Title
Report regarding consideration of a recommendation to the City Council for a General Plan Amendment to comply with Senate Bill 1425 to create a new General Plan policy and actions that address equitable access to open space, climate resilience, and rewilding opportunities and determination that an Addendum to the 2040 General Plan Environmental Impact Report is the appropriate CEQA document per CEQA Guidelines Sections 15162 and 15164. (Adena Friedman, Chief Planner)
label
MOTIONS TO ADOPT STAFF RECOMMENDATIONS
1. Move to adopt a resolution recommending that the City Council make a CEQA determination; and
2. Move to adopt a resolution recommending that the City Council adopt a General Plan Amendment.
RECOMMENDATION
Recommendation
Staff recommends that the Planning Commission conduct a public hearing and adopt a Resolution making findings and recommending that the City Council adopt a General Plan Amendment to comply with State Senate Bill No. 1425 to create a new policy and actions that address equitable access to open space, climate resilience, and rewilding opportunities and adopt a resolution recommending that the City Council make a determination that an Addendum to the Environmental Impact Report for the Shape SSF 2040 General Plan (2040 General Plan EIR) is the appropriate CEQA document per CEQA Guidelines Sections 15162 and 15164.
Body
BACKGROUND/DISCUSSION
California State Senate Bill No. 1425 (SB1425) mandates that all cities and counties review and update their open space elements by January 1, 2026. This legislation requires updates to incorporate policies and actions that address equitable access to open space, climate resilience, and rewilding opportunities. Specifically, the updated open space elements must consider social, economic, and racial equity, correlate with the land use, safety, and environmental justice elements of the General Plan, and explore opportunities to enhance and expand integrated open space networks. SB1425 necessitates a review and revision of the City’s existing open space policies and actions to align with the state's objectives.
Specifically, SB1425 added section 65565.5 to the California Government Code, which reads:
(a) Every city and county shall review and update its local open-space plan by January 1, 2026. The update shall include plans and an action program, as required by Section 65564, that address all of the following:
(1) Access to open space for all residents in a manner that considers social, economic, and racial equity, correlated with the environmental justice element or environmental justice policies in the general plan, as applicable.
(2) Climate resilience and other cobenefits of open space, correlated with the safety element.
(3) Rewilding opportunities, correlated with the land use element.
(b) For purposes of this section, “rewilding opportunities” may include, but are not limited to, the following:
(1) Opportunities to preserve, enhance, and expand an integrated network of open space to support beneficial uses, such as habitat, recreation, natural resources, historic and tribal resources, water management, and aesthetics.
(2) Establishing a natural communities conservation plan to provide for coordinated mitigation of the impacts of new development.
Failure to comply with the requirements of SB1425 does not carry specific penalties under State law. However, noncompliance may disqualify or make the City less competitive for securing grant funding for environmental projects and programs, such as fire management or open space restoration projects.
ANALYSIS & PROPOSED AMENDMENTS
Staff conducted an analysis of the 2040 General Plan considering the requirements of SB1425. The following is an overview of staff’s analysis and recommendations:
SB1425 Requirement 1
Regarding SB1425 Requirement 1: Access to open space for all residents in a manner that considers social, economic, and racial equity, correlated with the environmental justice element or environmental justice policies in the general plan, as applicable.
Analysis & Recommendation: The 2040 General Plan’s goals, policies, and actions address and meet this requirement, especially those in Chapter 10: Abundant and Accessible Parks and Recreation and Chapter 12: Community Health and Environmental Justice.
Proposed Amendments: No amendments are required or proposed.
SB1425 Requirement 2
Regarding SB1425 Requirement 2: Climate resilience and other cobenefits of open space, correlated with the safety element.
Analysis & Recommendation: The 2040 General Plan includes goals, policies, and actions that address this requirement; however, staff recommends adding a new policy and new actions to Chapter 10: Abundant and Accessible Parks and Recreation to better connect open space planning, climate resilience, and hazard mitigation planning. Staff also recommends adding references to Goals CR-1, CR-2, and CR-5 in Chapter 13: Community Resilience (safety element) to correlate the proposed policy and actions with the safety element, as required in SB1425.
Proposed Amendments: Staff proposes adding a new policy and actions, as detailed in the section below titled “Proposed Changes to Address SB1425 Requirement 2 and 3.”
SB1425 Requirement 3
Regarding SB1425 Requirement 3: Rewilding opportunities, correlated with the land use element.
Analysis & Recommendation: The 2040 General Plan includes goals, policies, and actions to create new open spaces, parks, and trails, especially in Chapter 10: Abundant and Accessible Parks and Recreation. The General Plan also discusses the importance of parks and open space for wildlife, pollinators, and native plant species.
The General Plan does not include the terms “rewild” or “rewilding,” and staff recommends adding an action to Chapter 10: Abundant and Accessible Parks and Recreation to more directly address rewilding opportunities. Staff also recommends adding a reference to Goal LU-8 in Chapter 5: Land Use and Community Design (land use element) to correlate the proposed action with the land use element, as required in SB1425.
Proposed Amendments: Staff proposes adding a new policy and actions, as detailed in the section below titled “Proposed Changes to Address SB1425 Requirement 2 and 3.”
Proposed Changes to Address SB1425 Requirement 2 and 3
Staff proposes adding the following new policy and actions to address SB1425 Requirements 2 and 3. The proposed policy and actions are underlined.
Chapter 10: Abundant and Accessible Parks and Recreation
Goal PR-3: South San Francisco maintains a network of open spaces that provide recreational opportunities and are managed to encourage healthy ecosystems, improve air and water quality, and adapt to a changing climate.
Proposed Policy PR-3.4: Incorporate open space considerations into climate resiliency planning. Incorporate the strategic use of open spaces into climate resilience planning and hazard mitigation strategies.
Proposed Action PR-3.4.1: Develop nature-based solutions within open space areas. Develop and implement nature-based solutions within open space areas to mitigate climate hazards, enhance ecological function, and improve community well-being.
Proposed Action PR-3.4.2: Prioritize natural open spaces. Prioritize the restoration and expansion of natural open spaces, such as wetlands, riparian corridors, and urban forests, to enhance flood control, reduce urban heat island effects, improve air quality, and sequester carbon.
Proposed Action PR-3.4.3: Consider emergency management and operations in open space planning. Ensure that open space planning considers the potential for open space areas to function as emergency staging areas, evacuation routes, and community resource centers during climate-related events.
Proposed Action PR-3.4.4: Engage with tribal communities to incorporate indigenous land stewardship practices into climate resilience and rewilding strategies.
Proposed Action CR-3.4.4: Assess the use of open space and native and fire resilient plant communities in fire prevention planning. Assess the role of open space in mitigating wildfire risk, and include open space management in wildfire prevention planning.
Proposed Action CR-3.4.5: Use open space areas as adaptable floodable spaces. Design and manage open space areas, particularly those adjacent to the San Francisco Bay and Colma Creek, to function as adaptable floodable spaces.
Proposed Action CR-3.4.6: Identify rewilding opportunities in the built and natural environments, particularly in the areas along Colma Creek, along the San Francisco Bay, and around and between Sign Hill and San Bruno Mountain. As a part of land use and open space planning, identify rewilding opportunities in both the built and natural environments to foster biodiversity and healthy ecosystems, benefiting humans, animals, and plants, and to mitigate the impacts of new development.
For related policies and implementation actions related to open space, open space management, and ecology, see Goals LU-8, CR-1, CR-2, CR-5, ES-1, ES-2, ES-3, and ES-5.
Staff also recommends adding a reference to the goals below regarding Goal PR-3 to provide internal consistency and connection within the General Plan. New, proposed text is underlined.
Goal LU-8: A network of attractive, pedestrian-oriented, human-scale and sustainable, climate-adapted and well-landscaped streets and civic spaces throughout the city for all ages and abilities.
For related policies and implementation actions related to open space management, see Goal PR-3.
Goal CR-1: The City proactively advances community resilience and is prepared for hazards, including climate disruption.
For related policies and implementation actions related to open space and climate resiliency planning, see Goal PR-3.
GOAL CR-2: A resilient community that protects existing and future development and people from sea level rise and flooding.
For related policies and implementation actions related to open space management, sea level rise, and flooding, see Goal PR-3.
GOAL CR-5: The City minimizes the risk to life and property from wildfire in South San Francisco.
For related policies and implementation actions related to open space and wildfire management, see Goal PR-3.
Parks & Recreation Master Plan Update
The Parks and Recreation department recently released a Request for Proposals to update the Parks & Recreation Master Plan. The Master Plan will be used as a resource for future development and enhancement of the City’s parks, open space, recreational facilities, and recreation system over the next 10 to 15 years. Additionally, staff will incorporate consideration of the SB1425 requirements into the Parks & Recreation Master Plan update to further connect and implement these policies and actions. The plan is expected to take 12 - 18 months to complete.
ENVIRONMENTAL REVIEW
In October 2022, the City Council certified a programmatic Environmental Impact Report for the 2040 General Plan Update, Zoning Code Update and Climate Action Plan Update (2040 General Plan EIR) (State Clearinghouse No. 2021020064) (see Associated CEQA Resolution, Exhibit B). The City Council also adopted a Statement of Overriding Considerations in 2022, which carefully considered each significant and unavoidable impact identified in the 2040 General Plan EIR, related to project-level vehicle miles traveled, project-level roadway safety, project-level conflict with 2017 Bay Area Clean Air Plan, and project-level criteria air pollutants and found that the significant environmental impacts were acceptable in light of the social, economic, and environmental benefits associated with implementation of the 2040 General Plan Update.
The Planning Division, with assistance from Lamphier-Gregory, Inc., prepared an Addendum to the 2040 General Plan EIR (see Associated CEQA Resolution, Exhibit A), the purpose of which is to demonstrate that a subsequent environmental document is not required per Sections 15164 and 15162 of the CEQA Guidelines. The proposed General Plan Amendment is programmatic and:
• Does not modify land use designations or allowable land uses;
• Does not increase development intensity, density, or capacity;
• Does not authorize the construction, expansion, or alteration of any residential or non-residential structures; and
• Does not directly result in any physical changes to the environment.
The proposed General Plan Amendment provides policy-level guidance only and would continue to rely on future discretionary approvals and project-level environmental review, as required, for any development proposals that may be considered in the future.
Based on the analysis contained in the Addendum, none of the conditions described in CEQA Guidelines Sections 15162 that would require preparation of a Subsequent or Supplemental EIR have occurred. Specifically:
• No substantial changes to the project have been proposed that would require major revisions to the EIR;
• No substantial changes in circumstances have occurred; and
• No new information of substantial importance has become available that would result in new or more severe significant impacts.
Accordingly, the General Plan Addendum is the appropriate level of environmental documentation for the proposed General Plan policy and action updates.
SB18 - TRIBAL CONSULTATION
SB 18 requires that jurisdictions conduct tribal consultation with any federally recognized California Native American tribes, or non-federally recognized California Native American tribes, that are within the local government’s jurisdiction, are on the contact list maintained by the Native American Heritage Commission (NAHC) and are affected by a proposed General Plan Amendment. City staff conducted tribal consultation per the requirements of SB 18 and conducted outreach to seven tribes on a list provided by the NAHC (see Attachment 1, Tribal Consultation Outreach). Of these tribes, the Indian Canyon Mutsun Band of the Costanoan Ohlone People requested consultation. Planning Division staff conducted a meeting with a representative of tribe to gather input on the proposed General Plan amendment, which included the following:
• Open space projects should include training, capacity building, and learning opportunities for and about indigenous people
• Apply indigenous pedagogies when looking at landscaping and rewilding projects
• Create an accessibility strategy to allow native people to have access to open space areas, particularly areas where native plants are being planted
As a result of this consultation process, staff recommends the inclusion the following action: Engage with tribal communities to incorporate indigenous land stewardship practices into climate resilience and rewilding strategies. (Proposed Action PR-3.4.4). There will be additional opportunities for tribal consultation and outreach as part of the Parks & Recreation Master Plan.
CONCLUSION
Staff has conducted an analysis of the 2040 General Plan in light of the requirements of Senate Bill No. 1425. To meet the requirements of SB1425, staff recommends amending the 2040 General Plan to add a new policy and actions, as detailed above. The proposed policies and actions serve to further implement several of the existing General Plan goals and policies, as while ensuring consistency with State law.
Staff recommends that the Planning Commission adopt resolutions recommending that the City Council adopt the General Plan Amendments to comply with SB1425 and determine that the SB1425 Addendum is the appropriate CEQA document.
Attachments:
1. SB 1425, Government Code Section 65565.5
2. Tribal Consultation Outreach, per SB18
Exhibits to Associated CEQA Resolution (Legistar File 26-XXXX)
A. SB1425 Addendum to the 2040 General Plan EIR
B. 2040 General Plan EIR (Link to online document)
Exhibit to the Associated General Plan Resolution (Legistar File 26-XXXX)
A. Proposed General Plan Amendment