element by submitting a final acoustical report prepared to the satisfaction of the Planning Division that identifies design measures to adequately minimize airport activity noise levels to meet the interior noise level standards shown in Table 11 of the Noise Element.

Outdoor active use space must also comply with the exterior noise standards of Table 11 of the Noise Element or must be excluded from such projects. The report must be approved by the Planning Division prior to issuance of building permits. • Any proposed commercial development project that would be located within the SFO 70 dBA CNEL noise contours shall demonstrate compliance with Policies NOI1.1 and NOI-1.2 of the City’s Noise Element by submitting a final acoustical report prepared to the satisfaction of the Planning Division that identifies design measures to adequately minimize airport activity noise levels to meet the interior noise level standards shown in Table 11 of the Noise Element. The report must be approved by the Planning Division prior to issuance of building permits.

Facts in Support of Findings: The City of South San Francisco experiences air traffic noise impacts due to its proximity to SFO. Aircraft noise in the City results from aircraft departing from Runway 28 and from Runway 1. Flights departing from Runway 28 climb directly over noise-sensitive land uses resulting in high pass-by noise levels in residential areas, including areas outside the contours that define noise-impacted areas. The proposed project does not propose additional special events or sources of single-event noise in the form of aircraft flyover noise. Therefore, the proposed project would not result in changes in the 65 dBA CNEL airport noise contours and would not increase airport noise impacts.

However, future development could introduce noise-sensitive land uses to excessive aircraft noise levels if they would occur within the 65 dBA CNEL contours of the airport. Any local plans, policy actions or development activities that affect areas within the 65 dBA CNEL contour established in the SFO ALUCP must receive San Mateo County ALUC approval or have a finding of overriding consideration prior to local permit issuance. The proposed project envisions future development that could occur within the 65 dBA CNEL noise contours which could expose persons residing or working at these areas to noise levels from airport activity that would be in excess of normally acceptable land use compatibility standards. For example, the proposed project includes planned mixed-use residential areas east of US-101 which would lie within the airport’s runway safety zone boundaries and the SFO 65 dBA CNEL noise contours shown on Exhibit 3.11-2 of the Draft Program EIR.

These airport activity noise levels could exceed the City’s noise/land use compatibility standards for certain land uses. Therefore, mitigation would be required to reduce this potential impact. With implementation of MM NOI-3, detailed above, impacts generated by future development projects under the proposed project would be reduced to less than significant (Draft Program EIR, Pages 3.11- 34-35).

The City finds that MM NOI-3 is feasible, is adopted, and will further reduce noise impacts.

Accordingly, the City finds that, pursuant to Public Resources Code Section 21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project that mitigate or avoid the potentially significant impacts as identified in the EIR. Therefore, impacts associated with noise would be less than significant with mitigation incorporated.

City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 118 FirstCarbon Solutions
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1.7 - Impacts Identified in the Draft Program EIR as Being Significant and Unavoidable Even After the Incorporation of All Feasible Mitigation Measures The City of South San Francisco hereby finds that, despite the incorporation of mitigation measures outlined in the Draft Program EIR and the attached MMRP, the following impacts from the proposed project and related approvals cannot be fully mitigated to a less than significant level and a Statement of Overriding Considerations is therefore included herein.

1.7.1 - Air Quality
Impact AIR-1 The proposed project would conflict with or obstruct implementation of an applicable air quality plan (Draft Program EIR, Page 3.2-35-50).

Mitigation Measures
MM AIR-1a Individual development projects facilitated by the proposed project shall incorporate the following Basic Construction Mitigation Measures recommended by the Bay Area Air Quality Management District (BAAQMD):
• All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day. • All haul trucks transporting soil, sand, or other loose material off-site shall be covered.
• All visible mud or dirt trackout onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.
• All vehicle speeds on unpaved roads shall be limited to 15 mph. • All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.

MM AIR-1b Projects that may result in additional toxic air contaminants (TACs) that are located within 1,000 feet of a sensitive receptor(s) or would place sensitive receptors within 1,000 feet of uses generating TACs, such as roadways with volumes of 10,000 average annual daily trips or greater, shall implement Bay Area Air Quality Management District (BAAQMD) Guidelines and California Office of Environmental Health Hazard Assessment (OEHHA) policies and procedures requiring a Health Risk Assessments (HRA) for residential development and other sensitive receptors.

MM TRANS-1 Transportation Demand Management
To reduce Vehicle Miles Traveled (VMT), the City shall implement its Transportation Demand Management (TDM) Ordinance as part of the Zoning Code Amendments and parking requirements. The City shall also update its TDM Ordinance and parking requirements every five to ten years and establish an East of 101 Area Trip Cap, to achieve the maximum feasible reductions in vehicle travel. The City shall achieve the performance standards outlined in the TDM Ordinance.

The City shall update its TDM Ordinance every 5 to 10 years to limit Total VMT and Work-Based VMT by incentivizing use of transit and active transportation and disincentivizing auto use. The TDM Ordinance shall cover all development projects generating greater than 100 daily trips, with the most stringent requirements for office/Research and Development (R&D) land uses that disproportionately account for the highest rates of VMT in the City. Development projects shall implement a combination of TDM programs, services, and infrastructure improvements, including but not limited to: establishing trip reduction programs; subsidizing transit and active transportation use; coordinating carpooling and vanpooling; encouraging telecommuting and flexible work schedules; designing site plans to prioritize pedestrian, bicycle, and transit travel; funding first/last mile shuttle services; establishing site-specific trip caps; managing parking supply; and constructing transit and active transportation capital improvements. Developments shall be subject to annual monitoring. The City shall establish an administrative fine structure for developments found to be out of compliance and apply any revenues from fines to infrastructure and services aimed at reducing VMT.

The City shall establish an East of 101 Area Trip Cap to support the monitoring of vehicle trip activity and focus efforts to reduce VMT. The area-wide trip cap shall apply to the high-density employment uses in the East of 101 Area. The City shall conduct annual traffic counts along the cordon area perimeter. Should the trip cap be reached, the City shall consider corrective actions such as: revising mode share targets for projects subject to the TDM Ordinance, identifying new funding measures for TDM services, implementing new vehicle user charges, creating new street connections, or slowing the pace of development approvals within the cordon zone.

City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 120 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx The City shall update its parking requirements every 5 to 10 years to align with its TDM Ordinance and East of 101 Area Trip Cap. The City shall establish parking maximums for office/R&D uses to ensure that VMT reduction goals are incorporated into the design of development projects.

Facts in Support of Findings: According to the BAAQMD’s guidance, a proposed land use plan would be consistent with the AQP if it would: (1) support the primary goals of the AQP, (2) include applicable control measures from the AQP, (3) not disrupt or hinder implementation of any AQP control measures, and (4) the plan’s projected VMT increase must be less than or equal to its projected population growth.
(1) The proposed project supports the primary goals of the AQP: The primary goals of the 2017 Bay Area Clean Air Plan are to attain air quality standards, reduce population exposure and protect public health, and reduce GHG emissions and protect the climate.

The proposed project would be consistent with the 2017 Bay Area Clean Air Plan’s primary goal of achieving and maintaining attainment status for AAQS as the land use patterns in the proposed project would not be substantially different from existing land use patterns. In addition to existing regulations in the Municipal Code, the proposed project includes several policies and actions related to improving air quality, including Policy CHEJ-3.1, Action CHEJ-3.1.1, Action CHEJ-3.2, Action CHEJ3.2.2, Action CHEJ-3.3.2, Policy CEHJ-3.5, Policy CR-6.1, and Policy CR-6.5. The CAP includes several actions that assist in reducing or avoiding impacts related to air quality. Several of the CAP measures focus on reducing VMT and consequently mobile source emissions, as well as promoting green building design which reduces indirect air quality associated with the building envelope. These include Action CE-1.1, CE-1.3, CE-1.6, TL-1.1, TL-2.2, and TL-2.6, as well as the South San Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of the proposed project, including Section 20.300.008 (Lighting and Illumination), Section 20.480 (Design Review), and Section 20.300.010 (Performance Standards). Furthermore, as discussed in Impact AIR-2, individual development projects would be required to undergo their own respective CEQA environmental review, including an analysis of potentially significant impacts on local and regional air quality and consideration of an individual development project’s contribution to an existing or forecasted air quality violation. MM AIR-1a would be required to ensure that individual development projects would result in less than significant construction fugitive dust impacts. MM AIR-1a contains BAAQMD’s “Basic Construction Mitigation Measures Recommended for All Proposed Projects.” The daily VMT per service population (employees + residents) is anticipated to be reduced from

27.42 VMT per service population for existing conditions to 26.80 VMT per service population for proposed project buildout conditions (see Draft Program EIR, Section 3,14, Transportation.) The reduction in VMT per service population would reduce the population’s exposure to TACs from transportation-related sources. As identified in the discussion of community risk and hazards (see Impact AIR-3), new sensitive land uses could be proximate to sources of TACs, and new commercial land uses could generate an increase in TACs. As discussed in Impact AIR-3, mandatory compliance with BAAQMD regulations would ensure that new sources of TACs do not expose populations to significant health risk. Consistent with BAAQMD’s CEQA Air Quality Guidelines, the proposed project City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 121
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx would not result in a potentially significant community risk and hazard impact if the land use diagram identifies special overlay zones around existing and planned sources of TACs, including special overlay zones of at least 500 feet on each side of all freeways and high-volume roadways (or another BAAQMD-approved modeled distance), and the plan identifies goals, policies, and objectives to minimize potentially adverse impacts. Because the proposed project does not currently contain a land use diagram which identifies special overlay zones around existing and planned sources of TACs, MM AIR-1b would be required to ensure that future development facilitated by the proposed project would result in less than significant impacts related to exposing sensitive receptors to substantial pollutant concentrations. Measures identified in HRAs shall be included into the site development plan as a component of the project. MM AIR-1b would ensure that future development facilitated by the proposed project would result in less than significant impacts to sensitive receptors related to operational TACs. Implementation of new and revised General Plan Update and CAP policies and programs would reduce community risk and hazards. Lastly, future development would be required to comply with Section 20.300.010 (Performance Standards) of the Zoning Ordinance.

As discussed in Section 3.7, Greenhouse Gas Emissions, implementation of the proposed project would substantially contribute to the region’s achievement of the 2030 Statewide GHG reduction goal and is forecasted to advance toward the 2050 Statewide goal. In addition, the proposed project is consistent with regional strategies for infill development identified by the MTC/ABAG in the Plan Bay Area.

Consequently, the proposed project is consistent with the goals of the 2017 Bay Area Clean Air Plan to reduce GHG emissions.
(2) The Proposed Project Includes Applicable Control Measures From the AQP: The proposed project includes the applicable control measures from the AQP. Table 3.2-5 from the Draft Program EIR identifies the applicable control measures included in the 2017 Clean Air Plan and the General Plan Update and CAP policies and actions, as well as regulations in the South San Francisco Municipal Code and Zoning Ordinance related to the control measures.

Measures not included in Table 3.2-5 were determined by the City to not be applicable to the proposed project. As shown in Table 3.2-5, the General Plan Update, South San Francisco Zoning Ordinance, CAP, and South San Francisco Municipal Code include policies, actions, and requirements that incorporate and implement the control measures included in the 2017 Clean Air Plan. As such, the proposed project would be consistent with the 2017 Clean Air Plan under this criterion.
(3) The Proposed Project Would Not Disrupt or Hinder Implementation of Any AQP Control Measures: As shown in Table 3.2-5, the General Plan Update and South San Francisco Municipal Code incorporate and are consistent with the control measures included in the 2017 Clean Air Plan. The proposed project does not include any components that would disrupt or hinder implementation of any control measures, such as precluding an extension of a planned transit line or bike bath or proposing excessive parking. As previously discussed, control measures not included above would not pertain to the proposed project as a long-range land use planning document, such as Control Measure SS7, Sulfuric Acid Plants, which calls for the consideration of amending District Rule 9-1 to limit SO2 emissions from acid plants associated with petroleum refining or Control Measure TR1, Clean Air Teleworking Initiative, that calls for the development of teleworking best practices for City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 122 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx employers. Measures not included in Table 3.2-5 were determined by the City to not be applicable to the proposed project. Please refer to the BAAQMD’s 2017 Clean Air Plan for more information on all 55 control measures. As such, the proposed project would not hinder the BAAQMD from implementing the control measures in the 2017 Clean Air Plan. (4) The Proposed Project Would Not Reduce VMT Per Capita: The increase in daily VMT from implementation of the proposed project has been analyzed in Section 3.14, Transportation, which found that the total daily VMT would increase from the existing (year 2019) 3,387,200 VMT to 6,585,400 VMT in 2040 with buildout of the proposed project, resulting in a net increase of 3,198,200 daily VMT. As discussed in Section 3.14, Transportation, the City’s population would grow from an estimated 67,200 people under existing conditions to an estimated 108,100 people in 2040 with buildout of the proposed project. As such, the proposed project would facilitate an estimated population growth of 40,900 people by 2040. The VMT growth facilitated by the proposed project would constitute an approximately 94 percent growth through 2040 while population growth facilitated by the proposed project would constitute an approximately 61 percent growth through 2040. The forecasted VMT growth would outpace the forecasted population growth facilitated by the proposed project. Therefore, the proposed project would be considered inconsistent with the 2017 Clean Air Plan. The proposed project would implement MM TRANS-1, which would require the City to implement its Transportation Demand Management (TDM) Ordinance as part of the Zoning Code Amendments and parking requirements to reduce project-generated VMT. MM TRANS-1 also requires the City to update its TDM Ordinance and parking requirements every 5 to 10 years and establish an East of 101 Area Trip Cap, to achieve the maximum feasible reductions in vehicle travel. However, even with the implementation of the General Plan Update policies and actions and implementation of MM TRANS-1, because the effectiveness of VMT reduction strategies cannot be quantified in this programmatic analysis, the City of South San Francisco may not achieve the overall VMT threshold reduction level. As such, this impact would be significant and unavoidable.

In conclusion, overall development facilitated by the proposed project would be inconsistent with the 2017 Clean Air Plan, since it would facilitate VMT growth which outpaces the forecasted population growth. Nonetheless, the proposed project would support the primary goals of the AQP, include applicable control measures from the AQP, and neither disrupt nor hinder implementation of any AQP control measures. Because the proposed project would facilitate VMT growth which outpaces forecasted population growth through 2040, the proposed project would conflict with the 2017 Clean Air Plan and impacts would be significant and unavoidable after mitigation. (Draft Program EIR, Page 3.2-34-50).

The City finds that MM AIR-1a, MM AIR-1b and MM TRANS-1 are feasible, are adopted, and will reduce VMT impacts to the extent feasible. Accordingly, the City finds that, pursuant to Public Resources Code Section 21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the project that mitigate or reduce the potentially significant impacts as identified in the EIR to the extent feasible. However, impacts associated with VMT growth would remain significant and unavoidable even with mitigation incorporated.

3.2-50-54).

Mitigation Measures
Implement MM AIR- 1a and MM TRANS-1.

Facts in Support of Findings: Construction: Future development supported by the proposed project would result in short-term construction-related criteria pollutant emissions that have the potential to have an adverse effect on air quality. Short-term criteria pollutant emissions would occur during demolition, site preparation, grading, building construction, paving, and architectural coating activities associated with individual development projects. ROG and NOX emissions are primarily associated with gasoline and diesel equipment exhaust and the application of architectural coatings.

Fugitive dust emissions (PM10 and PM2.5) are primarily associated with site preparation and vary as a function of such parameters as soil silt content, soil moisture, wind speed, acreage of disturbance area, and VMT by construction vehicles on- and off-site. Typical construction equipment associated with development and redevelopment projects includes dozers, graders, excavators, loaders, and trucks.

Although the exact coverage, location, or duration of future construction projects is unknown at the time of preparation of the Draft Program EIR, future development activities would generally entail demolition, site preparation, grading, building construction, paving, and painting. Since South San Francisco is generally a built-out city, many new projects in the City will likely require the demolition of existing structures to make room for newer ones. In addition, the proposed project may result in other private and public improvements throughout the City. Fugitive dust emissions would typically be greatest during building demolition, site preparation, and grading due to the disturbance of soils and transport of material. NOX emissions would also result from the combustion of diesel fuels used to power off-road heavy-duty vehicles and equipment (e.g., backhoes, bulldozers, excavators). The types and quantity of equipment, as well as duration of construction activities, would be dependent on project-specific conditions. Larger projects would require more equipment over a longer time frame than that required for redevelopment of a single, residential home or small residential or mixed-use project.

The BAAQMD maintains and recommend project-level thresholds would apply to potential future development projects. In addition, the BAAQMD’s CEQA Air Quality Guidelines identify and recommend a series of “Basic” measures to control and reduce construction-related emissions. For City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 124 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx all projects, the BAAQMD recommends implementation of eight Basic Construction Measures to reduce construction fugitive dust emissions. The BAAQMD determines a less than significant impact with respect to construction fugitive dust emissions when following Basic Construction Measures highlighted in the Draft Page EIR at page 3.2-51. MM AIR-1a would be required to ensure that individual development projects facilitated by the proposed project would result in less than significant impacts. MM AIR-1a contains BAAQMD’s “Basic Construction Mitigation Measures Recommended for All Proposed Projects” in the bullet points listed above and contained in the BAAQMD’s 2017 CEQA Air Quality Guidelines, which are recommended by the BAAQMD to ensure construction fugitive dust emissions are less than significant.

Operation: The proposed project would accommodate new residential and nonresidential development that will operate through the General Plan Update horizon year 2040. Long-term criteria pollutant emissions would result from the operation of residential, retail, light industrial, commercial, and institutional uses supported by the proposed project. Operational air quality emissions are principally generated from area, energy, and mobile sources. Area source emissions are the combination of many small emission sources that include use of outdoor landscape maintenance equipment, use of consumer products such as cleaning products, use of fireplaces and hearths, and periodic reapplication of architectural coatings. Criteria pollutants generated from energy sources are principally from the on-site use of natural gas; electricity consumption is not included in energy source emissions as those potential emissions would be generated as the result of the operation of an electricity generation facility which may or may not be within the same air basin and under the same attainment status as the end-use. Mobile source emissions result from the vehicle activity associated with the operation of a given land use development project, including resident, worker, and patron vehicle trips.

Implementation of the proposed project may result in development of up to 17,153 net new residential units (based on 2019 baseline data from Fehr & Peers), and up to 14,100,523 square feet of net new nonresidential space. Future development projects would be subject to the City’s standard CEQA review process and would be required to assess project-specific emissions in relation to the BAAQMD significance thresholds.

The estimated net criteria air pollutants resulting from the proposed project are shown in the Draft Program EIR, Table 3.2-7. Overall area and energy source emissions would increase from baseline conditions as a result of the projected increase in residential units and nonresidential space. Overall mobile source emissions would decrease from baseline emissions as a result of improved fuel efficiency standards, the accelerated adoption of EVs, and fleet turnover requirements implemented at the State level through 2040 as compared to existing conditions.

As discussed in Impact AIR-1, the proposed project would be consistent with the applicable 2017 Clean Air Plan control measures. As discussed in Impact AIR-1, the VMT growth facilitated by the proposed project would constitute an approximately 94 percent growth rate through 2040, while population growth facilitated by the proposed project would constitute an approximately 61 percent growth rate through 2040. Therefore, the forecasted VMT growth would outpace the forecasted population growth facilitated by the proposed project. As such, this impact would be potentially significant. As described in Impact AIR-1, there is no reasonable mitigation that could be City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 125
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx implemented to increase population projections while keeping VMT growth to a minimum in an area that is already fully urbanized and built out, such as the City of South San Francisco; therefore, this impact would remain significant and unavoidable after mitigation (Draft Program EIR, Page 3.2-50— 54).

The City finds that MM AIR-1a and MM TRANS-1 are feasible, are adopted, and will reduce VMT impacts to the extent feasible. Accordingly, the City finds that, pursuant to Public Resources Code Section 21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the project that mitigate or reduce the potentially significant impacts as identified in the EIR to the extent feasible. However, impacts associated with VMT growth would remain significant and unavoidable even with mitigation incorporated.

Cumulative Impacts
The proposed project’s cumulative impacts related to air quality would be significant and unavoidable, even with mitigation incorporated. (Draft Program EIR, Page 3.2-58-63).

Mitigation Measures
Implement MM AIR-1a, MM AIR-1b, and MM TRANS-1.

Facts in Support of Findings: The geographic scope of the cumulative impact analysis for air quality is the Air Basin.

As discussed in Impact AIR-4, the proposed project would not result in cumulatively considerable impacts related to odor impacts or cumulatively considerable impacts exposing sensitive receptors to substantial pollutant concentrations. Nonetheless, as discussed in Impact AIR-1, the proposed project would result in an inconsistency with the 2017 Clean Air Plan and a cumulatively considerable net increase in criteria pollutants as a result of VMT growth facilitated by the proposed project. As such, the proposed project would have a cumulatively considerable contribution to a cumulative impact, even with implementation of the policies in the proposed project and all feasible mitigation.
2017 Clean Air Plan Consistency
The BAAQMD CEQA Guidelines provide that land use plans should incorporate policies and requirements that ensure they do not inhibit attainment of air quality standards and that actually assist in improving local and regional air quality. BAAQMD further recommends that air qualityrelated goals, policies, performance measures and standards should be incorporated within the context of the plan itself, rather than introduced as corrective actions within the plan’s EIR. As shown City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 126 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx in Table 3.2-5 of the Draft Program EIR, the General Plan Update, South San Francisco Zoning Ordinance, CAP, and South San Francisco Municipal Code include policies, actions, and requirements that incorporate and implement the control measures included in the 2017 Clean Air Plan. As discussed in Impact AIR-1, the proposed project would support the overall goals of the 2017 Clean Air Plan with implementation of MMs AIR-1a and AIR-1b.

BAAQMD evaluates criteria pollutants resulting from long-range plans such as the proposed project, by evaluating consistency with the AQP, as well as a comparison of project VMT to projected population increase. The proposed project would support the primary goals of the AQP, include applicable control measures from the AQP, and neither disrupt nor hinder implementation of any AQP control measures. However, as noted in Impact AIR-1, the development envisioned by the proposed project would be inconsistent with the 2017 Bay Area Clean Air Plan, since it would facilitate VMT growth which outpaces the forecasted population growth.

The SFBAAB is currently designated as a nonattainment area for PM. The BAAQMD’s recommended significance threshold for construction fugitive dust is binary–meaning a project’s construction fugitive dust emissions would be less than significant with the inclusion of dust control BMPs, and potentially significant without dust control BMPs. Implementation of MM AIR-1a, detailed above in Impact AIR-1, would ensure that individual development projects facilitated by the proposed project would result in less than significant construction fugitive dust impacts.

Consistent with BAAQMD’s CEQA Air Quality Guidelines, the proposed project would not result in a potentially significant community risk and hazard impact if the land use diagram identifies special overlay zones around existing and planned sources of TACs, including special overlay zones of at least 500 feet on each side of all freeways and high-volume roadways (or another BAAQMD-approved modeled distance), and the plan identifies goals, policies, and objectives to minimize potentially adverse impacts. The proposed project does not currently contain a land use diagram which identifies special overlay zones around existing and planned sources of TACs. Implementation of MM AIR-1b, detailed in Impact AIR-1 would ensure that future development facilitated by the proposed project would result in less than significant impacts related to exposing sensitive receptors to substantial pollutant concentrations.

Criteria Air Pollutant and Ozone Precursor Emissions
BAAQMD’s plan-level guidelines do not require an emissions inventory of criteria air pollutants for plan-level projects. Impact AIR-2 provides an inventory of criteria pollutants for informational purposes only. A plan-level analysis must demonstrate project consistency with AQP control measures and a projected VMT increase that is less than or equal to its projected population growth for this impact to be less than significant.

As explained previously, the development envisioned by the proposed project would be inconsistent with the 2017 Bay Area Clean Air Plan, since it would facilitate VMT growth which outpaces the forecasted population growth. Nonetheless, the proposed project would support the primary goals of the AQP, include applicable control measures from the AQP, and neither disrupt nor hinder implementation of any AQP control measures. The General Plan Update and CAP contain new policies and actions to reduce criteria air pollutants to the maximum extent practicable.

City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 127
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx All new development and redevelopment within the City would be required to meet the BAAQMD rules and regulations, including Regulation 6-3-306 which restricts the installation of wood burning fireplaces into a new building and Regulation 8-3-301, which limits the allowed VOC levels in the architectural coatings applied onto buildings within the City. The 2019 California Code of Regulations, Title 24, Part 6, standards also now require all homes built in California to have zeronet-energy use, which is achieved through energy efficiency measures as well required rooftop solar photovoltaic systems. The 2019 California Code of Regulations, Title 24, Part 6, standards also apply to nonresidential buildings and require a variety of energy efficiency measures to be implemented that will reduce energy usage as well as air emissions.

Therefore, compliance with the applicable policies and actions in the General Plan Update and CAP, as well applicable State and BAAQMD rules and regulations, would minimize the potential air quality impacts resulting from implementation of the proposed project, which would encourage or require the use of fuel-efficient equipment, vehicles, and BMPs. Mandatory compliance with design review regulations and policies in the South San Francisco Municipal Code and General Plan would ensure that operation-related air quality impacts from new development under the General Plan would be less than significant on an individual project basis, and the City will review those future projects under its standard design review procedures in the Municipal Code.

As previously discussed, the SFBAAB is currently designated as a nonattainment area for PM. The BAAQMD’s recommended significance threshold for construction fugitive dust is binary–meaning a project’s construction fugitive dust emissions would be less than significant with the inclusion of dust control BMPs, and potentially significant without dust control BMPs. Implementation of MM AIR-1a, detailed above in Impact AIR-1, would ensure that individual development projects facilitated by the proposed project would result in less than significant construction fugitive dust impacts.

Nonetheless, as the proposed project would facilitate VMT growth which outpaces projected population growth through the planning horizon of 2040, the proposed project would be inconsistent with the 2017 Clean Air Plan and would therefore result in a cumulatively considerable net increase in criteria air pollutants and ozone precursors, resulting in a conflict with the applicable air quality plan, even after implementation of MMs AIR-1a and AIR-1b.

Sensitive Receptor Exposure to Substantial Pollutant Concentrations As discussed under Impact AIR-3, localized risks are primarily associated with exposure to TAC emissions. Common sources of TAC emissions are stationary sources (e.g., dry cleaners, diesel backup generators, and gasoline stations), which are subject to BAAQMD permit requirements.

Another common and often more significant source type is on-road motor vehicles on high-volume roads, such as US-101, I-280, SR-82, SR-35, and off-road sources such as construction equipment and diesel-powered trains traveling on the Caltrain corridor. Although the proposed project does not include specific plans for any new, large stationary sources of emissions, it could result in new sensitive receptors (primarily residential receptors) near existing sources of emissions.

As discussed above, the proposed project would not result in a potentially significant community risk and hazard impact if the land use diagram identifies special overlay zones around existing and City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 128 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx planned sources of TACs, including special overlay zones of at least 500 feet on each side of all freeways and high-volume roadways (or another BAAQMD-approved modeled distance), and the plan identifies goals, policies, and objectives to minimize potentially adverse impacts. The proposed project does not currently contain a land use diagram which identifies special overlay zones around existing and planned sources of TACs. Implementation of MM AIR-1b, detailed in Impact AIR-1 would ensure that future development facilitated by the proposed project would result in less than significant impacts related to exposing sensitive receptors to substantial pollutant concentrations.

The General Plan Update contains several policies and actions that aim to reduce the potential growth of vehicle use through encouraging the use of alternative modes of transportation, monitoring and improving existing sources of TACs throughout the City and reducing overall health impacts related to air quality in general.

Odor Impacts
While odors could be generated during construction activities, the proposed project consists of a General Plan Update, Climate Action Plan Update, and Zoning Code Amendment and would not directly result in construction of any development project. Project-specific information for future individual land use development projects is unknown, thus identification of potential impacts related to construction-generated odors from future projects is not possible. As discussed in Impact AIR-4, the City contains several of the land uses listed by the BAAQMD as potential odor sources. As the City of South San Francisco is a fully urbanized and built-out city, it currently has, and the proposed project would facilitate future development of, sensitive receptors within the identified screening distances of existing odor sources. Consistent with the BAAQMD’s CEQA Air Quality Guidelines, a plan-level analysis must acknowledge odor sources within the Planning Area and identify policies, goals, and objectives aimed at reducing potential odor impacts to ensure that potential impacts would be less than significant.

Furthermore, the South San Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of the proposed project, contain Section 20.300.010 (Performance Standards), which establishes regulations related to odors and restricts uses, processes, or activities that produce objectionable odors that are perceptible without instruments by a reasonable person at the lot lines of a site. Sections 20.410.004 (Indoor Commercial Cannabis Cultivation), 20.410.005 (Commercial Cannabis Manufacturing), and 20.410.006 (Cannabis Testing Operations) require that operators install and maintain, in good working-order, air treatment or other ventilation systems to prevent odors generated from the cultivation of cannabis from being detected within 10 feet of the structure in which commercial cannabis cultivation occurs. In addition, BAAQMD Regulation 7 limits emissions of odorous substances within the Air Basin and would apply to any future odor source within the Planning Area (Draft Program EIR, Page 3.2-58—63).

The City finds that MM AIR-1a, MM AIR-1b, and MM TRANS-1 are feasible, are adopted, and will reduce air quality impacts to the extent feasible. Accordingly, the City finds that, pursuant to Public Resources Code Section 21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the project that mitigate or reduce the potentially significant impacts as identified in the EIR to the extent feasible. However, air quality impacts would remain significant and unavoidable even with mitigation incorporated.

1.7.2 - Transportation and Traffic
Impact TRANS-1 Implementation of the proposed project would conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b) (Draft Program EIR, Page 3.14- 35-40).

Mitigation Measures
Implement MM TRANS-1.

Facts in Support of Findings: While impacts would be less than significant for citywide Home-Based VMT Per Resident for residential use without mitigation, impacts with mitigation (MM TRANS-1) for citywide Total VMT Per Service Population and for Work-Based VMT Per Employee would remain significant and unavoidable. Even with the General Plan Update policies and mitigation measures related to the TDM Ordinance, East of 101 Area Trip Cap, and parking requirements, the City may not achieve the overall VMT threshold reduction level due to uncertainty in the cumulative effectiveness of these measures as well as unknowns related to transit service levels, transportation technology, and travel behavior. Moreover, these policies and mitigation measures primarily apply to new developments; existing land uses, and land uses that have already been approved and are under construction are generally not affected. Because of the programmatic nature of the proposed project, no additional mitigation measures are available, and the impact is considered significant and unavoidable. (Draft Program EIR, Page 3.14-35-40).

The City finds that MM TRANS-1 is feasible, is adopted, and will reduce VMT impacts to the extent feasible. Accordingly, the City finds that, pursuant to Public Resources Code Section 21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the project that mitigate or reduce the potentially significant impacts as identified in the EIR to the extent feasible. However, impacts associated with VMT growth would still have traffic impacts that remain significant and unavoidable even with mitigation incorporated.

Impact TRANS-4 Implementation of the proposed project could substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment) (Draft Program EIR, Pages 3.14-48-50).

Findings: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effects as identified in the EIR (State CEQA Guidelines § 15091(a)(1)). However, impacts would still remain significant and unavoidable even with mitigation incorporated. Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 130 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx mitigation measure or project alternatives identified in the EIR (State CEQA Guidelines § 15091(a)(3)). (Draft Program EIR, Page 3.14-50).

Mitigation Measures
Implement MM TRANS-1 and MM TRANS-4.

MM TRANS-4 Freeway Offramp Queue Improvements
To minimize queueing hazards, the City shall work with Caltrans to develop improvement measures for freeway off-ramps and adjacent intersections that help manage offramp queues. These measures may include geometric changes, changes to signal timing and phasing, and new connections as identified in Table 3.14-5. Such improvement measures shall not adversely affect pedestrian, bicycle, and transit conditions or otherwise undermine the City’s VMT mitigation efforts described in MM TRANS-1. MM TRANS-1 is also applicable here and should be implemented to minimize freeway offramp queues.

Facts in Support of Findings: Even with the implementation of General Plan Update policies and actions and implementation of MMs TRANS-4 and TRANS-1, given the uncertainty around specific operational conditions and ability to mitigate such conditions in a constrained right-of-way, this impact remains significant and unavoidable. However, due to the programmatic nature of the proposed project, no additional mitigation measures are available, and the impact is considered significant and unavoidable.

The City finds that MM TRANS-1 and MM TRANS-4 are feasible, are adopted, and will reduce traffic impacts to the extent feasible. Accordingly, the City finds that, pursuant to Public Resources Code Section 21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the project that mitigate or reduce the potentially significant impacts as identified in the EIR to the extent feasible. However, impacts associated with traffic hazards would still remain significant and unavoidable even with mitigation incorporated. (Draft Program EIR, Pages 3.14-48—50).

1.8 - Findings Regarding Alternatives

1.8.1 - Introduction
This section presents findings regarding alternatives to the proposed project. The section provides a summary and discussion of the feasibility of the following alternatives evaluated in the Draft Program EIR:
• Alternative 1: No Project Alternative/1999 General Plan. • Alternative 2: Decreased Employment Alternative.
• Alternative 3: Increased Residential Alternative
In accordance with CEQA Guidelines Section 15126.6, the Draft Program EIR contained a comparative impact assessment of alternatives to the proposed project. The primary purpose of this City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 131
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx analysis is to provide decision makers and interested agencies, organizations and individuals with information about a reasonable range of potentially feasible project alternatives, which could avoid or reduce any of the proposed project’s significant adverse environmental effects. Important considerations for the alternatives analysis are noted below:
• An EIR need not consider every conceivable alternative to a project; • An EIR should identify alternatives that were considered by the lead agency, but rejected as infeasible during the scoping process;
• Reasons for rejecting an alternative include:
- Failure to meet most of the basic project objectives identified in Section 4.2, Project Objectives;
- Infeasibility; and
- Inability to avoid significant environmental effects.

CEQA does not require that an analysis of alternate sites always be included in an EIR. Pursuant to CEQA Guidelines Section 15126.6(f)(2), in making the decision to include or exclude analysis of an alternate site, the “key question and first step in analysis is whether any of the significant effects of the project would be avoided or substantially lessened by putting the project in another location.

Only locations that would avoid or substantially lessen any of the significant effects of the project need to be considered for inclusion in the EIR.”
In this case, an alternative location does not constitute a feasible alternative because the project in question consists of a comprehensive update to the City of South San Francisco General Plan, Zoning Code Amendments, and Climate Action Plan. A General Plan serves as the comprehensive land use planning document for the jurisdiction that adopts it; as such, the geographical area encompassed by the plan is an immutable, fundamental characteristic. Similarly, the Zoning Code and Climate Action Plan address the entire City. Thus, it is not possible to evaluate an alternative location for programmatic planning documents such as the City’s General Plan, Zoning Code, or Climate Action Plan.

Alternative 1: No Project Alternative/1999 General Plan.

Under the No Project Alternative/1999 General Plan, the General Plan would not be updated with new policies and no zoning or land use designation changes would occur. Future development would be in accordance with the current land use and zoning maps identified in the 1999 General Plan. The 1999 General Plan provided for development of then-approved projects plus future development of a total of 2,780 housing units and 9 million square feet of nonresidential space to the City’s current inventory of an estimated 19,400 housing units and 18.1 million square feet of nonresidential development. The 1999 General Plan estimated a population of 67,400 at projected buildout in 2020. Existing land uses in 2019 include 24,647 residential units and 31,906,205 square feet of commercial/industrial/civic space. Exhibit 4-1 illustrates the existing land use map from the 1999 General Plan. Additionally, under this alternative the Zoning Code would not be updated, and the City would not consider updating the existing Climate Action Plan. Under this alternative, the current goals, policies, and zoning would remain in place through the horizon year.

City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 132 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx The No Project Alternative/1999 General Plan would have similar impacts to the proposed project’s less than significant or no impacts associated with biological resources, cultural resources, and tribal cultural resources. Because the No Project Alternative/1999 General Plan would not offer the policy enhancements and benefits that the proposed project would, overall impacts would not be reduced to the same degree as the proposed project, resulting in greater impacts associated with aesthetics, light, and glare, air quality, energy, geology, soils, and seismicity, GHG emissions, hazards and hazardous materials, hydrology and water quality, land use and planning, noise, population, housing, and employment, public services and recreation, utilities and service systems, and wildfire. (Draft Program EIR, Chapter 4, Alternatives to the Proposed Project, Page 4-18.) The significant and unavoidable impacts related to exceedance of the VMT threshold and freeway offramp queueing impacts would remain significant and unavoidable under this alternative, and somewhat greater for VMT impacts than the proposed project. The significant and unavoidable impacts related to a conflict with the 2017 Clean Air Plan and a cumulatively considerable net increase in criteria pollutants would remain significant and unavoidable under the No Project Alternative/1999 General Plan.

Additionally, the No Project Alternative/1999 General Plan would not meet the majority of project objectives. As the new policies and programs in the proposed project reflect the current goals and vision expressed by City residents, businesses, decision-makers, and other stakeholders, continuing development under the 1999 vision of the No Project Alternative/1999 General Plan would not achieve the first objective of the proposed project. Additionally, the No Project Alternative/1999 General Plan would not update the General Plan or update the CAP to address issues and concerns related to energy, sustainability and climate resiliency, sea level rise, hydrology and water quality, or any other issue raised by City residents and therefore would not meet the second objective of the proposed project. (Draft Program EIR, Chapter 4, Alternatives to the Proposed Project, Page 4-19) The No Project Alternative/1999 General Plan would not provide additional mitigation for biological resources or cultural and tribal cultural resources or reduce VMT and noise impacts to the same extent as the proposed project. The No Project Alternative/1999 General Plan would also fail to achieve objectives because this alternative would not meet the City’s housing needs, nor would it include new policies and programs that provide direction for cohesive development to meet the projected population and employment growth. Neither would the No Project Alternative/1999 General Plan meet the last two objectives because it would not update the Zoning Code and would not provide needed updates to address new requirements of State law. (Draft Program EIR, Chapter 4, Alternatives to the Proposed Project, Page 4-19.)
Finding: Based on the discussion in the Draft Program EIR and all other evidence before it, the City finds that the No Project Alternative fails to meet the majority of the project objectives. The City rejects this alternative as infeasible.

Alternative 2: Decreased Employment Alternative.

Under the Decreased Employment Alternative, there would be a 25 percent decrease in nonresidential uses in the East of 101, Lindenville, and El Camino subareas to decrease the number of employment opportunities and improve the jobs/housing balance in the City. It is assumed that these decreases would not occur within 0.333 mile of existing transit. This alternative was selected City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 133
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx because it would decrease VMT associated with employment and would therefore result in reduced traffic-related impacts compared to the proposed project.

The Decreased Employment Alternative would have similar less than significant impacts compared to the proposed project with respect to biological resources, cultural and tribal cultural resources, geology, soils and seismicity, GHG emissions, hazards and hazardous materials, hydrology and water quality, land use and planning, population, housing and employment, and wildfire. This alternative would incrementally decrease the proposed project’s less than significant impacts related to aesthetics, light and glare, air quality, energy, noise, public services, recreation, and utilities. This alternative would slightly decrease the significant and unavoidable impacts associated with exceedance of the VMT threshold, freeway offramp queuing, a conflict with the 2017 Clean Air Plan, and a cumulatively considerable net increase in criteria pollutants, although not to less than significant. (Draft Program EIR, Chapter 4, Alternatives to the Proposed Project, Page 4-25.) The Decreased Employment Alternative would partially achieve the project objectives related to developing a resilient community that is prepared for climate change by updating the CAP as part of the alternative. Additionally, this alternative would meet objectives to develop a well-connected transportation system by encouraging development near transit, increasing transit ridership, improving circulation for all modes, and improving the pedestrian environment. Because of decreased capacity for jobs, this alternative is less likely to meet project objectives relating to economic development and job growth because this alternative would prioritize increased residential development over nonresidential development, which does not reflect the goals and vision expressed by City stakeholders to the same extent as the proposed project. Similar to the proposed project, this alternative would incorporate updates to the Zoning Code and provide updates to address existing new laws. (Draft Program EIR, Chapter 4, Alternatives to the Proposed Project, Page 4-26.)
Finding: Based on the discussion in the Draft Program EIR and all other evidence before it, the City finds that the Reduced Residential Alternative only partially meets the project objectives. The City rejects this alternative as infeasible.

Alternative 3: Increased Residential Alternative.

This alternative would propose an increase in residential development along the El Camino Real transit corridor through increased density zoning (see Exhibit 4-2). This alternative would result in an increase in approximately 500 dwelling units compared to the proposed project. An additional 3,017 residential units would be added to this area (compared to the 2,524 units under the proposed project). Approximately 95 acres of what is now proposed as Medium-Density Mixed Use along El Camino Real and around the Bay Area Rapid Transit (BART) station would be designated as HighDensity Mixed Use, resulting in a change in maximum allowable density from 120 dwelling units per acre to 180 dwelling units per acre. Maximum building heights for these parcels would increase from 85 feet to 120 feet. This alternative was selected because it would reduce the jobs to housing imbalance; thereby reducing VMT impacts associated with commuting compared to the proposed project.

City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 134 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx The Increased Residential Alternative would have similar less than significant impacts compared to the proposed project with respect to air quality, biological resources, cultural resources and tribal cultural resources, geology, soils, and seismicity, hazards and hazardous materials, hydrology and water quality, population, housing, and employment, and wildfire (Draft Program EIR, Chapter 4, Alternatives to the Proposed Project, Page 4-33). This alternative would result in greater impacts associated with aesthetics, light, and glare, energy, GHG emissions, land use and planning, noise, public services and recreation, and utilities and service systems. The Increased Residential Alternative would further decrease VMT compared to the proposed project, but not to below the significance threshold and the significant and unavoidable impacts associated with exceedance of the VMT threshold, freeway offramp queuing, a conflict with the 2017 Clean Air Plan, and a cumulatively considerable net increase in criteria pollutants would remain. Similar to the proposed project, the Increased Employment Alternative would be required to comply with identified mitigation along with applicable regulations including internally consistent General Plan Update and Zoning Code policies and implementing actions. The Increased Residential Alternative would achieve the project objectives related to developing a resilient community that is prepared for climate change by updating the CAP to reduce greenhouse gas emissions as part of the alternative.

Additionally, this alternative would meet objectives to provide affordable, safe, attractive, amenityrich neighborhoods, develop a well-connected transportation system by encouraging development near transit, increasing transit ridership, improving circulation for all modes, and improving the pedestrian environment. Similar to the proposed project, this alternative would incorporate updates to the Zoning Code and provide updates to address existing new laws. However, because this alternative would also result in incrementally greater impacts on aesthetics, air quality, energy, greenhouse gas emissions, land use and planning, noise, public services and recreation, and utilities it would not meet the City’s fundamental objective to address issues and concerns identified by South San Francisco residents, businesses, decision-makers, and other stakeholders to the same degree as the proposed project. Nor would it address the City’s goal of providing attractive, balanced housing to the same degree due to the increased aesthetic impacts of locating increased height buildings adjacent to single family residential neighborhoods. (Draft Program EIR, Chapter 4, Alternatives to the Proposed Project, Page 4-33.)
Finding: Based on the discussion in the Draft Program EIR and all other evidence before it, the City finds that the Increased Residential Alternative only partially meets the project objectives. The City rejects this alternative as infeasible.

Environmentally Superior Alternative
Section 15126.6(e)(2) of the State CEQA Guidelines indicates that an analysis of alternatives to a proposed project shall identify an environmentally superior alternative among the alternatives evaluated in an EIR.

Each of the three project alternatives would lessen the environmental impacts relative to the proposed project to a certain degree (as described above and further in the EIR). Overall, based on these Findings, the Decreased Employment Alternative would be considered the environmentally superior alternative, even though, as discussed above, the City finds that it fails to fully implement proposed project objectives and is therefore infeasible.

1.9 - Findings Regarding Cumulative Impacts
Consistent with CEQA’s requirements, the Draft Program EIR for the proposed project includes an analysis of cumulative impacts in every topical discussion. As discussed above, except as to cumulative air quality impacts, all other cumulative impacts associated with the proposed project are less than significant with the implementation of applicable regulations including new and revised General Plan Update policies and implementing actions. Cumulative air quality impacts remain significant and unavoidable even with incorporation of all available feasible mitigation.

1.10 - Findings Regarding Growth Inducement
State CEQA Guidelines Section 15126.2(e) requires a discussion of the ways in which a proposed project could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment. Typical growth-inducing factors might be the extension of urban services or transportation infrastructure to a previously unserved or underserved area, or the removal of major barriers to development.

Direct growth-inducing impacts occur when the development of a project imposes new burdens on a community by directly inducing population growth, or by leading to the construction of additional developments in the same area. Also included in this category are projects that remove physical obstacles to population growth. Projects that physically remove obstacles to growth, or projects that indirectly induce growth may provide a catalyst for future unrelated development in an area such as a new residential community that requires additional commercial uses to support residents.

Consistent with the State CEQA Guidelines Section 15126.2(e), it “must not be assumed that growth in any one area is necessarily beneficial, detrimental or of little significance to the environment.” The General Plan Update does not propose or entitle any specific development that would directly increase growth. Additionally, the General Plan Update cannot predict when any particular development would occur; however, the General Plan Update anticipates approximately 14,312 net new housing units, for a total of 38,959 housing units by 2040. A total of 40,068 new persons could be accommodated under the General Plan Update at full buildout, for a total projected population of approximately 107,203. The General Plan Update anticipates approximately 42,297 net new employment opportunities, for a total of 137,557 employment opportunities from full buildout of the General Plan Update by 2040. The population estimate is 34 percent greater than the Association of Bay Area Government (ABAG) 2040 estimates, while the employment opportunities estimate is 154 percent greater.13 However, full buildout may not be achieved by 2040. To provide a reasonable forecast, the City’s population and employment projections are based on projects that are entitled, under review, or under construction, and approved plans.

The City’s jobs-to-employed residents’ ratio was approximately 1.46 in 2010 and 1.70 in 2019. By 2040, with buildout of the proposed project, the jobs-to-employed residents’ ratio is estimated to be

2.95, meaning there are more jobs than employable residents under current and future conditions.

Therefore, under current and future conditions, it is reasonably anticipated that nonresidents would 13 Association of Bay Area Governments (ABAG). 2017. Projections 2040 by Jurisdiction. Website: https://abag.ca.gov/ourwork/landuse/forecasts-projections. Accessed May 18, 2022.

City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 136 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx continue to fill employment positions in the City. As there is not enough housing in the City for the projected labor force, employees may need to commute to the City for employment.

It is too speculative at this time to identify the particular sectors for future job growth or to anticipate whether any of these positions would be virtual employment opportunities that could be filled by individuals residing in higher unemployment areas that would not have associated growthinducing impacts. Additionally, while an increase in permanent employment demand in the City could result in an increase in population growth that may necessitate the construction of housing or other infrastructure to support the population increase in adjacent communities, and while this construction could cause physical environmental effects; it is too speculative to identify where or when this increase would occur. Because of these uncertainties, it would be too speculative for the City to identify and discuss any potential related environmental impacts as part of the Draft Program EIR pursuant to CEQA Guidelines Section 15145. Specific projects under the proposed project would comply with local and State regulations and undergo project-level environmental review to assess environmental effects. Therefore, because the new employment opportunities in the City of South San Francisco exceed growth projections and would likely be filled by employees residing outside the City, the new employment opportunities could have growth-inducing impacts outside of the Planning Area; however, those potential impacts are too speculative to address in further detail.

Because South San Francisco is a fully built city, new development would primarily occur on parcels that already contain some existing homes or businesses, with the majority of potential growth occurring within the East of 101, Lindenville, Downtown, and El Camino planning subareas. The City is already well served by existing services and infrastructure As such, implementation of the proposed project would not likely require extensions of electrical, natural gas, or water utility infrastructure beyond that which currently exists within the Planning Area. However, for undeveloped sites, future projects may require connections to existing infrastructure on or adjacent to those sites. The proposed project would not extend urban infrastructure other than to future projects within the Planning Area, and thus would not induce growth in other areas outside the City’s Sphere of Influence. As such, the proposed project would not result in indirect population growth through providing an extension of infrastructure or services, or through the removal of a barrier to growth.

As discussed above, possible growth-inducing impacts outside of the Planning Area as a result of new employment facilitated by the proposed project are too speculative to address in further detail.

The reasonably foreseeable environmental impacts resulting from the growth envisioned by the General Plan Update would be avoided or lessened with the implementation of proposed General Plan Update policies, including policies related to growth management, and by implementation of mitigation measures. Therefore, by design, the proposed project reduces most of the impacts of the growth it could otherwise have induced (Draft Program EIR, Chapter 5, Other CEQA Considerations,

Page 5 ends

1.11 - Findings Regarding Significant Irreversible Environmental Changes According to Sections 15126(c) and 15126.2(d) of the State CEQA Guidelines, the City of South San Francisco must address any significant irreversible environmental changes that would occur should City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 137
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx the project be implemented. Generally, a project would result in significant irreversible environmental changes if any of the following would occur:
• The proposed project would involve a large commitment of non-renewable resources; • The primary and secondary impacts of the project would generally commit future generations to similar uses;
• The proposed project involves uses in which irreversible damage could result from any potential environmental accidents; or
• The proposed consumption of resources is not justified. • Development under the proposed project could result in approximately 14,312 net new housing units and approximately 42,297 net new employment opportunities within the Planning Area. Because South San Francisco is a fully built city, new development would primarily occur on parcels that already contain some existing homes or businesses.

Additionally, the proposed project may result in other private and public improvements throughout the City.

Construction facilitated by the proposed project would include the consumption of resources that are not replenishable or which may renew so slowly to be considered nonrenewable. These resources would include the following: certain types of lumber and other forest products; aggregate materials used in concrete and asphalt such as sand, gravel, and stone; metals such as steel, copper, and lead; petrochemical construction materials such as plastics; and water. Fossil fuels such as gasoline and oil would also be consumed in the use of construction vehicles and equipment.

Development would not be expected to involve an unusual commitment of nonrenewable resources, nor be expected to consume any resources in a wasteful manner. Construction-related impacts related to electricity and fuel consumption would be less than significant.

At operation, the proposed project would include the consumption of energy as part of building operations and transportation activities (vehicle trips associated with the proposed project). Fossil fuels, a nonrenewable resource, would be the primary energy source during operation of the proposed project. All new development in the City would be required to meet State energy efficiency regulations that include Title 24 Part 6 building energy efficiency standards that require new residential uses to meet a net zero energy use standard and nonresidential buildings to be designed for increased energy efficiency standards (Section 3.5, Draft Program EIR). Other State energy efficiency regulations include Senate Bill (SB) 100 that requires 100 percent of retail sales of electricity to be generated from zero-carbon emission sources by 2045 and Executive Order N-79-20 that requires 100 percent of new passenger vehicles sold in California to be zero-emissions by 2035.

In addition, compliance with the General Plan Update and Climate Action Plan policies and actions, adherence to the development standards in the South San Francisco Municipal Code and Zoning Ordinance, and compliance with State regulations, would ensure that implementation of the proposed project would not result in wasteful, inefficient, or unnecessary consumption of energy, thus minimizing demands for energy resources and ensuring their efficient use. Furthermore, the proposed project minimizes petroleum fuel use for transportation by locating new housing and jobs in areas well-served by transit services and that have good access to opportunity (such as jobs, City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 138 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx neighborhood amenities, and health care facilities). Finally, the implementation of MM TRANS-1, which requires the City to implement its TDM Ordinance as part of the Zoning Code Amendments and parking requirements, would reduce VMT. Thus, although the proposed project would result in an irretrievable commitment of nonrenewable resources at operation, the resources would not be consumed inefficiently, unnecessarily, or wastefully.

Implementation of the proposed project could result in an irreversible commitment of land uses from existing land uses to land uses proposed under the General Plan Update. Therefore, future generations would be committed to similar land uses and the irreversible long-term environmental changes discussed below.

The irreversible long-term environmental changes associated with the proposed project would include an increase in local and regional vehicular traffic, and the resultant increase in air pollutants, greenhouse gas emissions, and noise generated by this traffic. The proposed project would also irreversibly increase the commitment of energy resources, potable water supply, wastewater treatment, solid waste disposal, and public services, such as providing police and fire services, to support the proposed project through its lifetime. However, features incorporated into the proposed project and proposed mitigation measures would minimize the significant effects of the environmental changes associated with the proposed project to the maximum degree feasible.

The proposed project may have the potential to cause significant environmental accidents through hazardous material releases into the environment by new commercial or industrial land uses.

Compliance with State law and implementation of a Storm Water Pollution Prevention Plan (SWPPP) during construction activities would ensure that future development would not create a significant hazard to the public or environment through reasonably foreseeable upset and accident conditions involving release of hazardous materials. According to California Department of Forestry and Fire Protection (CAL FIRE), the Planning Area is not located in a Fire Hazard Severity Zone (FHSZ) but is adjacent to land identified as Moderate FHSZ within a State Responsibility Area (SRA) and High FHSZ within an SRA (San Bruno Mountain State Park). Sign Hill Park is susceptible to wildfires as evidenced by a fire that occurred in 2020. Land use designations in the City in the vicinity of San Bruno Mountain State Park and Sign Hill Park are not being modified under the General Plan Update. As a result, the degree of wildland fire hazard, including secondary hazards, would not substantially change with adoption of the General Plan Update, and current hazards would not significantly increase. In addition, existing fire protection facilities would be adequate to serve the Planning Area under the proposed project, and the proposed project would not result in a significant and unavoidable impact related to need for new or altered fire protection facilities. Thus, implementation of the proposed project would not have the potential to result in significant environmental accidents related to wildfire hazards and would not result in significant irreversible environmental changes (Draft Program EIR, Chapter 5, Other CEQA Considerations, Pages 5-6-8).

1.12 - Findings Regarding Recirculation
During the public review period after the Draft Program EIR was published, the City of South San Francisco received certain additional information. City of South San Francisco staff and consultants involved in preparing the various studies, reports and analyses included in the Project EIR have also City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 139
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx presented additional information since the publication of the Draft Program EIR. Some of this information was contained in comments submitted on the Draft Program EIR, and in responses to those comments contained in the Final EIR. Other information was presented at or before public meetings/hearings on the Draft Program EIR. The Draft Program EIR incorporates additions, clarifications, modifications, and other changes, in response to comments and as determined appropriate by City of South San Francisco staff and required under CEQA Guidelines.

The City of South San Francisco has considered all relevant information including the opinions and comments of interested agencies, organizations and individuals. The City of South San Francisco finds that the additional information does not show that any of the following situations requiring recirculation identified in CEQA Guidelines Section 15088.5 have occurred:
• A new significant environmental impact that would result from the project (or any alternative) or from a new mitigation measure proposed to be implemented. • A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance. • A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the significant environmental impacts of the project (or an alternative), but the project’s proponents decline to adopt it. • The Draft Program EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded.

Based on the foregoing and as explained in more detail in the Final EIR, and having reviewed all the information in the record of proceedings, the lead agency hereby finds that this additional information does not constitute significant new information, nor does it require recirculation of the Draft Program EIR. The additional information merely clarifies or amplifies an adequate EIR.

1.13 - Statement of Overriding Considerations
CEQA requires that a Lead Agency balance the benefits of a project against its unavoidable environmental risk in determining whether to approve the project. If the benefits outweigh the unavoidable adverse effects, those effects may be considered “acceptable” pursuant to CEQA Guidelines Section 15093(a). CEQA requires that a Lead Agency support, in writing, the specific reasons for considering a project acceptable when significant impacts are infeasible to mitigate.

Those reasons must be based on substantial evidence in the EIR or elsewhere in the administrative record pursuant to CEQA Guidelines Section 15093(b). The Lead Agency’s written reasons are referred to as a Statement of Overriding Considerations.

As explained in the above Findings of Fact, most of the proposed project’s impacts on the environment would either be insignificant or, through the incorporation of mitigation measures as conditions of approval of the proposed project, can be reduced to less than significant. However, as set forth in Section 1.6 above, even with implementation of all available mitigation, the proposed project would result in significant unavoidable impacts related to project-level vehicle miles traveled, project-level roadway safety, cumulative vehicle miles traveled, cumulative roadway safety, project- City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 140 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx level conflict with 2017 Bay Area Clean Air Plan and cumulative criteria air pollutants. Further, as set forth in Section 1.7 above, there are no feasible alternatives to the proposed project, which would mitigate or avoid those environmental impacts, and which would meet project objectives.

Accordingly, as set forth below, the City of South San Francisco hereby declares that the following benefits provided to the public through the approval and implementation of the proposed project outweigh the identified significant adverse environmental impacts of the proposed project that cannot be mitigated. The Planning Commission finds that each of the proposed project benefits separately and individually outweigh all of the unavoidable adverse environmental effects identified in the Draft Program EIR and therefore finds those impacts to be acceptable.

The City of South San Francisco hereby declares that pursuant to the State CEQA Guidelines Section 15093, the City of South San Francisco has balanced the benefits of the proposed project against any unavoidable environmental impacts in determining whether to approve the proposed project.

Pursuant to the State CEQA Guidelines, if the benefits of the proposed project outweigh the proposed project’s unavoidable adverse environmental impacts, those impacts may be considered “acceptable.”
Having reduced the adverse significant environmental effect of the proposed project to the extent feasible by adopting the mitigation measures contained in the Draft Program EIR, the MMRP, and this Resolution, having considered the entire administrative record on the proposed project, and having weighed the benefits of the proposed project against its unavoidable adverse impact after mitigation, the Planning Commission has determined that each of the following social, economic and environmental benefits of the proposed project separately and individually outweigh the potential unavoidable adverse impact and render those potential adverse environmental impacts acceptable based upon the following overriding considerations:
• The proposed project would provide consistent direction for development of vacant and underutilized sites in the City and the ensure cohesive development of attractive buildings that meet or exceed current building standards and complement existing and planned uses, in accordance with the General Plan.
• The proposed project would promote the effective use of City resources by establishing a framework to promote business diversification, create cohesive innovative areas, and retain local businesses.
• The proposed project would implement policies of importance to the City, as reflected in the General Plan Update.
• The proposed project would promote more efficient land use interaction by encouraging residential and nonresidential development within already developed urban areas; the concentration of population, employment, and services allows for more mixed-use and would consequently reduce air quality impacts.
• The proposed project would protect unique views in the City and promote restoration of Colma Creek through General Plan Update Policy LU-8.7 and Action CS-3.1 of the Climate Action Plan. Additionally, the Zoning Code Amendments that are part of the proposed project contain architectural guidelines, design review criteria, lot and development standards, City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 141
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx landscaping requirements, and other regulations for various land uses in order to promote aesthetic quality within the City and protect scenic views. • The proposed project, especially the update to the General Plan, includes policies that encourage civic engagement in the public decision-making process as well as goals and policies to promote safe and sanitary homes throughout the City. • The proposed project contains policies and actions that support a connected community. The proposed project will contribute to the community through the provision of pedestrian and bicycle facilities that may reduce greenhouse gas emissions. • The proposed project would assist the City in competing economically on a domestic and international scale by developing commercial and industrial uses that are positioned to be economically competitive.

The proposed project proposes modern state-of-the-art infrastructure improvements that would benefit the entire community and would be designed to comply with the California MUTCD and the City’s design guidelines. Additionally, the proposed project would designate official truck routes. The official designation of truck routes would direct heavy vehicles to roadways that are suited for such travel. Likewise, it would promote avoidance of neighborhood streets that are poorly suited for heavy vehicle traffic, thereby reducing incompatible uses in neighborhoods.

Custodian of Record; Scope and Content of Record
The documents and materials that constitute the record of proceedings on which these Findings are based are located at Planning Division at 315 Maple Avenue South San Francisco, CA 94080. This information is provided in compliance with Public Resources Code Section 21081.6.

Various documents, information, testimony, reports, studies, analyses and other materials (both oral and written) constitute the record upon which the Commission bases these Findings and the basis for the Commission’s approval and/or adoption contained herein. These Findings cite specific pieces of evidence, but none of the Commission's findings are based solely on those cited pieces of evidence. Rather, these Findings are based upon the entire record, and the City of South San Francisco intends to rely upon all supporting evidence in the record for each of its conclusions contained herein.

The documents in the record include all items referenced in Public Resources Code Section 21167.6(e):
(i) All project application materials;
(ii) The Project EIR (including the Draft Program, the Final EIR, and all appendices attached thereto);
(iii) All staff reports, and related documents prepared by the lead agency and/or consultants with respect to the lead agency’s compliance with the substantive and procedural requirements of this division and with respect to the action on the project; City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations 142 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/FOF/50000006 SSF GPU FOF.docx (iv) All staff reports, and related documents prepared by the lead agency and written testimony, or documents submitted by any person relevant to any findings or statement of overriding considerations adopted by the lead agency pursuant to this division; (v) All documentary and oral evidence received and reviewed at public hearings, public meetings, study sessions, and workshops on the Project EIR, and any transcript or minutes of the proceedings at which any advisory body or decision-making body heard testimony on, or considered the Project EIR;
(vi) All notices issued by the lead agency to comply with this division or with any other law governing the processing and approval of the project;
(vii) All written comments received in response to, or in connection with, the Project EIR, including comments on the Draft Program EIR;
(viii) All written evidence or correspondence submitted to, or transferred from, the lead agency with respect to compliance with this division or with respect to the project; (ix) Any proposed decisions or findings submitted to the decision makers by lead agency staff, or the project proponent, project opponents, or other interested agencies, organizations and/or individuals;
(x) The documentation of the final decision, including the Project EIR and all documents, in addition to those referenced in paragraph (c), cited or relied on in the findings or in a statement of overriding considerations adopted pursuant to this division; (xi) For documentary and informational purposes, all locally-adopted land use plans and ordinances, including, without limitation, general plans, specific plans and ordinances, master plans together with environmental review documents, findings, mitigation monitoring programs, and other documentation relevant to planned growth in the area; (xii) Any other written materials relevant to the lead agency’s compliance with this division or to its decision on the merits of the project, including any drafts of any environmental document or portions thereof, which have been released for public review, and copies of studies or other documents relied upon in any environmental document prepared for the project and either made available to the public during the public review period or included in the lead agency's files on the project, and all internal agency communications, including staff notes and memoranda related to the project or to compliance with this division; (xiii) The full written record before any inferior administrative decision-making body whose decision was appealed to a superior administrative decision-making body prior to the filing of litigation; and
(xiv) Any additional items not included above if otherwise required by law.

City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions
Attachment A:

Mitigation Monitoring and Reporting Program

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NORTH AMERICA | EUROPE | AFRICA | AUSTRALIA | ASIA
WWW.FIRSTCARBONSOLUTIONS.COM
Mitigation Monitoring and Reporting Program
for the
General Plan Update, Zoning Code Amendments, and Climate Action Plan
City of South San Francisco, San Mateo County, California Prepared for:

City of South San Francisco
315 Maple Avenue
South San Francisco, CA 94080
650.877.8535
Contact: Billy Gross, Senior Planner
Prepared by:

FirstCarbon Solutions
2999 Oak Road, Suite 250
Walnut Creek, CA 94597
925.357.2562
Contact: Mary Bean, Project Director
Report Date: September 6, 2022

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City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program Preface
FirstCarbon Solutions 1 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/MMRP/50000006 SSF GPU MMRP.docx

PREFACE
Section 21081.6 of the California Environmental Quality Act (CEQA) and CEQA Guidelines Section 15097 require a Lead Agency to adopt a Mitigation Monitoring and Reporting Program (MMRP) whenever it adopts an Environmental Impact Report (EIR) in conjunction with a project approval.

The purpose of the MMRP is to ensure compliance with the mitigation measures occurs during project implementation.

The Draft Program EIR prepared for the General Plan Update, Zoning Code Amendments, and Climate Action Plan concluded that project implementation could result in potentially significant effects on the environment and mitigation measures were incorporated into the proposed project or are required as a condition of project approval that reduce these potential impacts to a less than significant level. This MMRP documents how and when the mitigation measures adopted by the lead agency will be implemented and confirms that potential environmental impacts are reduced to less than significant levels as identified in the Draft Program EIR.

This document does not discuss those subjects that the environmental analysis demonstrates would result in less than significant impacts and for which no mitigation was proposed or necessary.

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City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program FirstCarbon Solutions 3 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/MMRP/50000006 SSF GPU MMRP.docx Table 1: General Plan Update, Zoning Code Amendments, and Climate Action Plan Project Mitigation Monitoring and Reporting Program Mitigation Measures Method of Verification Timing of Verification Responsible for
Verification
Verification of Completion
Date Initial

3.2 Air Quality
MM AIR-1a: Individual development projects facilitated by the proposed project shall incorporate the following Basic Construction Mitigation Measures recommended by the Bay Area Air Quality Management District (BAAQMD):
• All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day.
• All haul trucks transporting soil, sand, or other loose material off-site shall be covered.
• All visible mud or dirt trackout onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.
• All vehicle speeds on unpaved roads shall be limited to 15 mph.
• All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.
• Idling times shall be minimized either by shutting
equipment off when not in use or reducing the maximum
idling time to 5 minutes (as required by the California Airborne Toxics Control Measure [ATCM] Title 13, Section 2485 of the California Code of Regulations). Clear signage shall be provided for construction workers at all access points.
• All construction equipment shall be maintained and
properly tuned in accordance with manufacturer’s
specifications. All equipment shall be checked by a certified Incorporation into
project construction
documents; the City of
South San Francisco
Planning Division shall
inspect the worksite
regularly to ensure the
mitigation measures are
implemented
Prior to issuance of
building permits for
individual projects
and ongoing
throughout
construction
City of South San
Francisco Planning
Division,
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program FirstCarbon Solutions 4 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/MMRP/50000006 SSF GPU MMRP.docx Mitigation Measures Method of Verification Timing of Verification Responsible for
Verification
Verification of Completion
Date Initial
mechanic and determined to be running in proper
condition prior to operation.
• Prior to the commencement of construction activities, individual project proponents shall 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 BAAQMD phone number shall also be visible to ensure compliance with applicable regulations.

MM AIR-1b: Projects that may result in additional toxic air contaminants (TACs) that are located within 1,000 feet of a sensitive receptors(s) or would place sensitive receptors within 1,000 feet of uses generating TACs, such as roadways with volumes of 10,000 average annual daily trips or greater, shall implement Bay Area Air Quality Management District (BAAQMD) Guidelines and California Office of Environmental Health Hazard Assessment (OEHHA) policies and procedures requiring a Health Risk Assessments (HRA) for residential development and other sensitive receptors. Screening area distances may be increased on a case-by-case basis if an unusually large source or sources of hazardous emissions are proposed or currently exist. Based on the results of the HRA, identify and implement measures (such as air filtration systems) to reduce potential exposure to particulate matter, carbon monoxide, diesel fumes, and other potential health hazards. Measures identified in HRAs shall be included into the site development plan as a component of a proposed
project.

Qualified air quality
specialist conducts an
HRA and identifies
mitigation measures;
incorporation of
mitigation measures into
the site development
plan; on-site inspection
Prior to plan check
review; during
construction
City of South San
Francisco Planning
Division
MM TRANS-1: Transportation Demand Management
To reduce Vehicle Miles Traveled (VMT), the City shall
implement its Transportation Demand Management (TDM)
Ordinance as part of the Zoning Code Amendments and
parking requirements. The City shall also update its TDM Implementation of TDM
Ordinances; review and
update of TDM
Ordinances and parking
requirements;
Review and update
of TDM Ordinances
and parking
requirements:
every 5 to 10 years
City of South San
Francisco
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program FirstCarbon Solutions 5 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/MMRP/50000006 SSF GPU MMRP.docx Mitigation Measures Method of Verification Timing of Verification Responsible for
Verification
Verification of Completion
Date Initial
Ordinance and parking requirements every five to ten years and establish an East of 101 Area Trip Cap, to achieve the maximum feasible reductions in vehicle travel. The City shall achieve the performance standards outlined in the TDM
Ordinance.

The City shall update its TDM Ordinance every 5 to 10 years to limit Total VMT and Work-Based VMT by incentivizing use of transit and active transportation and disincentivizing auto use. The TDM Ordinance shall cover all development projects generating greater than 100 daily trips, with the most
stringent requirements for office/Research and Development (R&D) land uses that disproportionately account for the highest rates of VMT in the City. Development projects shall implement a combination of TDM programs, services, and
infrastructure improvements, including but not limited to:
establishing trip reduction programs; subsidizing transit and active transportation use; coordinating carpooling and
vanpooling; encouraging telecommuting and flexible work schedules; designing site plans to prioritize pedestrian, bicycle, and transit travel; funding first/last mile shuttle services; establishing site-specific trip caps; managing parking supply; and constructing transit and active transportation capital improvements. Developments shall be subject to
annual monitoring. The City shall establish an administrative fine structure for developments found to be out of
compliance and apply any revenues from fines to
infrastructure and services aimed at reducing VMT.

The City shall conduct annual traffic counts along the cordon area perimeter. Should the trip cap be reached, the City shall establishment of an East
of 101 Area Trip Cap;
achievement of
performance standards
outlined in the TDM
Ordinance
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program FirstCarbon Solutions 6 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/MMRP/50000006 SSF GPU MMRP.docx Mitigation Measures Method of Verification Timing of Verification Responsible for
Verification
Verification of Completion
Date Initial
consider corrective actions such as: revising mode share targets for projects subject to the TDM Ordinance, identifying new funding measures for TDM services, implementing new vehicle user charges, creating new street connections, or slowing the pace of development approvals within the cordon zone.

The City shall update its parking requirements every 5 to 10 years to align with its TDM Ordinance and East of 101 Area Trip Cap. The City shall establish parking maximums for office/R&D uses to ensure that VMT reduction goals are
incorporated into the design of development projects.

3.3 Biological Resources
MM BIO-1: Special-status Species, Migratory Birds, and
Nesting Birds
Special-status species are those listed as Endangered,
Threatened or Rare, or as Candidates for listing by the United States Fish and Wildlife Service (USFWS) and/or California Department of Fish and Wildlife (CDFW), or as Rare Plant Rank 1B or 2B species by the California Native Plant Society (CNPS). This designation also includes CDFW Species of
Special Concern and Fully Protected Species. Applicants or sponsors of projects on sites where potential special-status species, migratory birds, or nesting birds are present shall retain a qualified Biologist to conduct a focused survey per applicable regulatory agency protocols to determine whether such species occur on a given project site. The project applicant or sponsor shall ensure that, if development of occupied habitat must occur, species impacts shall be avoided or minimized, and if required by a regulatory agency or the CEQA process, loss of wildlife habitat or individual plants shall be fully compensated on the site. If off-site mitigation is necessary, it shall occur within the South San Francisco Planning Area whenever possible, with a priority given to Pre-construction survey
by a qualified Biologist;
mitigation and
monitoring program (if
required) by a qualified
Biologist; submittal and
review of survey and
monitoring documents
Prior to
commencement of
grading and
construction
activities for
individual projects;
ongoing during
construction
City of South San
Francisco Planning
Division;
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program FirstCarbon Solutions 7 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/MMRP/50000006 SSF GPU MMRP.docx Mitigation Measures Method of Verification Timing of Verification Responsible for
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existing habitat mitigation banks. Habitat mitigation shall be accompanied by a long-term management plan and
monitoring program prepared by a qualified Biologist, and include provisions for protection of mitigation lands in perpetuity through the establishment of easements and
adequate funding for maintenance and monitoring.

MM BIO-3: Assess Potential Wetland Impacts
Applicants or sponsors of projects on sites where potential jurisdictional wetlands or waterways are present shall retain a qualified Biologist/wetland regulatory specialist to conduct a site investigation and assess whether wetland or waterway features are jurisdictional with regard to the United States Army Corps of Engineers (USACE), Regional Water Quality Control Board (RWQCB), and/or California Department of Fish and Wildlife (CDFW). This investigation shall include assessing potential impacts to wetlands and other waters of the United States and/or State. If a feature is found to be jurisdictional or potentially jurisdictional, the project applicant or sponsor shall comply with the appropriate permitting process with each agency claiming jurisdiction prior to disturbance of the feature, and a qualified Biologist/wetland regulatory
specialist shall conduct a detailed wetland delineation if necessary.

Site investigation and
assessment by a
qualified Biologist;
submittal of
investigation and
assessment documents
Prior to issuance of
grading permit and
construction
activities for
individual projects
City of South San
Francisco Planning
Division

3.6 Geology, Soils, and Seismicity
MM GEO-6: Applicants, owners, and/or sponsors of all future development or construction projects shall be required to perform or provide paleontological monitoring for all
proposed excavations in the Colma Formation and Merced
Formation, including those buried in the shallow subsurface below Quaternary deposits, due to the high paleontological sensitivity for significant resources in these areas. Should significant paleontological resources (e.g., bones, teeth, wellpreserved plant elements) be unearthed by the future project Retention of a
professional
paleontologist; ongoing
monitoring
Prior to issuance of
grading permit for
individual projects.

Ongoing during
construction
activities
City of South San
Francisco Planning
Division
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program FirstCarbon Solutions 8 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/MMRP/50000006 SSF GPU MMRP.docx Mitigation Measures Method of Verification Timing of Verification Responsible for
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construction crew, the project activities shall be diverted at least 15 feet from the discovered paleontological resources until a professional vertebrate Paleontologist has assessed such discovered resources and, if deemed significant, such resources shall be salvaged in a timely manner. The
applicant/owner/sponsor of said project shall be responsible for diverting project work and providing the assessment including retaining a professional vertebrate Paleontologist for such purpose. Collected fossils shall be deposited by the applicant/owner/sponsor in an appropriate repository (e.g., University of California Museum of Paleontology (UCMP), California Academy of Sciences) where the collection shall be properly curated and made available for future research.

3.11 Noise and Vibration
MM NOI-1: Operational Noise Reduction Plan
Prior to issuance of building permits, the project applicant or sponsor shall implement the following measures to limit onsite operational stationary noise source impacts:
• Any proposed development projects that include parking areas, terminals, or loading docks of commercial or
industrial land uses within 300-feet of a residential
receptor shall demonstrate compliance with Policies NOI1.1 and NOI-1.2 of the City’s Noise Element by submitting a final acoustical report prepared to the satisfaction of the Planning Division that identifies design measures to
adequately minimize the potential noise impacts of
vehicles on the site to adjacent land uses. The report must be approved by the Planning Division prior to issuance of building permits.
• For any future development project that would include exterior mechanical systems (such as mechanical
ventilation systems) within 50 feet of a residential receptor, the project applicant or sponsor shall submit a final
Implementation of
measures and submittal
and approval of final
acoustical report, when
applicable
Prior to issuance of
building permits for
individual projects
City of San
Francisco Planning
Division
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program FirstCarbon Solutions 9 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/MMRP/50000006 SSF GPU MMRP.docx Mitigation Measures Method of Verification Timing of Verification Responsible for
Verification
Verification of Completion
Date Initial
acoustical report prepared to the satisfaction of the
Planning Division that demonstrates compliance of the
project with Policies NOI-1.1 and NOI-1.2 of the City’s Noise Element. Noise reduction design features may
include, but are not limited to, locating stationary noise sources on the site to be shielded by structures (buildings, enclosures, or sound walls) or by using equipment that has a quieter rating. The report must be approved by the
Planning Division prior to issuance of building permits.

MM NOI-3: Airport Noise Impact Reduction Plan
Prior to issuance of building permits, the project applicant or sponsor of proposed development projects shall implement the following measures to limit airport activity noise source impacts:
• Any proposed residential development project or any
hotel, motel, or transient lodging land use development project, that would be located within the San Francisco International Airport (SFO) 65 A-weighted decibel (dBA) Community Noise Equivalent Level (CNEL) noise contours, shall demonstrate compliance with Policies NOI-1.1 and
NOI-1.2 of the City’s Noise Element by submitting a final acoustical report prepared to the satisfaction of the
Planning Division that identifies design measures to
adequately minimize airport activity noise levels to meet the interior noise level standards shown in Table 11 of the Noise Element. Outdoor active use space must also comply with the exterior noise standards of Table 11 of the Noise Element or must be excluded from such projects. The
report must be approved by the Planning Division prior to issuance of building permits.
• Any proposed commercial development project that would be located within the SFO 70 dBA CNEL noise contours shall demonstrate compliance with Policies NOI-1.1 and NOI-1.2 of the City’s Noise Element by submitting a final acoustical Implementation of
measures and submittal
and approval of a final
acoustical report, when
applicable
Prior to the
issuance of building
permits for
individual projects
City of South San
Francisco Planning
Division
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program FirstCarbon Solutions 10 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/MMRP/50000006 SSF GPU MMRP.docx Mitigation Measures Method of Verification Timing of Verification Responsible for
Verification
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Date Initial
report prepared to the satisfaction of the Planning Division that identifies design measures to adequately minimize
airport activity noise levels to meet the interior noise level standards shown in Table 11 of the Noise Element. The
report must be approved by the Planning Division prior to issuance of building permits.
• Any proposed institutional or public facility development project that would be located within the SFO 65 dBA CNEL noise contours shall demonstrate compliance with Policies NOI-1.1 and NOI-1.2 of the City’s Noise Element by
submitting a final acoustical report prepared to the
satisfaction of the Planning Division that identifies design measures to adequately minimize airport activity noise
levels to meet the interior noise level standards shown in Table 11 of the Noise Element. Outdoor active use space must also comply with the exterior noise standards of Table 11 of the Noise Element or must be excluded from such
projects. The report must be approved by the Planning
Division prior to issuance of building permits.

3.14 Transportation
MM TRANS-1: Transportation Demand Management
To reduce VMT, the City shall implement its Transportation Demand Management (TDM) Ordinance as part of the Zoning Code Amendments and parking requirements. The City shall also update its TDM Ordinance and parking requirements
every five to ten years and establish an East of 101 Area Trip Cap, to achieve the maximum feasible reductions in vehicle travel. The City shall achieve the performance standards outlined in the TDM Ordinance pursuant to Section

20.400.004 of the Zoning Ordinance.

The City shall review and update its TDM Ordinance every five to ten years to limit Total VMT and Work-Based VMT by
incentivizing use of transit and active transportation and Implementation of TDM
Ordinances; review and
update of TDM
Ordinances and parking
requirements;
establishment of an East
of 101 Area Trip Cap;
achievement of
performance standards
outlined in the TDM
Ordinance
Review and update
of TDM Ordinances
and parking
requirements:
every 5 to 10 years
City of South San
Francisco
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program FirstCarbon Solutions 11 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/MMRP/50000006 SSF GPU MMRP.docx Mitigation Measures Method of Verification Timing of Verification Responsible for
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disincentivizing auto use. The TDM Ordinance shall cover all development projects generating greater than 100 daily trips, with the most stringent requirements for office/R&D land uses that disproportionately account for the highest rates of VMT in the City. Development projects shall implement a combination of TDM programs (pursuant to Sections

20.400.003 and 20.400.004 of the Zoning Ordinance),
services, and infrastructure improvements, including but not limited to: establishing trip reduction programs; subsidizing transit and active transportation use; coordinating carpooling and vanpooling; encouraging telecommuting and flexible
work schedules; designing site plans to prioritize pedestrian, bicycle, and transit travel; funding first/last mile shuttle services; establishing site-specific trip caps; managing parking supply; and constructing transit and active transportation capital improvements. Developments shall be subject to
annual reporting and monitoring. The City shall establish a fine structure for developments found to be out of
compliance and apply any revenues from fines to
infrastructure and services aimed at reducing VMT.

The City shall conduct annual traffic counts along the cordon area perimeter. Should the trip cap be reached, the City shall consider corrective actions such as: revising mode share targets for projects subject to the TDM Ordinance, identifying new funding measures for TDM services, implementing new vehicle user charges, creating new street connections, or slowing the pace of development approvals within the cordon zone.

City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program FirstCarbon Solutions 12 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/MMRP/50000006 SSF GPU MMRP.docx Mitigation Measures Method of Verification Timing of Verification Responsible for
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The City shall review and update its parking requirements every five to ten years to align with its TDM Ordinance and East of 101 Area Trip Cap. The City shall establish parking maximums for office/R&D uses to ensure that VMT reduction goals are incorporated into the design of development
projects.

MM TRANS-4: Freeway Offramp Queue Improvements
To minimize queueing hazards, the City shall work with
Caltrans to develop improvement measures for freeway offramps and adjacent intersections that help manage offramp queues. These measures may include geometric changes,
changes to signal timing and phasing, and new connections as identified in Table 3.14-5. Such improvement measures shall not adversely affect pedestrian, bicycle, and transit conditions or otherwise undermine the City’s VMT mitigation efforts described in MM TRANS-1. MM TRANS-1 is also applicable
here and should be implemented to minimize freeway
offramp queues.

Development of
improvement measures.

Documentation in the
General Plan progress
report.

Ongoing.

Consultation with
Caltrans to initiate
within a year of
adoption of General
Plan Update.

City of South San
Francisco Planning
Division, Caltrans

South San Francisco City CouncilOctober 12, 2022

South San Francisco City Council
October 12, 2022