February 25, 2017

To:

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Office of the Zoning Administrator
1650 Mission Street, Suite 400
San Francisco, CA 94103

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From: Jared Birchall, CFO
Neuralink, Inc.
318018th Street, Suite 100
San Francisco, CA 94110
RE:

Letter of Determination for the T Want Improvement Renovation of 2 Floors in the Pioneer Bldg,
318018t'' St SF ~3~73 ~~)

SUBJ:

Delineation of "Laboratory" and "Life Science" Use within the PDR-1-G Zone as defined in
Section 210.3 of the San Francisco Municipal Code

The purpose of this letter is a request to the City of San Francisco to provide a determination of
approved uses for the tenant improvement listed below.

A. Project Scope:
Tenant Improvement of two floors of the Pioneer Building, East Building. See attached Exhibit #1, Plot
Plan

B. Project Data
Tenant:

Neuralink, Inc.

Project Address

318018t'' St

Lot/Block:

3573/003

Project Location: 2"d and 3~d floors of the East Building (or 3~d and 4th floors depending on final lease
terms)
Zoning:

PDR-1-G

Construction Type:

VB

Total Square Footage: 2"d FI = 2,786 SF
3rd FI = 2,786 SF
(4"~ floor is ~F~e same square footage as Znd and 3'd Floors)

1of 2a

 C. Use Description
The tenant intends to use the 2"d floor as an interdisciplinary workroom for electrical, chemical,
mechanical &materials engineering and computer science development, with a small machine shop
attached, to modify prefabricated small bio-mechanical devices as well as perform 3D printing and CNC
(Computer Numerical Control) milling. The machine shop is an accessory use to the workroom.
The tenant intends to use the 3~d floor as a biological research laboratory for neurological interface
testing and development . Ancillary to this use, the tenant will require a clean room for microfabricated
device integration, a small operating room for in vivo testing, and a small room to house rodents. This
will follow the CNC/NIH Animal Biosafety Laboratory Level 1. The use of rodents is exempt from the
Animal Welfare Act. The clean room, operating room, and rodent housing uses are accessory to the
laboratory use.

D. Allowable Uses in the PDR-1-G Zone
According to the San Francisco Municipal Code, table 210.3 of the PDR-1-G Zoning allowable uses,
"Laboratory" uses are permitted. Neuralink's occupation of 318018th Street is anon-retail and nonservice research group intent on the integration of engineering and biology for the advancement of
medical understanding, specifically in the field of neurology. As stated in the definition of "Laboratory",
we are a specialized engineering and biological research facility that does not perform any form
manu€acturrng at thrs location.
In addition, Table 210.3 does not allow "Life Sciences" uses. Neuralink's functions do not fall within this
Use Category for the following reasons:
-

We dp not provide any products, goods or services at this location. Our work is centered
around research.
We do not perform research or use biological techniques on organisms, cells, or parts
thereof for goods and services manufactured at this location.
We do perform biochemical or reagent analysis related to illness prevention with an end
to provide a product.
We do not provide machinery, instruments, or software for research or production; we
actually do the research.

E. Neighborhood Impact
According to section 210.3, the definition of the PDR-1-G District limits office, retail, residential and
institutional uses. It also limits the production of biological and engineering goods and services as
defined within the Life Science use. As mentioned, Neuralink's intent is to further the understanding of
neurology through an interdisciplinary approach. We believe this use fits within the established uses of
the neighborhood as well as enhances the intent of the PDR-1-G use zone, allowing laboratory research.

2of ?~

 3/1/17
Jare Date

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WEST BUILDING

PIOl`~TEER TRUNK FACTORY
3180 18th STREEr~'
SAN FRANCISCO,CA
SEC(aND FLOOR

16'

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'IRTH STREET

8'

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16'