Exhibit A - Vantage II CEQA Checklist Sept 2023 — South San Francisco City Council, December 13, 2023 (part 1 of 2)

Vantage Campus Master Plan Project
Initial Study/CEQA Analysis
September, 2023
Prepared for:

City of South San Francisco
315 Maple Avenue
South San Francisco, CA 94080
Prepared By:

Lamphier–Gregory
1944 Embarcadero
Oakland, CA 94606
Vantage Master Plan Project – CEQA Analysis page i
Table of Contents
Vantage Master Plan Project - Initial Study/CEQA Document Project Information ......................................................................................................................................1 Purpose of this CEQA Document
Initial Study ......................................................................................................................................2 Project Consistent With a Community Plan or Zoning ....................................................................3 Potential for Additional Environmental Review ..............................................................................4 Project Description
Project Location and Surrounding Land Uses .................................................................................5 Project Site .......................................................................................................................................7 Background and Entitlement History ...............................................................................................9 General Plan Designation and Zoning ...........................................................................................11 Detailed Project Description – Vantage Campus Master Plan ......................................................15 Development Phasing ....................................................................................................................31 List of Project Approvals Required ................................................................................................33 Project’s Consistency with General Plan and Zoning
Consistency with Shape SSF 2040 General Plan Update................................................................35 Consistency with Title 20 (Zoning) of the South San Francisco Municipal Code ...........................37 Conclusions ....................................................................................................................................41 Initial Study / CEQA Checklist
CEQA Section 15183 Checklist........................................................................................................42 Reliance on a Prior Program EIR ....................................................................................................43 Aesthetics.................................................................................................................................48 Agriculture and Forestry Resources.........................................................................................55 Air Quality ................................................................................................................................57 Biological Resources ................................................................................................................72 Cultural Resources...................................................................................................................82 Energy ......................................................................................................................................87 Geology and Soils.....................................................................................................................92 Greenhouse Gas Emissions....................................................................................................105 Hazards and Hazardous Materials.........................................................................................114 Hydrology and Water Quality ................................................................................................127 Land Use and Planning...........................................................................................................140 Mineral Resources .................................................................................................................145 Noise and Vibration ...............................................................................................................146 Population and Housing.........................................................................................................152 Public Services and Recreation ..............................................................................................155 Transportation .......................................................................................................................162 Tribal Cultural Resources ......................................................................................................175 Utilities and Service Systems ................................................................................................178 Wildfire ..................................................................................................................................191 Mandatory Findings of Significance ......................................................................................195 Vantage Master Plan Project – CEQA Analysis page ii
CEQA Determination/Findings ................................................................................................................203 Sources and References ...........................................................................................................................206 List of Tables
Table 1 Existing Land Use at Project Site ...............................................................................................7 Table 2 Previously Entitled Development ............................................................................................11 Table 3 Project’s Proposed New Building Space ..................................................................................16 Table 4 Projected Employment ............................................................................................................20 Table 5 Estimated Parking Demand for the Project ............................................................................21 Table 6 Project’s Proposed Parking ......................................................................................................21 Table 7 Proposed Subdivision of the Project Site ...............................................................................31 Table 8 Regional Air Pollutant Emissions during Construction ............................................................60 Table 9 Net Operational Emission, at General Plan Buildout 2040 .....................................................66 Table 10 Project’s Operational Emissions of Criteria Pollutants ...........................................................68 Table 11 Project’s Building Energy Demands ........................................................................................89 Table 12 Project’s Expected Building Performance vs 2019 CalGreen Energy Efficiency Standards ....90 Table 13 Project’s Required 20% Energy Reduction over CALGreen “Baseline” .................................108 Table 14 Proposed TDM Measures.......................................................................................................164 Table 15 Calculation of Project Trip Cap ..............................................................................................166 Table 16 Estimated Trip Cap at Build-Out: Various Employment Densities ........................................166 Table 17 Project’s Home-Based Work VMT/Employee, with TDM .....................................................167 Table 18 Summary of Estimated Annual Water Demand ....................................................................183 List of Figures
Figure 1 Project Site Location and Surrounding Land Uses ..............................................................6 Figure 2 Project Site ..........................................................................................................................8 Figure 3 Previously Entitled Phase 1 of Vantage Campus Project...................................................10 Figure 4 South San Francisco General Plan Land Use Map.............................................................13 Figure 5 South San Francisco Zoning Map ......................................................................................14 Figure 6 Vantage Campus Master Plan (Project) ............................................................................17 Figure 7 Architectural Rendering of Project, from Forbes Boulevard ............................................19 Figure 8 Vehicle Circulation Plan.....................................................................................................22 Figure 9 Pedestrian, Bicycle and Transit Access .............................................................................24 Figure 10 Conceptual Landscape Plan ..............................................................................................25 Figure 11/12 Proposed Community Benefits – Fire Station and Amenity Building................................28 Figure 13 Proposed Vesting Tentative Map and Lot Layout .............................................................30 Figure 14 Project’s Proposed Phasing Plan ......................................................................................32 Figure 15 Changes in Visual Character .............................................................................................51 Figure 16 Ecologically Sensitive Areas ..............................................................................................75 Figure 17 Geologic Maps Showing Locations of High Sensitivity for Paleontological Resources ...103 Figure 18 South San Francisco Flood Hazard Zones and Tsunami Inundation Areas......................137 Figure 19 Sea Level Rise Risk (2100 Mid-level Scenario) ................................................................139 Vantage Master Plan Project – CEQA Analysis page iii
Figure 20 FAA Part 77 Airport Imaginary Surface ...........................................................................143 Figure 21 Wildfire Hazard Severity Zones ......................................................................................193 Attachments and Technical Appendices (bound separately) Attachment A Vantage Master Plan, Mitigation Monitoring and Reporting Program (MMRP) Appendix B Lamphier-Gregory, California Emissions Estimator Model, Construction Period Emissions,November 2022
Appendix C Lamphier-Gregory, California Emissions Estimator Model, Operational Period Criteria Polutant Emissions,November 2022
Appendix D Meyers + and Lamphier-Gregory, Energy Performance Based on Preliminary Designs and Regulatory/Policy Compliance, November 2022
Appendix E Langan Engineering and Environmental Services, Inc., Preliminary Geotechnical Site Assessment, Gallo Site, October 27, 2020
Appendix F Langan Engineering and Environmental Services, Inc., Geotechnical Investigation for Vantage Phases 2 and 3, October 17, 2022
Appendix G Langan Engineering and Environmental Services, Inc., Preliminary Geotechnical Conclusions and Recommendations for Vantage Phase 2 – Fire Station, October 17, 2022 Appendix H Langan Engineering and Environmental Services, Inc., Phase I Environmental Site Assessment – Gallo Site, October 23, 2020
Appendix I Langan Engineering and Environmental Services, Inc., Soil Management Plan for Vantage Phases 2 and 3, November 4, 2022
Appendix J Fehr & Peers, Healthpeak Vantage Transportation Impact Analysis, August 2023 Appendix K Fehr & Peers, Healthpeak Vantage Transportation Demand Management Plan, August 2023 Appendix L Lamphier-Gregory, C/CAG VMT Estimation Tool Results, November 2022 Appendix M EKI Water and Environment, Water Supply Assessment for Healthpeak Vantage Project, March 2023
Vantage Master Plan Project – CEQA Analysis page 1
Project Information

1. Project Title: Vantage Master Plan
# P22-0117

2. Lead Agency Name and Address: City of South San Francisco Planning Division
315 Maple Avenue
South San Francisco, CA 94080

3. Contact Person: Christy Usher, Senior Planner
[email protected]

4. Project Location: 420, 440, 460 and 480/490 Forbes Boulevard South San Francisco, CA
Assessor’s Parcel Numbers: #015-050-890, #015-050-900, #015- 050-230, #015-050-710, #015-050-720, and #015-050-730

5. Project Sponsor’s Name and Address: HCP Forbes LLC and LS Forbes LLC Scott Bohn, Chief Development Officer
1920 Main Street, Suite #1200
Irvine, California, 92614

6. Existing General Plan Designation: Business Technology Park – High

7. Existing Zoning: Business Technology Park – High (BTP-H)

8. Requested Permits/Approvals: Findings of General Plan and Zoning consistency for the Master Plan
Conditional Use Permit (pursuant to SSF Zoning Ordinance Section

20.330.004 Required Parking Spaces) to allow parking in excess of the maximum parking ratio
Community Benefits Program/Community Benefits Agreement (included with Development Agreement)
Transportation Demand Management (TDM) Checklist and a TDM Plan
Vesting Tentative Subdivision Map Approval
Development Agreement
Vantage Master Plan Project – CEQA Analysis page 2
Purpose of this CEQA Document
The purpose of this document is to provide the required environmental review of the proposed Vantage Campus Master Plan Project (the Project), pursuant to the California Environmental Quality Act (CEQA). Pursuant to CEQA Guidelines Section 15060 to 15065, the City of South San Francisco, as Lead Agency for environmental review of this Project, is required to commence the environmental review process according to the following processes:

1. “Once a lead agency has determined that an activity is a project subject to CEQA, the lead agency shall determine whether the project is exempt from CEQA”. A project is exempt from CEQA if it is . . . ,”exempt by statute (commencing with CEQA Guidelines Section 15260), or exempt pursuant to a categorical exemption (commencing with CEQA Guidelines Section 15300) and the application of that categorical exemption is not barred by one of the exceptions set forth in Section 15300.2” (CEQA Guidelines Section 15061).

2. “Following preliminary review, the Lead Agency shall conduct an Initial Study to determine if the Project may have a significant effect on the environment” (CEQA Guidelines Section 15063[a]).

3. “If the agency determines that there is substantial evidence that any aspect of the project, either individually or cumulatively, may cause a significant effect on the environment, the lead agency shall do one of the following:
• Prepare a Mitigated Negative Declaration or an EIR;
• Use a previously prepared EIR which the Lead Agency determines would adequately analyze the project at hand; or
• Determine, pursuant to a program EIR, tiering or another appropriate process, which of a project’s effects were adequately examined by an earlier EIR or negative declaration. ‘Another appropriate process’ may include, for example . . . approval of residential projects consistent with a community plan, general plan or zoning as described in CEQA Guidelines Section 15183” (CEQA Guidelines Section 15063[b]).

4. “The Lead Agency shall then ascertain which effects, if any, should be analyzed in a later EIR or Negative Declaration” (CEQA Guidelines Section 15063[c]).

The City of South San Francisco has determined that the Vantage Campus Master Plan Project requires consideration of discretionary actions or approvals including, but not limited to a Conditional Use Permit (pursuant to SSF Zoning Ordinance Section 20.330.004 Required Parking Spaces) to allow parking in excess of the maximum parking ratio, a Community Benefits Program/Community Benefits Agreement, (included with Development Agreement) a Transportation Demand Management (TDM) Checklist and a TDM Plan, a Vesting Tentative Subdivision Map and a Development Agreement. As such, the Project is subject to CEQA.

Initial Study
Pursuant to CEQA Guidelines Section 15063, this document consists of an Initial Study prepared by the City of South San Francisco, as Lead Agency, intended to provide the City of South San Francisco’s decision-making bodies (i.e., the South San Francisco Planning Commission and City Council) with information as to the potential environmental effects of the proposed Project. This initial study provides substantial evidence that supports the conclusion that the Project qualifies as a “project consistent with a Community Plan or Zoning” pursuant to CEQA Guidelines Section 15183. Consistent with these CEQA Guidelines, this Initial Study contains the following information:
• A description of the Project, including its location
Vantage Master Plan Project – CEQA Analysis page 3
• An examination of whether the Project is consistent with existing zoning, the South San Francisco General Plan, and other applicable land use controls
• An identification of the existing environmental setting • An identification of potential environmental effects of the Project, using a checklist method that includes adequate explanation and evidence to support the Checklist entries The checklist also includes a determination of whether the Project would result in significant effects that are peculiar to the Project or its site that were not were adequately examined in an earlier EIR, such that the Project may qualify as a project that is consistent with a Community Plan, General Plan or zoning, pursuant to Public Resources Code (PRC) Section 21083.3 and CEQA Guidelines Section 15183. The CEQA Checklist also provides information as to which environmental effects, if any, should be analyzed in a later Environmental Impact Report (EIR), Negative Declaration or Mitigated Negative Declaration (MND).

Project Consistent With a Community Plan or Zoning
PRC Section 21083.3 and CEQA Guidelines Section 15183 provides, “projects that are consistent with the development density established by existing zoning, community plan or general plan policies for which an EIR was certified shall not require additional environmental review, except as might be necessary to examine whether there are project-specific significant effects which are peculiar to the project or its site”. These provisions of CEQA are intended to streamline the environmental review of certain types of projects, and to reduce the need to prepare repetitive environmental studies. These provisions of CEQA apply only to projects that are consistent with a community plan adopted as part of a General Plan, a zoning action which zoned or designated the parcel on which the Project would be located to accommodate a particular density of development, or the General Plan of a local agency. Per CEQA Guidelines section 15183(i)(2), “consistent means that the density of the proposed project is the same or less than the standard expressed for the involved parcel in the general plan, community plan or zoning action for which an EIR has been certified, and that the project complies with the density-related standards contained in that plan or zoning. Where the zoning ordinance refers to the general plan or community plan for its density standard, the project shall be consistent with the applicable plan”. An EIR must have been certified by the Lead Agency for the community plan, the zoning action or the General Plan, for these provisions to apply.

Section 15183(a) of the CEQA Guidelines provides that, in approving a project meeting these requirements, “a public agency shall limit its examination of environmental effects to those impacts that the agency determines, in an Initial Study or other analysis:
• are peculiar to the project or the parcel on which the project would be located, • are not analyzed as significant effects in a prior EIR on the zoning action, General Plan or community plan,
• are potentially significant off-site impacts and cumulative impacts that were not discussed in the prior EIR prepared for the general plan, community plan or zoning action, or • are previously identified significant effects which, as a result of substantial new information which was not known at the time the prior EIR was certified, are determined to have a more severe adverse impact than discussed in the prior EIR”
When reviewing the environmental effects of the Project pursuant to these provisions, an effect of the Project on the environment shall not be considered peculiar to the Project if uniformly applied development policies or standards have been previously adopted by the City. A finding must have been made that the applicable development policies or standards will substantially mitigate environmental effects when applied to future Vantage Master Plan Project – CEQA Analysis page 4
projects, unless substantial new information shows that the policies or standards will not substantially mitigate the environmental effect. The finding shall be based on substantial evidence, which need not include an EIR.

This Initial Study/CEQA Checklist includes information to determine whether the Project is consistent with the development density established by existing zoning and the City of South San Francisco 2040 General Plan (SSF 2040 General Plan or Shape SSF 2040). This CEQA Checklist also examines whether the potential impacts of the Project have already been addressed in the City of South San Francisco General Plan Update, Zoning Code Amendments, and Climate Action Plan and Other CEQA Considerations Program EIR (SSF 2040 General Plan EIR), or whether the Project may have Project-specific significant effects which are peculiar to the Project or its site.

Potential for Additional Environmental Review
The provisions of CEQA Guidelines Section 15183 for projects that are consistent with a Community Plan or zoning would not apply to the Project if it were inconsistent with the development density established by the Shape SSF 2040 General Plan and applicable zoning regulations. These provisions of CEQA would not apply if the Project would have Project-specific significant environmental effects that are peculiar to the Project or its site, or if the Project would result in new or more severe significant environmental effects than were previously addressed in the prior SSF 2040 General Plan EIR (also referred to as the “Prior EIR” or the Program EIR” in this analysis).

Under such circumstances, the Project would trigger preparation of a Mitigated Negative Declaration or an Environmental Impact Report (EIR). This Initial Study fully analyzes the environmental impacts of the Project to determine the most appropriate approach for CEQA documentation of the Project in light of the certified SSF 2040 General Plan EIR and provides substantial evidence to support the conclusion that the Project is exempt from further CEQA review pursuant to CEQA Guidelines Section 15183.

Vantage Master Plan Project – CEQA Analysis page 5
Project Description
LS Forbes LLC and HCP Forbes LLC (the Project applicant) has assembled multiple contiguous parcels along Forbes Boulevard in the East of 101 area under its ownership and proposes to redevelop these properties in one research and development life sciences campus, to be known as the Vantage Campus Master Plan.

This section describes Phases 2 and 3 of the proposed Vantage Campus Master Plan (collectively, the Project) as evaluated in this CEQA Analysis. The following includes a description of the properties assembled under this Master Plan proposal (i.e., Project site) and their surroundings, existing site conditions, the proposed development of the Project site, and required Project approvals.

Project Location and Surrounding Land Uses
Project site is located in the central portion of the East of 101 area of the City of South San Francisco (see Figure 1). The site is approximately 0.65 miles due east of US Highway 101, approximately 1-mile due east of the San Bruno Channel of the San Francisco Bay, and approximately 2.7 miles north of the main terminal at the San Francisco International Airport.

Regional access to the site is provided primarily from US 101 via the East Grand Avenue interchange to Forbes Boulevard (at approximately 1.27 miles driving distance to the nearest intersection at Forbes Boulevard/Eccles Avenue. Secondary access to the site is via the Oyster Point Boulevard interchange at US 101 to Gull Drive, then Forbes Boulevard to the nearest intersection at Forbes Boulevard/Allerton Avenue. The Project site fronts the southerly side of Forbes Boulevard, from Allerton Avenue nearly to Eccles Avenue.

The Project site is 0.75 linear miles (an approximately 12-minute walk or seven-minute bicycle ride) from the South San Francisco Caltrain station.

Land uses within the immediate vicinity include the Genentech biotechnology campus to the east, including Genentech’s 2nd Generation childcare center to the immediate east. One- and two-story light industrial properties are along Cabot Road to the immediate south, one- and two-story light industrial and distribution properties are along the remaining portions of Forbes Boulevard to Eccles Avenue to the west, and one- and two-story light industrial properties are across Forbes Boulevard to the north (see Figure 1). The Project site is centrally located within the continuously growing life sciences and biotechnology hub of East of 101, amid many new and emerging campuses, corporate headquarters, research and development facilities, and offices.

Vantage Master Plan Project – CEQA Analysis page 6
Fig 1
Vantage Master Plan Project – CEQA Analysis page 7
Project Site
The Project site includes six properties with addresses at 420, 440, 460 and 480/490 Forbes Boulevard, totaling

18.99 acres, or 827,601 square feet (see Table 1). These properties, from east to west, include the following (see Figure 2):
• 480/490 Forbes Boulevard (Assessor’s Parcel Number (APN) 015-050-890) is 7.484 acres is size, and is currently under construction
• 460 Forbes Boulevard (APN #015-050-900) is 3.026 acres in size, and is now vacant after recent demolition of a prior 75,000 square-foot warehouse
• 440 Forbes Boulevard (APN #015-050-230) is 5.167 acres in size, with an existing 105,000 square-foot warehouse, and
• 420 Forbes Boulevard, with three separate parcels including APN #015-050-710 at 1.105 acres, APN #015-050-720 at 1.126 acres, and APN #015-050-730 at 1.091 acres. These properties are all vacant land, with the exception of a surface parking lot for trucks adjacent to the warehouse at 440 Forbes Boulevard
Table 1: Existing Land Use at Project Site
Address Parcel Number Lot Size Existing Use
480/490 Forbes Boulevard 015-050-890 7.484 acres Vacant / under construction 460 Forbes Boulevard 015-050-900 3.026 acres Vacant / under construction 440 Forbes Boulevard 015-050-230 5.167 acres 105,000 square-foot warehouse 420 Forbes Boulevard 015-050-710 1.105 acres Surface parking 015-050-720 1.126 acres Vacant
015-050-730 1.091 acres Vacant
Total: 18.99 acres 105,000 square feet bldg. space
Source: Flad Architects, Vantage Conditional Use Permit Application, October 2022 Other Existing Site Characteristics
None of the properties comprising the Project site are identified on a hazardous waste or substances site list as compiled pursuant to Government Code Section 65962.5 (i.e., the properties are not on the Cortese List).

There are no known historic resources within or directly adjacent to the Project site.

Forbes Boulevard forms the Project site’s northerly frontage and is a divided four-lane road with no parking on either side. There are no existing sidewalks along the Project site’s frontage on Forbes, but sidewalks do exist on the opposite, northerly side of the street. East of the Allerton Avenue intersection, Forbes Boulevard becomes a divided two-lane road with dedicated bike lanes in each direction and sidewalks on both sides of the street.

Allerton Avenue forms the Project site’s eastern frontage and is a divided two-lane road with dedicated bike lanes in each direction, and with sidewalks on both sides of the street.

Vantage Master Plan Project – CEQA Analysis page 8
Fig 2
Vantage Master Plan Project – CEQA Analysis page 9
The Project applicant previously converted a portion of the former rail spur that is immediately to the south of the Project site as part of the Rails-to-Trails network, as a 6-foot paved pedestrian and bicycle path. The Rails-toTrails path currently runs generally parallel to Forbes Boulevard, from the Genentech campus near the Bay Trail, past the Project site, to its current terminus near the Roebling Avenue cul-de-sac. The City’s Pedestrian and Bicycle Master Plan show this trail as eventually extending along Forbes Boulevard to East Grand Avenue and extending directly to the Caltrain station near US 101.

Existing landscaping and vegetation at the site are limited to sparse tree clusters along the perimeter of the 480/490 Forbes Boulevard parcel, and a narrow strip of landscape with mature trees along portions of the Forbes Boulevard frontage.

Background and Entitlement History
In 2012, the City of South San Francisco conducted environmental review for a project known as the 494 Forbes Boulevard Research & Development (R&D) Project. The environmental review document was a Second Partial Recirculated EIR (SCH #2006092054). The subject of that environmental review was the approximately 7.48-acre site located at the intersection of Forbes Boulevard and Allerton Avenue (with current address of 480/490 Forbes Boulevard). That prior project was the construction of two new R&D buildings totaling 326,020 square feet and a four-level parking garage. The CEQA document was certified, and that project was approved, but construction did not commence.

In November of 2019, the City re-approved development of the two lab/office buildings (Buildings A and B) located at 480/490 Forbes Boulevard, plus an at-grade 4-level parking structure with 954 parking spaces, and 24 surface lot parking spaces (for 978 total parking spaces). After that approval, a minor change to the approved plans was permitted to allow 742 surface parking spaces allocated among multiple properties, in lieu of the parking garage. Between December 2021 and April 2022, permits were issued for Buildings A and B for grading, foundations, and core and shell, and construction of those buildings is underway.

In March of 2022, the Project applicant obtained City approvals and modified these prior entitlements to construct 742 of the previously approved 978 surface parking spaces distributed across the three separate parcels at 420, 460 and 480/490 Forbes Boulevard, and to construct a third building, referred to as the Amenities Building, on the adjacent parcel at 460 Forbes Boulevard. Those March 2022 plans (see Figure 3) were considered by the City Planning Commission on June 16, 2022, and were approved as a minor modification to the prior approvals, including demolition of the existing warehouse and construction of a new Amenities Building. The Planning Commissions determined that these minor modifications did not result in new significant environmental effects or a substantial increase in the severity of identified significant effects as disclosed in the Second Partial Recirculated EIR. Table 2 summarizes the prior entitlements currently effective for these portions of the Project site.

Vantage Master Plan Project – CEQA Analysis page 10
Fig 3
Vantage Master Plan Project – CEQA Analysis page 11
Table 2: Previously Entitled Development
Address Lot Size Building Bldg. Size Parking Allocation 490 Forbes Boulevard

7.48 acres
Building B 179,345 sf
253
480 Forbes Boulevard Building A 146,675 sf
460 Forbes Boulevard 3.06 acres Amenities Bldg. 40,600 sf 180 440 Forbes Boulevard 5.18 acres 309
Subtotal: 742
Parking (in reserve) + 236
Total: 15.72 366,620 sf 978
Parking Ratio: 1 3.0/1,000 sf
Source: Flad Architects, Vantage Precise Plan (January 21, 2022) and Vantage Parking Entitlement (May 25, 2022) Notes:
1: Parking ratio recognizes that the parking allocation of 742 of the 978 approved parking spaces for the previously entitled 480/490 Forbes R&D buildings is distributed across three separate parcels, and assumes no parking allocation for the Amenities Building According to the SSF 2040 General Plan EIR, “existing land use conditions represent on-the-ground uses, projects that are entitled, under review or under construction, and approved plans”.1 The General Plan EIR used the existing land use conditions data as a baseline from which to determine environmental impacts of the General Plan update and to assess the level of development within the City based on reasonable assumptions for development activity anticipated to occur through buildout of the General Plan. Accordingly, the previously entitled development as described in Table 2 (hereafter referred to as Phase 1) is part of the General Plan’s baseline development, and only the subsequent development of Phases 2 and 3 (as further described below as the Project) represent additional development anticipated to occur pursuant to the Project.

General Plan Designation and Zoning
General Plan
On October 12, 2022, the City of South San Francisco adopted the SSF 2040 General Plan update (Shape SSF 2040). Shape SSF 2040 presents South San Francisco’s vision for the next two decades and provides, “a roadmap for the City to implement policies and actions that create a resilient community, improve the quality of life of its residents, and expand economic development opportunities.” Among the Guiding Principles for Shape SSF 2040 is the intent to “strengthen the City’s role as the worldwide hub of the biotech and life sciences industries and attract more jobs in the technology sector, professional office sector, and other sectors with long-term growth potential and the ability to diversify the city’s supply of high-wage jobs”. 2 Shape SSF 2040 seeks to retain and expand the life science land uses that will ensure the City remains a worldclass life sciences destination, but also recognizes that the city’s inventory of light industrial space is declining.

Expansion of office/R&D space for biotechnology and life sciences businesses drives reuse or redevelopment of existing industrial buildings, such as at the Project site. Accordingly, Shape SSF 2040 seeks to allow for growth and the continued success of life sciences by intensifying development along and north of East Grand Avenue and close to key transportation corridors, in exchange for community benefits and district-wide improvements. 1 City of SSF, SSF 2040 General Plan EIR, 2022, page 2-10 2 City of SSF, Shape SSF 2040 General Plan, 2022, page 11 Vantage Master Plan Project – CEQA Analysis page 12
By allowing the life sciences area to grow through intensification rather than expanding its geographic area, Shape SSF 2040 enables transportation, trade and industrial uses to remain on other lands and continue to thrive in East of 101.3
Shape SSF 2040 specifically seeks to direct intensification of new life sciences development by re-designating certain lands in the East of 101 area, generally along and north of East Grand Avenue and along Forbes Boulevard and Oyster Point Boulevard, with a General Plan land use designation of ‘Business Technology Park High’.

The Project site is centrally located within this Business Technology Park High land use designation (see Figure 4). This land use designation is intended to provide for high-density development of a wide range of corporate, R&D, and office uses, at floor-to-area (FAR) ratios that range from 0.5 up to 2.0, depending on the extent of community benefits provided.

Zoning
Concurrent with its General Plan update, the City has also updated its Zoning Ordinance with land use regulations intended to implement the new General Plan. The Zoning Ordinance includes a new non-residential zoning district, Business Technology Park-High (BTP-H), which corresponds to the General Plan land use designation of Business Technology Park High. The BTP-H zoning district provides areas for campus-like environments for corporate headquarters, research and development facilities, and offices. Typical uses include incubator-research facilities, prototype manufacturing, testing, repairing, packaging, publishing and printing, as well as offices and research and development facilities. Warehousing, distribution, manufacturing, retail, personal services, grocery and hotel use are also allowed. The Project site is centrally located within this BTP-H zoning district (see Figure 5).

A provision of this zoning district provides for a potential maximum FAR of between 0.5 and up to 2.0 for clean technologies, office and R&D land uses, depending on the provision of community benefits. Chapter 20.395 of the Zoning Ordinance establishes the non-residential Community Benefits Program by which the City may grant additional development capacity (i.e., an FAR bonus) in exchange for community benefits. The Community Benefits Program is a means by which the City can derive greater benefits for the broader community by granting planning entitlements that would be greater than would otherwise be possible through base zoning district standards.
3 City of SSF, Shape SSF 2040 General Plan, 2022, page 95 Vantage Master Plan Project – CEQA Analysis page 13
Fig 4
Vantage Master Plan Project – CEQA Analysis page 14
Fig 5
Vantage Master Plan Project – CEQA Analysis page 15
Potential community benefits may include:
• public spaces beyond the requirements of the base zoning district and applicable design standards • enhanced transportation connectivity beyond the requirements of the base zoning district standards and applicable design standards (e.g., new through streets, bicycle/pedestrian paths or other connections to existing trails)
• on-site provision of non-profit social services and/or public facilities • support for local businesses (e.g., tenant space for local small businesses; building frontage devoted to active walk-in uses such as retail, restaurant, or café; participation in a local hire program, and/or façade improvements or enhancements)
• TDM measures beyond those required, and
• contributions to, or construction of district-wide sea level rise mitigation measures (i.e., construction of levees or sea walls, creek restoration and improvements, construction of detention basins, or landscaping efforts aimed at creating biodiversity and improving resilience in impacted areas Detailed Project Description – Vantage Campus Master Plan Phases 2 and 3 The following provides a description of the Project, including the Project applicant’s objectives for the Project, proposed development (including previously approved and new office/lab buildings, parking and site circulation, and landscaping), proposed community benefits that are part of the Project, a proposed Vesting Tentative Map, development phasing and construction sequencing, and a list of approvals necessary for Project implementation.

Project Objectives
The Project applicant has proposed development of the Vantage Campus Master Plan to provide, “an exemplary model of the type of high-quality new development that can be achieved with an increase in FAR in the East of 101 area”. Specifically, the Project has the following primary objectives for the Project:

1. Create opportunities to further the City of South San Francisco’s ability to attract and house high caliber research and development companies by providing additional new construction and build-to-suit lab/office space to prospective science and technology tenants.

2. Create a distinctive architectural character and outdoor open space amenities that define the Vantage Campus as a destination within the larger context of the surrounding East of 101 neighborhood.

3. Accommodate substantial growth in the population of highly trained and specialized workers within the city, with corollary benefits including increased foot and bicycle traffic, public transit ridership, retail transactions, and commercial and community engagement.

4. Construct future site improvements that meet current City of South San Francisco sustainability standards.

5. Add programmed landscape spaces at the campus that connect the Project site with the larger City open space network.

6. Establish a clearly articulated hierarchy of pedestrian and vehicular circulation to and through the site with architectural and site design features for visitors, workers and service vehicles arriving by car, shuttle or truck.

7. Replace surface parking with new parking structures to better accommodate future green space and outdoor amenities.

Vantage Master Plan Project – CEQA Analysis page 16

8. Provide a location for the City to potentially design and construct a new City fire station to serve both the existing and planned development in the East of 101 neighborhood.

New Building Space
The Project proposes approximately 1.65 million square feet of new building space on the Project site, anticipated to accommodate health sciences/biotechnology tenants, including approximately 366,000 square feet of previously entitled buildings and 1.29 million square feet of proposed new construction.

The Project would retain the previously entitled Lab/Office buildings (Buildings A and B) at 480/490 Forbes Boulevard, and the separate Amenity building at 460 Forbes Boulevard.

To accommodate new construction, the Project proposes to demolish the existing warehouse building at 440 Forbes Boulevard, which is approximately 105,000 square feet in size. The Project would construct four new lab/office buildings (Buildings C, D, E and F) on the redeveloped properties (see Figure 6). The new Buildings C, D, E and F are intended as lab and office space, accommodating future new life science and technology/biotechnology tenants. Individual floor plans for these buildings will be developed at a later phase, once the tenants have been identified and their individual needs are established. The buildout assumptions for the Vantage Campus Master Plan are summarized in Table 3, below.

Table 3: Project’s Proposed New Building Space
Building Building Area (sf) # of Floors Bldg. Height
Previously Approved (Phase I) 1
Building A 146,675 5 106’
Building B 179,345 6 123’
Amenity 40,600 2 47’
Subtotal: 366,620
Proposed New Construction (the Project, Phase 2 and 3)
Building C 440,000 12 237’
Building D 249,000 8 169’
Building E 283,000 10 203’
Building F 316,582 10 203’
Subtotal: 1,288,582
Total Building Space 1,655,202
Resulting FAR 2 2.0
Source: Flad Architects, Vantage Conditional Use Permit Application, October 2022 Notes:

1. See prior Table 2

2. FAR calculation based on total building space (previously approved and proposed new construction) of 1,655,202 sf / 18.99 acres (or 827,601 square feet) = 2.0
The net gain of building area on the Project site, not including the previously approved Amenity, A and B buildings, is 1,183,582 square feet (1,288,582 square feet of new construction, less 105,000 square feet of demolished warehouse space).

Vantage Master Plan Project – CEQA Analysis page 17
Fig 6
Vantage Master Plan Project – CEQA Analysis page 18
Pursuant to Chapter 20.395 of the Zoning Ordinance, achieving the desired development intensity at an FAR of

2.0 is subject to the City approving additional development capacity (i.e., an FAR bonus) in exchange for community benefits. The Project’s proposed community benefits are described in a separate Community Benefits section of this Project Description.

Architectural Design
The architecture for each of the Project’s new buildings is thematically consistent with the previously approved Buildings A and B and the Amenity building (see Figure 7). The exterior structural supports for the new buildings area are all made of steel columns and beams, with high-performance insulated glazing set in steel and metal panel/glass shadow boxes as the primary façade materials. Metal fins separate each floor at the exterior. At the ground level, floor-to-ceiling, low iron, high performance insulated glazing units separated by metal panels are used, which provides greater transmission of light, a high degree of clarity and color fidelity.

TDM Plan
The Project is required to implement and monitor a Transportation Demand Management (TDM) Plan. The purpose of the TDM Plan is to provide options to encourage future employers and employees to use non-auto transportation modes, to encourage carpooling, biking, walking and transit use, and to incorporate on-site design features to promote the same.

The Project’s proposed TDM Plan includes a number of TDM measures that support a 50 percent reduction in vehicle miles traveled (VMT), including:
• Site enhancements, such as improved on- and off-site bicycle network, active transportation gap closure, end-of-trip facilities (storage showers and lockers), bicycle and pedestrian oriented site access, on-site pedestrian-oriented amenities, on-site car share, and bicycle maintenance facilities and on-site amenities
• Parking management strategies such as providing electric vehicle charging and designated parking • Programs and services such 50% Transit pass subsidies and pre-tax transit benefits, participation in Commute.org programs, carpool/vanpool programs and parking, and enhanced shuttle commitment. • Retain a full-time transportation coordinator
• Implement subsidized or discounted transit programs, and encourage telecommuting and alternative work schedules
Vantage Master Plan Project – CEQA Analysis page 19
Fig 7
Vantage Master Plan Project – CEQA Analysis page 20
Employment
The Project’s new buildings are intended as build-to-suit facilities, and the future tenant(s) of these buildings have not yet been identified. It is anticipated that the buildings will likely be occupied by a combination of R&D laboratories and/or corporate headquarters-type office space. The range of potential on-site employment will depend on the tenant occupancy, but the Project’s potential employment (inclusive of the previously entitled Phase 1 development) is projected to be approximately 5,975 employees, as shown in Table 4, below.

Table 4: Projected Employment
R&D Lab at 50% Office at 50% Amenity Total
Phase 1 (previously entitled)
Gross Building Space 1 163,010 163,010 40,600 366,620
SF per Employee Ratio 425 sf/employee 200 sf/employee 1,000 sf/employee Employees 383 815 40 1,238
Phases 2 and 3 (Project)
Gross Building Space 1 644,291 644,291 1,288,582
SF per Employee Ratio 425 sf/employee 200 sf/employee
Employees 1,516 3,221 4,737
Total Employees 5,975
Total Gross Building Space 1,655,202
Avg. Employees per Gross SF (at 1,655,202 sf) 277
Sources:

1. Flad Architects, Conditional Use Permit Application, October 2022 Parking
Parking Demand
The Project’s parking demand is primarily a function of the Project’s employment, with parking factors based on employee home-to-work commutes. Employee commute numbers are then adjusted to specifically reflect the Project’s consistency with the General Plan and zoning ordinance requirements to implement a TDM Plan.

Beginning at Phase 1 (the previously entitled portion of the Project), a TDM plan meeting the City’s Tier 3 requirements will be initiated. Beginning with Phase 2 approvals, the Project’s TDM Plan would transition to meet Tier 4 requirements, achieving up to a 50 percent reduction in drive-alone vehicle trips for the entire Project. The parking demand also recognizes the need for additional visitor parking, carpool parking and a reasonable “circulation factor”, which recognizes daily turnover and efficiencies in parking design, as indicated in Table 5. These factors are taken from the methodology presented in the city’s Transportation Impact Analysis Guidelines for calculating a site-specific trip cap.

Vantage Master Plan Project – CEQA Analysis page 21
Table 5: Estimated Parking Demand for the Project
Building Space (sf) Employee Parking Factors Parking Demand Project 1,655,202 5,975 employees
Daily Drive Alone Rate (per TDM) 50% 2,987
Carpool 12% at 3 persons per carpool 239
Visitor Rate + 5% 299
Parking Demand (full occupancy) 3,525
90% Circulation Factor + 5% + 176
Total Parking Demand 3,701
Parking Spaces/SF 2.24 spaces/KSF
Sources:

Flad Architecture – building space and employment
South San Francisco Transportation Impact Analysis Guidelines: Trip Cap Calculation Guidance, p. 33 As shown above, the Project’s anticipated 5,975 total employees generate a demand for 3,701 parking spaces.

With 1,655,202 square feet of total building space, this equates to an approximate parking ratio for the entire Project of 2.24 parking spaces per 1,000 square feet of building space.

Table 20.330.004 of the SSFMC establishes a parking ratio based on land use types, with 1.5 parking spaces per 1,000 square feet of R&D building space. The total parking allowance for Phases 2 and 3 of the Project would be 2,422 spaces at a ratio of 1.5 spaces per 1,000 square feet.

The Project applicant seeks approval of a CUP that would enable an overall Project parking ratio of 2.24 parking spaces per 1,000 square feet of building space, yielding 3,701 parking spaces, as indicated in Table 6.

Table 6: Project’s Proposed Parking
Parking Levels Height (feet) Structure Area (sf) # of Parking Spaces Surface stalls surface N/A N/A 47
Parking Structure 1 12 floors, plus roof 129 417,536 1,194 Parking Structure 2 12 floors, plus roof 129’ 417,536 1,324 Parking Structure 3 11 floors, plus roof 119’ 384,180 1,136 Total: 3,701
Source: Flad Architects, November 2022
Vehicle Circulation
Both Forbes Boulevard and Allerton Avenue serve as the primary vehicle access via a perimeter roadway that traverses the south and west edges of the Project site and connects to the parking garages (see Figure 8). The perimeter roadway intersects with Forbes Boulevard at the northwest and northeast portion of the Project site and intersects with Allerton Avenue at the southeast portion of the Project site. The perimeter roadway minimizes the number of vehicles that would be present within the central area of the campus.

Vantage Master Plan Project – CEQA Analysis page 22
Fig 8
Vantage Master Plan Project – CEQA Analysis page 23
Three secondary vehicle access points (two along Forbes Boulevard and one along Allerton Avenue) provide access to convenient drop-off points located at each building entry, and consolidated when possible, to reduce curb cuts. Compared to the primary access points, these secondary driveways will serve primarily visitors and commercial vehicles. Several service access points provide direct access to freight loading zones, which are distributed between buildings. These service access points are positioned in areas that will minimize traffic disruptions on Forbes Boulevard or Allerton Avenue. All roadways accommodate emergency vehicle access, and emergency vehicles can access the interior of the campus via drivable surfaces within the landscape.

Pedestrian, Bicycle and Transit Circulation
The Project site is approximately 0.75 miles, or an approximately 12-minute walk from the South San Francisco Caltrain station. The site is also served by the Commute.org shuttle system via the South San Francisco Ferry shuttle route, which connects via Forbes Boulevard with the South San Francisco Ferry Terminal and the South San Francisco Caltrain station. The Project will accommodate safe and convenient access to the City’s new onstreet shuttle stops along Forbes Boulevard or Allerton via on-site walkways that connect each building to shuttle stops to encourage employees to commute by transit (see Figure 9).

The City’s planned Class II buffered bicycle lanes along Forbes Boulevard (similar to the roadway design west of Allerton Avenue) will serve as the primary bicycle access to the Project site. This planned bicycle facility will provide a continuous bikeway along the Project site frontage, connecting the Project site to the new South San Francisco Caltrain station. Along the south frontage, bicycle access will be provided via the existing “Rails-ToTrails” Class 1 pathway that runs between Roebling Road and the Genentech Campus. The Project includes multiple on-site access pathways to provide direct connectivity to these bicycle facilities.

The Project’s proposed building lobbies are oriented along internal pedestrian corridors that connect the building entrances to the parking structures and to the Amenity building. This pedestrian corridor is separated from vehicular traffic, except at one crossing. A series of north-south pathways intersect the east-west corridor and connect to the transit and bicycle facilities along Forbes Boulevard to the north and Rails-to Trails to the south.

Landscape Concept
The landscape concept for the Project (see Figure 10) includes three key landscape features:
• A central promenade will function as the central pedestrian spine integrating the entire campus. This promenade will have an array of programs including plazas, amphitheaters, gateways, gardens, food truck areas, assembly spaces, parks and sport courts. Tall columnar trees will line the promenade. The promenade also functions as an emergency vehicle access lane, which is materially integrated within the space. A continuous linear artistic element is embedded in the promenade that will incorporate linear lighting, a leaning-rail, bio-swales, directional signage, benches and a prominent gateway. • Paseos will provide shared entries into the Campus on the north/south axis. Stormwater treatment facilities will be integrated along the paseos with bridges that span over stormwater swales and provide connections from the paseos to the building lobbies. The paseos are made of linear precast pavers. Two of the paseos connect to the Rails-to-Trails network, and all connect to a central promenade. • The public sidewalk at Forbes will be tree lined and shaded. Streetscape lighting standards will include fixtures for vehicular and pedestrian lighting. The City plans for the street to be redesigned to include Class II bike lanes. Campus flagpoles and building monument signage will be located at the paseo entries for wayfinding. The Allerton Avenue streetscape will include a continuous sidewalk that will connect to the central promenade. The streetscape between buildings B and C is integrated into the central campus design so that it feels like an extension of the campus interior.

Vantage Master Plan Project – CEQA Analysis page 24
Fig 9
Vantage Master Plan Project – CEQA Analysis page 25
Fig 10
Vantage Master Plan Project – CEQA Analysis page 26
The perimeter of the Campus will feature native plants, while the interior spaces will have a mix of shade tolerant, low water-use grasses and a number of special gardens featuring groupings of climate-appropriate plant materials. There will also be a large succulent garden. Shade-loving and shade tolerant plantings are specified for the main east-west promenade, which receives morning and afternoon shade for half of the year.

The site perimeter plantings are filled with California native and adapted plants. The majority of on-site plantings are low water use and native or adapted species, following Bay Friendly Planting Requirements as a baseline. Stormwater treatment areas are included, consistent with South San Francisco NPDES C3 stormwater treatment requirements. The treatment areas include a mix of bio-retention swales and flow-through planters, featuring plants that are adapted to occasionally wet conditions and can be flooded during large storm events.

Planting adjacent to service and back-of-house areas are to be low maintenance, low water use and adapted plantings. This includes parking garage screening plants and landscaped berms.

Utilities
The following summarizes the improvements included as part of the Project utilities and services program.

Stormwater Drainage System
The Project will incorporate stormwater management measures. The Project site is 50% impervious under existing conditions. Approximately 595,910 square feet of the Project site is impervious area connected to the City storm drain system. Between the end of Phase 1a and the beginning of Phase III, the Project site will be 79% impervious. Upon Project completion, the Project site will be 72% impervious. The temporary period between Phase 1a and Phase III will generate the highest amount of stormwater run-off. The Project design includes provisions for hydro-modification mitigation through use of an underground hydro-modification structure and underground detention, so that project flows will meet City requirements for peak runoff reduction during each phase of the project. The Project will include stormwater treatment best management practices (“BMPs”), including bio-filtration areas, flow-through planters, and pervious pavers and pavements, among other acceptable stormwater BMP types. The stormwater BMPs will generally be spread throughout the site, near the individual sources of run-off in-lieu of larger end-of-the-line BMPs to the maximum extent practicable. The design includes implementation of stormwater treatment BMPs with the completion of each phase of construction, sized to treat the total amount of impervious surface at each phase. A bioretention area connected to a 12-inch storm drain would be located on the Public Benefit/Fire Station site.

Water Supply
Based on the General Plan EIR’s water demand estimates for BTP-H land uses, the Project is anticipated to generate a demand of 336,000 gallons per day of water (equivalent to 377 acre-feet (“AF”) per year). This is approximately more than 50 AF per year more than the existing uses on the property. An 8-inch water line connected to the City network will also be located on the Public Benefit/Fire Station site for fire flow.

Sanitary Sewer
Sanitary sewers and separate laterals to serve each lot and shall be stubbed to property line prior to paving.

Sewer mains shall be of sufficient size to accommodate potential future development within the upstream basin. A 6-inch sanitary sewer line and a 6-inch potable water line would connect the Public Benefit/Fire Station site to the City’s main lines in Forbes Road.

Water lines, gas lines, electric lines, cable television substructures and other utility services to serve each lot and shall be stubbed to clear public improvements prior to paving. The subdivider will incorporate the installation of such facilities into the project design. Appurtenances and associated equipment such as, but not limited to, surface-mounted transformers, pedestal-mounted terminal boxes and meter cabinets, and concealed ducts in an underground system may be placed aboveground in commercial and industrial subdivisions only.

Vantage Master Plan Project – CEQA Analysis page 27
All surface-mounted installations shall be screened with landscaping in accordance with the Vantage Project Master Plan Landscaping Plan.

Energy and Efficiency Metrics
The Project is designed to comply with CalGreen efficiency standards. Both phases of the Vantage Project target achieving LEED Gold Certification.

Pursuant to the City’s 2022 Climate Action Plan Policy BNC 2.1, the City intends to adopt an all-electric reach code for non-residential new construction. Until the adoption of the non-residential all-electric reach code, this policy requires any new non-residential conditioned space of 5,000 square feet or more to comply with CALGreen Tier 2 energy efficiency requirements, exceeding mandatory energy efficiency requirements by 20% or more. Either the Project will comply with the all-electric reach code, or it will comply with the CAP policy. One option that the Project may pursue if an all-electric Project is not achieved is to incorporate a photovoltaic system that provides a 20% improvement over the baseline energy requirements of Title 24 of the California Energy Code. The Project’s Phases 2 and 3 can achieve the overall 20% Title 24 improvement by: 1) using industry-best performance photovoltaic panels; 2) achieving an 80% layout efficiency covering target areas; and 3) including heat recovery on lab exhaust systems.

Community Benefits
Chapter 20.395 of the SSF Zoning Ordinance establishes a non-residential Community Benefits Program by which the City may grant an FAR bonus, in exchange for providing greater benefits for the broader community than would otherwise be required under the zoning district standards. The Project proposes the following community benefits that are fully integrated into the Project plans:

Public Benefit/Fire Station Site
The Vantage Campus Master Plan provides an opportunity to support the City’s efforts to establish a new fire station that can better serve the East of 101 area. The existing Fire Station #62 is not in the closest proximity to the newer life sciences developments occurring alongside and north of the East Grand Avenue corridor. The Vantage Master Plan identifies an approximately one-acre site within the Master Plan boundaries at the westerly portion of the site that the Project applicant would offer for dedication to the City, intended for use as a fire station.

The public Benefit/Fire Station site is assumed to include a future approximately 9,600 square foot (± 500 square feet) fire station to improve fire service throughout the East of 101 area. The Fire Station will be located on an approximately one-acre (38,066 gross square-foot) parcel in the northwestern corner of the Vantage Project site, near the intersection of Forbes Blvd. and Eccles Avenue (see Figure 11). The Fire Station will fulfill one of the City’s goals of increasing the availability of public services in the East of 101 neighborhood, including fire service. The Fire Station will increase service levels to existing uses in East of 101, as well as to the planned mixed-use development around the nearby Caltrain station.

Vantage Master Plan Project – CEQA Analysis page 28
Fig 11-12
Vantage Master Plan Project – CEQA Analysis page 29
The Public/Benefit/Fire Station Site will be accessible from Forbes Boulevard. The Fire Station site would include a parking lot with 15 parking spaces for employees and visitors. The fire station would house one or two fire trucks and employ approximately 10 to 14 firefighters and staff. The fire trucks will be approximately 33-feet in size. The entire frontage along Forbes is accessible with separate fire truck/personal vehicles access. A left turn lane westbound on Forbes may need to be modified to accommodate a new fire station entrance. If the City prefers not to provide a full curb cut along Forbes, a back entrance to the Public Benefit/Fire Station Site for personal vehicles can be provided from the access road directly east of the proposed site.

The Project applicant will complete rough grading before conveying the Public Benefit Site to the City. The City is anticipated to accept the parcel prior to construction of a fire station. The Project applicant plans to convey the Public Benefit Site to the City in accordance with the Development Agreement and a Public Benefit Agreement.

Support for Local Business
The previously entitled portion of the Vantage Campus Master Plan includes a new Amenities building that is centrally located within the Campus (see Figure 12) and is intended to support both the Campus and the surrounding community. The program for this centrally located building is to activate the site and serve as a hub for the Project and the community. This building space will accommodate tenant space for a local Food Service vendor, with portions of the building frontage devoted to active walk-in uses such as restaurants, café, and bar.

Open Space
The SSF Zoning Ordinance Table 20.100.003(A): Development Standards establishes a minimum landscape requirement for new development within the BTP-H zone at 15% of the site. More specifically, Section

20.100.004(J): Public Open Space requires a minimum of five percent of the lot to be set aside for open space that is publicly visible and accessible, and located on the primary street frontage of the lot. Additionally, Section

20.100.004(K): Business, Technology and Office Park Design requires open space areas equal to 10% of the site that provide gathering space or opportunities for active or passive recreation, with amenities that enhance the comfort, aesthetics, or usability of the space.

The landscape concept for the Project includes three key landscape features, including a central east/west promenade pedestrian spine, separate paseos that provide shared entries into the Campus on the north/south axis, and streetscape landscaping along Forbes Boulevard and Allerton Avenue. Together, these landscape features account for approximately 215,000 square feet of landscaped area, or approximately 26% of the Project site. This proposed landscape area substantially exceeds the 15% minimum landscape requirement for new development within the BTP-H zone.

Vesting Tentative Map
The Project includes a Vesting Tentative Subdivision Map that subdivides the Project site into individual parcels that correspond to new buildings and parking structures on the Project site. The Vesting Tentative Subdivision Map would rearrange the lot lines that establish the existing six legal parcels, and further subdivide the site to create four new parcels, for ten total parcels on the site, as indicated in Table 7 and shown on Figure 13.

Vantage Master Plan Project – CEQA Analysis page 30
Fig 13
Vantage Master Plan Project – CEQA Analysis page 31
Table 7: Proposed Subdivision of the Project Site
Parcel Building/Structure Approximate Lot Size (sf)
Parcel A Proposed Public Benefit/Fire Station Site 38,066 sf Parcel 1 Buildings F 77,350 sf
Parcel 2 Buildings E 70,927 sf
Parcel 3 Buildings D 83,797 sf
Parcel 4 Buildings A 81,448 sf
Parcel 5 Building B 115,152 sf
Parcel 6 Building C 104,390 sf
Parcel 7 Amenity Building 68,374 sf
Parcel 8 Parking Structures 1 and 2 122,552 sf
Parcel 9 Parking Structures 3 65,545 sf
Total: 827,601 sf
Source: Vantage Preliminary Lot Line Exhibit, October 14, 2022 Development Grading and Phasing
Grading
Grading for Phase 2 will take approximately four weeks under three separate mobilizations. Phase 3 grading will similarly take four weeks with two separate mobilizations. The Project will require grading disturbance of approximately 586,390 square feet. This will result in approximately 55,833 cubic yards of cut, 4,472 cubic yards of fill, and 51,361 cubic yards of exported soil.

Phasing
The Project applicant would develop the Master Plan in three separate phases (see Figure 14):
• Phase 1 of the Project consists of completion of the previously entitled Building A, Building B and the Amenity Building, with 742 surface parking spaces spread across the properties at 480/490 Forbes Boulevard (253 spaces), 460 Forbes Boulevard (180 spaces), and 440 Forbes Boulevard (309 spaces).

Phase 1 includes demolition of both existing warehouses at 460 and 440 Forbes Boulevard. Phase 1 construction is currently underway, with completion expected in the first quarter of 2023. • Phase 2 of the Project consists of new construction of the approximately 440,000 square-foot lab/office Building C, the approximately 249,000 square-foot lab/office Building D, and Parking Structures 1 and 2.

In order to construct these new Project buildings, some of the existing 742 surface parking spaces constructed in Phase 1 will be removed and replaced by the new parking structures. Submittal of Precise Plans and City Design Review for Phase 2 is estimated to occur during the fourth quarter of 2022, with construction anticipated to start in the third quarter of 2023 and completed by the close of 2025.

Phase 2 is anticipated to include the City’s construction of a new fire station, pending City approval of the Development Agreement and Public Benefits/Fire Station Agreement that include the Project’s Community Benefits. Current assumptions are that the City will commence the new fire station design after Project approval, with construction completed within the term of the Development Agreement.

Vantage Master Plan Project – CEQA Analysis page 32
Fig 14
Vantage Master Plan Project – CEQA Analysis page 33
• Phase 3 of the Project consists of new construction of the approximately 283,000 square-foot lab/office Building E, the approximately 316,600 square-foot lab/office Building F, and parking Structure 3. The remainder of temporary surface parking installed in Phase 1 is to be removed in this phase. The timing of submittal of Precise Plans for Phase 3 is uncertain, but is estimated to occur sometime during the end of 2025, with construction anticipated to start on Phase 3 sometime after 2025.

List of Project Approvals Required
City of South San Francisco
The Project requires the following discretionary actions or approvals from the City of South San Francisco prior to implementation:
• Findings of General Plan and Zoning consistency for the Master Plan • Conditional Use Permit (pursuant to SSF Zoning Ordinance Section 20.330.004 Required Parking Spaces) to allow parking in excess of the maximum parking ratio • Community Benefits Program/Community Benefits Agreement (included with Development Agreement) • Transportation Demand Management (TDM) Checklist and a TDM Plan • Vesting Tentative Subdivision Map Approval
• Development Agreement
Subsequent discretionary approvals would include:
• Design Review/approvals of Precise Plans for individual buildings and parking garages (Design Review Board recommendations and Planning Commission design review authority) – required materials include site plans, elevations, floor plans, landscape plans, color renderings, and photos The Project will also require subsequent administrative permits from the City of SSF for the following:
• building, grading and other administratively approved construction-related permits • stormwater control/Consistency with MRP NPDES c.3 provisions Other Agency Approvals
The Project will also require subsequent approvals from the following additional agencies:
• Bay Area Air Quality Management District (BAAQMD), approval of a site-specific Asbestos Dust Mitigation Plan pursuant to Title 17 of the California Code of Regulations (17 CCR) Section 93105 – CARB Asbestos Airborne Toxic Control Measures (ATCM)
• BAAQMD permits (Authority to Construct or Permit to Operate) for any new sources of hazardous air pollutant emissions, including demonstrated achieved-in-practice best available control technology (BACT) for any large emergency backup engines
• San Mateo County Environmental Health Division (SMCEHD), review and approval of a Hazardous Material Business Plan pursuant to California Health and Safety Code for businesses handling and/or storing hazardous materials at minimum reportable quantities • SMCEHD, notification and review of the Project’s proposed change in land use and/or proposed soil removal activity
• SMCEHD, review and approval of a technical work plan (Soil Management Plan, or SMP) for soils proposed for on-site reuse and/or disposal
Vantage Master Plan Project – CEQA Analysis page 34
• State Water Board, acceptance of the applicant’s Notice of Intent to comply with, and undertake all other activities required by the Construction General Permit), including preparation of a Storm Water Pollution Prevention Plan (SWPPP)
• Federal Aviation Administration (FAA), to receive a Notice of Proposed Construction or Alteration and approval of an Obstruction Evaluation/Airport Airspace Analysis for each of the Project’s Buildings C, D, E and F, and each of the three proposed parking structures Vantage Master Plan Project – CEQA Analysis page 35
Project’s Consistency with the General Plan and Zoning
In October 2022, the City of South San Francisco adopted the City of South San Francisco 2040 General Plan Update (Shape SSF 2040). Shape SSF 2040 presents South San Francisco’s vision for the next two decades and, “provides a roadmap for the City to implement policies and actions that create a resilient community, improve the quality of life of its residents, and expand economic development opportunities.” The following analysis has been conducted to determine whether the proposed Project is consistent with the land use and development assumptions and improvement strategies of Shape SSF 2040 and applicable provisions and development standards of Title 20 of South San Francisco Municipal Code (SSFMC), as updated commensurate with the Shape SSF 2040. To be considered eligible for CEQA streamlining as a Project Consistent with a Community Plan or Zoning per CEQA Guidelines Section 15183, the Project must be consistent with the development density established by existing zoning and the General Plan’s density-related policies for which the SSF 2040 General Plan EIR was certified.

Consistency with Shape SSF 2040 General Plan Update
Guiding Principles
Among the Guiding Principles for Shape SSF 2040 is the intent to “strengthen the City’s role as the worldwide hub of the biotech and life sciences industries and attract more jobs in the technology sector, professional office sector, and other sectors with long-term growth potential and the ability to diversify the city’s supply of highwage jobs”.4 Consistency: The intent of the Vantage Campus Master Plan is to create new opportunities to further the City of South San Francisco’s ability to attract and house high-caliber research and development companies by providing additional new construction and lab/office space to prospective science and technology tenants. The Project would accommodate substantial growth in the population of highly trained and specialized workers, diversifying the city’s supply of high-wage jobs. The Project is fully consistent with this Guiding Principle of the Shape SSF 2040 General Plan.

Land Use and Community Design
Land Use
The General Plan land use designation for the Project site is Business Technology Park – High (see prior Figure 4).

This land use designation allows high-density development of a wide range of corporate, R&D and office uses.5 Consistency: The Project site is centrally located in the Business Technology Park – High land use designation. Properties surrounding the Project site to the north, west and south are also similarly designated as Business Technology Park – High, and properties to the east are within the Genentech campus and designated as Business Technology Park. The Project’s proposed new lab/office space is intended to accommodate prospective new science and technology tenants, fully consistent with the intent of this land use classification.
4 City of SSF, Shape SSF 2040, 2022, page 11
5 City of SSF, Shape SSF 2040, 2022, Figure 6 and Table 2 (page 65) Vantage Master Plan Project – CEQA Analysis page 36
Development Intensity
The Business Technology Park – High land use designation provides for new development with floor-to-area (FAR) ratios that range from 0.5 up to 2.0, depending on the extent of community benefits provided.6 Consistency: The Project proposes to develop the 18.99-acre (or 827,601 square-foot) Project site with 1,655,202 square feet of building space, proposing an overall FAR of 2.0 across the site. To achieve this intensity of development, the Project proposes to rely on the General Plan’s Community Benefits Program and enter into a Development Agreement/Community Benefits Agreement with the City (see further discussion under Zoning Consistency).

East of 101 Subarea Policies
Life science companies may intensify development north of East Grand Avenue and closer to key transportation corridors, in exchange for community benefits and district improvements. By allowing the life sciences area to grow through intensification rather than expanding its geographic area, the General Plan enables transportation, trade, and industrial uses to retain land area and continue to thrive in East of 101.7 Consistency: The Project’s proposed new lab/office space is intended to accommodate prospective new life science and technology tenants at an FAR of 2.0 FAR, which intensifies development at the site and does not expand its footprint into areas in East of 101 retained for transportation, trade and industrial uses. The Project is fully consistent with the intent of this General Plan direction.

Policy SA-16.3: Create new parks and open spaces in East of 101. Introduce a new, connected park and open space system that includes . . . a recreational greenway between Forbes Blvd and Oyster Point Blvd that extends into the Genentech Master Plan Area and connects to the San Francisco Bay Trail.

Consistency: The Project site is immediately adjacent to (north of) the Rail-to-Trails pedestrian/bike corridor that connects Forbes Boulevard and the Genentech Campus. The Project applicant has been instrumental in converting this former rail spur to the Rails-to-Trails network as a 6-foot paved pedestrian and bicycle path and intends to provide on-site connections from the Project site to this trail as part of its development plan. The Project is fully consistent with Policy SA-16.3 of the General Plan.

Policy SA-18.2: Improve sidewalk and related pedestrian amenities. Require and finance sidewalk improvements to provide shade, street furniture, and other amenities for pedestrians to create an attractive public realm along corridors.

Policy SA-18.3: Improve pedestrian and bicycle infrastructure to the San Francisco Bay Ferry Terminal. Improve pedestrian and bicycle infrastructure to provide convenient last mile connections to the San Francisco Bay Ferry Terminal.

Policy SA-18.4: Maintain roadway connections. Maintain roadways within East of 101 and foster connectivity between East of 101 and the rest of South San Francisco.8 Consistency: The Project will provide new public right-of-way improvements along its full frontage on Forbes Boulevard, including adding sidewalks where none exist, and establishing a Class II buffered bicycle lane, similar to that on the west side of Allerton Avenue. This added bike path extends the reach of the existing bikeway on Allerton to the Ferry Terminal farther west. The Project will establish a landscaped edge along Forbes Boulevard with native trees and plants for shading, new lighting 6 City of SSF, Shape SSF 2040, 2022, Table 2 (page 65)
7 City of SSF, Shape SSF 2040, 2022, page 95
8 City of SSF, Shape SSF 2040, 2022, page
Vantage Master Plan Project – CEQA Analysis page 37
standards and campus flagpoles, and building monument signage. The Project also includes a perimeter roadway that intersects with Forbes Boulevard at the northwest and northeast portion of the Project site and intersects with Allerton Avenue at the southeast portion of the Project site. The perimeter roadway maintains connectivity along this portion of the East of 101 subarea. The Project is fully consistent with Policy SA-18.2, 18.3 and 18.4 of the General Plan.

Policy SA-18.5: Encourage parcel assembly and master planning in areas designated Business Technology Park High [along Beacon Street].
9 Consistency: Although the Project is not located along Beacon Street, it does provide for parcel assembly and is a master planned development, consistent with Policy SA-18.5 of the General Plan.

Consistency with Title 20 (Zoning) of the South San Francisco Municipal Code The Shape SSF 2040 General Plan’s Business Technology Park – High land use classification has a corresponding zoning designation of Business Technology Park – High (BTP-H), as defined in SSFMC Title 20 (Zoning Ordinance).

The Zoning Ordinance was updated consistent with the 2040 General Plan update because the land uses, rules and regulations included in the Zoning Ordinance Update are intended to be compatible with the goals, policies and land use designations established in Shape SSF 2040.

Permitted Uses
According to SSFMC Table 20.100.002: Use Regulations for Non-Residential Zoning Districts, the BTP-H zoning district permits a variety of business and business-serving uses including, but not limited to coffee shop/café, business and professional offices, clean technology, and Research and Development (general).

Consistency: The Project’s proposed land use mix is primarily intended to accommodate future tenants in the life sciences industry, generally considered as R&D, office and technology uses. The Project’s Amenity building is proposed to house employee support uses such as a coffee shop or restaurant, personal services, or a small market. Each of these use types is listed as being permitted within (i.e., consistent with) the BTP-H zoning district.

Maximum Floor Area Ratio (FAR)
According to SSFMC Table 20.100.002, the maximum FAR for clean technology, office, and R&D uses is 0.5, but up to 2.0 with the provision of additional community benefits. Chapter 20.395 of SSFMC establishes the city’s Community Benefits Program by which additional FAR can be achieved. This section establishes a community benefit fee program, and fees provided into this program are to be used to fund one or more of the benefits that are consistent with the City’s priorities. If an applicant proposes a physical community benefit as a part of a Development Agreement for a project, the benefit must also be consistent with the City’s priorities as established in this Section. These priorities include:
• Public spaces beyond the requirements of the base zoning district and applicable design standards, which may include active or passive parks, plazas, community gardens, rooftop gardens, or other publicly accessible open spaces, and other amenities that support the project’s intended uses • Provision of enhanced connectivity beyond the requirements of the base zoning district standards and applicable design standards, including new through streets, bicycle/pedestrian paths, or other connections to existing trails, and signage and appropriate public access to all new connections 9 City of SSF, Shape SSF 2040, 2022, page
Vantage Master Plan Project – CEQA Analysis page 38
• A property owner or applicant who completes and develops an existing rail spur that is or will be abandoned as a publicly accessible open space connection consistent with the General Plan’s Mobility Element or applicable Specific Plan
• On-site provision of non-profit social services and/or public facilities that may include a senior center, childcare facility, public safety facilities, community meeting rooms, after-school center, or other nonprofit organizations • Support for local businesses, including tenant space for local small businesses in need of relocation, building frontage devoted to active walk-in uses such as retail, restaurant or café, participation in a local hire program, and façade improvements or enhancements
• Development of on-site or off-site affordable housing for very low, low, and moderate-income units developed by the applicant or otherwise caused to be constructed, such as through a partnership with a reputable affordable housing developer or non-profit organization. • District Transportation Demand Management (TDM) measures beyond those required and beyond applicable requirements of a Transportation Management Association (TMA) • District-wide sea level rise mitigation measures providing greater benefits for the broader community than would otherwise be required under the zoning district standards.

Consistency: To achieve the Project’s proposed FAR bonus of up to an FAR of 2.0, the Project proposes the following community benefits that are fully integrated into the Project plans:
• Public Benefit /Fire Station Site: The Project proposes to support the City’s efforts to establish a new fire station that can better serve the East of 101 area be making an approximately one-acre site within the Master Plan boundaries at the westerly portion of the site available to the City for dedication of an approximately 9,500 square-foot fire station, and proposes to complete site grading so that the City will be able to construct the fire station and associated improvements after the City accepts dedication.
• Support for Local Business: The Project’s previously approved Amenity building will accommodate tenant space for a local food service vendor, with portions of the building frontage devoted to active walk-in uses such as restaurant or café.
• Open Space: The landscape concept for the Project includes approximately 26% of the Project site, substantially exceeding the 15% minimum landscape requirement for new development within the BTP-H zone.

The acceptance of these proposed community benefits will be subject to approval by the City of a Development Agreement/Community Benefits Agreement, with details of how and when these community benefits will be provided. If accepted by the City pursuant to the provisions of Chapter

20.395 of SSFMC, the FAR bonus up to 2.0 would be consistent with the City zoning ordinance in fulfillment of the Community Benefits Program.

Development Standards
SSFMC Table 20.100.003: Development Standards for Non-Residential Zoning Districts establishes the following development standards for all non-residential zoning districts (except the GMP zoning district). The following development standards apply to the BTP-H zoning district:

Vantage Master Plan Project – CEQA Analysis page 39
Lot Size
The minimum lot area for all parcels created in the BTP-H district in the East of 101 area is 1 acre, with a minimum lot width of 50 feet.

Maximum Height
Building heights in the East of 101 area and within the BTP-H zoning district are required to comply with SSFMC Chapter 20.300.003: Airport Land Use Compatibility Plan Consistency for height allowances and for airspace protection requirements, based on the San Francisco International Airport Land Use Compatibility Plan (ALUCP).

Building heights in East of 101 and within the BTP-H zoning district are allowed the maximum height limits permissible under FAA regulations and the SFO ALUCP Critical Aeronautical Surfaces requirements. For avoidance of doubt, the lower of the two heights identified by the ALUCP and the FAA shall be the controlling maximum height.

According to the San Francisco International Airport ALUCP, the Critical Aeronautical Surface at the Project site varies between 500 and 550 feet above mean sea level. The FAA regulations (per 14 CFR Part 77) establish a requirement for notice of proposed construction or alteration for any proposed construction of buildings with a height more than 200 feet above ground level, or exceeding an imaginary surface established as a slope of 100:1 from the nearest SFO runway (or between 65 and 100 feet above sea level at the Project site).

Consistency: The ground surface at the Project site varies between approximately 40 to 46 feet above mean sea level. The tallest proposed building pursuant to the Project is the 237-foot tall, 12-story Building C, which reaches a height of approximately 282 feet above mean sea level. This tallest building does not exceed the Project site’s Critical Aeronautical Surface of approximately 500 feet above mean sea level, and neither do any of the Project’s other buildings or parking structures.

However, Buildings C, E and F (at 237 feet, 203 feet and 203 feet above ground level, respectively) all exceed the FAA Part 77 Notice of Proposed Construction height of 200 feet above ground level, and all new buildings pursuant to the Project (except the 40-foot tall Amenity building) exceed the FAA Part 77 imaginary surface established as a slope of 100:1. Accordingly, the Project sponsor shall file a Notice of Proposed Construction or Alteration with the FAA to obtain a “no hazard” determination for these structures (see additional details in the Land Use section of this CEQA Checklist). The Notice of Proposed Construction requirement and the “no hazard” determination is a common process for taller buildings with the East of 101 Area. With a “no hazard” determination by the FAA, the Project’s building heights would be fully consistent with City zoning requirements for building heights.

Setbacks
The applicable minimum setbacks within the BTP-H zone (where not adjacent to a Residential zone) are 20 feet for front setbacks, 0 feet for side yard setbacks, 10 feet for minimum street side setbacks, and 0 feet for minimum rear yard setbacks.

Consistency: The Project proposes to subdivide the existing six parcels that comprise the Project site into ten separate parcels, with separate parcels corresponding to the R&D/office buildings, parking structures, the Amenity building and the Public Benefit/Fire Station site. Each of these new parcels would provide front yard and street side yard setback that would substantially exceed SSFMC setback Vantage Master Plan Project – CEQA Analysis page 40
requirements (the Project site is not adjacent to a Residential zone). The new buildings fronting onto Forbes Boulevard (Buildings D, E and F) are set back by approximately 30 feet so that Forbes can be used for fire aerial access. The nearest new building fronting onto Allerton Avenue (Building C) is set back by approximately 60 feet.

Landscaping and Open Space
SSFMC Table 20.100.003: Development Standards for Non-Residential Zoning Districts establishes a minimum requirement for 15% of the site to be landscaping or open space. More specifically, Section 20.100.004(J): Public Open Space requires a minimum of five percent of the lot to be set aside for open space that is publicly visible and accessible, and located on the primary street frontage of the lot. Additionally, Section 20.100.004(K):

Business, Technology and Office Park Design requires open space areas equal to 10% of the site that provide gathering space or opportunities for active or passive recreation, with amenities that enhance the comfort, aesthetics, or usability of the space.

Consistency: The landscape concept for the Project includes three key landscape features, including a central east/west promenade pedestrian spine, separate paseos that provide shared entries into the Campus on the north/south axis, and streetscape landscaping along Forbes Boulevard and Allerton Avenue. Together, these landscape features account for approximately 215,000 square feet of landscaped area, or approximately 26% of the Project site. This proposed landscape area meets and exceeds the 15% minimum landscape requirement for new development within the BTP-H zone.

Site and Building Design Standards
All new buildings within the BTP-H district are also subject to the supplemental standards of Chapter 20.100.004 for site and building design; primary building entrance orientation; architectural articulation; employee eating areas; landscaped setback of parking areas; special Business, Technology and Office-Park design; and truck docks, loading and service areas.

Consistency: The Vantage Master Plan provides conceptual illustrations and information that demonstrates general consistency with each of these supplemental standards, but final building designs for each new building will be subject to individual Design Review pursuant to the city’s standards and procedures. This later Design Review process for each new building will enable the city to verify that these standards have been met.

Parking
Pursuant to SSFMC Section 20.330.004: Required Parking Spaces, the required on-site parking spaces for R&D land uses are established as 1.5 parking spaces per 1,000 square feet of R&D floor area. SSFMC Section

20.330.004 also provides that the Planning Commission may allow parking in excess of the spaces required pursuant to Table 20.330.004, subject to a Conditional Use Permit and based on a finding that the amount of parking provided is supportive of the recommendations and requirements of a Transportation Demand Management (TDM) plan prepared for the project. Where a Conditional Use Permit is required for the use, the ultimate parking requirement will be established by the Planning Commission during the Conditional Use Permit application process.

Consistency:

The Project’s proposed parking program exceeds the on-site parking ratios established pursuant to SSFMC Table 20.330.004. Accordingly, the Project applicant seeks Planning Commission approval of a Conditional Use Permit for parking that is more than the spaces required by the Zoning Ordinance. In support of this requested CUP, this CEQA Checklist’s Project Description includes a parking demand estimate that calculates parking demand based on projected Project employment. The parking demand Vantage Master Plan Project – CEQA Analysis page 41
estimate is inclusive of and supports the recommendations and requirements of the Project’s TDM plan, which provides for a 50 percent reduction in single-occupant vehicle use in accordance with the City’s Tier 4 TDM Plan requirements.

SSFMC provides an avenue for achieving an increase in parking above the maximum imposed parking (i.e., with a CUP), and it gives the Planning Commission the authority to increase the parking ratio for a project based on findings in support of the higher ratio. Given that the Project’s parking program is supportive of the recommendations contained in the Project’s TDM plan (i.e., it anticipates and incorporates a 50 percent reduction in drive alone vehicles), the Project’s proposed parking ratio is consistent with the parking provisions of the SSFMC.

Conclusions
The Project’s proposed development is consistent with the Shape SSF 2040 (the General Plan Update) land use designation for the site. The Project’s proposed development intensity and associated community benefits are consistent with the General Plan’s permissible FAR. The Project does not present any inconsistencies with other Shape SSF 2040 General Plan Elements. Similarly, the Project is consistent with applicable Business Technology Park-High (BTP-H) zoning regulations that apply to the site. As such, the Project qualifies as a Project that is consistent with a Community Plan, General Plan and/or zoning, pursuant to CEQA Guidelines Section 15183.

Vantage Master Plan Project – CEQA Analysis page 42
Initial Study / CEQA Checklist
The following Initial Study/CEQA Checklist provides an assessment of the potential environmental impacts that may result from approval and implementation of the Project. Consistent with CEQA Guidelines Section 15063, this Initial Study identifies potential environmental effects of the Project using a checklist method, with adequate explanation and evidence to support the Checklist entries and conclusions. These explanations include narrative analysis of the Project. The Checklist uses the following acronyms for CEQA conclusions:
• No Impact - for environmental factors that would not be affected in any manner • LTS - for less than significant impacts
• LTS w/PR - for impacts that would be reduced to LTS with implementation of identified Project Requirements (including regulations, standard conditions and/or policy requirements), including measures identified in an applicable prior program EIR (i.e., the SSF 2040 General Plan EIR), and • SU - for significant and unavoidable impacts
CEQA Section 15183 Checklist
Section 15183(a) of the CEQA Guidelines states that, “projects that are consistent with the development density established by the existing zoning, community plan or general plan policies for which an Environmental Impact Report (EIR) was certified shall not require additional environmental review, except as may be necessary to examine whether there are project-specific significant effects that are peculiar to the project or its site”.

The analysis in the following Initial Study/CEQA Checklist provides an assessment of whether the Project qualifies for streamlined review under CEQA Guidelines Section 15183. It evaluates the potential environmental impacts of the Project in relation to the impacts identified in the SSF 2040 General Plan Update EIR. The analysis determines whether the potential impacts of the Project were fully evaluated and disclosed in the prior SSF General Plan EIR, and whether uniformly applied development policies or standards as identified in the SSF 2040 General Plan EIR would apply to the Project. It also determines whether the Project would have significant effects on the environment that may be peculiar to the Project or the site. This Initial Study/CEQA Checklist incorporates by reference the discussion and analysis of all potential environmental impact topics as presented in the SSF 2040 General Plan EIR, and reference to this prior EIR includes citations to the page or pages where this information is found. This CEQA Checklist provides an analysis in support of a determination of whether the Project would result in:
• an equal or less severe impact than previously identified in the SSF 2040 General Plan EIR, or • a new impact, or a substantial increase in the severity of a significant impact as disclosed in the prior SSF 2040 General Plan EIR
If the severity of a potential impact of the Project would be the same as or less than the severity of the impact as described in the SSF 2040 General Plan EIR, the checkbox for “Equal or Less Severe” is checked. If the checkbox is marked as “New or Substantial Increase in Severity”, that would indicate that the Project’s impacts are either:
• peculiar to the Project or the Project site, pursuant to CEQA Guidelines §15183(b) (1) • not identified in the SSF 2040 General Plan EIR (the prior Program EIR), per CEQA Guidelines §15183(b) (2), including off-site and cumulative impacts, per CEQA Guidelines §15183(b) (3), or • due to substantial new information that was not known at the time the SSF 2040 General Plan EIR was certified, per CEQA Guidelines §15183(b)(4)
Vantage Master Plan Project – CEQA Analysis page 43
In such a circumstance, an MND or a new EIR would be required for the Project, focused on those topics that might be indicated as new or substantially more severe effects. Current CEQA Checklist topics that may not have been addressed in the prior SSF 2040 General Plan EIR remain applicable to the Project.

Whereas the prior section of this document provides substantial evidence that the Project is consistent with the development assumptions of Shape SSF 2040 and zoning, the Project is therefore eligible for consideration of CEQA streamlining pursuant to California Public Resources Code Section 21083.3 and CEQA Guidelines Section 15183. The City of South San Francisco prepared a program-level EIR for the Shape SSF 2040 General Plan (the SSF 2040 General Plan EIR) that is applicable to the Project and its site, and that Program EIR provides programmatic environmental review of new development that is consistent with the Shape SSF 2040 General Plan, such as the Project.

Reliance on a Prior Program EIR
Pursuant to CEQA Guidelines Section 15168, “a Program EIR is an EIR that has been prepared on a series of actions that can be characterized as one large project and that are related either geographically, as logical parts in a chain of contemplated actions, in connection with general criteria to govern the conduct of a continuing program, or as individual activities carried out under the same authorizing statute or regulatory authority and having generally similar environmental effects which can be mitigated in similar ways”. CEQA Guidelines Section 15168(c) provides that, “later activities in the program must be examined in the light of the Program EIR to determine whether an additional environmental document must be prepared (unless that project is determined to be eligible for a categorical exemption):
• If a later activity would have effects that were not examined in the program EIR, a new initial study would need to be prepared leading to either an EIR or a negative declaration. That later analysis may tier from the program EIR as provided in Section 15152.
• If the agency finds, pursuant to Section 15162, that no subsequent EIR would be required, the agency can approve the activity as being within the scope of the project covered by the Program EIR, and no new environmental document would be required. Whether a later activity is within the scope of a Program EIR is a factual question that the lead agency determines based on substantial evidence in the record. Factors that an agency may consider in making that determination include but are not limited to consistency of the later activity with the type of allowable land use, overall planned density and building intensity, geographic area analyzed for environmental impacts, and covered infrastructure, as described in the program EIR.
• The Lead Agency shall incorporate feasible mitigation measures and alternatives developed in the Program EIR into later activities in the program.
• Where the later activities involve site-specific operations, the Lead Agency should use a written checklist or similar device to document the evaluation of the site and the activity, to determine whether the environmental effects of the operation are within the scope of the program EIR.

A finding of reliance on a prior program EIR may be made concurrently, and in addition to a finding of categorical exemption.

SSF 2040 General Plan EIR
Prior to adopting the Shape SSF 2040 General Plan Update, the City of South San Francisco certified the SSF 2040 General Plan Update EIR. The SSF 2040 General Plan EIR is the prior Program EIR examined in this CEQA analysis to determine whether this prior Program EIR is applicable to the Project, and whether it supports streamlining and/or tiering provisions under CEQA Section 15183. The CEQA analysis for the Project, as provided in the following Checklist, evaluates the specific environmental effects of the Project in light of the analysis and Vantage Master Plan Project – CEQA Analysis page 44
conclusions addressed in that prior Program EIR. The Final SSF 2040 General Plan EIR is hereby incorporated by reference and can be obtained on the City’s Shape SSF website at: http://shapessf.com/wpcontent/uploads/2022/09/SSF-GPU-Final-EIR_Combined.pdf .

CEQA Streamlining
The SSF 2040 General Plan Update EIR is intended to evaluate the environmental impacts of the adoption and implementation of the General Plan. The document is intended to serve as a source of information in the review of subsequent planning and development proposals, including subsequent environmental review of development projects, for infrastructure provision and individual development proposals, and for public facilities to serve new development. According to the SSF 2040 General Plan Update EIR, “The City intends and anticipates that the certified Final Program EIR would be utilized in conjunction with existing streamlining provisions provided by CEQA, emerging streamlining techniques such as those related to implementation of the Sustainable Communities Strategy (PRC § 21155), and other streamlining procedures, including those that may become available in the future. To promote the effective use of City resources, the analysis in this certified Draft Program EIR may be considered the first tier of environmental review and it is the intent of the City that future, project-specific and/or sitespecific CEQA documents may utilize this analysis as appropriate.” Tiering refers to a multi-level approach to preparing environmental documents that is codified in Public Resources Code Section 21083.3 and State CEQA Guidelines Section 15152.

Significant Unavoidable Impacts
The SSF 2040 General Plan EIR and its Initial Study determined that development consistent with Shape SSF 2040 would, for the most part, result in impacts that would be less than significant, or would result in impacts that would be reduced to a level of less than significant with implementation of existing regulatory requirements and implementation of policies contained within the Shape SSF 2040 General Plan. However, the SSF 2040 General Plan EIR determined that development consistent with Shape SSF 2040 would result in certain significant impacts that could not be avoided:
• Project-Level Vehicle Miles Traveled: The General Plan’s Vehicle Miles Traveled (VMT) would result in a significant impact for citywide Total VMT per Service Population and for Work-Based VMT per Employee. The General Plan would implement Mitigation Measure (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 and the impact would remain significant and unavoidable. • Project-Level Roadway Safety: Implementation of the General Plan would increase vehicle trips on the City’s freeway ramps, which would cause vehicle queues to exceed off-ramp storage capacity or exacerbate off-ramps that already experience off-ramp queues exceeding storage capacity, resulting in a potentially significant impact. The General Plan would implement MM TRANS-4, which would require the City to work with the California Department of Transportation (Caltrans) to develop improvement measures for freeway off-ramps and adjacent intersections that help manage off-ramp queues to minimize queueing hazards. MM TRANS-1 is also applicable and would be implemented to minimize freeway off-ramp queues. However, even with the implementation of General Plan Update policies and Vantage Master Plan Project – CEQA Analysis page 45
actions and implementation of MM TRANS-4 and MM 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.
• Cumulative VMT: Cumulative projects in the nine-county Bay Area may generate new VMT, which would be added to the roadway network within the geographic context. All cumulative projects would be required to comply with County and local ordinances and General Plan policies that address VMT, as well as mitigate their fair share of impacts related to VMT. Nonetheless, the proposed project, in conjunction with other past, present, and future projects, would have a cumulatively significant impact related to VMT. The General Plan would implement MM TRANS-1, which would require the City to implement its 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 incorporation of MM TRANS-1 which would partially reduce VMT impacts, the impacts would remain significant and unavoidable. As the proposed project’s impacts related to VMT are significant and unavoidable, the proposed project’s incremental contribution to the cumulative impact is significant and the proposed project’s contribution to cumulative VMT impacts would be cumulatively considerable. • Cumulative Roadway Safety: Cumulative projects in the nine-county Bay Area may generate new VMT, which would be added to the roadway network, potentially increasing vehicle trips on the City’s freeway ramps, which would cause vehicle queues to exceed off-ramp storage capacity or exacerbate off-ramps that already experience off-ramp queues exceeding storage capacity. All cumulative projects would be required to mitigate their impacts, as well as ensure that roadway safety is maintained, and comply with applicable policies in local and regional planning documents. Nonetheless, a cumulatively significant impact related to roadway safety would remain. The proposed project would implement MM TRANS-4, which would require the City to work with Caltrans to develop improvement measures for freeway offramps and adjacent intersections that help manage off-ramp queues. Implementation of MM TRANS-1 would also assist in minimizing freeway off-ramp queues. However, even with incorporation of MM TRANS-4 and MM TRANS-1, the impacts would remain significant and unavoidable. As the proposed project’s impacts to the City’s freeway ramps are significant and unavoidable, the proposed project’s incremental contribution to the cumulative impact is considered significant and the proposed project’s contribution to roadway safety cumulative impacts would be cumulatively considerable. • Project-Level Conflict with 2017 Bay Area Clean Air Plan: The VMT growth facilitated by the General Plan would constitute an approximately 94 percent growth through 2040 while population growth facilitated by the General Plan would constitute an approximately 61 percent growth through 2040. The forecasted VMT growth would outpace the forecasted population growth facilitated by the General Plan. Therefore, the General Plan would be considered inconsistent with the 2017 Clean Air Plan. The General Plan would implement MM TRANS-1, which would achieve the maximum feasible reductions in vehicle travel.

However, as there is no reasonable mitigation that could be implemented to increase population Vantage Master Plan Project – CEQA Analysis page 46
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, this impact would remain significant and unavoidable after mitigation.
• Cumulative Conflict with 2017 Bay Area Clean Air Plan: Development envisioned by the General Plan would be inconsistent with the 2017 Bay Area Clean Air Plan since it would facilitate VMT growth which outpaces the forecasted population growth. As the General Plan would facilitate VMT growth which outpaces projected population growth through the planning horizon of 2040, the General Plan is 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.
• Cumulative Criteria Air Pollutants: Because the General Plan would result in a projected VMT growth which outpaces the projected population growth through the planning horizon of 2040, the General Plan would result in a cumulatively considerable net increase in criteria air pollutants and ozone precursors.

Due to these potentially significant unavoidable impacts, the City adopted a Statement of Overriding Considerations as part of the City’s approval of Shape SSF 2040 General Plan.

Cumulative Effects
CEQA Guidelines Section 15183(j) provides that projects analyzed in relationship to a prior Program EIR do not affect the CEQA requirement to analyze potentially significant off-site or cumulative impacts, if those impacts were not adequately discussed in the prior EIR. If a significant off-site or cumulative impact was adequately discussed in the prior EIR, then this section may be used as a basis for excluding further analysis of that off-site or cumulative impact. Analysis of the Project’s potential to contribute to cumulatively significant environmental effects considers whether these cumulative effects have already been addressed in the prior SSF 2040 General Plan Update EIR, but otherwise relies on the streamlining provisions of CEQA Guidelines Section 15183 to address cumulative effects.

Applicable Mitigation
The SSF 2040 General Plan EIR is a Program EIR as defined under CEQA Guidelines Section 15168 and Section 15183. As such, subsequent activities pursuant Shape SSF 2040 are subject to SSF 2040 General Plan EIR mitigation measures, General Plan policies, standard conditions for new development, and identified regulatory requirements. The Project is required to comply with applicable policies, regulatory requirements and/or other mitigation as identified in the SSF 2040 General Plan EIR, as applicable. The Project sponsor must agree to incorporate and/or implement these policies, regulatory requirements and/or other mitigation as part of the Project.
• A dash (–) is used in the Checklist to indicate that the SSF 2040 General Plan EIR did not identify any requirements or mitigation measures for the respective environmental impact, and so none would apply to the Project.
• The abbreviation N/A is used when a policy, regulatory requirement or mitigation was identified in the SSF 2040 General Plan EIR, but it does not apply to the Project.

In some instances, the Project applicant has submitted analysis or plans as required pursuant to mitigation, policies and/or standard conditions of approval as identified in the SSF 2040 General Plan EIR. In these instances, the Checklist describes the results or conclusions of these Project-specific analyses or plans in the narrative under the heading “Project Plans in Furtherance of Required Mitigation”. This heading also identifies any Project-specific measures that are recommended to provide further clarification for the underlying mitigation, and which have been accepted by the Project applicant and incorporated into the Project design to avoid any Vantage Master Plan Project – CEQA Analysis page 47
greater impacts. Consequently, the Project would not result in new significant impacts or substantially greater impacts than the impacts identified in the SSF 2040 General Plan EIR.

Vantage Master Plan Project – CEQA Analysis page 48
Aesthetics
Would the Project:

SSF 2040
General
Plan EIR
Findings
Relationship to SSF 2040 General
Plan EIR Findings: Project Conclusions:

Equal or
Less Severe
New or Substantial
Increase in Severity
Applicable
Standards and
Requirements
Resulting
Level of
Significance
a) Have a substantial adverse effect on a
scenic vista LTS  ☐ - Less than
Significant
b) Substantially damage scenic resources,
including but not limited to trees, rock
outcroppings, and historic buildings within a
state scenic highway
No Impact  ☐ - No Impact
c) As the Project is located in an urbanized
area, would the project conflict with
applicable zoning and other regulations
governing scenic quality
LTS  ☐ Regulatory
Requirement
Aesthetics-1, Design
Review
LTS with PR
d) Create a new source of substantial light
or glare which would adversely affect day
or nighttime views in the area
LTS  ☐ Regulatory
Requirement
Aesthetics-2, Design
Review for Light and
Glare
LTS with PR
a) Scenic Vistas
SSF General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact AES-1) determined that future development and land use activities that occur within South San Francisco in a manner consistent with the Shape SSF 2040 General Plan would not have significant adverse effects on a scenic vista.
10 Development under the General Plan would result in additional non-residential development which could alter existing scenic vistas and views, but because South San Francisco is a fully built city, new development would primarily occur on parcels that already contain some existing businesses. Mandatory compliance with design review regulations and policies in the South San Francisco Municipal Code and Zoning Ordinance and General Plan would ensure that potential impacts related to scenic vistas and views from new development would be less than significant. Specifically, GP Policy LU-9.2 requires the City to encourage distinctive architecture and other elements that add visual interest to buildings to enhance people’s perceptions of South San Francisco as an interesting and inviting place.

The South San Francisco Zoning Ordinance contains architectural guidelines, design review criteria, lot and development standards, landscaping requirements, and other regulations for various land uses in order to promote aesthetic quality within the City and to protect scenic vistas and views. In particular, SSFMC Chapter

20.480 (Design Review) establishes the procedure for design review to ensure that development is designed to 10 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact AES-1, page 3.1-12 Vantage Master Plan Project – CEQA Analysis page 49
support General Plan policies. Consistent with the General Plan, individual development projects would be required to undergo project-specific environmental review, which may require additional site-specific or projectspecific measures to reduce any potential impacts and would ensure that impacts to scenic views and vistas remain less than significant.

Project Analysis
The Project site is not located within any scenic vista or scenic resources as designated by the City of South San Francisco. As such, the Project would not obstruct a designated public vista, nor would it result in the placement of an arguably offensive or negative-appearing object within a designated public vista. Much of the Project site was previously developed for warehousing uses, which will be replaced with new, modern higher-rise office and parking structures. The Project’s proposed development would be substantially taller than the prior uses on the site, but fully consistent with the development intensity as envisioned for the Business and Technology Park – High land use designation, and generally consistent with building heights of other new development in the surrounding East of 101 area north of East Grand Avenue.

Conclusion: Consistent with the findings of the SSF 2040 General Plan EIR, development and use of the Project site would not have significant adverse effects on a designated scenic vista or a designated scenic resource. The Project’s impact on designated scenic resources and scenic vistas (Checklist item Aesthetics-a) would be less than significant, and no mitigation is required.
b) Scenic Resources within a State Scenic Highway
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact AES-2) concluded that future development and land use activities that occur within South San Francisco in a manner consistent with the Shape SSF 2040 General Plan would not substantially damage scenic resources, including but not limited to trees, rock outcroppings, and historic buildings within a State Scenic Highway.11
The SSF 2040 General Plan EIR found that there are no officially designated State Scenic Highways that traverse through South San Francisco. I-280, from its intersection with Mission Bay Drive in the City of San Francisco to the South San Francisco and San Bruno border, is eligible for designation as a State Scenic Highway, and the portion of SR-35 (the Junipero Serra Freeway) that borders the western side of South San Francisco is similarly eligible for designation as a State Scenic Highway. Distant views of San Francisco Bay, San Bruno Mountain and the Coast Range are intermittently visible from I-280 and SR-35, but most of these views are shielded by topography and trees. Accordingly, impacts related to scenic resources within a State Scenic Highway were found to be less than significant.

Project Analysis
The Project site is not uniquely visible from I-280 or SR-35, and its development would be generally consistent with the surrounding business and technology uses in the area. As such, the Project would not damage scenic resources within a designated state scenic highway.

Conclusion: Consistent with the findings of the SSF 2040 General Plan EIR, the Project would not have an adverse effect on scenic resources within a designated state scenic highway (Checklist item Aesthetics-b). 11 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact AES-2, page 3.1-14 Vantage Master Plan Project – CEQA Analysis page 50
c) Visual Character / Conflicts with Regulations Governing Scenic Quality SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact AES-3) found that future development and land use activities that occur within South San Francisco in a manner consistent with the Shape SSF 2040 General Plan would generally be located within urbanized areas and would not conflict with applicable zoning and other regulations governing scenic quality.12
As the City receives development applications for subsequent development, those applications will be reviewed by the City pursuant to its Design Review criteria for compliance with the policies and actions of Shape SSF 2040 related to scenic quality in urbanized areas, including scenic views and scenic resources. Compliance with Shape SSF 2040 General Plan policies and actions, and adherence to development and design standards in the South San Francisco Municipal Code and Zoning Ordinance related to quality design, would ensure that impacts to visual character remain less than significant.

Project Analysis
The Project site is centrally located within the Business Technology Park - High land use designation of Shape SSF 2040. This land use designation specifically seeks to retain and expand the life science land uses that will ensure the City remains a world-class life sciences destination. The Project’s expansion of office/R&D space for biotechnology and life sciences businesses will result in redevelopment of existing industrial warehouse buildings, changing the visual character of the site and intensifying development along Forbes Boulevard north of East Grand Avenue (see Figure 15). This change in visual character is specifically intended and anticipated pursuant to the Shape SSF 2040 General Plan, which allows this area to grow through intensification rather than expanding its geographic area, such that transportation, trade and industrial uses can remain on other lands within East of 101.

As demonstrated in the General Plan and Zoning consistency analysis presented in this CEQA Checklist, the Project is consistent with the architectural guidelines, design review criteria, lot and development standards, landscaping requirements, and other regulations intended to promote aesthetic quality within the City. 12 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact AES-3, page 3.1-16 Vantage Master Plan Project – CEQA Analysis page 51
Fig 15
Vantage Master Plan Project – CEQA Analysis page 52
Regulatory Requirement
The SSF 2040 General Plan EIR cited compliance with development and design standards of the South San Francisco Municipal Code and Zoning Ordinance related to new building design that would ensure that impacts to visual character remain less than significant. Pursuant to this General Plan EIR citation for all proposed projects, the following design review criteria are required of each new building and parking structure pursuant to the Project:

Regulatory Requirement Aesthetics-1, Design Review: Pursuant to the City of South San Francisco’s Zoning Code (Chapter 20.480: Design Review) the City will continue to review the design of new buildings on Campus. The City’s Design review criteria will be used to ensure that new buildings promote high-quality design, are well crafted and maintained, use high-quality building materials and are attentive to the design and execution of building details and amenities. The Project must satisfy the following applicable criteria:

1. The site subject to design review shall be graded and developed with due regard for the natural terrain, aesthetic quality and landscaping so as not to impair the environmental quality, value, or stability of the site or the environmental quality or value of improved or unimproved property in the area.

2. A building, structure, or sign shall reasonably relate to its site and property in the immediate and adjacent areas; not be of such poor quality of design as to adversely affect the environmental quality or desirability of the immediate areas or neighboring areas; and not unreasonably interfere with the occupancy, environmental quality, or the stability and value of improved or unimproved real property or have an unreasonable detrimental effect on the health, safety, and general welfare of the community.

3. A site shall be developed to achieve a harmonious relationship with the area in which it is located and adjacent areas, allowing a reasonable similarity of style or originality, which does not impair the environmental quality or value of improved or unimproved property or prevent appropriate development and use of such areas or produce degeneration of properties in such areas with attendant deterioration of conditions affecting the health, safety, and general welfare of the City.

5. Parking areas shall be designed and developed to buffer surrounding land uses; compliment pedestrian-oriented development; enhance the environmental quality of the site, including minimizing stormwater run-off and the heat-island effect; and achieve a safe, efficient, and harmonious development.

5. Open space, pedestrian walks, signs, illumination, and landscaping (including irrigation) shall be designed and developed to enhance the environmental quality of the site, achieve a safe, efficient, and harmonious development, and accomplish the objectives set forth in the precise plan of design and design criteria.

6. Electrical and mechanical equipment, works and fixtures and trash storage areas shall be designed and constructed so as not to detract from the environmental quality of the site. Electrical and mechanical equipment, works and fixtures, and trash storage areas shall be concealed by an appropriate architectural structure which uses colors and materials harmonious with the principal structure, unless a reasonable alternative is identified.

7. Components considered in design review shall include but not be limited to exterior design, materials, textures, colors, means of illumination, landscaping, irrigation, height, shadow patterns, parking, access, security, safety, and other usual on-site development elements.

Conclusion: Consistent with the findings of the SSF 2040 General Plan EIR, the Project’s individual buildings, parking structures, landscape and lighting will be subject to the City’s Design Review process and criteria. These processes and criteria include measures to ensure that the Project’s impacts to visual character (Checklist item Aesthetics c) remain less than significant, and no additional mitigation is required.

Vantage Master Plan Project – CEQA Analysis page 53
d) Light and Glare
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact AES-4) found that future development and land use activities that occur within South San Francisco in a manner consistent with the Shape SSF 2040 General Plan would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.13 Because South San Francisco is a fully built city, most new development under the SSSF 2040 General Plan would primarily occur on parcels that already contain some existing homes or businesses that currently generate light and glare. Nonetheless, subsequent development under the General Plan would create new sources of light and glare, contributing to increased ambient nighttime lighting conditions. Specific sources of lighting would include exterior light fixtures, signage on businesses, interior lighting, and headlights from motor vehicles. Specific sources of glare would include reflective building and motor vehicle surfaces, including windows.

The South San Francisco Zoning Ordinance contains architectural guidelines, design review criteria, lot and development standards, landscaping requirements, and other regulations for various land uses in order to reduce light and glare impacts within the City. Section 20.300.009 (Lighting and Illumination) establishes regulations that allow outdoor lighting for uses and activities consistent with the need for utility, safety and nighttime attractiveness, while minimizing light and glare impacts. Section 20.300.009(C) establishes general standards for outdoor lighting, including maximum heights for lighting fixtures, locations and shielding for lighting fixtures, and submittal of photometric data from lighting manufacturers to the City by the project applicant to demonstrate that the lighting requirements have been satisfied. Section 20.300.009(D) prohibits the use of certain types of outdoor lighting, including lighting that results in glare to motor vehicles on public rightof-way, outdoor floodlighting, search lights, flood lights, laser lights or similar high intensity light, and any lighting device located on the exterior of a building or on the inside of a window which is visible beyond the property boundaries of the lot or parcel, with intermittent fading, flashing, blinking, rotating or strobe light illumination. Section 20.360.004 establishes standards for signs, including display standards and sign illumination, to minimize light and glare impacts.

As the City receives development applications for subsequent development, those applications will be reviewed by the City of South San Francisco for compliance with the City’s Municipal Code and Zoning Ordinance standards for exterior lighting, as well as a review of potential glare impacts in the design review process. For projects that require a design review permit, the Design Review Board will review exterior lighting to ensure that the lighting is appropriately designed and located to minimize visual impacts to adjacent properties and the public. Potential issues related to glare would be addressed, thereby reducing daytime glare and nighttime lighting impacts. Subsequent development, infrastructure, and planning projects would be subject to the General Plan Update policies and actions, as well as the South San Francisco Municipal Code and Zoning Ordinance to reduce potential impacts related to daytime glare and nighttime lighting. As such, the impacts would remain less than significant.

Project Analysis
The Project will add new sources of light at the Project site, including new street lighting standards, security lighting at parking areas and building entries, and pedestrian-scaled accent lighting. Other than as may be needed for a fire station, and potential FAA markings for Buildings C, D, E and F, the Project will not include any outdoor floodlighting, searchlights, laser lights or similar high intensity light. No lighting device that is visible 13 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact AES-4, page 3.1-17 Vantage Master Plan Project – CEQA Analysis page 54
beyond the property boundaries will have intermittent fading, flashing, blinking, rotating or strobe light illumination, and no lighting standards will result in glare to motor vehicles on public rights-of-way.

There is nothing specific or unusual about the Project that might be a source of substantial daytime glare.

Regulatory Requirement
The SSF 2040 General Plan EIR cited compliance with design standards of the South San Francisco Municipal Code Section 20.300.009 (Lighting and Illumination) as required to ensure that impacts related to light and glare remain less than significant. Pursuant to this General Plan EIR citation for all proposed projects, the following design review criteria are required of each new building, parking structure and landscape improvements pursuant to the Project:

Regulatory Requirement Aesthetics-2, Design Review for Light and Glare: Consistent with South San Francisco Municipal Code, section 20.300.09, new development pursuant to the Project will be required to comply with the following design considerations relative to light and glare:

1. All outdoor lighting fixtures must be installed and maintained in conformance with the provisions of the SSMC and applicable Building Codes.

2. All exterior doors, during the hours of darkness, shall be illuminated with a minimum of one footcandle of light.

3. Lighting fixtures shall not exceed the maximum height of 25 feet.

4. All lighting fixtures shall be fully shielded, located and aimed so that the direct illumination from the fixture shall be confined to the property boundaries of the source. Further, any light fixture located within 50 feet of a public right-of-way must utilize an internal or external shield, with the light fixture and shield oriented to minimize light trespass onto adjacent right-of-way line. If an external shield is used, its surface must be painted black to minimize reflections.

5. All motion sensing light fixtures must conform to all applicable standards of this Division, including the shielding standards.

6. Photometric data from lighting manufacturers shall be submitted to the City by the project applicant to demonstrate that the lighting requirements have been satisfied.

Conclusion: Consistent with the findings of the SSF 2040 General Plan EIR, the Project’s individual buildings, parking structures and landscape plans will be subject to the City’s Design Review process and criteria. These processes and criteria include measures to ensure that impacts related to light and glare (Checklist item Aesthetics-d) remain less than significant, and no additional mitigation is required.

CEQA Conclusion Pertaining to Aesthetics
Based on the analysis, findings and conclusions of the prior SSF 2040 General Plan EIR, implementation of the Project would not substantially increase the severity of any significant aesthetic impacts identified in that prior Program EIR, nor would it result in new significant impacts related to aesthetics or visual resources that were not previously identified. The SSF 2040 General Plan EIR did not identify any mitigation measures related to aesthetics or visual resources that would apply to the Project and none would be needed. No further environmental analysis of the Project pertaining to the topics of aesthetics is required.

Vantage Master Plan Project – CEQA Analysis page 55
Agriculture and Forestry Resources
Would the Project:

SSF 2040
General Plan
EIR Findings
Relationship to SSF 2040 General
Plan EIR Findings: Project Conclusions:

Equal or Less
Severe
New or
Substantial
Increase in
Severity
Applicable
Standards
and
Requirements
Resulting
Level of
Significance
a) Convert Prime Farmland, Unique
Farmland, or Farmland of Statewide
Importance (Farmland), as shown on the
maps prepared pursuant to the Farmland
Mapping and Monitoring Program of the
California Resources Agency, to nonagricultural use
No Impact  ☐ - No Impact
b) Conflict with existing zoning for
agricultural use, or a Williamson Act
contract
No Impact  ☐
- No Impact
c) Conflict with existing zoning for, or
cause rezoning of, forest land (as defined
in Public Resources Code section
12220(g)), timberland (as defined by
Public Resources Code section 4526), or
timberland zoned Timberland Production
(as defined by Government Code section
51104(g))
No Impact  ☐
- No Impact
d) Result in the loss of forestland or
conversion of forestland to non-forest use
No Impact  ☐ - No Impact
e) Involve other changes in the existing
environment which, due to their location
or nature, could result in conversion of
Farmland to non-agricultural use or
conversion of forestland to non-forest use
No Impact  ☐ - No Impact
a) - e) Agriculture and Forestry Resources
SSF 2040 General Plan EIR Conclusions
The SSF2040 General Plan EIR includes an analysis of the potential effects associated with General plan buildout on agricultural resources. The General Plan EIR concluded that the GP planning area is located within an urban environment and no existing agriculture or forestry land use activities occur. No portion of the GP planning area is designated as relevant for agriculture or forestry resources by the City of South San Francisco or by the State of California. As such, construction and operation pursuant to the General Plan would not result in the conversion of Prime Farmland or Farmland of Statewide Importance to nonagricultural uses, nor would it conflict with any zoning for agricultural use or a Williamson Act Contract, or any zoning for forestland or Vantage Master Plan Project – CEQA Analysis page 56
timberland and would not result in loss or conversion of forestland to non-forest uses. Therefore, no impacts related to agriculture and forestry resources would occur.14 Project Analysis
Based on a current search of the California Department of Conservation’s Farmland Mapping and Monitoring Program, the Project site does not contain Prime Farmland, Farmland of Statewide Importance, or Unique Farmland,
15 and does not meet the state definition of “forest land”. The Project site does not contain active farmlands or grazing lands, is not encumbered by Williamson Act contracts, and is not included within any agricultural or forest resources zoning district. The Project would not convert Important Farmland to nonagricultural use and would not result in loss of an active forest resource.

Consistent with the findings of the SSF 2040 General Plan, the Project would not create pressures to convert farmland or forestland to non-agricultural use.

CEQA Conclusions Pertaining to Agriculture
Based on the analysis, findings and conclusions of the prior General Plan EIR, implementation of the Project would not substantially increase the severity of any significant agricultural or forestland impacts identified in that Program EIR, nor would it result in new significant impacts related to agriculture or forestlands that were not previously identified. The prior Program EIR did not identify any mitigation measures related to agriculture or forestlands that would apply to the Project and none would be needed. 14 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Chapter 6: Effects Found Not To Be Significant, page 6.1 15 California Department of Conservation, Farmland Mapping and Monitoring Program accessed August 2021 at:
https://maps.conservation.ca.gov/DLRP/CIFF/
Vantage Master Plan Project – CEQA Analysis page 57
Air Quality
Would the Project:

SSF 2040
General Plan
EIR Findings
Relationship to SSF 2040
General Plan EIR Findings: Project Conclusions:

Equal or
Less Severe
New or
Substantial
Increase in
Severity
Applicable
Standards and
Requirements
Resulting
Level of
Significance
a) Conflict with or obstruct implementation
of the applicable air quality plan SU  ☐ - No Impact
b) During construction, result in a
cumulatively considerable net increase of
any criteria pollutant for which the project
region is non-attainment under an
applicable federal or state ambient air
quality standard
LTS with MM  ☐
MM AIR-1a, Basic
Construction
Mitigation Measures
LTS w/ PR
c) During construction, expose sensitive
receptors to substantial pollutant
concentrations
LTS with MM  ☐ MM AIR-2A, Health
Risk Assessment
Or
Project Option AIR-2B,
Additional
Construction
Mitigation Measures
LTS w/ PR
d) During operations, result in a
cumulatively considerable net increase of
any criteria pollutant for which the project
region is non-attainment under an
applicable federal or state ambient air
quality standard
NA (not
applicable to
Plans)
 ☐ - LTS
e) During operations, expose sensitive
receptors to substantial pollutant
concentrations
LTS with MM  ☐ Project Requirement
Air-3, Diesel
Engines/Generator
Permits
Project Requirement
Air-4, New Source
Review
LTS w/ PR
f) Result in other emissions (such as those
leading to odors) adversely affecting a
substantial number of people
No Impact  ☐ - No Impact
a) Consistency with the Applicable Air Quality Plan
SSF 2040 General Plan EIR Conclusions
Vantage Master Plan Project – CEQA Analysis page 58
The SSF 2040 General Plan EIR (Impact AIR-1) determined that implementation of the 2040 General Plan would conflict with or obstruct implementation of the applicable air quality plan (AQP). The General Plan EIR determined that the current AQP is the 2017 Bay Area Clean Air Plan. 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. The General Plan EIR determined the following as pertaining to consistency with the applicable AQP:
• The General Plan, Zoning Ordinance amendments and 2022 CAP support the primary goals of the AQP to attain air quality standards, reduce population exposure and protect public health, and reduce GHG emissions and protect the climate. The General Plan was found to be consistent with the 2017 Bay Area Clean Air Plan’s primary goal of achieving and maintaining attainment status for ambient air quality standards, as the General Plan’s land use patterns would not be substantially different from existing land use patterns.
• With implementation of General Plan EIR MM AIR-1a (BAAQMD’s Basic Construction Mitigation Measures Recommended for All Proposed Projects), which are recommended by the BAAQMD to ensure construction fugitive dust emissions are less than significant, impacts pertaining to ambient air quality standards was determined to be less than significant with mitigation. • With implementation of General Plan EIR MM AIR-1b (BAAQMD Guidelines and California Office of Environmental Health Hazard Assessment (OEHHA) Policies and Procedures requiring a Health Risk Assessment), the General Plan was found to be consistent with the applicable AQP’s primary goal of reducing public health impacts, and this impact was determined to be less than significant with mitigation
• The General Plan was found to be consistent with the goals of the 2017 Bay Area Clean Air Plan to reduce GHG emissions, and accordingly this impact was determined to be less than significant. • The General Plan, Zoning Ordinance amendments and 2022 CAP include applicable control measures from the AQP. The BAAQMD’s 2017 Clean Air Plan contains 55 control measures aimed at reducing air pollution in the Bay Area. These include control measures addressing stationary, area, mobile source, and transportation emissions. They also include control measures designed to protect the climate and promote mixed use, compact development to reduce vehicle emissions and exposure to pollutants from stationary and mobile sources. The General Plan EIR found that the General Plan, Zoning Ordinance amendments and 2022 CAP include applicable control measures from the AQP. As such, the EIR concluded that the General Plan was consistent with the 2017 Clean Air Plan under this criterion, and this impact was determined to be less than significant. • The General Plan, Zoning Ordinance amendments and 2022 CAP would not disrupt or hinder implementation of any AQP Control Measures. 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, and do 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 such, the EIR determined that the General Plan would not hinder the BAAQMD from implementing the control measures in the 2017 Clean Air Plan, and this impact was found to be less than significant.
• The General Plan, Zoning Ordinance amendments and 2022 CAP would not reduce VMT per capita. One of the criteria for determining consistency with the 2017 Clean Air Plan is comparing the Planning Area’s VMT growth with population growth. The VMT growth facilitated by the General Plan was found to Vantage Master Plan Project – CEQA Analysis page 59
constitute an approximately 94 percent growth through 2040, while population growth facilitated by the General Plan was found to constitute an approximately 61 percent growth through 2040. The forecasted VMT growth was found to outpace the forecasted population growth.

Therefore, the EIR concluded that the General Plan was inconsistent with the 2017 Clean Air Plan, and this impact was determined to be significant and unavoidable.16 Project Analysis
Pursuant to the BAAQMD CEQA Guidelines Section 2.7, Thresholds of Significance for Plan-Level Impacts, proposed plans (such as the General Plan) must analyze the Plan’s consistency with the applicable AQP, including consistency with current AQP control measures and projected VMT or vehicle trips increase relative to its projected population increase. Individual projects are subject to project-level analysis pursuant to BAAQMD CEQA Guidelines Sections 2.1 through 2.6, addressing project-specific effects related to construction and operational-related criteria air pollutant emissions, construction and operational-related emissions of TACs or fine particulate matter, and odors. Those analyses are provided below. b) Construction-Period Criteria Pollutant Emissions
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact AIR-2) determined that implementation of the 2040 General Plan would result in a cumulatively considerable net increase of criteria air pollutants for which the region is under nonattainment status under applicable federal or State ambient air quality standards. Future development supported by the General Plan would result in short-term construction-related criteria pollutant emissions that have the potential to have an adverse effect on air quality. Future development activities would generally entail demolition, site preparation and grading, building construction, paving, and painting. Many new projects in the City will likely require the demolition of existing structures to make room for newer ones. 17 Fugitive dust emissions would typically be greatest during building demolition, site preparation and grading due to the disturbance of soil 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 type 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 timeframe than that required for redevelopment of small residential or mixed-use projects.

The General Plan EIR relies on criteria recommended by the Bay Area Air Quality Management District (BAAQMD) for determining the significance of construction-related impacts of criteria air pollutants and ozone precursors and cites BAAQMD’s CEQA Guidelines and its recommended “Basic” measures to control and reduce construction-related emissions. The General Plan EIR determined that consistency with these current Air Quality Control Plan measures would ensure the region's achievement and maintenance of attainment of federal and State ambient air quality standards. The General Plan EIR recommended Mitigation Measure AIR-1a, which contains BAAQMD’s “Basic Construction Mitigation Measures Recommended for All Proposed Projects”, as recommended by the BAAQMD to reduce construction-period fugitive dust emissions. The General Plan EIR concluded that construction-period criteria air pollutants would be reduced to less than significant levels with implementation of MM AIR-1a.
16 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact AIR-1, page 3.2-35 17 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact AIR-2, page 3.2-50 Vantage Master Plan Project – CEQA Analysis page 60
Project Analysis
Short-term criteria pollutant emissions associated with the Project (i.e., the Vantage Master Plan Phases 2 and 3) would occur during demolition, site preparation, grading, building construction, paving, and architectural coating activities.18 Project-related emission of ROG and NOX would primarily be associated with gasoline and diesel equipment exhaust and the application of architectural coatings. Project-related fugitive dust emissions (PM10 and PM2.5) would primarily be associated with site preparation. Typical construction equipment associated with construction of the Project includes dozers, graders, excavators, loaders and trucks.

The Project’s construction emissions were modeled using the latest version of the California Emissions Estimator Model (CalEEMod, Version 2022.1.0.14). Project-specific details were entered into the model for each phase of the Project’s construction, as well as individual construction sub-phases. Factors entered into the emissions estimator model included site acreage, demolition of the existing warehouse, site preparation and soil export quantities, grading acreage, new building construction (including parking structures), and architectural coatings.

Model defaults were otherwise used. The CalEEMod results are included in Appendix B, and emissions from construction are summarized in Table 8.

Table 8: Regional Air Pollutant Emissions during Project Construction Reactive Organic Gases Nitrogen Oxides PM10, Exhaust PM2.5, Exhaust Phase 2 Construction
Average Daily Emissions, 2023 2.46 lbs/day 21.0 lbs/day 0.55 lbs/day 0.51 lbs/day Average Daily Emissions, 2024 20.8 lbs/day 2.18 lbs/day 0.06 lbs/day 0.06 lbs/day Annual Emissions, 2023 0.45 tons/yr 3.83 tons/yr 0.10 tons/yr 0.09 tons/yr Annual Emissions, 2024 3.79 tons/yr 0.40 tons/yr 0.01 tons/yr 0.01 tons/yr Phase 3 Construction
Average Daily Emissions, 2026 1.54 lbs/day 13.6 lbs/day 0.37 lbs/day 0.35 lbs/day Average Daily Emissions, 2027 17.5 lbs/day 1.65 lbs/day 0.05 lbs/day 0.04 lbs/day Annual Emissions, 2026 0.28 tons/yr 2.48 tons/yr 0.07 tons/yr 0.06 tons/yr Annual Emissions, 2027 3.19 tons/yr 0.30 tons/yr 0.01 tons/yr 0.01 tons/yr Thresholds:

Daily Threshold 54 lbs/day 54 lbs/day 82 lbs/day 54 lbs/day Annual Threshold 10 tons/yr 10 tons/yr 15 tons/yr 10 tons/yr Exceed Threshold? No No No No
Source: Lamphier-Gregory, CalEEMod results included as Appendix B As shown above, the Project’s construction‐period emissions of criteria pollutants during both Phase 2 and Phase 3 are lower than BAAQMD threshold levels. However, BAAQMD considers fugitive dust generated by grading and construction activities to be a significant impact associated with the Project if uncontrolled. 18 Construction emissions from Phase 1 have already been subject to environmental review, and Phase 1 is currently under construction.

Vantage Master Plan Project – CEQA Analysis page 61
Applicable General Plan EIR Mitigation Measures
Pursuant to BAAQMD recommendations, the SSF 2040 General Plan EIR identified implementation of construction mitigation measures to reduce construction‐related emissions and dust for all projects, regardless of comparison to their construction‐period thresholds. These basic measures are included in the SSF General Plan EIR Mitigation Measure AIR‐1a, and would apply to the Project:

MM AIR-1a, Basic Construction Mitigation Measures: The Project shall incorporate the following Basic Construction Mitigation Measures recommended by the Bay Area Air Quality Management District (BAAQMD):19

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

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

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

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

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

6. Idling times shall be minimized either by shutting equipment off when not in use, or by 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.

7. All construction equipment shall be maintained and properly tuned in accordance with the manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation.

8. 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.

Conclusion: Consistent with the SSF 2040 General Plan EIR air quality impact analysis, the Project would be required to implement the BAAQMD’s recommended Basic Construction Mitigation Measures for control of construction-related criteria pollutant emissions per GP EIR MM AIR-1a. These measures would control construction-related emissions to levels of less than significant for Checklist item Air-b), and no additional mitigation is required.
c) Sensitive Receptor Exposure to Toxic Pollutant Concentrations - Construction SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact AIR-3) determined that implementation of the 2040 General Plan could expose sensitive receptors to substantial toxic air pollutant concentrations during construction. The General 19 Bay Area Air Quality Management District (BAAQMD), CEQA Guidelines, accessed at:
https://www.baaqmd.gov/~/media/files/planning-and research/ceqa/ceqa_guidelines_may2017-pdf.pdf Vantage Master Plan Project – CEQA Analysis page 62
Plan EIR defined toxic air contaminants (TACs) as airborne pollutants that may pose a present or potential hazard to human health.20
The General Plan EIR determined that TACs could be generated during construction activities, but that identification of potential impacts to sensitive receptors resulting from construction-generated TACs would require project-specific information for future individual land use development projects that was not known at the time of preparation of the General Plan EIR. The General Plan EIR includes mitigation measure MM AIR-1b, which requires future projects that may result in additional TACs and that are located within 1,000 feet of a sensitive receptor to implement BAAQMD CEQA Guidelines, and OEHHA policies and procedures requiring an HRA.

In consideration of policies and actions of the General Plan and regulations in SSFMC that target various strategies for reducing human health impacts and reducing exposure of sensitive receptors to substantial pollutant concentrations, as well as the implementation of MM AIR-1b, the General Plan EIR determined that this impact was less than significant with mitigation.

Project Analysis
The primary sources of TAC emissions during construction are diesel emissions from off-road equipment and onroad diesel trucks also known as diesel particulate matter (or DPM). Diesel exhaust is identified by the State of California as a known carcinogen. Exposure to DPM poses an increased health risk because small particles can deposit deeply in the lungs and contain substances that are particularly harmful to human health. Prolonged DPM exposure to sensitive receptors resulting from construction generated TACs can cause a wide range of health effects including aggravating asthma and bronchitis, causing visits to the hospital for respiratory and cardiovascular symptoms, and contributing to heart attacks and deaths.

For assessing community risks and hazards, the BAAQMD recommends identifying a 1,000-foot radius zone of influence around the Project property boundary. Within a 1,000-foot zone of influence from the Project site, there are no residential sensitive receptors, and no hospitals, congregate care facilities or school sensitive receptors. However, both of the Genentech pre-school/daycare facilities and the private Early Years preschool are within a 1,000-foot distance from Phase 2 construction activities at the Project site. • The private Early Years preschool is approximately 600 feet distant from construction of Building C, 750 feet distant from construction of Parking Structure 1, and 850 feet distant from construction of Building D, all during Phase 2 construction.
• The Genentech Second Generation preschool is approximately 300 feet distant from construction of Building C, 750 feet distant from construction of Building D, and 950 feet distant from construction of Parking Structure 1, all during Phase 2 construction.
• The relatively new Genentech Cabot Second Generation daycare is approximately 700 feet distant from construction of Building C, and 1,000 feet distant from construction of Building D and Parking Structure 1, all during Phase 2 construction.

There are no portions of Phase 3 construction within a 1,000-foot radius of the preschools and daycare centers.

No Health Risk Analysis (HRA) has been prepared for this CEQA checklist. According to BAAQMD CEQA Guidelines, “due to the variable nature of construction activity, the generation of TAC emissions in most cases would be temporary, especially considering the short amount of time such equipment is typically within an influential distance that would result in the exposure of sensitive receptors to substantial concentrations. 20 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact AIR-3, page 3.2-54 Vantage Master Plan Project – CEQA Analysis page 63
Concentrations of mobile-source diesel PM emissions are typically reduced by 70 percent at a distance of approximately 500 feet (ARB 2005). Current models and methodologies for conducting HRA are associated with longer-term exposure periods of 9, 40 and 70 years, which do not correlate well with the temporary and highly variable nature of construction activities”.

The Genentech Master Plan EIR (SSF, 2019) included an HRA that considered the health risks to each of these three daycare/preschool facilities from future construction within the Genentech Campus boundaries. Average annual dispersion factors were estimated for each sensitive receptor location, and an adjustment factor was applied to air concentrations modeled with continuous averaging time when the actual exposure occurs for less than 24 hours and/or less than one year. It was assumed that the emissions from construction sources would occur only during a 10-hour operational day, thereby compressing emissions that could potentially occur over a 24-hour period, 7 days per week into a 10-hour period, 5 days per week. Modeling adjustment factors were applied to the childcare population to adjust for the age of the receptors and the anticipated construction period during which a daycare child might be exposed to construction emissions. Cancer risk, chronic Health Index and PM2.5 concentrations were mapped, identify where construction activities pursuant to the Genentech Master Plan could be expected to exceed applicable health risk thresholds under an unmitigated scenario. According to the maps presented in the Genentech Master Plan EIR, construction activities could occur throughout the vast majority of the Genentech Campus without exceeding any health risk-based thresholds.

Limited areas of the Campus, generally within an approximate 300-foot radius from the preschools and daycare facilities, were shown as locations where construction activity could contribute to a significant health risk impact, and where refined health risk analyses for individual projects could ensure that cancer risk, chronic HI, and PM2.5 concentrations do not exceed significance thresholds. The HRA concluded that construction could occur within these 300-foot radius areas around the preschools and daycare facilities if all off-road dieselpowered construction equipment were to be installed with diesel particulate filters capable of reducing PM10 and PM2.5 emissions by as much as 85%. 21
Regulatory Requirements / SSF General Plan EIR Mitigation Measures The General Plan EIR’s MM AIR-1b requires future projects that may result in TAC emissions and that are located within 1,000 feet of a sensitive receptor to implement BAAQMD CEQA Guidelines, and/or OEHHA policies and procedures for preparing a Health Risk Analysis. Based on this General Plan EIR mitigation, one of the following options would be required of the Project:

Project Requirement Option AIR-2A, Health Risk Assessment: Similar to the Genentech HRA, the Project applicant would be required to conduct a HRA for all Phase 2 construction activities that are located within 1,000 feet of the preschool/daycare facilities prior to grading, and implement diesel emission reductions as prescribed by that HRA as being necessary to protect the health of preschool and daycare sensitive receptors (i.e., below threshold levels of cancer risks of less than 10 in a million, below a Health Index of 1, and below a PM2.5 concentration of 0.30ug/m3).

Or –
Project Option AIR-2B, Additional Construction Mitigation Measures: The Project shall incorporate the following Additional Construction Mitigation Measures as recommended by the BAAQMD for projects where construction-related emissions could exceed the applicable thresholds of significance: 22 21 SSF, Genentech Master Plan Update Draft EIR, October 2019, pages 6-21 through 6-29 22 Bay Area Air Quality Management District (BAAQMD), CEQA Guidelines, Table 8-3, page 8-5, accessed at:
https://www.baaqmd.gov/~/media/files/planning-and research/ceqa/ceqa_guidelines_may2017-pdf.pdf Vantage Master Plan Project – CEQA Analysis page 64

1. All exposed surfaces shall be watered at a frequency adequate to maintain minimum soil moisture of 12 percent. Moisture content can be verified by lab samples or moisture probe.

2. All excavation, grading, and/or demolition activities shall be suspended when average wind speeds exceed 20 mph.

3. Wind breaks (e.g., trees, fences) shall be installed on the windward side(s) of actively disturbed areas of construction. Windbreaks should have a maximum of 50 percent air porosity.

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

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

6. All trucks and equipment, including their tires, shall be washed off prior to leaving the site.

7. Site access to a distance of 100 feet from the paved road shall be treated with a 6-to-12-inch compacted layer of wood chips, mulch, or gravel.

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

9. Minimizing the idling time of diesel-powered construction equipment to two minutes.

10. The project shall develop a plan demonstrating that the off-road equipment (more than 50 horsepower) to be used in the construction project (i.e., owned, leased, and subcontractor vehicles) would achieve a project wide fleet-average 20 percent NOX reduction and 45 percent PM reduction compared to the most recent ARB fleet average. Acceptable options for reducing emissions include the use of late model engines, low-emission diesel products, alternative fuels, engine retrofit technology, after-treatment products, add-on devices such as particulate filters, and/or other options as such become available.

11. Use low VOC (i.e., ROG) coatings beyond the local requirements (i.e., Regulation 8, Rule 3: Architectural Coatings).

12. Require that all construction equipment, diesel trucks, and generators be equipped with Best Available Control Technology for emission reductions of NOx and PM.

13. Require all contractors to use equipment that meets CARB’s most recent certification standard for offroad heavy-duty diesel engines.

The current Tier 4 emission standards have been phased-in from 2008 through 2015 for the sale of all new offroad heavy-duty diesel engines. Recent studies show that off-road heavy-duty diesel engines meeting Tier 4 standards (CARB’s most recent certification standard for off-road heavy-duty diesel engines) result in reductions of PM and NOx emissions by about 90% as compared to prior Tier 2 and Tier 3 engines. 23 Conclusion: Consistent with the findings of the SSF 2040 General Plan EIR, the Project would be required to either conduct an HRA for Phase 2 construction and implement diesel emission reductions as identified in that HRA, or implement the BAAQMD’s recommended Additional Construction Mitigation Measures for control of construction-related TAC emissions per GP EIR MM AIR-1b. Either of these approaches would control construction-related TAC emissions to levels of less than significant for Checklist item Air-c, and no additional mitigation is required.
23 DieselNet, accessed at: https://dieselnet.com/standards/us/nonroad.php Vantage Master Plan Project – CEQA Analysis page 65
Airborne Asbestos Hazards
As addressed in detail in the Hazards section of this CEQA Checklist, the northwestern corner of the Project site’s bedrock consists of sandstone, shale and serpentinite, which may contain naturally occurring asbestos. As part of the geotechnical investigations for the Project, the results of asbestos testing indicated concentrations of asbestos ranging from 0.25 to 3 percent, which exceeds the 2019 RWQCB ESLs for both commercial and industrial land use.

Regulatory Requirement
The BAAQMD regulates construction projects of greater than one acre in size, where naturally occurring asbestos (NOA), serpentinite or ultramafic rock is present. The following regulatory requirement (as more fully addressed in the Hazards section of this CEQA Checklist) applies to grading and construction activity, specifically at this portion of the Project site:
❖ Project Requirement HAZ-5, Asbestos Airborne Toxic Control Measures: Due to the presence of naturally occurring asbestos at portions of the Project site, those portions of the site are subject to Title 17 of the California Code of Regulations (17 CCR) Section 93105 – CARB Asbestos Airborne Toxic Control Measures (ATCM). The CARB Asbestos ATCM is enforced locally by the Bay Area Air Quality Management District (BAAQMD) and requires construction projects greater than one acre in size, in which naturally occurring asbestos (NOA), serpentinite or ultramafic rock is present, to prepare a site-specific Asbestos Dust Mitigation Plan (ADMP) for agency approval. The ADMP must specify dust mitigation measures to be initiated at the start and maintained throughout the duration of the construction and grading activity.

The Project would be required to implement the BAAQMD’s Asbestos Airborne Toxic Control Measures, and these measures would control construction-related emissions of naturally occurring asbestos to levels of less than significant.

Conclusions: Consistent with the findings of the SSF General Plan EIR, the Project would be required to implement the BAAQMD’s Asbestos Airborne Toxic Control Measures, and these measures would control construction-related emissions of naturally occurring asbestos to levels of less than significant. As such, the Project’s construction activities would not expose persons to substantial pollutant concentrations (Checklist item Air-c), this impact would be less than significant, and no additional mitigation is required. d) Operational Period Criteria Pollutant Emissions
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact AIR-2) determined that implementation of the 2040 General Plan would result in a cumulatively considerable net increase of operational criteria air pollutants for which the region is in non-attainment status under applicable federal or State ambient air quality standards.24 Long-term criteria pollutant emissions would result from the operation of residential, retail, light industrial, commercial, and institutional uses supported by the General Plan. Operational air quality emissions are principally generated from area sources, energy, and mobile sources. Area source emissions are the combination of outdoor landscape maintenance equipment, use of consumer products such as cleaning products, use of fireplaces and hearths, and periodic re-application 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 direct energy source emissions as those emissions are generated from operation of an electricity 24 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact AIR-2, page 3.2-52 Vantage Master Plan Project – CEQA Analysis page 66
generation facility, which may or may not be within the same air basin and under the same attainment status as the end-user. Mobile source emissions result from the vehicle activity associated with the operation of land use development projects, including worker and patron vehicle trips.

The General Plan EIR requires that future development projects pursuant to the General Plan be subject to the City’s standard CEQA review process, and that project-specific emissions be evaluated in relation to the BAAQMD significance thresholds. Although project-level information was not available when the City prepared the General Plan EIR, the General Plan EIR estimated emissions resulting from future development by utilizing CalEEMod, which provided an estimate of the potential overall area, energy and mobile source emissions resulting from General Plan buildout. This estimate was presented in the General Plan EIR for informational purposes only, because BAAQMD guidance for plan-level analysis does not require an emissions inventory of criteria air pollutants.

The General Plan EIR (Table 3.2-7, reproduced here as Table 9) identified that overall area and energy source emissions would increase from baseline conditions due to the projected increase in residential units and nonresidential space. Conversely, the General Plan EIR found that overall mobile source emissions would decrease from baseline emissions, largely due to improved fuel efficiency standards, the accelerated adoption of EVs, and fleet turnover requirements implemented at the State level. Nonetheless, the emissions estimates contained in the General Plan EIR provide a picture of the potential overall area, energy, and mobile source emissions resulting from buildout of the General Plan.

Table 9: Net Operational Emission, at General Plan Buildout 2040 Criteria Air Pollutants (lbs/day)
Category ROG NOx PM10 (emissions) PM2.5 (emissions)
Area 529.8 135.6 17.9 17.9
Energy 11.6 102.2 8.0 8.0
Transportation -243.5 -1,517.2 2,216.6 445.9
Total, lbs/day 297.8 -1,279.3 2,242.5 471.8
Total, tons/yr. 54.4 -233.5 409.3 86.1
Source: General Plan EIR Table 3.2-7, per CalEEMod Version 2020.4.0 and EMFAC 2021 Pursuant to BAAQMD recommendations, the criteria used for determining the significance of plan-level impacts is to analyze the General Plan’s projected growth in VMT as compared to its projected population growth under existing conditions. If the General Plan’s projected VMT growth outpaces projected population growth, then the General Plan would result in a cumulatively considerable net increase in criteria pollutants, and this impact would be potentially significant. The General Plan EIR determined that VMT growth facilitated by the General Plan would constitute an approximately 94 percent growth in VMT through 2040, while population growth facilitated by the General Plan would constitute an approximately 61 percent growth through 2040. Therefore, the forecasted VMT growth was found to outpace the forecasted population growth. As such, the General Plan EIR concluded that this impact would be potentially significant. The General Plan EIR found no reasonable mitigation that could be implemented to increase population projections while keeping VMT growth to a minimum, and this impact was concluded to remain significant and unavoidable.

Vantage Master Plan Project – CEQA Analysis page 67
Project Analysis
Criteria pollutant emissions from operation of the Project (i.e., Phases 2 and 3 of the Vantage Master Plan) could cumulatively contribute to air pollutant levels in the region. These air pollutants include ROG and NOx that affect ozone levels (and to some degree), particulate levels of PM10, and PM2.5.25 Emissions of air pollutants associated with the Project were predicted using CalEEMod (California Emissions Estimator Model, 2022 Soft Release). This model predicts daily emissions associated with development projects including transportation, energy and other utilities, and on‐site activities such as landscaping and building cleaning and maintenance.

CalEEMod inputs included the following:
• Project-specific data regarding building space, lot size and landscape area • VMT data specific to the Project, including implementation of the Project’s required Tier 4 TDM Plan (see Transportation section of this CEQA checklist)26
• Project-specific energy demands are based on the energy demands, inclusive of an approximately 4% decrease in energy use from Title 24 Energy Efficient Standards based on design efficiencies. Energy demands also incorporate on-site energy generation from PV panels on building rooftops as an option, if all-electric buildings are not pursued (see Energy section of this CEQA Checklist) • Water demands of the Project, as calculated using water use factors from the General Plan EIR (see Utility section of this CEQA Checklist)
• Solid waste, based on General Plan EIR waste generation rates (see Utility section of this CEQA Checklist) • All other CalEEMod inputs relied on model default values.

The results of operational emissions modeling for the Project are included in Appendix C, and summarized in Table 10, below.
25 Phase 1 of the Project has already been reviewed, approved and is currently under construction. Operational emissions from Phase 1 of the Project are not included in this analysis.
26 The VMT data for Phases 2 and 3 represent a 78.5 % proportional share of Project buildout VMT (1,298.6 ksf / 16552 ksf = 0.785) Vantage Master Plan Project – CEQA Analysis page 68
Table 10: Project’s Operational Emissions of Criteria Pollutants Criteria Air Pollutants (lbs/day)
Category ROG NOx PM10 (emissions) PM2.5 (emissions)
Project Emissions
Area 36.1 0.2 0.1 0.1
Energy 0.4 7.2 0.5 0.5
Transportation 15.6 12.3 0.2 0.2
Total, lbs/day 52.1 19.7 0.8 0.8
Threshold (Exceed?) 54 (No) 54 (No) 82 (No) 54 (o)
Total, tons/yr. 9.5 3.6 0.2 0.2
Threshold (Exceed?) 10 (No) 10 (No) 15 (No) 10 (No)
Source: CalEEMod Version 2022 Soft Release (see Appendix C) As demonstrated in Table 10, the Project’s predicted average daily and annual operational-generated emissions of NOx, PM10 and PM2.5 criteria air pollutants are below the operational significance thresholds as recommended by the BAAQMD and as relied on in the General Plan EIR. Therefore, operational air quality impacts related to cumulatively considerable net increases of these non-attainment criteria pollutants would be less than significant.

Conclusion: Consistent with the findings of the SSF 2040 General Plan EIR, the Project has been subject to the City’s standard CEQA review process, and Project-specific emissions have been evaluated in relation to the BAAQMD significance thresholds. This analysis demonstrates that the Project’s impact related to increased operational criteria air pollutants for which the region is in non-attainment status (Checklist item Air-d) would be less than significant, and no additional mitigation is required. e) Operational Period Toxic Pollutant Concentrations
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact AIR-3) determined that implementation of the 2040 General Plan would not expose sensitive receptors to substantial pollutant concentrations. Localized risks associated with pollutant concentrations are primarily related to exposure to TAC emissions. TACs are a defined set of airborne pollutants that may pose a present or potential hazard to human health. Common sources of TAC emissions are stationary sources (e.g., diesel backup generators), which are subject to BAAQMD permit requirements. Although the General Plan does not include specific plans for any new, large, stationary sources of emissions, such sources could be developed near sensitive receptors.27
The General Plan EIR includes Mitigation Measure AIR-1b, which recommends that future development facilitated by the General Plan not expose sensitive receptors to substantial pollutant concentrations. As detailed in MM AIR-1b, future projects that may result in additional TACs, and that are located within 1,000 feet of a sensitive receptors to implement BAAQMD Guidelines and OEHHA policies and procedures requiring an HRA to demonstrate that future development would result in less than significant impacts to sensitive receptors. 27 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact AIR-3, page 3.2-54 Vantage Master Plan Project – CEQA Analysis page 69
SSFMC Section 20.300.010 also establishes regulations related to air contaminants, requiring that new sources of air pollution comply with rules identified by the EPA, the CARB, and the BAAQMD. The section further requires that operators of activities, processes, or uses that require an “approval to operate” permit from the BAAQMD to file a copy of that permit with the Planning Division. Considering the policies and actions of the General Plan and regulations in SSFMC that target various strategies for reducing human health impacts and reducing exposure of sensitive receptors to substantial pollutant concentrations, as well as the implementation of MM AIR-1b,this impact was found to be less than significant with mitigation.

Project Analysis
The Project includes multiple new buildings and parking structures of 8 to 13 stories tall. These buildings and parking structures will require elevators, and these elevators will need back-up power (typically diesel emergency generators) to provide power in the event of a power outage emergency.

The Project is also intended to accommodate future R&D uses. The specific R&D tenants are not known, the types of research and development facilities have not been identified, and the need for research and development equipment that may generate new sources of toxic air contaminants is unknown. However, future R&D tenants may rely on such equipment.

Regulatory Requirements
The BAAQMD regulates stationary sources of toxic air contaminants through its permit authority pursuant to Regulation 2, Rule 5: New Source Review of Toxic Air Contaminants. The purpose of this rule is to provide for the review of new and modified sources of toxic air contaminant (TAC) emissions in order to evaluate potential public exposure and health risk, to mitigate potentially significant health risks resulting from these exposures, and to provide net health risk benefits by improving the level of control when existing sources are modified or replaced.
❖ Project Requirement Air-3, Diesel Engines/Generator Permits: Owners/operators of engines (including emergency back-up generators) larger than 50 brake horsepower are required to get Air District permits.

The Air District is currently notifying permit applicants of achieved-in-practice best available control technology (BACT) for large emergency backup engines. This would potentially affect engine permit applications under Air District review by requiring engines to meet EPA Tier 4 emissions standards. ❖ Project Requirement Air-4, New Source Review: New sources of toxic air contaminants associated with the Project are required to obtain an Authority to Construct, or a Permit to Operate. New sources with hazardous air pollutant emissions may also be subject to the Maximum Achievable Control Technology (MACT) requirements.

1. An application for an Authority to Construct or Permit to Operate shall contain an HRA.

2. If the Air Pollution Control Officer (APCO) notifies the applicant that the results of an HRA indicate that the project would not meet requirements of this rule, the applicant shall be given the opportunity to perform a more refined HRA, modify the project, or submit any required plans or information as necessary to comply with the requirements of this rule.

3. The applicant shall apply Toxic BACT to any new or modified source of TACs where the source risk is a cancer risk greater than 1.0 in one million (10-6 or 1.0E-6), and/or a chronic hazard index greater than

0.20. 4. The APCO shall deny an Authority to Construct or Permit to Operate for any new or modified source of TACs if the project risk exceeds any of the following project risk limits: 1) a cancer risk of 10.0 in one million, 2) a chronic hazard index of 1.0, or 3) an acute hazard index of 1.0.

Vantage Master Plan Project – CEQA Analysis page 70
Conclusion: Consistent with the findings of the SSF General Plan EIR, future tenants of the Project’s R&D buildings will be required to obtain from the BAAQMD an “Authority to Construct” or a “Permit to Operate” for any new sources of hazardous air pollutant emissions. The requirements of these authorizations or permits would control operational-related emissions of toxic air contaminants to levels of less than significant. As such, the Project’s operations would not expose persons to substantial pollutant concentrations (Checklist item Air-e), this impact would be less than significant, and no additional mitigation is required. f) Odors
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact AIR-4) determined that implementation of the 2040 General Plan would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

According to the BAAQMD’s 2017 CEQA Air Quality Guidelines, land uses associated with odor complaints typically include agricultural operations, wastewater treatment plants, landfills, and certain industrial operations such as chemical and other manufacturing. While odors do not present a health risk themselves, they are often considered a nuisance by people who live, work, or otherwise are located near outdoor odor sources. The BAAQMD’s CEQA Air Quality Guidelines identify a screening distance for 1 and 2 miles for the most common odor-generating land uses. Projects located outside of these screening distances would be presumed to not be exposed to odors, while projects within these screening distances present a potential to be exposed to odors.

BAAQMD Regulation 7 limits emissions of odorous substances within the Air Basin and would apply to any new odor source. Compliance with the applicable regulations in SSFMC and applicable BAAQMD rules and regulations would minimize odor emissions from adversely affecting a substantial number of people within the City, and this impact was found to be less than significant.28
Project Analysis
The Project does not include any of the types of land uses typically associated with odor complaints, such as agricultural operations, wastewater treatment plants or landfills. Consistent with BAAQMD Regulation 7 as cited in the General Plan EIR, any potential source of odorous substances that may be attributed to the R&D operations within the project would apply (as may be necessary), and compliance with these potentially applicable regulations of the BAAQMD would minimize any such odor emissions to a level of less than significant.

Conclusion: Consistent with the findings of the SSF 2040 General Plan EIR, the Project would not result in odor emissions that would affect a substantial number of people within the City. This impact (Checklist item Air-f) would be less than significant, and no additional mitigation is required.

CEQA Conclusion Pertaining to Air Quality
Based on the analysis, findings and conclusions of the SSF 2040 General Plan EIR, implementation of the Project would not substantially increase the severity of any significant air quality impacts as identified in that prior EIR, nor would it result in new significant air quality impacts that were not previously identified. The 2040 General Plan EIR identified three mitigation measures that are applicable to the Project:
• MM AIR-1a: Individual development projects shall incorporate Basic Construction Mitigation Measures recommended by the BAAQMD
28 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact AIR-4, page 3.2-57 Vantage Master Plan Project – CEQA Analysis page 71
• MM AIR-1b: Projects that may result in additional toxic air contaminants 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 • MM TRANS-1: 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
These mitigation measures and applicable regulatory requirements related to air quality would apply to the Project and/or have been incorporated into the Project design. Implementation of those mitigation measures and regulatory requirements would ensure the Project’s impacts to air quality would remain less than significant. No further environmental review of the Project pertaining to the topic of air quality is required.

Vantage Master Plan Project – CEQA Analysis page 72
Biological Resources
Would the Project:

SSF 2040
General Plan
EIR Findings
Relationship to SSF 2040
General Plan EIR Findings: Project Conclusions:

Equal or
Less Severe
New or
Substantial
Increase in
Severity
Applicable Standards
and Requirements
Resulting
Level of
Significance
a) Have a substantial adverse effect, either
directly or through habitat modifications,
on any species identified as a candidate,
sensitive, or special status species in local
or regional plans, policies, or regulations,
or by the California Department of Fish and
Game or U.S. Fish and Wildlife Service
LTS with MM  ☐ MM BIO-1, Specialstatus Species, Migratory Birds and Nesting Birds
Regulatory Requirement
Bio-1A, Nesting Birds
Regulatory Requirement
Bio-1B, Roosting Bats
LTS w/ PR
b) Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional
plans, policies or regulations, or by the
California Department of Fish and Game or
US Fish and Wildlife Service
LTS  ☐
- No Impact
c) Have a substantial adverse effect on
state or federally protected wetlands
(including, but not limited to, marsh,
vernal pool, coastal, etc.) through direct
removal, filling, hydrological interruption,
or other means
LTS with MM  ☐
- No Impact
d) Interfere substantially with the
movement of any native resident or
migratory fish or wildlife species or with
established native resident or migratory
wildlife corridors, or impede the use of
native wildlife nursery sites
LTS with MM  ☐ - Less than
Significant
e) Conflict with any local policies or
ordinances protecting biological resources,
such as a tree preservation policy or
ordinance
LTS  ☐ Regulatory Requirement
BIO-5A: Street Trees
Regulatory Requirement
BIO-5B: Protected Trees
LTS w/ PR
Vantage Master Plan Project – CEQA Analysis page 73
f) Conflict with the provisions of an
adopted Habitat Conservation Plan,
Natural Community Conservation Plan, or
other approved local, regional, or state
habitat conservation plan
LTS  ☐ - No Impact
a) Candidate, Sensitive or Special Status Species
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact Bio-1) determined that implementation of the 2040 General Plan could have a substantial adverse effect, either directly or through habitat modifications, on species identified as 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.29 As cited in the SSF 2040 General Plan, 48 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. These sensitive plant species are most likely to be found in the estuary habitats around San Francisco Bay and the San Bruno Mountain State Park. The special-status wildlife species are most likely to be found in open space areas of the City, in the surrounding hillsides, and 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. Those species most adapted to manmade habitats include the Alameda song sparrow, American peregrine falcon and Townsend’s big-eared bat.

Development pursuant to the SSF 2040 General Plan would result in additional residential and nonresidential development, but 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 sub-areas. However, other projects may occur on private and public lands throughout the City where there is the potential for environmental effects related to biological resources. Therefore, subsequent development pursuant to the General Plan could result in the direct/indirect loss or indirect disturbance of special-status plant or animal species or their habitats.

Future development pursuant to the General Plan update would be required to comply with the various federal and State laws and regulations that protect special-status plant and animal species, including the Endangered Species Act and the California ESA, as well as requirements of the South San Francisco Zoning Ordinance, and General Plan policies and actions related to biological resources. To further enhance and ensure protection of threatened and endangered species, and to protect nesting and migratory birds, the SSF 2040 General Plan EIR includes Mitigation Measure BIO-1, which requires that focused surveys be conducted by any project applicant or sponsor to determine whether special-status species, nesting birds or migratory birds occur on a given project site, that potential impacts to special-status species be avoided and minimized, and that any losses be fully compensated on-site or at a habitat mitigation bank. Implementation of these requirements will result in avoiding the most biologically sensitive areas, concentrating development in previously disturbed areas, requiring surveys, and emphasizing avoidance, minimization and mitigation of impacts to habitats. 29 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact BIO-1, page 3.3-18 Vantage Master Plan Project – CEQA Analysis page 74
Therefore, with mandatory regulatory compliance and implementation of MM BIO-1, the SSF 2040 General Plan EIR concluded that future development projects would not result in significant adverse effects to biological resources, and such impacts were concluded to be less than significant with mitigation.

Project Analysis
General Plan EIR Figure 3.3-1 does not show the Project site as being within an identified habitat type or protected area, and General Plan EIR Figure 3.3-2 does not show the Project site as being within an ecologically sensitive area (see Figure 16).

The Project site is more than one-half mile from sensitive species that may be associated with estuary habitats around San Francisco Bay, and where shorebirds and aquatic species can be found. The Project site is even further separated from San Bruno Mountain State Park and surrounding hillsides, where critical sensitive plant habitat and special-status wildlife species are most likely to be found.

The Project site is dominated by developed and landscaped habitat that includes paved roads, buildings, parking lots, paved and gravel trails, ornamental and landscaped areas. The habitat suitability for rare or native vegetation in these areas is very low to absent. Similarly, developed habitats as exist at the Project site primarily support common, urban-adapted wildlife species, and overall wildlife abundance and diversity are low.

However, existing shrubs and trees may offer sufficient cover for nesting birds.

Applicable Mitigation Measures
Consistent with the SSF 2040 General Plan EIR, the following General Plan EIR mitigation measure pertaining to migratory birds and nesting birds is applicable to the Project:

MM BIO-1, Special-status Species, Migratory Birds and Nesting Birds: 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 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.

Vantage Master Plan Project – CEQA Analysis page 75
Fig 16
Vantage Master Plan Project – CEQA Analysis page 76
Regulatory Requirements
More specifically and pursuant to existing regulatory requirements of the Migratory Bird Treaty Act and/or the California Fish and Game Code, the following measures for projects that involve tree removal shall be implemented prior to the removal of any existing trees at the Project site. Certain trees within the Phase I portion of the site have already been removed in accordance with prior City approval of Phase I development, and that development is currently under construction.
❖ Regulatory Requirement Bio-1A, Nesting Birds: Vegetation clearing and tree removal during the nesting season (February 1 through August 31) could impact active nests of birds protected under the Migratory Bird Treaty Act and/or the California Fish and Game Code, including special‐status bird species. Pre‐ construction nesting bird surveys will be required within 30 days prior to proposed tree removal, in and adjacent to the areas scheduled to be cleared. If an active nest is found, a buffer (typically 50 to 300 feet depending on the nesting species) around the nest would be required, and the nest may have to be periodically monitored by a qualified biologist until the young have fledged and are foraging independently, or until the nest is determined to be inactive.
❖ Regulatory Requirement Bio-1B, Roosting Bats: Tree‐roosting bats could occur in the trees on or near the site. A roosting bat survey should be conducted by a qualified biologist in and around suitable trees and buildings to be removed, within 30 days prior to proposed tree removal or demolition, to determine whether or not bats are roosting within or adjacent to the project area. Surveys should consist of daytime pedestrian surveys to look for visual signs of bats, and if determined necessary, evening emergence surveys to note the presence or absence of bats.

1. If roosting bats are detected and directly impacted by the work, bat exclusion from roosts should be performed by a qualified biologist in consultation with CDFW prior to the removal of the roosts.

Exclusionary devices such as plastic sheeting, plastic or wire mesh may be used to allow bats to exit but not re‐enter any occupied roosts.

2. If special‐status bats are found on‐site and their roosts would be destroyed during development, an artificial roost should be provided for the bats. The artificial roost should be constructed and placed on‐ site prior to removal of the original roost.

3. Removal of maternity roosts for special‐status bats should be coordinated with CDFW prior to removal.

Maternity roosts for any species of bat, either common or special status, should not be demolished or removed until the young are able to fly independently of their mothers. Trees and branches that support potential bat roosts that are being removed as part of the Project should be left in‐place overnight before being wood‐chipped or hauled away. Leaving trees and branches overnight will allow any possible roosting bats present within the fallen trees to fly away.

4. If maternity roosts are found in trees to be preserved near the work area, a qualified biologist should determine an appropriate no‐work buffer zone. Species‐specific noise tolerance levels (including high frequency noise) should be established for work taking place near the buffer around the maternity roost.

Conclusion: Consistent with the conclusions of the SSF 2040 General Plan EIR, the Project would be required to implement existing regulatory requirements of the Migratory Bird Treaty Act and/or the California Fish and Game Code pursuant to MM Bio-1. These measures provide for protection of active nests of migratory and other birds and bats, including their roosts, eggs and young. Implementation of these measures would avoid and/or reduce impacts to sensitive status species (Checklist item Bio-a) to levels of less than significant.

Vantage Master Plan Project – CEQA Analysis page 77
b) Riparian Habitat or Other Sensitive Natural Community SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact BIO-2) determined that implementation of the 2040 General Plan would not have a substantial adverse effect on any riparian habitat or other sensitive natural community as identified in local or regional plans, policies and regulations, or as identified by the California Department of Fish and Wildlife or United States Fish and Wildlife Service.30
Future development pursuant to the General Plan would be required to comply with adopted State, federal and local regulations for the protection of riparian habitat and other sensitive natural communities. In addition, future projects would comply with requirements of General Plan policies and actions and the SSF Zoning Ordinance related to the protection of biological resources. Implementation of these policies, actions and requirements would reduce potential impacts to below a level of significance. Therefore, the General Plan EIR concluded that future development pursuant to the General Plan would not result in significant adverse effects to riparian habitat or other sensitive natural communities.

Project Analysis
The Project site is dominated by developed and landscaped habitat that includes paved roads, buildings, parking lots, paved and gravel trails, and ornamental and landscaped areas. The Project site does not contain riparian habitat or other sensitive natural community types. According to Figure 3.2-2 of the General Plan EIR, the nearest sensitive natural communities are the riverine wetlands and tidal marshes south of the Oyster Point Marina (approximately 0.3 miles to the northeast), and tidal marshes and open water in San Francisco Bay (approximately 0.66 miles to the south).

Conclusion: Consistent with the conclusions of the SSF 2040 General Plan EIR, development of the Project site will have no adverse effect on riparian habitat or other sensitive natural community types (Checklist item Bio-b). c) Wetlands
SF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact BIO-3) determined that implementation of the SSF 2040 General Plan 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. 31 Estuarine and marine wetlands line the City’s coastline and parts of Colma Creek and San Bruno Creek, and a navigable slough is located south of Colma Creek in the southeastern portion of the City. Subsequent development pursuant to the General Plan, primarily adjacent to the San Francisco Bay, could result in direct or indirect effects on estuarine habitat and other sensitive marine communities. To ensure protection of wetlands and waters of the United States and/or the State, the SSF 2040 General Plan includes MM BIO-3, which requires that a qualified biologist/wetland regulatory specialist conduct a site investigation and assessment for those projects located on sites where potential jurisdictional wetlands or waterways are present. MM BIO-3 further requires that if a feature is found to be jurisdictional or potentially jurisdictional, that the applicant complies with the appropriate permitting process of the respective agency’s jurisdiction prior to disturbance of the feature.
30 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact BIO-1, page 3.3-22 31 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact BIO-3, page 3.3-23 Vantage Master Plan Project – CEQA Analysis page 78
The SSF 2040 General Plan EIR concluded that, with mandatory regulatory compliance and implementation of MM BIO-3, future development projects would not result in significant adverse effects to federally protected wetlands, waters of the United States or waters of the State, and impacts would be considered less than significant with mitigation.

Project Analysis
According to a Preliminary Geotechnical Site Assessment conducted at the Project site, the surface of the site is overlain with two to three feet of fill consisting of sand and gravel.32 The Project site does not contain any natural watercourses or manmade drainage ditches, and there is no indication of wetlands or water features on the site. The majority of the site has been previously covered with urban industrial development and paving.

Only the previously entitled Phase I portion of the site (currently under construction) and the proposed Public Benefit/Fire Station site have any bare soil exposed, and no marsh, vernal pools or estuarine or marine wetlands are present. 33 No potential jurisdictional wetlands or waters occur on the Project site.

Conclusion: Consistent with the findings of the SSF 2040 General Plan EIR, the Project would not have a substantial adverse effect on State or federally protected wetlands or waters of the U.S. or waters of the State (Checklist item Bio-c), and no mitigation is required.
d) Wildlife Corridors or Native Wildlife Nursery Sites
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact BIO-4) determined that implementation of the SSF 2040 General Plan could interfere substantially with the movement of native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors and could impede the use of wildlife nursery sites. 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 also support the movement of a variety of migratory bird species, while creeks and drainages typically serve as movement corridors for wildlife.34
As described in the General Plan EIR, future development pursuant to the General Plan would be required to comply with adopted State, federal and local regulations for the protection of biological resources. Future projects must also comply with requirements of the South San Francisco Municipal Code and Zoning Ordinance, and General Plan policies related to biological resources. MM BIO-1 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. MM BIO-3 requires site investigations and assessments for projects on sites where potential jurisdictional wetlands or waterways are present, and compliance with the appropriate permitting process. Accordingly, future development pursuant to the General Plan would not result in significant adverse effects to wildlife corridors or native wildlife nursery sites, and impacts were concluded to be less than significant with mitigation. 32 Langan Engineers, Preliminary Geotechnical Site Assessment, October 2020 33 National Wetlands Inventory, accessed at: https://fwsprimary.wim.usgs.gov/wetlands/apps/wetlands-mapper/ 34 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact BIO-4, page 3.3-26 Vantage Master Plan Project – CEQA Analysis page 79
Project Analysis
According to Exhibit 3.3-3 of the SSF 2040 General Plan EIR showing Potential Connectivity for Wildlife Species, the undeveloped portions of the Project site and the Rails-to-Trails pedestrian and bikeway path immediately south of the Project site are identified as “tree-covered areas” that may provide wildlife connections between other open areas of the City.

However, the Phase I portion of the Project site was previously entitled for new development that is currently under construction, and no trees remain on this portion of the site. The most westerly 420 Forbes parcel has been disked and surface-graded for maintenance and temporary truck parking for well over 20 years. No trees have been located on that site for at least that amount of time. These portions of the Project site are generally isolated undeveloped properties amid a very urbanized and industrial area, and unlikely to provide for substantial movement of native resident or migratory wildlife species. The Project site does not include any waterways, ridgelines or creek corridors, and the Project site is not identified as a wildlife corridor or wildlife nursery site.

Conclusion: Consistent with the findings of the SSF 2040 General Plan EIR, the Project would not have a substantial adverse effect on wildlife corridors or wildlife nursery sites (Checklist item Bio-d). e) Local Policies or Ordinances Protecting Biological Resources SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact BIO-5) determined that implementation of the 2040 General Plan would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. As cited in the General Plan EIR, Chapter 13.28 of SSFMC, which establishes the City’s Street Tree Preservation regulations pertaining to trees located on City property. SSFMC Chapter 13.30 establishes the standards and requirements for the protection of certain large trees and trees with unique characteristics, provides standards and requirements for planting and maintenance of trees for new development, and establishes recommended standards for planting and maintaining trees on property that is already developed.35 Future development pursuant to the General Plan would be subject to these mandatory tree preservation requirements and would therefore not conflict with local policies or ordinances protecting biological resources.

The General Plan EIR concluded that this impact would be less than significant.

Project Analysis
With prior removal of trees from the previously entitled and currently under construction Phase I site, there are few if any on-site trees at the Project site. However, the frontage along 440 and 460 Forbes Boulevard would remain as a landscaped and tree-lined setback.

Regulatory Requirements
As cited in the SSF 2040 General Plan, the following regulatory requirements are applicable to the Project:
❖ Regulatory Requirement BIO-5A: Street Trees: Per SFFMC Section 13.28, if any proposed construction, improvement, demolition or any other work on or adjacent to public property requires removal of a tree planted on the public property, the person undertaking the work shall apply for a permit to remove the tree.

The permit may be issued on condition that the applicant replaces the tree with one of the same size and species.
35 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact BIO-5, page 3.3-27 Vantage Master Plan Project – CEQA Analysis page 80
❖ Regulatory Requirement BIO-5B: Protected Trees: Per SSFMC Section 13.30, the removal or pruning of protected trees without a permit is prohibited.

1. A “protected tree” is defined as: a) any upright, single-trunked tree of a species not considered to be a heritage tree, with a circumference of forty-eight inches diameter at breast height (dbh); any upright, single-trunked tree of the following species: Blue Gum, Black Acacia, Myoporum, Sweetgum, Glossy Privet or Lombardy Poplar with a circumference of seventy-five inches dbh; or any upright, singletrunked tree considered to be a heritage tree species, with a circumference of thirty inches or more when measured at fifty-four inches dbh. A heritage tree means any of the following: California Bay, Oak, Cedar, California Buckeye, Catalina Ironwood, Strawberry Tree, Mayten or Little Gem Dwarf Southern Magnolia.

2. Pursuant to any such permit, replacement trees will be determined as set forth in SSFMC Section

13.30.080. Replacement of a protected tree can be waived by the director if a sufficient number of trees exist on the property to meet all other requirements of the tree preservation ordinance. If replacement trees cannot be planted on the property, payment of the replacement value of the tree will be made to the city.

Conclusion: Consistent with the findings of the SSF 2040 General Plan EIR, the Project would be required to obtain a Tree Removal permit for removal of any tree on public property, and for removal of any other protected trees on the site. If the City approves that Tree Removal permit, the Project will be required to provide replacement tree plantings and/or in lieu fees. These Tree permit requirements would achieve compliance with local policies or ordinances protecting biological resources, would minimize impacts related to potential conflicts with local policies or ordinances protecting biological resources (Checklist item Bio-e) to a level of less than significant, and no additional mitigation is required. f) Conflict with HCP or Natural Community Conservation Plans SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Section 7.2.3) determined that new development pursuant to the General Plan would not conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan or other approved local, regional, or State Habitat Conservation Plan.36 South San Francisco contains two areas set aside as habitat for the conservation of threatened and endangered species; Sign Hill Park and San Bruno Mountain State Park, the latter of which is governed by the San Bruno Mountain HCP and the San Bruno Mountain HMP. The BCDC has jurisdiction over all areas of San Francisco Bay that are subject to tidal action and over an area 100 feet wide inland and parallel to the shoreline. Any subsequent development pursuant to the General Plan that is within or adjacent to Sign Hill Park, San Bruno Mountain State Park or adjacent to the San Francisco Bay would require a site-specific assessment of biological resources, and the City’s environmental review process would be utilized to impose appropriate mitigation measures. Future projects that border San Francisco Bay and lie within BCDC jurisdiction may require a permit and must comply with the requirements of the McAteer-Petris Act and the San Francisco Bay Plan. Therefore, The General Plan EIR concluded that potential conflicts San Bruno Mountain HCP, San Bruno Mountain HMP, and the San Francisco Bay Plan would be reduced to less than significant levels. There are no other local, regional or State HCPs that are applicable to South San Francisco. As such, implementation of the General Plan was found to not conflict with the provisions of an adopted HCP, Natural Community Conservation Plan, or other approved local, regional, or State HCP.
36 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact BIO-6, page 3.3-28 Vantage Master Plan Project – CEQA Analysis page 81
Project Analysis
The Project site is not located within or near Sign Hill Park, San Bruno Mountain State Park or adjacent to the San Francisco Bay.

Conclusion: Consistent with the findings of the SSF 2040 General Plan, the Project would not conflict with an adopted Habitat Conservation Plan or Natural Community Conservation Plan (Checklist item Bio-f).

CEQA Conclusion Pertaining to Biological Resources
Based on the analysis, findings and conclusions of the SSF 2040 General Plan EIR, implementation of the Project would not substantially increase the severity of any significant impacts to biological resources as identified in that prior EIR, nor would it result in new significant impacts related to biological resources that were not previously identified. The 2040 General Plan EIR did identify mitigation measures as regulatory requirements related to biology that would apply to the Project and have been incorporated into the Project design, and implementation of those mitigation measures and regulatory requirements would ensure the Project’s impacts to biological resources would remain less than significant. No further environmental review of the Project pertaining to the topics of biological resources is required.

Vantage Master Plan Project – CEQA Analysis page 82
Cultural Resources
Would the Project:

SSF 2040
General Plan
EIR Findings
Relationship to SSF 2040
General Plan EIR Findings: Project Conclusions:

Equal or
Less Severe
New or
Substantial
Increase in
Severity
Applicable Standards
and Regulations
Resulting
Level of
Significance
a) Cause a substantial adverse change in
the significance of a historic resource
pursuant to Section 15064.5
LTS  ☐ - No Impact
b) Cause a substantial adverse change in
the significance of an archaeological
resource pursuant to Section 15064.5
LTS  ☐
Project Requirement
Cultural-1: Discovery of
Archaeological
Resources
LTS with PR
c) Disturb any human remains, including
those interred outside of formal
cemeteries
LTS  ☐
Project Requirement
Cultural-2: Discovery of
Human Remains
LTS with PR
a) Historic Resource
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact CUL-1) determined that implementation of the General Plan would not cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5.37 The SSF 2040 General Plan Appendix D identifies those properties considered historic or potentially historic resources, which include:
• Two National Register of Historic Places (NRHP)-listed properties are located within the City of South San Francisco: the Martin Building located at 265 Grand Avenue (also known as the Metropolitan Hotel) and the South San Francisco Hillside Sign. These two properties are also the only resources listed on the California Register of Historic Places (CRHP).
• The City of South San Francisco recognizes 40 designated Historic Landmarks that are considered cultural resources under CEQA
• One historic district is situated within the City of South San Francisco, the Grand Avenue Commercial Historic District
• Four potential historic resources are situated within the City of South San Francisco. The potential historic resources include residential properties (located along Baden, Pine and Miller Avenues) and the South San Francisco/San Bruno Water Quality Control Plant. • Historic era buildings and structures, typically over 50 years in age, may be considered eligible for inclusion on the NRHP and CRHP. Those found eligible by survey or evaluation are considered historic resources under CEQA. Approximately 250 eligible historic architectural resources are located within the 37 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact CUl-1, page 3.4-32 Vantage Master Plan Project – CEQA Analysis page 83
City, the majority of which are not included within the City’s register, and include residential homes, commercial buildings, medical facilities, fraternal organizations, civic, educational, religious and transportation infrastructure.
• Evaluated resources determined to be ineligible for listing have been excluded. 38 The General Plan policies and actions specifically address the conservation and protection of historical resources, and SSFMC contains rules and regulations that protect historical resources. As the City receives development applications for subsequent development projects, those applications will be reviewed by the City for compliance with these policies regulations. Individual development projects that propose to alter a building or structure greater than 45 years of age at the time an application is deemed complete would be required to undergo project-specific environmental review to determine whether the building or structure may be a historic resource and take appropriate action such as requiring additional site-specific or project-specific measures to reduce any potential impacts. Therefore, future development Pursuant to the General Plan was determined to not result in significant adverse effects to historical resources.

Project Analysis
One existing industrial warehouse building occupies 440 Forbes Boulevard. A separate warehouse at 460 Forbes Boulevard was removed pursuant to the previously entitled Phase 1, and a third industrial warehouse that existed at 480 Forbes Boulevard was removed in 2006.

Only the one remaining warehouse at 440 Forbes Boulevard has not already been cleared for demolition.

According to historic maps of the area, this building was constructed in 1965, making it well over 50 years in age and therefore eligible for consideration as an historic structure. This building is not listed on the CRHP, is not a designated Historic Landmarks, is not located within the Grand Avenue Commercial Historic District, is not identified as a potential historic resource, and is not one of the 250 eligible historic architectural resources located within the City but that are not included within the City’s register. This building and its grounds appear to have been well maintained, but “this typical 1-story warehouse does not exhibit any features that would qualify it for inclusion on the California Register of Historical Resources or the local register of historical resources. It is evident that the 1965 warehouse building with its office wing and detached truck shop are a standard industrial building type, of typical design and construction, and are not the work of a notable engineer, so do not appear to have historical potential on those primary bases”. 39 It is also noted that the similar adjoining
warehouses at 460 and 490 Forbes Boulevard (which have already been removed) were of a similar date of construction, and similarly not found to be historic resources. A full Historic Resource Evaluation will be prepared to verify this conclusion prior to permitting demolition of this structure.

Conclusion: Consistent with the findings of the SSF 2040 General Plan EIR, the Project would not cause a substantial adverse change in the significance of a historic resource (Checklist item Cultural-a), and no mitigation is required.
b) Archaeological Resources
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact Cul-2) determined that implementation of the 2040 General Plan would not cause a substantial adverse change in the significance of an archaeological resource. Based on information 38 City of SSF, SSF 2040 General Plan EIR Appendix D: Cultural Resources-Tribal Cultural Resources Supporting Information,2022 39 Preservation Architecture, October 28, 2022
Vantage Master Plan Project – CEQA Analysis page 84
available at the NWIC, there are known archaeological resource sites located within South San Francisco such as at Terrabay and El Camino Real. Additionally, undiscovered archaeological sites could exist. The potential for archaeological sites to be present within the City varies by location. The waterfront and the areas around Colma Creek and San Bruno Creek have the greatest potential for buried prehistoric archaeological resources to be present.

The SSF 2040 General Plan EIR concluded that new development could affect known or previously unidentified archaeological resources, but compliance with General Plan policies and regulations of the Zoning Ordinance would ensure that future development projects are appropriately reviewed and designed in terms of potential impacts to archaeological resources. Based on the policies contained within the SSF 2040 General Plan, future development and land use activities contemplated by the 2040 General Plan were found to not have significant impacts on archaeological resources, this impact was found to be less than significant, and no additional mitigation was indicated as necessary.40
Project Analysis
Several cultural resource studies have been completed in immediate proximity to the Project site, including a 2020 cultural resource assessment for the 499 Forbes Boulevard project immediately across Forbes Boulevard from the Project site. This prior assessment included a records search of the California Historical Resources Information System (CHRIS). Based on the findings of that records search, “no archaeological resources have been identified within [that] project site. The results indicate the presence of one prehistoric resource within the project vicinity (located approximately 500 meters east). Given the prior development of [that} property and level of disturbance, there is relatively low potential for intact subsurface archaeological deposits to be encountered during construction. However, unanticipated discoveries during construction are possible.” 41 Several other recent cultural resource assessments conducted in the vicinity found no known cultural resources present in the area, but there remains at least a moderate potential for the inadvertent discovery of previously unrecorded historic‐period archaeological resources. The Project site is not located near the waterfront, Colma Creek or San Bruno Creek, where there is the greatest potential for buried prehistoric archaeological resources to be present.

Regulatory Requirements
The following regulatory requirement is incorporated into SSF 2040 General Plan policy, and applies to all development projects in SSF, specifically intended to address the potential for unanticipated discovery of archaeological resources:
❖ Project Requirement CUL-1, Discovery of Archaeological Resources: In accordance with California Public Resources Code Sections 21083.2 and 21084.1, if construction or grading activities result in the discovery of significant historic or prehistoric archaeological artifacts, then all work within 100 feet of the discovery shall cease, the Economic and Community Development Department shall be notified, and the resources shall be examined by a qualified archaeologist for appropriate protection and preservation measures. Work may only resume when appropriate protections are in place and the protections have been approved by the Economic and Community Development Department (see further discussion of tribal cultural resources in the Tribal Cultural Resource section of this CEQA Checklist).

Conclusion: In the unlikely event of discovery of cultural resources during construction, the Project would be required to comply with SSF General Plan policies and State law that addresses such an unanticipated circumstance, consistent with the requirements of the General Plan EIR. These policies and regulations ensure 40 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact CUL-2, page 3.4-34 41 Rincon Consultants, Inc., Cultural Resource Assessment for the 499 Forbes Boulevard Project, January 2020 Vantage Master Plan Project – CEQA Analysis page 85
that the Project’s construction does not cause a substantial adverse change in the significance of an archaeological resource (Checklist item Cultural-b), and no additional mitigation is required. c) Human Remains
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact CUL-3) determined that implementation of the 2040 General Plan could disturb human remains, including those interred outside of formal cemeteries. Excavation and construction may uncover human remains that may not be marked in formal burial locations. Under CEQA, human remains are protected under the definition of archaeological materials as being “any evidence of human activity”. 42 The General Plan EIR cites the section 7050.5 of the California Health and Safety Code as setting forth provisions related to the treatment of human remains, including the treatment of human remains found in locations other than a dedicated cemetery and the responsibilities of the Coroner. These requirements apply to all construction projects. The General Plan also includes policies and actions intended to conserve and reduce impacts to archaeological resources, including human remains. Implementation of policies and actions in the General Plan, as well as compliance with adopted State, federal and local regulations for the protection of human remains would ensure that future development would not result in significant adverse effects to human remains.

Therefore, this impact was determined to be less than significant.

Project Analysis
There are no known human remains buried at the Project site, but the potential for such a discovery is possible during construction and ground-disturbing activities.

Regulatory Requirements
The following regulatory requirement is incorporated into SSF 2040 General Plan policy, and applies to all development projects in SSF, specifically intended to address the potential for unanticipated discovery of archaeological resources:
❖ Project Requirement CUL-2, Discovery of Human Remains: In accordance with California Health and Safety Code and General Plan policy, if construction or grading activities result in the discovery of human remains, then all work within 100 feet of the discovery shall cease, the County Coroner shall be notified by the project applicant, and appropriate action shall be taken by the project applicant in coordination with the Native American Heritage Commission, in accordance with section 7050.5 of the California Health and Safety Code or, if the remains are Native American, Section 5097.98 of the California Public Resources Code (see further discussion of tribal cultural resources in the Tribal Cultural Resource section of this CEQA Checklist).

Conclusion: In the unlikely event of discovery of human remains during construction, the Project would be required to comply with State law that addresses such an unanticipated circumstance. Consistent with the conclusions of the General Plan EIR, these State regulations will ensure that the Project’s construction does not disturb human remains, including those interred outside of formal cemeteries (Checklist item Cultural-c) , and no additional mitigation is required.
42 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact CUL-3, page 3.4-36 Vantage Master Plan Project – CEQA Analysis page 86
CEQA Conclusions Pertaining to Cultural Resources
Based on the analysis, findings and conclusions of the prior SSF 2040 General Plan EIR, implementation of the Project would not substantially increase the severity of any significant impacts to cultural resources as identified in that Program EIR, nor would it result in new significant impacts to cultural resources that were not previously identified. The prior Program EIR did not identify any additional mitigation measures related to cultural resources that would apply to the Project, and none would be needed.

Vantage Master Plan Project – CEQA Analysis page 87
Energy
Would the Project:

SSF 2040
General Plan
EIR Findings
Relationship to SSF 2040
General Plan EIR Findings: Project Conclusions:

Equal or
Less Severe
New or
Substantial
Increase in
Severity
Applicable Standards
and Requirements
Resulting
Level of
Significance
a) Result in potentially significant
environmental impacts due to wasteful,
inefficient or unnecessary consumption of
energy resources, during project
construction or operation
LTS  ☐ Project Requirement
Energy-1: CALGreen
Building Energy
Efficiency Standards
Project Requirement
Transportation-1: Tier 4
TDM Plan
LTS with PR
b) Conflict with or obstruct a state or local
plan for renewable energy or energy
efficiency
LTS  ☐ - LTS
a) Energy Resources
SSF 2040 General Plan EIR
The SS 2040 General Plan EIR (Impact ENER-1) found that new development pursuant to the General Plan would not result in potentially significant environmental impacts due to wasteful, inefficient or unnecessary consumption of energy resources, during project construction or operation. However, subsequent development pursuant to the General Plan would result in the consumption of energy resources during both construction and operation. 43
Construction
The General Plan EIR found that construction activities associated with individual development projects would consume energy in the form of petroleum fuel for heavy equipment, as well as from worker trips and material delivery trips to the construction sites. Temporary electrical grid power may also be provided to construction sites. The General Plan EIR concluded that future construction would be required to comply with requirements of the South San Francisco Municipal Code and General Plan policies and actions that directly and indirectly reduce energy consumption during construction. Future construction would also be required to comply with the California Code of Regulations that limit idling from both on-road and off-road diesel-powered equipment. As such, construction activities were not found to result in wasteful, inefficient or unnecessary consumption of energy, and this impact was found to be less than significant.

Operations
The General Plan EIR found that new development would consume natural gas and electricity for building heating and power, lighting, and water conveyance, among other operational requirements. Indirect energy use would include the pumping, treatment and conveyance of water for buildings and landscaping. The electrical 43 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact ENER-1, page 3.5-17 Vantage Master Plan Project – CEQA Analysis page 88
consumption and natural gas use associated new development pursuant to the General Plan was found to result in a net increase in consumption of 237.3 million kWh of electricity per year and 392.6 million kBTU of natural gas per year. These electricity and natural gas consumption rates account for 2019 California Building Code standards, which require a variety of energy efficiency measures to be implemented during construction of nonresidential structures that will reduce energy use and air emissions. The General Plan EIR anticipates that future development within the City will be designed and built to minimize electricity and natural gas use. Moreover, all new developments in the City will be required to meet State and SSFMC energy efficiency regulations.

The SSF 2040 General Plan EIR concluded that with compliance with General Plan and Climate Action Plan policies, adherence to SSFMC development standards and state regulations, new development pursuant to the General Plan would not result in wasteful, inefficient or unnecessary consumption of energy. These policies and actions would minimize demands for energy resources and ensure their efficient use. Furthermore, the General Plan minimizes petroleum use for transportation, and implementation of Transportation Demand Management and parking requirements would reduce VMT.

The General Plan EIR concluded that new development would be designed, built and operated to minimize energy consumption, and would ensure that building energy consumption would not be wasteful, inefficient or unnecessary, and that this impact would be less than significant.

Project Analysis
Buildings pursuant to Phase 1 have already been reviewed, approved and are under construction, having previously demonstrated compliance with applicable CALGreen standards and SSFMC requirements.

None of the individual buildings pursuant to Phase 2 or Phase 3 (the Project) has been designed at a level of detail necessary to accurately identify CALGreen compliance. However, estimates have been prepared for a Title 24 “baseline” for each building, representing expected energy use (expressed as million BTUs/year, or MBtu) for each Phase 2 and Phase 3 building, based on current 2019 CALGreen standards. Estimates have also been prepared for each building’s expected energy performance based on preliminary designs and regulatory/policy compliance (see Appendix D). The anticipated energy demands of each new building pursuant to Phase 2 and Phase 3 of the Project are based on the following Project assumptions and/or requirements:
• At a minimum, each new building will be required to demonstrate compliance with the CALGreen Building Energy Efficiency Standards.
44 • The Project’s proposed new buildings are expected to exceed the current (2019) CALGreen Building Energy Efficiency Standards by about 4 percent. This additional energy savings is attributable to the selection of high-efficiency HVAC equipment, and façade design measures that have been demonstrated to meet or slightly exceed CALGreen energy performance requirements. • Consistent with the provisions of the SSF 2022 CAP Action BNC 2.1, the Project commits to either: 1) complying with all-electric reach codes for non-residential buildings, or 2) construction and operation of all Phase 2 and 3 buildings such that they comply with CALGreen Tier 2 energy efficiency requirements and exceed mandatory energy efficiency requirements by 20 percent or more, if required. Consistent with 2022 CAP requirement, all new buildings pursuant to Phases 2 and 3 of the Project can accommodate PV panels on their rooftops (assumed at 30% roof cover), and additional PV arrays can be installed on the rooftops of each parking structure in an amount necessary to achieve compliance with 44 At the time the Project application was filed, and at the time of preparation of this Initial Study/CEQA Checklist, neither CalGreen nor the City of SSF require that non-residential buildings be all-electric. Accordingly, the Project’s HVAC system has been proposed as a natural gas-powered system.

Vantage Master Plan Project – CEQA Analysis page 89
the policy requirements of the SSF 2022 CAP. The demonstration of each building’s actual CALGreen Tier 2 energy efficiencies will be provided at the time of building permit application for each new building. • Consistent with SSF 2022 CAP polices, the fire station (as a municipal building) is expected to be an allelectric building (i.e., no natural gas service), and achieve additional energy efficiencies with installation of PV panels capable of providing at least 20 percent of the fire station’s energy demands.

The energy demands of the Project, as calculated for each building under three scenarios (i.e., 1) meeting Title 24 “baseline” energy efficiency requirements, 2) exceeding Title 24 standards based on expected building design efficiencies, and 3) potentially offsetting each building’s electrical demands by adding solar-power PV panels), is shown below in Table 11.

Vantage Master Plan Project – CEQA Analysis page 90
Table 11: Project’s Building Energy Demands (MMBtu)
Building (sf) Title 24 “Baseline” Project Design
Efficiencies
Project Design, with
Solar
Building C 440,000
Electricity 17,224 15,153 11,209
Natural Gas 31,297 31,406 31,406
Total: 48,522 46,559 42,615
Building D 249,000
Electricity 9,745 8,578 6,343
Natural Gas 17,712 17,773 17,773
Total: 27,457 26,351 24,116
Building E 283,000
Electricity 11,078 9,746 7,206
Natural Gas 20,130 20,200 20,200
Total: 31,208 29,946 27,405
Building F 316,582
Electricity 12,393 10,903 8,061
Natural Gas 22,518 22,596 22,596
Total: 34,912 33,499 30,657
Fire Station 9,000 (All Electric)
Electricity 317 508 430
Natural Gas 640 0 0
Total: 957 508 430
Total, Project 1,297,582
Electricity 50,441 44,889 33,248
Natural Gas 91,657 91,974 91,975
Total: 142,098 136,863 (-4%) 125,223 (-12%)
Source: Meyers + Engineers, November 2022
Time Dependent Valuation
The 2019 California Title 24 Building Energy Efficiency Standards (CALGreen) use a Time Dependent Valuation (TDV) methodology for building energy load calculations to account for the time value of energy. The concept of TDV holds the total cost of energy constant at forecasted retail price levels but gives more weight to on‐peak hours and less weight to off‐peak hours. This means that energy efficiency measures that perform better on‐ peak will be valued more highly than measures that do not. TDV energy is calculated by multiplying the site energy use (either electricity or natural gas) for each energy type, times the applicable TDV multiplier. TDV multipliers vary for each hour of the year and by energy type (electricity, natural gas or propane), by Climate Zone, and by building type.

Vantage Master Plan Project – CEQA Analysis page 91
Table 12: Project’s Expected Building Performance vs 2019 CalGreen Time Dependent Valuation Standards for Energy Efficiency (TDV – MBtu)
Building Building Size (GSF)
CalGreen) “Baseline” TDV Energy
Use (MBTU/yr)
Projected TDV Building Energy Use
(MBYU/yr)
Building C 440,000 147,200 140,700
Building D 249,000 83,300 79,600
Building E 283,000 84,700 80,900
Building F 316,582 126,800 121,200
Fire Station 9,600 1,640 1,400
Total: 1,298,182 443,640 423,640
Source: Meyers + Engineers, November 2022
As Table 12 demonstrates, the Project’s proposed new buildings are expected to meet and exceed the 2019 CALGreen Time Dependent Valuation building energy efficiency standards by about 5 percent. By adhering to CALGreen and SSFMC energy efficiency requirements, the Project’s new building space would not result in wasteful, inefficient or unnecessary consumption of energy.

Additionally, the Project’s compliance with General Plan and SSFMC requirements to implement a TDM plan that achieves a 50 percent reduction in single-occupant vehicle will lower overall Project-generated VMT and minimize petroleum used for transportation.

Regulatory Requirements
As cited in the SSF 2040 General Plan EIR, and consistent with SSFMC requirements, the following regulatory requirements are applicable to the Project:
❖ Project Requirement Energy-1: CALGreen Building Energy Efficiency Standards: Per SFFMC Section

15.26.010, the California Energy Code, 2019 Edition was adopted by reference. Whereas SSFMC Amendments to CALGreen provide that newly constructed residential buildings shall be an all-electric building, Exception #3 of SSFMC allows that newly constructed non-residential buildings and all nonresidential occupancies in a mixed-use building shall be exempt from the all-electric requirements. ❖ Project Requirement Transportation-1: Tier 4 TDM Plan: (see details in the Transportation section of this Initial Study)
Conclusion: Consistent with the findings of the SSF 2040 General Plan EIR, the Project would be required to comply with CALGreen Building Energy Efficiency Standards as applicable at the time of building permit application and would be required to achieve Tier 4 TDM performance for a 50 percent reduction in commuter single-occupant vehicle use. These regulatory requirements would achieve compliance with local policies and ordinances pertaining to energy use and would substantially lower overall energy demand of the Project such that the Project would not result in wasteful, inefficient or unnecessary consumption of energy (Checklist item Energy-a). The Project’s impacts related to energy use would be less than significant and no additional mitigation is required.

Vantage Master Plan Project – CEQA Analysis page 92
b) Energy Efficiency and Renewable Energy Standards Consistency SSF 2040 General Plan EIR
The SS 2040 General Plan EIR (Impact ENER-2) found that the General Plan would not conflict with or obstruct a State or local plan for renewable energy or energy efficiency. The General Plan EIR concluded that compliance with the SSF 2022 CAP, General Plan policies and development standards of SSFMC would ensure that new development pursuant to the General Plan would not conflict with or obstruct State or local plans for renewable energy or energy efficiency, and implementation of the General Plan would result in a less than significant impact.45
Project Analysis
Whereas the General Plan and the SSF 2022 CAP were previously found to be consistent with State and local plans for renewable energy or energy efficiency, and the Project is consistent with the General Plan and SSFMC (see Project’s Consistency with the General Plan and Zoning) and is also consistent with the SSF 2022 CAP (see the GHG section of this CEQA Checklist), the Project is also consistent with State and local plans for renewable energy or energy efficiency.

Conclusion: Consistent with the General Plan EIR, the Project would not conflict with or obstruct a State or local plan for renewable energy or energy efficiency (Checklist item Energy-b), and this impact is less than significant.

CEQA Conclusions Pertaining to Energy
Based on the analysis, findings and conclusions of the prior SSF 2040 General Plan EIR, implementation of the Project would not substantially increase the severity of any significant impacts related to energy use as identified in that Program EIR, nor would it result in new significant impacts related to energy use that were not previously identified. The prior Program EIR did not identify any additional mitigation measures related to energy that would apply to the Project, and none would be needed. 45 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact ENER-2, page 3.5-22 Vantage Master Plan Project – CEQA Analysis page 93
Geology
Would the Project:

SSF 2040
General Plan
EIR Findings
Relationship to SSF 2040
General Plan EIR Findings: Project Conclusions:

Equal or
Less Severe
New or
Substantial
Increase in
Severity
Applicable Standards
and Requirements
Resulting
Level of
Significance
a) Directly or indirectly cause potential
substantial adverse effects, including the
risk of loss, injury or death, involving:
i. Rupture of a known earthquake fault, as
delineated on the most recent AlquistPriolo Earthquake Fault Zoning map issued by the State Geologist for the area or
based on other substantial evidence of a
known fault
ii. Strong seismic ground shaking
iii. seismic-related ground failure, including
liquefaction
iv. Landslides
LTS  ☐ Project Requirement
GEO-1, California Seismic
Building Standards
LTS w/ PR
b) Result in substantial soil erosion or the
loss of topsoil?
LTS  ☐
Project Requirement
GEO-2, Erosion Control
LTS w/ PR
c) be located on a geologic unit or soil that
is unstable, or that would become
unstable as a result of the project and
potentially result in on- or off-site
landslide, lateral spreading, subsidence ,
liquefaction or collapse?
LTS  ☐
Project Requirement
Geo-3, Foundations
LTS w/ PR
d) Be located on expansive soil as defined
in Table 18-1-B of the Uniform Building
Code (1994), or other soils conditions
creating substantial direct or indirect risks
to life or property?
LTS  ☐ Project Requirement
Geo-4, California
Building Standards Code
- Adverse Soil Conditions
Project Requirement
GEO-5, Asbestos
Airborne Toxic Control
Measures (Fire Station
Site)
LTS w/ PR
e) Have soils that are incapable of
adequately supporting the use of septic
tanks or alternative wastewater disposal
systems where sewers are not available
for the disposal of wastewater?
 ☐ - No Impact
f) Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?
 ☐ GP EIR Mitigation
Measure GEO-6,
Paleontological
Monitoring
LTS with PR
Vantage Master Plan Project – CEQA Analysis page 94
Information related to the Project and the Project site as included in the following Geology section of this CEQA Checklist has been derived from the following primary sources:
• Langan Engineering and Environmental Services, Inc., Preliminary Geotechnical Site Assessment, Gallo Site, October 27, 2020 (Appendix E)
• Langan Engineering and Environmental Services, Inc., Geotechnical Investigation for Vantage Phases 2 and 3, October 17, 2022 (Appendix F), and
• Langan Engineering and Environmental Services, Inc., Preliminary Geotechnical Conclusions and Recommendations for Vantage Phase 2 – Fire Station, October 17, 2022 (Appendix G) The Langan 2020 site assessment presents a preliminary geotechnical site assessment for the Project site for purposes of due diligence and development of preliminary conclusions and recommendations regarding geotechnical aspects of the site.

The Langan October 17, 2022, Geotechnical Investigation report presents the results of more detailed field explorations to supplement the available subsurface information, with engineering analyses to develop conclusions and recommendations regarding:
• soil, bedrock, and groundwater conditions at the site • seismic hazards, including ground rupture, liquefaction, and differential compaction, • the most appropriate foundation type(s) for the proposed structure, • design criteria for the most appropriate foundation type(s), including values for vertical and lateral capacities,
• estimated foundation and surrounding ground surface settlement, • 2019 California Building Code (CBC) site classification, mapped values SS and S1, modification factors Fa and Fv and SMS and SM1,
• floor slabs,
• site preparation, grading, and excavation, including criteria for fill quality and compaction, • soil corrosivity with brief evaluation,
• flexible pavement design, and
• construction considerations
The Langan October 17, 2022, Preliminary Fire Station report provides preliminary geotechnical conclusions and recommendations specific to the proposed Public Benefit/Fire Station Site that is part of the Vantage Master Plan’s Community Benefit proposal.
a) Seismic Hazards
SSF 2040 General Plan EIR
The SSF 2040 General Plan EIR (Impact GEO-1) found that new development pursuant to the SSF2040 General Plan would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury or death involving rupture of a known earthquake fault, strong seismic ground shaking, or seismic-related Vantage Master Plan Project – CEQA Analysis page 95
ground failure including liquefaction and landslides.46 Given the City’s proximity to the San Andreas Fault Zone as well as other active faults, the General Plan EIR found it likely that the city would experience periodic minor to strong earthquake motion. Residents and employees would potentially be exposed to the effects of surface fault rupture, seismic ground shaking, liquefaction, settlement and landslides from local and regional earthquakes.

Structures built on steep slopes could be exposed to the risk of landslide, and new structures could exacerbate existing landslide conditions. New structures and other improvements could also experience substantial damage during seismic events.

The General Plan EIR cites policies and actions included in the General Plan, as well as regulations of the South San Francisco Municipal Code and Zoning Ordinance that address potential impacts related to surface fault rupture, seismic shaking, seismic-related ground failure and landslides. Future projects would be required to conduct an environmental analysis and the City would determine which policies sections of the Municipal Code and Zoning Ordinance apply, depending on the specific characteristics of the project type and/or project site.

The General Plan EIR concluded that compliance with local codes, mandatory California Building Code (CBC) requirements, and implementation of General Plan policies would ensure that future development projects are appropriately investigated for potential seismic hazards, and that any new buildings and structures are constructed to withstand the anticipated range of seismic events. Individual development projects would be required to undergo project-specific environmental review, which may require additional site-specific or projectspecific measures to reduce any potential for loss, injury or death in the event of a seismic event. As such, the General Plan EIR found this impact to be less than significant.

Project Analysis
The Project site is located in a seismically active region. Numerous earthquakes have been recorded in the region in the past, and moderate to large earthquakes should be anticipated during the service life of the Project. The San Andreas and San Gregorio faults are the major faults closest to the site. The following information pertaining to seismic hazards at the Project site (including the fire station site) is derived from the Langan Geotechnical Investigation reports of October 2022.47 Fault Rupture
Historically, ground surface ruptures closely follow the trace of geologically young faults. The Project site (including the fire station site) is not within an Earthquake Fault Zone as defined by the Alquist-Priolo Earthquake Fault Zoning Act, and no known active or potentially active faults exist on the site. The Hillside Fault appears to have been mapped as crossing the previously entitled Phase 1 development area. The Hillside Fault is an inactive fault, with the latest activity occurring at least 1.8 million years ago. Langan concludes the risk of fault offset through the site from a known active fault is low.

Ground Shaking
During a major earthquake on one of the active faults in the general region, the Project site will experience very strong to violent ground shaking similar to other areas of the seismically active San Francisco Bay Region. The intensity of the earthquake ground motion at the site will depend upon the characteristics of the generating fault, distance to the earthquake epicenter, magnitude and duration of the earthquake, and site-specific geologic conditions. During its history, the site has been subjected to strong ground shaking from moderate to 46 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact GEO-1, page 3.6-17 47 Langan, Geotechnical Investigation Vantage Phases 2 and 3, 17 October 2022; and Langan, Preliminary Geotechnical Recommendations – Fire Station, 17 October 2022
Vantage Master Plan Project – CEQA Analysis page 96
large earthquakes on the San Andreas, Hayward, Monte Vista-Shannon and the San Gregorio faults. A major earthquake on one of the nearby faults could again produce strong to very strong shaking at the site.

Seismically Induced Liquefaction
Strong shaking during an earthquake can result in ground failure such as that associated with soil liquefaction.

When saturated soil with little to no cohesion liquefies during a major earthquake, it experiences a temporary loss of shear strength. Flow failure, lateral spreading, differential settlement, loss of bearing, ground fissures, and sand boils are evidence of excess pore pressure generation and liquefaction. The Project site is not within a zone designated as having the potential for liquefaction. Specifically, the map shows the Project site is outside the area “where historic occurrence of liquefaction, or local geological, geotechnical and groundwater conditions indicate a potential for permanent ground displacements such that mitigation as defined in Public Resources Code Section 2693 would be required.” 48
• Langan used the results of soil borings performed on the site to evaluate the potential of these phenomena occurring at the Phase 2 and Phase 3 portions of the site. The subsurface data indicates the sand layers encountered below the groundwater level have generally sufficient cohesion or relative density to resist liquefaction. Therefore, Langan concludes the potential for liquefaction and lateral spreading on these portions of the site to be low.
• At the Public Benefit/Fire Station Site, Langan found that bedrock is shallow, and the overlying fill is above groundwater, and judges the liquefaction potential at the proposed fire station location to be low.

Seismically Induced Densification
Langan analyzed the seismic densification of non-saturated, cohesion-less soil following a major earthquake. • Borings at the Phase 2 and 3 portions of the site indicate that the materials above the water table may be susceptible to seismic densification. Langan conclude that the soil in the upper five feet above the groundwater table could potentially densify during a major earthquake, and settlements due to seismic densification of up to ½ inch could occur in the fill.
• At the proposed fire station location, soil borings indicate the top of bedrock is at approximately 2½ to 4 feet below ground surface (bgs). The fill above the bedrock is sufficiently dense and/or clayey.

Therefore, Langan judges the potential for seismic densification settlement during a major earthquake at the fire station site as low.

Required Regulations, Policies and Standards
The following regulatory requirements apply to all new development within SSF and the State of California, specifically intended to address California’s earthquake and seismic hazards:
❖ Project Requirement GEO-1, California Seismic Building Standards: SSFMC Chapter 15.08 adopts the California Building Standards Code by reference. Building permit issuance would be based upon satisfactory completion of any identified applicable measures. The Project is therefore subject to those seismic safety requirements as set forth in the California Building Standards Code, and the Project shall be designed and constructed pursuant to those building standards.
48 California Geological Survey, Earthquake Zones of Required Investigation, San Francisco South Quadrangle, 2021 Vantage Master Plan Project – CEQA Analysis page 97
Project Recommendations Pursuant to Regulatory Requirements For seismic design of Phases 2 and 3 of the Project, Langan recommends the following seismic design parameters in accordance with the provisions of 2019/2022 California Building Code:
• Risk-Targeted Maximum Considered Earthquake (MCER) Ss and S1 of 1.841g and 0.754g, respectively • Site Class C, should be confirmed with shear wave velocity measurements from MASW survey as part of the addendum to the design geotechnical investigation report • Site Coefficients FA and FV of 1.2 and 1.4
• Maximum Considered Earthquake (MCE) spectral response acceleration parameters at short periods, SMS, and at one-second period, SM1, of 2.209g and 1.055g, respectively, and • Design Earthquake (DE) spectral response acceleration parameters at short period, SDS, and at onesecond period, SD1, of 1.473g and 0.704g, respectively49 For seismic design of the fire station, Langan recommends the following seismic design parameters in accordance with the provisions of 2019/2022 California Building Code:
• Risk-Targeted Maximum Considered Earthquake (MCER) Ss and S1 of 1.841g and 0.754g, respectively • Site Class B, should be confirmed with shear wave velocity measurements from MASW survey as part of the addendum to the design geotechnical investigation report for Vantage Phase 2 and 3 • Site Coefficients FA and FV of 0.9 and 0.8
• Maximum Considered Earthquake (MCE) spectral response acceleration parameters at short periods, SMS, and at one-second period, SM1, of 1.657g and 0.603g, respectively • Design Earthquake (DE) spectral response acceleration parameters at short period, SDS, and at onesecond period, SD1, of 1.105g and 0.402g, respectively Conclusion: Consistent with the findings of the SSF 2040 General Plan EIR, full compliance with the CBC regulations and building standards, with site-specific recommendation as provided by the geotechnical engineer, will reduce the effects of strong ground shaking in the event of a likely earthquake scenario (Checklist item Geology-a) to levels considered acceptable by professional engineers, and therefore considered under CEQA to be less than significant. No additional mitigation is required. b) Soil Erosion
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact GEO-2) found that future development pursuant to the General Plan would not result in substantial soil erosion or the loss of topsoil. Future development would involve construction activities such as stockpiling, grading, excavation, paving and other earth-disturbing activities. Loose and disturbed soils are more prone to erosion and loss of topsoil by wind and water. As such, soil erosion is dependent on individual site locations and conditions on-site during construction. 50 The General Plan EIR cited compliance with NPDES General Construction Permit requirements, General Plan policies and actions, and South San Francisco Municipal Code and Zoning Ordinance regulations that all address 49 Langan, Geotechnical Investigation October 2022, page 19 50 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact GEO-2, page 3.6-23 Vantage Master Plan Project – CEQA Analysis page 98
means for minimizing soil erosion and the loss of topsoil. With implementation of these permit requirements, policies and regulations, potential impacts related to soil erosion and loss of topsoil were found to be reduced to less than significant levels.

Project Analysis
New Project development could potentially generate soil erosion, primarily from site preparation activities.

Vegetation removal in landscaped areas could reduce soil cohesion and remove buffers from wind, water and surface disturbance, potentially rendering exposed soils susceptible to erosive forces. Excavation or grading may result in erosion as bare soil becomes exposed. Construction-period earth-disturbing work would be temporary, and erosion effects would depend largely on the length of time soil is subject to conditions that would be affected by erosion processes.

After construction is complete, substantial erosion is unlikely to occur, and is not considered significant.

Regulatory Requirements
The following regulatory requirements apply to all new development within SSF, specifically intended to address the adverse effects of erosion:
❖ Project Requirement GEO-2, Erosion Control: Pursuant to SSFMC Chapter 14.04.180(d), the Project shall implement year-round effective erosion control, run-on and runoff control, sediment control, active treatment systems (as appropriate), good site management, and non-stormwater management through each subsequent phase of construction (including, but not limited to, site grading, building and finishing of lots) until the site is stabilized by landscaping or the installation of permanent erosion control measures.

The Project will also be subject to the following additional regulatory requirements that also address erosionrelated concerns:
• California Building Code, Chapter 18, which regulates excavation activities and the construction of foundations and retaining walls, and CBC Chapter 33, which regulates grading activities, including drainage and erosion control
• Bay Area Air Quality Management District Rules regarding fugitive dust, which require stabilizing soils to prevent erosion through the reduction of dust generation • As more specifically cited in the Hydrology section of this CEQA Checklist, the Project will be required to comply with all regulatory provisions of the Municipal Regional Permit (MRP), including filing a Notice of Intent for permit coverage under the Construction General Permit, and preparation of a Stormwater Pollution Prevention Plan (SWPPP)
Conclusion: Consistent with the conclusions of the SSF 2040 General Plan EIR, the Project’s effects related to erosion during construction (Checklist item Geology-b) will be fully addressed through implementation of existing regulations, and this impact would be reduced to less than significant. c) Unstable Geologic Unit
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact GEO-3) found that future development pursuant to the General Plan would not be located on a geologic unit or soil that is unstable or that would become unstable as a result of new Vantage Master Plan Project – CEQA Analysis page 99
development, and as such would not result in settlement, an on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse.51
The General Plan EIR did find that certain geologic units present in the City could have the potential for landslides, slope instability, rock falls, liquefaction, settlement and liquefaction-induced lateral spreading. Other geologic hazards, such as subsidence or collapse, are also present. As such, development allowed under the General Plan could occur within areas containing unstable geologic units or be located on soils that are unstable or could become unstable from such development. However, the General Plan EIR cites compliance with the California Standards Building Code, and the regulations of SSFMC and Zoning Ordinance as including policies and regulations specifically designed to protect individuals from injuries and minimize property damage resulting from development on unstable geologic units or unstable soils by limiting development in certain areas and requiring increased review and mitigation where appropriate.

Future projects located within areas containing unstable geologic units or unstable soils would be required to conduct an environmental analysis at the time a specific project is defined, including preparation of site-specific soils and geologic reports for review and approval by the City Engineer, and incorporation of the recommended actions during construction. With implementation of the policies and actions of the General Plan, as well as applicable State and local codes, potential impacts associated with development on unstable geologic units or unstable soils would be less than significant.

Project Analysis
The Project site is generally flat with no slopes that may be susceptible to landslides, or where landslide potential may be exacerbated by new development.

The subsurface information presented by Langan indicates the Phase 2 and Phase 3 portions of the site are blanketed by sandy fill which is underlain by medium dense to very dense native sand and stiff to very stiff clay.

In the northwest corner of the site at the location of the fire station, about 4 feet of sandy fill is underlain by shallow bedrock. These conditions do not represent an unstable geologic unit or unstable soils but may have implications related to differential settlement.

Required Regulations, Policies and Standards
The following regulatory requirement applies to all new construction activity within California and is incorporated by reference into SSFMC, specifically intended to address building foundation design to protect against differential settlement:
❖ Project Requirement Geo-3, Foundations: CBC Section 1808A.2, foundations shall be so designed that the allowable bearing capacity of the soil is not exceeded, and that differential settlement is minimized. The enforcing agency may require an analysis of foundation elements to determine subgrade deformation in order to evaluate the effects on the superstructure.

Project Recommendations Pursuant to Regulatory Requirements According to the Langan 2022 report, the most economical foundation system for structures at the Phase 2 and Phase 3 portions of the site are shallow foundation systems consisting of spread footings gaining support in the native medium dense to very dense sand and stiff to very stiff clay or bedrock beneath the fill. If the foundation and building loads are not sufficient to resist the seismic uplift loads, tie-down anchors may be used. The Phase 2 and Phase 3 structures may be supported on individual spread footings and/or continuous strip footings bearing on native soil or bedrock. Continuous footings should be at least 18 inches wide and isolated spread 51 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact GEO-3, page 3.6-24 Vantage Master Plan Project – CEQA Analysis page 100
footings should be at least 24 inches wide. Footings should extend at least 18 inches below the lowest adjacent soil subgrade and through fill. Borings indicate the fill extends to a depth of about 4 to 5 feet across most of the site. Where fill is encountered, the footing excavations should be deepened to bear on native soil or bedrock.

Therefore, most footing excavations should extend at least five feet bgs with at least one foot into native soil or bedrock; if bedrock is encountered at shallower depth the footings excavations may be reduced. The final depth of the footing excavations will need to be determined by the geotechnical engineer of record during construction.

At the Public Benefit/Fire Station site, Langan preliminarily concludes that the fire station can be supported on a shallow foundation system such as isolated and continuous footings gaining support in the bedrock beneath the fill. If the foundation and building loads are not sufficient to resist the seismic uplift loads, tie-down anchors may be used. Where fill is encountered, the footing excavations should be deepened to bear on bedrock, which is estimated to be about 4 feet. The over-excavations can be backfilled with lean or structural concrete to the base of the footings. The bottom of the footings should be embedded at least 18 inches below the lowest adjacent soil subgrade and should be at least 18 inches wide for continuous footings and 24 inches for isolated spread footings.

Conclusion: Consistent with the findings of the SSF General Plan EIR, the Project would be required to comply with regulatory standards, including CBC requirements related to foundation support. Based on Langan’s preliminary geotechnical reports, foundation designs consistent with these regulatory standards would reduce the effects of potential soil settlement (Checklist Item Geology-c) to levels considered acceptable by professional engineers and therefore less than significant, and no additional mitigation is required. d) Expansive or Corrosive Soils, or Hazardous Geologic Conditions SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact GEO-4) found that future development pursuant to the General Plan would not be located on expansive soil that could create substantial direct or indirect risks to life or property.52 The General Plan EIR did find that new development constructed on expansive soils could be subject to damage or become unstable when underlying soil shrinks or swells. Expansive soils in the City are generally located within the Colma Formation which runs horizontally through the central portion of the City. Along the eastern perimeter of the City near San Francisco Bay is primarily artificial fill (artificial fill over tidal flats, alluvium, and slope debris and ravine fill) susceptible to damage from expansive soils. The General Plan EIR cited CBC and SSFMC requirements that address soil-related hazards such as expansive soils. Typical measures to treat hazardous soil conditions involve removal, proper fill selection, and compaction. In cases where soil remediation is not feasible, the CBC requires structural reinforcement of foundations to resist expansive soil forces.

The General Plan EIR concluded that compliance with the rules and regulations of SSFMC and Zoning Ordinance, including compliance with the CBC, and implementation of the policies and actions in the General Plan, would ensure that potential impacts related to expansive soils remain less than significant. 52 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact GEO-4, page 3.6-26 Vantage Master Plan Project – CEQA Analysis page 101
Project Analysis
Soils Conditions
Analysis of soil samples taken at the Phase 2 and Phase 3 sites was used to evaluate the potential of corrosion for buried metals and concrete. On the basis of resistivity test results, the soil samples were classified as moderately corrosive-to-corrosive to buried steel.

Serpentine / Naturally Occurring Asbestos
Langan indicates that bedrock below the proposed Public Benefit/Fire Station site consists of sandstone, shale and serpentinite, which sometimes contains naturally occurring asbestos (NOA). This geologic type of the Franciscan Complex bedrock was encountered beneath the existing fill on the Fire Station site, between approximately 2½ and 4 feet bgs. The results of asbestos testing of the bedrock indicated concentrations of asbestos ranging from 0.25 to 3 percent. The rock is intensely fractured to crushed, plastic to friable, deeply weathered, and has soft to moderately hard hardness. Bedrock generally becomes deeper to the south and east.

Naturally occurring asbestos may be encountered if bedrock is disturbed.

Required Regulations, Policies and Standards
The following regulatory requirements apply to all new construction activity, specifically intended to address expansive soils conditions:
❖ Project Requirement Geo-4, California Building Standards Code - Adverse Soil Conditions: The Project is subject to the soil engineering and foundation design requirements set forth in the California Building Standards Code, which recommends measures and practices to ensure that new structures are adequately supported and are not susceptible to the adverse effects of expansive soils.

Project Recommendations
Although not identified as a site with highly expansive soil types, the Langan Geotechnical report does include detailed recommendations to address corrosive soil. These recommendations include the following:
• All buried metallic pressure piping, such as ductile iron firewater pipelines, should be protected against corrosion.
• All other buried iron, steel, cast iron, ductile iron, galvanized steel, and dielectric coated steel or iron should be properly protected against corrosion, depending upon the critical nature of the structure. • To protect reinforcing steel from corrosion, adequate coverage should be provided as required by the building code.
• On-site fill should consist of soil that is non-corrosive, free of organic matter, and contains no rocks or lumps larger than three inches. Fil soil should have a liquid limit of less than 40 and plasticity index of less than 12 and be approved by the geotechnical engineer. Fill placed beneath asphalt pavements should have a minimum R-value of 9. Langan anticipates that most of the on-site soil meets the requirements for general fill.
❖ Project Requirement GEO-5, Asbestos Airborne Toxic Control Measures: Due to the presence of serpentine in the bedrock at the Public Benefit/Fire Station Site, this site and any portions of Phase 2 or Phase 3 development where serpentinite bedrock is present within the planned zone of excavation may be subject to the California Air Resource Board (CARB) Airborne Toxic Control Measure (ATCM), if construction activities call for disturbance to bedrock. The CARB Asbestos ATCM is enforced locally by the Bay Area Air Quality Management District (BAAQMD) and requires construction projects greater than one acre in size, in which naturally occurring asbestos, serpentine or ultramafic rock is present, to prepare a site-specific Asbestos Dust Monitoring Plan (ADMP) for agency approval.

Vantage Master Plan Project – CEQA Analysis page 102

1. The ADMP specifies dust mitigation measures and will determine those locations where dust mitigation must be initiated, at the start and maintained throughout the duration of the construction and grading activities where the Asbestos ATCM is applicable.

2. Asbestos dust mitigation will be implemented every day when construction and grading activities which disturb naturally occurring asbestos are performed. Naturally occurring asbestos disturbance during construction and grading activities include any disturbance of surface or stockpiles cat locations identified in the ADMP and that are conducted with powered equipment or any related activity including, but not limited to all surface and subsurface cuts and fills, excavation, material loading, trenching, stockpiling, auger drilling, bulldozing, and landfilling.

Conclusion: Consistent with the findings of the SSF General Plan EIR, the Project will be required to implement California Building Code (CBC) Standards. These CBC standards ensure that new structures are adequately supported and are not susceptible to the adverse effects of expansive or corrosive soils. Detailed recommendations have been identified and that apply specifically to corrosive soil conditions. These recommendations would further reduce the potential adverse effects of expansive soils (Checklist item Geologyd), and no additional mitigation measures are needed.

Additionally, excavation and grading activity at the fire station site, and any portions of Phase 2 or Phase 3 development where serpentinite bedrock is present within the planned zone of excavation will be required to comply with statewide Airborne Toxic Control Measures (ATCM), as enforced by the BAAQMD. e) Septic System Capability
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR found that future development pursuant to the General Plan would not be located on soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater. The General Plan encourages growth management and development location and timing to be planned in consideration of infrastructure capacity, public service availability, and fiscal impacts. As such, the General Plan EIR found that new development facilitated by the General Plan would be served by the existing sewer system, and most new development would connect to existing sewer lines. Should any new development require the installation of septic tanks or alternative wastewater disposal systems, the General Plan includes policies and actions to ensure that any new development can be feasibly constructed according to soil conditions. With implementation of policies and actions of the General Plan, as well as applicable local codes, new septic tanks or alternative wastewater disposal systems would be constructed on soils that can support such systems. Therefore, impacts would be less than significant.53
Project Analysis
The local sewer system would provide sewer service to the Project, and on-site wastewater treatment systems are not required or proposed at the site. Consistent with the findings of the SSF General Plan EIR, the Project would not have an adverse effect pertaining to septic system capabilities (checklist item Geology-e). 53 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact GEO-5, page 3.6-27 Vantage Master Plan Project – CEQA Analysis page 103
f) Paleontological Resources
SSF2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (GEO-6) identified that future development pursuant to the General Plan could directly or indirectly destroy a unique paleontological resource or site or unique geologic feature. Based on paleontological records, the potentially fossiliferous areas are the Merced Formation and the Colma Formation.

The Merced Formation is located along the western portion of the city and has a high sensitivity and a moderate potential for significant paleontological resources. The Colma Formation is located in the central portion of the city and in parts of East of 101 and has a high paleontological sensitivity and a low paleontological potential. As such, the General Plan EIR determined that construction-related and earth-disturbing actions within the Merced Formation and Colma Foundation have the potential to damage or destroy fossils resulting in significant impacts on paleontological resources. 54
The General Plan EIR identified Mitigation Measure GEO-6, which requires paleontological monitoring of all proposed excavations within the Merced Formation and Colma Formation. As such, with implementation of MM GEO-6, the General Plan EIR concluded that potential impacts to paleontological resources would be reduced to less than significant.

The General Plan EIR found that the remaining portions of the city have a low paleontological sensitivity and low paleontological potential, but in the unlikely event that any earth-disturbing construction-related activities uncover significant paleontological resources (e.g., bones, teeth, well-preserved plant elements), potential impacts to paleontological resources would be minimized through compliance with federal and State laws that protect paleontological resources.

Project Analysis
According to geologic maps presented in the General Plan EIR (see Figure 17), the Project site is located primarily within the Colma Formation (Cq), with the most northwesterly portion of the site (i.e., the Public Benefit/Fire Station site) being located on sheared rock (fsr). 54 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact GEO-6, page 3.6-28 Vantage Master Plan Project – CEQA Analysis page 104
Fig 17
Vantage Master Plan Project – CEQA Analysis page 105
Applicable Mitigation Measures
For those portions of Phase 2 and Phase 3 of the Project site that are located within the Colma Formation, the following mitigation measure of the SSF 2040 General Plan EIR applies:

Mitigation Measure GEO-6, Paleontological Monitoring: 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.

1. 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.

2. 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.

3. 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.

Conclusion: Consistent with the findings of the SSF 2040 General Plan EIR, the Project would be required to implement Mitigation Measure GEO-6 Building Code standards to ensure that excavations for new structures do not directly or indirectly destroy a unique paleontological resource (Checklist item Geology-f). With implementation of MM GEO-6, potential impacts to paleontological resources would be reduced to less than significant.

CEQA Conclusion Pertaining to Geology
Based on the analysis, findings and conclusions of the prior SSF 2040 General Plan EIR, implementation of the Project would not substantially increase the severity of any significant geologic or paleontological impacts identified in that prior EIR, nor would it result in new significant impacts related to geology that were not previously identified. The 2040 General Plan EIR identified one mitigation measure related to geology that would apply to the Project, and no other mitigation other than existing regulatory requirements would be needed. No further environmental review of the Project pertaining to the topics of geology is required.

Vantage Master Plan Project – CEQA Analysis page 106
Greenhouse Gas Emissions
Would the Project:

SSF 2040
General Plan
EIR Findings
Relationship to SSF 2040
General Plan EIR Findings: Project Conclusions:

Equal or
Less Severe
New or
Substantial
Increase in
Severity
Applicable Standards
and Requirements
Resulting
Level of
Significance
a) Generate greenhouse gas emissions,
either directly or indirectly, that may have
a significant impact on the environment
LTS  ☐ Project Description’s
consistency with SSF
2022 CAP Actions
LTS with PR
b) Conflict with an applicable plan, policy
or regulation adopted for the purpose of
reducing the emissions of greenhouse
gases
LTS  ☐ LTS
a) Greenhouse Gas Emissions
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (GHG-1) determined that future development pursuant to the General Plan would not generate greenhouse gas emissions that may have a significant impact on the environment.55 Construction Emissions
Pertaining to construction-period GHG emissions, the General Plan EIR found that future development would be required to comply with the requirements of SSFMC, the General Plan and General Plan EIR MM AIR-1a to reduce GHG emissions during construction. Future construction would also be required to comply with the California Code of Regulations that limit idling from both on-road and off-road diesel-powered equipment.

Accordingly, the General Plan EIR determined that future construction activities would not result in potentially significant impacts related to GHG emissions based on compliance with identified mitigation and compliance with policies and regulations, and this impact was found to be less than significant with incorporation of mitigation via MM AIR-1a.

Operational Emissions
The General Plan EIR identified that long term operational sources of GHG emissions would include mobile sources (e.g., vehicle exhaust), energy consumption (e.g., electricity and natural gas), solid waste, wastewater treatment, and water consumption (e.g., electricity used to deliver and treat water consumed by customers in the City). The operational GHG emissions from buildout of the General Plan were calculated using the CalEEMod emissions model for area sources, energy usage, solid waste, and water and wastewater, and EMFAC 2021 for mobile sources. The operational GHG emissions calculated by CalEEMod were based on General Plan buildout conditions at year 2040, including up to 38,959 dwelling units and up to 50,052,914 square feet of non55 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact GHG-1, beginning at page 3.7-53 Vantage Master Plan Project – CEQA Analysis page 107
residential space. The GHG emissions forecast assumes that several State and local GHG reduction measures will be implemented by 2040, including the following actions:
• Implementation of the Renewable Portfolio Standard, which requires electricity providers to increase the portion of energy that comes from renewable sources to 60 percent by 2030 and zero-carbon by 2045
• Implementation of the most current Title 24 building energy use standards • Reduction of indoor residential and indoor/outdoor commercial lighting energy usage as detailed in AB 1109
• Implementation of California Advanced Clean Car, including Pavley standards and Executive Order N-79- 20 that requires 100 percent of new passenger vehicles sold in California to be zero-emissions by 2035 • Adoption of Complete Streets standards to expand pedestrian and bicycle infrastructure and provide availability for future residents and visitors with infrastructure for alternative modes of transportation and reduce reliance on motorized transportation, and
• Improvements to public transit and ridesharing programs In addition to these State and local GHG reduction measures, the General Plan EIR cited numerous General Plan and 2022 Climate Action Plan (CAP) actions that would help reduce GHG emissions generated from existing and future development.

The General Plan EIR determined that at buildout the City is estimated to generate approximately 872,000 MT CO2e per year in 2040, with a service population (residents and employees) of an estimated 245,700 people.

Citywide GHG emissions per service population were projected to be 3.55 MT CO2e in 2040. These GHG emissions per service population were found to not exceed a 4.0 MT CO2e per service population threshold, which was based on the ARB’s current Scoping Plan and represents the rate of emission reductions necessary for the City to achieve a fair share of Statewide GHG reductions necessary to meet the State’s long-term GHG reduction targets. The General Plan EIR concluded that buildout of the General Plan would result in annual per service population emissions of 3.55 MT CO2e, which is below the established significance threshold of 4.0 MT CO2e per service population, and as such, this impact was found to be less than significant.

Project Analysis
The City’s 2022 CAP is intended to establish an analytical pathway per CEQA Guidelines Section 15183.5(b) to allow projects to be analyzed through a streamlined or tiered approach utilizing an adopted Greenhouse Gas Reduction Plan. Whereas the SSF 2040 General Plan EIR was certified and the 2022 CAP was adopted, the updated 2022 CAP is considered a qualified GHG Reduction strategy.

Accordingly, and pursuant to CEQA Guidelines Section 15183.5(b)(2), the SSF 2022 CAP is used in the following analysis of the Project to identify those requirements specified in the SSF 2022 CAP that apply to the Project, and providing substantial evidence to demonstrate the Project's compliance with the specific requirements of the 2022 CAP. To be considered eligible for CEQA streamlining per CEQA Guidelines Section 15183.5, the Project must be consistent with the SSF 2022 CAP.

Consistency with SSF 2022 CAP
The following analysis identifies those Actions of the SSF 2022 CAP that apply to the Project, and a discussion of the Project’s compliance with those Actions.

Vantage Master Plan Project – CEQA Analysis page 108
Clean Energy
Action CE 1.1: Require the construction of any new non-residential conditioned space of 5,000 square feet or more to meet a minimum of 50 percent of modeled building electricity needs with on-site renewable energy sources, as is feasible. To calculate 50 percent of building electricity needs for the new conditioned space, the applicant shall calculate building electricity use as part of the Title 24 compliance process. Total electricity use shall include total use for the new conditioned space, excluding process energy.

Consistency: The Project proposes to either construct Phases 2 and 3 in compliance with an all-electric reach code, to provide on-site renewable energy sources, or to otherwise exceed CalGreen energy efficient standards by 20 percent. By obtaining its electrical needs from Peninsula Clean Energy’s renewable energy portfolio, this CAP Action can be achieved. Alternatively, according to preliminary calculations, each of the buildings pursuant to Phase 2 and Phase 3 can provide approximately 30 percent of their rooftop space (space not otherwise required for mechanical equipment and elevator towers) for the application of PV panels. PV panels would be installed on an additional 33,000 square feet of rooftop space on each of the Project’s parking structures. Together, these rooftop spaces amount to approximately 134,880 square feet of PV-covered area, generating 2,223 kW of electrical power, or approximately 69,300 MBTU/year of electrical power supply.

This maximum PV panel area is estimated to generate approximately 15.6 percent of the CALGreen “baseline” energy demands of the Project, and therefore represents the maximum feasible on-site renewable energy supply that can be provided by the Project.

Action CE 2.1: Maintain City membership in Peninsula Clean Energy and continue to work to maintain a minimum of 95 percent of private property owner participation in PCE.

Consistency: The Project applicant intends to obtain its electrical power supply from Peninsula Clean Energy.

Built Environment
Action BNC 2.1: Implement the residential all-electric reach code and adopt an all-electric reach code for nonresidential new construction. Exempt occupancies must install electric building systems (e.g., space and water heating equipment) where feasible. Until the adoption of the non-residential all-electric reach code, require any new non-residential conditioned space of 5,000 square feet or more, or the conversion of unconditioned space 5,000 square feet or more, to comply with CALGreen Tier 2 energy efficiency requirements and to exceed mandatory energy efficiency requirements by 20 percent or more. Existing building space already permitted shall not be subject to CALGreen Tier 2 requirements
Consistency: This Action of the 2022 CAP specifically exempts from the CalGreen Tier 2 requirement those building spaces that exist or that have already permitted. Phase 1 has already been permitted and is currently under construction. Accordingly, Phase 1 is not subject to this 2022 CAP Action.

In May of 2021, SSF adopted an all-electric reach code (SSFMC Section 15.26.020) that applies to newly constructed residential buildings, but newly constructed non-residential buildings and all non-residential occupancies in a mixed-use building were exempted from this requirement. At the time the Project application was filed, and at the time of preparation of this Initial Study/CEQA Checklist, the City of SSF has not yet adopted an all-electric reach code that applies to non-residential buildings. Accordingly, Phase 1 (which is exempt), and Phases 2 and 3 of the Project are not required to be all-electric buildings.

Consistent with the provisions of this 2022 CAP Action that apply until adoption of a non-residential allelectric reach code, the Project commits to either installing all electric building systems for Phase 2 and 3 buildings or constructing and operating all Phase 2 and 3 buildings such that they comply with Vantage Master Plan Project – CEQA Analysis page 109
CALGreen Tier 2 energy efficiency requirements, exceeding mandatory energy efficiency requirements by 20 percent or more. Each building will demonstrate how it will achieve CALGreen Tier 2 energy efficiencies at the time of building permit application for each new building. If the Project does not construct each of its buildings as all-electric, the Project proposes to achieve the mandatory CALGreen building energy efficiency requirements for these buildings by 20 percent or more as follows:
• Meeting CALGreen Building Energy Efficiency Standards for each building and exceeding those standards by as much as 5 percent based on the selection of highest-efficiency HVAC equipment and façade design measures that have been demonstrated to exceed CALGreen energy performance requirements.
• Including heat recovery systems on all lab exhaust systems • Adding industry-best-performance photovoltaic (PV) panels on the roofs of all new buildings and parking structures as feasible. According to preliminary calculation (see Table 13), a PV array covering 134,880 square feet of rooftop area (the maximum rooftop area available) can generate 2,223 kW, or approximately 69,300 MBTU/year. These PV panels would reduce mandatory energy efficiency requirements by an additional 15 percent or more.

Table 13: Project’s Required 20% Energy Reduction over CALGreen “Baseline” (MBTU/yr) Building
Building
Size (GSF)
2019 Title 24
CalGreen)
“Baseline”
Projected
Building Energy
Use PV Output
Projected
Building Energy
Use, with PV
Energy
Efficiency
Savings
Building C 440,000 147,200 140,700 -23,100 117,600 20.1% Building D 249,000 83,300 79,600 -13,000 66,600 20.0%
Building E 283,000 84,700 80,900 -13,400 67,500 20.3%
Building F 316,582 126,800 121,200 -19,700 101,500 20.0% Fire Station 9,500 1,640 1,400 -100 1,300 20.7%
1,298,182 443,640 423,800 -69,300 354,500 20.0%
Source: Flad Architects, November 2022
Note: PV array assumes 30% coverage of each building’s rooftop, plus additional required PV array on parking garage rooftops As demonstrated above, the Project’s alternative proposal for using a combination of energy-efficient design and solar power arrays is capable of achieving CALGreen Tier 2 energy efficiency requirements, exceeding mandatory energy efficiency requirements by 20 percent or more for all new Phase 2 and Phase 3 buildings. Consistent with 2022 CAP Action BNC 2.1, all new buildings pursuant to Phases 2 and 3 of the Project will either be all electric or will include PV panels on their rooftops (assumed at 30% roof cover), and additional PV arrays installed on the rooftops of each parking structure, or other measures in an amount necessary to achieve compliance with 2022 CAP Action BNC 2.1.

Transportation and Land Use
Action TL 1.1: Implement EV reach code.

Consistency: In May of 2021, South San Francisco amended Title 15 of SSFMC to adopt certain modifications and additions to the California Energy Code/Building Energy Efficiency Standards and the Vantage Master Plan Project – CEQA Analysis page 110
California Green Building Standards Code, which serve as reach codes to increase building efficiency and increase requirements related to electric vehicle charging stations (EVCS). The SSF-adopted EV reach code applies to new residential construction only and does not apply to the Project.

The upcoming 2022 CalGreen Code (planned to go into effect January 2023) is expected to include new mandatory measures for non-residential projects. Pursuant to 2022 CalGreen, 20 percent of the parking spaces in locations that provide more than 200 parking spaces are to be EV-capable spaces, and 25 percent of those are to be fully installed EV charging receptacles or permanently installed chargers (EVSE).56 These 2023 EV charging station requirements do not yet apply to the Project but are anticipated to be applicable at the time of building permit application (at least for Phase 3 buildings).

Action TL 2.2: Implement, monitor, and enforce compliance with the City’s TDM Ordinance.

Consistency: The Project is required to and shall implement and monitor a Transportation Demand Management (TDM) Plan. The purpose of the TDM Plan is to provide options to encourage future employers and employees to use non-automobile transportation modes, to encourage carpooling, biking, walking and transit use, and to incorporate on-site design features to promote the same.

Beginning at Phase 1 (previously entitled), a TDM plan meeting the City’s Tier 3 requirements will be initiated. Beginning with Phase 2 approvals, the Project’s TDM Plan will transition to meet Tier 4 requirements, achieving up to a 50 percent reduction in drive-alone vehicle trips for the entire Project, consistent with the City’s TDM Ordinance and 2022 CAP Action TL 2.2.

Action TL 2.4: Incorporate maximum parking requirements for new residential and office/R&D projects.

Consistency: Section 20.330.004 of SSFMC provides that each land use shall provide no more than the number of on-site parking spaces as provided in SSFMC Table 20.330.004. However, the Planning Commission may allow parking in excess of the number of spaces as specified in this SSFMC table, subject to a Conditional Use Permit and based on a finding that the amount of parking provided is supportive of the recommendations and requirements of a TDM Plan prepared for the Project.

Table 20.330.004 of SSFMC establishes parking ratios of 1.5 parking spaces per 1,000 square feet of R&D building space. At this parking ratio, the parking for Phases 2 and 3 of the Project would be limited to 2,422 spaces. The Project applicant seeks approval of a CUP that would enable an overall Project parking ratio of 2.24 parking spaces per 1,000 square feet of building space, yielding 3,701 parking spaces. This proposed parking program accounts for the parking ratios recommended in SSFMC, the expected parking demand, and is inclusive of TDM requirements needed to meet a 50 percent reduction in drivealone commute trips, consistent with 2022 CAP Action TL 2.4.

Action TL 2.5: For 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. Use the development review process to identify opportunities to enhance bicycle, pedestrian and transit connectivity.

Consistency: As indicated in both the Project Description and the Transportation section of this CEQA Checklist, the Project will implement a Tier 3 TDM Plan pursuant to Phase 1 of the Project, and this TDM Plan will transition into a Tier 4 TDM Plan commensurate with the certificate of occupancy for the first building under Phase 2. The Tier 4 TDM Plan will then become applicable to the entire Project.

Consistent with the General Plan and SSFMC, the Tier 4 TDM Plan will achieve the required points necessary to demonstrate its capability of achieving a 50 reduction in drive-alone commute vehicles. 56 CALGreen Chapter 5 – Nonresidential Mandatory Measures, Section 5.106.5.3.1 EV Capable Spaces, Table 5.106.5.3.1, accessed at:
https://up.codes/viewer/california/ca-green-code-2022/chapter/5/nonresidential-mandatory-measures#5 Vantage Master Plan Project – CEQA Analysis page 111
To encourage alternatives modes of travel other than drive-alone commute, the Project’s TDM Plan includes measures that support transit, bicycle and pedestrian modes. As part of the Project, the applicant has already completed the Rails-to-Trails bicycle and walking trail improvements along the southern portion of the Project site. In addition to this investment, the Project will establish pedestrian and bicycle connections from the Project site to existing bicycle lanes on Forbes Boulevard and Allerton Avenue, as well as to the existing Rails-to-Trails pathway south of the Project site. The Project will provide additional active transportation improvements designed to close other existing gaps in the bike and pedestrian network. In coordination with the City, these improvements may include a formal crossing of the Class I trail across Allerton Avenue, additional improvements to the Class II bicycle facilities on Forbes Boulevard, or site connections to the Class I bicycle facility as it runs south of the Project site. The Project will review opportunities with the City to identify additional gaps closures in the pedestrian and bicycle network, with the goal of reaching four points worth of improvements pursuant to the City’s tiered TDM ordinance requirements.

The Project’s internal circulation network is designed to meet the needs of all roadway users including pedestrians and bicycles. Implementation of the Project’s TDM Plan will significantly reduce the share of employees commuting to work via single occupancy vehicles, and will provide connectivity to the city transit system, with anticipated new bus stop locations adjacent to the Project site, all consistent with SSF 2022 CAP Action TL 2.5.

Action TL 2.6: 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. Develop Capital Improvement Program (CIP) prioritization criteria, including equity considerations for SB 1000 neighborhoods, to strategically advance multimodal Complete Streets projects. 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. and -
Action TL 2.8: Leverage 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.

Consistency: Pursuant to the Project’s Tier 4 TDM Plan and in addition to regular participation in the Commute.org shuttle consortium, the Project will partner with Genentech by contributing additional funding to allow employees working at the Project site to utilize the last-mile Genenbus shuttles. Under future phases, a shuttle stop will be provided adjacent to the Project site. Final location of the proposed shuttle stop, including the proposed accompanying infrastructure, will be determined based on shuttle routing and service following initiation of Phase 2 construction. These measures are fully consistent with SSF 2022 CAP Actions TL 2.6 and TL 2.8.

Action TL 2.9: Continue collaboration with Caltrain, SamTrans, WETA, and shuttle providers to scale service levels in growing areas and leverage private sector subsidies of transit fares to support BART, Caltrain, SamTrans, and WETA ridership.

Consistency: Pursuant to the Project’s Tier 4 TDM Plan, the Project will offer public transit passes or subsidies equivalent to at least 50% of the cost of a monthly two-zone Caltrain pass, as a means to incentivize transit use. This may be implemented through lease terms obligating future tenants/ employers to provide these subsidies to their employees. The private sector subsidies of transit fares will help to support increases in BART, Caltrain, SamTrans and WETA ridership, consistent with SSF 2022 CAP Action LTL 2.9.

Vantage Master Plan Project – CEQA Analysis page 112
Solid Waste
Action SW 1.1: Adopt a SB 1383-compliant zero-waste plan for municipal operations and the community that includes: mandatory residential and commercial recycling and collection of organics/food waste, mandatory commercial edible food recovery program (per MOU with San Mateo County Office of Sustainability), and updated trash enclosure space and access requirements based on hauler recommendations to accommodate all waste streams (e.g., recycling, trash, and organics).

Consistency: As further addressed in the Utilities section of this CEQA Checklist (Project Requirement Utilities-8, Organic Waste), the Project shall enroll in the city’s three-container organic waste collection services with source-separated recyclable materials, thereby assisting in the reduction of landfill methane emissions. Additionally, the Project will (per Project Requirement Utilities-7, Solid Waste and Scavenger Services) arrange for and have solid waste collection service, with solid waste, recyclable materials and salvageable materials (including organics/food waste) separated for collection by the city’s authorized recycling agent. At such time the City may adopt an SB 1383-compliant zero-waste plan that applies to the Project, the Project will incorporate a commercial edible food recovery program consistent with SSF 2022 CAP Action SW 1.1.

Water and Wastewater
Action WW 2.1: Require high-efficiency fixtures in all new construction and major renovations, comparable to CALGreen Tier 1 or 2 standards.

Consistency: New Project buildings will be required to demonstrate compliance with CALGreen building standards at the time of building permit application and pursuant to a required CALGreen Checklist, including those standards pertaining to water efficiency. The currently effective CALGreen Building Standards Code, 2019 Edition (CALGreen) was adopted by reference as the building standards of the City of South San Francisco, and the 2022 Edition of CALGreen is expected to be adopted in January of 2023.

The current (2019) CALGreen standards contain mandatory measures for water-efficient fixtures and equipment in new buildings, and the Project will be required to comply with these measures.

SSF 2022 CAP Action WW 2.1 requires projects to meet a higher efficiency standard, comparable to the CALGreen “voluntary” Tier 1 or Tier 2 standards. These Tier 1 and Tier 2 standards add additional requirements beyond the mandatory measures, effectively requiring an additional 12 percent water savings beyond the mandatory measures under Tier 1 (one additional elective measure), and an additional 20 percent water savings beyond the mandatory measures under Tier 2 (3 additional elective measures). Although these Tier 1 and Tier 2 measures are indicated as “voluntary” under CALGreen, the Project will be required to meet these higher standards pursuant to future building permits in order to demonstrate compliance with SSF 2022 CAP Action WW 2.1.

Carbon Sequestration
Action CS 2.2: For non-residential and residential new construction, require silva cell structures and soil compaction plan for tree growth, and require the preservation and addition of trees on private property.

Consistency: The project includes an overall Landscape Concept that will be refined over time, as each application for every new building brings additional detail. Pursuant to the Landscape Concept, the majority of site plantings are to be low water use and native or adapted species, following Bay Friendly planting requirements. Stormwater treatment areas are to be designed and implemented consistent with MRP c.3 requirements, including a mix of swales and flow-through planters with plants that are adapted to occasionally wet conditions and can be flooded during large storm events. Pursuant to those individual MRP c.3 provisions, each landscape and stormwater treatment design will review the Vantage Master Plan Project – CEQA Analysis page 113
potential for inclusion of deep root silva cells as a stormwater BMP to better leverage soil and trees to provide water quality control and peak overflow reduction, consistent with SSF 2022 CAP Action CS 2.2.

Conclusions: Based on the above analysis, the Project is, and/or will be required to demonstrate consistency with the SSF 2022 CAP. The Project’s proposed development plans indicate that the Project will be consistent with individual CAP Actions related to clean energy, building design, transportation and land use, solid waste, water and wastewater, and carbon sequestration. The Project does not present any inherent inconsistencies with other SSF 2022 CAP Actions. As such, the Project is eligible for streamlined environmental review of its impacts pertaining to GHG emissions pursuant to CEQA Guidelines Section 15183.5. Based on the Project’s consistency with applicable CAP Actions, the Project meets the CEQA threshold of less than a significant impact for GHG by being consistent with the SSF 2022 CAP and would not generate greenhouse gas emissions that may have a significant impact on the environment (Checklist item GHG-a). b) Conflict with Plan, Policy or Regulation that Reduces Emissions SSF General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact GHG-2) concluded that implementation of the 2040 General Plan would not conflict with any applicable plan, policy or regulation of an agency adopted for purposes of reducing the emissions of greenhouse gases.57
The General Plan EIR examined each of the following plans, policies and regulations, finding the General Plan and its 2022 CAP to be fully consistent:
• ARB Climate Change Scoping Plan: The 2017 Climate Change Scoping Plan recommends a local, planlevel target of no more than 6.0 MT CO2e per capita by 2030, and no more than 2.0 MT CO2e per capita by 2050. Based on a linear interpolation of these two GHG reduction goals, the target for the 2040 General Plan was no more than 4.0 MT CO2e per service population. The General Plan EIR projected citywide emissions of 3.55 MT CO2e per service population in 2040, finding these emissions to meet the GHG reduction target of the 2017 Climate Change Scoping Plan. The General Plan EIR also concluded that future development projects would be required to comply with State standards for new construction as well as policies and actions of the General Plan and 2022 CAP that aim to reduce GHG emissions. Therefore, development facilitated by the General Plan would not conflict with the 2017 Climate Change Scoping Plan.
• Plan Bay Area 2050: Strategy for a Sustainable Region: The General Plan EIR determined that housing development pursuant to the General Plan would promote new population and employment growth in and around Priority Development Areas (PDAs), especially in areas that are transit-oriented, and as infill development opportunity areas within existing communities. The General Plan EIR also found that policies and actions of the General Plan encourage the use of alternative modes of travel and reduce dependence on auto use, consistent with Plan Bay Area’s vision. Moreover, the General Plan contains several policies and actions which would support Plan Bay Area 2050 policies and strategies related to GHG emissions. The General Plan EIR concluded that development facilitated by the General Plan would not conflict with the Plan Bay Area 2050.
• Bay Area Air Quality Management District 2017 Clean Air Plan: The General Plan EIR included a detailed analysis of the General Plan’s consistency with the BAAQMD 2017 Clean Air Plan, finding consistency 57 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact GHG-2, beginning at page 3.7-66 Vantage Master Plan Project – CEQA Analysis page 114
with control measures that focus primarily on reducing GHG emissions. This analysis demonstrated the General Plan’s consistency with applicable control measures of the 2017 Clean Air Plan.

In conclusion, the General Plan EIR determined that development facilitated by the General Plan would be required to comply with requirements of the General Plan, the updated 2022 CAP, and SSFMC regulations to reduce GHG emissions, as well as existing and new federal, State, and local statutes and regulations related to GHG emissions. The General Plan and associated 2022 CAP was found to be consistent with the plans and policies adopted for purposes of reducing the emissions of greenhouse gases, and this impact was determined to be less than significant.

Project Analysis
Conclusion: Whereas the General Plan and the SSF 2022 CAP were previously found to be consistent with State and local plans adopted for purposes of reducing the emissions of greenhouse gases, and the Project is consistent with the General Plan and SSF 2022 CAP, then the Project is similarly consistent with State and local plans for renewable energy or energy efficiency (Checklist item GHG-b). This impact is less than significant.

CEQA Conclusions Pertaining to GHG Emissions
Based on the analysis, findings and conclusions of the prior SSF 2040 General Plan EIR, implementation of the Project would not substantially increase the severity of any significant impacts related to GHG emissions as identified in that Program EIR, nor would it result in new significant impacts related to GHG that were not previously identified. The prior Program EIR did not identify any additional mitigation measures related to GHG that would apply to the Project, and none would be needed.

Vantage Master Plan Project – CEQA Analysis page 115
Hazards and Hazardous Materials
Would the Project:

SSF 2040
General Plan
EIR Findings
Relationship to SSF 2040
General Plan EIR Findings: Project Conclusions:

Equal or
Less Severe
New or
Substantial
Increase in
Severity
Applicable Standards
and Requirements
Resulting
Level of
Significance
a) Create a significant hazard to the public
or the environment through the routine
transport, use, or disposal of hazardous
materials
LTS  ☐ Project Requirement
HYD-1, Construction
General Permit
Project Requirement
HYD-2, Storm Water
Pollution Prevention
Plan (SWPPP)
Project Requirement
HAZ-1, Performance
Standards for Hazardous
and Extremely
Hazardous Materials
Project Requirement
HAZ-2, Hazardous
Material Business Plan
LTS with PR
b) Create a significant hazard to the public
or the environment through reasonably
foreseeable upset and accident conditions
involving the release of hazardous
materials into the environment
LTS  ☐ Project Requirement
HAZ-2, Hazardous
Material Business Plan
LTS with PR
c) Emit hazardous emissions or handle
hazardous or acutely hazardous materials,
substances, or waste within one-quarter
mile of an existing or proposed school
LTS  ☐ - No Impact
d) Be located on a site which is included
on a list of hazardous materials sites
compiled pursuant to Government Code
Section 65962.5 and, as a result, would it
create a significant hazard to the public or
the environment
LTS  ☐ Project Requirement
HAZ-3, Notification to
San Mateo County
Environmental Health
Division
Project Requirement
HAZ-4, Soil Reuse
Project Requirement
HAZ-5, Asbestos
Airborne Toxic Control
Measures
LTS with PR
e) For a project located within an airport
land use plan or, where such a plan has
not been adopted, within two miles of a
public airport or public use airport, would
the project result in a safety hazard or
No Impact  ☐ - No Impact
Vantage Master Plan Project – CEQA Analysis page 116
excessive noise for people residing or
working in the project area
f) Impair implementation of or physically
interfere with an adopted emergency
response plan or emergency evacuation
plan
No Impact  ☐ - Less than
Significant
g) Expose people or structures, either
directly or indirectly, to a significant risk of
loss, injury or death involving wildland
fires
See Wildfire section of this Initial Study Checklist
a) Routine Transport, Use or Disposal of Hazardous Materials / Upset and Accident Condition SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact HAZ-1) concluded that implementation of the 2040 General Plan would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials.58
New development could result in an increase in the routine transportation, use, and disposal of hazardous materials, and development in the Business Technology Park, Business Technology Park High, Mixed Industrial, Mixed Industrial High and Industrial Transition Zone were identified as land use designations that have the greatest potential to generate hazardous materials. During construction activities, commercially available hazardous materials (e.g., fuels, solvents, paints, and some consumer electronics) would be used, which may generate small amounts of hazardous waste. Demolition of existing structures could potentially result in the release of hazardous building materials (e.g., asbestos, lead paint, etc.). The SSF 2040 General Plan EIR determined that all new development would be required to comply with mandatory regulations for hazardous materials adopted by the EPA, OSHA, USDOT, DTSC, Caltrans, CHP, local CUPA and BAAQMD. Businesses handling or storing hazardous materials over threshold quantities are required to submit an HMBP to the local CUPA. The SSFFD and South San Francisco Building Division coordinate review of building permits to ensure hazardous materials requirements are met prior to construction. Any businesses that generate or use hazardous materials are also subject to existing hazardous materials regulations as implemented by the local CUPA. The CUPA and SSFFD also conduct inspections for fire safety and hazardous materials management. Businesses storing or handling hazardous materials over threshold quantities are required to submit HMBPs pursuant to federal, State, and local regulations. These HMBPs must include measures for safe storage, use, and handling of hazardous materials, along with a contingency plan that describes the facility’s response procedures in the event of a hazardous materials release.

The General Plan EIR found that the transportation of hazardous materials on local roadways and along railways is regulated and monitored by multiple agencies. These agencies enforce federal and State regulations regarding transportation of hazardous materials and respond to hazardous material spills and releases that occur. If an accident were to occur during transport of hazardous materials, the CUPA, South San Francisco Fire Department (SSFFD), and South San Francisco Police Department (SSFPD) would respond. As noted, the CHP conducts regular 58 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact HAZ-1, page 3.8-24 Vantage Master Plan Project – CEQA Analysis page 117
inspections of licensed transporters to assure regulatory compliance and responds to hazardous materials emergencies on roadways.

The disposal of hazardous materials is regulated and monitored by the City of South San Francisco (Chapter 8.20 of the Municipal Code), local CUPA, SSFFD, Cal/OSHA and the DTSC, consistent with the requirements of federal, State, and local regulations and policies.

The General Plan EIR concluded that future projects would be subject to environmental analysis at the time a specific project is defined. In reviewing individual project applications, the City would determine which General Plan policies and Zoning Ordinance chapters apply, depending on the specific characteristics of the project type and/or project site. While development envisioned by the General Plan could result in an increase in the transportation, use and disposal of hazardous materials, future projects would be required to comply with requirements and regulations of the City of South San Francisco, EPA, OSHA, USDOT, DTSC, Caltrans, CHP, local CUPA and BAAQMD. Therefore, impacts related to the transportation, use and disposal of hazardous materials were found to be less than significant.

Project Analysis
Construction activities associated with the Project will involve the use of heavy equipment using fuels and oils and will involve the use of other products such as concrete, paints and adhesives. Such hazardous materials will be stored, used and transported in varying amounts during construction.

The Project’s new buildings are intended as build-to-suit facilities. The future tenants of these buildings have not yet been identified but are likely to be occupied by a combination of office space and R&D laboratories. The R&D laboratories may handle certain materials considered hazardous biological and/or chemical substances. Office spaces would likely involve use of common commercial hazardous materials such as cleaners and solvents.

These hazardous materials will likely be stored, used and transported in varying amounts during Project operations
Regulatory Requirements
Construction Period
The Project would be required to comply with all Federal, State, and local regulations regulating the handling, storage, and transportation of hazardous materials. The following regulatory requirements apply to all new construction activity, specifically intended to address expansive soils conditions:
❖ Project Requirement HYD-1, Construction General Permit: (see Hydrology section of this CEQA Checklist for details)
❖ Project Requirement HYD-2, Storm Water Pollution Prevention Plan (SWPPP): (see Hydrology section of this CEQA Checklist for details)
The Construction General Permit GP regulates stormwater management at construction sites, and the Storm Water Pollution Prevention Plan prevents the discharge of pollutants to surface waters or groundwater. With implementation of these regulatory requirements, construction activities would not create a significant hazard to the public or the environment through routine transport, use, or disposal of hazardous materials or through a reasonably foreseeable upset and accident condition involving the release of hazardous materials in the environment.

Operational
The following regulatory requirements apply to all facilities handling hazardous or acutely hazardous materials, specifically intended to reduce the risk of upset to adversely affect the public or the environment:

Vantage Master Plan Project – CEQA Analysis page 118
❖ Project Requirement HAZ-1, Performance Standards for Hazardous and Extremely Hazardous Materials:

Pursuant to SSFMC Section 20.300.010 (D.10), the use, handling, storage and transportation of hazardous and extremely hazardous materials shall comply with the provisions of the California Hazardous Materials Regulations and the California Fire and Building Code, as well as the laws and regulations of the California Department of Toxic Substances Control and the County Environmental Health Agency. Activities, processes, and uses shall not generate or emit any fissionable or radioactive materials into the atmosphere, a sewage system or onto the ground.
❖ Project Requirement HAZ-2, Hazardous Material Business Plan: The San Mateo County Environmental Health Department (SMCEHD) enforces regulations of the California Health and Safety Code, Division 20 Chapter 6.95, including requirements to submit a Hazardous Material Business Plan (HMBP). If future tenants of the Project’s new buildings handle and/or store hazardous materials at minimum reportable quantities, those tenants will be required to file a HMBP that must include:

1. Summary of business activities

2. Owner/operator information including emergency contacts

3. The type and quantity of reportable hazardous materials

4. Site map

5. Emergency response procedures

6. Employee training program
Conclusion: Consistent with the findings of the SSF General Plan EIR, the Project would be required to comply with all applicable city, county, state and federal regulations related to the transport, use, and disposal of hazardous materials. These regulations control the use of hazardous materials to minimize the risk of exposure of the public to substantial adverse effects related to the routine transport, use, or disposal of hazardous materials to a level of less than significant (Checklist item Hazards-a), and no additional mitigation is required. b) Hazardous Materials Upset Risk
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (impact HAZ-2) concluded that implementation of the SSF 2040 General Plan would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the likely release of hazardous materials into the environment.59 The General Plan EIR found that compliance with mandatory regulations would reduce all potential construction-related impacts to a less than significant level, and that those laws will be enforced at all construction sites. Additionally, future development must comply with the California Code of Regulations, which establishes Cal/OSHA requirements related to public and worker protection. The local CUPA is responsible for ensuring that the California Code of Regulations and all other programs related to hazardous materials are implemented. The General Plan EIR concluded that compliance with State law and implementation of federal, State, and local policies and regulations 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 into the environment.
59 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact HAZ-2, page 3.8-26 Vantage Master Plan Project – CEQA Analysis page 119
Project Analysis
The Project would be required to comply with all federal, State and local regulations regulating the handling, storage, and transportation of hazardous materials during operations. With compliance, operational activities would not create a significant hazard to the public or the environment through a reasonably foreseeable upset and accident condition involving the release of hazardous materials in the environment. Therefore, operational impacts would be less than significant.

Conclusion: Consistent with the findings of the SSF General Plan EIR, the Project would be required to comply with all applicable city, state and federal regulations related to the transport, use, and disposal of hazardous materials. These regulations control the use of hazardous materials to minimize the risk of exposure of upset and accident conditions involving release of hazardous materials into the environment (Checklist item Hazardsb) to a level of less than significant, and no additional mitigation is required. c) Hazardous Emissions near a School
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (impact HAZ-3) concluded that implementation of the SSF 2040 General Plan would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. 60 As discussed in the General Plan EIR, it is possible that future development and redevelopment projects will involve hazardous emissions or handle hazardous materials and wastes that may occur within 0.25 mile of an existing or future school. However, such projects would be required to comply with existing federal, State, and local regulations related to hazardous materials. In particular, the SSFFD and South San Francisco Building Division coordinate their review of building permits to ensure hazardous materials requirements are met prior to construction, including required separation between hazardous materials and sensitive land uses and proper hazardous materials storage facilities. Future development would be required by the local CUPA to store, manage, and dispose of the materials in accordance with the Unified Program. Therefore, the General Plan EIR found this impact to be less than significant.

Project Analysis
The Project site is not within a quarter mile of an existing or proposed school. The school closest to the Project site is Martin Elementary School on School Street, nearly one mile away to the northwest. Therefore, no impacts related to hazardous materials near schools would occur.

Conclusion: Consistent with the General Plan EIR, the Project’s effects related to hazardous emissions or handling hazardous or acutely hazardous materials, substances or waste within one-quarter mile of an existing or proposed school (Checklist item Hazards-c) would be less than significant and no additional mitigation measures are necessary.
d) Cortese List / Known Hazardous Conditions at the Site SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact HAZ-4) concluded that development facilitated by the General Plan could occur on a contaminated site, but that such sites will be evaluated for project-specific impacts related to 60 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact HAZ-3, page 3.8-28 Vantage Master Plan Project – CEQA Analysis page 120
hazardous materials at the time they are proposed. Any development on a contaminated site would be required to comply with mandatory regulations to ensure it does not create a significant hazard to the public or the environment. 61
If hazardous materials are known or encountered during construction activities, the handling, transportation and disposal of hazardous materials would be required to comply with the requirements and regulations set forth by the City of South San Francisco, San Mateo County, SFRWQCB, DTSC, EPA, the local CUPA and BAAQMD. In reviewing individual project applications, the City would determine which General Plan policies regulations apply, depending on the specific characteristics of the project type and/or project site during the development review process. Therefore, the SSF General Plan EIR found this impact to be less than significant.

Project Analysis
This Hazardous Materials section contains Information related to the Project and the Project site based on the following primary sources:
• Langan Engineering and Environmental Services, Inc., Phase I Environmental Site Assessment - Gallo Site, October 23, 2020 (Appendix H)
• Langan Engineering and Environmental Services, Inc., Soil Management Plan for Vantage Phases 2 and 3, November 4, 2022 (Appendix I)
Cortese List
Hazardous materials sites compiled pursuant to Government Code Section 65962.5 are known as the Cortese list. The Cortese List is comprised of identified sites with suspected and/or confirmed releases of hazardous materials to the sub-surface soil and/or groundwater, and is a compilation of data from the following sources:
• the California Department of Toxic Substances Control (DTSC) portion of the Hazardous Waste and Substances Sites List, available on the DTSC EnviroStor database; • the California State Water Resources Control Board (SWRCB)/or San Francisco Regional Water Quality Control Board (RWQCB) list of leaking underground storage tanks (LUSTs), underground storage tanks (UST), and Spills, Leaks, Investigations and Cleanup (SLIC) sites as listed on the SWRCB GeoTracker database;
• solid waste disposal sites identified by SWRCB with waste constituents above hazardous waste levels outside the waste management unit;
• “Active” Cease and Desist Order (CDO) and Cleanup and Abatement Order (CAO) sites from the SWRCB, and
• hazardous waste facilities subject to corrective action pursuant to Section 25187.5 of the Health and Safety Code, as identified by DTSC and listed on the EnviroStor database Langan’s 2020 Phase I Preliminary Environmental Site Assessment (Phase I ESA) concluded that the portion of the Project site at 440 Forbes Boulevard was listed on the SWRCB GeoTracker database as a LUST Cleanup Site with a status of “Completed - Case Closed”. An October 2022 review of this database confirms this status as 61 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact HAZ-4, page 3.8-29 Vantage Master Plan Project – CEQA Analysis page 121
current, with no other SWRCB-reported cases at the Project site. 62 An October 2022 review of the DTSC
EnviroStor database found no DTSC-reported cases at the Project site.63 440 and 460 Forbes Boulevard
As referenced in Langan’s Phase I ESA, five underground storage tanks (USTs) were removed from the site at 440 Forbes Boulevard in November 1991. Four of the USTs contained petroleum fuel and the fifth UST contained waste oil. Soil and groundwater contamination was discovered upon tank removal activities. Subsequent subsurface investigations showed that the petroleum hydrocarbon contamination consisted of free phase and dissolved gasoline, benzene/toluene/ethylbenzene/xylenes (BTEX, collectively), and methyl tertiary butyl ether (MTBE) in groundwater. A system was installed that included groundwater extraction equipment for removal, treatment, and discharge of impacted groundwater, and soil vapor extraction equipment was installed for removal of volatile hydrocarbons from the subsurface soil. Based on the contaminated soil remediation and groundwater monitoring activities, administrative Case Closure for the fuel leak was granted by the San Mateo County Environmental Health Department, Groundwater Protection Program (SMCEHD-GPP) in April 2013, and no further action was required. However, SMCEHD-GPP informed the City of South San Francisco Building Department that should excavation or development of the 440 Forbes Boulevard or adjacent 460 Forbes Boulevard sites be proposed that may encounter impacted soil or groundwater, SMCEHD-GPP must be notified.

The Langan Phase 1 ESA identified this condition at the Project site as a “Controlled Recognized Environmental Condition” resulting from a past release of hazardous substances or petroleum products that has been addressed to the satisfaction of the applicable regulatory authority (e.g., as evidenced by the issuance of a no further action letter or equivalent, or meeting risk-based criteria established by regulatory authority). Hazardous substances or petroleum products are allowed to remain in place subject to the implementation of required controls (e.g., property use restrictions, activity and use limitation, institutional controls, or engineering controls).64
420 Forbes Boulevard
The Langan Phase I ESA also references an earlier April 2019 Phase I Environmental Site Assessment for the 420 Forbes Boulevard property (Condor Earth, April 2019). According to that 2019 Phase I ESA, “the 3.25-acre site at 420 Forbes Boulevard consists of a vacant lot in a primarily industrial area of South San Francisco. A warehousetype building occupied the site from the 1930s until the early 1960s. A rail spur was constructed on the southern portion of the site in the mid-1960s until it was removed in the late 1980s. In the early 1990s, the eastern portion of the site was used for additional parking by the eastern adjoining property. The site was vacant until 2018 when it was used by a construction company during construction of the southern adjoining parking garage.

Several inches of aggregate base cover the majority of the site, but past aerial images do not show evidence of stressed vegetation. There are several nearby properties with documented groundwater contamination by chlorinated solvents, but do not appear to pose a significant risk to the site”. While there may be low concentrations of chlorinated solvents in local groundwater due to nearby releases, Condor considered the risk of subsurface vapor intrusion at the site to be low. Condor concluded that there are no recognized environmental conditions, historical recognized environmental conditions, or controlled recognized environmental conditions associated with the site. Condor recommends no further evaluation of the site for environmental concerns.65
62 Accessed at: https://geotracker.waterboards.ca.gov/, October 2022 63 Accessed at: https://www.envirostor.dtsc.ca.gov/public/ , October 2022 64 Langan, Phase I ESA, 2020, page 4 and pages 13-16
65 Langan, Phase I ESA 2020, page 16
Vantage Master Plan Project – CEQA Analysis page 122
Other Adjacent Properties
Based on Lagan’s review of the neighboring properties, most of the nearby listings were closed by the regulatory agency, were hydrologically cross gradient or down gradient, or were determined to be a significant distance (greater than a 1/4 mile) from the site.
• 317 E. Grand Ave – Former Grand Roebling Property: This property is subject to a Land Use Convent dated 1 January 2019. Based on the distance and gradient direction from the site, this location does not appear to pose an environmental risk to the site.
• 485 Cabot Road – Fluid Gauge Company: This property underwent active remediation until case closure in 2014. Due to the distance and the southwestern flow of groundwater, this location does not appear to pose an environmental risk to the site.
• 477 Forbes Blvd – Pacific Agri Products: This location is under active site assessment and is required to submit a Remedial Action Plan due to the presence of free products and contaminated soil in the subsurface. Due to the distance from the site and the groundwater beneath the location flowing away from the site, this location does not appear to pose a risk to the site. 66 Regulatory Requirements
Whereas an unknown amount of gasoline-impacted soil and groundwater remains in the subsurface at the 460 Forbes Boulevard site in the vicinity of the former underground storage tanks, and at adjacent property, the following regulatory requirement applies to this site:
❖ Project Requirement HAZ-3, Notification to San Mateo County Environmental Health Division: As required by the San Mateo County Environmental Health Division’s Case Closure letter, SMCEHD must be notified prior to any excavation or development of the 440 Forbes Boulevard property. The Project’s proposed change in land use or proposed soil or groundwater removal activity must be submitted to the SMCEHD-GPP for review, to determine whether residual contaminates may pose a risk to public health and the environment if the proposed activities are implemented.67 Based on this requirement for SMCDEH notification, the Project’s proposed change in land use and proposed soil removal will be reviewed to determine whether residual contaminates may pose a risk to public health and the environment.

Potential Risks to Public Health and the Environment
Soil Sampling and Results
Over the past two years, 12 soil borings have been taken throughout the Phase 2 and Phase 3 portions of the Project site (3 soil borings for an October 2020 geotechnical investigation, 3 soil borings for a November 2021 geotechnical investigation, and 6 soil borings for a September 2022 geotechnical investigation). Analytical results of the most recent soil samples indicate that some of the material present at the site do contain low levels of petroleum hydrocarbons, semi-volatile organic compounds (SVOCs), heavy metals and naturally occurring asbestos in the soil at the site:
• Of the petroleum hydrocarbons, TPHg, TPHd and TPHmo were detected above laboratory reporting limits. None of the detections of TPHg, TPHd or TPHmo exceeded their respective 2019 RWQCB commercial environmental screening levels (ESLs).
66 Langan, Phase I ESA 2020, page 17
67 San Mateo County Health Systems, Case Closure Summary, January 10,2013 Vantage Master Plan Project – CEQA Analysis page 123
• Trace concentrations of ten different SVOCs were detected in at least one of 18 different soil samples analyzed, but none of the SVOCs exceeded their respective 2019 RWQCB commercial environmental screening levels ESLs.
• No OCPs or PCBs were detected at or above the laboratory reporting limits in any of the soil samples analyzed.
• Total chromium was detected at or above the laboratory reporting limits in each of 18 samples analyzed. These samples were subsequently analyzed for STLC chromium to determine if soluble chromium levels exceed State of California hazardous waste criteria. STLC chromium was detected at or above the laboratory reporting limits, but below the State of California STLC hazardous waste criteria.

Total chromium was also detected and analyzed for TCLP chromium. TCLP chromium was not detected at or above the laboratory reporting limits. None of the STLC or TCLP chromium concentrations exceed the Class I non-RCRA State of California, or Class I RCRA federal hazardous waste thresholds. • Arsenic was detected at or above the lab reporting limits in each of the 18 samples analyzed, with all detections exceeding the commercial ESL. None of the detections exceeded applicable soluble testing criteria, and these detections are within normal background ranges found in the San Francisco Bay Area. • The remaining metal concentrations were also within normal background ranges found in the San Francisco Bay Area.
• Bedrock, consisting of sandstone, shale and serpentinite was encountered approximately between 2½ and 4 feet below ground surface in the northwestern corner of the Project site during the geotechnical investigations. The results of asbestos testing indicate concentrations of asbestos ranging from 0.25 to 3 percent, which exceeds the 2019 RWQCB ESLs for commercial and industrial land use.

The presence of these compounds poses soil management and potential health and safety issues that would be addressed as part of development activities at the Project site.

Regulatory Requirements
The following regulatory requirements will apply to the Project, based on the presence of non-hazardous waste petroleum hydrocarbon impacted soil, and naturally occurring asbestos:
❖ Project Requirement HAZ-4, Soil Reuse: As applied to all sites in San Mateo County where soil reuse is proposed, a technical work plan containing required compliance information must be submitted to County Environmental Health Services (SMCEHS) staff for review and approval. SMCEHS guidance pursuant to this requirement relates to the on-site reuse of non-hazardous waste petroleum hydrocarbon impacted soil on the same or contiguous property where it was generated. This guidance does not apply to hazardous waste, nor does it apply to the off-site reuse or disposal of soil, or the import of soil for construction or other uses.

Soil proposed for reuse must be approved by San Mateo County Environmental Health Services staff prior to placement. The standards applied pursuant to this process are designed to meet risk-based screening levels per RWQCB Screening for Environmental Concerns at Sites with Contaminated Soil and Groundwater, to demonstrate that the soil is inert as defined the California Code of Regulations with respect to the water quality objectives, and to be consistent with the RWQCB’s Characterization and Reuse of Petroleum Hydrocarbon Impacted Soil as Inert Waste. If, based on the information submitted, the reuse is approved by Environmental Health Services, County staff will issue a letter approving implementation of the soil reuse.

After implementation of the approved reuse, a letter must be submitted to Environmental Health Services Vantage Master Plan Project – CEQA Analysis page 124
by the registered professional in charge of the work certifying that the soil was reused in accordance with the approved scope of work.68
❖ Project Requirement HAZ-5, Asbestos Airborne Toxic Control Measures: Due to the presence of naturally occurring asbestos at portions of the Project site, those portions of the site are subject to Title 17 of the California Code of Regulations (17 CCR) Section 93105 – CARB Asbestos Airborne Toxic Control Measures (ATCM). The CARB Asbestos ATCM is enforced locally by the Bay Area Air Quality Management District (BAAQMD) and requires construction projects greater than one acre in size, in which naturally occurring asbestos (NOA), serpentinite or ultramafic rock is present, to prepare a site-specific Asbestos Dust Mitigation Plan (ADMP) for agency approval. The ADMP must specify dust mitigation measures to be initiated at the start and maintained throughout the duration of the construction and grading activity.

Project Plans Pursuant to Regulatory Requirements
Langan has prepared a Soil Management Plan (SMP) for the Project. The SMP presents analytical results of Langan’s subsurface investigations and recommends measures to mitigate any long-term environmental or health and safety risks caused by the presence of hazardous materials and/or contamination at the site. The SMP also contains contingency plans to be implemented during construction activities should unanticipated hazardous wastes be encountered. Construction activities will include soil handling, excavation and disposal. The SMP includes measures to mitigate potential risks to the environment and to protect construction workers, nearby employees, and pedestrians from potential exposure to hazardous substances that may be associated with unknown impacts. The SMP also provides a framework for managing soil during construction, and presents procedures for handling, management and disposal of impacted soil, if encountered. The following provides a brief summary of the conclusions of the SMP, and the measures anticipated to be required by SMCEHD pursuant to their notification requirement.

The SMP’s objectives for the site are to minimize exposure of potentially hazardous constituents in soil to construction workers, nearby office and R&D employees and/or pedestrians, and future users of the site. The routes of potential exposure could be through skin contact with the soil, inhalation of dust, and ingestion of the soil. The SMP is intended to facilitate compliance with applicable federal, state and local laws and regulations that are applicable to earthwork activities at the Project site due to reported petroleum hydrocarbon, SVOCs, heavy metals, and asbestos concentrations.

SMP Framework
The SMP provides a framework for managing soil during construction, and presents procedures for handling, management and disposal of impacted soil, if encountered. Specific provisions of the SMP address the following key topics:
• Proper health and safety procedures to minimize worker and public exposure to site contaminants during construction
• A Health and Safety Plan (HASP) to minimize worker and public exposure to site contaminants during construction
• Oversight of any soils handling and excavation of potentially impacted soil during building demolition and removal of concrete slabs
68 SMCEHS, Characterization and Reuse of Petroleum Hydrocarbon Impacted Soil, accessed at:
https://www.smchealth.org/sites/main/files/file-attachments/869705846soil_reuse.pdf Vantage Master Plan Project – CEQA Analysis page 125
• Soil handling procedures intended to support compliance with federal, state and local requirements, reduce the potential for off-site migration, and reduce the potential for exposure by construction workers, nearby workers and pedestrians to constituents in site soil and groundwater • Soil management and dust control measures to be implemented during earthwork activities to reduce the potential exposure of construction workers, off-site receptors, and future site users to constituents in the soil
• Dust control plans to reduce potential exposure during excavation and loading operations • Asbestos dust suppression to be implemented in accordance with the agency-approved Asbestos Dust Mitigation Plan (ADMP)
• Odor suppression measures as needed, to be implemented to minimize odor during excavation activities • Construction dewatering is not anticipated based on site development plans and the estimated depth to groundwater. If required, any construction dewatering must adhere to a discharge permit obtained from the South San Francisco Department of Public Works Water Quality Control Division, Environmental Compliance Program
• Contingency procedures for implementation during soil excavation, if unknown historical subsurface features and/or unanticipated hazardous materials are encountered • Preparation of a Soil Management Completion Report (Completion Report) subsequent to the completion of the site development’s soil handling and excavation activities Asbestos ATCM Compliance
Asbestos dust suppression measures will be implemented in accordance with the agency-approved Asbestos Dust Mitigation Plan (ADMP). Pursuant to that Plan, perimeter airborne asbestos monitoring will be conducted every day in which construction and grading activities occur. Typically, this includes one up-wind and two downwind monitoring locations. Based on air monitoring results, visual observations of fugitive dust and/or complaints of excessive dust generation by off-site parties, additional dust suppression measures may need to be implemented. At a minimum, the following dust mitigation measures must be initiated at the start and maintained throughout the duration of the construction or grading activity:
• Construction vehicle speed at the work site must be limited to 15 miles per hour or less • Prior to any ground disturbance, sufficient water must be applied to the area to be disturbed to prevent visible emissions from crossing the property line
• Areas to be graded or excavated must be kept adequately wetted to prevent visible emissions from crossing the property line
• Storage piles must be kept adequately wetted, treated with a chemical dust suppressant, or covered when material is not being added to or removed from the pile • Equipment must be washed down before moving from the property onto a paved public road; and • Visible track-out on the paved public road must be cleaned using wet sweeping or a HEPA filter equipped vacuum device within twenty-four hours
Per the Asbestos ATCM, the Project shall initiate the mitigation measures listed above at the start and maintain them throughout the duration of the construction earth-disturbing activity until the site is fully encapsulated with concrete or serpentinite fragments are no longer exposed at the surface (i.e., covered with hardscape and/or landscape).

Vantage Master Plan Project – CEQA Analysis page 126
Conclusion: Consistent with the findings of the SSF General Plan EIR, the Project would be required to comply with all applicable City, County, State and federal regulations related to development of a contaminated (or previously contaminated) site. These regulations minimize the risks associated with sites that are included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 that could create a significant hazard to the public or the environment (Checklist item Hazards-d) to a level of less than significant, and no additional mitigation is required.
e) Airport-Related Safety or Excessive Noise Hazards
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact HAZ-5) found that the city is located within the FAA Part 77 Sphere of Influence and within the boundaries of SFO Airport Influence Areas (AIA). Within the AIA (Area B), the ALUC C/CAG is responsible for reviewing proposed land development proposals. Depending on location, future development pursuant to the General Plan could expose people to safety hazards or excessive noise because of proximity to SFO. In accordance with the SFO ALUCP, the City would consult with the C/CAG and FAA when development applications for subsequent development in the vicinity of SFO are received, minimizing the exposure of people residing or working in the City to a safety hazard or excessive noise because of proximity to SFO. The general Plan EIR determined this effect to be less than significant.69 Project Analysis
As discussed in detail in the land Use section of this CEQA Checklist, none of the five safety zones associated with SFO applies to the Project site, and the Project would be consistent with land use safety criteria.

Additionally, the Project site is not located within any of the ALUCP-identified noise impact areas. Thus, the ALUCP land use noise exposure criteria do not apply to the Project and the Project would not be a safety hazard or exposed to excessive noise due to its proximity to SFO.

Conclusion: Consistent with the findings of the SSF General Plan EIR, the Project would not expose persons to aviation safety hazards or excessive noise (Checklist item Hazards-e), and no impact related to airport safety hazards would occur.
f) Interference with Emergency Response Plan or Emergency Evacuation Plan SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact HAZ-6) determined that implementation of the SSF 2040 General Plan would not impair implementation of, or physically interfere with an adopted emergency response plan or emergency evacuation plan. In the event of an evacuation, major freeways (including I-280 and US-101) can be used, and if major freeways are not available, potential alternative emergency evacuation routes include SR-82, Sister Cities Boulevard, Junipero Serra Boulevard, and East Grand Avenue. Buildout pursuant to the 2040 General Plan was not found to materially overburden any designated evacuation route or substantially impair any emergency response plans or emergency evacuation plans. Most of the development facilitated by the General Plan would be served by existing emergency evacuation routes, which have sufficient capacity to accommodate projected growth. Given the existing inter-jurisdictional programs that are already in place, and 69 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact HAZ-5, page 3.8-30 Vantage Master Plan Project – CEQA Analysis page 127
the City’s focus on maintaining and enhancing emergency management capacity and evacuation routes to protect life and property in the event of emergency, this impact was found to be less than significant.70 Project Analysis
The Project site is directly accessible from Forbes Boulevard to East Grand Avenue, which is a City-designated alternative emergency evacuation route, and which provides direct access to US-101. The Project would not interfere with this emergency evacuation route but would add an increment of additional traffic relying on this route in the potential event of an evacuation.

Conclusion: Consistent with the findings of the SSF General Plan EIR, the Project would not impair implementation of, or physically interfere with an adopted emergency response plan or emergency evacuation plan (Checklist item Hazards-f) and this impact is not considered significant.

Wildland Fires
See the Wildfire section of this CEQA Checklist for a full discussion of this topic.

CEQA Conclusion Pertaining to Hazards and Hazardous Materials Based on the analysis, findings and conclusions of the prior SSF 2040 General Plan EIR, implementation of the Project would not substantially increase the severity of any significant impacts related to hazards or hazardous materials as identified in that prior EIR. The Project would not result in new significant impacts related to hazards and hazardous materials that were not previously identified. The SSF 2040 General Plan EIR did not identify any mitigation measures related to hazards or hazardous materials that would apply to the Project, and no mitigation other than existing regulatory requirements would be needed. No further environmental review of the Project pertaining to the topics of hazards and hazardous materials is required. 70 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact HAZ-6, page 3.8-32 Vantage Master Plan Project – CEQA Analysis page 128
Hydrology and Water Quality
Would the Project:

SSF 2040
General Plan
EIR Findings
Relationship to SSF 2040
General Plan EIR Findings: Project Conclusions:

Equal or
Less Severe
New or
Substantial
Increase in
Severity
Applicable Standards
and Requirements
Resulting
Level of
Significance
a) Violate any water quality standards or
waste discharge requirements or
otherwise substantially degrade surface or
groundwater quality during construction
LTS  ☐ Project Requirement
Stormwater-1,
Construction General
Permit
Project Requirement
Stormwater-2, Erosion
Control
Project Requirement
Stormwater-3, Storm
Water Pollution
Prevention Plan
LTS w/ PRs
b) Violate any water quality standards or
waste discharge requirements or
otherwise substantially degrade surface or
groundwater quality during project
operations
LTS  ☐ Project Requirement
HYD-4, Provisions C.3 of
the NPDES Permit
LTS with PR
c) Substantially decrease groundwater
supplies or interfere substantially with
groundwater recharge such that the
project may impede sustainable
groundwater management of the basin
LTS  ☐ - LTS
d) Substantially alter the existing drainage
pattern of the site or area, including
through the alteration of the course of a
stream or river or through the addition of
impervious surfaces, in a manner which
would result in substantial erosion or
siltation, substantially increase the rate or
amount of surface runoff in a manner
which would result in flooding, create or
contribute runoff water which would
exceed the capacity of existing or planned
stormwater drainage systems; or impede
or redirect flood flows
LTS  ☐ Project Requirement
HYD-5, Potential
Hydromodification
LTS with PR
e) In flood hazard, tsunami, or seiche
zones, risk release of pollutants due to
project inundation
LTS  ☐ - No Impact
f) Conflict with or obstruct implementation
of a water quality control plan or
sustainable groundwater management
plan?
LTS
Vantage Master Plan Project – CEQA Analysis page 129
a) Water Quality during Construction
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact HYD-1) concluded that implementation of the 2040 General Plan would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality during construction.71
Future development (including redevelopment of existing developed sites) that disturbs one acre or more of soil or that is part of a common plan of development that disturbs one acre or more of soil must obtain permit coverage under the Construction General Permit by filing an NOI and SWPPP with the RWQCB prior to commencement of construction. The SWPPP must describe the site, the facility, erosion and sediment controls, runoff water quality monitoring, means of waste disposal, implementation of approved local plans, control of construction sediment and erosion control measures, maintenance responsibilities, and non-stormwater management controls. Inspection of construction sites before and after storms is also required to identify stormwater discharge from the construction activity and to identify and implement erosion controls, where necessary.

The General Plan includes policies and actions to protect water quality during project construction, and SSFMC contains rules and regulations to protect water quality during construction. SSFMC Section 14.04.180 identifies construction related BMPs to reduce pollutants entering the City storm sewer system, Section 14.04.132 and Section 14.04.133 requires all new development and redevelopment projects to minimize disturbance of natural water bodies and drainage systems, protect slopes and channels, and conserve natural areas, including existing trees, other vegetation and soils. Section 20.180.005 includes standards for the Flood Plain/SLR Overlay District including a bay access buffer, creek access buffers, using living vegetation and natural materials for levees and sea walls, employing low-impact stormwater runoff techniques, retaining 100 percent of drainage from impervious surfacing on-site, using a minimum of 80 percent native species in landscaping, requiring no net new impervious areas, and requiring the installation of fencing during construction to protect riparian areas. These regulations will assist in protecting water quality during construction. Section 20.310.002 includes grading and drainage requirements for all projects throughout the City, including submittal of a grading plan for any grading on a site with a natural slope of 15 percent or greater, and slope stabilization to control against erosion, which will also assist in protecting water quality during construction.

The General Plan EIR concluded that compliance with mandatory NPDES permit requirements, adherence to SSFMC requirements, and implementation of General Plan policies and actions would ensure that impacts related to water quality degradation from construction activities would be less than significant.

Dewatering
The General Plan EIR found that construction activities associated with future development, including excavation and trenching, may encounter shallow groundwater, and if shallow groundwater is encountered, dewatering of the excavation or trenching site may be required. In accordance with the General Waste Discharge Requirements for Extracted Groundwater from Structural Dewatering Requiring Treatment in the San Francisco Bay Region (Order #R2-2018-0026: General NPDES Permit No. CAG912004), any contaminated groundwater must be treated prior to discharge or disposed of at an appropriate disposal facility or wastewater treatment plant. Discharges of dewatered groundwater to a storm drain must be conducted in a manner that complies with the San Francisco Bay RWQCB Order #R2-2015-0049, Municipal Regional Permit (MRP). Consistent with California Water Code and the CWA, Section 14.08.290 of SSFMC regulates excessive, accidental and harmful discharges. In addition, Chapter 14.08 of SSFMC provides for the regulation of direct and indirect 71 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact HYD-1, page 3.9-27 Vantage Master Plan Project – CEQA Analysis page 130
dischargers to the to the publicly owned treatment works through the issuance of permits for certain nondomestic users and through enforcement of general requirements for all users.

Compliance with mandatory NPDES permit requirements and adherence to the South San Francisco Municipal Code would ensure that impacts related to water quality degradation from the discharge of dewatered groundwater would be less than significant.

Project Analysis
The Project would involve grading, excavation and removal of existing paved surfaces, buildings and vegetative cover that has the potential to result in runoff that contains sediment and other pollutants. These pollutants could degrade surface and groundwater quality if not properly controlled. Sources of potential pollution associated with construction include fuel, grease, oil and other fluids, concrete material, sediment and litter.

These pollutants have the potential to result in impacts due to chemical contamination from construction activities and materials that could pose a hazard to the environment or degrade water quality if not properly managed and controlled.

Regulatory Requirements
The State Water Board Stormwater General Permit for Construction Activity (Construction General Permit, as amended through 2012-0006-DWQ) applies to all construction activities that would disturb 1 acre of land or more. Construction activities subject to the Construction General Permit include clearing, grading, stockpiling, and excavation. Dischargers (including the Project’s construction activities) are required to eliminate or reduce non-stormwater discharges to storm sewer systems and other waters.

In SSF, the City’s program for prevention of non-point source pollution is implemented through the City’s Stormwater Management and Discharge Control Ordinance (Chapter 14.04 of SSFMC). The purpose of this chapter of SSFMC is to ensure the future health, safety and general welfare of the city of South San Francisco citizens by eliminating non-stormwater discharges to the municipal separate storm sewer; controlling the discharge to municipal separate storm sewers from spills, dumping or disposal of materials other than stormwater; and reducing pollutants in stormwater discharges to the maximum extent practicable. The following regulatory requirements apply to the Project. These regulations are specifically intended to prevent stormwater pollution during construction and provide for compliance with State and federal regulations. ❖ Project Requirement HYD-1, Construction General Permit: As a discharger associated with construction activity, the Project applicant shall file a Notice of Intent to comply with, and undertake all other activities required by the statewide General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities (Construction General Permit) for each subsequent phase of development.

Construction activity subject to this permit includes clearing, grading and disturbances to the ground such as stockpiling or excavation.
❖ Project Requirement HYD-2, Storm Water Pollution Prevention Plan (SWPPP): Whereas the Project is subject to the State’s Construction General Permit and NPDES requirements, the Project applicants shall submit and implement a Storm Water Pollution Prevention Plan (SWPPP) for each phase of construction, developed pursuant to the Construction General Permit. The Project applicant must prepare a SWPPP, and implement inspection, monitoring, and reporting requirements appropriate to the Project’s risk level as specified in the SWPPP. The SWPPP shall include:

1. A site map

2. A description of construction activities and potential pollutants Vantage Master Plan Project – CEQA Analysis page 131

3. Best management practices (BMPs) that will be employed to prevent soil erosion and discharge of other construction-related pollutants that could contaminate nearby water resources, such as petroleum products, solvents, paints, and cement

4. All NPDES permits also have inspection, monitoring, and reporting requirements ❖ Project Requirement Geo-2, Erosion Control: (see Geology section of this CEQA Checklist for details) The Project will comply with NPDES requirements for erosion and sediment control, will file a Notice of Intent with the State Water Board, and will prepare and implement a Project-specific Stormwater Pollution Prevention Plan. The Project would not disturb any natural water bodies or drainage systems, slopes, channels or natural areas. The Project is not located within the Flood Plain/SLR Overlay District and is not on a site with a natural slope of 15 percent or greater. SSFMC regulations pertaining to such sites would not apply.

Conclusion: Consistent with the conclusions of the SSF 2040 General Plan EIR, the Project’s effects related to potential violations of water quality standards or waste discharge requirements, or otherwise substantially degrading surface or groundwater quality during construction (checklist item Hydrology-a) will be fully addressed through implementation of existing regulations, and this impact would be reduced to less than significant.
b) Water Quality during Operation
SSF General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact HYD-1) concluded that implementation of the 2040 General Plan would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality during operations.
72 New development pursuant to the General Plan would add additional areas of impervious surface and could increase the volume of pollutants that are typically associated with urban runoff into the stormwater. These pollutants can include sediments, petroleum hydrocarbons, pesticides, fertilizers and heavy metals such as lead, zinc, and copper. Precipitation washes away most of these pollutants, resulting in high pollutant concentrations in the initial wet weather runoff. The amount and type of runoff generated by future projects could potentially be greater than under existing conditions. An increase in impervious surfaces could result in a corresponding increase in urban runoff pollutants and first flush roadway contaminants, as well as an increase in nutrients and other chemicals from landscaped areas. These constituents could result in water quality impacts to on-site and off-site drainage flows to area waterways.

The SSF 2040 General Plan includes policies and actions intended to protect water quality in and around the Planning Area. The South San Francisco Municipal Code also contains rules and regulations to protect water quality during operation. The SSF Climate Action Plan also includes actions that would protect water quality during operation. Future development pursuant to the General Plan would also be required to comply with the Clean Water Act (CWA) and regulations enforced by the RWQCB. With implementation of all regulatory requirements, the SSF 2040 General Plan EIR found that future development pursuant to the General Plan would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality. As such, implementation of the General Plan was found to result in a less than significant impact relative to this topic.
72 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact HYD-1, starting at page 3.9-29 Vantage Master Plan Project – CEQA Analysis page 132
Project Analysis
Phase 1 has already been entitled and is under construction and is subject to the regulations and policies that were in effect at the time of that prior entitlement. Phases 2 and 3 (the Project) will add new impervious surface area and will replace all of the remaining impervious surface at the site. The new and replaced impervious surfaces pursuant to Phases 2 and 3 could increase the volume of pollutants that are typically associated with urban runoff into the stormwater, as well as increase nutrients and other chemicals from landscaped areas.

These constituents could result in water quality impacts to off-site drainages and waterways, potentially including the Bay.

Regulatory Requirements
In May of 2022, the City of South San Francisco, together with the cities of Belmont, Brisbane, Burlingame, Daly City, East Palo Alto, Foster City, Half Moon Bay, Menlo Park, Millbrae, Pacifica, Redwood City, San Bruno, San Carlos, and San Mateo, the towns of Atherton, Colma, Hillsborough, Portola Valley, and Woodside, the San Mateo County Flood and Sea Level Rise Resiliency District, and San Mateo County (collectively referred to as the San Mateo Permittees) were reissued waste discharge requirements under the NPDES permit to discharge stormwater runoff from storm drains and watercourses (the Municipal Regional Stormwater permit, or MRP).73 Pursuant to Provision C.3 of this MRP, the permittees are to use their planning authorities to include appropriate source control, site design, and stormwater treatment measures in new development and significant redevelopment projects to address stormwater runoff pollutant discharges and prevent increases in runoff flows from new development and redevelopment projects. This goal is to be accomplished primarily through implementation of low impact development (LID) techniques. ❖ Project Requirement HYD-4, Provisions C.3 of the NPDES MRP Permit: Whereas the Project is a redevelopment project that creates and/or replaces 5,000 square feet or more of impervious surface, the Project is subject to Provision C.3 of the MRP. In South San Francisco, these NPDES MRP requirements are primarily implemented pursuant to the City’s Stormwater Management and Discharge Control Ordinance (Chapter 14.04 of SSFMC). The following regulatory requirements apply to each subsequent phase of the Project and are intended to prevent stormwater pollution during operations, and to provide for compliance with State and federal regulations:

1. Pursuant to SSFMC Section 14.04.134, the Project shall implement Low Impact Development (LID) requirements as specified in NPDES Permit No CAS612008 (the MRP) to reduce runoff, to mimic the site’s pre-development hydrology, and to treat stormwater. LID may include preserving and re-creating natural landscape features and minimizing imperviousness to create functional and appealing site drainage that treats stormwater as a resource. Practices used to adhere to these LID principles include measures such as rain barrels and cisterns, green roofs, permeable pavement, preserving undeveloped open space, and biotreatment through rain gardens, bioretention units, bioswales, and planter/tree boxes.

2. Pursuant to Section 14.04.133, the Project shall implement site design and stormwater treatment requirements for regulated projects to minimize stormwater runoff by implementing one or more of the following site design measures:
• Direct roof runoff into cisterns or rain barrels for reuse • Direct roof runoff onto vegetated areas
• Direct runoff from sidewalks, walkways and/or patios onto vegetated areas 73 California Regional Water Quality Control Board San Francisco Bay Region, Municipal Regional Stormwater NPDES Permit (Permit #CAS612008, Order #R2-2022-0018), May 11, 2022
Vantage Master Plan Project – CEQA Analysis page 133
• Direct runoff from driveways and/or uncovered parking lots onto vegetated areas • Construct sidewalks, walkways, and/or patios with permeable surfaces • Construct driveways, bike lanes, and/or uncovered parking lots with permeable surfaces

3. Pursuant to Section 14.04.180 (g), the Project shall implement source control measures consistent with the NPDES MRP, including:
• Storm drain stenciling—No Dumping-Flows to Bay
• Landscaping that minimizes irrigation and runoff, promotes surface infiltration where possible, minimizes the use of pesticides and fertilizers and incorporates appropriate sustainable landscaping practices and programs such as Bay-Friendly Landscaping • Appropriate covers, drains and storage precautions for outdoor material storage areas, loading docks, repair/maintenance bays and fueling areas
• Covered trash, food waste and compactor enclosures
• Plumbing certain discharges to the sanitary sewer, subject to the local sanitary sewer agency’s authority and standards

4. Pursuant to Section 20.300.007, the Project is required to prepare a soil management report and grading plan designed to reduce runoff.

5. Pursuant to Section 20.310.002, the Project must prepare drainage plans for any alterations of the slope or contour of the site’s existing drainage pattern in a manner that can assist in protecting water quality during operation.

Project Plans Pursuant to Regulatory Requirements
The Project’s design will include provisions for stormwater treatment of the impervious surface areas of the site.

This will include construction of stormwater treatment Best Management Practices (BMPs) such as bio-filtration areas, flow-through planters, and pervious pavers and pavements, among other acceptable stormwater BMP types. The stormwater BMPs will generally be distributed throughout the site and near the individual sources of run-off to the maximum extent practicable, rather than larger end-of-the-line BMPs. The Project’s design will include stormwater treatment BMPs included in each subsequent phase of construction, sized to treat the total amount of impervious surface at each phase.

Conclusion: Consistent with the conclusions of the SSF 2040 General Plan EIR, the Project’s effects related to potential violations of water quality standards or waste discharge requirements, or otherwise substantially degrading surface or groundwater quality during project operations (Checklist item Hydrology-b) will be fully addressed through implementation of existing regulations, and this impact would be reduced to less than significant.
c) Groundwater Supplies and Groundwater Recharge
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact HYD-2) concluded that new development pursuant to the 2040 General Plan would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge, and the General Plan would not impede sustainable groundwater management of the basin. 74 74 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact HYD-2, page 3.9-31 Vantage Master Plan Project – CEQA Analysis page 134
Development pursuant to the General Plan could lead to an increased demand for water, which could lead to an increase in groundwater pumping. Subsequent development pursuant to the General Plan could also result in an increase in impervious surfaces, which could reduce stormwater and rainwater infiltration. The General Plan includes policies and actions to maximize infiltration and rainwater retention and minimize impacts to groundwater recharge. The South San Francisco Municipal Code also contains rules and regulations to maximize stormwater infiltration and rainwater retention and minimize impacts to groundwater recharge. Future development pursuant to the General Plan would be required to comply with requirements of the South San Francisco Municipal Code and Zoning Ordinance, and the General Plan and Climate Action Plan policies and actions related to maximizing infiltration and rainwater retention. Therefore, future development pursuant to the General Plan was not found to substantially interfere with groundwater recharge or impede groundwater management of the basin, and this impact was determined to be less than significant.

Project Analysis
The Project is located on an urban area within the Visitation Valley Basin. The Visitation Valley Basin is considered a Very Low priority basin for water supply, with only approximately 3 wells, none of which is a water supply well.75 As such, the Basin is not subject to requirements of the California Sustainable Groundwater Management Act. The California Water Service (Cal Water) South San Francisco District supplies water to the City of South San Francisco and would serve the Project site. Groundwater makes up approximately 20 percent of the water supply for the South San Francisco District, which comes from the separate Westside Basin. 76 The Project site is currently developed with primarily impervious surfaces. At the completion of the previously entitled Phase 1 improvements currently under construction, the site will consist of approximately 79% impervious surfaces. Once the full Master Plan Project is completed and the landscape and storm drain system is installed, the post-Project conditions will actually increase pervious surfaces, with approximately 72% of the site as impervious surfaces. The Project’s new drainage system would include catch‐basins, stormdrain pipes, bio‐ retention areas, and flow‐through planters to capture, treat and discharge runoff from the entire site, generally maintaining the existing flow discharge pattern.

The Project would not extract groundwater or directly interfere with the groundwater table through construction activities on the site. The Project would comply with stormwater drainage requirements and is consistent with expected use of the site pursuant to the Basin Plan. The Project would not substantially deplete groundwater supplies or interfere substantially with groundwater recharge and would have a less than significant impact related to groundwater.

Conclusion: Consistent with the conclusions of the SSF 2040 General Plan EIR, the Project’s effects related to decreasing groundwater supplies or interfering substantially with groundwater recharge such that the Project may impede sustainable groundwater management of the basin (Checklist item Hydrology-c) is considered less than significant, and no mitigation is required.
d) Alter Existing Drainage Patterns
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact HYD-3) concluded that new development pursuant to the 2040 General Plan could substantially alter the existing drainage pattern of the area, including through the alteration of the 75 Groundwater Exchange, accessed at https://groundwaterexchange.org/ , October 2022 76 California Water Service (Cal Water), 2020 Urban Water Management Plan: South San Francisco District, available at:
https://www.calwater.com/docs/uwmp2020/SSF_2020_UWMP_FINAL.pdf. , June 2021 Vantage Master Plan Project – CEQA Analysis page 135
course of a stream or river or through the addition of impervious surfaces, in a manner which could result in substantial erosion or siltation on- or off-site, substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site, create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff, or impede or redirect flood flows.77
Development pursuant to the General Plan encourages infill development and discourages development on hillsides. However, new development or redevelopment that would be allowed under the General Plan could increase the total impervious area and increase stormwater runoff. Increased stormwater runoff could result in flooding, could exceed stormwater drainage facility capacity or create additional sources of polluted runoff (see Water Quality, above),
However, implementation of General Plan and Climate Action Plan policies and adherence to the requirements of the South San Francisco Municipal Code and Zoning Ordinance would maximize the on-site infiltration capacity for new development and redevelopment projects and would minimize the off-site runoff that would leave those project sites. Compliance with existing regulations and the General Plan policies would maximize stormwater infiltration and rainwater retention, which would in turn reduce stormwater runoff. Therefore, impacts related to surface water and flooding were found to be less than significant.

Project Analysis
Following completion of the previously entitled Phase 1 development and during construction of Phase 2 of the Master Plan, there will be a temporary condition where there are five buildings and two parking structures in some stage of completion, along with the completed temporary surface lots. Although temporary, this stage of development represents the site’s highest quantity of impervious surface, at 79% of the site, and will produce the most run-off.

The construction of Phase 3 will remove the large temporary surface parking lot to construct the remaining buildings, final parking structure and expansive amenity green space. This will ultimately result in a post-Project site impervious cover of approximately 72%.

Regulatory Requirements, Policies and Standards
Pursuant to the Municipal Regional Stormwater Permit (MRP) provisions C.3.g, projects that create and/or replace one acre or more of impervious surface are generally considered Hydromodification Management (HM) projects, and the volume of runoff from such sites is regulated such that increases in runoff flow and volume are be managed so that post-project runoff shall not exceed estimated pre-project rates and durations, where such increased flow and/or volume is likely to cause increased potential for erosion of creek beds and banks, silt pollutant generation, or other adverse impacts on beneficial uses due to increased erosive force. Exceptions to HM requirements apply to the following conditions.
• The post-project impervious surface area is less than, or the same as the pre-project impervious surface area.
• The project is located in a catchment that drains to a hardened (e.g., continuously lined with concrete) engineered channel or channels or enclosed pipes, which extend continuously to the Bay, Delta, or flowcontrolled reservoir, or in a catchment that drains to channels that are tidally influenced. • The project is located in a catchment or sub-watershed that is highly developed (i.e., that is 70 percent or more impervious).
77 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact HYD-3, page 3.9-33 Vantage Master Plan Project – CEQA Analysis page 136
According to Attachment C of the MRP, the Project site is located in a catchment area that drains to a hardened channel, and it therefore exempt from hydromodification measures.78 Increased runoff from the project is unlikely to cause increased potential for erosion of creek beds and banks, silt pollutant generation, or other adverse impacts on beneficial uses due to increased erosive force.

However, during the temporary period between end of construction of the previously entitled Phase 1 development and the start of Phase 3 of the Master Plan, the Project will generate the highest amount of runoff from the site, which is anticipated to exceed the pre-Project run-off volume. This increase in runoff may contribute on a cumulative basis to exceeding the capacity of the downstream storm drain system serving the site and surrounding areas. Accordingly, the Project will be subject to the following regulatory requirement:
❖ Project Requirement HYD-5, Potential Hydromodification: Pursuant to SSFMC Section 14.04.180 the director of Public Works may establish controls on the volume and rate of stormwater runoff from new developments and redevelopments. One of the purposes of required Low Impact Development (LID) is to reduce runoff and mimic a site’s pre-development hydrology. According, the Project’s design may require provision for hydromodification. If required, the Project shall install an underground hydromodification structure providing for underground detention. This strategy shall be designed to enable the Project’ runoff flows to meet City requirements for peak runoff reduction during each phase of the Project.

The Project’s design will include the installation of multiple stormwater detention facilities that reduce the peak runoff from the site by 15 percent, in keeping with City’s typical development conditions.

Conclusion: Consistent with the conclusions of the SSF 2040 General Plan EIR, the Project would incorporate BMPs and Low Impact Development standards (LIDs) into the Project’s design, thereby ensure that the Project does not result in a significant net increase in surface runoff. Therefore, the Project would not substantially alter the existing drainage pattern of the site or area in a manner which would result in substantial erosion or siltation, substantially increase the rate or amount of surface runoff, exceed the capacity of existing or planned stormwater drainage systems, or impede or redirect flood flows (Checklist item Hydrology-d). e) Flood and Tsunami Hazards
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact HYD-4) concluded that implementation of the General Plan could lead to new development being located in a flood hazard zone or tsunami zone, and could risk release of pollutants due to project inundation.79 Some areas of the City are located within the 100-year flood zone (primarily along Colma Creek, the navigable slough, San Bruno Creek, and the San Francisco Bay, and some areas of the Planning Area are located within the 0.2 percent annual chance flood hazard, or the “500-year flood zone,” (primarily within the East of 101 and the Lindenville planning sub-areas). Portions of the City that are low-lying are also susceptible to inundation by tsunami. These areas are primarily on the eastern side of the City and adjacent to San Francisco Bay.

The General Plan EIR determined that subsequent development, infrastructure and planning projects would be subject to General Plan policies and actions and SSFMC and Zoning Ordinance requirements, which reduce the risks of flooding to City residents and properties. Furthermore, federal and State agencies including the USACE and BCDC are responsible for maintaining flood protection features in the City. Therefore, the General Plan EIR concluded that the potential for loss, injury or death from impeding flood flows would be reduced to a less than 78 SFRWQCB, Municipal Regional Stormwater NPDES Permit, Attachment C, May 2022 79 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact HYD-4, page 3.9-38 Vantage Master Plan Project – CEQA Analysis page 137
significant level. Similarly, the General Plan EIR concluded that the risk of release of pollutants due to inundation would also be less than significant.

Project Analysis
As demonstrated on SSF 2040 General Plan EIR Exhibits 3.9-2 and 3.9-4 (see Figure 18), the Project site is not located within a 100-Year Flood Hazard Zone (1% Annual Chance Flood Hazard), a 500-Year Flood Hazard Zone (2% Annual Chance Flood Hazard), or a Tsunami Susceptibility location.

Conclusion: Consistent with the conclusions of the SSF 2040 General Plan EIR, the Project’s effects related to inundation hazards including flood hazard, tsunami or seiche zones, or risk release of pollutants due to Project inundation (Checklist item Hydrology-e) is considered less than significant. f) Conflict with Water Quality Control Plan or Sustainable Groundwater Management Plan SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact HYD-5) concluded that implementation of the General Plan would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.

Development facilitated by the General Plan would be required to comply with the CWA, the General Plan, the South San Francisco Municipal Code and Zoning Ordinance, and the mandatory NPDES permit requirements.

Therefore, future development would not violate any water quality standards or WDRs or otherwise substantially degrade surface or groundwater quality, in compliance with the San Francisco Bay Basin Plan, and implementation of the General Plan was found to result in a less than significant impact.

Additionally, the General Plan Update contains several policies and actions that would facilitate groundwater recharge by encouraging pervious surfaces in new developments and requiring projects to meet federal, State, regional and local stormwater requirements, including stormwater infiltration. The General Plan EIR concluded that implementation of the General Plan would not conflict with or obstruct implementation of a sustainable groundwater management plan and impacts would be less than significant.

Project Analysis
As discussed above, the Project would comply with applicable requirements of the General Construction Activity Storm Water Permit, the County of San Mateo’s Water Pollution Prevention Program, the City’s Stormwater Management and Discharge Control Ordinance (Chapter 14.04 of SSFMC) and the National Pollution Discharge Elimination System (NPDES), all of which are intended to implement relevant laws and plans related to water quality.

As also discussed above, the local groundwater basin is not required to comply with the Sustainable Groundwater Management Act. The Project would not extract or recharge a substantial amount of groundwater from the basin, would not introduce more intensive or water‐demanding uses than planned for the site, and would not otherwise conflict with Cal Water’s Urban Water Management Plan or groundwater management.

Conclusion: Consistent with the conclusions of the SSF 2040 General Plan EIR, the Project’s effects related to potential obstruction of a water quality control plan or sustainable groundwater management plan (Checklist item Hydrology-f) is considered less than significant.

Vantage Master Plan Project – CEQA Analysis page 138
Fig 18
Vantage Master Plan Project – CEQA Analysis page 139
Non-CEQA Sea Level Rise
As specifically noted in the SSF 2040 General Plan EIR, the appellate court of California has specifically held that an EIR need not contain an extensive analysis of sea level rise (SLR) or evaluate the potential impacts of SLR on a project. Therefore, the discussion included in the General Plan EIR related to site inundation from SLR was included for informational purposes, only.

The General Plan EIR identifies the projected SLR and coastal flooding by year 2100 along the coast of South San Francisco. A significant number of public facilities and infrastructure, buildings and other structures are likely to be affected based on a vulnerability assessment conducted by San Mateo County. Portions of US-101, Fire Stations 61 and 62, the former Oyster Point Landfill, Bay Trail, South San Francisco-San Bruno Water Quality Control Plant, and SFO are among the large public assets exposed to future SLR.

The General Plan EIR cites General Plan and Climate Action Plan policies, and SSFMC and Zoning Ordinance regulations that address SLR. These policies require the City to pursue a comprehensive shoreline management plan that uses a variety of adaptation solutions to protect the shoreline and enhance ecosystem resilience.

SSFMC and zoning regulations contain rules and regulations related to flood hazards and SLR that promote the public health, safety and general welfare, and minimize public and private losses due to flood conditions in specific areas by legally enforceable regulations pertaining to land within flood prone, mudslide or flood-related areas. The updated Zoning Ordinance also includes new construction requirements, building heights, bay access buffers, creek access buffers, elevation of lowest floor, utilities, site grading, levees and sea walls, stormwater runoff and drainage, landscape species, impervious areas, and riparian area protection for projects located within a new Flood Plain/SLR Overlay District.

Project Analysis
As demonstrated on SSF 2040 General Plan EIR Exhibits 3.9-3 (see Figure 19), the Project site is not located within an area susceptible to SLR under any of the year 2100 mid-level scenarios (100-year flood, 100-year flood plus 2040 SLR, or 100-year flood plus 3 feet of SLR). No SLR adaptation strategies are needed to reduce risks of SLR inundation at the Project site, as indicated in the General Plan EIR.

CEQA Conclusion Pertaining to Hydrology and Water Quality Based on the analysis, findings and conclusions of the prior SSF 2040 General Plan EIR, implementation of the Project would not substantially increase the severity of any significant impacts related to hydrology as identified in that prior EIR, nor would it result in new significant impacts related to hydrology that were not previously identified. The SSF 2040 General Plan EIR did not identify any mitigation measures related to hydrology that would apply to the Project, and no mitigation, other than existing regulatory requirements, would be needed.

Further environmental analysis of the Project pertaining to the topic of hydrology is not required, as the Project would not result in a substantial increase in the severity of hydrology and water quality impacts compared to the impacts identified in the General Plan EIR.

Vantage Master Plan Project – CEQA Analysis page 140
Fig 19
Vantage Master Plan Project – CEQA Analysis page 141
Land Use
Would the Project:

SSF 2040
General Plan
EIR Findings
Relationship to SSF 2040
General Plan EIR Findings: Project Conclusions:

Equal or
Less Severe
New or
Substantial
Increase in
Severity
Applicable Standards
and Requirements
Resulting
Level of
Significance
a) Physically divide an established
community LTS  ☐ - No Impact
b) Cause a significant environmental
impact due to a conflict with any land use
plan, policy, or regulation adopted for the
purpose of avoiding or mitigating an
environmental effect
LTS  ☐ Project Requirement
LU-1, Notice of
Proposed Construction
or Alteration
Project Requirement
LU-2, Obstruction
Evaluation/Airport
Airspace Analysis
LTs with PRs
a) Divide an Established Community
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact LU-1) concluded that implementation of the 2040 General Plan would not divide an established community. The General Plan found that implementation of General Plan policies and actions would support community connectivity rather than support development that could divide an established community. New development is anticipated to be primarily infill development and redevelopment of existing developed properties, which would not divide and established community. The General Plan EIR determined that the General Plan would not physically divide an established community. Impacts would be less than significant.80
Project Analysis
The Project is located in an urbanized area and surrounded by existing industrial and R&D properties and roadways. The project site does not act as a connection point between other properties. The Rails-to-Trails corridor immediately south of the Project does site provide for such connectivity, but the Project will not divide of segment this corridor.

Conclusion: Consistent with the conclusions of the SSF 2040 General Plan EIR, the Project would not involve any physical changes that would have the potential to divide an established community (Checklist item Land Use-a), and the Project would have no impact under this criterion. 80 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact LU-1, page 3.10-15 Vantage Master Plan Project – CEQA Analysis page 142
b) Conflict with Land Use Plan, Policy or Regulation
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact LU-2) concluded that implementation of the 2040 General Plan would not conflict with applicable plans adopted for the purpose of avoiding or mitigating an environmental effect. 81 • Future development pursuant to the General Plan would be required to demonstrate consistency with applicable federal, State, and local policies, including those mitigating or avoiding environmental impacts through the mechanisms of project permitting and approvals. • Plan Bay Area 2050 and the General Plan use similar growth projections, developed in consideration of each other. The General Plan Update would not conflict with Plan Bay Area 2050. • The General Plan requires conformance with land use compatibility standards of the Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport (ALUCP), ensuring that future development would be consistent with the ALUCP.

Project Analysis
As identified in the Project Consistency with the General Plan and Zoning section of this Initial Study/CEQA Checklist, the Project is consistent with Shape SSF 2040 (the General Plan Update) and its land use designation for the site. The Project’s proposed development intensity, assuming City acceptance of the Project’s proposed Community Benefits, is consistent with the General Plan’s permissible FAR. The Project does not present any inconsistencies with other Shape SSF 2040 General Plan Elements. Similarly, the Project is consistent with applicable Business Technology Park-High (BTP-H) zoning regulations that apply to the site. • Other sections of this Initial Study/CEQA Checklist demonstrate the Project’s consistency with applicable federal, State, and local policies, including those mitigating or avoiding environmental impacts through the mechanisms of project permitting and approvals.
• By demonstrated consistency with the General Plan, the Project would similarly not conflict with Plan Bay Area 2050.

ALUCP Provisions
The Project site is entirely within the SFO Airport Influence Area (AIA) and as such, the compatibility criteria contained within the ALUCP are applicable to the Project. As indicated below, the Project is consistent with the noise and land use safety criteria of the ALUCP. With required FAA clearance of future building heights, the Project would not conflict with plans and policies intended to protect and promote airport operations safety and/or airspace protection.

Land Use Safety
The ALUCP defines five safety zones within its AIA, and land use compatibility standards are established to restrict development of certain types of land uses that could pose particular hazards to the public or to vulnerable populations in case of an aircraft accident. None of the five safety zones associated with SFO apply to the Project site, and the Project would be consistent with land use safety criteria.

Noise
The ALUCP establishes boundaries within which noise compatibility policies apply. These boundaries depict “noise impact areas” or noise compatibility zones, defined by noise contours at the 65 dB CNEL, 70 dB CNEL, and 81 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact LU-2, page 3.10-18 Vantage Master Plan Project – CEQA Analysis page 143
75 dB CNEL contours. Noise compatibility policies apply to each noise impact area or contour. Commercial uses (e.g., offices and business) or industrial and manufacturing uses, and related structures are considered compatible without restrictions within all of these noise impact areas. The Project site is not located within any of the ALUCP-identified noise impact areas. Thus, the ALUCP land use noise exposure criteria do not apply to the Project and the Project is consistent with the ALUCP noise criteria.

Airspace Protection
The ALUCP includes plans and policies related to airspace protection. The criteria used in establishing these policies is based on the Code of Federal Regulations (CFR) 14, Safe, Efficient Use and Preservation of the Navigable Airspace (Part 77), which 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.

Pursuant to these federal regulations, the important FAA criteria as specifically pertaining to the Project site include the following:

Notice of Proposed Construction or Alteration: Pursuant to FAA Part 77 Subpart B, any new or altered structure with a height of greater than 200 feet above mean sea level (MSL) or exceeding an imaginary surface established at a slope of 100:1 from the runway, is required to prepare an FAA Form 7460-1, Notice of Proposed Construction or Alteration, and submit the notice to the FAA. These regulations apply to buildings and other structures or portions of structures, such as mechanical equipment, flagpoles and other projections that may exceed this elevation.
• With a ground surface of approximately 40 feet above MSL, any building at the Project site exceeding 60 feet in height would exceed the imaginary surface established at a slope of 100:1 from the runway and is subject to notice requirements.

Critical Aeronautical Surface: The ALUCP includes mapping that illustrates the critical aeronautical surfaces that protect the airspace required for multiple types of flight procedures (such as those typically factored into FAA aeronautical studies). These critical aeronautical surfaces depict the lowest elevations from all FAA-required obstacle clearance criteria to ensure safe separation of aircraft. Any proposed structures penetrating these critical surfaces are likely to receive a Determinations of Hazard from the FAA, and these surfaces indicate the maximum height at which structures can be considered compatible with Airport operations. The critical aeronautical surface within the Project site is between 500 and 550 feet above MSL. • The tallest proposed building pursuant to the Project is the 237-foot tall, 12-story Building C, which reaches a height of approximately 282 feet above MSL. This tallest proposed building does not exceed the Project site’s Critical Aeronautical Surface of approximately 500 feet above mean sea level, and the Project does not propose any new buildings or structures that would exceed critical aeronautical surface elevations. The Project is consistent with the critical aeronautical surface criteria of the ALUCP.

Potential Obstructions to Air Navigation: 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.” These imaginary surfaces rise from the primary surface (ground level at the SFO runways), and gradually rise along the approach slopes and sides of the runways. The FAA considers any objects that penetrate these imaginary surfaces as potential obstructions to air navigation. Obstructions may occur without compromising safe air navigation, but they must be marked, lighted and noted in aeronautical publications to ensure that pilots can see and avoid them. As indicated on Figure 20, the FAA Part 77 airport imaginary surface that defines potential obstructions to air navigation is established at a horizontal surface of 163.2 feet above MSL at the Project site. Buildings exceeding the height of this imaginary surface are subject to an aeronautical study prepared by the FAA (known as an Obstruction Evaluation/Airport Airspace Analysis), and a determination by the FAA that the building is “not a hazard to air navigation”.

Vantage Master Plan Project – CEQA Analysis page 144
Fig 20
Vantage Master Plan Project – CEQA Analysis page 145
• The Project’s proposed new Buildings C, D, E and F, and each of the three proposed parking structures all exceed a height of 163.2 feet above MSL (or an approximately 120-foot building height) and are required to be subject to an Obstruction Evaluation/Airport Airspace Analysis.

Regulatory Requirements
Pursuant to federal FAA regulations and the requirements of the Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport (ALUCP), the following regulatory requires are applicable to the Project:
❖ Project Requirement LU-1, Notice of Proposed Construction or Alteration: Pursuant to FAA Part 77 Subpart B, the Project applicant shall prepare and submit a Notice of Proposed Construction or Alteration to the FAA prior to construction of any proposed structures on the site pursuant to Phases 2 or 3. ❖ Project Requirement LU-2, Obstruction Evaluation/Airport Airspace Analysis: Pursuant to FAA Part 77 Subpart C, the Project applicant shall apply to the FAA for an Obstruction Evaluation/Airport Airspace Analysis for each of the Project’s Buildings C, D, E and F, and each of the three proposed parking structures.

Only upon FAA issuance of a determination of “no hazard to air navigation”, may construction of these structures commence.

Parking
The SSFMC establishes a parking ratio based on land use types, with 1.5 parking spaces per 1,000 square feet of R&D building space. At this ratio, the total parking allowance for the Project would be 2,422 spaces. The Project applicant seeks approval of a CUP that would enable an overall Project parking ratio of 2.24 parking spaces per 1,000 square feet of building space, yielding 3,701 parking spaces.

The Project’s proposed parking program is based on parking demand, with parking factors based on employee home-to-work commutes. Those assumed employee commutes are adjusted to reflect the Project’s requirements to implement a full Tier 4 TDM Plan, achieving up to a 50 percent reduction in drive-alone vehicle trips for the entire Project. The parking demand also recognizes the need for additional visitor parking, carpool parking and a reasonable “circulation factor”. The Project’s proposed parking program exceeds the City parking standards. However, the required TDM Plan and the Project’s trip cap would serve to reduce vehicle trips to acceptable levels, and the parking program would have no further environmental effects.

Conclusion: Consistent with the conclusions of the SSF 2040 General Plan EIR, the Project is required to demonstrate conformance with the standards of the Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport (ALUCP), ensuring that future development would be consistent with the ALUCP. With completion of all Project Requirements, including applying for an Obstruction Evaluation/Airport Airspace Analysis for each of the Project’s buildings and FAA issuance of a determination of “no hazard to air navigation”, the Project’s impacts pertaining to conflicts with City zoning and FAA regulations adopted to avoid or mitigate an environmental effect (Checklist item Land Use-b) would be less than significant.

CEQA Conclusions Pertaining to Land Use
Based on the analysis, findings and conclusions of the prior SSF 2040 General Plan EIR, implementation of the Project would not substantially increase the severity of any significant land use impacts as identified in that Program EIR, nor would it result in new significant impacts related to land use that were not previously identified. The prior Program EIR did not identify any mitigation measures related to land use that would apply to the Project and none would be needed.

Vantage Master Plan Project – CEQA Analysis page 146
Minerals
Would the Project:

SSF 2040
General Plan
EIR Findings
Relationship to SSF 2040
General Plan EIR Findings: Project Conclusions:

Equal or
Less Severe
New or
Substantial
Increase in
Severity
Applicable Standards
and Requirements
Resulting
Level of
Significance
a) Result in the loss of availability of a
known mineral resource that would be of
value to the region and the residents of the
state
No Impact  ☐ - No Impact
b) Result in the loss of availability of a
locally important mineral resource
recovery site delineated on a local general
plan, specific plan or other land use plan
No Impact  ☐ - No Impact
Loss of Important Mineral Resources
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Section 6.2.2) concluded that there are no mineral resource recovery sites within the City. The Aggregate Resource Sectors Map prepared by the California Geological Survey indicates that no property within the City is owned or controlled by aggregate producers. The Mineral Resource Zones map prepared by the California Geological Survey indicates that the majority of the City is located within Mineral Resource Zone-1, where no significant mineral deposits are present, or where it is judged that little likelihood exists for their presence. As such, the General Plan EIR determined that development pursuant to the General Plan would not result in the loss of availability of a known mineral resource of value to the region and residents of the State, and this impact was determined to be less than significant.82 Project Analysis
As there are no known important mineral deposits or active mineral extraction operations identified by the California Department of Conservation at the Project site.

Conclusion: Consistent with the findings of the SSF General Plan, the Project would not have an adverse effect on important mineral resources (Checklist items Minerals-a, or Minerals–b).

Based on the analysis, findings and conclusions of the prior General Plan EIR, implementation of the Project would not substantially increase the severity of any significant impacts on mineral resources as identified in that Program EIR, nor would it result in new significant impacts related to mineral resources that were not previously identified. The prior Program EIR did not identify any mitigation measures related to mineral resources that would apply to the Project and none would be needed.
82 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Section 6.2.2, page 6-2 Vantage Master Plan Project – CEQA Analysis page 147
Noise and Vibration
Would the Project:

SSF 2040
General Plan
EIR Findings
Relationship to SSF 2040
General Plan EIR Findings: Project Conclusions:

Equal or
Less Severe
New or
Substantial
Increase in
Severity
Applicable Standards
and Requirements
Resulting
Level of
Significance
a) Generate a substantial temporary
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
LTS  ☐ Project Requirement
Noise-1, Construction
Hours and Noise Limits
LTS with PR
b) Generate a substantial 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
N/A  ☐ - Less than
Significant
c) Generate excessive groundborne
vibration or groundborne noise levels LTS  ☐ - LTS
d) For a project located within the vicinity
of a private airstrip or an airport land use
plan or, where such a plan has not been
adopted, within two miles of a public
airport or public use airport, would the
project expose people residing or working
in the project area to excessive noise levels
No Impact  ☐ - No Impact
a) Temporary Construction Noise
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact NOI-1) concluded development and land use activities contemplated by the 2040 General Plan could generate a substantial temporary increase in ambient noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.

Construction activity can temporarily increase noise. The City has not adopted numeric thresholds of significance for construction noise. Construction noise is typically considered temporary in nature, intermittent and a normal part of living in a developed, urban area. However, the City has adopted mandatory requirements to ensure that construction noise remains less than significant. Compliance with mandatory requirements of SSFMC and General Plan policies will ensure that construction noise occurs only at appropriate times of day and is minimized to acceptable levels. Therefore, construction noise impacts were found to be less than significant.83 83 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact NOI-1, page 3.11-24 Vantage Master Plan Project – CEQA Analysis page 148
Project Analysis
Construction noise generated by the Project will vary based on the construction equipment used, the equipment location, and the timing and duration of the construction activities. The Project’s subsequent site preparation phases (at the beginning of Phase 2, Phase 3 and potential separate sub-phase for the Fire Station (to be constructed by the City) will include demolition, excavation and grading activities, and will generate among the highest noise levels (the Project does not expect to require impact or vibratory pile driving). Excavation machinery such as bulldozers, backhoes, front loaders, roller compactors, scrapers, and graders can typically generate noise levels of 80 to 85 dBA Lmax at distances of 50 feet from the operating equipment. Subsequent phases of construction activity would likely produce lower noise levels, typically in the range from 70 to 80 dBA at a distance of 100 feet from the center of the active construction work.

Generally, land uses that surround the Project site consist of other office/R&D facilities and light industrial uses.

However, immediately across the street at Allerton Avenue is the Genentech 2nd Generation pre-school, and the Cabot 2nd Generation pre-school and Early Years pre-school are only about 500 feet further to the south.

Regulatory Requirements
All construction activities within SSF, including the Project, are subject to the following regulatory requirements and General Plan policies:
❖ Project Requirement Noise-1, Construction Hours and Noise Limits: Pursuant to SSF Municipal Code Section

8.32.050, construction activities are limiting to the period between 8:00 a.m. and 8:00 p.m. on weekdays, between the hours of 9:00 a.m. and 8:00 p.m. on Saturdays, and between the hours of 10:00 a.m. and 6:00 p.m. on Sundays and holidays. An exception may be granted to these hours only if an application for construction-related exception is made to and considered by the City Manager or the City Manager’s designee. Construction noise must also meet at least one of the following noise limitations:

1. No individual piece of equipment shall produce a noise level exceeding 90 dB at a distance of twentyfive feet. If the device is housed within a structure or trailer on the property, the measurement shall be made outside the structure at a distance as close to twenty-five feet from the equipment as possible.

2. The noise level at any point outside of the property plane of the project shall not exceed 90 dB.

Most of the types of construction equipment likely to be used for Project-related construction would not generate more than 90 dB at 25 feet. However, certain types of construction activity (e.g., concrete mixer trucks, excavators and graders and jackhammers) that generate 85 dB at a distance of 50 feet could generate noise that exceeds 90 dB at a distance of 25 feet (assuming a standard practice increment of approximately 6 dB increase at one-half the distance from the source). Use of such equipment would occur at each individual construction site, which are set back from the property line by a distance of greater than 25 feet, therefore unlikely to exceed 90 dB at the property line. Construction noise attributed to the Project would be temporary, and the Project applicant and/or construction contractors will be required to obtain all necessary permits and to abide by all construction hours as stipulated by existing regulation and General Plan policy.

Conclusion: Consistent with the findings of the SSF General Plan EIR, the Project would be required to comply with all standards and regulations pertaining to construction noise. Construction noise would be temporary and would cease at the completion of the construction process. As such, the Project would not expose persons to a substantial temporary increase in ambient noise levels in excess of standards established in the General Plan or SSFMC (Checklist item Noise-a), this impact would be less than significant, and no additional mitigation is required.

Vantage Master Plan Project – CEQA Analysis page 149
b) Permanent Operational Noise
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR Impact NOI-1) also concluded that development and land use activities contemplated by the 2040 General Plan could generate a substantial permanent increase in ambient noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.84
For purpose of the General Plan EIR analysis, a substantial increase in noise was defined as a change of 5 dBA if the CNEL would remain below normally acceptable levels for a receiving land use, a change of 3 dBA or more if it causes the CNEL in the vicinity of the proposed project to exceed normally acceptable levels, and 1.5 dBA or more where the CNEL currently exceeds conditionally acceptable levels. In industrial areas of the City, a CNEL value of less than 75 dBA is considered “satisfactory”. • The General Plan EIR used the FHWA highway traffic noise prediction model (FHWA-RD-77-108) and traffic data prepared for the EIR to evaluate existing and future traffic noise conditions along modeled roadway segments. The resultant noise levels were weighted and summed over a 24-hour period to determine the CNEL values. The resulting noise levels were considered “normally acceptable” for all land use types. Therefore, the General Plan EIR determined this impact to be less than significant.85 • Future development projects would include new stationary noise sources such as parking lot activities and mechanical ventilation system equipment. These potential point sources of noise could affect noisesensitive receptors in the vicinity if they were to occur in areas adjacent to sensitive receptor land uses.

Therefore, the General Plan EIR identified mitigation as required to reduce this potential impact. With implementation of these Mitigation Measures, impacts generated by future development projects were found to be reduced to less than significant levels.

Project Analysis
Operational Noise
The Project’s on-site office and R&D uses are not considered noise‐sensitive receptors and are not generators of substantial levels of operational off‐site noise. Typical noise sources include industrial-type indoor operations, parking garages, roof-mounted HVAC systems, and landscape maintenance, which may generate noise levels of approximately 60 dBA to 70 dBA Lmax at 50 feet. Such activities are typical within the East of 101 area and other surrounding office, R&D and industrial uses are not considered noise sensitive use. The types of operational noise generated by the Project that would generate Lmax noise levels of 60 dBA to 70 dBA at 50 feet would not exceed the “satisfactory” CNEL noise value of 75 dBA for other nearby commercial and industrial uses.

Regulatory Requirement
All new buildings within SSF, including the Project, are subject to the following regulatory requirement:
❖ Project Requirement Noise-2, HVAC Mechanical Equipment Shielding: Pursuant to SSFMC Noise Ordinance (Section 8.32.030), prior to approval of building permits the applicant shall submit a design plan for the project demonstrating that noise levels from operation of mechanical equipment will not exceed the exterior noise level limits for a designated receiving land use category. Noise control measures may include 84 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact NOI-1, starting at page 3.11-27 85 Note that none of the roadway segments analyzed in the General Plan EIR was located in the East of 101 area or in the vicinity of the Project.

Vantage Master Plan Project – CEQA Analysis page 150
but are not limited to the selection of quiet equipment, equipment setbacks, silencers, and/or acoustical barriers.

With implementation of these standards, noise impacts from the Project’s stationary operational equipment would result in a less than significant impact.

Fire Station Noise
The Project’s potential new fire station would be a source of new operational noise, including sirens from emergency vehicles, backup beepers, training activities and routine firehouse activities.

Most emergency vehicle sirens are rated at 123 dBA at 10 feet.86 Factoring an attenuation rate of approximately 6 dBA per doubling of distance from the fire station equates to a noise level of approximately 103 dBA at 100 feet. The duration of exposure to this peak noise level is estimated to last for 10 to 20 seconds, as emergency vehicles exit the fire station. Therefore, new and existing receptors within 100 feet of the fire station would be exposed to short-duration high noise levels for approximately 10 to 20 seconds for each emergency response event, and receptors along Forbes Boulevard in each direction (including the Project’s new R&D uses) would be subject to similar short-duration noise levels. According to SSFFD data, the current five fire stations in South San Francisco responded to 14,857 calls in year 2021, or an average of approximately 2,970 responses per station per year, or about 8 responses per day.87 Even at such high short-term noise levels, a combined period of 80 to 160 seconds per day (8 responses times 10 to 20 seconds each) would occur randomly, would be very shortterm, and would not substantially change the daily Ldn or CNEL noise levels in the vicinity of the fire station.

These intermittent siren events would not constitute a significant change in the existing noise environment.88 Other noise sources associated with a fire station would be backup beepers caused by firetrucks re-entering the firetruck bay (assuming a station design with back-in bays), firehouse activities, and training activities/fire fighter drills. Backup beepers can generate noise levels up to 79 dBA at 30 feet, or about 66 dBA at 100 feet. Like siren noise, back-up beeper noise would only occur occasionally, would be of a short-term duration, and would not substantially change the existing daily noise levels in the vicinity.

Routine firehouse actives that have the potential to generate stationary noise include personal gear checks and daily fire truck maintenance, and training activities/fire fighter drills (e.g., fire ladder drills, hose drills and physical fitness tests). These activities do not include the use of emergency sirens and would not generate noise that is greater than existing noise levels in the vicinity. Noise from firehouse activities would be a less than significant change in the existing noise environment.

Traffic Noise
Vehicle noise is a combination of the noise produced by the engine, exhaust, and tires. Due to the logarithmic nature of noise, the doubling of traffic volumes results in an increased noise level of 3 dBA. Based on the Federal Highway Administration (FHWA) community noise assessment criteria, this change is “barely perceptible”.

According to other recent traffic and noise studies in the area, Forbes Boulevard currently carries approximately 7,700 average daily trips (ADT), generating noise levels of approximately 73 dBA CNEL.89 The Project (at full buildout of approximately 1.655 million square feet) is projected to generate approximately 11,288 ADT. 86 https://www.fireapparatusmagazine.com/fire-apparatus/siren-limitation-training/#gref 87 https://www.ssf.net/departments/fire/fire-stations
88 Per SSFMC Section 8.32.050: Special Provisions, vehicle horns or other devices primarily intended to create a loud noise for warning purposes shall be used only when the vehicle is in a situation where life, health or property are endangered, and emergency response warning noises are exempt from the requirements of the Noise Ordinance. 89 SSF, Genentech Master Plan EIR, Table 14-4, 2017 and 101 Gull Drive Initial Study, page 40, October 2021 Vantage Master Plan Project – CEQA Analysis page 151
Conservatively assuming that all of this traffic will rely on Forbes Boulevard for access to the Project site, the Project’s increase in traffic would more double the existing traffic volumes on Forbes, resulting in an increase in traffic noise of approximately 4 dBA CNEL. However, this roadway is located in the business and technology park area of East of 101, where the adjoining land uses are not considered to be noise-sensitive uses.90 Therefore, the Project’s increase in traffic noise would not adversely affect sensitive land uses, and this impact would not be considered significant.

Conclusion: Consistent with the findings of the SSF General Plan EIR, the Project would be required to comply with all standards and regulations pertaining to operational noise. The Project would not expose persons to a substantial permanent increase in ambient noise levels in excess of standards established in the General Plan or SSFMC (Checklist item Noise-b), this impact would be less than significant, and no additional mitigation is required.
c) Groundborne Vibration
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact NOI-2) determined that implementation of the General Plan could result in generation of excessive groundborne vibration or groundborne noise levels. Construction activities and the operation of heavy trucks, buses and trains can produce vibration that may be felt by adjacent uses. 91 Of the variety of equipment used during construction, impact pile drivers produce the greatest groundborne vibration levels. Construction vibration levels from future development projects could exceed the FTA damage threshold criteria of 0.12 in/sec PPV. The General Plan EIR found that construction vibration sources can be mitigated to acceptable levels either at the source, or on the adjacent property using alternate equipment, adequate setbacks, or by digging temporary trenches between the source and the receptor. General Plan policies requires a vibration impact analysis for any construction activities located within 100-feet of residential or sensitive receptors that require the use of pile driving or other construction methods that have the potential to produce high groundborne vibration levels. These required site-specific analyses would identify measures such as setback requirements, use of alternate construction methods, or pre-emptive trenching to interrupt groundborne vibration transmission. These policies are applied to all construction permits and compliance is mandatory, ensuring that construction groundborne vibration impacts will not occur to a level that exceeds the General Plan policy thresholds. With compliance with mandatory requirements of the General Plan, construction groundborne vibration impacts were found to be reduced to acceptable (less than significant) levels.

Project Analysis
According to the geotechnical studies prepared for the Project, the recommended foundation system for structures at the Phase 2 and Phase 3 portions of the site are, “shallow foundation systems consisting of spread footings gaining support in the native medium dense to very dense sand and stiff to very stiff clay or bedrock beneath the fill. If the foundation and building loads are not sufficient to resist the seismic uplift loads, tie-down anchors may be used. The Phase 2 and Phase 3 structures may be supported on individual spread footings 90 According to the General Plan EIR, Table 3.11-7: Land Use/Noise Compatibility Matrix to Guide New Development, office buildings, R&D uses and professional offices do not have an exterior noise compatibility level. Noise compatibility levels are limited to private yards of single-family residential; multi-family residential and mobile home park outdoor common space area; hospital patio; park picnic area; school playground; and hotel and motel recreation areas. 91 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact NOI-2, page 3.11-32 Vantage Master Plan Project – CEQA Analysis page 152
and/or continuous strip footings bearing on native soil or bedrock”. 92 No pile driving or other construction
methods that have the potential to produce high groundborne vibration levels are anticipated for the Project, and the project would not expose persons to excessive vibration levels.

Conclusion: Consistent with the General Plan EIR, construction vibrations attributed to the Project would not generate excessive groundborne vibration or groundborne noise levels that exceed applicable thresholds (Checklist item Noise-c). This impact would be less than significant, and no additional mitigation is required.

Excessive Noise Levels from Airport Activity
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact NOI-3) concluded that future development pursuant to the General Plan could expose people residing or working in the area to excessive noise levels for projects 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. The City of South San Francisco experiences air traffic noise impacts due to its proximity to SFO. Future development could introduce noise-sensitive land uses to excessive aircraft noise levels if they 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 General Plan EIR recommended mitigation measures that would require using acoustic-rated wall and window assemblies at the receiving land use. The General Plan EIR concluded that implementation of mitigation measures would reduce the potential effect of airport activity noise to less than significant.

Project Analysis
The ALUCP establishes boundaries within which noise compatibility policies apply. These boundaries depict “noise impact areas” or noise compatibility zones, defined by noise contours at the 65 dB CNEL, 70 dB CNEL, and 75 dB CNEL contours. Commercial uses (e.g., offices and business) or industrial and manufacturing uses and related structures are considered compatible without restrictions within all of these noise impact areas. The Project site is not located within any of the ALUCP-identified noise impact areas. Thus, the ALUCP land use noise exposure criteria do not apply to the Project.

Conclusion: The Project would not expose people working in the area to excessive noise levels from a private airstrip, a public airport or public use airport (Checklist item Noise-d).

CEQA Conclusions Pertaining to Noise and Vibration
Based on the analysis, findings and conclusions of the prior General Plan EIR, implementation of the Project would not substantially increase the severity of any significant noise impacts as identified in that Program EIR, nor would it result in new significant noise impacts that were not previously identified. The prior Program EIR did not identify any mitigation measures related to noise that would apply to the Project and none would be needed.
92 Langan Engineering and Environmental Services, Inc., Geotechnical Investigation for Vantage Phases 2 and 3, October 17, 2022 (Appendix F)
Vantage Master Plan Project – CEQA Analysis page 153
Population and Housing
Would the Project:

SSF 2040
General Plan
EIR Findings
Relationship to SSF 2040
General Plan EIR Findings: Project Conclusions:

Equal or
Less Severe
New or
Substantial
Increase in
Severity
Applicable Standards
and Requirements
Resulting
Level of
Significance
a) Induce substantial unplanned population
growth in an area, either directly (for
example, by proposing new homes and
businesses) or indirectly (for example,
through extension of roads or other
infrastructure)
No Impact  ☐ - No Impact
b) Displace substantial numbers of existing
people or housing, necessitating the
construction of replacement housing
elsewhere
LTS  ☐ Project Requirement POP1, Commercial Linkage
Fee
LTS with PR
a) Population Growth
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact POP-1) concluded that future development pursuant to the General Plan would not induce substantial unplanned population growth. The General Plan anticipates approximately 14,312 net new housing units, for a projected 38,959 total housing units by 2040. The General Plan also anticipates approximately 42,297 net new employment opportunities, with a projected 137,557 total employment opportunities by 2040. This new growth would increase the City’s population by approximately 40,068 people.

The General Plan also found that under current and projected future conditions, the City provides more jobs than it has employable residents. These results indicate that the City is likely to experience intensified pressure for additional residential development to house the labor force of the City.

By virtue of the fact that the General Plan is the long-range blueprint for growth and development in the City, the additional population growth (housing and employment) would be considered planned growth. The City has supported urban growth and development that is served by infrastructure for more than 100 years, and accordingly, implementation of the General Plan would not result in indirect growth. The General Plan EIR found impacts related to unplanned population and employment growth to be less than significant.93 Project Analysis
As indicated in the Project Description, the Project’s new buildings are intended as build-to-suit facilities. The future tenant(s) of these buildings have not yet been identified, but it is anticipated that the buildings will likely to be occupied by a combination of R&D laboratories and/or corporate headquarters-type office space. As described in the Project description, employment at the Project site (inclusive of Phase 1, and Phases 2 and 3) is expected to include 1,899 lab-based employees, 4,036 office-based employees and 40 employees at the 93 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact POP-1, page 3.12-19 Vantage Master Plan Project – CEQA Analysis page 154
Amenity building, for 5,975 total employees. Of this total, nearly 1,240 employees are expected to occupy Buildings A, B and the Amenity Building in Phase 1, which are considered part of the baseline conditions of existing, under construction and/or previously entitled development. The additional 1,516 lab-based employees and 3,221 office-based employees, or 4,737 additional total employees are attributable to Phase 2 and Phase 3 of the Project. These 4,737 new employees represent about 11 percent of the employment growth anticipated under the General Plan. The new fire station anticipated to be provided at the project site is expected to employ an additional approximately 10 to 14 firefighters and staff.

Conclusion: Consistent with the findings of the General Plan EIR, the Project would not induce substantial unplanned employment growth in the City (Checklist item Population-a), and this impact would be less than significant.

Housing Displacement
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact POP-2) concluded that buildout of the 2040 General Plan would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere. The General Plan includes policies and actions to ensure that existing housing is appropriately protected, and additional housing is added to support future growth within the City. When the City receives development applications for subsequent development, those applications will be reviewed for compliance with the General Plan Update and the SSMC to ensure the displacement of housing or significant need for new housing does not occur. As such, the General Plan EIR concluded that development pursuant to the General Plan would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere, and impacts were found to be less than significant.94 Project Analysis
The Project is located in the industrial and business section of East of 101, where no residential uses currently exist. The Project would remove an existing warehouse but would not directly displace people or housing.

Regulatory Requirement
To offset the demand for affordable housing that is created by new commercial development, all commercial development in the City is required to comply with the following regulation:
❖ Project Requirement POP-1, Commercial Linkage Fee: In order to provide sufficient affordable housing to achieve the city’s goal of providing a full range of affordable housing options to residents of the city, developers of commercial development projects shall pay a commercial linkage fee.

Any commercial linkage fee shall be paid at the time of issuance of each building permit. Payment of this Commercial Linkage fee would offset the Project’s indirect pressure for additional residential development to house the labor force of the City.

Conclusion: Consistent with the findings of the General Plan EIR, the Project would not displace substantial numbers of existing people or housing, (Checklist item Population-b), and this impact would be less than significant.
94 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact POP-2, page 3.12-21 Vantage Master Plan Project – CEQA Analysis page 155
CEQA Conclusions Pertaining to Population and Housing
Based on the analysis, findings and conclusions of the prior General Plan EIR, implementation of the Project would not substantially increase the severity of any significant impacts related to population or housing as identified in that Program EIR, nor would it result in new significant impacts related to population or housing that were not previously identified. The prior Program EIR did not identify any mitigation measures related to population or housing that would apply to the Project and none would be needed.

Vantage Master Plan Project – CEQA Analysis page 156
Public Services
Would the Project:

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

SSF 2040
General Plan
EIR Findings
Relationship to SSF 2040
General Plan EIR Findings: Project Conclusions:

Equal or
Less Severe
New or
Substantial
Increase in
Severity
Applicable Standards
and Requirements
Resulting
Level of
Significance
a) Fire Protection LTS  ☐ Project Requirement
Public Services-1,
California Fire Code and
SSFMC Amendments
Project Requirement
Public Services-2,
Subdivision
Improvements
LTS with PR
b) Police Protection LTS  ☐ Project Requirement
Public Services-3, Public
Safety Impact Fee
LTS with PR
c) Schools, Childcare and Libraries
LTS  ☐ Project Requirement
Public Services-4, School
Impact Fees
Project Requirement
Public Services-5,
Childcare Impact Fees
Project Requirement
Public Services-6, Library
Impact Fees
LTS with PR
d) Parks
Would the Project increase the use of
existing neighborhood and regional parks
or other recreational facilities such that
substantial physical deterioration of the
facility would occur or be accelerated
Does the project include recreational
facilities or require the construction or
expansion of recreational facilities which
might have an adverse physical effect on
the environment
LTS  ☐ Project Requirement
Public Services-7, Parks
and Recreation Impact
Fee
LTS with PR
a) Fire Protection
Vantage Master Plan Project – CEQA Analysis page 157
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact PUB-1) found that implementation of the 2040 General Plan would not result in substantial adverse physical impacts associated with the provision of new or physically altered fire protection facilities, or the need for new or physically altered fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection.95
The General Plan EIR found that development and growth in the City would increase demand for fire protection services, and as the demand for fire protection services increases there may be a need to increase staffing and equipment to maintain acceptable service ratios, response times, and other performance standards. This would require existing fire stations to be able to accommodate the additional staff and/or equipment. If an existing fire station is at capacity for staffing, this could require an expansion of an existing fire station or construction of a new fire station, the construction of which could cause environmental impacts. The project-specific environmental impacts of constructing new or expanded fire protection facilities to support the growth anticipated under the General Plan could not be determined because the site-specific locations and designs of future new or expanded facilities were not known. However, fire protection facilities are allowed within the “Public” land use designation and are contemplated as part of the General Plan, which could include fire protection facilities. It can be expected that construction and operation of future new or expanded fire protection facilities would have similar impacts as would construction and operation of other types of new development. As the City proceeds with the construction of new or expanded fire protection facilities, those projects will be reviewed by the City for compliance with the policies and actions of the General Plan, SSFMC, and the mitigation measures referenced in other sections of General Plan EIR. Therefore, the physical effects on the environment from the construction of new or expanded fire protection facilities would be less than significant.

Furthermore, as the City receives development applications for subsequent development pursuant to the General Plan, those applications will be reviewed by the City of South San Francisco for compliance with policies and actions of the General Plan to ensure that fire protection services keep pace with new development. In addition, SSFMC would be reviewed when development applications are received, including Chapter 8.75, Public Safety Impact Fee, and Chapter 15.24, California Fire Code. Therefore, future development under the proposed project would not result in significant adverse effects related to fire protection services, and impacts would be less than significant.

Project Analysis
Enhanced Fire Protection Service Capacity
The existing Fire Station #62 located at 249 Harbor Way is the only fire station in East of 101 and is not in the closest proximity to the newer life sciences developments occurring alongside and north of the East Grand Avenue corridor. The location of this fire station cannot provide optimal response times to fires or emergencies that occur in this portion of the continually emerging business and technology center.

As part of the Project’s proposed Community Benefit program, the Vantage Campus Master Plan provides an opportunity to support the City’s efforts to establish a new fire station that can better serve the East of 101 area. The Vantage Master Plan identifies an approximately one-acre (38,066 gross square-foot) parcel in the northwestern corner of the Vantage Project site, near the intersection of Forbes Boulevard and Eccles Avenue.

The Project applicant will convey the parcel to the City and complete rough grading, and the City is anticipated to construct the fire station and associated improvements. The Project applicant intends to dedicate and deliver 95 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact PUB-1, page 3.13-22 Vantage Master Plan Project – CEQA Analysis page 158
the Public Benefits/Fire Station site to the City within the term of the Development Agreement. Improvements to be included under the Project as part of the Vantage Master Plan include:
• Site preparation and site remediation (as needed), grading and utility installation necessary for the Fire Station
• An approximately 9,600 square-foot (± 500 square feet) fire station building, large enough to accommodate one or two fire trucks and 10 to 14 firefighters and staff • Frontage improvements along Forbes Boulevard so that the site is accessible, with separate fire trucks and personal vehicles access, including a left turn lane going west on Forbes. If the City prefers not to provide a full curb cut along Forbes, a back entrance to the Fire Station for personal vehicles can be provided from the access road directly east of the proposed Fire Station site. • 15 parking spaces for employees and visitors, and all associated paving, landscaping, and other site infrastructure
A new fire station would increase service levels to existing uses in East of 101 (including the Project), as well as to the planned mixed-use development around the nearby Caltrain station.

This Initial Study/CEQA Checklist evaluates the Fire Station as part of the Project and as part of this environmental review. Consistent with the assumptions of the General Plan EIR, the fire station will have been reviewed by the City for compliance with the policies and actions of the General Plan, the SSFMC, and applicability of mitigation measures referenced in other sections of General Plan EIR. Based on the conclusions of this Initial Study/CEQA Checklist, the physical effects on the environment from construction of the new fire protection facility would be less than significant.

Fire Access
Primary emergency vehicle access is provided from Forbes Boulevard via a perimeter roadway that traverses the edge of the site and connects to parking garage access points. The perimeter road intersects Forbes Boulevard along the northern edge of the site. A right-in/right-out only access driveway is provided on the southeast edge of the site off of and onto Allerton Avenue, which can also be used for emergency access. Secondary access is also provided on Forbes Boulevard. These on-site roadways provide access for emergency vehicles, with access extended through drivable surfaces within the landscape (portions of the Promenade function as an emergency vehicle access lane, which is materially integrated within the space).

Regulatory Requirements
The following regulatory requirements apply to all new construction activity within South San Francisco, specifically intended to address fire protection services and fire access:
❖ Project Requirement Public Services-1, California Fire Code and SSFMC Amendments: Pursuant to Chapter

15.24 of SSFMC, the Project shall comply with all provisions of the California Fire Code 2019 Edition as published by the California Building Standards Commission, and as modified by the amendments, additions and deletions set forth in Section 15.24.020 Amendments, general. The SSF Fire Chief shall examine all building permit applications for the Project and shall indicate approval or disapproval thereof, based on applicable sections of the California Fire Code and other related statutes and ordinances. No certificate of occupancy shall be issued for the Project without the approval of the Fire Chief or the Fire Chief’s designated representative.
❖ Project Requirement Public Services-2, Subdivision Improvements: Pursuant to SSFMC Chapter 19.24, the Project’s proposed subdivision improvements shall include fire hydrants of a type and size approved by the Vantage Master Plan Project – CEQA Analysis page 159
Fire Chief with fire flow as approved by the Fire Chief, and a fire alarm system and alarm boxes of a type and at locations approved by the Fire Chief as applicable.

Conclusion: Consistent with the findings of the SSF General Plan EIR, the Project would be required to fully comply with all regulatory standards of SSFMC, including those standards identified in Title 15: Fire Code. These regulatory standards would reduce the Project’s potential effects on the provision of effective fire protection services (Checklist item Public Services-a) to a level of less than significant, and no additional mitigation is required.
b) Police Service
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact PSU-2) found that implementation of the 2040 General Plan would not result in substantial adverse physical impacts associated with the provision of new or physically altered police protection facilities, need for new or physically altered police protection facilities, the construction of which could cause significant environmental impacts in order to maintain acceptable service ratios, response times or other performance objectives for police protection. The General Plan includes policies and actions to ensure that police protection services keep pace with new development, and General plan Policy SA-16.4 requires the City to coordinate with the SSFPD to ensure public services can accommodate growth impacts of new development in the East of 101 area. The General Plan EIR found that future development pursuant to the General Plan would not result in significant adverse effects related to police protection services and impacts would be less than significant.96
Project Analysis
As identified in the Population and Housing section of this CEQA Checklist, the Project would result in estimated increase over baseline employment of as many as 4,737 new employees, representing approximately 11 percent of the approximately 42,297 net new employment opportunities forecast under the General Plan, and only about 3 percent to the projected 137,557 total employment opportunities by 2040. This increase in employment would not result in substantial adverse physical impacts associated with the provision of new or physically altered Police Department facilities or the need for new or physically altered police facilities. The Project would have a less than significant impact on police protection services and no mitigation measures are required.

Regulatory Requirement
The following regulatory requirements apply to all new construction activity within South San Francisco, specifically intended to address cumulative public safety services within the City:
❖ Project Requirement Public Services-3, Public Safety Impact Fee: Pursuant to SSMC Section 8.75.010, the Project is subject to the City’s public safety impact fee, intended to provide funding for adequate police and fire equipment, vehicles, and facilities to meet the broad range of needs of South San Francisco residents and employees, as established in the General Plan.

Conclusion: Consistent with the findings of the SSF General Plan EIR, the Project would be required to fully comply with all regulatory standards of SSFMC including public safety fees, these regulatory requirements would reduce the Project’s potential effects on the provision of effective police services (Checklist item Public Servicesb) to a level of less than significant, and no additional mitigation is required. 96 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact PUB-2, page 3.13-24 Vantage Master Plan Project – CEQA Analysis page 160
c) Schools, Libraries and Childcare
SSF 2040 General Plan EIR Conclusions
Schools
The SSF 2040 General Plan EIR (Impact PUB-3) found that implementation of the 2040 General Plan would not result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities, need for new or physically altered school facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives for schools. Development and growth in the City would increase demand for school facilities. However, schools within the SSFUSD are operating at approximately 65.7 percent of capacity. Therefore, as the demand for school services increases from the buildout of the General Plan, existing school facilities would be able to accommodate the additional students in existing facilities. As student enrollment increases, there will be an incremental increase in staffing and equipment needed to maintain acceptable service ratios and other performance objectives for schools. However, the incremental increase in staffing and equipment would not result in significant environmental impacts. Furthermore, as the City receives development applications for subsequent development, those applications will be reviewed to ensure that school facilities keep pace with new development, including payment of school impact fees per SB 50. The General Plan EIR concluded that future development would not result in significant adverse effects related to school facilities and impacts would be less than significant.97
Libraries
The SSF 2040 General Plan EIR (Impact PUB-4) found that implementation of the 2040 General Plan would not result in substantial adverse physical impacts associated with the provision of new or physically altered library facilities, need for new or physically altered library facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives for library facilities. Development and growth in the City would increase demand for library facilities. Although the new library at the Community Civic Campus can accommodate some of the increase in demand for library services from buildout of the proposed project, there may be an additional need to increase staffing and equipment to maintain acceptable service ratios and other performance objectives for library facilities.

However, this would require existing library facilities to be able to accommodate the additional staff and/or equipment. As the City receives development applications for subsequent development, those applications will be reviewed for compliance with the General Plan to ensure that library facilities keep pace with new development. In addition, new development would be required to pay library impact fees in accordance with Chapter 8.74 of the Municipal Code. Therefore, the General Plan EIR found that future development would not result in significant adverse effects related to library facilities and impacts would be less than significant.98 Project Analysis
The Project will contribute to cumulative increased demands for schools, libraries and childcare services in the city, proportional to the Project’s increased employment.

Regulatory Requirements
The following regulatory requirements apply to all new construction activity within South San Francisco, specifically intended to address cumulative public safety services within the City:
97 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact PUB-3, page 3.13-26 98 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact PUB-4, page 3.13-27 Vantage Master Plan Project – CEQA Analysis page 161
❖ Project Requirement Public Services-4, School Impact Fees: Pursuant to the requirements of California’s SB 50 requirements and California Education Code Section 17620, the Project is subject to the SSFUSD school impact fees to offset the costs of construction or reconstruction of school facilities. The City requires proof of payment of this fee to SSFUSD prior to building permit issuance. ❖ Project Requirement Public Services-5, Childcare Impact Fees: Pursuant to the requirements of Section

20.310 of SSFMC, the Project is subject to the SSF fee on new development based on the projected need for new or expanded childcare facilities, necessary to fund the new spaces and mitigate the increased demand for childcare generated by development.
❖ Project Requirement Public Services-6, Library Impact Fees: Pursuant to City Council Resolution 121-2020, the Project is subject to the SSF fee on new development based on the projected need for new or expanded library facilities.

Conclusion: Consistent with the findings of the SSF General Plan EIR, the Project would be required to fully comply with all regulatory requirements of SSFMC, including payment of applicable development impact fees.

These development fees reduce the Project’s contribution to cumulatively increased demands on schools, libraries and childcare services (Checklist item Public Services-c) to a level of less than significant, and no additional mitigation is required.

Parks
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact REC-1) found that implementation of the 2040 General Plan would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of these facilities would occur or be accelerated. Development would increase demand for parks and recreational facilities, and as the demand for parks and recreational facilities increases there may be a need to increase staffing and other resources to maintain existing parks and recreational facilities from their increased use. Additionally, as the demand for parks and recreational facilities increases there may be a need to expand existing parks and recreational facilities or construct new parks and recreational facilities to maintain acceptable service ratios. Future development applications will be reviewed for compliance with the policies and actions of the General Plan to ensure that parks and recreational facilities keep pace with new development. In addition, developers will be required to pay parks and recreation impact fees in accordance with SSFMC. The General Plan EIR concluded that future development pursuant to the General Plan would not result in significant adverse effects related to parks and recreational facilities, and impacts would be less than significant.99
Project Analysis
The Project’s new employees will contribute to cumulative increased demands for parks and recreation services in the city, proportional to the Project’s increased employment.

Regulatory Requirements
The following regulatory requirements apply to all new construction activity within South San Francisco, specifically intended to address cumulative parks and recreation facilities and services within the City:
❖ Project Requirement Public Services-7, Parks and Recreation Impact Fee: Pursuant to SSFMC Section 8.67, in order to provide sufficient funding to achieve the city’s goal of maintaining park service levels and 99 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact REC-1, page 3.13-30 Vantage Master Plan Project – CEQA Analysis page 162
providing adequate parks and recreational services and facilities to residents of the city, the project is required to pay the parkland acquisition fee and a park construction fee in order to mitigate its share of cumulative effects on parks and recreational services and facilities in the city.

These development fees reduce the Project’s contribution to cumulatively increased demands on parks and recreation services (Checklist item Public Services-d) to a level of less than significant, and no additional mitigation is required.

CEQA Conclusions Pertaining to Public Services
Based on the analysis, findings and conclusions of the prior General Plan EIR, implementation of the Project would not substantially increase the severity of any significant impacts related to public services as identified in that Program EIR, nor would it result in new significant impacts related to public services that were not previously identified. The prior Program EIR did not identify any mitigation measures related to public services that would apply to the Project and none would be needed.

Vantage Master Plan Project – CEQA Analysis page 163
Transportation
Would the Project:

SSF 2040
General Plan
EIR Findings
Relationship to SSF 2040
General Plan EIR Findings: Project Conclusions:

Equal or
Less Severe
New or
Substantial
Increase in
Severity
Applicable Standards
and Requirements
Resulting
Level of
Significance
a) Conflict with or be inconsistent with
CEQA Guidelines Section 15064.3,
subsection (b) re: VMT
SU  ☐ Regulatory Requirement
Transportation-1, TDM
Plan
LTS with PR
b) Conflict with a program, plan, ordinance
or policy assessing the circulation system,
including bicycle, and pedestrian facilities
LTS  ☐ - LTS
c) Conflict with a program, plan, ordinance
or policy assessing the circulation system,
including transit
LTS  ☐ -
d) Substantially increase hazards due to a
geometric design feature LTS  ☐ - LTS
e) Result in inadequate emergency access LTS  ☐ - LTS
a) Consistency with CEQA Guidelines Section 15064.3(b) - Vehicle Miles Traveled SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact TRANS-1) determined that future development and land use activities that occur within South San Francisco in a manner consistent with the Shape SSF 2040 General Plan would conflict or be inconsistent with CEQA Guidelines Section 15064.3(b). Development under the General Plan would result in new non-residential development throughout South San Francisco. Because the City is fully built out, any new development will consist of the redevelopment of parcels that contain existing businesses. The General Plan EIR explains that the City’s primary approach to accommodating growth is to locate new development in four planning subareas, including East of 101. Each of these subareas are well served by transit service and have good access to jobs, neighborhood amenities and health care facilities. However, the General Plan EIR concluded that the implementation of the General Plan would result in vehicle miles traveled (VMT) in excess of the City’s VMT threshold of 15% below the current regional average. 100 The SSF 2040 General Plan policies and SSFMC ordinances address VMT reduction by managing vehicle trips, and incentivizing transit use and active transportation. This includes GP Policy MOB-2-1 which calls for incorporating complete street improvements into all roadway and development projects; GP Policy MOB 3-1 which calls for promoting mode shift among employers; and GP Policy MOB 4-1 which calls for increasing substantially the proportion of travel using modes other than driving alone.

General Plan EIR Mitigation Measure TRANS-1 requires the City to implement its Transportation Demand Management (TDM) Ordinance and to impose a trip cap for high intensity employment uses in the East of 101 100 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact TRANS-1, page 3.14-35 Vantage Master Plan Project – CEQA Analysis page 164
Area. To further the intent of these policies, SSFMC Chapter 20.400 Zoning Code amendments adopt an update to the City’s TDM Ordinance, which requires certain larger development projects to implement a combination of TDM programs, services and infrastructure improvements.

Even with the General Plan policies and General Plan EIR mitigation measures related to the TDM Ordinance, East of 101 Area Trip Cap and parking requirements, the General EIR concluded that the City may not achieve the overall VMT threshold reduction level. The General Plan EIR cited 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 development, and 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 General Plan, The General Plan EIR concluded that no additional mitigation measures are available, and this impact was found to be significant and unavoidable.

Project Analysis
This Transportation section is based on information contained in the Fehr & Peers, Healthpeak Vantage Transportation Impact Analysis (TIA) of August 2023 (Appendix J).

Required TDM
Consistent with Mitigation Measure TRANS-1 of the General Plan EIR and SSFMC requirements, the Project will implement a TDM Plan (see Appendix K). Phase 1 temporarily qualifies that first phase of development as a Tier 3 project for the purposes of the TDM Ordinance. As a Tier 3 project, 40 points worth of TDM strategies are required to be implemented by Phase 1 development, to achieve a maximum of 60 percent of employees commuting via driving alone (single-occupant vehicle – or SOV) mode share. Each of the Tier 3 TDM measures for Phase 1 provides options to future employers and employees to allow use of non-auto modes, strategies to encourage carpooling, biking, walking, and transit use, and site design features to promote the same. This TDM strategy also includes all trip reduction measures that are mandatory for the Phase I Project, as included in section 20.400.004 of the South San Francisco Zoning Code. These measures would be monitored to demonstrate compliance with 60 percent SOV / 40 percent non-drive-alone mode share for Phase 1, as required by the ordinance. The Phase I project will implement each of the Phase 1 TDM measures listed in Table 14 at the time of occupancy of Phase 1 buildings.

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Table 14: Proposed TDM Measures
TDM Measure Points VMT Reduction Potential
Tier 3 Required Measures
50% transit pass subsidies and pre-tax transit benefits 7 0.8% to 2.8% Participation in Commute.org programs 5 4%
Carpool/ vanpool programs and parking 3 8%
Bicycle storage, showers, and lockers 2 2.7%
Designated TDM coordinator 1 Supportive
Bicycle and pedestrian-oriented site access 1 Up to 3%
Encourage telecommuting & flexible work schedules 1 Up to 5.5% Tier 3 Optional Measures
Enhanced shuttle commitment 10 0.5 to 2%
Active transportation gap closure Up to 6 Up to 2%
On-site pedestrian-oriented amenities 3 Up to 5%
On-site car share, and 2 Up to 0.1%
Bicycle repair stations 1 Supportive
Total: 42 (Tier 3) 15% to 30% (Tier 3)
Tier 4 Measures, to be finalized with Future Phases
Offer Parking Cash-out Incentive 10 Up to 12%
or:

Transit Capital Improvements Up to 6 Up to 0.6%
Bike Share Program 2 Up to 0.3%
Cash Incentives 1 Up to 3%
Additional Bicycle repair stations 1 Supportive
Total: 52 (Tier 4) 27% to 50% (Tier 4)
Source: Fehr & Peers, Healthpeak Vantage Transportation Impact Analysis, August 2023 Total VMT reduction is calculated using the equation: 𝑅𝑒𝑑𝑢𝑐𝑡𝑖𝑜𝑛 = 1 − [(1 − 𝐴) ∗ (1 − 𝐵) ∗ (1 − 𝐶)] where A, B, and C represent the percent reduction in VMT for a specific TDM Measure.

Based on the TDM Plan (Appendix K), these Tier 3 measures are capable of achieving at least 40 points pursuant to the City’s TDM Ordinance and are capable of reducing VMT for Phase 1 by 15 percent to 30 percent by shifting SOV drivers to alternative modes. The Phase I project must achieve a 40 percent non-drive alone (or 60 percent SOV) mode share to comply with the City’s ordinance. Existing drive alone (SOV) mode share for employees in South San Francisco is currently 80 percent. A 15 to 30 percent reduction from the baseline of 80 percent drive alone mode share would result in a drive alone mode share of 56 to 68 percent (or conversely a 32 percent to 44 percent SOV trip reduction). Thus, implementation of the Phase 1 TDM program has the potential to meet the trip reduction goal of a 60 percent SOV trip rate.

Beginning with Phase 2 development, the entire Project will be subject to Tier 4 TDM requirements (see also Appendix K). Projects subject to Tier 4 TDM plans require the following:

Vantage Master Plan Project – CEQA Analysis page 166
• increased TDM Strategy commitments, totaling 50 points rather than 40 points • targeted single-occupancy vehicle mode share decreases from 60 percent to 50 percent, and • additional monitoring, including driveway counts to monitor compliance with a site-specific trip cap The Project will leverage information concerning the most successful elements of the Phase I TDM Program to determine which additional measures are most appropriate and effective.

To meet Tier 4 requirements, subsequent phases of the Project will be required to implement additional measures, totaling 50 points. The following additional TDM measures are recommended for consideration for the Tier 4 requirements as part of an updated version of the TDM Plan for development of Phases 2 and 3:
• A parking cash-out program would provide up to 10 additional points, and would fully meet the additional point requirements under Tier 4
• Alternatively, the Project may choose to fund shuttle stop infrastructure (up to 6 points), participate in a bike share program (2 points), provide additional cash incentives for non-drivers (1 point) and provide an additional bicycle repair station (1 point), for a total of 10 points Either the parking cash-out program or a combination of the other Tier 4 measures listed above are capable of achieving 50 points pursuant to the City’s TDM Ordinance, are capable of reducing VMT by an additional 12 to 20 percent beyond that achieved by the Tier 3 TDM measures, and thereby achieving a total potential SOV reduction of between 27 percent and 50 percent by shifting SOV drivers to alternative modes. Based on a background drive alone mode share of 80 percent, these additional TDM measures pursuant the Tier 4 TDM Plan required of Project buildout are expected to lead to an overall drive alone mode share of between 40 to 58 percent, indicating that some combination of the above strategies will be sufficient to meet the Tier 4 drive alone mode share target of 50 percent. In addition, there may be an opportunity for further shuttle partnerships and shuttle service improvements in the future, which would have additional positive mode shift effects beyond these identified reductions.

Trip Cap
Consistent with SSF Transportation Impact Analysis (TIA) Guidelines, the Project will be subject to a Projectspecific trip cap that manages the number of peak direction vehicle trips that the Project generates during peak periods. The trip cap reinforces mode share for the Project as needed to attain TDM requirements, while providing some flexibility to accommodate fluctuations in employee density, daily variations in travel patterns, and anticipated levels of guest/visitor travel activity.

Based on a mix of laboratory and office land use as described in the Project description, the Project anticipates accommodating 5,975 employees at buildout. This represents employee density assumptions for 50 percent R&D uses and 50 percent office uses. Allowing for carpool and vanpool vehicles, visitors, loading activity and service vehicles, the peak period trip cap would be 3,823 vehicle trips, as shown in Table 15.

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Table 15: Calculation of Project Trip Cap
Trip Cap Factors Equation Trips
Total Employees (per Project Description, Table 4) 5,975 50% drive-alone rate for employees (50% x 5,975) = 2,987 Carpool/vanpool mode share, with 3 people per vehicle (12% x 5,975 /3 persons per vehicle) = 239 Visitors, Loading, and Service Vehicles 10% x 5,975 597 Peak Period Trip Cap 3,823
Source: Methodology per SSF Transportation Impact Analysis (TIA) Guidelines, 2022 At Project build out, the actual tenant mix may result in a different mix of office/R&D uses, which could result in a different employee count, thereby potentially triggering a recalculation of the Project’s trip cap. For illustrative purposes only, Table 16 shows various trip caps for different employment calculations based on a range of different land use mixes allowed under the existing zoning.

Table 16: Estimated Trip Cap at Build-Out: Various Employment Densities Office / R&D Mix 100% / 0% 75% / 25% 50% / 50% (Project) 25% / 75% 0% / 100% Total Employees 8,114 7,046 5,975 4,908 3,840
Employees Driving Alone 4,057 3,523 2,987 2,454 1,920
Employees Carpooling and
Vanpooling
325 282 239 196 154
Visitors, Loading, and Service
Vehicles
811 705 597 491 384
Total 5,193 4,510 3,823 3,141 2,458
Source: Fehr & Peers, Vantage TIA May 2023, Table 3.4
While Table 15 shows an appropriate trip cap based on the reasonable estimate for total employment based on the developer’s leasing data for its other buildings, once the Project buildings reach 50 percent occupancy, the developer will conduct annual monitoring as part of its TDM plan. The trip cap monitoring will include a trip cap calculation based on actual employment and driveway counts from 6:30 a.m. to 10:30 a.m., and from 3 p.m. to 7 p.m. for one week each year, to ensure that the total number of peak period trips does not exceed the trip cap listed above. Some measures may need to be adjusted, or additional measures identified in the TDM Plan may be implemented once the Project reaches a Tier 4 occupancy level threshold, in order to continue to maintain compliance with the TDM Ordinance.

Home-Based Work Trip VMT
Under City of South San Francisco Resolution 77-2020 and CEQA Guidelines Section 15064.3, subdivision (b)(1), a significant impact would occur if VMT for the Project were not at least 15 percent below the applicable baseline VMT.

The Project has been analyzed based on a metric of home-based work (HBW) VMT per employee. This metric follows the City’s guidelines and the California Governor’s Office of Planning and Research (OPR) guidance for measuring VMT for office projects and helps compare the Project’s relative transportation efficiency to the Vantage Master Plan Project – CEQA Analysis page 168
regional average baseline. The Bay Area’s regional average baseline for home-based work trips is 15.9 VMT per employee, as derived from the C/CAG Travel Demand Model. Therefore, a significant VMT impact would occur if the Project’s home-based work VMT per employee is higher than 13.5 home-based work trip VMT per employee (i.e., 15 percent below the existing regional average of 15.9). This threshold of 13.5 home-based work VMT per employee also applies to cumulative conditions.

The Project is located in a C/CAG Travel Demand Model’s Transportation Analysis Zone (TAZ) that has an existing average home-based work VMT of 15.7. This existing average VMT for the Project area exceeds the 13.5 homebased work VMT threshold. However, the Project is required to implement a TDM program that is expected to result in at least a 15 percent reduction in VMT for the Phase 1, Tier 3 TDM Plan; and between a 27 percent to 50 percent reduction in VMT for the Tier 4 TDM Plan as required for subsequent development phases of the Project. Based just on the minimum Tier 3 requirements, the TDM Plan will achieve at least a 15 percent reduction in home-based work VMT per employee, resulting in a home-based work VMT per employee of 13.3 (see Table 17). This is below the home-based work VMT threshold of 13.5, demonstrating a less than significant VMT impact. Full compliance with the City’s TDM Ordinance for a Tier 4 TDM Plan will require the Project to achieve a 50 percent drive-alone mode share, representing at least a 27 percent reduction in home-based work VMT per capita and resulting in a home-based work VMT per employee of 11.5 (see also Table 17).

Table 17: Project’s Home-Based Work VMT/Employee, with TDM Estimated HBW VMT/Employee
Bay Area Regional Average (Existing) 15.9
VMT Reduction Requirement 15%
Resulting Threshold (HBW VMT per employee) 13.5
Existing VMT at Project Site’s TAZ 15.7
Project with at least a 15% Reduction in VMT (per Tier 3 TDM Plan) 13.3 Project with at least a 27% Reduction in VMT (per Tier 4 TDM Plan) 11.5 Is Project VMT per employee lower than threshold (Tier 3/Tier 4) Yes/Yes To validate this conclusion, the C/CAG VMT Estimation Tool was used to estimate the Project-generated VMT rate using a combination of the Project’s location and details, as well as VMT mitigation measures that are included in the C/CAG model. The C/CAG VMT Estimation Tool applies the VMT reductions that are available under the model to determine whether the Project’s VMT/employee can be reduced to below threshold levels.

Per the C/CAG VMT Estimation Tool (as shown in Appendix L), the calculated results indicate a rate of 13.7 VMT/employee, which is similar to the 13.3 VMT/employee rate achieved for the Project under the Tier 3 TDM Plan requirements.

This analysis does not include trips attributed to the Fire Station. It is presumed the fire station’s emergency calls are exempt from VMT analysis, and that its employee-based trips are not so large as to materially affect this analysis. Furthermore, the primary purpose of the new fire station is to provide this emergency service closer to the business and technology land uses north of East Grad Avenue, thereby reducing trip length (and time) for emergency response to this area.

Regulatory Requirement
The SSF 2040 General Plan EIR relies on compliance with the TDM Ordinance of the South San Francisco Municipal Code Chapter 20.400 (Transportation Demand Management) to ensure that the Project implements Vantage Master Plan Project – CEQA Analysis page 169
the necessary measures to reduce its transportation impacts. Pursuant to this regulatory requirement, the Project would implement the following TDM measures:
❖ Regulatory Requirement Transportation-1, Implementation of a TDM Plan: Consistent with South San Francisco Municipal Code, chapter 20.400, new development including the Project will be required to implement a TDM Plan at a tier-level consistent with the size of the development.

1. Phase 1 is already approved and under construction. Based on the square footage of Phase 1 development, Phase 1 qualifies for a Tier 3 TDM Plan, required to achieve 40 points and achieving a 40 percent reduction home-to-work single-occupant vehicle trips.

2. At the initiation of Phase 2, additional measures will need to be incorporated into an updated version of the TDM Plan to achieve the 50-point criteria of Tier 4 requirements and achieve a 50 percent reduction in home-to-work single-occupant vehicle trips.

3. Annual monitoring must demonstrate that the Project achieves 50% of employees traveling by single occupancy vehicles and that the Project does not exceed its Project-specific Trip Cap.101 Conclusion: Consistent with the SSF 2040 General Plan EIR and the TDM Ordinance, the Project is required to include measures to reduce the number of drive-alone vehicle commute (home-to-work) trips to 50 percent.

This reduction in permitted vehicle trips will be established as a Trip Cap for the Project. The resulting Trip Cap is demonstrated as capable of reducing per-employee VMT to below threshold levels, such that the Project would not conflict with or be inconsistent with CEQA Guidelines Section 15064.3, subsection (b) regarding VMT (Checklist item Transportation-a), the Project’s VMT impact would be less than significant, and no additional mitigation is required.

Cumulative VMT
The General Plan EIR concluded that the City may not be able to achieve overall VMT reduction levels necessary to reduce cumulative VMT impacts associated with buildout of the SSF 2040 General Plan, citing uncertainty in the cumulative effectiveness of these measures as well as unknowns related to transit service levels, transportation technology and travel behavior. The General Plan EIR found that trip reduction policies, ordinances and EIR mitigation measures primarily apply to new development, and those existing land uses, and land uses that have already been approved and are under construction would generally not be affected. Because of the programmatic nature of the General Plan, the General Plan EIR concluded that cumulative VMT impacts would be significant and unavoidable. However, the General Plan’s trip reduction policies, TDM ordinance requirements and General Plan EIR mitigation measures do apply to the Project. The Project’s required TDM measures are capable of achieving Project-specific VMT reduction levels necessary to reduce its individual VMT impacts to less than significant, and the Project’s contribution to cumulative VMT impacts would be less than cumulatively significant.
b) Consistency with Bicycle and Pedestrian Plans and Policies SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact TRANS-2) concluded that future development would contribute to and increase the use of bicycle and pedestrian facilities in South San Francisco, which may have a significant impact on the environment. Implementation of the General Plan may additionally result in other private and public improvements throughout the City that have the potential for environmental effects related to bicycle and pedestrian facilities. Nevertheless, the General Plan EIR noted that the General Plan aligns with the existing 101 Fehr & Peers, Healthpeak Advantage TIA dated May 2023, Regulatory Requirement TRANS-1 Vantage Master Plan Project – CEQA Analysis page 170
Active South City Plan, which enhances bicycle and pedestrian facilities citywide, improves connectivity, and shortens walking and biking distances.102
The SSF 2040 General Plan adopts several policies that result in improving the bicycle and pedestrian network and supporting programs to increase bicycle and pedestrian travel. This includes GP Policy MOB-2-1, which calls for incorporating complete streets improvements into all roadway and development projects; Policy MOB-3-1, which calls for promoting mode shift among employers; and Policy MOB-5-2, which calls for enhancing access to the City’s trail network and trail facilities. Implementation of these policies, along with the City’s Transportation Demand Management (TDM) Ordinance (discussed below), was found to improve the bicycle and pedestrian network and support programs to increase transit, 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. Accordingly, any impacts to such programs were found to be less than significant.

Project Analysis
The Project is consistent with many of the policies that would support bicycle and pedestrian travel as outlined in the SSF 2040 General Plan and its EIR. The Project would not produce or contribute to deficiencies in existing bicycle or pedestrian facilities or conflict with adopted policies in adopted City plans. The Project would generate additional vehicle trips along existing sidewalks, bikeways and shuttle routes along streets such as Forbes Boulevard and Allerton Avenue and would generate new walking and bicycling trips on these streets. However, as the Project is only adding approximately 18-21 vehicles per minute to the surrounding street network, the Project would not adversely affect existing or planned bicycle or pedestrian facilities.

As part of Phase 1, the applicant has already completed Rails-to-Trails bicycle and walking trail improvements along the southern portion of the Project site. Additionally, the Project’s internal circulation network is designed to meet the needs of all roadway users including pedestrians and bicycles. Implementation of the Project’s TDM Plan will also include several bicycle and pedestrian strategies that would contribute to and increase the use of bicycle and pedestrian facilities. Specific bicycle and pedestrian improvements included in the Project include the following:
• The Project proposes a Class II buffered bikeway along the Forbes Boulevard corridor due to anticipated high vehicle volumes and speeds.
• The Project will provide safe and convenient bicycle parking per City code requirements, as well as showers, changing rooms and lockers. Phase I of the Project already includes 16 short-term and 54 longterm bicycle parking spaces across two bike rooms. An additional 247 bicycle parking spaces (73 Class 1 bicycle parking spaces in a dedicated bicycle parking room and in the parking garages, intended for employees, and 174 Class II bicycle parking spaces intended for visitors) will be provided in Phases 2 and 3, for 317 total bike parking spaces
• Phase I is designed with a well-lit pedestrian walkway between the two buildings for pedestrian convenience.
• Along the Project’s south frontage, bicycle access will be provided via the existing “Rails-to-Trails” Class I pathway that runs between Roebling Road and the Genentech campus. The Project will provide multiple on-site access pathways to provide direct connectivity to this Class I trail. 102 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact TRANS-2, page 3.14-41 Vantage Master Plan Project – CEQA Analysis page 171
• All bicycle and pedestrian facilities will be lit with appropriate lighting and will have wayfinding signage to direct cyclists and pedestrians to various locations within the site, as well as to Caltrain. • The Project has significantly funded the completion of the Rails-to-Trails pathway south of the Project site. The Project will establish pedestrian and bicycle connections from the Project site to existing bicycle lanes on Forbes Boulevard and Allerton Avenue, as well as to the existing Rails-to-Trails pathway south of the Project site.
• The Project will review opportunities to provide additional active transportation improvements designed to continue to close gaps in the bike and pedestrian network. • The Project will include an active, pedestrian-oriented commercial use (the Amenity building) to be oriented along the pedestrian walkways running through the Project site. • The Project will offer bicycle repair stations that will include a toolkit and air pump. The repair stations will be located within a designated secure area of a building to encourage bicycling and support employees and residents.
• The Project includes one crosswalk located east of the Amenity Building to connect the site to the Railsto-Trails pathway immediately south of the site. As the Rails-to-Trails facility provides the most direct route for pedestrians to the South San Francisco Caltrain Station, providing a high-quality point of access from the trail to the site is needed to encourage walking and bicycling behavior. Pedestrian access to the Rails-to-Trails facility will be designed to minimize walking distance, maximize visibility and promote pedestrian comfort.

The Project proposes to install new sidewalks on the north side of the site. However, west of the Project, there are no sidewalks continuing along Forbes Boulevard. In addition, there is no marked crosswalk. Pedestrians approaching the site along Forbes Boulevard may have to detour in order to cross and maintain sidewalk continuity. This represents a deficiency in pedestrian access to the site. ❖ Improvement Measure Transportation-2: The Project shall design and fund installation of one marked crosswalk at Allerton Avenue and Forbes Boulevard, as well as one at Eccles Boulevard and Forbes Boulevard.103
❖ Improvement Measure Transportation-3: The Project shall provide additional contributions toward completion of the Rails-to-trails facility to provide a seamless connection to Caltrain. The existing Rails to Trails facility terminates before it reaches Forbes Boulevard. As a result, users of the facility must travel on Roebling Road and cross Grand Avenue at either Forbes Boulevard or Gateway Boulevard. These crossings cover long distances and signal cycle times are long, resulting in long waits for pedestrians. The City’s planned Rails-to-Trails pathway, however, would connect across Forbes Boulevard and follow the north side of Grand Avenue, before connecting to the Caltrain Station via a connection from the north side of Grand Avenue to Poletti Way.104
By implementing Improvement Measures Transportation-2 and Transportation-3, the Project would contribute toward advancing the City’s bicycle and pedestrian goals. The Project’s effects under cumulative 2040 conditions would be similar to that of existing conditions.
103 Fehr & Peers, Healthpeak Advantage TIA dated August 2023, Improvement Measure TRANS-1 104 Fehr & Peers, Healthpeak Advantage TIA dated August 2023, Improvement Measure TRANS-3 Vantage Master Plan Project – CEQA Analysis page 172
Conclusion: Consistent with the conclusions of the General Plan EIR, the Project will not conflict with any City plan, ordinance or policies addressing the circulation systems bicycle and pedestrian facilities (Checklist item Transportation-b), the Project’s impact would be less than significant, and no additional mitigation is required. c) Consistency with Transit Plans and Policies
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact TRANS-3) concluded that future development pursuant to the General Plan would not conflict with a program, plan, ordinance or policy regarding transit facilities, and would not decrease the performance or safety of such facilities in a manner that may have a significant impact on the environment.105
Future development pursuant to the General Plan would increase use of transit service and transit facilities in South San Francisco. Adding new residents and jobs near transit will increase the number of destinations that can be easily served via transit. Pairing transit-oriented development with improvements to transit access and street designs supports ridership growth for rail, bus, shuttle and ferry services. The General Plan EIR concluded that increased demand for transit is beneficial to the environment and does not constitute an impact.

Project Analysis
The Project would not produce a detrimental impact to existing transit facilities or conflict with adopted policies in adopted City plans. The Project would not include features disrupting existing or planned transit routes or facilities. The Project’s driveways would not cause disruptions to existing or planned transit services or transit stops. The Project may add net new transit trips to both Caltrain and Commute.org shuttles and trips on private shuttles, but transit operators are expected to scale their services with the level of demand associated with this Project and other developments in the East of 101 area. The Project’s impact to transit is less than significant under Existing plus Project conditions, and the Project would not be a cumulatively considerable contributor to significant cumulative impacts under Cumulative plus Project conditions.

The Project is consistent with many of the policies that would support transit as outlined in the SSF 2040 General Plan and its EIR. The Project provides direct access to sidewalks and bicycle facilities that connect to local shuttle stops as well as the South San Francisco Caltrain station. Implementation of Improvement Measures Transportation-2 and Transportation-3 (see above) would improve pedestrian and bike access between the Project site and existing/future transit stops and would be consistent with relevant City plans and policies. The Project’s required Trip Cap will reduce the number of allowed single-occupant commuters, effectively directing these commuters towards alternative transit modes instead. Implementation of the Project’s TDM Plan will also include transit-oriented strategies that would lead to increased demand for transit, including the following:
• The Project will offer public transit passes or subsidies equivalent to at least 50% of the cost of a monthly two-zone Caltrain pass to incentivize transit use. This may be implemented lease terms obligating employers to provide said subsidies.
• The Project will partner with Commute.org to provide TDM marketing services and promotions. Key services that the Project will participate in include the Commute.org ride-matching program (designed to aid in carpool and vanpool formation), funding of shuttle services connecting East of 101 with regional transit, Guaranteed Ride Home services, a try transit program, bicycle and vanpool incentives, and general educational and promotional programs and materials. 105 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact TRANS-3, page 3.14-44 Vantage Master Plan Project – CEQA Analysis page 173
• The Project will partner with Genentech to contribute additional funding to allow employees working at the Project to utilize the last-mile Genenbus shuttles. Under future phasing, a shuttle stop will be provided on Forbes Boulevard adjacent to the Project site. The final location of the proposed shuttle stops, including the proposed infrastructure, will be determined based on shuttle routing and service following initiation of Phase II construction.

Other transit based TDM measures that will be considered pursuant to the Phase 2 and Phase 3 development (which requires additional TDM beyond the initial Tier 3 Plan), may include:
• funding infrastructure supporting shuttles serving the site, such as high-quality transit shelters, bulbouts and boarding islands, or dedicated transit loading zones, including wayfinding signage • Provide cash incentives to employees who commit to using transit, or for new carpools and vanpools.

This may include providing a cash / gift card award for new vanpoolers or carpoolers, individuals who pledge to bicycle to work at least twice a week, or new transit users.

Conclusion: Consistent with the conclusions of the General Plan EIR, the Project will not conflict with any City plan, ordinance, or policies addressing the transit system (Checklist item Transportation-c), this impact would be less than significant, and no mitigation is required.
d) Substantially Increase Transportation Hazards
SSF 2040 General Plan EIR Conclusions
The SSF General Plan EIR (Impact TRANS-4) determined that implementation of the General Plan would modify the existing transportation network to accommodate existing and future users, which could change travel patterns or traveler expectations. For example, the General Plan EIR explains that General Plan implementation would increase vehicle trips on City freeway ramps, which could exacerbate vehicle queues on ramps already in excess of their storage capacity. 106
The General Plan EIR identified several policies that would reduce the impacts to transportation patterns. This includes completing 25 circulation improvements. For example, Policy MOB-2-1 calls for incorporating complete street improvements into all new development projects and Policy MOB-5-1 calls for expanding the City’s lowstress bicycle and pedestrian network. Mitigation Measure TRANS-4 requires the City to work with Caltrans to develop improvement measures for freeway off-ramps and adjacent intersections that help manage off-ramp queues.

Nevertheless, even with mitigation implemented, given uncertainties around specific operational conditions and the ability to mitigate those conditions, implementation of the General Plan could result in significant and unavoidable impacts causing traffic hazards.

Project Analysis
The Project would increase vehicle trips on City freeway ramps, which could exacerbate vehicle queues on ramps already in excess of their storage capacity, thereby contributing to these significant and unavoidable impacts. Fees paid by the Project will be used by the City to develop roadway infrastructure improvement that directly address traffic impacts, including exacerbating vehicle queues on freeway ramps that are already in excess of their storage capacity and that may be exacerbated by the Project. Further, the Project will conform to several of the General Plan’s transportation policies, including Policies MOB 2-1 and 5-1, which require the development of complete streets and the expansion of the City’s bike and pedestrian network, respectively. The 106 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact TRANS-4, page 3.14-48 Vantage Master Plan Project – CEQA Analysis page 174
Project’s internal circulation network will be designed to provide complete streets that accommodate both pedestrians and bicyclists, as well as vehicle traffic. The Project applicant has already completed improvements to a portion of the Rails-to-Trails network on the southern portion of the Project site. With payment of traffic fees and implementation of complete street designs on Project roadways, the Project will not exacerbate the previously identified transportation hazard impacts that were identified in the General Plan EIR.

The new driveways along both Forbes Boulevard and Allerton Avenue would not change the geometry of the adjacent roadways. As the Project is expected to increase pedestrian and bicycle trips at the driveways along Forbes Boulevard and Allerton Avenue, it may increase risk to pedestrians and bicyclists. Any future vegetation located within the sight triangles at the driveways would be maintained so as not to restrict drivers’ sight distance when exiting the driveway. Sight distance at the proposed driveway locations is expected to be adequate for drivers exiting the Project site and for pedestrians crossing the driveways.

The Project would not include any uses that are incompatible with the surrounding land use or the existing roadway system. Therefore, the Project is not expected to result in a substantial increase to hazards, and the Project’s impacts to hazards would be less than significant under Existing plus Project conditions, and less than cumulatively considerable under Cumulative plus Project conditions. No mitigation is required.

Regulatory Requirements
❖ Project Requirement Transportation-4: The Project is required to provide fair share contributions to the City’s Overpass Contribution Fee and Transportation Impact Fee programs. These contributions will be used to fund infrastructure promoting walking, bicycling and transit, and promoting the City’s General Plan policies.107
❖ Project Improvement Measure Transportation-5: Any future vegetation located within the sight triangles at the driveways are to be maintained so as not to restrict drivers’ sight distance when exiting the driveway.108 Conclusion: Consistent with the conclusions of the General Plan EIR, the Project will not substantially increase hazards due to a geometric design feature or other transportation hazard (Checklist item Transportation-d), this impact would be less than significant, and no mitigation is required. e) Emergency Access
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact TRANS-5) acknowledges that General Plan implementation will alter land use patterns and increase travel demand in the City. The proposed circulation improvements identified in the General Plan would improve connectivity and promote emergency access.109 In addition to the previously identified General Plan policies, such as Policy MOB-2-1 calling for complete streets, General Plan Policy SA-16.4 calls for coordination with the City Fire and Police Departments to ensure that public services can accommodate growth in East of 101. These policies will ensure adequate emergency access across the City. The General Plan EIR recognizes that the implementation of the City’s TDM Ordinance will reduce the amount of VMT generated by new development and, thus, reduce traffic congestion which will inherently improve emergency access. The EIR concludes that, following implementation of these measures, impacts to emergency access will be less than significant.
107 Fehr & Peers, Healthpeak Advantage TIA dated August 2023, Mitigation Measure TRANS-1 108 Fehr & Peers, Healthpeak Advantage TIA dated August 2023, Mitigation Measure TRANS-2 109 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact TRANS-5, page 3.14-50 Vantage Master Plan Project – CEQA Analysis page 175
Project Analysis
Vehicle trips generated by the Project represent a small percentage of overall daily and peak hour traffic on roadways and freeways in the study area. The Project would generate about 20 to 22 vehicle trips per minute on average during peak hours, which is not expected to introduce or exacerbate conflicts for emergency vehicles traveling near the Project. The Project would not include features that would alter emergency vehicle access routes or roadway facilities. Fire and police vehicles would continue to have access to all facilities around the entire City. Emergency vehicles would have full access to the Project site from all driveways connecting to adjacent streets, and each driveway would be equipped to handle all types of emergency vehicles. Therefore, the Project would result in adequate emergency access, and the Project’s impacts to emergency access would be less than significant under Existing plus Project conditions and less than significant under Cumulative plus Project conditions.

The Project applicant is proposing to dedicate to the City as a community benefit a one-acre parcel so that the City may construct a 9,600 square foot fire station to serve the East of 101 Area. This would improve fire service coverage in a part of the City recognized for its underservice, especially considering the rapidly densifying nature of East of 101. The Project site incorporates separate emergency ingress and egress from the fire station to separate the emergency vehicle traffic from the vehicular and alternative transportation modes entering the Vantage campus. Thus, the Project will greatly improve emergency access in the East of 101 area in the City, while managing emergency vehicle operations into and out of the Project site.

Conclusion: The Project will not exacerbate emergency access impacts or result in inadequate emergency access (Checklist item Transportation-e) beyond that identified in the General Plan EIR. This impact would be less than significant, and no mitigation is required.

CEQA Conclusions Pertaining to Transportation
Based on the analysis, findings and conclusions of the prior SSF 2040 General Plan EIR, implementation of the Project would not substantially increase the severity of any significant transportation impacts identified in the prior General Plan EIR. The Project would not result in new significant impacts related to transportation that were not previously identified in the SSF 2040 General Plan EIR. The SSF 2040 General Plan EIR identified mitigation measures TRANS-1 that would apply to the Project, reducing the total VMT and the share of single occupancy vehicles used by commuters. No further environmental analysis of the Project pertaining to the topic of transportation is required.

Vantage Master Plan Project – CEQA Analysis page 176
Tribal Cultural Resources
Would the Project:

Cause a substantial adverse change in the
significance of a tribal cultural resource,
defined in Public Resources Code section
21074 as either a site, feature, place,
cultural landscape that is geographically
defined in terms of the size and scope of
the landscape, sacred place, or object with
cultural value to a California Native
American tribe, and that is:

SSF 2040
General Plan
EIR Findings
Relationship to SSF 2040
General Plan EIR Findings: Project Conclusions:

Equal or
Less Severe
New or
Substantial
Increase in
Severity
Applicable Standards
and Regulations
Resulting
Level of
Significance
a) Listed or eligible for listing in the
California Register of Historical Resources,
or in a local register of historical resources
as defined in Public Resources Code
section 5020.1(k), or
LTS  ☐- No Impact
b) A resource determined by the lead
agency, in its discretion and supported by
substantial evidence, to be significant
pursuant to criteria set forth in subdivision
(c) of Public Resources Code Section
5024.1
In applying the criteria set forth in
subdivision (c) of Public Resources Code
Section 5024.1, the lead agency shall
consider the significance of the resource
to a California Native American tribe.

LTS  ☐Project Requirement
Tribal Cultural
Resources-1: Discovery
of Tribal Cultural
Resources
LTS with PR
Tribal Cultural Resources
SSF 2040 General Plan EIR
The SSF 2040 General Plan EIR (Impact CUL-4) would not cause a substantial adverse change in the significance of a Tribal Cultural Resource that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k). In February of 2022, as part of its efforts toward preparation of the SSF 2040 General Plan EIR, the City sent a letter to the Native American Heritage Commission (NAHC) to determine whether any sacred sites within South San Francisco are listed on the Sacred Lands File. The response from the NAHC, received on March 27, 2022, indicated that the search returned negative results for tribal cultural resources. A separate records search conducted at the Northwest Information Center (NWIC) identified 15 listed prehistoric sites that meet the definition of a tribal cultural resource.110
In accordance with requirements promulgated by SB 18 and AB 52, the City notified the Amah Mutsun Tribal Band, the Coastanoan Rumsen Carmel Tribe, the Indian Canyon Mutsun Band, the Muwekma Ohlone Indian Tribe of San Francisco Bay, the Ohlone Indian Tribe and the Wuksache Indian Tribe/Eshom Valley Band of its 110 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact CUL-4, page 3.4-37 Vantage Master Plan Project – CEQA Analysis page 177
proposed General Plan and invited the tribes to participate in consultation. No responses to that invitation were received.111
The General Plan EIR noted that it is possible for subsurface excavation activities to encounter previously undiscovered tribal cultural resources, and therefore unidentified tribal cultural resources could be adversely affected by development. The General Plan EIR determined that the General Plan does not directly propose any adverse changes to any recorded tribal cultural resources, but that future development pursuant to the General Plan could affect known or previously unidentified tribal cultural resources. The potential for additional undiscovered eligible tribal cultural resources to be present varies by location, with the waterfront and areas around Colma Creek and San Bruno Creek having the greatest potential for buried tribal cultural resources to be present. The General Plan includes policies and actions intended to conserve and reduce impacts to tribal cultural resources. By adhering to the policies and actions in the General Plan, as well as State provisions pursuant to SB 18 and AB 52, potential impacts to existing or undiscovered eligible tribal cultural resources were found to be reduced to less than significant.

Project Analysis
Public Resources Code requires a lead agency to consult with California Native American tribes that request consultation and that are traditionally and culturally affiliated with the geographic area of a proposed project.

Tribal consultation must take place prior to the release of a Negative Declaration, Mitigated Negative Declaration, or EIR for a project. That consultation took place pursuant to the General Plan EIR process and yielded no indication of additional known areas of tribal cultural resources within the vicinity of the Project. As a project consistent with the General Plan and its EIR, no subsequent EIR, MND or Neg. Dec., is required of the Project, and no further consultation is required. The Project site is not located in an area around Colma Creek or San Bruno Creek, where the greatest potential for buried tribal cultural resources is present.

It is unlikely, but possible that unknown tribal cultural resources are present below the surface. The Project site is located within the Colma Formation, which is buried in the shallow subsurface below Quaternary deposits and where there is a high sensitivity for significant paleontological resources. Pursuant to General Plan EIR Mitigation Measure GEO-6, Paleontological Monitoring, the Project shall be required to perform or provide paleontological monitoring for all proposed excavations in the Colma Formation. If undiscovered tribal cultural resources are discovered during this monitoring activity, the following regulatory requirements would apply.

Regulatory Requirements, Policies and Standards
In the unlikely event that tribal cultural resources are discovered during Project excavation, the following regulatory requirements would apply, addressing the potential discovery of tribal cultural resources and/or human remains of Native American origin:
❖ GP EIR Mitigation Measure GEO-6, Paleontological Monitoring (see Geology section of this Initial Study Checklist)
❖ Project Requirement Tribal Cultural Resources-1, Discovery of Tribal Cultural Resources: In the event that Native American human remains, or funerary objects are discovered, the provisions of Section 7050.5(b) of the California Health and Safety Code apply. These provisions provide that, the County Coroner, upon recognizing the remains as being of Native American origin, is responsible to contact the Native American Heritage Commission within 24 hours. The Commission has various powers and duties to provide for the ultimate disposition of any Native American remains, as does the assigned Most Likely Descendant. Sections 111 City of SSF, SSF 2040 General Plan Draft EIR, 2022, page 3.4-38 Vantage Master Plan Project – CEQA Analysis page 178
5097.98 and 5097.99 of the Public Resources Code also call for "protection of Native American human burials and skeletal remains from vandalism and inadvertent destruction.

In the unlikely event of discovery of Tribal Cultural resources during construction, the Project would be required to comply with State law that addresses such an unanticipated circumstance.

Conclusion: The Project’ compliance with existing applicable regulations will ensure that the Project’s construction does not cause a substantial adverse change in the significance of a tribal cultural resource with cultural value to a California Native American tribe (Checklist item Tribal Cultural Resources-a and-b).

CEQA Conclusions Pertaining to Tribal Cultural Resources Based on the analysis, findings and conclusions of the prior General Plan EIR, implementation of the Project would not substantially increase the severity of any significant impacts to tribal cultural resources as identified in that Program EIR, nor would it result in new significant impacts to tribal cultural resources that were not previously identified. The prior Program EIR did not identify any mitigation measures related to tribal cultural resources that would apply to the Project, and none would be needed.

Vantage Master Plan Project – CEQA Analysis page 179
Utilities and Service Systems
Would the Project:

SSF 2040
General Plan
EIR Findings
Relationship to SSF 2040
General Plan EIR Findings: Project Conclusions:

Equal or
Less Severe
New or
Substantial
Increase in
Severity
Applicable Standards
and Requirements
Resulting
Level of
Significance
a) Have sufficient water supplies available
to serve the project and reasonably
foreseeable future development during
normal, dry and multiple dry years
LTS  ☐ Project Requirement
Utilities-1, CALGreen
Project Requirement
Utilities-2, Water Efficient
Landscape
Project Requirement
Utilities-3, Water
Shortage Limitations and
Drought Restrictions
LTS with PR
b) Result in a determination by the
wastewater treatment provider which
serves or may serve the project that it has
adequate capacity to serve the project’s
projected demand in addition to the
provider’s existing commitments
LTS  ☐ Project Requirement
Utilities-1, CALGreen
Project Requirement
UTIL-4, Sewer Fees
Project Requirement
UTIL-5, Wastewater
Discharge Permits
LTS with PR
c) 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
d) Comply with federal, state, and local
statutes and regulations related to solid
waste
LTS  ☐ Project Requirement
Utilities-6, Construction
and Demolition Waste
Management Plan
Project Requirement
Utilities-7, Solid Waste
and Scavenger Services
Project Requirement
Utilities-8, Organic Waste
LTS with PR
e) 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 of which could cause
significant environmental effects
LTS  ☐ Regulatory Requirement
Utilities-9,
Commercial/Industrial
Water Service
Project Requirement
Utilities-10, Sewer Lateral
Construction
LTS with PR
Water Supplies
Vantage Master Plan Project – CEQA Analysis page 180
SSF 2040 General Plan EIR Conclusions
The General Plan EIR identified that 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 Westborough Water District (WWD).

The General Plan EIR relied on a threshold that a significant impact would occur if water demand for development facilitated by the General Plan could not be met by the providers’ existing entitlements and water supply resources. The SSF 2040 General Plan EIR (Impact UTIL-2) found that sufficient water supplies would be available to serve the reasonably foreseeable future development pursuant to the General Plan buildout during normal, dry and multiple dry years.112
To calculate approximate water demand at buildout, water demand factors from Cal Water were assigned to each land use type. Based on these factors and the General Plan buildout by land use types, the General Plan buildout was anticipated to result in an increased water demand of approximately to 1,921 AFY for new residential uses and 2,847 AFY for new commercial/industrial uses. The General Plan’s projected increase of approximately 4,768 AFY (or 4.28 MGD) represents approximately 59 percent of the water demand of Cal Water’s South San Francisco District service area by year 2040. Since Cal Water’s Urban Water Management Plan (UWMP) projects its water demands based on general growth in the service area, the projected water demand from General Plan buildout is accounted for in the overall demand forecast under normal water years.

Further, Cal Water’s 2020 UWMP states that purchased water supplies, along with groundwater supply to the South San Francisco District, will be sufficient to serve normal year demands through 2045.

The General Plan EIR identified that significant water supply shortfalls are currently projected in future single and multiple dry years due to implementation of the Bay-Delta Plan Amendment. The SFPUC has provided alternative water supply reliability projections (i.e., without implementation of the Bay-Delta Plan Amendment), which indicate that SFPUC would be able to supply 100 percent of the General Plan’s projected water demands in all year types through 2045, except for fourth and fifth consecutive dry years in 2045, during which 90 percent of projected demands would still be met. As noted in the Cal Water 2020 UWMP, the large disparity in projected water supply reliability between these two scenarios demonstrates the current level of uncertainty. Cal Water’s Water Shortage Contingency Plan addresses the shortfall and would be applicable to all users. Because the General Plan is “planned growth” and because Cal Water’s UWMP and Water Shortage Contingency Plan consider future planned growth, the General Plan EIR determined that sufficient water supplies are expected to be available in single and multiple dry years, with implementation of the Water Shortage Contingency Plan.

The General Plan EIR also found that, while development facilitated by the General Plan would result in an increased demand for both potable and recycled water, the UWMP determined that the water supply will be sufficient to accommodate future demand in the service area through 2045 under normal water years. If the Water District should experience a shortage of supply during a drought, water consumption reduction measures would be implemented in accordance with the applicable UWMP. Any direction by the Water District for reduced consumption would apply to all City customers, not only the increased demand resulting from General Plan buildout.

Under State and county water conservation ordinances, each jurisdiction within the water service area is required to conserve its water use through water efficiency measures. As required by the General Plan, 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. 112 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact UTIL-2, page 3.15-30 Vantage Master Plan Project – CEQA Analysis page 181
The General Plan EIR also noted that larger development projects would be subject to SB 610 and SB 221, which require preparation of a Water Supply Assessment (WSA) to confirm whether current and projected water supplies could accommodate these larger developments as they are proposed. The General Plan EIR also noted that Cal Water intends to adopt a Water Neutral Development Policy in the near future, which would require 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 water demand to offset its net increase in water demand. Once adopted, future development consistent with the General Plan would be required to comply with the proposed Development Offset Program. Compliance with the Development Offset Program 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.

In conclusion, the General Plan EIR determined that both Cal Water and WWD have considered projected growth and have determined that sufficient water supplies are anticipated to be available to accommodate future demands of development associated with General Plan buildout within their respective service areas.

Compliance with future water reductions under dry year scenarios, compliance with the policies and actions in the General Plan, compliance with SB 610 and SB 221 or provision of will-serve letters, and compliance with existing water conservation regulations and drought plans would ensure that impacts related to water supply remain less than significant.

According to the SSF 2040 General Plan EIR, buildout of the General Plan is estimated to generate a water demand of approximately 4,768 AFY (or 4.28 MGD). Relying on the same Cal Water demand factor of 0.21 gpd/square foot for land uses in the Business Technology Park High land use designation as used in the General Plan EIR,
113 the 1,288,582 square feet of office/R&D land use represented by Phases 2 and 3 of the Project are estimated to generate a demand for approximately 270,600 gallons per day (or 303.1 AFY) of water. This water demand represents approximately 6 percent of the total daily water demand generated by buildout of the General Plan. The 1,655,202 square feet of office/R&D land use represented by buildout of the Project are estimated to generate a demand for approximately 347,600 gallons per day (or 389 AFY) of water. This water demand represents approximately 8 percent of the total daily water demand generated by buildout of the General Plan. Water demands attributable to the fire station are not included in this total. The additional water demands of the fire station represent a minor increment in comparison to the overall Project, and these water demands are assumed to have been fully accounted for in CalWater’s UWMP.

Given that Cal Water has considered projected growth pursuant to the General Plan and determined that sufficient water supplies are anticipated to be available to accommodate future demands of General Plan buildout, and that the Project’s Phase 2 and Phase 3 water demands represent only about 6 percent of the water demand generated by General Plan buildout, it is reasonable to conclude that Cal Water has sufficient water supplies available to serve the Project and other reasonably foreseeable future development during normal years.
113 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Table 3.15-11: Water Demand Rate Assignment and Calculation, page 3.15-32 Vantage Master Plan Project – CEQA Analysis page 182
Similar to all other water users within the District, the Project will be required to conserve water use through water efficiency and conservation measures, demand management measures promoted by the Water District, and compliance with CALGreen measures and South San Francisco CAP measures promoting efficient indoor and outdoor water use. These measures would serve to reduce the Project’s water use and demand overall, especially during drought years. If Cal Water is required to implement its Water Shortage Contingency Plan to address water shortages, the Project (like all other water users) will be required to further reduce water consumption consistent with the Water Shortage Contingency Plan to address water shortages. It is therefore reasonable to conclude that Cal Water has sufficient water supplies available to serve the Project and other reasonably foreseeable future developments during single and multiple dry years.

Water Supply Assessment
To verify the conclusions presented above regarding water supply, and consistent with the requirements of SB 610 and SB 221, and CEQA Guidelines Section 15155, the Project applicant has requested Cal Water to prepare a Water Supply Assessment (WSA) to determine and confirm that the Project’s projected water demands are included in Cal Water’s UWMP. That Water Supply Assessment has been prepared and is summarized below (see Appendix M).114
The purpose of a WSA is to evaluate whether a water provider has sufficient water supply to meet the current and planned water demands within its service area, including the demands associated with the proposed Project, during normal and dry hydrologic years over a 20-year time horizon.115 Given that the SSF District shares its contractual allocation for its primary supply source (i.e., the City and County of San Francisco’s Regional Water System) with Cal Water’s Bear Gulch and Mid-Peninsula Districts (referred to as the “three Peninsula Districts”), the collective projected supplies and demands for all three Peninsula Districts are considered in the WSA. The WSA includes the following specific information:
• a summary of the WSA requirements articulated in Water Code §10910-10912, and a description of how they apply to the proposed Project
• a description and analysis of the current and projected future water demands of the Project through the year 2045
• a description and analysis of the historical and current water demands for the SSF District, and projected future water demands for the three Peninsula Districts’ service areas through the year 2045 • a description and analysis of the current and projected future water supplies for the three Peninsula Districts’ service areas through the year 2045, and
• a comparison of the water supplies and demands for the three Peninsula Districts’ service areas, including the projected water demands associated with the Project 116 Information contained in the WSA is based primarily on Cal Water’s SSF, Bear Gulch and Mid-Peninsula Districts 2020 Urban Water Management Plans (UWMPs), except where updated with relevant water demand and supply reliability and other information provided by Cal Water, DWR, the San Francisco Public Utilities Commission (SFPUC), and the Bay Area Water Supply and Conservation Agency (BAWSCA). 114 EKI Water and Environment, Water Supply Assessment for Healthpeak Vantage Project, prepared for South San Francisco District of California Water Service, March 2023
115 The Water Code specifies that a WSA must look at supplies and demand on a 20-year horizon (i.e., to 2040), but given the available data, this WSA looks beyond that to 2045
116 EKI Water and Environment, March 2023, page 5
Vantage Master Plan Project – CEQA Analysis page 183
The projected future water demands of the Project as calculated in the WSA are as shown below in Table 18. 117
As shown, the WSA calculates a substantially lower overall water demand for the Project at buildout (at 229 AFY) than is calculated based on water demand factors as presented in the General Plan EIR (as shown above at 389 AFY). This difference is based on substantially lower (and less conservative) demand factors per square foot of new development. The WSA’s annual water demand for the proposed Project was estimated using various literature sources and evaluated relative to current water use by similar uses in the Cal Water SSF District.

Similar uses within the Cal Water SSF District are based on the Cal Water WSA Water Factor Tool, which was developed based on 2016-2018 water use data for the SSF District. 117 Note that Table 19 of this document provides separate water demands for Phase 1 and for future phases, whereas the WSA provides a single water demand for the project based on full buildout Vantage Master Plan Project – CEQA Analysis page 184
Table 18: Summary of Estimated Annual Water Demand
Estimated Water Demand (AFY)
Water Use Area (sq.ft.) Demand Factor Units 2025 2030 and Later Phase 1 (Previously Entitled)
Office 163,010 0.055 gpd/sf 10.1 10.1
R&D 163,010 0.18 gpd/sf 32.9 32.9
Food Service 17,970 0.075 gpd/sf 1.5 1.5
Fitness Center 3,219 0.21 gpd/sf 0.8 0.8
Other 19,411 0.055 gpd/sf 1.2 1.2
Irrigation 69,202 2.5 2.5
System Losses 2.4% 1.8 1.8
Subtotal: 50.8 50.8
Phases 2 and 3 (Project)
Office 644,291 0.055 gpd/sf 39.9 39.9
R&D 644,291 0.18 gpd/sf 130.1 130.1
Fire Station 10,100 0.21 gpd/sf - 2.4
Parking Garage 1,613,850 0.02 gpd/sf 0.9 0.9
Irrigation 138,414 - - 5.1 5.1
System Losses 2.4% - 3.7 3.7
Existing Demand - - -3.7 -3.7
Subtotal: 176.2 176.2
Total: 226 229
Source: EKI, Water Supply Assessment for Healthpeak Vantage Project, prepared for South San Francisco District of California Water Service, Table 1 page 18. The WSA source table has been divided into Phase 1 (previously entitled) and Phases 2 and 3 (the Project), for purposes of this CEQA report.

This WSA concludes that, with supply augmentation and implementation of water demand management measures equal to the Project’s estimated net new demands consistent with Cal Water’s Development Offset Program, the proposed Project will not affect water supply reliability within the SSF District. Based on currently available information and reasonable worst-case estimates of projected demand, the WSA concludes that Cal Water expects to be able to meet all future demands within its existing SSF District service area (as well as the Mid-Peninsula and Bear Gulch Districts), inclusive of the proposed Project, in normal hydrologic years. The shortfalls that are currently projected during dry years will be addressed through planned implementation of the SSF District Water Shortage Contingency Plan. In addition, the Bay Area Water Supply and Conservation Agency, Cal Water, and SFPUC are pursuing development of additional water supplies to improve the Regional Water System and SSF District supply reliability. 118
118 EKI Water and Environment, March 2023, page 56
Vantage Master Plan Project – CEQA Analysis page 185
The findings of the WSA are contingent upon implementation of Cal Water’s Development Offset Program.

Regulatory Requirements
Pursuant to SSF 2040 General Plan EIR citations for all projects, the following water conservation and water use limitation and regulations apply to the Project:
❖ Project Requirement Utilities-1, CALGreen: The Cal Water UWMP’s estimate of future water demands accounts for assumed savings resulting the installation of water-efficient fixtures and equipment in new buildings as required under CALGreen Building Code Standards, and the Project will be required to install all such CALGreen-compliant water-efficient fixtures and equipment. ❖ Project Requirement Utilities-2, Water Efficient Landscape: Pursuant to: Landscaping, the City has fully incorporated the provisions and standards of the State of California Model Water Efficient Landscape Ordinance, which apply to the Project. Accordingly, the Project is required to comply with all provisions of SSFMC Section 20.300.008, including completion of a Water Efficient Landscape Worksheet that contains information on the plant factor, irrigation method, irrigation efficiency, and area associated with each hydrozone of the Project’s landscape. Calculations must show that the evapotranspiration adjustment factor (ETAF) for the landscape project does not exceed a factor of 0.45 for non-residential areas, exclusive of special landscape areas. The estimated total water use (ETWU) shall be calculated based on the plants used and irrigation method selected for the landscape design and must be below the Maximum Applied Water Allowance.
❖ Project Requirement Utilities-3, Water Shortage Limitations and Drought Restrictions: Like all of Cal Water’s customers, the Project will be subject to water shortage restrictions and limitations as may be deemed necessary by Cal Water.
❖ Project Requirement Utilities-4, Development Offset Program: Per Cal Water’s Advice Letter No. 2453 to the California Public Utilities Commission dated June 7, 2022, the Development Offset Program requires any new residential, commercial or industrial development within any of the three Peninsula Districts that is projected to increase net demand by more than 50 AFY to pay a special facilities fee, referred to as a developer offset fee. The Project’s developer offset fee will be used to fund accelerated water supply projects and expanded customer conservation programs. Cal Water intends to verify compliance with this Program by establishing a phased fee schedule whereby the developer’s offset fee is paid at the time that each new building or water service demand for the Project is created.

Conclusion: Consistent with the findings of the SSF 2040 General Plan EIR, the Project would be required to implement water saving and conservation measures as incorporated in the UWMP’s forecast of future water demands, and to provide a Development Offset Program fee to Cal Water. These conservation measures would control the Project’s water demands to levels fully contemplated in the UWMP, and the fees would assist in accelerating water supply projects and expanding customer conservation programs. The Project would not result in exceeding water supplies available to serve the Project and reasonably foreseeable future development during normal, dry and multiple dry years (Checklist item Utilities-a), and no additional mitigation is required.

The Project would not generate a substantial increase in the severity of water-related impacts or in a new significant water supply impact.

Wastewater Treatment
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact UTIL-3) found that the wastewater treatment providers (the City of South San Francisco’s Public Works Department, and the Westborough Water District (WWD)/North San Mateo Vantage Master Plan Project – CEQA Analysis page 186
County Sanitation District) would have adequate capacity to serve new development pursuant to the General Plan buildout, in addition to the provider’s existing commitments.119 Wastewater generated within South San Francisco is treated at one of two treatment plants. The South San Francisco/San Bruno Water Quality Control Plant (WQCP) is operated by the City of South San Francisco. It serves the population located outside of the Westborough Water District (WWD). The WWD/North San Mateo County Sanitation District treatment plant serves those residing within the WWD. According to the SSF General Plan EIR, the WQCP has experienced an average flow rate of 79 gallons per capita per day over the last 10 years.

Applying this factor to the General Plan’s projected increase in population, an additional 3.03 MGD of wastewater would be produced. Applying these same flow rates to flows attributed to the WWD/North San Mateo County Sanitation District treatment plant, the SSF General Plan EIR found an additional increase of 0.13 MGD of generated wastewater. All newly generated wastewater would be directed to either the South San Francisco/San Bruno WQCP or the North San Mateo County Sanitation District treatment plants. • The WQCP has a design capacity to treat 13 MGD average daily flow. The average dry weather flow through the facility is 7 MGD, leaving a remaining capacity of approximately 6 MGD. • The North San Mateo County Sanitation District treatment plant has a permitted capacity and design capacity of 10.3 MGD dry weather flows. Average dry weather flow is 5.6 MGD, leaving a remaining capacity of approximately 4.7 MGD
• These two wastewater treatment plants that serve 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

10.7 MGD. The 3.13 MGD of additional wastewater generated by new development under the General Plan represent about 23 percent of total treatment capacity of the wastewater treatment plants, or about 30 percent of total remaining treatment capacity of the wastewater treatment plants. Both wastewater treatment plants have the capacity to handle the General Plan’s increase in wastewater.

The General Plan EIR also found that both the WQCP and the WWD treatment plant maintain Sewer System Management Plans (SSMPs) as required under the Statewide General Waste Discharge Requirements for Sanitary Sewer Systems. These management plans consider development and redevelopment as would occur under the General Plan. As such, 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 General Plan EIR concluded that while development facilitated by the General Plan would result in an increase in the demand for wastewater collection and treatment, the wastewater collection systems and treatment plants have sufficient capacity to support new infill development. The City’s Sewer Capacity Charge would reduce impacts caused by future development and redevelopment by financing the replacement and renewal of existing sanitary sewer facilities, and the upgrade and construction of new sanitary sewer facilities.

Furthermore, the SWMPs include consideration of future growth in the City. Finally, the City’s Capital Improvement Plan includes projects covering both the wastewater system and the WQCP. Therefore, impacts related to wastewater collection and treatment would be less than significant.

Project Analysis
The previously entitled development pursuant to Phase 1 is part of the General Plan’s baseline development (see prior page 7), and therefore accounted for under “existing” wastewater demand. Therefore, only the subsequent development of 1,288,582 square feet of office/R&D building space pursuant to Phases 2 and 3 represent the additional wastewater demands attributable to the Project under “buildout”. 119 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact UTIL-3, page 3.15-35 Vantage Master Plan Project – CEQA Analysis page 187
According to the SSF 2040 General Plan EIR, buildout of the General Plan is estimated to generate a water demand of approximately 2.55 MGD and generate approximately 3.13 MGD of wastewater flows. Since the General Plan EIR’s estimate of wastewater flows exceed the estimated water demands, the difference (at a ratio of 1 MGD water demand per 1.22 MDG wastewater) is assumed as attributable to inflow and infiltration into the wastewater collection system, and other wastewater treatment peaking factors as incorporated into that analysis. Relying on the calculated water demands for Phases 2 and 3 of the Project (see above) and the General Plan EIR’s water-to-wastewater ratio of 1:1.22, the Project is estimated to generate approximately 330,130 MGD of wastewater (270,600 MGD of water x 1.22). This volume of wastewater represents approximately 11 percent of the total wastewater treatment demand generated by buildout of the General Plan, as presented in the General Plan EIR.

Wastewater generated by the Project will be treated at the South San Francisco/San Bruno Water Quality Control Plant (WQCP). Given that the 3 MGD of additional wastewater generated by new development under General Plan buildout represents about 50 percent of the remaining 6 MDG of treatment capacity at the WQCP, the Project’s (Phase 2 and 3) wastewater demands represent only about 5.5 percent of the remaining capacity of the WQCP. The WQCP has adequate capacity to handle the Project’s incremental increase in wastewater treatment demand, in addition to other existing commitments, and this impact is less than significant. The Project would not generate a substantial increase in the severity of wastewater impacts or in a new significant impact to the provision of wastewater treatment services.

Regulatory Requirements
Like all development projects and office/R&D land uses in SSF, the Project will be required to comply with the following regulatory requirements intended to minimize wastewater flows, ensure the upgrade and construction of necessary new sanitary sewer facilities, and to ensure that effluent discharged into the sewer system meets water quality requirements:
❖ Project Requirement Utilities-1, CALGreen: (see above), as water efficiencies also result in reductions in wastewater demand
❖ Project Requirement Utilities-5, Sewer Fees: Pursuant to the provisions of Health and Safety Code Section 5470 et seq. and SSFMC Section 14.12.010, the Project shall pay the City’s established sewer system fees for all domestic, commercial, and industrial uses of the municipal sewage facilities. ❖ Project Requirement Utilities-6, Wastewater Discharge Permits: Pursuant to SSFMC Section 14.08.100, all significant industrial users proposing to discharge wastewater to the City’s collection, storage, treatment or recycling facilities must obtain a wastewater discharge permit from the Superintendent. Moderate industrial users may be required to obtain a permit as deemed necessary by the Superintendent. The objectives of the permits are to prevent the introduction of pollutants into the wastewater system that may upset or interfere with operation, to prevent the introduction of pollutants, to improve the opportunity to recycle and reclaim wastewater, and to prevent the exposure of workers to chemical hazards.

Conclusion: Consistent with the findings of the SSF General Plan, the Project’s wastewater demands would not result in a determination by the wastewater treatment provider that it does not have adequate capacity to serve the Project’s projected demand in addition to the provider’s existing commitments (Checklist item Utilities-b), and the Project’s impact on wastewater treatment would be less than significant. The Project would not generate a substantial increase in the severity of wastewater impacts or in a new significant impact to the provision of wastewater treatment services.

Vantage Master Plan Project – CEQA Analysis page 188
c) Landfill Capacity and Compliance with Solid Waste Regulations SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact UTIL-4) determined that implementation of the 2040 General Plan 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, new development pursuant to the General Plan would comply with federal, State and local statutes and regulations related to solid waste.120 Development and growth in the City would increase the generation of solid waste (both temporary construction and permanent operation waste), but implementation of General Plan policies and actions would reduce and divert solid waste, including requirements for 75 percent waste diversion for municipal construction and demolition projects, maintenance and regular updates of the City’s waste reduction plans and programs to ensure consistency with California’s waste reduction goals, and education and technical assistance programs to help all residents and businesses to compost and recycle. In accordance with City requirements, development that does occur would be required to be served with solid waste, recycling, and green waste services provided by the City’s franchise hauler. Additionally, construction and demolition debris from new development would be required to be recycled. Statewide ordinances require waste reduction, recycling and diversion, and would be applicable to development occurring pursuant to the General Plan.

Construction waste would be temporary and would be required to be diverted from landfills in accordance with Municipal Code Chapter 15.60. Operationally, development pursuant to the General Plan was found to generate approximately 191 tons per day of solid waste at full buildout. For the solid waste that would be landfilled, four landfills serving the City have a combined remaining capacity of 43.43 million cubic yards. The solid waste generated by the General Plan represents only approximately 0.09 percent of the remaining capacity of these servicing landfills. This capacity would be more than sufficient to accommodate the solid waste generated by implementation of the General Plan. Therefore, the General Plan EIR determined this impact to be less than significant.

Project Analysis
During the construction process, the Project will generate construction waste consisting of demolished building, asphalt and concrete, lumber and other construction materials. During operations, the Project’s employees will also generate waste material such as garbage, recyclable products and green waste. These waste materials are common and regular components of new construction and office/R&D land uses, are not unique or specific to the Project, and in proportion to overall waste generated within SSF, will be relatively small in volume. Based on waste generation rates utilized in the General Plan EIR, Phases 2 and 3 of the Project may generate as much as

11.8 tons of waste materials per day. This represents approximately 6 percent of the General Plan’s additional daily solid waste generation at buildout, and approximately 0.05 percent of the City’s overall waste stream at buildout. These waste streams resulting from the Project will incrementally add to the total amount of waste destined for landfill, but the Project’s solid waste disposal needs will not cause an exceedance of permitted landfill capacity, and will comply with federal, state and local statutes and regulations related to solid waste.

Required Regulations, Policies and Standards
Like all construction projects and office/R&D land uses in SSF, the Project will be required to comply with the following regulatory requirements intended to reduce the overall waste stream that is destined for landfill:
120 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact UTIL-4, page 3.15-38 Vantage Master Plan Project – CEQA Analysis page 189
❖ Project Requirement Utilities-7, Construction and Demolition Waste Management Plan: Pursuant to Chapter 15.60 of SSFMC, the Project will be required to prepare and submit a Waste Management Plan to the Building Official, demonstrating how it intends to reduce the amount of waste disposed in a landfill. 1 Contractors are encouraged to make every structure planned for demolition available for deconstruction, salvage and recovery prior to demolition, and to recover the maximum feasible amount of salvageable designated recyclable and reusable materials prior to demolition, but at least at the rate set forth in the California Green Building Standards Code (CALGreen).

2. The diversion requirements shall be met by submitting and following a waste management plan that includes deconstructing and salvaging all or part of the structure as practicable; directing one hundred percent of inert solids to reuse or recycling facilities approved by the city; and either taking all mixed construction and demolition debris to mixed construction and demolition debris recycling facilities, or source separating non-inert materials and directing them to recycling facilities approved by the city, and taking the remainder to a facility for disposal.

3. Every contractor shall submit a properly completed waste management plan as an integral part of the building or demolition permit application
❖ Project Requirement Utilities-8, Solid Waste and Scavenger Services: Pursuant to SSFMC Chapter 8.16, each and every commercial and industrial or institutional property located in the city shall arrange for and have solid waste collection service. Solid waste, recyclable materials and salvageable materials shall be separated for collection by the city’s authorized recycling agent or for other disposition. ❖ Project Requirement Utilities-9, Organic Waste: Pursuant to SSFMC Chapter 8.27: Mandatory Organic Waste Disposal Reduction, the Project shall enroll in the city’s three-container organic waste collection services with source-separated recyclable materials to reduce landfill methane emissions by achieving a 75% reduction in organic waste disposal by 2025 (compared to 2014 levels).

Conclusion: Consistent with the findings of the SSF General Plan EIR, the Project would be required to implement existing regulatory requirements related to waste management and landfill diversion, and these regulatory requirements would reduce impacts to public utilities or services. The 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 (Checklist item Utilities-c), and the Project would comply with federal, state and local statutes and regulations related to solid waste (Checklist item Utilities-d), the impacts of the Project would be less than significant, and no mitigation is required.

Construction of New Utility Service Infrastructure
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR (Impact UTIL-1) determined that implementation of the 2040 General Plan 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.121 Water Infrastructure
The General Plan EIR found that most new development pursuant to the General Plan is expected to be infill, and would rely on the existing water distribution network, which has sufficient capacity to convey available 121 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact UTIL-1, page 3.15-28 Vantage Master Plan Project – CEQA Analysis page 190
water supplies. As such, implementation of the General Plan was not found to result in the need to construct or expand water supply and treatment facilities that have not already been described and accounted for in the 2020 UWMPs. The General Plan EIR also cited Cal Water’s 2020 UWMP and WWD’s 2020 UWMP, which 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 using integrated resource planning practices to create a long-term supply reliability strategy through 2050 for Cal Water districts in the Bay Area. It is anticipated that this study will identify feasible water supply projects that may benefit the South San Francisco District. The SFPUC has been implementing its Water System Improvement Plan (WSIP) since it was adopted in 2008, and it includes several water supply projects to address Level of Service Goals and Objectives. The SFPUC’s Alternative Water Supply Planning Program is also being implemented to explore other projects that would increase overall water supply resiliency. 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 SSF General Plan EIR determined that no new or expanded water facilities would be, and this impact would be less than significant. The Project would not generate a substantial increase in the severity of impacts to water-related infrastructure or in a new significant impact.

Wastewater Infrastructure
The SSF General Plan EIR determined that future development pursuant to the General Plan would be located within the urban framework of the City and near existing wastewater infrastructure. As such, buildout of the General Plan 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.

Therefore, the General Plan would not result in insufficient wastewater collection and treatment, no new or expanded wastewater treatment facilities would be needed, and this impact was found to be less than significant. The Project would not generate a substantial increase in the severity of impacts to wastewater treatment facilities or associated infrastructure or in a new significant impact.

Storm Drainage Capacity
The SSF General Plan EIR determined that, pursuant to General plan policy, new development 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 (see further discussion in the Hydrology section of this CEQA Checklist). City requirements and policies would ensure that runoff would not inundate downstream storm drainage facilities such that new or expanded facilities would be required, and this impact was found to be less than significant.

Electric Power, Natural Gas, and Telecommunications
The SSF General Plan EIR indicated that electricity, natural gas and telecommunications utilities prepare longrange plans to accommodate projected growth in their service areas. For example, PG&E has requested approval for 387 megawatts (MW) of additional energy storage from six projects slated for completion by August 2023. These projects will provide “system reliability procurement that will help integrate increasing amounts of renewable energy and meet peak summer demand.” Telecommunications companies continually expand their infrastructure to serve the growing population. These planning efforts take into account growth projections. Because the General plan 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 General Plan EIR concluded that new development pursuant to the General Plan would not be expected to require or result in new or expanded electricity, natural gas, or telecommunications facilities beyond those already planned. This impact was found to be less than significant.

Vantage Master Plan Project – CEQA Analysis page 191
Project Analysis
The Project intends to connect each of its new buildings to existing water, wastewater and storm drainage infrastructure that exist within the Forbes Boulevard right-of-way. Additional connections will also be made to existing PG&E electrical power lines and gas mains, and telecommunication systems. All unused connections to the utility systems that served the former warehouses on the Project site will be disconnected and removed. All construction activity (i.e., trenching and installation) will be conducted in conformance with the erosion control dust suppression and water quality requirements as cited in separate sections of this CEQA Checklist.

Regulatory Requirements
Consistent with the requirements of all new construction, the Project will be required to comply with the following regulatory requirements intended to address new utility service infrastructure:
❖ Regulatory Requirement Utilities-10, Commercial/Industrial Water Service: Consistent with Cal Water requirements, the Project shall apply for and receive approval from Cal Water for new water service connections. All such water service connections will be required to adhere to applicable Code requirements, and these requirements will be incorporated into individual development project designs and construction. ❖ Project Requirement Utilities-11, Sewer Lateral Construction: Pursuant to SSFMC Chapter 14.14: Sewer Lateral Construction, Maintenance and Inspection, the Project applicant will be responsible for constructing, operating and maintaining all individual sanitary sewer laterals from each new building to the City sanitary sewer main. Any new sewer lateral connections must obtain all applicable permits, including encroachment permits, building permits and/or plumbing permits.
❖ Project Requirement Utilities-4, Sewer Fees: (see above) Conclusion: Consistent with the findings of the SSF General Plan EIR, the Project would be required to fully comply with regulations pertaining to construction-related erosion, water quality and dust suppression as applicable to new construction, and to implement other existing regulatory requirements related to construction of new utility service infrastructure. These regulatory requirements would reduce impacts associated with the construction or relocation of new utility systems. The project would not require or result in the relocation or construction of new or expanded infrastructure facilities that could cause significant environmental effects (Checklist item Utilities-e), and the impacts of the Project would be less than significant.

CEQA Conclusions Pertaining to Utilities and Service Systems Based on the analysis, findings and conclusions of the prior General Plan EIR, implementation of the Project would not substantially increase the severity of any significant impacts related to utilities or service systems as identified in that prior Program EIR. The Project would not result in new significant impacts related to utilities or service systems that were not previously identified. The prior Program EIR did not identify any mitigation measures related to utilities or service systems that would apply to the Project and none would be needed.

Vantage Master Plan Project – CEQA Analysis page 192
Wildfire
Would the Project:

If located in or near state responsibility
areas or lands classified as Very High Fire
Hazard Severity Zones:

SSF 2040
General Plan
EIR Findings
Relationship to SSF 2040
General Plan EIR Findings: Project Conclusions:

Equal or
Less Severe
New or
Substantial
Increase in
Severity
Applicable Standards
and Requirements
Resulting
Level of
Significance
a) Due to slope, prevailing winds and other
factors, exacerbate wildfire risks, and
thereby expose project occupants to
pollutant concentrations from a wildfire or
the uncontrollable spread of a wildfire?
LTS  ☐ - LTS
b) Substantially impair an adopted
emergency response plan or emergency
evacuation plan?
LTS  ☐ - LTS
c) 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 risks or that may result in
temporary or ongoing impacts to the
environment?
LTS  ☐ - LTS
d) Expose people or structures to
significant risk, including downslope or
downstream flooding or landslides from
runoff post-fire slope instability, or
drainage changes?
LTS  ☐ - LTS
Exacerbate Wildfire Risks
SSF 2040 General Plan EIR Conclusions
The SSF 2040 General Plan EIR determined that no portion of the City is located in or near state responsibility areas or lands classified as Very High Fire Hazard Severity Zones. Accordingly, the General Plan EIR concluded that:
• New development pursuant to the 2040 General Plan would not expose people or structures, directly or indirectly, to a significant risk of loss, injury or death involving wildland fires (Impact WILD-1). 122
• New development pursuant to the 2040 General Plan would not substantially impair an adopted emergency response plan or emergency evacuation plan (Impact WILD-2).123 122 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact WILD-1, page 3.16-11 123 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact WILD-2, page 3.16-16 Vantage Master Plan Project – CEQA Analysis page 193
• New development pursuant to the 2040 General Plan 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 (Impact WILD-3).124 • New development pursuant to the 2040 General Plan would not require the installation or maintenance of associated infrastructure that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment (Impact WILD-4).125
• New development pursuant to the 2040 General Plan would not expose people or structures to significant risks, including downslope or downstream flooding or landslides from runoff, post-fire slope instability or drainage changes (Impact WILD-5).126
The General Plan EIR determined that no portions of the City are located in a Fire Hazard Severity Zone (FHSZ) within a State Responsibility Area (SRA) or within a Very Fire Hazard Severity Zone (VHFHSZ) in a local, State or federal responsibility area. As such, the General Plan does not approve, propose or authorize development in an SRA or FHSZ. The City is adjacent to land identified as Moderate FHSZ within an SRA, and a High FHSZ within an SRA (i.e., at San Bruno Mountain State Park). While there are no Very High, High or Moderate FHSZs within the city limits, Sign Hill Park is susceptible to wildfires as evidenced by a fire that occurred in 2020. 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, which is required to include a landscape design plan in accordance with the Model Water Efficient Landscape Ordinance. In particular, a landscape design plan for projects in fire-prone areas shall address fire safety and prevention, including a defensible space or zone around a building or structure. 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 General Plan, and current hazards would not be significantly increased.

The General Plan EIR concluded that development envisioned by the General Plan is generally focused in already developed areas of the City, but new development could result in an incremental increase in exposure of people and structures to wildland fires and associated hazards. Accordingly, future projects would be required to comply with fire protection measures in the policies and actions within the General Plan and SSFMC. Continued implementation of the San Mateo - Santa Cruz County CWPP, San Mateo County LHMP, San Mateo County EOP, and review of architectural and development plans by the SSFFD Division of Fire Prevention, will assist in protecting life and property in the event of a wildfire. Implementation of the General Plan policies and actions would reduce potential impacts related to exposure to wildland fires and associated hazards to below a level of significance, and no additional mitigation is required.

Project Analysis
As indicated in the General Plan EIR Exhibit 3.16-1: Wildfire Hazard Severity Zones (Figure 21), the Project site is not located in a Medium or High Wildfire Hazard Severity Zone. Accordingly, the Project would not expose Project occupants to pollutant concentrations from a wildfire or the uncontrollable spread of a wildfire; would not substantially impair an adopted emergency response plan or emergency evacuation plan; would not require the installation or maintenance of associated infrastructure that may exacerbate fire risks or that may result in temporary or ongoing impacts to the environment; and would not expose people or structures to significant risk, including downslope or downstream flooding or landslides as a result of runoff post-fire slope instability or drainage changes.
124 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact WILD-3, page 3.16-18 125 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact WILD-4, page 3.16-19 126 City of SSF, SSF 2040 General Plan Draft EIR, 2022, Impact WILD-5, page 3.16-20 Vantage Master Plan Project – CEQA Analysis page 194
Fig 21
Vantage Master Plan Project – CEQA Analysis page 195
Conclusion: Consistent with the findings of the SSF 2040 General Plan, the Project would not have an adverse effect related to wildfire risk. The Project is not located in a Very High Fire Hazard Severity Zone.

CEQA Conclusions Pertaining to Wildfire
Based on the analysis, findings and conclusions of the prior General Plan EIR, implementation of the Project would not substantially increase the severity of any significant impacts related to wildfire as identified in that prior Program EIR. The Project would not result in new significant impacts related to wildfire that were not previously identified. There is no new information about wildfire hazards that is now available, and that was not available at the time of preparation of the 2040 General Plan EIR. The prior Program EIR did not identify any mitigation measures related to wildfire that would apply to the Project and none would be needed.

Vantage Master Plan Project – CEQA Analysis page 196
Mandatory Findings of Significance
SSF 2040
General Plan
EIR Findings
Relationship to SSF 2040
General Plan EIR Findings: Project Conclusions:

Equal or
Less Severe
New or
Substantial
Increase in
Severity
Applicable Standards
and Requirements
Resulting
Level of
Significance
a) Does the project have the potential to
degrade the quality of the environment,
substantially reduce the habitat of a fish or
wildlife species, cause a fish or wildlife
population to drop below self-sustaining
levels, threaten to eliminate a plant or
animal community, or reduce the number
or restrict the range of a rare or
endangered plant or animal? Does the
project have the potential to eliminate
important examples of the major periods
of California history or prehistory?
LTS  ☐ CALGreen
Water Efficient Landscape
Water Shortage/Drought
Restrictions
LTS
b) Does the project have impacts that are
individually limited, but cumulatively
considerable? ("Cumulatively
considerable" means that the incremental
effects of a project are considerable when
viewed in connection with the effects of
past projects, the effects of other current
projects, and the effects of probable future
projects)
LTS  ☐ - LTS
c) Does the project have environmental
effects which will cause substantial adverse
effects on human beings, either directly or
indirectly
LTS  ☐ - LTS
Degrade the Quality of the Environment
As addressed in the Air Quality, Biology, Cultural Resources, GHG, Hazards and Hydrology sections of this Initial Study Checklist, with implementation of all applicable SSF General Plan EIR mitigation measures and other regulatory requirements, the Project would not degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, or reduce the number or restrict the range of a rare or endangered plant or animal. The Project would not eliminate important examples of the major periods of California history or prehistory.
• The Project would be required to implement the BAAQMD’s recommended Basic Construction Mitigation Measures for control of construction-related criteria pollutant emissions (per the GP EIR Mitigation Measure AIR-1a), and these measures would control construction-related emissions to levels of less than significant.

Vantage Master Plan Project – CEQA Analysis page 197
• The Project’s predicted average daily and annual operational-generated emissions of NOx, PM10 and PM2.5 criteria air pollutants are below the operational significance thresholds as recommended by the BAAQMD and as relied on in the General Plan EIR. Therefore, operational air quality impacts related to cumulatively considerable net increases of these non-attainment criteria pollutants would be less than significant.
• The Project site is dominated by developed and landscaped habitat that includes paved roads, buildings, parking lots, paved and gravel trails, ornamental and landscaped areas. The habitat suitability for rare or native vegetation in these areas is very low to absent. Similarly, developed habitats as exist at the Project site primarily support common, urban-adapted wildlife species, and overall wildlife abundance and diversity are low. The Project would be required implement existing regulatory requirements of the Migratory Bird Treaty Act and/or the California Fish and Game Code that provide for protection of active nests of migratory and other birds and bats, including their roosts, eggs and young. Implementation of these measures would avoid and/or reduce impacts to sensitive status species to levels of less than significant.
• The Project site does not contain riparian habitat or other sensitive natural community types. The nearest sensitive natural communities are the riverine wetlands and tidal marshes south of the Oyster Point Marina (approximately 0.3 miles to the northeast), and tidal marshes and open water in San Francisco Bay (approximately 0.66 miles to the south). Development of the Project site will have no adverse effect on riparian habitat or other sensitive natural community types. • No potential jurisdictional wetlands or waters occur on the site, and the Project would not have a substantial adverse effect on State or federally protected wetlands or waters of the U.S. or waters of the State.
• The Project site does not include any waterways, ridgelines or creek corridors, and the Project site is not identified as a wildlife corridor or wildlife nursery site. The Project would not have a substantial adverse effect on wildlife corridors or wildlife nursery sites. • The Project would be required to obtain a Tree Removal Permit for removal of any tree on public property, and for removal of any other protected trees on the site. If the City approves that Tree Removal permit, the Project will be required to provide replacement tree plantings and/or in lieu fees.

These Tree Removal Permit requirements would achieve compliance with local policies or ordinances protecting biological resources and would minimize the impacts related to the loss of trees to a level of less than significant.
• The Project site is not located within or near Sign Hill Park, San Bruno Mountain State Park or adjacent to the San Francisco Bay, and would not conflict with any adopted Habitat Conservation Plan or Natural Community Conservation Plan adopted for these areas.
• Only the one remaining warehouse at 440 Forbes Boulevard has not already been cleared for demolition. According to historic maps of the area, this building was constructed in 1965, making it well over 50 years in age and therefore eligible for consideration as an historic structure. This building is not listed on the CRHP, is not a designated Historic Landmarks, is not located within the Grand Avenue Commercial Historic District, is not identified as a potential historic resource, and is not one of the 250 eligible historic architectural resources located within the City but that are not included within the City’s register. This building “does not exhibit any features that would qualify it for inclusion on the California Register of Historical Resources or the local register of historical resources. It is evident that the 1965 warehouse building with its office wing and detached truck shop are a standard industrial building type, of typical design and construction, and are not the work of a notable engineer, so do not appear to have Vantage Master Plan Project – CEQA Analysis page 198
historical potential on those primary bases”. A full Historic Resource Evaluation will be prepared to verify this conclusion prior to permitting demolition of this structure. • There is at least a moderate potential for the inadvertent discovery of previously unrecorded historic‐ period archaeological resources at the site during ground-disturbing activity. However, the Project site is not located near the waterfront, Colma Creek or San Bruno Creek, where there is the greatest potential for buried prehistoric archaeological resources to be present. In the unlikely event of discovery of cultural resources during construction, the Project would be required to comply with SSF General Plan policies and State law that addresses such an unanticipated circumstance. These policies and regulations ensure that the Project’s construction does not cause a substantial adverse change in the significance of an archaeological resource.
• The Project is, and/or will be required to demonstrate consistency with the SSF 2022 CAP. The Project’s proposed development plans indicate that the Project will be consistent with individual CAP Actions related to clean energy, building design, transportation and land use, solid waste, water and wastewater, and carbon sequestration. The Project does not present any inherent inconsistencies with other SSF 2022 CAP Actions. As such, the Project meets the CEQA threshold of less than a significant impact for GHG emissions.
• Construction activities associated with the Project will involve the use of heavy equipment using fuels and oils and will involve the use of other products such as concrete, paints and adhesives. Such hazardous materials will be stored, used and transported in varying amounts during construction. The Project would be required to comply with all Federal, State, and local regulations regulating the handling, storage, and transportation of hazardous materials. With implementation of these regulatory requirements, construction activities would not create a significant hazard to the public or the environment through routine transport, use, or disposal of hazardous materials or through a reasonably foreseeable upset and accident condition involving the release of hazardous materials in the environment.
• The Project would be required to comply with all federal, State and local regulations regulating the handling, storage and transportation of hazardous materials during operations. With compliance, operational activities would not create a significant hazard to the public or the environment through a reasonably foreseeable upset and accident condition involving the release of hazardous materials in the environment.
• The Project would involve grading, excavation and removal of existing paved surfaces, buildings and vegetative cover that has the potential to result in runoff that contains sediment and other pollutants.

These pollutants could degrade surface and groundwater quality if not properly controlled. The Project’s effects related to water pollution from non-point sources during construction will be fully addressed through implementation of existing regulations (i.e., by filing a Notice of Intent with the State Water Board and preparing and implementing a Project-specific Stormwater Pollution Prevention Plan), and this impact would be reduced to less than significant.
• The Project will add new impervious surface area and will replace all of the remaining impervious surface at the site. The new and replaced impervious surfaces could increase the volume of pollutants that are typically associated with urban runoff into the stormwater, as well as increase nutrients and other chemicals from landscaped areas. These constituents could result in water quality impacts to offsite drainages and waterways, potentially including the Bay. The Project is subject to Provision C.3 of the Master Regional Permit, which is primarily implemented pursuant to the City’s Stormwater Management and Discharge Control Ordinance. The Project must comply with these regulatory requirements, which are intended to prevent stormwater pollution during operations, and to provide for Vantage Master Plan Project – CEQA Analysis page 199
compliance with State and federal regulations. The Project’s design includes provisions for stormwater treatment of the impervious surface areas of the site. This will include construction of stormwater treatment Best Management Practices (BMPs) such as bio-filtration areas, flow-through planters, and pervious pavers and pavements, among other acceptable stormwater BMP types. These stormwater BMPs will generally be distributed throughout the site and near the individual sources of run-off to the maximum extent practicable. The Project’s effects related to water pollution from non-point sources will be fully addressed through implementation of existing regulations, and this impact would be reduced to less than significant.
• The Project site is located in a catchment area that drains to a hardened channel and is therefore exempt from hydromodification measures. Increased runoff from the Project is unlikely to cause increased potential for erosion of creek beds and banks, silt pollutant generation, or other adverse impacts on beneficial uses due to increased erosive force. However, during the temporary period between end of construction of the previously entitled Phase 1 development and the start of Phase 3 of the Master Plan, the Project will generate the highest amount of run-off from the site, which is anticipated to exceed the pre-Project run-off volume. This increase in runoff may contribute on a cumulative basis to exceeding the capacity of the downstream storm drain system serving the site and surrounding areas. The Project includes BMPs, and Low Impact Development standards (LIDs) incorporated into its design that would ensure that the Project does not result in a net increase in surface runoff, and the Project’s effects related to the alteration of existing drainage patterns is considered less than significant.
• It is unlikely, but possible that unknown tribal cultural resources are present below the surface at the Project site. The Project site is located within the Colma Formation, which is buried in the shallow subsurface below Quaternary deposits and where there is a high sensitivity for significant paleontological resources. Pursuant to General Plan EIR Mitigation Measure GEO-6: Paleontological Monitoring, the Project shall be required to perform or provide paleontological monitoring for all proposed excavations in the Colma Formation. If undiscovered tribal cultural resources are discovered during this monitoring activity, regulatory requirements would apply. These regulations will ensure that the Project’s construction does not cause a substantial adverse change in the significance of a tribal cultural resource.

Based on these conclusions, the Project would not degrade the quality of the environment. The Project would not substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, or threaten or eliminate a plant or animal community, or reduce the number or restrict the range of a rare or endangered plant or animal. The Project would not eliminate important examples of major periods of California history or prehistory.

Cumulative Impacts
CEQA Guidelines Section 15183 provides that future projects analyzed in relationship to a prior Program EIR may be excluded from further analysis of off-site or cumulative impacts, if those off-site or cumulative impacts were adequately discussed in the prior Program EIR.

Cumulative Effects Identified in the SF General Plan Update EIR Prior to adopting the Shape SSF 2040 General Plan Update, the City of South San Francisco certified the SSF 2040 General Plan Update EIR. The SSF 2040 General Plan EIR examined the potential cumulative effects of new development pursuant to the 2040 General Plan Update. That EIR determined that, for the majority of environmental topics analyzed, cumulative development consistent with the General Plan Update would result Vantage Master Plan Project – CEQA Analysis page 200
in environmental impacts that would be reduced to levels of less than significant with implementation of existing regulatory requirements, implementation of policies contained within the General Plan EIR, and additional mitigation measures as identified in that EIR. However, the SSF 2040 General Plan Update EIR determined that the following list of environmental impacts would be cumulatively significant and unavoidable.

Cumulative Vehicle Miles Traveled
The General Plan EIR concluded that cumulative growth and development throughout the City and throughout the nine-county Bay Area would result in a cumulative increase in VMT as measured in total VMT per service population and as home-based work VMT per employee. Although cumulative development within the City of SSF would be required to implement Transportation Demand Management (TDM) measures, an East of 101 Area Trip Cap, and parking requirements to reduce cumulative VMT increases, the effectiveness of the VMT reduction strategies were not able to be quantified in the General Plan EIR analysis, which concluded that the City of South San Francisco may not be able to achieve a cumulative reduction in overall VMT to below threshold level, and this cumulative impact was found to be significant and unavoidable.

Cumulative Roadway Safety
The SSF General Plan Update EIR concluded that cumulative growth and development throughout the City, as well as cumulative development throughout the nine-county Bay Area, would increase vehicle trips on the City’s freeway ramps. That traffic would cause vehicle queues to exceed off-ramp storage capacity or exacerbate offramps that already experience off-ramp queues exceeding storage capacity, resulting in a potentially significant cumulative impact. Although the City will continue to work with Caltrans to develop improvement measures for freeway off-ramps and adjacent intersections that help manage off-ramp queues to minimize queueing hazards, the General Plan EIR concluded that there is uncertainty around specific operational conditions and the ability to mitigate such conditions in a constrained right-of-way. This cumulative impact was found to remain significant and unavoidable.

Conflict with 2017 Bay Area Clean Air Plan
The SSF General Plan Update EIR concluded that new cumulative development facilitated by the General Plan would increase VMT by approximately 94 percent through 2040, whereas population would grow by only approximately 61 percent during the same period. Forecasted VMT growth would outpace population growth and the General Plan EIR concluded that this imbalance between cumulative VMT and cumulative population growth would be inconsistent with the 2017 Clean Air Plan. Because the effectiveness of identified VMT reduction strategies could not be quantified, the General Plan Update EIR determined that City of South San Francisco may not achieve cumulative VMT reductions, and this impact was found to be cumulatively significant and unavoidable.

Cumulative Criteria Air Pollutants
The SSF General Plan Update EIR similarly concluded cumulative VMT growth would result in a cumulatively considerable net increase in criteria pollutants. The EIR determined there is no reasonable mitigation that can be implemented to keep growth in VMT to a minimum, while also increasing population. The cumulative increase in VMT was found to result in a cumulatively considerable net increase in criteria air pollutants and ozone precursors. This cumulative impact was found to remain significant and unavoidable.

Project Contributions
This Initial Study Checklist analyzes whether the Project may contribute to cumulative environmental effects as identified in the SSF General Plan Update EIR. This Initial Study Checklist also considers whether mitigation measures, development standards, policies and/or regulations identified in the SSF General Plan Update EIR would apply to the Project. The analysis in this Initial Study finds that the Project would not have environmental Vantage Master Plan Project – CEQA Analysis page 201
impacts that are unique to the Project, and that the Project’s contribution to cumulative effects were fully evaluated and disclosed in the prior SSF General Plan EIR, and that certain mitigation measures, development standards, policies and ordinances identified in that prior EIR would apply to the Project.

As specifically addressed in the Air Quality and Transportation sections of this Initial Study:
• Unlike the conclusions of the General Plan EIR, the effectiveness of VMT reduction strategies for the Project are able to be quantified, as presented in this Initial Study. This analysis demonstrated that the Project site is located in a C/CAG Travel Demand Model’s Transportation Analysis Zone (TAZ) that has an existing average home-based work VMT “baseline” of 15.7. With implementation of a rigorous (Tier 4) TDM Plan and associated parking requirement and a Trip Cap, the Project is expected to achieve a 50 percent drive-alone mode share, representing at least a 27 percent reduction in home-based work VMT per employee, with a resulting home-based work VMT per employee of 11.5. This is well below the home-based work VMT threshold of 13.5, demonstrating a less than significant VMT impact for the Project.
• Vehicle trips generated by the Project represent a small percentage of overall daily and peak hour traffic, but the Project would contribute to a cumulative increase in vehicle trips on City freeway ramps and could exacerbate vehicle queues on ramps that already exceed their storage capacity, thereby contributing to these significant and unavoidable impacts. Fees paid by the Project will be used by the City to develop roadway infrastructure improvement that directly address traffic impacts. • The Project’s predicted average daily and annual operational-generated emissions of NOx, PM10 and PM2.5 criteria air pollutants are below the operational significance thresholds as recommended by the BAAQMD, and as relied on in the General Plan EIR. Therefore, operational air quality impacts related to a cumulatively considerable net increase of these non-attainment criteria pollutants would be less than significant.

As demonstrated in this Initial Study, the Project does not have any unique or peculiar effect that would indicate a new significant cumulative impact, or a substantial increase in a previously identified significant cumulative environmental impact. Accordingly, this Initial Study Checklist relies on the streamlining provisions of CEQA Guidelines Section 15183 to address cumulative effects and finds that the Project would not contribute to any cumulative effects not previously disclosed and adequately analyzed in the prior SSF General Plan Update EIR.

Effects on Human Beings
As addressed in the Air Quality, Geology, Hazards, Hydrology, Noise and Wildfire sections of this Initial Study Checklist:
• During construction, diesel emissions from off-road equipment and on-road diesel trucks (also known as DPM) will be emitted. Diesel exhaust is identified by the State of California as a known carcinogen, and increased exposure to DPM poses an increased health risk. The Project would be required to conduct a health risk analysis (HRA) and implement diesel emission reductions as identified in that HRA or implement the BAAQMD’s recommended Additional Construction Mitigation Measures for control of construction-related TAC emissions (GP EIR MM AIR-1b). Either of these approaches would control construction-related TAC emissions to levels of less than significant. • The northwestern corner of the Project site’s bedrock consists of sandstone, shale and serpentinite, which may contain naturally occurring asbestos. Asbestos testing indicates concentrations of asbestos that exceed environmental Screening Levels for both commercial and industrial land uses. The Project would be required to implement BAAQMD’s Asbestos Airborne Toxic Control Measures, and these Vantage Master Plan Project – CEQA Analysis page 202
measures would control construction-related emissions of naturally occurring asbestos to levels of less than significant.
• The Project is intended to accommodate future R&D uses. The specific R&D tenants are not known, the types of research and development facilities have not been identified, and the need for research and development equipment that may generate new sources of toxic air contaminants is unknown.

However, future R&D tenants may rely on such equipment. Future tenants within the Project will be required to obtain from the BAAQMD an “Authority to Construct” or a “Permit to Operate” for any new sources of hazardous air pollutant emissions. The requirements of these authorizations or permits would control operational-related emissions of toxic air contaminants to levels of less than significant. • The Project site is located in a seismically active region. During a major earthquake the Project site will experience very strong to violent ground shaking, similar to other areas of the seismically active region.

Compliance with the CBC regulations and building standards, with site-specific recommendation as provided by a geotechnical engineer, will reduce the effects of strong ground shaking in the event of a likely earthquake scenario to levels considered acceptable by professional engineers, and therefore considered under CEQA to be less than significant.
• The Project’s new buildings are intended as build-to-suit facilities. The future tenants of these buildings have not yet been identified but are likely to be occupied by a combination of office space and R&D laboratories. The R&D laboratories may handle certain materials considered hazardous biological and/or chemical substances. The Project would be required to comply with all applicable city, county, state and federal regulations related to the transport, use and disposal of hazardous materials. These regulations control the use of hazardous materials to minimize the risk of exposure of the public to substantial adverse effects and would reduce this impact to a level of less than significant. • Gasoline-impacted soil and groundwater remains in the subsurface at the 460 Forbes Boulevard site in the vicinity of a former underground storage tank, and these residual contaminates may pose a risk to public health and the environment. The Project would be required to comply with all applicable City, County, State and federal regulations related to development of a contaminated (or previously contaminated) site. These regulations minimize the risk of significant hazards to the public or the environment to a level of less than significant.
• No safety zones associated with SFO apply to the Project site, and the Project would be consistent with land use safety criteria. Additionally, the Project site is not located within any of the ALUCP-identified noise impact areas. Thus, the ALUCP land use noise exposure criteria do not apply to the Project and the Project would not pose a safety hazard by being exposed to excessive noise due to its proximity to SFO. • The Project site is directly accessible from Forbes Boulevard to East Grand Avenue, which is a Citydesignated alternative emergency evacuation route that provides direct access to US-101. The Project would not interfere with this emergency evacuation route but would add a less than significant increment of additional traffic relying on this route in the potential event of an evacuation. • The Project site is not located within a 100-Year Flood Hazard Zone (1% Annual Chance Flood Hazard), a 500-Year Flood Hazard Zone (2% Annual Chance Flood Hazard), or a Tsunami Susceptibility location. The Project’s effects related to inundation hazards are considered less than significant. • The Project site is not located within an area susceptible to sea level rise (SLR) under any of the year 2100 mid-level scenarios (100-year flood, 100-year flood plus 2040 SLR, or 100-year flood plus 3 feet of SLR). No SLR adaptation strategies are needed to reduce risks of SLR inundation at the Project site. • The tallest proposed building pursuant to the Project is the 237-foot tall, 12-story Building C, which reaches a height of approximately 282 feet above MSL. This tallest proposed building does not exceed Vantage Master Plan Project – CEQA Analysis page 203
the Project site’s Critical Aeronautical Surface of approximately 500 feet above mean sea level, and the Project does not propose any new buildings or structures that would exceed critical aeronautical surface elevations. The Project is consistent with the critical aeronautical surface criteria of the ALUCP. Many of the project’s proposed new buildings exceed a height of 163.2 feet above MSL and are therefore subject to an Obstruction Evaluation/Airport Airspace Analysis to demonstrate conformance with the standards of the ALUCP and issuance of a determination of “no hazard to air navigation”. • Generally, land uses that surround the Project site consist of other office/R&D facilities and light industrial uses. However, immediately across the street at Allerton Avenue is the Genentech 2nd Generation pre-school, and the Cabot 2nd Generation pre-school and Early Years pre-school are only about 500 feet further to the south. Certain types of construction activity (e.g., concrete mixer trucks, excavators and graders and jackhammers) would generate noise that could potentially exceed noise standards at these noise-sensitive receptors. Construction noise attributed to the Project would be temporary, and the Project applicant and/or construction contractors will be required to obtain all necessary permits and to abide by all construction hours as stipulated by existing regulation and General Plan policy.
• New and existing receptors within 100 feet of the proposed new fire station would be exposed to shortduration high noise levels for approximately 10 to 20 seconds for each emergency response event.

South San Francisco City CouncilDecember 13, 2023

South San Francisco City Council
December 13, 2023