LAMPHIER-GREGORY 4100 REDWOOD ROAD, STE 20A - #601 OAKLAND, CA 94619
LAMPHIER-GREGORY
MEMO
TO: Christopher Espiritu, Senior Planner
City of South San Francisco
Economic and Community Development Department
315 Maple Avenue
South San Francisco, CA 94080
FROM: Rebecca Auld, Vice President
Lamphier-Gregory, Inc.
SUBJECT: 800 Dubuque Avenue Project IS/MND – Review and Discussion of Comments DATE: June 1, 2023
PURPOSE OF THIS MEMO
This memo provides a brief discussion of comments received in response to the Initial Study/Mitigated Negative Declaration (“IS/MND”) for the 800 Dubuque Avenue Project (“project”). Though the California Environmental Quality Act (“CEQA”) does not require a lead agency to formally respond to written comments received on an IS/MND, this memorandum is being provided by the IS/MND preparer to demonstrate that the comments do not present substantial evidence supporting a fair argument that the project may have a significant environmental impact, or that the IS/MND should be revised and recirculated for public review.
A separate errata sheet has also been prepared to address minor corrections and clarifications informed by the comments received as noted in the response to comments below and included in the conclusions in this document. The errata sheet will be appended to the IS/MND.
SUMMARY CONCLUSIONS
In summary, the letters have not raised any issues that would require recirculation of the IS/MND or preparation of an environmental impact report under sections 15073.5 and 15074.1 of the CEQA Guidelines as no new significant effects were identified, no new mitigation measures were added, the significance of identified impacts remains unchanged, and all impacts are either below significance levels or reduced to that level through application of identified mitigation.
COMMENTS RECEIVED
The comment period ran from March 29, 2023, through April 27, 2023. Comment letters were received from three agencies during the comment period, as listed below. 6/1/23 PAGE 2 of 3
LAMPHIER-GREGORY 4100 REDWOOD ROAD, STE 20A - #601 OAKLAND, CA 94619 • Pacific Gas and Electric Company Letters: Plan Review Team and Justin Newell, Land Management, dated March 29 and April 25, 2023
• San Francisco International Airport Letter: Nupur Sinha, Director of Planning and Environmental Affairs, dated April 18, 2023
• California Geologic Survey: Dr. Erik Frost, Senior Engineering Geologist, email sent April 25, 2023
DISCUSSION OF COMMENT LETTERS
Pacific Gas and Electric Company
The March letter clarifies PG&E policies and procedures in the event PG&E owned properties and/or easements are on or adjacent to the project site, including information about the PG&E review process, safety procedures related to construction near gas transmission pipelines, and examples and restrictions for external uses within electric transmission fee strips and/or easements. The project would be required to follow applicable PG&E requirements and procedures when determined to be applicable.
These comments do not reference or specifically relate to the adequacy of the analysis in the IS/MND and no revisions to the IS/MND are necessary to address this comment. These procedural reminders have been provided to City staff and the applicant.
The April letter provides further information about procedures in the event of relocation or modification of existing gas and electric services.
Neither letter is a comment on the environmental analysis and do not require recirculation of the IS/MND or preparation of an environmental impact report under section 15073.5 of the CEQA Guidelines.
San Francisco International Airport
This letter confirms and clarifies the regulations specific to this site in regards to its proximity to the San Francisco International Airport (SFO).
The letter agrees with conclusions in the IS/MND related to airport noise and hazards (discussed on IS/MND pages 57 and 67). Clarifications to the approval process and allowable heights have been added to the errata sheet. The letter also notes that departing planes would ascend over the project site, which may experience some aircraft departure noise disturbance, particularly overnight. Consistent with the conclusions of the IS/MND, the letter also indicates that the project site is located outside the 65 decibel contour, and noise levels would not be inconsistent with the proposed use.
This information does not result in new significant impacts or mitigation measures, or changed impact conclusions. The comments in this letter, this response, and the related errata do not require recirculation of the IS/MND or preparation of an environmental impact report under section 15073.5 of the CEQA Guidelines.
California Geologic Survey
This letter clarifies that the project site is in a zone of required investigation for liquefaction (discussed on IS/MND page 45), and also notes that the required investigation was completed by the project’s Geotechnical Investigation as presented in the IS/MND. Clarifications to the project’s location in a mapped liquefaction hazard zone have been added to the errata sheet. 6/1/23 PAGE 3 of 3
LAMPHIER-GREGORY 4100 REDWOOD ROAD, STE 20A - #601 OAKLAND, CA 94619 This information does not result in new significant impacts or mitigation measures or changed impact conclusions. The comments in this letter and this response do not require recirculation of the IS/MND or preparation of an environmental impact report under section 15073.5 of the CEQA Guidelines.
Plan Review Team
Land Management
[email protected]
PG&E Gas and Electric Facilities Page 1
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March 29, 2023
Kelsey Evans
City of South San Francisco
315 Maple Ave
South San Francisco, CA 94080
Ref: Gas and Electric Transmission and Distribution
Dear Kelsey Evans,
Thank you for submitting the 800 Dubuque Ave plans for our review. PG&E will review the submitted plans in relationship to any existing Gas and Electric facilities within the project area.
If the proposed project is adjacent/or within PG&E owned property and/or easements, we will be working with you to ensure compatible uses and activities near our facilities.
Attached you will find information and requirements as it relates to Gas facilities (Attachment 1) and Electric facilities (Attachment 2). Please review these in detail, as it is critical to ensure your safety and to protect PG&E’s facilities and its existing rights.
Below is additional information for your review:
1. This plan review process does not replace the application process for PG&E gas or electric service your project may require. For these requests, please continue to work with PG&E Service Planning: https://www.pge.com/en_US/business/services/buildingand-renovation/overview/overview.page.
2. If the project being submitted is part of a larger project, please include the entire scope of your project, and not just a portion of it. PG&E’s facilities are to be incorporated within any CEQA document. PG&E needs to verify that the CEQA document will identify any required future PG&E services.
3. An engineering deposit may be required to review plans for a project depending on the size, scope, and location of the project and as it relates to any rearrangement or new installation of PG&E facilities.
Any proposed uses within the PG&E fee strip and/or easement, may include a California Public Utility Commission (CPUC) Section 851 filing. This requires the CPUC to render approval for a conveyance of rights for specific uses on PG&E’s fee strip or easement. PG&E will advise if the necessity to incorporate a CPUC Section 851filing is required.
This letter does not constitute PG&E’s consent to use any portion of its easement for any purpose not previously conveyed. PG&E will provide a project specific response as required.
Sincerely,
Plan Review Team
Land Management
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Attachment 1 – Gas Facilities
There could be gas transmission pipelines in this area which would be considered critical facilities for PG&E and a high priority subsurface installation under California law. Care must be taken to ensure safety and accessibility. So, please ensure that if PG&E approves work near gas transmission pipelines it is done in adherence with the below stipulations. Additionally, the following link provides additional information regarding legal requirements under California excavation laws: https://www.usanorth811.org/images/pdfs/CA-LAW-2018.pdf
1. Standby Inspection: A PG&E Gas Transmission Standby Inspector must be present during any demolition or construction activity that comes within 10 feet of the gas pipeline. This includes all grading, trenching, substructure depth verifications (potholes), asphalt or concrete demolition/removal, removal of trees, signs, light poles, etc. This inspection can be coordinated through the Underground Service Alert (USA) service at 811. A minimum notice of 48 hours is required. Ensure the USA markings and notifications are maintained throughout the duration of your work.
2. Access: At any time, PG&E may need to access, excavate, and perform work on the gas pipeline. Any construction equipment, materials, or spoils may need to be removed upon notice.
Any temporary construction fencing installed within PG&E’s easement would also need to be capable of being removed at any time upon notice. Any plans to cut temporary slopes exceeding a 1:4 grade within 10 feet of a gas transmission pipeline need to be approved by PG&E Pipeline Services in writing PRIOR to performing the work.
3. Wheel Loads: To prevent damage to the buried gas pipeline, there are weight limits that must be enforced whenever any equipment gets within 10 feet of traversing the pipe.
Ensure a list of the axle weights of all equipment being used is available for PG&E’s Standby Inspector. To confirm the depth of cover, the pipeline may need to be potholed by hand in a few areas.
Due to the complex variability of tracked equipment, vibratory compaction equipment, and cranes, PG&E must evaluate those items on a case-by-case basis prior to use over the gas pipeline (provide a list of any proposed equipment of this type noting model numbers and specific attachments).
No equipment may be set up over the gas pipeline while operating. Ensure crane outriggers are at least 10 feet from the centerline of the gas pipeline. Transport trucks must not be parked over the gas pipeline while being loaded or unloaded.
4. Grading: PG&E requires a minimum of 36 inches of cover over gas pipelines (or existing grade if less) and a maximum of 7 feet of cover at all locations. The graded surface cannot exceed a cross slope of 1:4.
5. Excavating: Any digging within 2 feet of a gas pipeline must be dug by hand. Note that while the minimum clearance is only 24 inches, any excavation work within 24 inches of the edge of a pipeline must be done with hand tools. So to avoid having to dig a trench entirely with hand tools, the edge of the trench must be over 24 inches away. (Doing the math for a 24 inch PG&E Gas and Electric Facilities Page 3
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wide trench being dug along a 36 inch pipeline, the centerline of the trench would need to be at least 54 inches [24/2 + 24 + 36/2 = 54] away, or be entirely dug by hand.) Water jetting to assist vacuum excavating must be limited to 1000 psig and directed at a 40° angle to the pipe. All pile driving must be kept a minimum of 3 feet away.
Any plans to expose and support a PG&E gas transmission pipeline across an open excavation need to be approved by PG&E Pipeline Services in writing PRIOR to performing the work.
6. Boring/Trenchless Installations: PG&E Pipeline Services must review and approve all plans to bore across or parallel to (within 10 feet) a gas transmission pipeline. There are stringent criteria to pothole the gas transmission facility at regular intervals for all parallel bore installations.
For bore paths that cross gas transmission pipelines perpendicularly, the pipeline must be potholed a minimum of 2 feet in the horizontal direction of the bore path and a minimum of 24 inches in the vertical direction from the bottom of the pipe with minimum clearances measured from the edge of the pipe in both directions. Standby personnel must watch the locator trace (and every ream pass) the path of the bore as it approaches the pipeline and visually monitor the pothole (with the exposed transmission pipe) as the bore traverses the pipeline to ensure adequate clearance with the pipeline. The pothole width must account for the inaccuracy of the locating equipment.
7. Substructures: All utility crossings of a gas pipeline should be made as close to perpendicular as feasible (90° +/- 15°). All utility lines crossing the gas pipeline must have a minimum of 24 inches of separation from the gas pipeline. Parallel utilities, pole bases, water line ‘kicker blocks’, storm drain inlets, water meters, valves, back pressure devices or other utility substructures are not allowed in the PG&E gas pipeline easement.
If previously retired PG&E facilities are in conflict with proposed substructures, PG&E must verify they are safe prior to removal. This includes verification testing of the contents of the facilities, as well as environmental testing of the coating and internal surfaces. Timelines for PG&E completion of this verification will vary depending on the type and location of facilities in conflict.
8. Structures: No structures are to be built within the PG&E gas pipeline easement. This includes buildings, retaining walls, fences, decks, patios, carports, septic tanks, storage sheds, tanks, loading ramps, or any structure that could limit PG&E’s ability to access its facilities.
9. Fencing: Permanent fencing is not allowed within PG&E easements except for perpendicular crossings which must include a 16 foot wide gate for vehicular access. Gates will be secured with PG&E corporation locks.
10. Landscaping: Landscaping must be designed to allow PG&E to access the pipeline for maintenance and not interfere with pipeline coatings or other cathodic protection systems. No trees, shrubs, brush, vines, and other vegetation may be planted within the easement area.
Only those plants, ground covers, grasses, flowers, and low-growing plants that grow unsupported to a maximum of four feet (4’) in height at maturity may be planted within the easement area.
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11. Cathodic Protection: PG&E pipelines are protected from corrosion with an “Impressed Current” cathodic protection system. Any proposed facilities, such as metal conduit, pipes, service lines, ground rods, anodes, wires, etc. that might affect the pipeline cathodic protection system must be reviewed and approved by PG&E Corrosion Engineering.
12. Pipeline Marker Signs: PG&E needs to maintain pipeline marker signs for gas transmission pipelines in order to ensure public awareness of the presence of the pipelines.
With prior written approval from PG&E Pipeline Services, an existing PG&E pipeline marker sign that is in direct conflict with proposed developments may be temporarily relocated to accommodate construction work. The pipeline marker must be moved back once construction is complete.
13. PG&E is also the provider of distribution facilities throughout many of the areas within the state of California. Therefore, any plans that impact PG&E’s facilities must be reviewed and approved by PG&E to ensure that no impact occurs which may endanger the safe operation of its facilities.
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Attachment 2 – Electric Facilities
It is PG&E’s policy to permit certain uses on a case by case basis within its electric transmission fee strip(s) and/or easement(s) provided such uses and manner in which they are exercised, will not interfere with PG&E’s rights or endanger its facilities. Some examples/restrictions are as follows:
1. Buildings and Other Structures: No buildings or other structures including the foot print and eave of any buildings, swimming pools, wells or similar structures will be permitted within fee strip(s) and/or easement(s) areas. PG&E’s transmission easement shall be designated on subdivision/parcel maps as “RESTRICTED USE AREA – NO BUILDING.”
2. Grading: Cuts, trenches or excavations may not be made within 25 feet of our towers.
Developers must submit grading plans and site development plans (including geotechnical reports if applicable), signed and dated, for PG&E’s review. PG&E engineers must review grade changes in the vicinity of our towers. No fills will be allowed which would impair ground-toconductor clearances. Towers shall not be left on mounds without adequate road access to base of tower or structure.
3. Fences: Walls, fences, and other structures must be installed at locations that do not affect the safe operation of PG&’s facilities. Heavy equipment access to our facilities must be maintained at all times. Metal fences are to be grounded to PG&E specifications. No wall, fence or other like structure is to be installed within 10 feet of tower footings and unrestricted access must be maintained from a tower structure to the nearest street. Walls, fences and other structures proposed along or within the fee strip(s) and/or easement(s) will require PG&E review; submit plans to PG&E Centralized Review Team for review and comment.
4. Landscaping: Vegetation may be allowed; subject to review of plans. On overhead electric transmission fee strip(s) and/or easement(s), trees and shrubs are limited to those varieties that do not exceed 10 feet in height at maturity. PG&E must have access to its facilities at all times, including access by heavy equipment. No planting is to occur within the footprint of the tower legs. Greenbelts are encouraged.
5. Reservoirs, Sumps, Drainage Basins, and Ponds: Prohibited within PG&E’s fee strip(s) and/or easement(s) for electric transmission lines.
6. Automobile Parking: Short term parking of movable passenger vehicles and light trucks (pickups, vans, etc.) is allowed. The lighting within these parking areas will need to be reviewed by PG&E; approval will be on a case by case basis. Heavy equipment access to PG&E facilities is to be maintained at all times. Parking is to clear PG&E structures by at least 10 feet.
Protection of PG&E facilities from vehicular traffic is to be provided at developer’s expense AND to PG&E specifications. Blocked-up vehicles are not allowed. Carports, canopies, or awnings are not allowed.
7. Storage of Flammable, Explosive or Corrosive Materials: There shall be no storage of fuel or combustibles and no fueling of vehicles within PG&E’s easement. No trash bins or incinerators are allowed.
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8. Streets and Roads: Access to facilities must be maintained at all times. Street lights may be allowed in the fee strip(s) and/or easement(s) but in all cases must be reviewed by PG&E for proper clearance. Roads and utilities should cross the transmission easement as nearly at right angles as possible. Road intersections will not be allowed within the transmission easement.
9. Pipelines: Pipelines may be allowed provided crossings are held to a minimum and to be as nearly perpendicular as possible. Pipelines within 25 feet of PG&E structures require review by PG&E. Sprinklers systems may be allowed; subject to review. Leach fields and septic tanks are not allowed. Construction plans must be submitted to PG&E for review and approval prior to the commencement of any construction.
10. Signs: Signs are not allowed except in rare cases subject to individual review by PG&E.
11. Recreation Areas: Playgrounds, parks, tennis courts, basketball courts, barbecue and light trucks (pickups, vans, etc.) may be allowed; subject to review of plans. Heavy equipment access to PG&E facilities is to be maintained at all times. Parking is to clear PG&E structures by at least 10 feet. Protection of PG&E facilities from vehicular traffic is to be provided at developer’s expense AND to PG&E specifications.
12. Construction Activity: Since construction activity will take place near PG&E’s overhead electric lines, please be advised it is the contractor’s responsibility to be aware of, and observe the minimum clearances for both workers and equipment operating near high voltage electric lines set out in the High-Voltage Electrical Safety Orders of the California Division of Industrial Safety (https://www.dir.ca.gov/Title8/sb5g2.html), as well as any other safety regulations.
Contractors shall comply with California Public Utilities Commission General Order 95 (http://www.cpuc.ca.gov/gos/GO95/go_95_startup_page.html) and all other safety rules. No construction may occur within 25 feet of PG&E’s towers. All excavation activities may only commence after 811 protocols has been followed.
Contractor shall ensure the protection of PG&E’s towers and poles from vehicular damage by (installing protective barriers) Plans for protection barriers must be approved by PG&E prior to construction.
13. PG&E is also the owner of distribution facilities throughout many of the areas within the state of California. Therefore, any plans that impact PG&E’s facilities must be reviewed and approved by PG&E to ensure that no impact occurs that may endanger the safe and reliable operation of its facilities.
Plan Review Team
Land Management
[email protected]
PG&E Gas and Electric Facilities Page 1
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April 25, 2023
Kelsey Evans
City of South San Francisco
315 Maple Ave
South San Francisco, CA 94080
Re: 800 Dubuque Avenue Project
800 Dubuque Avenue, South San Francisco, CA
Dear Kelsey:
Thank you for giving us the opportunity to review the subject plans. The proposed 800 Dubuque Avenue Project is within the same vicinity of PG&E’s existing facilities that impact this property.
The 800 Dubuque Avenue Project proposes to demolition of existing structures on the subject parcel. The applicant must contact the below resources to relocate or modify existing gas and electric service as needed. No structures are permitted to be built on any existing PG&E facilities to remain in place. Only plant lawns, flowers, low-profile grasses and low-growing herbaceous plants over any PG&E facilities within the subject parcels.
Please contact the Building and Renovation Center (BRSC) for facility map requests by calling 1-877-743-7782 and PG&E’s Service Planning department at www.pge.com/cco for any modification or relocation requests, or for any additional services you may require.
As a reminder, before any digging or excavation occurs, please contact Underground Service Alert (USA) by dialing 811 a minimum of 2 working days prior to commencing any work. This free and independent service will ensure that all existing underground utilities are identified and marked on-site.
If you have any questions regarding our response, please contact me at [email protected].
Sincerely,
Justin Newell
Land Management
916-594-4068
April 18, 2023
Christopher Espiritu, Senior Planner
City of South San Francisco
Economic and Community Development Department
315 Maple Street
South San Francisco, California 94080
TRANSMITTED VIA E-MAIL ONLY
[email protected]
Subject: SFO Comments on Initial Study/Mitigated Negative Declaration: 800 Dubuque Avenue Project, South San Francisco, California
San Francisco International Airport (SFO or the Airport) staff have reviewed the Initial Study/Mitigated Negative Declaration (IS/MND) for the 800 Dubuque Avenue Project (the Proposed Project), located in the City of South San Francisco. We appreciate this opportunity to provide comments on the IS/MND.
As described in the IS/MND, the Proposed Project is located at 800 Dubuque Avenue (Assessor’s Parcel Number 015-021-030), bordered by Dubuque Avenue and U.S. Highway 101 on the west and by the Caltrain right-of-way on the east; it is currently developed with two one-story buildings and one two-story building containing office/research and development (life science) uses and associated surface parking.
The Proposed Project consists of demolishing the three existing buildings and constructing three new office/research and development buildings containing a total of approximately 900,000 gross square feet and four levels of below-grade parking with a total of 1,335 parking spaces. The north building would be the tallest at approximately 195 feet above grade; the west and south buildings would be approximately 179 and 130 feet above grade, respectively. Including the mechanical penthouse on the tallest building, the maximum height of the Proposed Project would be approximately 215 feet above grade. The Proposed Project would include an event center, food/beverage uses, a fitness center, and a bicycle storage room. The three buildings would be connected by a two-story terrace featuring a central plaza and courtyard.
The Proposed Project site is inside Airport Influence Area B as defined by the Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport (SFO ALUCP). The Proposed Project site would be located outside the 65-decibel (dBA) Community Noise Equivalent Level (CNEL) contour and the Safety compatibility zones, and therefore would not appear to be inconsistent with the Noise and Safety Compatibility policies adopted in the SFO ALUCP. However, many airport departure procedures currently are designed to ascend over the project area, and overnight uses in particular could experience some noise disturbances from aircraft departures.
As described in Exhibit IV-17 of the ALUCP (see Attachment), the critical aeronautical surface at the Proposed Project location is at an elevation of approximately 860 feet above mean sea level (AMSL) as defined from the origin of the North American Vertical Datum of 1988 (NAVD88). Given that the ground elevation at the Proposed Project site is around 19 feet AMSL (NAVD88), the heights of the buildings as currently defined (195, 179, and 130 feet above ground level) would be below the critical aeronautical surfaces and the Proposed Project would not appear to be incompatible with the Airspace Compatibility Policies of the SFO ALUCP, subject to the issuance of a Determination of No Hazard from the Federal Aviation Administration (see below) for any proposed structures and determinations from the City/County Association of Governments of San Mateo County as the designated Airport Land Use Commission.
DocuSign Envelope ID: 3316EA2A-4486-4A10-8142-5ADF1D7D051E Christopher Espiritu, City of South San Francisco
April 18, 2023
The Project Description section on page 3 of the IS/MND includes the following language: “The north building would be the tallest at approximately 195 feet above grade, and the west and south buildings would be approximately 179 and 130 feet above grade, respectively (including the mechanical penthouses).” Based on the sections and elevations provided in Figures 5 through 7 of the IS/MND, the elevations of the north, west, and south buildings including the mechanical penthouses are approximately 215, 199, and 147 feet AMSL, respectively.
We note that in the Initial Study Checklist for the Proposed Project, the height limitations described in the Hazards and Hazardous Materials section are not characterized accurately. The section states: “Development on the project site is limited to maximum heights of 261 feet above mean sea level but could be modified through consultation with the Federal Aviation Administration (FAA).” The “maximum heights” described in the previous sentence are FAA obstruction evaluation surfaces described in 14 Code of Federal Regulations Part 77 Section 19, of which penetrations are considered obstructions, but not necessarily hazards to air navigation. Higher structures could be permissible through consultation with the FAA as long as the structures do not conflict with the critical aeronautical surfaces of the SFO ALUCP. Thus, the Proposed Project does not appear to be inconsistent with both height limitations (FAA and ALUCP critical aeronautical surface) identified in the SFO ALUCP, pending an FAA determination of no hazard.
This determination does not negate the requirement for the Proposed Project sponsor to undergo Federal Aviation Administration review as described in 14 Code of Federal Regulations Part 77 for both (1) the permanent structures and (2) any temporary cranes or other equipment taller than the permanent buildings which would be required to construct those structures.
* * *
The Airport appreciates your consideration of these comments. If I can be of assistance, please do not hesitate to contact me at (650) 821-6678 or at [email protected].
Sincerely,
Nupur Sinha
Director of Planning and Environmental Affairs
San Francisco International Airport
P.O. Box 8097
San Francisco, California 94128
Attachment
cc: Susy Kalkin, ALUC
Audrey Park, SFO
Chris DiPrima, SFO
DocuSign Envelope ID: 3316EA2A-4486-4A10-8142-5ADF1D7D051E THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY NOVEMBER 2012 Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport [IV-34] Airport/Land Use Compatibility Policies
and associated with human disease of varying severity.
b. Biosafety Level 3 practices, safety equipment, and facility design and construction are applicable to clinical, diagnostic, teaching, research, or production facilities in which work is done with indigenous or exotic agents with a potential for respiratory transmission, and which may cause serious and potentially lethal infection. c. Biosafety Level 4 practices, safety equipment, and facility design and construction are applicable for work with dangerous and exotic agents that pose a high individual risk of life-threatening disease, which may be transmitted via the aerosol route and for which there is no available vaccine or therapy.
4.5 Airspace Protection
The compatibility of proposed land uses with respect to airspace protection shall be evaluated in accordance with the policies set forth in this section. These policies are established with a twofold purpose:
1. To protect the public health, safety, and welfare by minimizing the public’s exposure to potential safety hazards that could be created through the construction of tall structures.
2. To protect the public interest in providing for the orderly development of SFO by ensuring that new development in the Airport environs avoids compromising the airspace in the Airport vicinity. This avoids the degradation in the safety, utility, efficiency, and air service capability of the Airport that could be caused by the attendant need to raise visibility minimums, increase minimum rates of climb, or cancel, restrict, or redesign flight procedures.
4.5.1 FEDERAL REGULATIONS REGARDING TALL STRUCTURES
14 Code of Federal Regulations (CFR) Part 77, Safe, Efficient Use and Preservation of the Navigable Airspace, governs the FAA’s review of proposed construction exceeding certain height limits, defines airspace obstruction criteria, and provides for FAA aeronautical studies of proposed construction. Appendix F describes the FAA airspace review process and the extent of FAA authority related to airspace protection.
4.5.2 PART 77, SUBPART B, NOTIFICATION PROCESS
Federal regulations require any person proposing to build a new structure or alter an existing structure with a height that would exceed the elevations described in CFR Part 77, Subpart B, Section 77.9, to prepare an FAA Form 7460-1, Notice of Proposed Construction or Alteration, and submit the notice to the FAA. The regulations apply to buildings and other structures or portions of structures, such as mechanical equipment, flag poles, and other projections that may exceed the aforementioned elevations.
DocuSign Envelope ID: 3316EA2A-4486-4A10-8142-5ADF1D7D051E THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY NOVEMBER 2012 Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport Airport/Land Use Compatibility Policies [IV-35]
Exhibit IV-10 depicts the approximate elevations at which the 14 CFR Part 77 notification requirements would be triggered; see Exhibit IV-11 for a close-up view of the northern half and Exhibit IV-12 for a close-up view of the southern half of the area. These exhibits are provided for informational purposes only. Official determinations of the areas and elevations within which the federal notification requirements apply are subject to the authority of the FAA.
The FAA is empowered to require the filing of notices for proposed construction based on considerations other than height. For example, in some areas of complex airspace and high air traffic volumes, the FAA may be concerned about the potential for new construction of any height to interfere with electronic navigation aids. In these areas, the FAA will want to review all proposed construction projects.
The FAA has developed an on-line tool for project sponsors to use in determining whether they are required to file a Notice of Proposed Construction or Alteration. Sponsors of proposed projects are urged to refer to this website to determine whether they are required to file Form 7460-1 with the FAA:
https://oeaaa.faa.gov/oeaaa/external/gisTools/gisAction.jsp?action=showNoNoticeRequiredToolForm
4.5.3 AIRSPACE MAPPING
Part 77, Subpart C, establishes obstruction standards for the airspace around airports including approach zones, conical zones, transitional zones, and horizontal zones known as “imaginary surfaces.” Exhibit IV-13 depicts the Part 77 Civil Airport Imaginary Surfaces at SFO. The imaginary surfaces rise from the primary surface, which is at ground level immediately around the runways. The surfaces rise gradually along the approach slopes associated with each runway end and somewhat more steeply off the sides of the runways. The FAA considers any objects penetrating these surfaces, whether buildings, trees or vehicles travelling on roads and railroads, as obstructions to air navigation.
Obstructions may occur without compromising safe air navigation, but they must be marked, lighted, and noted on aeronautical publications to ensure that pilots can see and avoid them.
Close-up views of the north and south sides of the Part 77 surfaces are provided in Exhibit IV-14 and Exhibit IV-15, respectively. Additionally, Exhibit IV-16 provides an illustration of the outer approach and transitional surfaces located on the southeast side of the Part 77 surfaces.
Together with its tenant airlines, SFO has undertaken a mapping effort to illustrate the critical aeronautical surfaces that protect the airspace required for multiple types of flight procedures such as those typically factored into FAA aeronautical studies, as shown on Exhibit IV-17 and Exhibit IV-18. These aeronautical surfaces include those established in accordance with FAA Order 8260.3B, U.S. Standard for Terminal Instrument Procedures (TERPS), and a surface representing the airspace required for One-Engine Inoperative (OEI) departures from Runway 28L (to the west through the San Bruno Gap).16 The exhibits depict the lowest elevations from the combination of the OEI procedure surface and all TERPS surfaces. The surfaces are defined with Required Obstacle Clearance (ROC) criteria to ensure safe separation of aircraft using the procedures from the underlying obstacles. Any proposed structures penetrating these surfaces are likely to receive Determinations of Hazard (DOH) from the FAA through the 7460-1 aeronautical study process. These surfaces indicate the maximum height at which structures can be considered compatible with Airport operations.
16 See Appendix F, Section F.3.2 for a discussion of one-engine inoperative procedures.
DocuSign Envelope ID: 3316EA2A-4486-4A10-8142-5ADF1D7D051E 280
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SHARP PA RK RD
SNEATH LN
PARK WY
C R ESPI DR
FLEETWOO D D R
MURCHISON D R
SULLIVAN AVE
ST FR ANCIS BLVD
JOHN DALY BLVD
RALSTON AVE
HE LEN DR
A RROYO DR
S AIRPORT BLVD
SKYLINE BO ULEVARD
GENEVA AVE
N HUMBOLDT ST
FASSLER AVE
BAYSHORE HWY
TILTON AVE
N AMPHLETT BLVD
N MCDONNELL R D
STATE HIGHWAY 35
HUNTINGTON AVE
LIN DA MAR BL VD
HICKEY BL V D
SHAW RD
ADELINE DR
E 4TH AVE
TERRA NOVA BLVD
HILLSIDE DR
LINDEN AVE
LO M ITA AVE
S SPR UCE AVE
SERRA M ONTE BL VD
CHESTNUT AVE
N DELAWARE ST
BELLEVUE AVE
E GRAND AVE
S NORFOLK ST
HOLLY A VE
CARMELITA AVE
S LINDEN AVE
UTAH AVE
LOYOLA DR
RAY DR
DWIGHT RD
OCCIDENTAL AVE
N SAN MATEO DR
C RESTMOOR DR
JENEVEIN AVE
MADISON AVE
MILLBRAE AVE
SISTER CITIES BLVD
CRYSTA L S PRINGS RD
W SAN B RUNO A V E
SEBASTIAN DR
ALTA MESA DR
LER ID A WY
PARK PLAZA DR
PAR K BLVD
JUNIPERO SERRA BLVD
ALICA N TE DR
MAGNOLIA AVE
SAN MATEO AVE
BROADWAY
HOFFMAN ST
RICHMOND DR
SE VILLE DR
MONTEREY RD
RIDGEWOOD DR
EASTON DR
EAR L AV E
SAN ANTONIO AVE
SHARON AVE
LARKSPUR DR
GATEWA Y DR
EL CERRITO AVE
CHATEAU DR
WESTLAKE AVE
BELLA VISTA DR
LIT T LEFIELD AVE
CROCKER AVE
E MARKET ST
LINCOLN AVE
OAKS DR
EL CAMINO REAL
ODDSTAD BLVD
HUNT DR
SUMMIT DR
EUCALYPTUS AVE
HELEN DR
STATE HIGHWAY 35
W SAN BRUNO AVE
EL CAM NI O REAL
SNEAT H LN
MAGNOLIA AVE
HILLSIDE BLVD
E 3RD AVE
Pacifica Pacifica
Daly City Daly City
San Bruno San Bruno
Brisbane Brisbane
San Mateo San Mateo
Colma Colma
Hillsborough Hillsborough
South San Francisco South San Francisco
Millbrae Millbrae Burlingame Burlingame
San Francisco San Francisco
Foster City Foster City
Broadmoor Broadmoor
Montara Montara
San Pedro Valley County Park San Pedro Valley County Park San Bruno Mt State & Cnty Park San Bruno Mt State & Cnty Park Golden Gate National Rec Area Golden Gate National Rec Area McNee Ranch State Park McNee Ranch State Park
San Andreas Lake San Andreas Lake
1. This map is intended for informational and conceptual planning purposes, generally representing the aeronautical surfaces considered most critical by San Francisco
International Airport (SFO) and its constituent airlines. It does not represent actual survey data, nor should it be used as the sole source of information regarding compatibility with airspace clearance requirements in the development of data for an FAA Form 7460-1, Notice of Proposed Construction or Alteration.
SFO does not certify its accuracy, information, or title to the properties contained in this plan. SFO does make any
warrants of any kind, express or implied, in fact or by law, with respect to boundaries, easements, restrictions, claims, overlaps, or other encumbrances affecting such properties.
2. This map does not replace the FAA's obstruction evaluation / airport airspace analysis (OE/AAA) review process. Proposing construction at elevations and heights that are lower than the critical aeronautical surfaces shown on this map, (a) does not relieve the construction sponsor of the obligation to file an FAA Form 7460-1, and (b) does not ensure that the proposal will be acceptable to the FAA, SFO, air carriers, or other agencies or stakeholders. SFO, San Mateo County, and local authorities having jurisdiction reserve the right to re-assess, review, and seek modifications to projects that may be consistent with this critical aeronautical surfaces map but that through the FAA OE/AAA process are found to have unexpected impacts to the safety or efficiency of operations at SFO.
Notes:
Exhibit IV-17
CRITICAL AERONAUTICAL SURFACES
-- NORTHWEST SIDE
Comprehensive Airport Land Use Plan
for the Environs of San Francisco International Airport C/CAG
City/County Association of Governments
of San Mateo County, California
Municipal Boundary
Road
Freeway
Railroad
Airport Property
BART Station
CALTRAIN Station
Regional Park or Recreation Area
Sources: San Francisco International Airport, Jacobs
Consultancy, and Planning Technology Inc., 2009
0 0.5 1 0.25
Miles
NORTH
Ground level
(Terrain)
Elevation of critical aeronautical surfaces, feet
Above Mean Sea Level (AMSL), North American
Vertical Datum of 1988 (NAVD88)
100
Height of Critical Aeronautical Surfaces, Feet Above
Ground Level (AGL)
LEGEND
Elevation of terrain, feet AMSL
Critical
aeronautical
surfaces
AIRPORT
Mean sea level
Elevation, feet AMSL
100 200 300 400
Elevation of critical aeronautical surfaces, feet AMSL (represented on plan with contours) Height of critical aeronautical surfaces,feet AGL (represented on plan with color gradient) Calculated as - =
0 Ground level
(Terrain)
A
B
C
A B C
A
B
C
A
C
35 and lower
35- 65
65 - 100
100 - 150
150 and more
DocuSign Envelope ID: 3316EA2A-4486-4A10-8142-5ADF1D7D051E THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY NOVEMBER 2012 Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport Airport/Land Use Compatibility Policies [IV-55]
Exhibit IV-19, which is provided for information purposes only, depicts a profile view of the lowest critical airspace surfaces along the extended centerline of Runway 10L-28R – the TERPS Obstacle Departure Procedure (ODP) surface, representing standard all-engines departures, and the approximate OEI surface developed by SFO through independent study in consultation with the airlines serving SFO. The exhibit also shows the terrain elevation beneath the airspace surfaces and various aircraft approach and departure profiles, based on varying operating assumptions. The exhibit illustrates a fundamental principle related to the design of airspace protection surfaces. The surfaces are always designed below the actual aircraft flight profile which they are designed to protect, thus providing a margin of safety.
Note that the ODP climb profile is above the ODP airspace surface, and the OEI climb profile is above the OEI airspace surface.
4.5.4 AIRSPACE PROTECTION POLICIES
The following airspace protection policies (AP) shall apply to the ALUCP.
AP-1 COMPLIANCE WITH 14 CFR PART 77, SUBPART B, NOTICE OF PROPOSED
CONSTRUCTION OR ALTERATION
AP-1.1 Local Government Responsibility to Notify Project Sponsors Local governments should notify sponsors of proposed projects at the earliest opportunity to file Form 7460-1, Notice of Proposed Construction or Alteration, with the FAA for any proposed project that would exceed the FAA notification heights, as shown approximately on Exhibit IV-10. Under Federal law, it is the responsibility of the project sponsor to comply with all notification and other requirements described in 14 CFR Part 77. This requirement applies independent of this ALUCP.
AP-1.2 FAA Aeronautical Study Findings Required Before Processing Development Application
The sponsor of a proposed project that would exceed the FAA notification heights, as shown approximately on Exhibit IV-10, shall present to the local government permitting agency with his or her application for a development permit, a copy of the findings of the FAA’s aeronautical study, or evidence demonstrating that he or she is exempt from having to file an FAA Form 7460-1. It is the responsibility of the local agency to consider the FAA determination study findings as part of its review and decision on the proposed project.
AP-2 COMPLIANCE WITH FINDINGS OF FAA AERONAUTICAL STUDIES Project sponsors shall be required to comply with the findings of FAA aeronautical studies with respect to any recommended alterations in the building design and height and any recommended marking and lighting of their structures for their proposed projects to be deemed consistent with this ALUCP.
DocuSign Envelope ID: 3316EA2A-4486-4A10-8142-5ADF1D7D051E THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY NOVEMBER 2012 Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport Airport/Land Use Compatibility Policies [IV-59]
AP-3 MAXIMUM COMPATIBLE BUILDING HEIGHT
In order to be deemed consistent with the ALUCP, the maximum height of a new building must be the lower of (1) the height shown on the SFO critical aeronautical surfaces map (Exhibits IV-17 and IV-18), or (2) the maximum height determined not to be a “hazard to air navigation” by the FAA in an aeronautical study prepared pursuant to the filing of Form 7460-1.
For the vast majority of parcels, the height limits established in local zoning ordinances are lower than the critical airspace surfaces. In those cases, the zoning district height regulations will control. Compliance with the zoning district height and the SFO critical aeronautical surfaces map, however, does not relieve the construction sponsor of the obligation to file a FAA Form 7460-1 Notice of Proposed Construction or Alteration, if required, and to comply with the determinations resulting from the FAA’s aeronautical study.
For a project to be consistent with this ALUCP, no local agency development permits shall be issued for any proposed structure that would penetrate the aeronautical surfaces shown on Exhibits IV-17 and IV-18 or the construction of which has not received a Determination of No Hazard from the FAA, or which would cause the FAA to increase the minimum visibility requirements for any instrument approach or departure procedure at the Airport.
AP-4 OTHER FLIGHT HAZARDS ARE INCOMPATIBLE
Proposed land uses with characteristics that may cause visual, electronic, or wildlife hazards, particularly bird strike hazards, to aircraft taking off or landing at the Airport or in flight are incompatible in Area B of the Airport Influence Area. They may be permitted only if the uses are consistent with FAA rules and regulations. Proof of consistency with FAA rules and regulations and with any performance standards cited below must be provided to the Airport Land Use Commission (C/CAG Board) by the sponsor of the proposed land use action.
Specific characteristics that may create hazards to aircraft in flight and which are incompatible include:
(a) Sources of glare, such as highly reflective buildings or building features, or bright lights, including search lights or laser displays, which would interfere with the vision of pilots making approaches to the Airport.
(b) Distracting lights that that could be mistaken by pilots on approach to the Airport for airport identification lighting, runway edge lighting, runway end identification lighting, or runway approach lighting.
(c) Sources of dust, smoke, or water vapor that may impair the vision of pilots making approaches to the Airport.
(d) Sources of electrical interference with aircraft or air traffic control communications or navigation equipment, including radar.
(e) Land uses that, as a regular byproduct of their operations, produce thermal plumes with the potential to rise high enough and at sufficient velocities to interfere with the control of aircraft in DocuSign Envelope ID: 3316EA2A-4486-4A10-8142-5ADF1D7D051E THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY NOVEMBER 2012 Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport [IV-60] Airport/Land Use Compatibility Policies
flight. Upward velocities of 4.3 meters (14.1 feet) per second at altitudes above 200 feet above the ground shall be considered as potentially interfering with the control of aircraft in flight.17 (f) Any use that creates an increased attraction for wildlife, particularly large flocks of birds, that is inconsistent with FAA rules and regulations, including, but not limited to, FAA Order 5200.5A, Waste Disposal Sites On or Near Airports, FAA Advisory Circular 150/5200-33B, Hazardous Wildlife Attractants On or Near Airports, and any successor or replacement orders or advisory circulars. Exceptions to this policy are acceptable for wetlands or other environmental mitigation projects required by ordinance, statute, court order, or Record of Decision issued by a federal agency under the National Environmental Policy Act.
4.5.5 iALP AIRSPACE TOOL
In consultation with C/CAG, SFO developed the iALP Airspace Tool, a web-based, interactive tool to evaluate the relationship of proposed buildings with the Airport’s critical airspace surfaces. The iALP Airspace Tool is designed to assist planners, developers, and other interested persons with the implementation of the airspace protection policies of the SFO ALUCP. The tool helps users determine: (1) the maximum allowable building height at a given site, and/or (2) whether a building penetrates a critical airspace surface, and by how much, given the proposed building height.
A more detailed description of the iALP Airspace Tool and a tutorial explaining how to use it is presented in Appendix J. Use of this tool, however, does not relieve a project sponsor of the duty to comply with all federal regulations, including the obligation to file Form 7460-1, Notice of Proposed Construction or Alteration, with the FAA. 17 This is a threshold established by the California Energy Commission in its review of power plant licensing applications. See Blythe Solar Power Project:
Supplemental Staff Assessment, Part 2,. CEC-700-2010-004-REV1-SUP-PT2, July 2010. California Energy Commission. Docket Number 09-AFC-6, p.
25. This criterion is based on guidance established by the Australian Government Civil Aviation Authority (Advisory Circular AC 139-05(0), June 2004). The FAA’s Airport Obstructions Standards Committee (AOSC) is studying this matter but has not yet issued specific guidance.
DocuSign Envelope ID: 3316EA2A-4486-4A10-8142-5ADF1D7D051E From: Frost, Erik@DOC <[email protected]>
Sent: Tuesday, April 25, 2023 12:23 PM
To: Evans, Kelsey <[email protected]>
Subject: RE: NOA/NOI - 800 Dubuque Avenue Project - South San Francisco, CA Hello Kelsey Evans,
The California Geological Survey (CGS) has reviewed the Initial Study & Mitigated Negative Declaration (IS/MND) for the proposed 800 Dubuque Avenue project. The IS/MND incorrectly states “the project site is not within a mapped liquefaction hazard zone.” The CGS has prepared a Seismic Hazard Zone Report and Earthquake Zone of Required Investigation Map for the San Francisco South quadrangle, and the project site is in fact located within a zone of required investigation for liquefaction. However, the IS/MND goes on to state that liquefaction potential was assessed in a geotechnical investigation.
For future reference, Earthquake Zones of Required Investigation can be reviewed here:
https://maps.conservation.ca.gov/cgs/EQZApp/app/
Associated maps, report, and GIS data are available here:
https://maps.conservation.ca.gov/cgs/informationwarehouse/index.html?map=regulatory maps
Please let me know if you have any questions.
Erik
Dr. Erik Frost
Senior Engineering Geologist | Seismic Hazards Program