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Report regarding Public Comments on the Draft Environmental Impact Report (EIR) for the proposed South San Francisco General Plan Update, Zoning Code Amendments and Climate Action Plan. (Billy Gross, Principal Planner)
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RECOMMENDATION
Recommendation
Staff recommends that the Planning Commission review and take public testimony on the Draft Environmental Impact Report (DEIR) and provide any additional comments to staff.
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BACKGROUND/DISCUSSION
A General Plan is the local government’s long-term blueprint for the community’s vision of future growth. Each city is required by California law to have a General Plan to guide its future land use decisions. South San Francisco’s last comprehensive General Plan update occurred in 1999.
The City Council initiated the comprehensive General Plan Update process including Zoning Code Update and preparation of the Climate Action Plan in early 2019. The process included monthly meetings with the General Plan Community Advisory Committee, extensive community engagement meetings and several discussion/direction hearings with the Planning Commission and City Council. The draft General Plan and Climate Action Plan were released for public review and comment late March 2022, and the Zoning Code was released for public review and comment in early June 2022. Both documents are available on the project web page: www.ShapeSSF.net.
The Draft Program EIR evaluates the proposed General Plan Update, Zoning Code Amendments and Climate Action Plan (the “Project”). The General Plan Update anticipates approximately 14,312 net new housing units and approximately 42,297 net new employment opportunities by 2040. The project includes amendments to the Zoning Code necessary to implement the General Plan update and to incorporate Specific Plans that were previously adopted. The project also includes the updated 2022 Climate Action Plan (CAP) which includes a community-wide inventory of greenhouse gas (GHG) emissions and identifies strategies and measures to reduce GHG emissions generated by existing and future uses in the City.
A Notice of Preparation (NOP) for the proposed project was issued on February 3, 2021. The NOP describing the original concept for the project and issues to be addressed in the EIR was distributed to the State Clearinghouse, responsible agencies, and other interested parties for a 30-day public review period extending from February 3, 2021, to March 22, 2021. A virtual scoping meeting was held on February 17, 2021.
A revised NOP was circulated from January 14, 2022, to February 28, 2022, to provide the public with an opportunity to comment on changes that were made to the Project Description related to net new housing units and net new employment opportunities anticipated under the General Plan Update. A virtual Scoping Meeting for the revised NOP was held on January 31, 2022.
Draft Environmental Impact Report
The City, with assistance from its environmental consultant First Carbon Solutions, prepared the Draft Environmental Impact Report (DEIR) analyzing the potential environmental impacts of the General Plan Update, Zoning Code Amendments and Climate Action Plan. The purpose of an EIR is to disclose information to the public and to decision makers about the potential environmental effects of a proposed project. An EIR does not recommend either approval or denial of a proposed project; rather, it is intended to provide a source of independent and impartial analysis of the foreseeable environmental impacts of a proposed course of action.
Per the requirements of CEQA, the City circulated the DEIR on June 24, 2022, for a 45-day public review period. This Planning Commission public hearing is intended to allow the public and the Planning Commission an opportunity to provide comments on the DEIR. The public review period will conclude on August 9, 2022. The Planning Commission will not be taking action on the proposed project or the DEIR at this time; there will be additional Planning Commission and City Council public hearings to consider the General Plan, Zoning Code Amendments and Climate Action Plan along with the Final EIR (FEIR).
Pursuant to CEQA Guidelines Section 15168, the DEIR is a program-level EIR. Specifically, the DEIR provides a program-level analysis of the potential effects on the environment that could occur from implementation of the proposed project, which comprises buildout of the proposed General Plan. This DEIR serves as a master CEQA document that will provide environmental clearance for the future developments consistent with the General Plan, or will allow those projects to tier-off this DEIR if further site-specific analysis is warranted.
Environmental Impact Analysis
A lead agency (here, the City of South San Francisco) may not approve a project that may result in significant impacts unless the lead agency finds that changes or alterations that will avoid or substantially lessen the impacts have been required or incorporated into the project, that such changes or alterations are within the responsibility of another jurisdiction, or that specific considerations make mitigation of the impacts or alternatives to the project infeasible.
The following CEQA categories have impacts that can be reduced through mitigation:
• Aesthetics, Light and Glare
• Biological Resources
• Cultural and Tribal Cultural Resources
• Energy
• Geology, Soils and Seismicity
• Greenhouse Gas Emissions (GHGs)
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Land Use and Planning
• Noise
• Population, Housing and Employment
• Public Services and Recreation
• Utilities and Service Systems
• Wildfire
The DEIR identifies the proposed Project would result in several significant unavoidable adverse impacts as feasible mitigation measures have either not been identified, have uncertain feasibility, or may not be effective in reducing the impacts to a less than significant level. These impacts, relate to air quality and transportation, are as follows:
• Project-Level Vehicle Miles Traveled: The proposed project’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 proposed project 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. This impact is also considered significant and unavoidable under the cumulative analysis.
• Project-Level Roadway Safety: Implementation of the proposed project would increase vehicle trips on the City’s freeway ramps, which would cause vehicle queues to exceed offramp storage capacity or exacerbate offramps that already experience offramp queues exceeding storage capacity, resulting in a potentially significant impact. The proposed project 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 offramps and adjacent intersections that help manage offramp queues to minimize queueing hazards. MM TRANS-1 is also applicable and would be implemented to minimize freeway offramp queues. However, even with the implementation of General Plan Update policies and 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. This impact is also considered significant and unavoidable under the cumulative analysis.
• Project-Level Conflict with 2017 Bay Area Clean Air Plan: The VMT growth facilitated by the proposed project would constitute an approximately 94 percent growth through 2040 while population growth facilitated by the proposed project would constitute an approximately 61 percent growth through 2040. The forecasted VMT growth would outpace the forecasted population growth facilitated by the proposed project. Therefore, the proposed project would be considered inconsistent with the 2017 Clean Air Plan. The proposed project would implement MM TRANS-1, which would achieve the maximum feasible reductions in vehicle travel. However, even with the implementation of the General Plan Update policies and actions and implementation of MM TRANS-1, because the effectiveness of VMT reduction strategies cannot be quantified in this programmatic analysis, the City of South San Francisco may not achieve the overall VMT threshold reduction level. As such, this impact would be significant and unavoidable. This impact is also considered significant and unavoidable under the cumulative analysis.
• Project-Level Criteria Air Pollutants: Because the proposed project’s projected VMT growth outpaces projected population growth, the proposed project would result in a cumulatively considerable net increase in criteria pollutants, and this impact would be potentially significant. The proposed project 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 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. This impact is also considered significant and unavoidable under the cumulative analysis
Alternatives Analysis
An EIR is required to assess a range of reasonable alternatives to the proposed project that would feasibly attain most of the basic objectives of the project while avoiding or substantially lessening any of the significant impacts of the project and evaluate the comparative merits of each alternative.
Three alternatives to the proposed project were evaluated and are discussed in detail in the DEIR. The three alternatives are:
• Alternative 1-No Project Alternative/1999 General Plan - Under the No Project Alternative/1999 General Plan, the General Plan would not be updated with new policies and no zoning or land use designation changes would occur. Future development would be in accordance with the current land use and zoning maps identified in the 1999 General Plan. The 1999 General Plan provided for development of then-approved projects plus future development of a total of 2,780 housing units and 9 million square feet of nonresidential space to the City’s current inventory of an estimated 19,400 housing units and 18.1 million square feet of nonresidential development. The 1999 General Plan estimated a population of 67,400 at projected buildout in 2020. Existing land uses in 2019 include 24,647 residential units and 31,906,205 square feet of commercial/industrial/civic space. Additionally, under this alternative the Zoning Code would not be updated, and the City would not consider updating the existing Climate Action Plan (CAP). Under this alternative, the current goals, policies, and zoning would remain in place through the horizon year.
• Alternative 2-Decreased Employment Alternative - Under the Decreased Employment Alternative, there would be a 25 percent decrease in nonresidential uses in the East of 101, Lindenville, and El Camino subareas to decrease the number of employment opportunities and improve the jobs/housing balance in the City. It is assumed that these decreases would not occur within 0.333 mile of existing transit. This alternative was selected because it would decrease VMT associated with employment and would therefore result in reduced traffic related impacts compared to the proposed project.
• Alternative 3-Increased Residential Alternative - This alternative would propose an increase in residential development along the El Camino Real transit corridor through increased density zoning (see Exhibit 4-2). This alternative would result in an increase in approximately 500 dwelling units compared to the proposed project. An additional 3,017 residential units would be added to this area (compared to the 2,524 units under the proposed project). Approximately 95 acres of what is now proposed as Medium-Density Mixed Use along El Camino Real and around the Bay Area Rapid Transit (BART) station would be designated as High-Density Mixed Use, resulting in a change in maximum allowable density from 120 dwelling units per acre to 180 dwelling units per acre. Maximum building heights for these parcels would increase from 85 feet to 120 feet. This alternative was selected because it would reduce the jobs to housing imbalance; thereby reducing VMT impacts associated with commuting compared to the proposed project.
Next Steps
The DEIR public comment period is open from June 24, 2022 through August 9, 2022. After the comment period closes, staff and the City’s CEQA consultant will prepare written responses to comments received on the DEIR and circulate a Final EIR (FEIR). Together the DEIR and FEIR will constitute the EIR for the General Plan, Zoning Amendment and Climate Action Plan, which will be presented to the Planning Commission and City Council for certification prior to formal action on the General Plan, Zoning Amendment and Climate Action Plan.
CONCLUSION
Staff recommends that the Planning Commission review and take public testimony on the Draft Environmental Impact Report (DEIR) and provide any additional comments to staff.
ATTACHMENTS
1. Draft Program EIR for the General Plan Update, Zoning Code Amendments and Climate Action Plan
2. DEIR Appendices (available online at <https://weblink.ssf.net/weblink/>, go to Planning>Environmental Reports>General Plan>2022 General Plan)