Cumulative Impact Management: Cumulative Effects Case Studies
Attachment L: Cumulative Shadow Analysis & 30 Van Ness ...
Transcript of Attachment L: Cumulative Shadow Analysis & 30 Van Ness ...
30 Van NessShadow Impacts
Attachment L: Cumulative Shadow Analysis & Shadow Coverage Diagram (The HUB Plan)
The following document contains selected pages of the HUB Plan shadow analysis, including methodology, analysis findings, and net shadow fan diagram. Provided to San Francisco Planning Department by PREVISION
February 11, 2019FINaL DraFT
TO: ALANA CALLAGY, SAN FRANCISCO PLANNING DEPT.1650 MISSION STREET, SUITE 400SAN FRANCISCO, CA 94103
FROM: ADAM PHILLIPS
PRINCIPALPREVISION DESIGN
Shadow analysis report for The Hub Plan,
30 Van Ness Avenue Project, 98 Franklin Street Project,
and Hub Housing Sustainability District (HSD) EIR
PREVISION DESIGN | THE HUB PLAN EIR CEQA SHADOW AN ALYSIS | FIN AL | FEBRUARY 11, 2019 PAGE 9
Planning Code Sections 146 and 147, both added in 1985, establish additional design
guidelines for buildings in C-3 Downtown Commercial, South of Market Mixed Use,
and Eastern Neighborhoods Mixed Use Districts for the purpose of limiting shadow on
public sidewalks, public plazas, and other publicly accessible spaces other than those
protected under Section 295.
Significance Criteria for Environmental Review under CEQA
Aside from the focused provisions of Sections 146, 147, and 295 of the Planning Code,
the San Francisco Planning Department has not formally adopted specific significance
criteria to be used in evaluating shadow impacts under CEQA. However, it is generally
considered that implementation of a project would have significant impacts if it were to
create net new shadow in a manner that substantially affects existing or future planned
outdoor recreational facilities or other public areas, or significantly detracts from the
usability of other existing publicly accessible open space.
IV. ANALYSIS METHODOLOGY and SCOPE OF REVIEW
Technical Standards
While there are no broadly established technical standards or methodologies for
evaluation of shadow effects under CEQA, the CEQA analysis for development
projects in San Francisco typically relies on the technical methodology developed
to demonstrate compliance with Planning Code Section 295 as described in (1) the
February 3, 1989 memorandum titled “Proposition K – The Sunlight Ordinance,”
and (2) the July 2014 memorandum titled “Shadow Analysis Procedures and Scope
Requirements.” The Recreation and Park Commission and the Planning Commission
adopted criteria in 1987 and 1989 for the review of shade, solar access, and shadow
effects. According to those adopted criteria:
Shadow is quantitatively measured by multiplying the area of the shadow by the
amount of time the shadow is present on the open space, in units called square
foot-hours (sfh). Determining the annual net new shadow load generated by a
project begins with a calculation of the number of square foot-hours that would
theoretically fall on a qualifying publicly accessible open space each day from
an hour after sunrise to an hour before sunset summed over the course of a year,
ignoring all shadow from any source. This total is referred to as the Theoretical Annual Available Sunlight (TAAS) for that park. The second step is the calculation
of the baseline (or current) shading conditions, which factors in the square foot-
hours of shadow cast by existing buildings and other structures on the open
PREVISION DESIGN | THE HUB PLAN EIR CEQA SHADOW AN ALYSIS | FIN AL | FEBRUARY 11, 2019 PAGE 10
space. Lastly, the shadow effects of the project are calculated, with the difference
between the baseline shadow condition and project shadow condition considered
being net new project shadow. The amount of shadow is defined as the shadow
in square foot-hours cast by the project divided by the TAAS, expressed as a
percentage.
Further, in addition to quantitative criteria, the adopted criteria set forth
qualitative criteria for evaluation of shadow. Those criteria for assessing net new
shadow are based on existing shadow profiles, important times of day, important
seasons in the year, location of the net new shadow, size, and duration of net new
shadows and the public good served by buildings casting net new shadow.
For this report, the San Francisco Planning Department has directed PreVision Design
to use most of the standards for review of shadow under Section 295, as described in the
following sections.
Quantitative Methodology
To perform quantitative shadow calculations, PreVision Design generated a 3D virtual
massing model of the urban context inclusive of all existing and proposed buildings/
sites (detailed further under Modeling Assumptions below). Within one hour after
sunrise through one hour before sunset (hereafter “the daily analysis period”),
PreVision Design performed snapshot analyses at 15-minute intervals, repeating this
process every seven days between the Summer Solstice (June 21) and Winter Solstice
(December 20), with interim times and dates extrapolated to approximate shadow
conditions on other days and times. This half-year period (between the Summer and
Winter Solstices) is referred to by the San Francisco Planning Department as a “solar
year.” Because the path of the sun is mirrored over the second half of the year, analysis
of this half-year period allows for reasonable extrapolation to arrive at a full-year
estimated shading calculation1.
In addition to the quantitative analysis of existing shadow conditions and the net
new shadow that would be generated by the Hub Plan (including the associated
individual projects at 30 Van Ness Avenue and 98 Franklin Street), this report
includes calculations to capture the combined shadow effects that would be generated
1 Annual percentages of existing shadow as listed in this report may vary from what has been reported within past shadow analysis reports on prior projects. In 2016 issued updated technical direction regarding solar angles and in 2017 the geographic boundaries of many parks were revised and re-issued by SF Planning, both which altered the calculated existing shadow loads of many parks. Additionally, due to the large number of data sample, rounding, extrapolation and unavoidable minor variations that occur in the software simulation process, even under identical model conditions minor discrepancies (typically under 0.05%) in calculated values may occur.
PREVISION DESIGN | THE HUB PLAN EIR CEQA SHADOW AN ALYSIS | FIN AL | FEBRUARY 11, 2019 PAGE 11
by adding reasonably foreseeable future projects2 that would cast shadow on the
same public open spaces affected by shadow from the Hub Plan (including the two
individual development projects). These calculations are referred to as the “Cumulative
Scenarios.” Because the environmental review process currently underway for the
proposed development at 10 South Van Ness Avenue evaluates both a proposed project
and a project variant, this report analyzes two separate cumulative scenarios reflecting
these two proposals for development at 10 South Van Ness Avenue.
Graphical Methodology
To provide a spatial and contextual understanding of the location, size, and features
affected by net new shadow, PreVision Design has prepared the following shadow
graphics to accompany the quantitative analysis:
• Net new shadow Fans. Graphic showing the full extent of the areas receiving
net new shadow at ANY point throughout the year, factoring out the presence of
shadow cast by existing buildings. Three shadow fans have been prepared as part
of this analysis, depicting the Hub Plan Scenario, the 30 Van Ness Avenue Project,
and the 98 Franklin Street Project.
• Sweep Shadow diagrams. Graphics showing “snapshot” shading conditions
at hourly intervals over the entire affected area for the Hub Plan, 30 Van Ness
Avenue, and the 98 Franklin Street scenarios. Graphics reflect shadow conditions
within the daily analysis period on the Summer Solstice (June 21), the approximate
equinoxes (March 22/September 20), and the Winter Solstice (December 20) and
the date with the greatest quantitative net new shadow (if different from above).
These graphics appear as Exhibits B-D.
• Detail Shadow diagrams. For parks and open spaces subject to Section 295,
graphics are produced showing “snapshot” shading conditions at hourly intervals
within the daily analysis period on the Summer Solstice (June 21), the approximate
equinoxes (March 22/September 20), and the Winter Solstice (December 20) and
the date with the greatest quantitative net new shadow (if different from above).
At times when the project is casting net new shadow on an open space, additional
graphics are provided at 15-minute intervals. These graphics appear as Exhibit E1-
E12.
2 Projects that are currently in some stage of the planning or permitting process but have not yet been ap-proved or have been approved but are not yet under construction.
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Qualitative Methodology
To gain a better understanding of how net new shadow may or may not affect existing
patterns of use in the affected the open spaces that are subject to Section 295, PreVision
Design conducted3 six 30-minute site visits to each open space to observe the nature
and intensity of uses. Two site visits were performed in the morning, two at midday,
and two late in the day, with one visit from each pair on a weekday and one on a
weekend.
The qualitative effects of net new shadow on the affected open spaces are discussed
based on the size, timing, and duration of net new shadow and how such shadow might
affect observed existing patterns of use.
Modeling Assumptions
Existing Conditions Model:
PreVision Design’s existing conditions model reflects an accurate 3D representation of
the affected area generated by Light Intensity Distance and Ranging [or Laser Imaging
Detection and Ranging] (LIDAR) modeling of both the terrain of San Francisco and all
existing buildings.4 Locations, boundaries, and sizes of the affected open spaces are
based on GIS data provided by the San Francisco Planning Department and/or RPD.
The Hub Plan Model:
Building forms used for the 17 Hub Plan sites (i.e., the 17 sites where the Hub Plan
would change building height limits, as shown in Table 1) have been determined based
on the level of information known about potential developments. The approach has
been divided into three groups:
Group A: Projects identified for upzoning and seeking individual project-level
environmental clearance through the Hub EIR (two sites):
1. 30 Van Ness Avenue2. 98 Franklin Street
For the two individual projects seeking project-level environmental clearance through
the Hub EIR, the buildings have been modeled based on the current plans on file for
those projects.
3 In consultation with San Francisco Planning, use observation reporting for some parks and open spaces from prior shadow studies performed by PreVision Design has been re-used in cases where the nature of use has been substantially unchanged since the time when the use observation visits were performed.
4 Recent buildings (built after 2010) and buildings currently under construction have been modeled and add-ed by PreVision Design, based on design drawings of the projects and/or 3D models provided by their project sponsors.
PREVISION DESIGN | THE HUB PLAN EIR CEQA SHADOW AN ALYSIS | FIN AL | FEBRUARY 11, 2019 PAGE 13
Group B: Projects that have their own completed or currently in-process environmental
review but would not maximize the upzoned height allotment proposed under the Hub
Plan (four sites):
1. 1500-1540 Market Street (One Oak) – environmental review complete2. 42 Otis Street – environmental review complete3. 10 South Van Ness Avenue – environmental review in process4. 30 Otis Street – environmental review complete
The Hub Plan proposes upzoning for the two projects for which environmental review
has been completed but construction has not yet begun, and upzoning for the two
projects for which environmental review independent of the Hub EIR is underway.
Completion of environmental review indicates that the project is reasonably foreseeable
but not guaranteed. As the two projects for which environmental review is complete
are not yet under construction, there is the possibility that the developers may allow
entitlements to expire and look to developing a project that uses the upzoned height
evaluated in the Hub Plan EIR. To capture the possibility of future height increases, the
analysis massing for the Hub Plan Scenario is based on the proposed project designs
but with the maximum height extended to the full Hub Plan height plus a 20-foot-tall
mechanical parapet allowance. The exception to this approach is the project proposal
for 10 South Van Ness Avenue, where the project sponsor has already submitted a
590-foot-tall design variant that reflects increased heights allowed under the Hub Plan.
For this Hub Plan project, the analysis uses the design variant rather than altering the
400-foot-tall double-tower design proposal.
Group C: Projects identified for upzoning that have not filed a development application
(11 sites):
1. 1 South Van Ness Avenue2. 50 Otis Street3. 99 South Van Ness Avenue4. 110 12th Street5. 180 12th Street6. 194 12th Street7. 154 South Van Ness Avenue8. 160 South Van Ness Avenue9. 170 South Van Ness Avenue10. 1695 Mission Street11. 33 Gough Street12. 170 Otis Street
For all sites listed under Group C above except 1 South Van Ness Avenue, the analysis
uses the full site boundary extended to the maximum proposed height plus a 20-foot-
tall mechanical parapet allowance. For 1 South Van Ness Avenue, considering adjacent
approximately 415- and 260-foot developments and San Francisco Planning code
PREVISION DESIGN | THE HUB PLAN EIR CEQA SHADOW AN ALYSIS | FIN AL | FEBRUARY 11, 2019 PAGE 14
requirements for tower separation; it would be unreasonable to assume that a project
with a maximum bulk will be constructed to a full height of 650 feet. Therefore, the
planning department has provided massing design for use in this analysis to reflect
a more likely massing of a future project at 1 South Van Ness Avenue, assuming the
maximum height of 650 feet allowed by the proposed Hub Plan but with massing and
tower articulation (setbacks at certain heights) to be more consistent with San Francisco
planning code.
Cumulative Conditions Scenarios: Both cumulative scenarios assume that all Hub
Plan sites reflect the maximum proposed heights under the Hub Plan plus a 20-foot-
tall mechanical parapet allowance. For 10 South Van Ness Avenue; for that project
the 590-foot-tall project variant is analyzed under a Cumulative Scenario 1 and the
400-foot-tall double-tower project is analyzed under Cumulative Scenario 2.
In addition to the Hub Plan sites, other reasonably foreseeable projects that would cast
shadow on publicly accessible open spaces affected by the Hub Plan have been included
to analyze the total cumulative net new shadow, as shown in Table 4 below.
CUMULATIVE PROJECT ADDRESS PROJECT HEIGHT DATE OF DESIGN DATA
455 Fell Street Approx 50’ 12/16/2015350 Octavia Street (Parcel N) Approx 55’ 12/9/2015300 Octavia Street (Parcel M) Approx 55’ 12/9/2015188 Octavia Street (Parcel T) Approx 55’ 1/16/20171740 Market Street Approx 85’ 1/7/20151700 Market Street Approx 85’ 6/2/20151870 Market Street Approx 85’ 3/23/2017198 Valencia Street Approx 55’ 2/7/20171601 Mission Street Approx 120’ 3/2016200-214 Van Ness Avenue Approx 135’ 9/26/2016600 Van Ness Avenue Approx 135’ 5/31/2017555 Golden Gate Avenue Approx 112’ 7/14/20171270 Mission Street Approx 200’ 5/12/20171025 Howard Street Approx 90’ 5/31/20161052 Folsom Street Approx 65’ 4/19/20171075 Folsom Street Approx 65’ 3/15/2017980 Folsom Street Approx 100’ 4/15/2017999 Folsom Street Approx 85’ 4/15/2017345 6th Street Approx 80’ 4/15/2017363 6th Street Approx 85’ 4/15/2017950 Gough Street Approx 80’ 8/7/2015807 Franklin Street Approx 80’ 8/16/2017
Table 5 (next page) lays out which models/assumptions are used for each of the analysis
scenarios reviewed in this report.
TABLE 4: Cumulative projects
PREVISION DESIGN | THE HUB PLAN EIR CEQA SHADOW AN ALYSIS | FIN AL | FEBRUARY 11, 2019 PAGE 15
TABLE 5: Modelling assumption / Scenario Matrix
ANALYSIS SCENARIOSEXISTING
CONDITIONS MODEL
THE HUB PLAN MODELSCUMULATIVE
PROJECT MODELS
GROUP A: INDIVDUAL PROJECTS
GROUP B: PROJECTS
UNDER REVIEW
GROUP C: FULL SITE MASSING
Existing Scenario X
The Hub Plan EIR X X X X
30 Van Ness Project X Xa
98 Franklin Project X Xb
Cumulative Scenario 1 X X X X Xc
Cumulative Scenario 2 X X X X Xd
a Only the 30 Van Ness Avenue Project would be included.b Only the 98 Franklin Street Project would be included.c Includes the 590-foot-tall project variant for 10 South Van Ness Avenue.d Includes the two 400-foot-tall towers proposed project for 10 South Van Ness Avenue. In all other respects identical to Cumulative Scenario 1.
PREVISION DESIGN | THE HUB PLAN EIR CEQA SHADOW AN ALYSIS | FIN AL | FEBRUARY 11, 2019 PAGE 47
% Timing % Timing % Timing % Timing % Timing
1 Jefferson Square Park RPD 1.34% 0.0002% Winter AM 0.0002% Winter AM 0.64% Year-Round AM
2 Margaret Hayward Playground RPD 14.65% 0.09% Winter AM 0.06% Winter AM 0.09% Winter AM
3 Buchanan Street Mall RPD 26.13% 0.01% Fall/Winter AM 0.01% Fall/Winter AM
4 Ella Hill Hutch Community Center SFRED Not Calculated N/A Fall/Winter AM N/A Fall/Winter AM
5 Hayes Valley Playground RPD 33.29% 0.07% Fall/Spring AM 0.01% Fall/Spring AM 0.07% Fall/Spring AM
6 Koshland Park RPD 15.45% 0.32% Spring/Summer AM 0.02% Spring/Summer AM 0.32% Spring/Summer AM
7 John Muir Elementary School SFUSD Not Calculated N/A Spring/Summer AM N/A Spring/Summer AM
8 Page & Laguna Mini Park RPD 50.80% 0.29% Spr/Sum/Fall AM 0.03% Summer AM 0.29% Spr/Sum/Fall AM 0.31% Spr/Sum/Fall AM
9 Patricia’s Green RPD 18.06% 1.53% Fall/Win/Spr AM 0.36% Fall/Spring AM 0.39% Fall/Spring AM 1.99% F/W/SP AM & PM 2.03% F/W/SP AM & PM
10 McCoppin Hub PW Not Calculated N/A Spring/Summer AM N/A SP/SU/F AM & PM
11 SOMA West Skate and Dog Park PW Not Calculated N/A Summer AM N/A
12 Brady Park (Proposed) POPOS Not Calculated N/A Year-Round AM &PM N/A SP/SU/F AM & PM
13 Civic Center Plaza RPD 10.20% 0.06% Winter Midday 0.06% Winter Midday 0.09% Fall/Winter AM/MD/PM
14 11th/Natoma Park (Proposed) RPD 22.09% 6.77% Year-Round PM 0.15% Summer PM 6.77% Year-Round PM 7.33% Year-Round PM
15 United Nations Plaza DPW Not Calculated N/A Winter PM N/A Winter PM N/A Winter PM
16 Howard & Langton Mini Park RPD 41.03% 0.03% Fall/Spring PM 0.004% Fall/Spring PM 0.05% Fall/Spring PM
17 Gene Friend Rec Center RPD 48.29% 0.0004% Fall/Winter PM 1.32% Year-Round AM & PM
18 Victoria Manalo Draves Park RPD 6.43% 0.01% Fall/Spring PM 0.51% Year-Round AM & PM
Same as C1
Same as C1
Same as C1
Same as C1
Same as C1
Cumulative Scenarios
Jurisdiction
Same as C1
Park or Open Space
Same as C1
Same as C1
Same as C1
Same as C1
Existing Shadow Load
Same as C1
Same as C1
Same as C1
Same as C1
Same as C1
The Hub Plan 30 Van Ness Avenue Project 98 Franklin Street Project
Project Scenarios
Cumulative Scenario 1 Cumulative Scenario 2
VI. ANALYSIS FINDINGS: Overview
Table 7 below shows an overview of the net new shadow that would be cast on the 18 affected public open spaces
under the Hub Plan Scenario, the 30 Van Ness Avenue Project Scenario, the 98 Franklin Street Project Scenario,
and both cumulative scenarios. For parks under the jurisdiction of RPD, quantitative shadow calculations have been
provided, while the general timing of net new shadow effects for other non-RPD parks and open spaces is listed.
The following sections (VII through XXIV) include detailed discussions of the shadow effects of the five analysis
scenarios on the affected public parks and open spaces.
TABLE 7: Shadow analysis results overview matrix
Summer AM
PREVISION DESIGN | ThE hub PlaN EIR CEQa ShaDOW aN alYSIS | FIN al | FEbRuaRY 11, 2019 PaGE 122
Affected Parks and Open Spaces1 Jefferson Square Park
2 Margaret Hayward Playground
3 Buchanan Street Mall
4 Ella Hill Hutch Community Center
5 Hayes Valley Playground
6 Koshland Park
7 John Muir Elementary School
8 Page & Laguna Mini Park
9 Patricia’s Green
q McCoppin Hub
w SOMA West Skate and Dog Park
e Brady Park (Proposed)
r Civic Center Plaza
t 11th/Natoma Park (Proposed)
y United Nations Plaza
u Howard & Langton Mini Park
i Gene Friend Rec Center
o Victoria Manalo Draves Park
Hub Plan Sites1 30 Van Ness Avenue2 1500-40 Market Street (One Oak) 3 98 Franklin Street4 1 South Van Ness Avenue 5 10 South Van Ness Avenue 6 30 Otis Street 7 42 Otis Street 8 50 Otis Street 9 99 South Van Ness Avenue 10 33 Gough Street 11 110 12th Street 12 180 12th Street 13 194 12th Street 14 154 South Van Ness Avenue 15 160 South Van Ness Avenue 16 170 South Van Ness Avenue 17 1695 Mission Street 18 170 Otis Street
Refi ned Net New Shadow FanDarker blue means more frequent new shadow
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Net new shadow fan diagram, accounting for the presence of existing shadowthe hub plan - all sitesA1
A1 - Annual net new Shadow Fan: The Hub Plan