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Report regarding consideration of an Addendum to the previously certified 101 Gull Drive Project Environmental Impact Report pursuant to the California Environmental Quality Act and Design Review and Transportation Demand Management Plan to construct a 9-story Office / R&D Building with attached parking garage at 101 Gull Drive in the Business Technology Park - High (BTP-H) Zoning District in accordance with Title 20 of the South San Francisco Municipal Code. (Stephanie Skangos, Associate Planner)
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RECOMMENDATION
Recommendation
Staff recommends that the Planning Commission conduct a public hearing and take the following actions:
1. Adopt a Resolution making findings and a determination that the 101 Gull Drive Project, as modified and amended, is fully within the scope of environmental analysis in the previously certified 101 Gull Drive Project Environmental Impact Report (EIR) and that the 2023 Addendum to the EIR is the appropriate document for the Project, and that no further environmental review is required per the California Environmental Quality Act (CEQA).; and,
2. Adopt a Resolution making findings approving the entitlements for Planning Project P21-0006, including Design Review DR22-0045 and Preliminary Transportation Demand Management Program TDM22-0010, based on the attached draft findings and subject to the attached draft Conditions of Approval.
MOTION FOR THE COMMISSION TO ADOPT STAFF RECOMMENDATION:
(1) Move to adopt the resolution making CEQA determinations and approving the Addendum; and
(2) Move to adopt the resolution approving planning entitlements.
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BACKGROUND/DISCUSSION
On December 16, 2022, Sanfo Group, LLC (“applicant”) submitted an application for a modification to an approved office / research and development (R&D) project at 101 Gull Drive that proposes an increased floor area ratio (FAR) and two additional stories for the project. The original project was approved by the Planning Commission on April 21, 2022, and included construction of a new 7-story office / R&D building, approximately 166,613 square‐feet, an attached 4.5-story parking garage with 419 parking spaces, and site improvements.
The City adopted a new General Plan and Zoning Code on October 26, 2022, and the new Zoning Code became effective on November 26, 2022. The new General Plan and Zoning Code included a change in land use designation and rezoning of the project site to Business Technology Park - High (BTP-H) from Business Technology Park (BTP), effectively allowing for a higher maximum floor area ratio (FAR) on the project site.
Site Overview
The 101 Gull Drive site is a vacant, generally triangular‐shaped 3.8‐acre lot located in the City’s “East of 101” planning area behind businesses fronting Eccles Avenue and Oyster Point Boulevard. The project site is bounded to the north, west, and south by office/commercial and light industrial buildings and associated parking lots. Gull Drive borders the project site to the east; however, the site is largely separated from the public right-of-way by a grade change and steep slope. Uses in the project vicinity include a mix of office, warehouse, corporate, commercial, and light industrial uses.
Project Description
The proposed expanded project consists of a 281,058-square-foot, 9-story, office / R&D building and an attached 7.5-level 574-stall parking garage. Compared to the original project, the proposed expansion represents an increase of the office / R&D area by approximately 115,000 square feet on the same footprint, through increased height of the office / R&D building (two additional stories) and parking garage (three additional levels). Site improvements would also include open space, landscaping, outdoor seating areas, pedestrian walkways, and vehicular circulation elements, including a connection to Gull Drive for existing mutual access easements in the vicinity.
Architectural Design
The design for the 101 Gull Drive Project was inspired by the unique challenges and opportunities presented by the project site, which is set above the adjacent properties located to the south and east due to a steep embankment along Gull Drive, rendering approximately 25% of the project site undevelopable. In response to these conditions, the proposed design utilizes available site coverage and enhances existing natural resources via two interlocking structures, a 9-story building and 7.5-story parking garage, situated along the edge of the embankment to highlight the spectacular Bay views on the outside and create a serene, landscaped courtyard that is buffered from the prevailing winds on the inside. The exterior materials reinforce the difference in orientation, with a glass curtain wall to the south / east and Glass Fiber Reinforced Concrete (GFRC) panels with continuous ribbon windows to the north / west. The glass line at the lower levels is recessed, allowing the column grid to be expressed externally, with the soffit providing both shade and weather protection. The entry is clearly identified with a simple Entry Portal with an inviting double-height lobby beyond.
Landscaping and Open Space
The project provides landscaping and private open space in the form of plazas, seating enclaves, terrace gardens, pedestrian promenades, landscape buffers, and tree plantings throughout the site. Within the exterior amenity spaces and plazas, accent paving, modular and concrete seating, recessed wall / step and bollard lighting, and low water use native and adaptive plantings will be used to define various outdoor spaces as well as define circulation and heighten the sense of arrival and points of egress. The landscape areas throughout the site include C-3 filtration/Bio-retention zones to capture and treat building and site paving runoff which are integrated into the site landscape composition. The tree palette contains trees species to provide windscreens, feature plantings, and shade elements for open space and parking and circulation areas throughout the site. Landscape plans and planting palettes are included in the Plan Set (Associated Entitlements Resolution, Exhibit B).
Access and Circulation
Vehicular access to and from the project will be via three routes (all of which have mutual access easements with nearby properties and are further discussed below):
• Along an existing shared drive aisle heading southwest from the project site then along an existing driveway between the Plenty Unlimited and Nickell properties to connect with Eccles Avenue at an unsignalized intersection.
• Along one of two adjacent existing 30‐foot drive aisle easements between the Plenty Unlimited and Iron Mountain buildings to Oyster Point Boulevard.
• A new right‐in/right‐out only driveway on Gull Drive (which would require recording a new access easement over a sliver of City‐owned land).
As mentioned previously, the project site is located along Gull Drive but is largely separated from the roadway by a grade change and step slope. Additionally, the project site is located behind existing businesses fronting Eccles Avenue and Oyster Point Boulevard without direct access to the surrounding public rights-of-way. Existing access easements with nearby properties will provide mutual access to existing driveways on Eccles Avenue and Oyster Point Boulevard. The existing access easements include an easement to Eccles Avenue to the west (via 570-590 Eccles Avenue) and an easement to Oyster Point Boulevard to the north (via 340 Oyster Point Boulevard).
Four existing businesses would directly share the above access easements with the project. Plenty Unlimited, Inc., a hydroponic produce company to the north of the project site, and the Nickell Property, which includes several office complexes and a wholesale business (MTC Trading Company), to the west of the project site, have direct connections from their parking lots to the mutually accessible 30-foot driveway to Eccles Avenue. Iron Mountain, a records storage and document shredding facility, located to the east of the Plenty Unlimited building, utilizes 30‐foot drive aisles that intersect with Oyster Point Boulevard east of the signalized intersection with Eccles Avenue and the signalized intersection with a driveway to the north. While the intersection of these driveways with Oyster Point Boulevard is not signalized and would be limited to right‐in, right‐out movements by existing medians on Oyster Point Boulevard, it is possible for vehicles to access the adjacent signalized driveway intersection internally through the parking lot area for full turning options. Due to the constraints of the connection to Oyster Point Boulevard at this access point, the project’s onsite circulation has been designed to discourage outbound movement along this pathway.
A mutual access easement also runs along the northwest border of the project site and the USDA facility to the southwest of the project site, allowing access around the back of the Plenty Unlimited and Iron Mountain properties and, if the project is implemented, to Gull Drive via a proposed new two-way driveway. The location for the new driveway access to Gull Drive is through a City of South San Francisco owned parcel (APN 015-190-180), due to grading and existing landfill constraints within and surrounding the project site. A request for an access easement through the City parcel for the project’s driveway and access to the Gull Drive public right-of-way was reviewed and conditionally approved by the City Council on March 23, 2022. The conditional approval is contingent upon the Planning Commission’s approval of the requested entitlements.
Project parking will be provided in an attached 7.5-story garage with two entrances / exits, accessible via the new driveway off Gull Drive and the existing shared mutual access easements described above. Long-term bicycle parking will be provided on the first level of the parking structure near two of the garage entrances. A vehicular drop-off zone adjacent to the building entry and an entry plaza, and accessible via the new driveway off Gull Drive, can be used for
carshare and taxi drop-offs and pick-ups. Short-term bicycle parking will be provided next to the building entry and entry plaza, as well. Accessible pedestrian and bicycle connections between the main building entrance to Gull Drive and the parking garage will be provided.
In addition to bicycle and pedestrian environments within the project site, the 101 Gull Drive Project is also contributing to first-and last-mile and active transportation connections. The project will restripe a total of two crosswalks at the intersection of Oyster Point Boulevard and the 329-333 Oyster Point Boulevard driveway with high-visibility longitudinal markings to enhance pedestrian access to westbound shuttle stops and nearby land uses. The project will also install eastbound and westbound Class II buffered bicycle lanes along Eccles Avenue between Forbes Boulevard and Oyster Point Boulevard to enhance its connection to transit stations and nearby land uses, as well as a new westbound bus stop at the far side of the Oyster Point Boulevard / Eccles Avenue intersection. Modification of an existing eastbound shuttle stop at the far side of the Oyster Point Boulevard / Eccles Avenue intersection to provide an accessible five-foot-long by eight-foot-wide landing pad and pavement markings is also part of the project. The project will also participate in commuter shuttle programs, to encourage employees to commute via transit.
Entitlements Request
The Project is seeking the following entitlements, discussed in detail in this staff report:
• Design Review
• Transportation Demand Management (TDM) Plan
• Approval of an Addendum to the 101 Gull Drive Project Environmental Impact Report
ZONING CONSISTENCY ANALYSIS
Proposed Use
The project site is located within the Business Technology Park - High (BTP-H) Zoning District. Per South San Francisco Municipal Code (SSFMC) Section 20.100.002 (Use Regulations - Non-Residential Zoning Districts), R&D and office uses are both permitted land uses by-right.
Development standards for the BTP-H District are outlined in SSFMC Table 20.100.003 (Development Standards - Non-Residential Zoning Districts). As noted below, the proposed project complies with all applicable development standards.
Table 1. BTP-H Development Standard Compliance
Additional Development Standards
SSFMC Section 20.100.004 (Supplemental Standards) outlines several additional standards, including new objective design standards, applicable to projects located within a non-residential zoning district, including the BTP-H District. The project, as a whole (original and expanded portions), has been redesigned to comply with the new objective design standards. A summary of changes between the original project and the current proposal, including design changes, is included as Attachment 1 to this staff report. The project also complies with most of the applicable supplemental standards, with one exception in regard to the requirements outlined for the primary building entrance orientation, as discussed below. For compliance status with each required supplemental standard, please view Sheet 02 of the project plan set (Associated Entitlements Resolution, Exhibit B).
SSFMC Section 20.100.004(D) requires that the primary entrance of a building shall face or be oriented to within 45 degrees of a line drawn parallel to the street frontage. This entrance must allow pedestrians to both enter and exit the building. An exception through Design Review allows for the entrance orientation to be modified or waived through the design review process where the location or shape of the site warrant a variation and it is found that street-facing building walls will exhibit architectural relief and detail in such a way as to create visual interest at the pedestrian level and there are specific features of the site and design of the building such that strict application of the orientation requirement is not necessary to create or enhance pedestrian activity.
As mentioned in the Site Overview section above, the project site has frontage along Gull Drive but is largely separated from the roadway by a grade change and steep slope. Due to the existing site conditions, compliance with the primary building entrance orientation requirements would require extensive grading. In lieu of an entry directly along the Gull Drive façade of the building, the applicant has proposed the main building entry in a centralized location with direct pedestrian and vehicular access via a new driveway off Gull Drive. The existing sloped area will be utilized as a landscaped bluff with a trail, native plantings, and bioretention gardens. Staff has reviewed this justification and supports the exception to this requirement.
Site and Building Design Standards
SSFMC Chapter 20.310 (Site and Building Design Standards) prescribes general citywide site and building design standards to be used in conjunction with the applicable base zoning district requirements and design standards. The project complies with all applicable site and building design standards, including building materials and textures.
A subsection in SSFMC Section 20.310.002(I) (Building Materials and Textures) establishes requirements for glazing for bird safety. To determine whether this section is applicable to the project, an Avian Collision Risk / Bird-Safe Design Assessment was prepared by H. T. Harvey & Associates Ecological Consultants (Associated Entitlements Resolution, Exhibit D). The assessment determined that there is potential for moderate numbers of resident landbirds and larger numbers of migratory landbirds to be attracted to the project site relative to existing conditions, and the potential for avian collisions with the proposed building is likely to increase considerably after project completion. A number of bird-safe design measures for building glazing and lighting have been recommended to reduce avian collision risk with the proposed building. These have been included as a draft Condition of Approval to ensure compliance.
Parking Requirements
Vehicle Parking
The maximum number of allowed parking spaces for different land uses is regulated by SSFMC Section 20.330.004 (Required On-Site Parking Spaces). Pursuant to this section, office and R&D uses have different parking ratios. However, combined office and R&D buildings are subject to the parking requirements for R&D uses only, as office space has been considered in the establishment of the R&D parking ratio. Therefore, the proposal must meet the parking requirements for R&D uses, which is no more than 1.5 spaces per 1,000 sq. ft. Per the requirement, and based on the new square footage of 114,455 sq. ft., the expanded project would need to provide no more than 172 additional parking spaces.
The original project (166,613 sq. ft.) included a total of 419 parking spaces, at a ratio of 2.5 parking spaces per 1,000 sq. ft. At the time of approval, the project was subject to parking requirements under the previous Zoning Code, under which the parking ratios for both office and R&D uses were higher, and required the approval of a parking reduction of approximately 20% through a Conditional Use Permit.
Based on the previously approved parking for the original project, a total of no more than 591 parking spaces would be allowed for the project. The proposed attached parking garage will provide a total of 574 parking spaces. Therefore, the project complies with the maximum parking requirements. Maximum parking requirements are a tool to help ensure compliance with the City’s Transportation Demand Management ordinance.
Bicycle Parking
SSFMC Section 20.330.007 (Bicycle Parking) establishes the requirements for short-term and long-term bicycle parking. The minimum number of on-site short-term and long-term bicycle parking spaces are based on the use and number of required automobile parking spaces. The following requirements are applicable to the project:
• Short-term Bicycle Parking: Rate of 5% of the number of required automobile parking spaces, with a minimum of four bicycle parking spaces provided per establishment.
• Long-term Bicycle Parking: Rate of 5% of the number of required automobile parking spaces.
Per these requirements, and considering both the previous parking requirements at the time of the original project’s approval and the current parking requirements for the expanded square footage, the project must provide a total of 35 short-term and 35 long-term bicycle parking spaces on site.
The project includes the required number of both short-term and long-term bicycle parking spaces with short-term bicycle parking provided adjacent to the building entry and entry plaza and long-term bicycle parking provided on the first level of the attached parking structure.
Loading Requirements
SSFMC Section 20.330.009 (On-Site Loading) establishes requirements for on-site loading spaces for new buildings. Based on a square footage of approximately 281,000, the project would be required to provide five loading spaces for the project. SSFMC Section 20.330.009(A)(1) includes a provision for a reduction in the number of loading spaces required, upon a finding by the Chief Planner and City Engineer that the applicant has satisfactorily demonstrated that due to the nature of the proposed use, such loading space will not be needed.
The project is proposing to include two loading spaces, and the applicant has submitted a study by American Trash Management that outlines the justification for the reduction in loading spaces (Attachment 2). The report finds that a project of this size and operating characteristics would have between 12 - 13 commercial truck deliveries per day, which will be spread out from 7:00 AM to 3:00 PM. Given the number of deliveries and the wide variation in arrival times, on almost all occasions not more than two or three delivery vehicles will be on site at any one time per loading bay. Additionally, the project’s building management team will include a loading dock manager, who will be responsible for scheduling, assigning loading locations, and limiting truck size. Staff has reviewed this justification and supports the waiver for a loading space reduction to two spaces.
Transportation Demand Management (TDM) Plan
Pursuant to SSFMC Chapter 20.400 (Transportation Demand Management), office / R&D uses between 50,000 and 400,000 sq. ft. of gross floor area are required to provide a TDM plan and are categorized as “Tier 3” projects. The minimum requirements for Tier 3 projects are to achieve a total of 40 points, in addition to annual monitoring to achieve a maximum of 60% of employees commuting via driving alone. Points in various quantities are awarded based on specific trip reduction measures; for instance, including promotional programs and materials as a TDM measure would result in 1 point, whereas including a TDM coordinator/point of contact for commute assistance would result in 5 points. In other words, a Tier 3 project would have to propose the number and type of trip reduction measures that would accumulate sufficient points to achieve 40 points.
A draft TDM plan has been prepared for the project by Fehr + Peers (Associated Entitlements Resolution, Exhibit C). The draft TDM plan provides a concise description of TDM Measures that the project will implement to achieve the 40-point minimum for Tier 3 projects, including seven City-mandated TDM measures and a number of optional measures, as outlined below. A draft Condition of Approval is included to ensure TDM compliance and annual reporting.
Table 2. TDM Certification Checklist
GENERAL PLAN CONSISTENCY ANALYSIS
The General Plan Land Use designation for the project site is Business Technology Park High (BTP-H), which is intended for high-density corporate headquarters, research and development facilities, and offices. The site is also within the East of 101 Planning Sub-Area, as defined by the General Plan.
The Project is consistent with the guiding and implementing policies in the General Plan as it has been designed to develop an underutilized site with a high-quality employment use. The site layout and building design architecture will contribute to and further shape the urban character of the East of 101 Area. The proposed office / R&D project is consistent with the land use designation, which promotes office / R&D facilities and supplementary uses.
DESIGN REVIEW BOARD
The Design Review Board (DRB) reviewed the proposal on February 21, 2023, and recommended approval with some minor design revisions, including revising the proposed courtyard area to be more pedestrian-friendly and less vehicular oriented, and minor landscaping revisions, including replacing medium water plant species with more very low and low water plant species along the bluff area. (The DRB comment letter is included as Attachment 3 to this staff report.) The DRB’s comments have been taken into consideration by the applicant and incorporated into the project, and revised plans in response to the DRB comments were reviewed administratively by the DRB on March 21, 2023 and recommended for approval.
ENVIRONMENTAL REVIEW
The Planning Commission certified the 101 Gull Drive Project Environmental Impact Report (Project EIR) (State Clearinghouse #2021100227) for the original project on April 21, 2022, as well as adopted a Statement of Overriding Considerations (SOC) for the project’s significant and unavoidable impacts and a Mitigation Monitoring and Reporting Program (MMRP) for the project (Associated CEQA Resolution, Exhibit B).
An Addendum to the Project EIR was prepared (2023 Addendum) by Lamphier-Gregory in accordance with CEQA Guidelines Sections 15162 and 15164 to evaluate whether preparation of a subsequent EIR or negative declaration is required for the modified and expanded project. The 2023 Addendum concludes the following:
• The proposed expansion of the project would not result in new significant environmental effects or a substantial increase in the severity of previously identified significant effects;
• There are no changes in circumstances that would result in the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; and
• There is no new information resulting in a new significant effect not discussed in new significant environmental effects, a substantial increase in the severity of previously identified significant effects, or a change in the feasibility (or acceptance) of mitigation measures.
While the proposed expansion would result in a larger building and parking garage than analyzed under the Project EIR, the change in size would be considered a minor technical change per CEQA Guidelines Section 15164, as it would not change environmental conclusions. Therefore, the 2023 Addendum, in combination with the Project EIR, is the appropriate CEQA document for the project, and no additional CEQA analysis or documentation is required to make a decision on the project.
All mitigation measures identified in the Prior EIR would remain applicable to the expanded project, with revisions to Mitigation Measure TR-2 as outlined below. Changes to this mitigation measure are consistent with updated TDM requirements under the new Zoning Code.
Deletions are noted by strikethrough. Additions are underlined.
• Mitigation Measure TR-2: First- and Last-Mile Strategies. The project sponsor shall coordinate with the City for the project sponsor to implement the following off-site improvements to support the project’s first- and last-mile and active transportation connections necessary to support reductions in Home-Based Work Vehicle Miles Traveled.
• Implementation of a TDM Program consistent with the City’s performance and monitoring requirements for Tier 3 projects (office/R&D land uses), including implementing required measures such as Pparticipation in first-/last-mile shuttle program(s) to Caltrain and BART, 50 percent transit pass subsidies, carpool/vanpool programs, a designated TDM coordinator, and encouraging telecommuting and flexible work schedules. Shuttles may be operated by Commute.org and/or other East of 101 shuttle providers offering services open to the general public.
• Restriping of five crosswalks at the intersection of Oyster Point Boulevard and Eccles Avenue, one crosswalk at the intersection of Oyster Point Boulevard, and two crosswalks at the intersection of Oyster Point Boulevard and the 329-333 Oyster Point Boulevard driveway with high-visibility longitudinal markings to enhance pedestrian access to the westbound shuttle stop and nearby land uses.
The project sponsor shall additionally coordinate with the City for the project sponsor to pay fair-share contribution toward the following off-site improvements to support the project’s first and last-mile and active transportation connections necessary to support reductions in Home-Based Work Vehicle Miles Traveled
• Modification of the existing eastbound shuttle stop at the far side of the Oyster Point Boulevard/Eccles Avenue intersection to provide an accessible five-foot long by eight-foot wide landing pad and pavement markings (if such facilities are not already fully funded or constructed by the City or SamTrans).
• Installation of a bus shelter consistent with city specifications at the planned westbound bus shuttle stop at on the far side of the Oyster Point Boulevard/Eccles Avenue intersection (bus stop to be implemented by the City) including a pole, accessible five-foot long by eight-foot wide landing pad, pavement markings, and shelter (if such facilities are not already fully funded or constructed by the City or SamTrans).
• Provision of eastbound and westbound Class II buffered bicycle lanes along Eccles Avenue between Forbes Boulevard and Oyster Point Boulevard, spanning approximately 3,000 linear feet. The improvement consists primarily of restriping the curbside vehicle travel lane in each direction to a Class II buffered bicycle lane and signage. The bicycle facility will help close a gap between the project and a planned Class I shared-use pathway between Forbes Boulevard / Eccles Avenue and the South San Francisco Caltrain station.
The City has reviewed the 2023 Addendum and supplemental analysis (Associated CEQA Resolution, Exhibit A) and has determined that the project is consistent with previously adopted environmental documents and that no further environmental review is required pursuant to CEQA Guidelines sections 15162 and 15164.
CONCLUSION
The proposed 101 Gull Drive office / R&D project, as modified and expanded, is consistent with both General Plan goals and the Zoning Ordinance requirements. The project would produce a 9-story state-of-the-art office / R&D building at 281,058 sq. ft., an attached parking garage with 574 parking stalls, and includes enhanced connectivity and off-site improvements for alternative modes of transportation in the surrounding area. Further, the proposed project is consistent with the City’s ongoing development of the East of 101 Area into a nationally recognized biotechnology / R&D center, and ultimately will provide quality jobs in South San Francisco. For these reasons, staff recommends that the Planning Commission take the following actions:
1. Adopt a Resolution making findings and a determination that the 101 Gull Drive Project, as modified and amended, is fully within the scope of environmental analysis in the previously certified 101 Gull Drive Project Environmental Impact Report (EIR) and that the 2023 Addendum to the EIR is the appropriate document for the Project, and that no further environmental review is required per the California Environmental Quality Act (CEQA).; and,
2. Adopt a Resolution making findings approving the entitlements for Planning Project P21-0006, including Design Review DR22-0045 and Preliminary Transportation Demand Management Program TDM22-0010, based on the attached draft findings and subject to the attached draft Conditions of Approval.
Attachments
1. 101 Gull Drive Project Summary of Changes, dated February 21, 2023
2. American Trash Management Analysis, dated December 15, 2022
3. Design Review Board (DRB) Comment Letter, dated March 6, 2023
Exhibits to Associated CEQA Resolution (23-284)
A. Addendum to the 101 Gull Drive Project EIR, dated April 2023
B. 101 Gull Drive Project EIR
1. Final EIR (FEIR)
2. CEQA Findings and Statement of Overriding Consideration (SOC)
3. Mitigation Monitoring and Reporting Program (MMRP)
4. Draft EIR (DEIR)
5. DEIR Appendices
Exhibits to Associated Entitlements Resolution (23-285)
A. Draft Conditions of Approval
B. 101 Gull Drive Project Plans, dated April 2023
C. Proposed TDM Plan, dated April 2023
D. Avian Collision Risk / Bird-Safe Design Assessment, dated March 2, 2023