CHAPTER 7: CEQA FINDINGS OF SIGNIFICANCE 

Transbay Terminal / Caltrain Downtown Extension / Redevelopment EIS/EIR 7-1 

CHAPTER 7: CEQA TOPICS AND FINDINGS OF SIGNIFICANCE 

This chapter describes those potential environmental effects identified in Chapter 5 that would be 

considered significant under the California Environmental Quality Act (CEQA). Potential 

cumulative impacts are also described, and the potential for the project to stimulate unplanned 

growth is considered. 

While CEQA requires that a determination of significant impacts be stated in an EIS/EIR, the 

National Environmental Policy Act (NEPA) does not. Under NEPA, significance is used to 

determine whether an EIS or some other level of documentation is required, and once a decision 

to prepare an EIS is made, the magnitude of the impact is evaluated and no further judgment of 

its significance is required. For this reason, the CEQA significance criteria and the 

determination of significant impacts have not been included in other sections of this combined 

NEPA/CEQA EIS/EIR. Instead, those criteria and determinations have been grouped in this 

chapter, titled “CEQA Findings of Significance.” 

It should be noted that although the presence of mitigation under CEQA creates a presumption of 

significant impacts, NEPA anticipates that an EIS will identify means to mitigate the adverse 

impacts of a project if such measures are not already included in the proposed action or 

alternatives. For this reason, some mitigation measures described in this document and in this 

section are wholly appropriate under NEPA, although the impacts they address may not be 

considered significant under CEQA. 

7.1 SIGNIFICANCE CRITERIA 

CEQA requires that an EIR identify the significant environmental effects of the project (CEQA 

Guidelines Section 15126), but does not provide thresholds for significance. Instead, CEQA 

Guidelines Section 15064(b) states that "the determination . . . calls for careful judgment on the 

part of the public agency involved . . . " and that "an ironclad definition of significant effect is 

not possible because the significance of an activity may vary with the setting." In the current 

analysis, the City and County of San Francisco and the Joint Powers Board have given careful 

consideration to the issue of significance. As a result, the significance criteria shown in 

Table 7.1-1 have been used to evaluate the environmental impact categories indicated. 
CHAPTER 7: CEQA FINDINGS OF SIGNIFICANCE 

7-2 Transbay Terminal / Caltrain Downtown Extension / Redevelopment Project EIS/EIR 

Table 7.1-1: CEQA Significance Thresholds For Selected Environmental Impact Categories 

DEIS/ 

DEIR 

Sec. No 

IMPACT 

CATEGORY 

EXPLANATION OF 

CEQA SIGNIFICANCE THRESHOLD SOURCE(S) 

5.1.1 Land Use 

A significant impact would occur if the project 

would substantially disrupt or divide the physical 

arrangement of an established community; or 

have a substantial adverse impact upon the 

existing character of the vicinity. 

State CEQA 

Guidelines 

Appendix G 

5.1.2 Wind 

The project would have a significant impact if it 

would cause the City of San Francisco’s wind 

hazard criterion (26 miles per hour) for more 

than one full hour per year. 

San Francisco 

Planning Code 

Section 148 

5.1.3 Shadow 

A project would have a significant effect if it 

would result in substantial new shadow on public 

open space under the jurisdiction of the 

Recreation and Park Commission during the 

period from one hour after sunrise to one hour 

before sunset, at any time of the year. 

San Francisco 

Planning Code 

Section 295 

5.2 

Residential/ 

Business 

Displacement 

A significant impact would occur if the project 

would displace substantial numbers of people 

requiring the construction of replacement 

housing elsewhere. 

State CEQA 

Guidelines, 

Appendix G 

5.4, 

5.5 

Community 

Facilities & 

Services; 

Parklands, 

Schools & 

Churches 

A significant impact would occur if the project 

would: (a) conflict with established recreational, 

educational or religious uses; (b) conflict with 

adopted plans and goals of the community; (c) 

create additional demand for public service 

facilities, the expansion of which would result in 

environmental impact. 

Derived from 

State CEQA 

Guidelines 

Appendix G 

5.7 Air Quality 

A significant impact would occur if the project 

would violate any ambient air quality standard 

(NAAQS or CAAQS), increase the number or 

frequency of violations, contribute substantially 

to an existing or projected air quality violation, 

or expose sensitive receptors to substantial 

pollutant concentrations. 

State CEQA 

Guidelines, 

Appendix G; 

US EPA; 

BAAQMD 

5.8 Noise 

A significant impact would occur if the project 

would substantially increase the ambient noise 

levels for adjoining areas. A noise increase of 10 

db is perceived as a doubling of noise, and is 

generally considered substantial. (See Section 

5.8 for a discussion of the FTA Noise Criteria, 

which determine "impact" and "severe impact" 

under NEPA). 

Derived from 

State CEQA 

Guidelines, 

Appendix G 
CHAPTER 7: CEQA FINDINGS OF SIGNIFICANCE 

Transbay Terminal / Caltrain Downtown Extension / Redevelopment EIS/EIR 7-3 

Table 7.1-1: CEQA Significance Thresholds For Selected Environmental Impact Categories 

DEIS/ 

DEIR 

Sec. No 

IMPACT 

CATEGORY 

EXPLANATION OF 

CEQA SIGNIFICANCE THRESHOLD SOURCE(S) 

5.8 Vibration 

A significant impact would occur if the project 

would create intrusive vibration substantially 

affecting adjacent land uses. Vibration of 75 

VdB is generally considered intrusive for 

residential land uses. (See Section 5.8 for a 

discussion of the FTA Vibration Criteria). 

Derived from 

State CEQA 

Guidelines, 

Appendix G 

5.9 Geology/ 

Seismicity 

A significant impact would occur if the project 

would expose people or structures to major 

geologic hazards. 

State CEQA 

Guidelines, 

Appendix G 

5.10, 

5.11 

Water 

Resources 

A significant impact would occur if the project 

would cause substantial flooding, erosion, or 

siltation, or would substantially degrade water 

quality, or would substantially degrade or deplete 

ground water resources. 

State CEQA 

Guidelines, 

Appendix G 

5.14 

Cultural & 

Historic 

Resources 

A project is normally found to have a significant 

impact on the environment if the project would 

have a substantial adverse change to an historic 

resource – either an archaeological site, an 

historic architectural structure, or an historic 

district. 

A “historic resource” is defined as a resource that 

is listed in or determined eligible for listing in the 

California Register of Historic Resources; listed 

in or determined eligible for listing in the 

National Register of Historic Places; one that is 

included as significant in a locally adopted 

register such as Article 10 and 11 of the San 

Francisco Planning Code; or one determined by 

the lead agency to be historically significant. A 

resource that is deemed significant due to its 

identification in a historic resource survey that 

meets the criteria of Public Resources Code 

Section 5024.1(g) would be presumed an historic 

resource unless a preponderance of evidence 

demonstrates otherwise. A “substantial adverse 

change” is defined as demolition, destruction, 

relocation, or alteration of the resource or its 

immediate surroundings such that the 

significance of the resource would be materially 

impaired (a major change to the defining 

elements of historic character). 

Derived from 

State CEQA 

Guidelines 

(Sec. 15064.5 

and 15065(a); 

Appendix G; 

CEQA Sec. 

21084.1, and 

City and 

County of San 

Francisco 

Planning 

Department. 
CHAPTER 7: CEQA FINDINGS OF SIGNIFICANCE 

7-4 Transbay Terminal / Caltrain Downtown Extension / Redevelopment Project EIS/EIR 

Table 7.1-1: CEQA Significance Thresholds For Selected Environmental Impact Categories 

DEIS/ 

DEIR 

Sec. No 

IMPACT 

CATEGORY 

EXPLANATION OF 

CEQA SIGNIFICANCE THRESHOLD SOURCE(S) 

5.15 Hazardous 

Waste 

A significant impact would occur if the project 

would create a potential public health hazard 

involving the use, production, or disposal of 

materials which pose a hazard to people or 

animal or plant populations in the area affected. 

(Quantitative hazardous waste criteria exist for 

specific materials and constituents.) 

Derived from 

State CEQA 

Guidelines, 

Appendix G 

5.16 Visual Changes 

The project would have a significant effect on 

the environment if it would have a substantial 

effect on a scenic vista, substantially degrade or 

obstruct publicly accessible views; substantially 

degrade the existing visual character or the 

quality of the area, or result in a substantial, 

demonstrable negative aesthetic effect; or 

generate obtrusive light or glare that would 

adversely affect views or substantially affect 

other properties. 

Derived from 

State CEQA 

Guidelines, 

Appendix G 

5.18 Energy 

A significant impact would occur if the project 

would encourage activities which result in the 

use of large amounts of fuel, water or energy; or 

use fuel, water, or energy in a wasteful manner. 

State CEQA 

Guidelines, 

Appendix G 

5.19 

Transit 

Services & 

Accessibility 

A significant impact would occur if a project 

would cause a substantial project-specific or 

cumulative increase in transit demand that cannot 

be accommodated by existing or proposed transit 

capacity resulting in unacceptable levels of 

transit service. When considering cumulative 

development in the area, an adverse impact 

would also be created if the project contributed 

substantially to the deterioration of transit service 

or caused a substantial conflict with transit 

operations. 

San Francisco 

Planning 

Department 
CHAPTER 7: CEQA FINDINGS OF SIGNIFICANCE 

Transbay Terminal / Caltrain Downtown Extension / Redevelopment EIS/EIR 7-5 

Table 7.1-1: CEQA Significance Thresholds For Selected Environmental Impact Categories 

DEIS/ 

DEIR 

Sec. No 

IMPACT 

CATEGORY 

EXPLANATION OF 

CEQA SIGNIFICANCE THRESHOLD SOURCE(S) 

5.19 Traffic 

Congestion 

In San Francisco, the threshold for a significant 

adverse impact on traffic has been established as 

the deterioration in the level-of-service (LOS) at 

a signalized intersection to LOS E or F (i.e., a 

deterioration from LOS D or better to LOS E or 

F), or if an intersection at LOS E deteriorates to 

LOS F. An intersection that is at LOS E or F in 

the existing condition may be a significant 

adverse impact depending on the magnitude of 

the project's contribution to worsening of delay. 

In addition, a project would have a significant 

adverse effect if it would cause major traffic 

hazards, or would contribute considerably to 

cumulative traffic increases that would cause 

deterioration in levels of service to unacceptable 

levels. (See Sections 3.2 for a definition of LOS 

and a quantification of associated delay.) 

San Francisco 

Planning 

Department 

5.19 Traffic 

Circulation 

A significant impact would occur if the project 

would substantially change traffic circulation 

patterns, creating an unusual safety hazard, or 

eliminating access to surrounding areas. 

Derived from 

State CEQA 

Guidelines 

Section 15382. 

5.19 Parking 

Displacement 

The displacement of parking spaces is not 

generally considered a significant physical 

environmental effect but is a social effect and an 

inconvenience to those who must seek other 

parking. The displacement of parking spaces and 

any resulting parking deficits are also not 

considered to be a permanent condition as drivers 

may be induced to seek and find alternative 

parking facilities and shift to other modes of 

travel. Therefore, parking shortages are 

considered to be social effects rather than 

impacts on the physical environment. 

San Francisco 

Planning 

Department 

5.21 

Temporary 

Construction 

Period Effects 

Construction impacts on traffic, transit, noise, air 

quality, and the visual environment would 

generally not be considered significant since 

construction-related changes are by their nature 

temporary. A significant impact would occur 

only if temporary effects substantially affected 

accessibility to an area for a long period of time, 

or posed a severe health or safety threat. 

Derived from 

State CEQA 

Guidelines, 

Section 15382 

Source: Parsons Transportation Group and other sources as noted, September 2001. 
CHAPTER 7: CEQA FINDINGS OF SIGNIFICANCE 

7-6 Transbay Terminal / Caltrain Downtown Extension / Redevelopment Project EIS/EIR 

Some impact categories lend themselves to scientific or mathematical analysis, and therefore to 

quantification. For other impact categories that are more qualitative or are entirely dependent on 

the immediate setting, a hard-and-fast threshold is not generally feasible. In these cases, the 

definition of significant effects from the CEQA Guidelines (Section 15382) has been applied as 

the significance criterion: "a substantial adverse change in physical conditions." Where a 

potential impact category is not relevant to the current project (potential impact on floodplains is 

a good example), no significance criterion is presented. Also, unlike NEPA, CEQA does not 

require a discussion of socioeconomic effects, except where they would result in physical 

changes, and states that social or economic effects shall not be treated as significant effects (see 

CEQA Guidelines Sections 15064(f) and 15131). For this reason, socioeconomic impact 

categories are not included in Table 7.1-1. 

7.2 UNAVOIDABLE SIGNIFICANT ADVERSE EFFECTS UNDER CEQA 

7.2.1 EFFECTS ON HISTORIC RESOURCES

Construction of a new Transbay Terminal and the Caltrain Downtown Extension would require 

demolition of properties listed in the National Register of Historic Places (NRHP), or properties 

that are individually eligible for listing or that are contributors to multi-component properties or 

districts that are or appear eligible for listing. These properties are described in Section 5.14. 

The existing Transbay Terminal and associated bus ramps and approach structures would be 

demolished to construct the new Transbay Terminal component of the Project. These 

demolitions would constitute significant adverse effects under CEQA.

Under either Caltrain Downtown Extension alternative, the Cut-and-Cover Option would result 

in the demolition of an additional 13 properties that are individually eligible or that are 

contributors to a district that is or appears eligible for listing in the NRHP. Also, three 

buildings that are contributors to the Second and Howard Historic District / New Montgomery – 

Second Street Conservation District that would not be demolished would be isolated from the 

remainder of the district; this would constitute a substantial adverse change to the district. 

The Tunneling Option for the Townsend Street to Folsom Street segment of either of the Caltrain 

Downtown Extension alternatives would result in the demolition of ten fewer buildings than 

under the Cut-and-Cover Option, but three buildings that are either individually eligible or that 

are contributors to a historic district that is eligible would still be demolished, and three other 

contributory buildings would still be isolated from the remainder of the district, as described in 

the preceding paragraph. These effects would constitute a substantial adverse change. In 

general, projects that result in the substantial alteration or demolition of a recognized historic 

resource would be considered to have a significant effect on the environment. 
CHAPTER 7: CEQA FINDINGS OF SIGNIFICANCE 

Transbay Terminal / Caltrain Downtown Extension / Redevelopment EIS/EIR 7-7 

7.2.2 EFFECTS ON TRAFFIC AND CIRCULATION

Although the project would result in a reduction in regional vehicle miles traveled (VMT), there 

would be unavoidable significant traffic impacts at the following seven intersections in the 

vicinity of the Transbay Terminal. These significant effects would occur under both the 2020 

baseline plus the project and the 2020 cumulative conditions plus the project. 

• First/Market 

• First/Mission 

• First/Howard 

• Fremont/Howard 

• Beale/Howard 

• Second/Folsom and 

• Second/Bryant

The predicted levels of service (LOS) at these intersections (identified in Table 5.19-4 in 

Section 5.19) would exceed the San Francisco CEQA thresholds of significance. 

7.3 CUMULATIVE EFFECTS 

CEQA defines cumulative impacts as "two or more individual effects which, when considered 

together are considerable," and suggests that cumulative impacts may "result from individually 

minor but collectively significant projects taking place over a period of time" (State CEQA 

Guidelines Section 15355). CEQA documents are required to include a discussion of potential 

cumulative effects when those effects are significant and the State CEQA Guidelines suggest two 

possible methods for assessing potential cumulative effects (State CEQA Guidelines Section 

15130). The first method is a list-based approach, which considers a list of past, present, and 

reasonably foreseeable future projects producing related or cumulative impacts. The second 

method is projections-based, and uses a summary of projections contained in an adopted general 

plan or related planning document that is designed to evaluate regional or areawide conditions. 

The projections-based method is generally used by San Francisco in evaluating projects within 

its jurisdiction. 

While the use of regional projections is one possible method of analyzing cumulative effects 

under CEQA, it is the required method under NEPA. FTA guidelines require that regional 

growth projections from the metropolitan planning organization (MTC in this case) be used as 

input for the assumed future year conditions. 

The San Francisco County Transportation Authority (SFCTA) countywide travel demand 

forecasting model (SFCTA Model) was used to develop the travel forecasts for development and 

growth through the year 2020 in the region, as well as to determine travel demand to and from 

the South of Market area (area roughly bounded by The Embarcadero, Market Street, South Van 

Ness Avenue and King Street). This approach results in an impacts assessment for year 2020 
CHAPTER 7: CEQA FINDINGS OF SIGNIFICANCE 

7-8 Transbay Terminal / Caltrain Downtown Extension / Redevelopment Project EIS/EIR 

conditions that takes into account both the future development expected in the South of Market 

area, as well as the expected growth in housing and employment for the remainder of 

San Francisco and the nine-county Bay Area. 

The most up-to-date version of the SFCTA Model estimates future traffic and transit travel 

demand for the entire nine-county Bay Area region based on land use and employment forecasts 

prepared by the San Francisco Planning Department for the county, plus regional growth 

estimates developed and adopted by the Association of Bay Area Governments (ABAG) in 1998 

(Projections ’98) for the remainder of the Bay Area region. Travel demand was estimated for 

three land use scenarios: 

• 2020 No Project, which assumed future development and growth, consistent with the ABAG 

forecasts for San Francisco and the Bay Area, and incorporates projects that have recently 

been approved or entitled in the South of Market area. 

• 2020 Project, which included the additional development associated with the 

Terminal/Extension Project. 

• 2020 Cumulative, which incorporated other plans recently proposed in the South of Market 

area including the Rincon Hill Rezoning and the South of Market Redevelopment Area Plan, 

the Mid-Market Redevelopment Area Plan, and the Terminal/Extension Project. As a result, 

the year 2020 cumulative conditions forecasts used in the analysis exceed the ABAG 

forecasts for San Francisco for employment by about 2.8 percent, and household population 

by about 1.4 percent. 

7.3.1 REGIONAL CONTEXT

Because this document is based on accepted, regional land use forecasts for 2020, and assumes 

transportation improvements programmed within the same time frame, effects evaluated with the 

project include the cumulative effects of development within the region. Thus, additional 

analysis of potential cumulative effects related to specific development and transportation 

improvement projects within the region is not necessary. Impact categories for which the project 

effects presented in Chapter 5 already present cumulative conditions include the following: land 

use, transportation (including traffic and transit), air quality, and noise. 

7.3.2 LOCAL CONTEXT

Potential cumulative effects are not always regional in scope, and the current project was 

analyzed to determine whether less than significant environmental effects that would be 

experienced locally could become significant when considered with other reasonably foreseeable 

future projects in the project area. Reasonably foreseeable future projects are here defined as the 

projects assumed in the 2020 No-Project Alternative and described in Section 2.1, other plans 

recently proposed in the local South of Market area including, the Rincon Hill Rezoning and the 
CHAPTER 7: CEQA FINDINGS OF SIGNIFICANCE 

Transbay Terminal / Caltrain Downtown Extension / Redevelopment EIS/EIR 7-9 

South of Market Redevelopment Area Plan, the Mid-Market Redevelopment Area Plan, and the 

Terminal/Extension Project. As noted above the inclusion of these local plans results in a 2020 

cumulative scenario that exceeds the ABAG forecasts for San Francisco for employment by 

about 2.8 percent, and household population by about 1.4 percent. 

To assess the effects of the vehicle-trips generated by the Transbay Terminal/Caltrain Downtown 

Extension/Redevelopment Project on 2020 Cumulative local traffic conditions, the contribution 

of the Project (Assuming the Full Build Redevelopment Alternative) to the 2020 Cumulative 

traffic volumes was determined. Results of the traffic analyses for these land use scenarios are 

provided in Section 5.19.4 

7.3.3 CUMULATIVE VISUAL IMPACTS 

The determination of visual effect is by its very nature is subjective. Potential changes to the 

San Francisco greater downtown cityscape are shown in Figure 5.16-3. This graphic from the 

Redevelopment Agency’s Draft Design for Development Vision shows a possible urban form 

resulting from proposed changes to the height and bulk in the Transbay Redevelopment Area. 

The reasonably foreseeable proposed projects within the Rincon Hill area are also shown. In 

addition to these projects, the Rincon Hill Mixed Use District is currently undergoing 

environmental review for proposed changes to zoning with increased height allowances and 

revised bulk requirements that would allow additional tall towers to be developed. This Rincon 

Hill Mixed Use District development along with Transbay Redevelopment Plan and other 

development in the area would result in loss of some existing views, both short- and long-range, 

from such citywide open spaces as Dolores Park, Twin Peaks, and Potrero Hill. From these 

sites, the downtown core area would appear larger as it would be extended southward toward 

the Bay Bridge. This would be a distinct visual change from existing conditions with lower-rise 

structures to an intensive view of urbanization. A similar change to a more intensive urban view 

would be expected from viewpoints on Treasure Island. 

 

Likewise from the Bay Bridge, there would be a segment of the Bridge where the views both 

short- and long-range would change with the full implementation of the Transbay and Rincon 

plans. With implementation of the Transbay cumulatively with the Rincon Mixed Use district, 

the more urban downtown core would be closer to the Bridge, changing the views from vehicles 

traveling along the segment of the highway adjacent to Rincon Hill. These changed visual 

features are commonly accepted in urban areas and would not substantially degrade existing 

visual quality or obstruct publicly accessible views; however, the types of views would change to 

a more intensive urban visual character. However, while changing views, the project would not 

result in a demonstrative cumulative adverse aesthetic effect. 

7.4 GROWTH INDUCEMENT 

This section considers whether the Caltrain Extension to the Transbay Terminal Site Alternative 

would encourage development in excess of amounts expected and provided for in the region 
CHAPTER 7: CEQA FINDINGS OF SIGNIFICANCE 

7-10 Transbay Terminal / Caltrain Downtown Extension / Redevelopment Project EIS/EIR 

and/or San Francisco. Growth inducement would occur if the amount of population or 

employment growth projected to occur as a result of the project would exceed planned levels. 

Increased development and growth in an area are dependent on a variety of factors, including 

employment and other opportunities, availability of developable land, and availability of 

infrastructure, water, and power resources. 

Transportation projects are potentially growth inducing when they extend service to the edge of 

an urban area, reducing travel times and improving access between employment opportunities 

and vacant or underdeveloped land to the extent that the travel time savings and enhanced 

accessibility outweigh other factors affecting locational decisions. 

The Transbay Terminal/Caltrain Downtown Extension/Redevelopment Project is being designed 

to facilitate planned growth on under-utilized properties in the heart of downtown San Francisco. 

An important goal of the project is to promote a vibrant new mixed-use neighborhood in an 

urban center, and enhance public transit access in this area. The redevelopment component of 

the project would provide a mix of residential and commercial development in a pedestrianoriented neighborhood, which is consistent with the existing urban character of the Transbay 

Terminal area. The proposed Transbay Terminal would also provide a hub, bringing a large, 

transit-user population into a confined area, focusing opportunities for economic/joint 

development on the site, and potentially stimulating economic activity in the general vicinity. 

Transit travel times with the Downtown Extension alternatives are projected to decrease by as 

much as 15 minutes. These time savings, while sufficient to attract additional riders to Caltrain, 

are not expected to induce unwanted or unplanned growth, both because they are not great 

enough to offset other locational factors, and because the project would extend an existing rail 

corridor, within a region that is already developed. 

Modest growth is expected in the region by 2020, and San Francisco population is expected to 

grow approximately 11.7 percent from 723,959 in 1990 to 808,798 by 2020. At the same time, 

jobs are expected to grow 19.4 percent from about 566,648 in 1990 to about 731,664 in 2020, 

with some shift in downtown jobs to the South of Market Area. The primary factors causing the 

magnitude of this growth, such as the regional economy, availability of services, and so on, are 

independent of the proposed project. 

In the context of downtown San Francisco, opportunities created by the Transbay 

Terminal/Caltrain Downtown Extension/ Redevelopment Project would not be expected to 

stimulate unplanned growth, but would rather facilitate the distribution of projected growth to 

available sites, and facilitate development activities consistent with the San Francisco General 

Plan.