HomeMy WebLinkAboutRESO 9395Resolution No. 9395
Resolution of the Council of the City of Palo Alto Certifying the Adequacy of the
Final Environmental Impact Report for the Palo Alto Municipal Golf Course
Reconfiguration and Baylands Athletic Center Expansion Project Pursuant to the
California Environmental Quality Act and Adopting the Mitigation Monitoring
and Reporting Program and the Statement of Overriding Considerations
The Council ofthe City of Palo Alto RESOLVES as follows:
SECTION 1. Introduction and Certification.
(a) The City Council (the "Council") of the City of Palo Alto (the "City"), in
the exercise of its independent judgment, makes and adopts the following findings to comply
with the requirements of the California Environmental Quality Act ("CEQA"), commencing with
California Public Resources Code ("PRC") §§ 21000 et seq., and the CEQA Guidelines (the
"Guidelines"), commencing with the California Code of Regulations title 14, § 15000 et seq., in
particular, §§ 15091, 15092 and 15093. All statements, including those set forth in this Section
l(a), set forth in this Resolution, constitute formal findings of the Council. These findings are
made relative to the conclusions of the City's Palo Alto Municipal Golf Course Reconfiguration
and Baylands Athletic Center Expansion Project Final Environmental Impact Report (State
Clearinghouse No. 2013012053) (the "Final EIR"), which includes the Draft Environmental
Impact Report, the public comments, and the responses to comments (the "Comments and
Responses") that are included in the Draft Environmental Impact Report and the Final EIR; both
"EIRs are incorporated herein by reference. The Final EIR addresses the environmental impacts
of the implementation of the Palo Alto Municipal Golf Course Reconfiguration and Baylands
. Athletic Center Expansion Project (the "Project"), described in Section 2(b), which is
incorporated herein by reference. These findings are based upon the entire record of
proceedings for the Project.
(b) Mitigation Measures, as defined, associated with the potentially significant
impacts ofthe Project will be implemented in accordance with the Mitigation Monitoring and
Reporting Program (the "Program"), described in Section 4.
(c) Under PRC § 21067, the City is the Lead Agency, as defined, as it has the principal
responsibility to approve and regulate the Project, and the Project applicant.
(d) The City exercised its independent judgment in accordance with the
requirements of PRC § 20182.1(c), in retaining the independent consulting firm, ICF
International ("ICF"), to prepare the Final EIR. ICF prepared the Final EIR under the supervision
and at the direction of the City's Director of Planning and Community Environment (the
"Planning Director").
(e) The City, acting by and through ICF, initially prepared and circulated the Draft EIR
for review by responsible and trustee agencies and the public and also submitted it to the State
Clearinghouse for review and comment by state agencies, during a comment period,
commencing on June 3, 2013 and ending on August 1, 2013 (the "Comment Period").
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Comments and Responses that were received during the Comment Period are included in the
Final EIR.
(f) The City's Planning and Transportation Commission (the "Commission") has
reviewed the Final EIR and a draft of these findings, and has provided its recommendations to
the Council regarding the certification of the Final EIR. The Council has independently reviewed
the Final EIR and has considered the Commission's recommendations in making these findings.
(g) Based upon its review and consideration of the information in the Final EIR, the
Council hereby certifies the Final EIR was completed in compliance with CEQA; this certification
reflects the City's independent judgment and analysis. The Council has considered all of the
evidence and arguments presented during consideration of the Project and the Final EIR. In
determining whether the Project may have a significant impact on the environment and in
adopting the findings set forth below, the Council certifies that it has complied with the
requirements of PRC §§ 21081, 21081.5, and 21082.2.
(h) The Final EIR contains all of the revisions that the Final EIR made to the Draft EIR,
which revisions include all public comments made and the City's responses thereto. The
comments and responses are included in the Final EIR. All references to the Draft EIR in these
findings include references to all of the revisions to the Draft EIR, including the Comments and
Response. In reviewing this Section 1 and the Final EIR, the Council hereby finds, determines,
and declares that no significant new information has been added to the Final EIR that would
require the recirculation of all or a portion ofthe Draft EIR. Likewise, the Council has considered
all public comments and other information-submitted into the record since the publication of
the Final EIR, and the Council further finds that none of comments or additional information
constitutes significant new information that would require the recirculation of the Final EIR.
SECTION 2. Project Information.
The Project information provides the context for the discussion and findings that follow,
but is intended as a summary and not a replacement for the information contained in the Draft
EIR, Final EIR, or the Project's approvals.
(a) Project Objectives
The Project Objectives of the Project applicant are set forth in Section 2.2 of the Draft
EIR.
(b) Project Description
The Project would reconfigure all eighteen (18) holes of the Palo Alto Municipal Golf
Course (the "Golf Course"), a portion of the driving range and practice facility, and replace a
restroom facility, as it retains a regulation golf course with a par of 71. In addition to the
reconfiguration of the Golf Course, the City has proposed incorporation of 10.5 acres of the Golf
Course in the Baylands Athletic Center (the "Athletic Center"). The design and scale ofthe
Athletic Center expansion are not yet finalized. For the purposes of the Final EIR, it is assumed
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that the Athletic Center expansion would include a maximum of five (5) full-size athletic fields
and additional parking and lighting. The baseball field and softball field at the Athletic Center
would not change.
A complete description of the Project, proposed by the City as the Project applicant, is
set forth in Chapter 2 ofthe Draft EIR, as modified and set forth in the Final EIR.
(c) Required Approvals
The approvals required by the City, as the Lead Agency for implementation of the
Project, include:
Agency Permit/Review Required
City of Palo Alto Grading Permit
Building Permit -'
Site and Design review and approval (Planning
& Transportation Commission,
Architectural Review Board, City
Council)
Parks and Recreation Commission
Golf Advisory Committee
Park improvement Ordinance
San Francisco Bay Regional Water Quality 401 Certification
Control Board Construction General Stormwater Permit
Army Corps of Engineering Section 404 Permit
U.S. Fish and Wildlife Service Biological Assessment
Federal Aviation Administration FAA Form 7460-1, Notice of Proposed
Construction or Alteration
SECTION 3. Record of Proceedings.
(a) For purposes of CEQA, the Guidelines § 15091(e), and these findings, the Record
of Proceedings for the Project include, but are not limited to, the following documents:
(1)
(2)
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The Final EIR, which consists of the Palo Alto Municipal Golf Course
Reconfiguration and Baylands Athletic Center Expansion Project Draft
Environmental Impact Report (the "Draft EIR"), published and circulated
for public review and comment by the City, during the Comment Period,
and the Palo Alto Municipal Golf Course Reconfiguration and Baylands
Athletic Center Expansion Project Final EIR, published and made available
on January 22, 2014, and all appendices, reports, documents, studies,
memoranda, maps, testimony, and other materials related thereto;
All public notices issued by the City in connection with the Project and
the preparation of the Draft EIR and the Final EIR, including, but not
limited to, public notices for all public workshops held to seek public
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Guidelines § 15384, to support each of the findings contained herein.
SECTION 4. Mitigation Monitoring and Reporting Program.
(a) Under CEQA, the Lead Agency, in approving a Project, is required to adopt a
Mitigation Monitoring and Reporting Program for the changes made to that Project it has
adopted in order to mitigate or avoid significant effects on the environment. The Program has
been prepared and is recommended for adoption by the Council concurrently with the
adoption of these findings to ensure compliance with mitigation measures during the Project's
implementation. As required by PRC § 21081.6, the Program designates the responsibility and
delineates the anticipated timing for the implementation of the mitigation measures
recommended in the Final EIR. The Program will remain available for public review during the
compliance period.
(b) The Council hereby adopts the Program for the Project, attached and
incorporated by reference 'as Exhibit A, and finds, determines, and declares that the adoption of
the Program will ensure enforcement and continued imposition ofthe mitigation measures
recommended in the Final EIR in order to mitigate or avoid Significant impacts on the
environment.
SECTION 5. Potentially Significant Impacts to be Mitigated.
The Draft EIR and the Final EIR conclude that the Project would result in potentially significant
environmental impacts in the areas listed below. Through the imposition of the identified
Mitigation Measures, these identified potentially significant environmental impacts will be
reduced to less-than-significant impacts.
Impact BIO-l: Disturbance of Special-Status Plant Populations. Because special-status
plants may be present on the Project site, construction operations of the Project could have a
potentially significant impact pertaining to special-status plant populations.
a) Potential Impact. The impact identified above is described and discussed in
Section 3.3 of the Final EIR.
b) Mitigation Measures. Mitigation Measures B10-1, B10-2a, B10-2b, B10-2c, BIO-
2d, and B10-2e will be adopted and will be implemented as provided in the Program.
c) Findings. The above-noted Mitigation Measures will reduce impacts to a less-
than-significant level as follows:
1) Mitigation Measure B10-1 will reduce the Significant impacts to a less-than-
significant level, because it requires worker awareness training regarding sensitive plant
species that provides workers with information on what look for and what steps to take
to avoid the disturbance of sensitive plant species.
2) Mitigation Measure B10-2a will reduce the significant impacts to a less-than-
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significant level, because it requires the City to retain a qualified botanist to conduct a
pre-construction survey to check for the presence of special-status plant species.
3) Mitigation Measure B10-2b will reduce the significant impacts to a less-than-
significant level, because it requires the protection of existing special-status plant
species through the establishment of buffer zones around any identified locations
where special-status plant species are identified on the Project site.
4) Mitigation Measure B10-2c will reduce the significant impacts to a less-than-
significant level, because, in the event that on-site special-status plants cannot be
protected during the Project, it requires the City to develop and implement a
compensation plan that will ensure that there will not be a net loss of special-status
plants as aresult ofthe Project.
5) Mitigation Measure B10-2d will reduce the significant impacts to a less-than-
significant level, because, in the event that on-site special-status plants cannot be
protected during the Project, it requires the City to develop and implement a 5-year
monitoring program overseen by a qualified botanist that will ensure that there will not
be a net loss of special-status plants as a result ofthe Project.
6) Mitigation Measure B10-2e will reduce the significant impacts to a less-than-
significant level, because, if special-status plants are identified during the pre-
construction survey, it requires the City to develop and implement a training program
for Golf Course employees that provides workers with information on what look for and
what steps to take to avoid disturbance of an special-status plants during landscape
maintenance activities, including deposition of landscape waste.
Impact BI0-3: Disturbance of Nesting Migratory Birds and Raptors. Because nesting
migratory birds and raptors may be present at the Project site, construction operations of the
Project could have a potentially significant impact pertaining to nesting migratory birds and
raptors.
a) Polentiallmpact. The impact identified above is described and discussed in
Section 3.3 ofthe Final EIR.
b) Mitigation Measures. Mitigation Measure B10-3 will be adopted and will be
implemented as provided in the Program.
c) Findings. Mitigation Measure B10-3 will reduce the significant impacts to a less-
than-significant level, because it requires a pre-construction survey for nesting birds and
raptors and establishes buffer zones around any identified nesting sites.
Impact BI0-4: Disturbance of Western Burrowing Owls and Habitat. Because the
Western Burrowing Owl may be present on the Project site, construction operations of the
Project could have a potentially significant impact pertaining to the Western Burrowing Owl.
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2) Mitigation Measure B10-6 will reduce the significant impacts to a less-than-
significant level, because it requires a pre-construction survey for the Salt Marsh Harvest
Mouse and the Salt Marsh Wandering Shrew habitat and establishes buffer zones
around any identified locations where the Salt Marsh Harvest Mouse and the Salt Marsh
Wandering Shrew habitat are identified at the Project site.
Impact BI0-8: Disturbance or Loss of State or Federally Protected Wetlands. Because
protected wetland areas atthe Project site will be temporarily impacted by the reconfiguration
of the Golf Course, the Project would have a potentially significant impact pertaining to
wetlands.
a) Potential Impact. The impact identified above is described and discussed in
Section 3.3 ofthe Final EIR.
b) Mitigation Measures. Mitigation Measures B10-1, B10-7, and B10-8 will be
adopted and will be implemented as provided in the Program.
c) Findings. The above-noted Mitigation Measures will reduce impacts to a less-
than-significant level, as follows:
1) Mitigation Measure B10-1 will reduce the significant impacts to a less-than-
significant level,because it requires worker awareness training regarding wetlands that
provides workers with information on what look for and what steps to take to avoid the
disturbance of wetland areas.
2) Mitigation Measure B10-7 will reduce the significant impacts to a less-than-
significant level, because it requires a pre-construction survey to identify and protect
jurisdictional wetlands with exclusionary fencing.
3) Mitigation Measure B10-8 will reduce the Significant impacts to a less-than-
significant level, because it requires the protection of existing and creation of new
wetlands areas on the Golf Course that will ensure that there will not be a net loss of
wetlands as a result of the Project. The measure also requires the development of a
wetlands Mitigation Monitoring Plan (the "MMplI
) that will protect the long-term
preservation of the wetlands.
Impact BI0-9: Loss of or Damage to Regulated Trees. Because a large number of
existing trees will be removed as a result of the reconfiguration of the Golf Course, the Project
would have a potentially significant impact pertaining to regulated trees.
a) Potential Impact. The impact identified above is described and discussed in
Section 3.3 of the Final EIR.
b) Mitigation Measures. Mitigation Measures B10-1, B10-9, and BIO-lO will be
adopted and will be implemented as provided in the Program.
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construction operations of the Project could have a potentially significant impact pertaining to
paleontological resources.
a) Potential Impact. The impact identified above is described and discussed in
Section 3.4 of the Final EIR.
b) Mitigation Measures. Mitigation Measures CUL-3, CUL-4, and CUL-5 will be
adopted and will be implemented as provided in the Program.
c) Findings. The above-noted Mitigation Measures will reduce impacts to a less-
than-significant level, as follows:
1) Mitigation Measure CUL-3 will reduce the significant impacts to a less-than-
significant level, because it requires a pre-construction paleontological resources survey
and evaluation prior to the start of construction activity on the site.
2) Mitigation Measure CUL-4 will reduce the significant impacts to a less-than-
significant level, because it requires work~r awareness training regarding
paleontological resources that provides workers with information on what look for and
what steps to take to avoid the disturbance of paleontological resources.
3) Mitigation Measure CUL-5 will reduce the significant impacts to a less-than-
significant level, because it requires the City to include a provision in the Project's
construction specifications that requires the stoppage of work upon the discovery of any
paleontological resources on the site.
Impact GEO-7: loss of Topsoil. Because existing site topsoil will be disturbed as a result
of the reconfiguration of the Golf Course, the Project would have a potentially significant
impact pertaining to loss oftopsoil.
a) Potential Impact. The impact identified above is described and discussed in
Section 3.5 ofthe Final EIR.
b) Mitigation Measures. Mitigation Measure GEO-1 will be adopted and will be
implemented as provided in the Program.
c) Findings. Mitigation Measure GEO-1 will reduce the significant impacts to a less-
than-significant level, because it requires the City to include a provision in the Project's
construction specifications that requires the stockpiling and reuse oftopsoil on the site.
Impact GHG-l: Generate Greenhouse Gas Emissions, Either Directly or Indirectly, That
May Have a Significant Impact on the Environment. Because the Project will generate a large
number of vehicle trips for delivery of supplies and materials during construction of the Project,
the Project would have a potentially significant impact as it pertains to greenhouse gas ("GHG")
emissions.
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a) Potential Impact. The impact identified above is described and discussed in
Section 3.6 ofthe Final EIR.
b) Mitigation Measures. Mitigation Measure GHG-1 will be adopted and will be
implemented as provided in the Program.
c) Findings. Mitigation Measure GHG-3 will reduce the significant impacts to a less-
than-significant level, because it requires the use of local materials and recycling/reuse of
construction waste in order to minimize GHG generation from vehicle miles traveled and
manufacturing of new products.
Impact HAZ-l: Creation of Hazard through Transport, Use, or Disposal of Hazardous
Materials. Because hazardous materials, including fuels,lubricants, and solvents, will be
utilized during construction of the Project, the Project would have a potentially significant
impact as it pertains to hazardous materials.
a) Potential Impact. The impact identified above is described and discussed in
Section 3.7 ofthe Final EIR.
b) Mitigation Measures. Mitigation Measures HAZ-1 and HAZ-2 will be adopted
and will be implemented as provided in the Program.
c) Findings. The above-noted Mitigation Measures will reduce impacts to a less-
than-significant level as follows:
1) Mitigation Measure HAZ-1 will reduce the significant impacts to a less-than-
significant level, because it requires the City to include a provision in the Project's
construction specifications that requires the contractor to develop and implement a spill
prevention and response plan.
2) Mitigation Measure HAZ-2 will reduce the significant impacts to aless-than-
significant level, because it requires the City to include a provision in the Project's
construction specifications that requires the contractor to develop and implement a
hazardous materials storage plan. I
Impact HAZ-2: Exposure of Workers or the Public to Existing Hazardous Materials
Contamination. Because there are existing areas of potentially contaminated soil in the Project
vicinity, the Project could have a potentially significant impact pertaining to worker exposure to
hazardous materials.
a) Potential Impact. The impact identified above is described and discussed in
Section 3.7 ofthe Final EIR.
b) Mitigation Measures. Mitigation Measures HAZ-1, HAZ-2, HAZ-3, and HAZ-4 will
be adopted and will be implemented as provided in the Program.
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c) Findings. The above-noted Mitigation Measures will reduce impacts to a less-
than-significant level, as follows:
1) Mitigation Measure HAZ-l will reduce the significant impacts to a less-than-
significant level, because it requires the City to include a provision in the Project's
construction specifications that requires the contractor to develop and implement a spill
prevention and response plan.
2) Mitigation Measure HAZ-2 will reduce the significant impacts to a less-than-
significant level, because it requires the City to include a provision in the Project's
construction specifications that requires the contractor to develop and implement a
hazardous materials storage plan.
3) Mitigation Measure HAZ-3 will reduce the significant impacts to a less-than-
significant level, because it requires the City to include a provision in the Project's
construction specifications that requires the contractor to stop work if hazardous
materials are encountered during the work.
4) Mitigation Measure HAZ-4 will reduce the significant impacts to a less-than-
significant level, because it requires the City to include a provision in the Project's
construction specifications that requires the contractor to employ engineering controls
and best management practices to minimize human exposure to potential
contaminants.
Impact HAZ-3: Generation of Hazardous Emissions/Use of Hazardous Materials within
0.25 Mile of Schools. Because hazardous materials, including fuels, lubricants, and solvents
will be utilized during construction of the Project, and the Athletic Center is located within 0.25
mile of the International School (151 Laura Lane), the Project could have a potentially
significant impact pertaining to hazardous materials exposure near schools.
a) Potential Impact. The impact identified above is described and discussed in
Section 3.7 of the Final EIR.
b) Mitigation Measures. Mitigation Measure HAZ-l will be adopted and will be
implemented as provided in the Program.
c) Findings. Mitigation Measure HAZ-l will reduce the significant impacts to a less-
than-significant level, because it requires the City to include a provision in the Project's
construction specifications that requires the contractor to develop and implement a spill
prevention and response plan.
Impact HAZ-6: Interference with Emergency Response or Evacuation Plan. Because
the construction activity associated with the Project could potentially interfere with evacuation
of the Golf Course and/or Athletic Center, the Project could have a potentially significant
impact pertaining to emergency evacuation.
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a) Potential Impact. The impact identified above is described and discussed in
Section 3.7 of the Final EIR.
b) Mitigation Measures. Mitigation Measure TRA-l will be adopted and will be
implemented as provided in the Program.
c) Findings. Mitigation Measure TRA-l will reduce the significant impacts to a less-
than-significant level, because it requires the City to include a provision in the Project's
construction specifications that requires the contractor to develop and implement a traffic
control plan, including a requirement to maintain emergency access to the site.
Impact HAZ-8: Breeding or Harborage of Disease Vector Organisms. Because the land
disturbance associated with the Project could potentially contribute to increased mosquito
breeding, the Project could have a potentially significant impact pertaining to vector organisms.
a) Potential Impact. The impact identified above is described and discussed in
Section 3.7 ofthe Final EIR.
b) Mitigation Measures. Mitigation Measure HAZ-5 will be adopted and will be
implemented as provided in the Program.
c) Findings. Mitigation Measure HAZ-5 will reduce the significant impacts to a less-
than-significant level, because it requires the City to include a provision in the Project's
construction specifications that requires the contractor to implement best management
practices that will prevent the accumulation of standing water that increases mosquito
breeding.
Impact HYD-2: Depletion of Groundwater Supplies or Interference with Groundwater
Recharge. Because the Project could utilize artificial turf that could hinder groundwater
recharge, the Project could have a potentially significant impact pertaining to groundwater
recharge.
a) Potential Impact. The impact identified above is described and discussed in
Section 3.8 of the Final EIR.
b) Mitigation Measures. Mitigation Measure HYD-l will be adopted and will be
implemented as provided in the Program.
c) Findings. Mitigation Measure HYD-l will reduce the significant impacts to a less-
than-significant level, because it requires the City to consider artificial turf products and base
course material that allow for water infiltration and groundwater recharge.
Impact HYD-4: Alteration of Stormwater Drainage Patterns to Cause Flooding On-or
Off-Site. Because the Project would increase the imperviousness of the site and would
consequently increase storm water runoff generated by the site, the Project would have a
potentially significant impact pertaining to flooding.
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a) Potential Impact. The impact identified above is described and discussed in
Section 3.8 ofthe Final EIR.
b) Mitigation Measures. Mitigation Measure HYD-2 will be adopted and will be
implemented as provided in the Program.
c) Findings. Mitigation Measure HYD-2 will reduce the significant impacts to a less-
than-significant level, because it requires the City to implement Low Impact Development
("LID") measures to improve drainage through detention or infiltration of storm water.
Impact HYD-S: Create or Contribute Additional Runoff to Exceed Stormwater Drainage
Capacities or Cause Additional Sources of Polluted Runoff. Because the Project would increase
the imperviousness ofthe site and would consequently increase storm water runoff generated
by the site, the Project would have a potentially significant impact pertaining to creation of
additional storm water runoff.
a) Potential Impact. The impact identified above is described and discussed in
Section 3.8 of the Final EIR.
b) Mitigation Measures. Mitigation Measure HYD-2 will be adopted and will be
implemented as provided in the Program.
c) Findings. Mitigation Measure HYD-2 will reduce the significant impacts to a less-
than-significant level, because it requires the City to implement LID measures to improve
drainage through detention or infiltration of storm water.
Impact HVD-6: Otherwise Substantially Degrade Water Quality. Because the Project
could result in the discharge of fill material into waters of the United States, the Project could
have a potentially significant impact pertaining to degradation of water quality in protected
wetland areas.
a) Potential Impact. The impact identified above is described and discussed in
Section 3.8 of the Final EIR.
b) Mitigation Measures. Mitigation Measures BIO-l, BIO-7, and BIO-8 will be
adopted and will be implemented as provided in the Program.
c) Findings. The above-noted Mitigation Measures will reduce impacts to a less-
than-significant level, as follows:
1) Mitigation Measure BlO-l will reduce the significant impacts to a less-than-
significant level, because it requires worker awareness training regarding wetlands that
provides workers with information on what look for and what steps to take to avoid the
disturbance of wetland areas.
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2) Mitigation Measure BIO-7 will reduce the significant impacts to a less-than-
significant level, because it requires a pre-construction survey to identify and protect
jurisdictional wetlands with exclusionary fencing.
3) Mitigation Measure BIO-8 will reduce the significant impacts to a less-than-
significant level, because it requires the protection of existing and creation of new
wetlands areas on the Golf Course that will ensure that there will not be a net loss of
wetlands as a result of the Project. The measure also requires the development of a
wetlands MMP that will protect the long-term preservation ofthe wetlands.
Impact LU-2: Conflict with Applicable Plan, Policy, or Regulation. Because the Project
would include nighttime lighting, the Project could have a potentially significant impact
pertaining to operations at the adjacent Palo Alto Airport.
a) Potential Impact. The impact identified above is described and discussed in
Section 3.9 of the Final EIR.
b) Mitigation Measures. Mitigation Measure LU-1 will be adopted and will be
implemented as provided in the Program.
c) Findings. Mitigation Measure LU-1 will reduce the significant impacts to a less-
than-significant level, because it requires voluntary coordination with the Airport Land Use
Commission (the "ALUC") regarding the design of new lighting for the proposed athletic playing
fields to ensure that it does not interfere with pilot visibility and/or other airport operations.
Impact PS-l: Adversely Affect Fire Protection Services or Require the Provision of New
or Physically Altered Fire Protection Facilities. Because the Project will generate a large
number of vehicle trips for delivery of supplies and materials during construction of the Project,
the Project would have a potentially significant impact pertaining to fire equipment emergency
access in the vicinity of the Project.
a) Potential Impact. The impact identified above is described and discussed in
Section 3.12 ofthe Final EIR.
b) Mitigation Measures. Mitigation Measure TRA-1 will be adopted and will be
implemented as provided in the Program.
c) Findings. Mitigation Measure TRA-1 will reduce the significant impacts to a less-
than-significant level, because it requires the City to include a provision in the Project's
construction specifications that requires the contractor to develop and implement a traffic
control plan, including a requirement to maintain emergency access to the site.
Impact PS-2: Adversely Affect Police Protection Services or Require the Provision of
New or Physically Altered Police Protection Facilities. Because the Project will generate a
large number of vehicle trips for delivery of supplies and materials during construction of the
Project, the Project would have a potentially significant impact pertaining to police emergency
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c) Findings. Mitigation Measure TRA-1 will reduce the significant impacts to a less-
than-significant level, because it requires the City to include a provision in the Project's
construction specifications that requires the contractor to develop and implement a traffic
control plan, including a requirement to limit truck access to the Project during peak traffic
hours and to stage equipment and materials on-site in a manner that minimizes disruption of
site operations during construction of the Project.
Impact TRA-S: Impacts to Transit and Bicycle/Pedestrian Circulation. Because the
Project will generate a large number of vehicle trips for delivery of supplies and materials
during construction of the Project, the Project would have a potentially significant impact
pertaining to transit, bicycle, and pedestrian circulation on roadways in the vicinity of the
Project during construction.
a) Potential Impact. The impact identified above is described and discussed in
Section 3.14 of the Final EIR.
b) Mitigation Measures. Mitigation Measure TRA-1 will be adopted and will be
implemented as provided in the Program.
c) Findings. Mitigation Measure TRA-1 will reduce the significant impacts to a less-
than-significant level, because it requires the City to include a provision in the Project's
construction specifications that requires the contractor to develop and implement a traffic
control plan, including a requirement to limit truck access to the Project during peak traffic
hours and to employ standard traffic control safety practices, including measures to protect
transit, bicycle, and pedestrian circulation, during construction of the Project.
SECTION 6. Significant and Unavoidable Impacts.
As noted in the Draft EIR and the Final EIR, the Project would result in significant and
unavoidable impacts, which cannot be adequately mitigated through the adoption and
implementation of feasible mitigation measures. Those impacts, along with mitigation
measures to mitigate them to the extent feasible, are listed below as referenced in the Draft
EIR and the Final EIR.
3.1 Aesthetics
Impact AES-4: The Athletic Center would create a new source of substantial light or
glare that would adversely affect daytime or nighttime views in the area during the Project's
operation.
a) Potential Impact. The impact identified above is described and discussed at
Pages 3.1.13 through 3.1-16 ofthe Draft EIR and the Final EIR.
b) Mitigation Measures. The following mitigation measures will be adopted and
will be implemented as provided in the Program, and as further described in the remainder of
these findings:
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c) Mitigation Measure AES-l: Apply Light Pollution and Glare Reduction Measures
All artificial outdoor lighting will be limited to safety and security requirements, signage
and stadium lighting. Lighting will conform to the City's applicable zoning regulations to
minimize visual impacts (set forth in Palo Alto Municipal Code ("PAMC") § 18.23.030) and will
be subject to Site and Design review approval (PAMC chapter 18.76) to ensure appropriate light
pollution and glare reduction standards are achieved. To meet the City's requirements, lighting
will be designed, using the Illuminating Engineering Society's ("IES") design guidelines and in
compliance with International Dark-Sky Association ("IDSA")-approved fixtures. All lighting will
provide minimum impact to the surrounding environment and will use downcast, cut-off type
fixtures that are shielded and direct the light only towards objects requiring illumination.
Therefore, lights will be installed at the lowest allowable height and cast low-angle illumination
while minimizing incidental light spill onto adjacent properties, open spaces, or backscatter into
the nighttime sky. The lowest allowable wattage will be used for all lighted areas and the
amount of nighttime lights needed to light an area will be minimized to the highest degree
possible. Light fixtures will possess non-glare finishes that will not cause reflective daytime
glare. All outdoor lighting will possess individual photocells. Lighting will be designed for energy
efficiency, will use high pressure sodium vapor lights with individual photocells, and will have
daylight sensors or will be timed with an on/off program. Lights will provide good color
rendering with natural light qualities with the minimum intensity feasible for security, safety,
and personnel access. Lighting, including light color rendering and fixture types, will be
designed to be aesthetically pleasing.
Lights along pathways and safety lighting at building entrances and loading areas will
employ shielding to minimize offsite light spill and glare and will be screened and directed away
from residences and adjacent uses to the highest degree possible. The amount of nighttime
lights used along pathways will be minimized to the highest degree possible to ensure that
spaces are not unnecessarily over-lit. For example, the amount of light can be reduced by
limiting the amount of ornamental light posts to higher use areas and by using hooded wall
mounts or bollard lighting on travel way portions of pathways.
Stadium lighting will employ spill and glare control features to minimize off-site light
pollution. Luminaires will be chosen for the ability to provide horizontal and vertical beam
control for better control in directing what is illuminated. In addition, shielding, such as a visor,
will be used to further direct light and reduce light spill and ambient light glow. Luminaires will
also incorporate photometric reflector systems that are designed to reduce light pollution.
All design measures used to reduce light pollution will employ the technologies available
at the time ofthe Project's design to allow for the highest potential to reduce light pollution
and meet the City's standards. These technologies may be available through information and
products endorsed by the IES and the ISDA in addition to the actual products that lighting
manufacturers have developed to improve lighting technologies and reduce light pollution and
glare.
d) Findings. The referenced mitigation measures will reduce the severity of this
140130 dm 00710339A 19
potentially significant impact, ensuring this impact will be mitigated, as practicable, as follows:
(is) there will be shielding to help reduce the amount and direction ofthe light as much as
possible; (ii) downcast, cut-off type fixtures that are shielded and direct the light only towards
objects requiring illumination will be used; and (iii) all design measures used to reduce light
pollution will employ the technologies available at the time of the Project's design to allow for
the highest potential to reduce light pollution and meet City standards. However, these
measures would not fully mitigate this impact to a less-than-significant level.
3.2 Air Quality
Impact AQ-2: Violate Any Air Quality Standard or Contribute Substantially to an
Existing or Projected Air Quality Violation. The Project would violate an air quality standard or
contribute substantially to an existing or projected air quality violation during the golf course
Project's construction.
a) Potential Impacts. The impacts identified above are described and discussed in
Chapter 3.2, Air Quality, Impacts and Mitigation Measures, at Pages 3.2-19 through 3.2-24 of
the Draft EIR and the Final EIR.
b) Mitigation Measures. The following mitigation measures will be adopted and
implemented, as provided in the Program, and as further described in the remainder of these
findings:
Mitigation Measure AQ-l: Implement Tailpipe Emission Reduction for Project
Construction
The City will require all construction contr.actors to implement the Bay Area Air Quality
Management District's (IIBAAQMD") Basic Construction Mitigation Measures and Additional
Construction Mitigation Measures recommended by BAAQMD to control exhaust emissions.
Emission reduction measures will include at least the following measures and may include other
measures identified as appropriate by BAAQMD and/or contractor:
Idling times shall be minimized either by shutting equipment off when it is not in use or
reducing the maximum idling time to 2 minutes. Clear sign age shall be provided for
construction workers at all access points.
All construction equipment shall be maintained and properly tuned in accordance with
the manufacturer's specifications. All equipment shall be checked by a certified visible
emissions evaluator.
The simultaneous occurrence of excavation, grading, and ground-disturbing
construction activities in the same area at anyone time shall be limited. Activities shall be
phased to reduce the amount of disturbed surfaces at anyone time.
The construction contractor for the Project shall develop a plan for submittal to the City
that demonstrates that the off-road equipment (more than 50 horsepower) to be used in
construction of the Project (i.e., owned, leased, and subcontractor vehicles) will achieve a
140130 dm 00710339A 20
PrOject-wide fleet-average 20 percent nitrous oxide (IINO/,) reduction. Acceptable options for
reducing emissions include the use of late-model engines, low-emission diesel products,
alternative fuels, engine retrofit technology, after-treatment products, add-on devices such as
particulate filters, and/or other options as such become available.
All construction equipment, diesel trucks"and generators shall be required to be
equipped with Best Available Control Technology for emission reductions of NOx and particulate
matter.
All contractors shall be required to use equipment that meets California Air Resources
Board's most recent certification standard for off-road heavy-duty diesel engines.
Mitigation Measure AQ-2: Implement BAAQMD's Basic Construction Mitigation
Measures to Reduce Construction-Related Dust
BAAQMD will require all construction contractors to implement the Basic Construction
Mitigation Measures recommended by BAAQMD to reduce dust emissions. Emission reduction
measures will include at least the following measures and may include other measures
identified as appropriate by BAAQMD and/or contractor:
• All exposed surfaces (including parking areas, staging areas, soil piles, graded
areas, and unpaved access roads) shall be watered two (2) times per day.
• All haul trucks transporting soil, sand, or other loose material off-site shall be
covered.
• All visible mud or dirt track-out onto adjacent public roads shall be removed,
using wet power vacuum street sweepers at least once per day. The use of dry
power sweeping is prohibited.
• All vehicle speeds on unpaved roads shall be limited to 15 MPH.
• All roadways, driveways, and sidewalks to be paved shall be completed as soon
as possible. Building pads shall be laid as soon as possible after grading is
completed, unless seeding or soil binders are used.
• A publicly visible sign, disclosing the telephone number and name of the person
to contact at the lead agency regarding dust complaints, shall be posted. This
person shall respond and take corrective action within 48 hours. BAAQMD's
phone number shall also be visible in order to promote and ensure compliance
with applicable regulations.
c) Findings. The referenced mitigation measures will reduce the severity of this
potentially significant impact by: (i) requiring tailpipe emission reduction for the Project's
construction; and (ii) implementing all feasible dust control measures as recommended by
BAAQMD. There are no additional feasible mitigation measures beyond those set forth in
Mitigation Measure AQ-1 to reduce this to a less-than-significant level. Implementation of the
Mitigation Measure will ensure that this impact is reduced to the extent feasible. However,
even with the implementation of this mitigation measure, the NOx emissions would still exceed
BAAQMD's thresholds and therefore would not fully mitigate these Impacts to a less-than-
significant !evels.
140130 dm 00710339A 21
SECTION 7. Findings Regarding Project Alternatives.
(a) Under PRC § 21002, a public agency is prohibited from approving a project if
there are feasible alternatives or feasible mitigation measures available, which would
substantially lessen the significant environmental effects ofthe project. When a lead agency
finds, even after the adoption of all feasible mitigation measures, that a project will still cause
one or more significant environmental effects that cannot be substantially lessened or avoided,
the lead agency must, prior to approving the project, as mitigated, first determine whether
there are any project alternatives that are feasible and that would substantially lessen or avoid
the project's significant impacts. Under CEQA, IIfeasibility" includes "desirability" to the extent
that it is based on a reasonable balancing of the relevant economic, environmental, social, and
technological factors. An alternative may be deemed by the lead agency to be "infeasible", if it
fails to adequately promote the project applicant's and/or the lead agency's primary underlying
goals and objectives for the project. Thus, a lead agency may reject an alternative, even if it
would avoid or substantially lessen one or more significant environmental effects of the
project, if it finds that the alternative's failure to adequately achieve the objectives for the
project, or other specific and identifiable considerations, make the alternative infeasible.
(b) The Council certifies that the Final EIR describes a reasonable range of
alternatives to the Project, which could feasibly obtain the basic objectives of the Project, and
that the Council has evaluated the comparative merits of the alternatives. As described below,
the Council has decided to approve the Project, as proposed, and to reject the remainder of the
alternatives, as summarized below.
(c) Section 2.1 ofthe Draft EIR and the Final EIR set forth the Project applicant's
objectives for the Project. That list is incorporated herein by reference. In light of the City's (as
the Project applicant) objectives for the Project, and as the Project is expected to result in
certain significant environmental effects, even after the implementation of all feasible
mitigation measures, as identified above, the City hereby makes the following findings with
respect to whether one or more of the alternatives evaluated in the Draft EIR could feasibly
accomplish most of the goals and objectives for the Project and substantially lessen or avoid
one or more of its potentially significant effects.
No Project Alternative
The (lNo Project Alternative" is discussed at Section 5.2.6 ofthe Draft EIR and the Final
EIR. Although the No Project Alternative would be the environmentally superior alt~rnative,
, because there would be no construction-related impact, there would be greater impacts on
hydrology and water quality, as storm water and irrigation water would continue to pond on
the Golf Course and would not drain properly through the drainage system, and on recreation,
as there would be no Athletic Center expansion. Further, the No Project Alternative does not
meet the Project's objectives to provide a golf course with enhanced wildlife habitat and
improved wetland areas, to expand recreation areas at the athletic fields, and to integrate the
Golf Course and the Athletic Fields into the Baylands theme. Based on these findings, the No
Project Alternative is hereby rejected as infeasible, because it would not achieve the Project's
140130 dm 00710339A 22
makes the following Statement of Overriding Considerations regarding the remaining significant
unavoidable impacts of the Project, as discussed above, and the anticipated economic, social
and other benefits of the Project.
(b) The City finds that: (i) the majority of the significant impacts ofthe Project will be
reduced to less-than-significant and acceptable levels by the Mitigation Measures described in
the Final EIR and approved and adopted by these Findings; (ii) the City's approval of the Project
will result in certain significant adverse environmental effects that cannot be avoided even with
the incorporation of all feasible Mitigation Measures into the Project; and (iii) there are no
other feasible Mitigation Measures or feasible Project alternatives that would further mitigate
or avoid the remaining significant environmental effects. The significant effects that have not
been mitigated to a less-than-significant level and are therefore considered significant and
unavoidable are identified in Section 6 above. Despite these potentially significant impacts, it is
the City's considered judgment that the benefits offered by the Project outweigh the
potentially adverse effects of these significant impacts. The substantial evidence supporting the
following described benefits of the Project can be found in the preceding findings and in the
Record of Proceedings.
(c) The benefits of the Project, which the Council finds serve as ((overriding
considerations", justifying the Project's approval, include the following:
(1) Implementation of the Project will transform the Golf Course from a flat, park-like
. expanse of maintained turf grass into a blend of land forms, vegetation, and golf
course furnishings that are compatible with the unique Baylands setting, and will
transform 66 irrigated acres to naturalized areas of baylands vegetation and habitat.
(2) As a part ofthe Project, existing non-native plants and trees will be replaced with
native grasses, and low-lying baylands zones will be planted with indigenous plants
that will survive in saline soil. With the increased use of native plants and the
replacement of the irrigation system with one which monitors soil moisture, overall
water usage for the Golf Course's irrigation is expected to be reduced by 30 -35
percent. In addition, the use of native ground cover and vegetation will have greater
infiltration capabilities, which will improve groundwater filtration and reduce the
risk of flooding. The new vegetatio~ zones would slow water down, allowing it to
percolate into the ground, and provide increased benefits for groundwater recharge.
(3) The Project is consistent with the City's Comprehensive Plan, which designates the
site as a public park (consistent with PAMC § 22.08.240), and emphasizes the need
to preserve and improve the aesthetic qualities of Palo Alto's natural and built
environment. The Project is also consistent with the City's Baylands Master Plan,
which encourages preservation and enhancement of the Baylands' environmental
quality, guides recreation development to minimize destruction of wildlife habitat
and limit development, vehicle parking areas and aboveground utility lines. The
Project also conforms with the City'S Baylands Design Guidelines, which contains
design principles to reflect and preserve the Baylands' unique landscape character
140130 dm 00710339A 24
ICF International. 2014. Mitigation Monitoring and Reporting Program. Palo Alto Municipal Golf Course
Reconfiguration and Baylands Athletic Center Expansion Project. January. (00631.12) San Jose, CA.
Prepared for City of Palo Alto, Palo Alto, CA.
Contents
List of Tables ........................................................................................................................................... ii
Page
Mitigation Monitoring and Reporting Program ................................................................................... 1
Introduction ............................................................................................................................................ 1
Mitigation Measures .................................................................... I ••• ~ •••••••••••••••••••••••••••••••••••••••••••••••••• 9
Aesthetics ................................................................................................................................................ 9
Air Quality ............................................................................................................................................. 10
BiologicClI Resources ................. ' ............................................................................................................ 11
Cultural Resources ................................................................................................................................ 19
Geology and Soils ................................................................................................................................... 21
Greenhouse Gas Emissions and Climate Change .................................................................................. 21
Hazards and Hazardous Materials ........................................................................................................ 21
Hydrology and Water Quality ............................................................................................................... 22
Land Use and Planning .......................................................................................................................... 23
Recreation ............................................................................................................................................. 23
Transportation and Traffic .................................................................................................................... 23
Palo Alto Municipal Golf Course Reconfiguration and
Baylands Athletic Center Expansion Project MMRP
January 2014
ICF 00631.12
Mitigation Monitoring and Reporting Program
Introduction
The City of Palo Alto, as Lead Agency under the California Environmental Quality Act (CEQA) and
State CEQA Guidelines, has prepared the Final Environmental Impact Report (EIR) for the Palo Alto
Municipal Golf Course Reconfiguration and Baylands Athletic Center Project (Project) (SCH
# 2013012053). When a lead agency makes findings on significant effects identified in an EIR, it
must also adopt a program for reporting or monitoring mitigation measures that were adopted or
made conditions of project approval (Public Resources Code [PRe] Section 21081.6[a]; State CEQA
Guidelines Sections 15091[d], 15097).
This document represents the mitigation monitoring and reporting program (MMRP) prepared by
the City of Palo Alto for the Project. This MMRP includes all measures required to reduce potentially
significant environmental impacts to a less-than-significant level. It also identifies the timing of
implementation, the agency responsible for implementing the mitigation, and the agency
responsible for monitoring the mitigation. The mitigation measures, timing, and responsibility are
summarized in Tables 1 and 2, and the full text of the mitigation measures follows. Table 1 lists the
mitigation measures required for the Golf Course Reconfiguration and Table 2 lists the mitigation
measures required for the Baylands Athletic Center Expansion.
This MMRP has been prepared by the City of Palo Alto, with technical assistance from
ICF International, an environmental consulting firm. Questions should be directed to Joe Teresi at
the City of Palo Alto.
Contact Information:
City of Palo Alto
250 Hamilton Avenue, 6th Floor
Palo Alto, CA 94301
650.329.2129
Palo Alto Municipal Golf Course Reconfiguration and
Baylands Athletic Center Expansion Project MMRP 1 January 2014
ICF 00631.12
City of Palo Alto Mitigation Monitoring and Reporting Program
Table 1. Mitigation Monitoring Reporting Program -Summary of Mitigation Measures for the Golf Course Reconfiguration
Mitigation Measure
Tobt;Jmpi~mented Prio~tOCo~struction
BIO-l: Develop and Implement Worker Awareness
Training·
BIO-2a: Conduct Preconstruction Botanical Surveys
BIO-2b: Confine Construction Disturbance and Protect
Special-Status Plants during Construction
BIO-2c: Compensate for Loss of Special-Status Plants
BIO-2d: Develop and Implement Special-Status Plant
Species Monitoring Plan
BIO-3: Establish Buffer Zones for Nesting Raptors and
Migratory Birds
BIO-4: Implement Survey and Avoidance Measures for
Western Burrowing Owls Prior to Construction Activities
BIO-5: Implement Survey and Avoidance Measures for
California Clapper Rail and California Black Rail Prior to
Construction Activities
BIO-6: Implement Survey and Avoidance Measures for
Salt Marsh Harvest Mouse and Salt Marsh Wandering
Shrew Prior to Construction Activities
BIO-7: Avoid and ProtectJurisdictional Wetlands during
Construction
BIO-8: Compensate for Impacts to Jurisdictional
Wetlands and Waters of the United States prior to
Project-Related Impacts during Construction
Palo Alto Municipal Golf Course Reconfiguration and Baylands
Athletic Center Expansion Project MMRP
Implementation
Responsibility
Monitoring
. Responsibility
City of Palo Alto and a qualified City of Palo Alto
biologist
City and a qualified biologist City of Palo Alto
City and construction City, CDFW, USFWS
contractor
City and qualified botanist
City and qualified botanist or
biologist
City and qualified biologist
City and qualified biologist
City and permitted biologist
City and permitted biologist
City and a qualified resource
specialist (biologist, ecologist,
or soil scientist)
City and qualified biologist
2
City, CDFW, USFWS
City of Palo Alto
City of Palo Alto
City of Palo Alto
City of Palo Alto
City of Palo Alto
City of Palo Alto
City and qualified
biologist
Monitoring Notes
January 2014
ICF 00631.12
City of Palo Alto
Mitigation Measure
BIO-7: Avoid and Protect Jurisdictional Wetlands during
Construction
BIO-8: Compensate for Impacts to Jurisdictional
Wetlands and Waters of the United States prior to
Project-Related Impacts during Construction
BIO-9: Transplant or Compensate for Loss of Protected
Landscape Trees by planting both On-Site and Off-Site,
Consistent with Applicable Tree Protection Regulations
BIO-l0: Protect Remaining Trees from Construction
Impacts
CUL-l: Conduct Worker Awareness Training for
Archaeological Resources Prior to Construction
CUL-3: Conduct a Preconstruction Paleontological
Resources Field Survey and Paleontological Resources
Inventory and Evaluati.on
CUL-4: Conduct Worker Awareness Training for
Paleontological Resources Prior to Construction
HAZ-l: Preparation and Implementation ofa Spill
Prevention, Control, and Countermeasure Plan
HYD-l: Use of Artificial Turf with High Permeability for
Athletic Fields
LU-l: Seeka Voluntary Referral or Ensure that the
Provisions of the CLUP are Met
TRA-l: Develop and Implement a Construction Traffic
Control Plan
Palo Alto Municipal Golf Course Reconfiguration and Baylands
Athletic Center Expansion Project MMRP
Implementation
Responsibility
City and a qualified
resource specialist
(biologist, ecologist, or soil
scientist)
Monitoring
Responsibility
City of Palo Alto
Mitigation Monitoring and Reporting Program
Monitoring Notes
City and qualified biologist City and qualified biologist
City of Palo Alto City of Palo Alto
Construction Contractor City of Palo Alto
and City's ISA Certified
Arborist
City of Palo Alto City of Palo Alto
City and qualified City of Palo Alto
personnel with experience
in vertebrate fossil
monitoring and salvage
City and quaiified City of Palo Alto
professional paleontologist
Construction Contractor City of Palo Alto
City of Palo Alto City of Palo Alto
City and the Airport Land City of Palo Alto
Use Commission
Construction Contractor City of Palo Alto
6 January 2014
'ICF 00631,12
City of Palo Alto
Mitigation Measure
Implementation
Responsibility
Monitoring
Responsibility
Mitigation Monitoring and Reporting Program
Monitoring Notes
TO~~Impi~m~~t~clDii~ing~q~trugfi~~ ·c;.};·
AQ-l: Implement Tailpipe Emission Reduction for
Project Construction
AQ-2: Implement BAAQMD Basic Construction
Mitigation Measures to Reduce Construction-Related
Dust
CUL-2: Stop Work if Cultural Resources, Including
Human Remains, are Encountered during Ground-
Disturbing Activities
CUL-S: Stop Work if Paleontological Resources are
Encountered during Ground-Disturbing Activities
GEO-l: Stockpile Topsoil during Earthwork Activities
and Reuse the Topsoil Onsite during Revegetation as
Needed
GHG-l: Implement BAAQMD Best Management Practices
for Construction
HAZ-2: Require Proper Storage and Handling of
Potential Pollutants and Hazardous Materials
HAZ-3: Stop Work and Implement Hazardous Materials
Investigations and Remediation in the Event that
Unknown Hazardous Materials Are Encountered
HAZ-4: Implement Engineering Controls and Best
Management Practices during Construction
HAZ-S: Prevent Mosquito Breeding During Project
Construction
HYD-2: Installation of LID Measures to Improve
Drainage in Detention or Low-lying Areas
Palo Alto Municipal Golf Course Reconfiguration and Baylands
Athletic Center Expansion Project MMRP
Construction Contractor
Construction Contractor
City of Palo Alto
City and qualified
paleontologist or
archeologist
Construction Contractor
Construction Contractor
Construction Contractor
City of Palo Alto
Construction Contractor
Construction Contractor
City of Palo Alto
7
City and BAAQMD
City and BAAQMD
Qualified archaeologist and
Native American
representative
City of Palo Alto
City of Palo Alto
City of Palo Alto
City of Palo Alto
City of Palo Alto
City of Palo Alto
City of Palo Alto
City of Palo Alto
At least two times per day
while construction activity is
occurring.
January 2014
ICF 00631.12
City of Palo Alto
Mitigation Measure
REC-I: Provide Clearly Signed Detour for Pedestrians
and Bicyclists
T()~e In1~f,~iIt~nted ~~#:r to ~i'9j~~~Opei'~9on
BIO-2e: Deposit Landscape Waste Exclusively in
Developed or Ruderal Areas Absent of Special-Status
Plant Species
Note:
All references to "City" refer to the City of Palo Alto.
Implementation
Responsibility
City of Palo Alto
Qualified
biologist/botanist; Golf
Course Staff
Monitoring
Responsibility
City of Palo Alto
City of Palo Alto
CDFW = California Department of Fish and Wildlife; USFWS = United States Fish and Wildlife Service
Palo Alto Municipal Golf Course Reconfiguration and Baylands
Athletic Center Expansion Project MMRP 8
Mitigation Monitoring and Reporting Program
Monitoring Notes
January 2014
ICF 00631.12
City of Palo Alto Mitigation Monitoring and Reporting Program
Mitigation Measures
Aesthetics
Mitigation Measure AES-l: Apply Light Pollution and Glare Reduction Measures
All artificial outdoor lighting is to be limited to safety and security requirements, signage and
stadium lighting. Lighting will conform to the City's applicable zoning regulations to minimize visual
impacts (PAMC Section 18.23.030) and will be subject to Site and Design review approval (PAMC
18.76) to ensure appropriate light pollution and glare reduction standards are achieved. To meet
City requirements, lighting will be designed using Illuminating Engineering Society's design
guidelines and in compliance with International Dark-Sky Association approved fixtures. All lighting
is to provide minimum impact to the surrounding environment and will use downcast, cut-off type
fixtures that are shielded and direct the light only towards objects requiring illumination. Therefore,
lights will be installed at the lowest allowable height and cast low-angle illumination while
minimizing incidental light spill onto adjacent properties, open spaces, or backscatter into the
nighttime sky. The lowest allowable wattage will be used for all lighted areas and the amount of
nighttime lights needed to light an area will be minimized to the highest degree possible. Light
fixtures will have non-glare finishes that will not cause reflective daytime glare. All outdoor lighting
will be with individual photocells. Lighting will be designed for energy efficiency, use high pressure
sodium vapor lights with individual photocells, and have daylight sensors or be timed with an on/off
program. Lights will provide good color rendering with natural light qualities with the minimum
intensity feasible for security, safety, and personnel access. Lighting, including light color rendering
and fixture types, will be designed to be aesthetically pleasing.
Lights along pathways and safety lighting at building entrances and loading areas will employ
shielding to minimize offsite light spill and glare and be screened and directed away from residences
and adjacent uses to the highest degree possible. The amount of nighttime lights used along
pathways will be minimized to the highest degree possib~e to ensure that spaces are not
unnecessarily over-lit. For example, the amount of light can be reduced by limiting the amount of
ornamental light posts to higher use areas and by using hooded wall mounts or bollard lighting on
travel way portions of pathways.
Stadium lighting will employ spill and glare control features to minimize off-site light pollution.
Luminaires will be chosen for the ability to provide horizontal and vertical beam control for better
control· in directing what is illuminated. In addition, shielding, such as a visor, will be used to further
direct light and reduce light spill and ambient light glow. Luminaires will also incorporate
photometric reflector systems that are designed to reduce light pollution.
All design measures used to reduce light pollution will employ the technologies available at the time
of project design to allow for the highest potential to reduce light pollution and meet City standards.
These technologies may be available through information and products endorsed by the
Illuminating Engineering Society and International Dark-Sky Association in addition to the actual
Palo Alto Municipal Golf Course Reconfiguration and
Baylands Athletic Center ExpanSion Project MMRP 9 January 2014
ICF 00631.12
City of Palo Alto Mitigation Monitoring and Reporting Program
products that lighting manufacturers have developed to improve lighting technologies and reduce
light pollution and glare.
Mitigation Measure AES-2: Reconfigure Baseball and Softball Field Lighting to Meet or Reduce
Existing Levels
Any reconfiguration of the baseball and softball field lighting will conform to the lighting standards
described in PAMC Section 18.23.030 and will, at a minimum, be designed to create no net increase
in the amount of light spill and ambient light glow produced when compared to existing conditions.
If feasible, measures will be taken to reduce the amount of light spill and ambient light glow
produced through the reconfiguration when compared to existing conditions using measures
specified in Mitigation Measure AES-1.
Air Quality
Mitigation Measure AQ"l: Implement Tailpipe Emission Reduction for Project Construction
The City of Palo Alto will require all construction contractors to implement the BAAQMD's exhaust
Basic Construction Mitigation Measures and Additional Construction Mitigation Measures
recommended by BAAQMD to control exhaust emissions. Emission reduction measures will include
at least the following measures and may include other measures identified as appropriate by the Air
District and/or contractor:
• Idling times shall be minimized either by shutting equipment off when not in use or reducing the
maximum idling time to 2 minutes. Clear sign age shall be provided for construction workers at
all access points.
• All construction equipment shall be maintained and properly tuned in accordance with
manufacturer's specifications. All equipment shall be checked by a certified visible emissions
evaluator.
• The simultaneous occurrence of excavation, grading, and ground-disturbing construction
activities in the same area at anyone time shall be limited. Activities shall be phased to reduce
the amount of disturbed surfaces at anyone time.
• The construction contractor shall develop a plan for submittal to the City that demonstrates that
the off-road equipment (more than 50 horsepower) to be used in construction of the Project
(i.e., owned,leased, and subcontractor vehicles) will achieve a Project-wide fleet-average 20
percent NOX reduction. Acceptable options for reducing emissions include the use oflate-model
engines, low-emission diesel products, alternative fuels, engine retrofit technology, after-
treatment products, add-on devices such as particulate filters, and/or other options as such
become available.
• All construction equipment, diesel trucks, and generators shall be required to be equipped with
Best Available Control Technology for emission reductions of NOX and PM.
• All contractors shall be required to use equipment that meets CARB's most recent certification
standard for off-road heavy-duty diesel engines.
Palo Alto Municipal Golf Course Reconfiguration and
Baylands Athletic Center Expansion Project MMRP 10 January 2014
ICF 00631.12
City of Palo Alto Mitigation Monitoring and Reporting Program
Mitigation Measure AQ-2: Implement BAAQMD Basic Construction Mitigation Measures to
Reduce Construction-Related Dust
The BAAQMD will require all construction contractors to implement the Basic Construction
Mitigation Measures re~ommended by BAAQMD to reduce dust emissions. Emission reduction
measures will include at least the following measures and may include other measures identified as
appropriate by the Air District and/or contractor:
• All exposed surface,s (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved
access roads) shall be watered two times per day.
• All haul trucks transporting soil, sand, or other loose material off-site shall be covered.
• All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power
vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.
• All vehicle speeds on unpaved roads shall be limited to 15 mph.
• All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible.
BUilding pads shall be laid as soon as possible after grading unless seeding or soil binders are
used.
• A publicly visible sign shall be posted with the telephone number and name of the person to
contact at the lead agency regarding dust complaints. This person shall respond and take
corrective action within 48 hours. The BAAQMD's phone number shall also be visible to ensure
compliance with applicable regulations.
Biological Resources
Mitigation Measure BIO-1: Develop and Implement Worker Awareness Training
Prior to construction, Worker Awareness Training will be conducted by a qualified biologist to
inform construction project workers of their responsibilities regarding sensitive environmental
resources. The training will include environmental education about sensitive plant species (Alkali
milk vetch, San Joaquin spearscale, Congdon's tarplant, Point Reyes bird's-beak, lost thistle, fragrant
fritillary, woodland woollythreads, hairless popcorn flower, California seablite, Showy Rancheria
clover, and saline clover), western pond turtles, nesting raptors and migratory birds including
western burrowing owl, California clapper rail, California black rail, salt marsh harvest mouse, salt
marsh wandering shrew, California red-legged frog, and San Francisco garter snake, as well as
sensitive resources (e.g., trees, wetlands). The training will include information regarding protected
status of the resource, visual aids to assist in identification of regulated biological resources, and
actions to take should protected wildlife and biological resources be observed within the Project
site. Qualified biologists will be on call and will regularly survey the site during construction.
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Mitigation Measure 810-2a: Conduct Preconstruction Botanical Surveys
The City will retain a qualified botanist to survey suitable habitat in the Project site for the presence
of special-status plants. Surveys will be conducted during the appropriate blooming periods as
indicated in Table 3.3-4.
Table 3.3-4. Timing of Surveys for Special-Status Plants
Species Blooming Period Period Surveys Should Oeeura
Alkali milkvetch March-June April-May
San Joaquin spearscale April-October July-August
Congdon's tarplant June-November July-August
Point Reyes bird's-beak June-October July-August
Lost thistle June-July June-July
Fragrant fritillary February-April February-April
Woodland woolly threads February-July February-July
Hairless popcorn-flower April-May April-May
California seablite July-October July-August
Showy rancheria clover April-June April-May
Saline clover April-June April-May
a Exact timing of surveys should account for annual variations in climate and weather; surveys should be
timed to coincide with blooming periods of known local populations whenever possible.
Surveys will follow the CNPS Botanical Survey Guidelines (California Native Plant Society 2001) and
occur 1 year prior to the start of construction. Since historical and recent routine disturbance has
occurred on the project site, the potential for special-status plants to occur is reduced and only one
season of surveys is expected to be necessary. Special-status plants identified during the surveys
will be mapped using a handheld global positioning system unit and documented as part of the
public record. A report of occurrences will be submitted to the City and the CNDDB. Surveys will be
completed before ground-disturbing activities begin; survey timing will allow for follow-up
mitigation, if needed. This may include seed collection or transplanting. If it is determined that
individuals of identified special-status plant species could be affected by construction traffic or
activities, Mitigation Measure BIO-2b and, if necessary, Mitigation Measure BIO-2c, will be
implemented.
Mitigation Measure BIO-2b: Confine Construction Disturbance and Protect Special-Status
Plants during Construction
Construction disturbance will be confined to the minimum area necessary to complete the work, and
will avoid encroachment on adjacent habitat. If special-status plants are found, a setback buffer will
be established around individuals or the area occupied by the population, based on judgment of a
qualified botanist. The plants and a speci~s-appropriate buffer area determined in consultation with
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agency (CDFW and USFWS) staff will be protected from encroachment and damage during
construction by installing temporary construction fencing to make crews visually aware of the plant
population. Fencing will be brightly colored and highly visible. Fencing will be installed under the
supervision of a qualified botanist to ensure proper location and to prevent damage to plants or the
seed bank during installation. Fencing will be installed before site preparation or construction work
begins and will remain in place for the duration of construction. Construction personnel will be
prohibited from entering these areas (the exclusion zone) for the duration of Project construction.
Fencing installation will be coordinated with fence installation required by other mitigation
measures protecting wetlands, riparian habitat, and mature trees. If special-status plant species
cannot be avoided during construction activities, then both Mitigation Measures BIO-2c and BIO-2d
will be implemented.
Mitigation Measure BIO-2c: Compensate for Loss of Special-Status Plants
If any individually listed special-status plant is present and cannot be effectively avoided through
implementation of Mitigation Measure BIO-2b, the Ctty will develop and implement a compensation
plan. The compensation plan will preserve an offsite area containing individuals of the affected
species. The plan will be implemented so that there is no net loss of special-status plants. If an offsite
population is not available for preservation, the City will employ a qualified nursery to collect and
propagate the affected species, collected at the appropriate time of year, prior to population
disturbance at the affected areas of the Project. Transplantation will also be implemented if
practicable for the species affected, including mature native plants to the extent feasible.
The compensation plan will be developed by a qualified botanist in coordination with and approval
of CDFW or USFWS, depending on whether the plant has state or federal status, respectively, or
both. The compensation area will contain a population and/or acreage equal to or greater than that
lost as a result of Project implementation and will include adjacent areas as needed to preserve the
special-status plant population in perpetuity. The quality of the population preserved will also be
equal to or greater than that ofthe affected population, as determined by a qualified botanist
retained by the City. Compensation sites and populations will be subject to CDFW and USFWS
approval. The City will be responsible for ensuring that the compensation area is acquired in fee or
in conservation easement, maintained for the benefit of the special-status plant population in
perpetuity, and funded through the establishment of an endowment. A monitoring and adaptive'
management plan will also be developed for each compensation site and will be similarly be subject
to CDFW and USFWS approval.
Mitigation Measure BIO-2d: Develop and Implement Special-Status Plant Species Monitoring
Plan
If any special-status plants are present and cannot be effectively avoided through implementation of
Mitigation Measure BIO-2b, the City will develop and implement a monitoring plan. The monitoring
plan will cover a span of 5 years beginning when construction is complete. The City will hire a
qualified biologist or botanist to conduct the monitoring plan. Special-status plants found during the
preconstruction botanical surveys for Mitigation Measure BIO-2a will be mapped and identified. The
qualified biologist will monitor the status of those same populations once a year for five years,
during the respective blooming seasons for each species. Golf Course staff will be aware of the
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location of the special-status plant species to ensure that no operation and maintenance activities
will disturb the existing populations. If the certain plant species' populations are unsuccessful, the
City will reseed/plant suitable habitat and resume monitoring activities until the success criteria
established by the monitoring plan are fully satisfied.
Mitigation Measure BIO-2e: Deposit Landscape Waste Exclusively in Developed or Ruderal
Areas Absent of Special-Status Plant Species
Training will take place after Project construction is complete to educate Golf Course staff in the
importance of the presence of special-status plant species. The training will include a handout of
pertinent special-status plant species' pictures, relevant regulations and legal protections, and an in-
person meeting with Golf Course staff and a qualified biologist/botanist. Golf Course staff will only
be permitted to deposit landscape waste in developed or ruderal areas absent of special-status plant
species (including the proposed 25-foot buffer between the Golf Course and the Athletic Center), as
determined through the botanical surveys proposed in Mitigation Measure BIO-2a during the
construction phase. Special-status plant species will be marked and protected clearly, so Golf Course
staff will be aware of appropriate deposit areas, as well as sensitive areas to avoid.
Mitigation Measure BIO-3: Establish Buffer Zones for Nesting Raptors and Migratory Birds
Prior to the start of construction activities that begin during the migratory bird nesting period
(between February 1 and August 31 of any year), the City will retain a qualified wildlife biologist ~o
conduct a survey for nesting raptors and migratory birds, including special-status species such as
salt marsh common yellowthroat, Alameda song sparrow, northern harrier, and white-tailed kite, at
a time(s) of day most opportune for active nest identification. Surveys will cover all suitable raptor
and migratory bird nesting habitat that will be impacted directly or indirectly through disturbance,
including habitat potentially used by ground-nesting migratory bird species.
If an active nest is discovered during these surveys, the qualified wildlife biologist will establish a
no-disturbance buffer zone around the nest tree (or, for ground-nesting species, the nest itself). The
no-disturbance zone will be marked with flagging or fencing that is easily identified by the
construction crew and will not affect the nesting bird. In general, the minimum buffer zone widths
will be 25 feet (radius) for non-raptor ground-nesting species; 50 feet (radius) for nonraptor shrub-
and tree-nesting spe~ies; and 250 feet (radius) for all raptor species. Buffer widths may be modified
based on discussion with CDFW, depending on the proximity of the nest, whether the nest would
have a direct line of sight to construction activities, existing disturbance levels at the nest, local
topography and vegetation, the nature of proposed activities, and the species potentially affected.
Buffers will remain in place as long as the nest is active or young remain in the area. No construction
presence or activity of any kind will be permitted within a buffer zone until the biologist determines
that the young have fledged and moved away from the area and the nest is no longer active.
If monitoring of active nests indicates that disturbance is affecting active nests, buffer widths will be
increased until the disturbance no longer affects the nest(s) as determined by the biologist. If the
buffer cannot be extended further, then work within the area will stop until the nest is no longer
active.
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Mitigation Measure BIO-4: Implement Survey and Avoidance Measures for Western
Burrowing Owls Prior to Construction Activities
Prior to any construction activity planned to begin during the fall and winter nonnesting season
(September i-January 31), the City will retain a qualified wildlife biologist to conduct a
preconstruction survey for burrowing owls. Surveys will follow the protocol outlined by the
California Burrowing Owl Consortium (CBOC) (1993) and the 2012 CDFW staff report. If any
burrows occupied by western burrowing owls are found within the disturbance area during the
surveyor at any time during the construction process, the City will notify CDFW and will proceed
under CDFW direction. If construction is planned to occur during the nesting season (February 1-
August 31), surveys for nesting owls will be conducted by a qualified wildlife biologist in the year
prior to construction to determine if there is breeding within 250 feet of the construction footprint.
This prior-year survey will provide the Project team advance notice regarding nesting owls in the
Project site and allow ample time to discuss with CDFW the appropriate course of action if nesting
owls are found. In addition, same-year preconstruction surveys for nesting western burrowing owls
will be conducted no more than 7 days prior to ground disturbance in all suitable burrowing owl
habitat to ensure owls can be avoided. If the biologist identifies the presence of a nesting burrowing
owl in an area scheduled to be disturbed by construction, a 250-foot no-activity buffer will be
established and maintained around the nest while it is active. Surveys and buffer establishment will
be performed by qualified wildlife biologists, will be coordinated with CDFW, and will be subject to
CDFW review and oversight.
Mitigation Measure BIO-5: Implement Survey and Avoidance Measures for California Clapper
Rail and California Black Rail Prior to Construction Activities
If work is to be conducted during California clapper rail and California black rail breeding and
rearing seasons (March i-August 31) within 700 feet of suitable habitat, the City will retain a
permitted biologist to conduct protocol-level surveys at the Project site including rail call surveys
and raiHrack surveys in appropriate habitat for California clapper rail and California black rail
(California Coastal Conservancy 2011). The surveys will be conducted no more than 48 hours prior
to commencement of construction and maintenance activities and will be performed at dawn or
dusk, the vocalization periods of highest intensity. Project activities occurring within 700 feet of
active nests will be postponed until after young have fledged, unless activities are behind a levee and
will not affect any active nests as determined by the biologist.
Outside of breeding season, the City will retain a permitted biologist to conduct surveys of
appropriate habitat for California clapper rail and California black rail within the work area,
including all staging and access routes, no more than 7 days prior to initiation of work within
suitable habitat. If individuals are observed during this survey, a biologist will conduct an additional
survey immediately prior to initiation of construction activities. If individuals are observed within or
near the work area, a no-disturbance buffer (minimum 50 feet) will be implemented. If the daily
work area is expanded, then a qualified biologist will survey the suitable habitat prior to initiation of
work and movement of equipment that day. No work will occur within the buffer until the biologist
verifies that California clapper rail or California black rail individuals have left the area.
If individuals are routinely detected in the work area, a species avoidance plan will be developed in
coordination with USFWS and CDFW. Ifno individuals are detected during surveys, no buffers will
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be required. All vegetation removal within suitable habitat of these species, as determined by a
biologist, will be done by hand to the extent possible. If movement of heavy equipment in necessary
in suitable habitat or within 50 feet (audibly or visually) of habitat, then a biological monitor will
observe the area in front of the equipment from a safe vantage point. If these species are detected
within the area in front of the equipment, then the equipment will stop and the biologist will direct
the equipment on an alternative path. If this is not possible, then equipment will stop until a clear
path can be identified.
Mitigation Measure BIO-6: Implement Survey and Avoidance Measures for Salt Marsh Harvest
Mouse and Salt Marsh Wandering Shrew Prior to Construction Activities
Prior to initiation of work within suitable habitat, a permitted biologist will be retained to monitor
the hand removal of pickle weed to avoid impacts on salt marsh harvest mouse and salt marsh
wandering shrew. Monitoring will occur for the duration of all clearing work within suitable habitat,
and all clearing of pickleweed will be conducted by hand. If salt marsh harvest mouse or salt marsh
wandering shrew are observed during clearing activities, dearing will cease and workers will move
to a new area. Clearing work may begin in the area of the observation 1 day or more after the
observation date.
During the survey, if salt marsh harvest mouse or salt marsh wandering shrew individuals are
observed, or if active nests of these species are observed, proposed Project activities within 100 feet
of the observation will be postponed and a no-disturbance buffer will be established. The buffer will
remain in place until the biologist determines that the individuals have left the area and are not
present in or near (100 feet) ofth~ work area. If no individuals are observed in accordance with the
survey protocols, no buffers will be required.
If salt marsh harvest mouse or salt marsh wandering shrew are observed within wetlands proposed
to be affected by the Project, then a habitat avoidance, impact minimization, and compensation plant
will be developed, in coordination with USFWS and CDFW, prior to alteration of occupied habitat. If
neither species is observed during preconstruction surveys, then no further mitigation associated
with this measure is necessary.
If salt marsh harvest mouse or salt marsh wandering shrew are observed within the Project Area,
construction and maintenance work, including site preparation, will be avoided to the extent
possible within suitable habitat for these species during their breeding seasons (February 1 to
November 30). As work during the species' breeding seasons will be necessary, a species avoidance
plan will be developed in consultation with USFWS and CDFW, and implemented. The avoidance
plan, at a minimum, will include the following.
• Hand removal of vegetation will start at the edge farthest from the largest contiguous salt marsh
area and work its way towards the salt marsh, providing cover for salt marsh harvest mice and
allowing them to move towards the salt marsh as vegetation is being removed.
• In consultation with CDFW, exclusion fencing will be placed around a defined work area
immediately following vegetation removal and before Project activitie~ begin. The final design
and proposed location of the fencing will be reviewed and approved by CDFW prior to
placement.
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• Prior to initiation of work each day within 300 feet of pickel weed habitats, a qualified biologist
will thoroughly inspect the work area and adjacent habitat areas to determine if saltmarsh
harvest mice are present. The biologist will ensure the exclusion fencing has no holes or rips and
the base remains buried. The fenced area will be inspected daily to ensure that no mice are·
trapped.
Mitigation Measure BIO-7: Avoid and Protect Jurisdictional Wetlands during Construction
The City will ensure that a qualified resource specialist (biologist, ecologist, or soil scientist) will
clearly identify wetland areas to be preserved and wetland areas outside of the direct impact
footprint with temporary orange construction fencing before site preparation and construction
activities begin at each site or will implement another suitable low-impact measure. Construction
will not encroach upon jurisdictional wetlands identified by the wetland specialist. The resource
specialist will use the Project's wetland delineation (ICF International 2013) to confirm the location
of wetland boundaries based on existing conditions at the time of the survey. Exclusion fencing will
be installed before construction activities are initiated, and the fencing will be maintained
throughout the construction period. No construction activity, traffic, equipment, or materials will be
permitted in fenced wetland areas.
Mitigation Measure BIO-8: Compensate for Impacts to Jurisdictional Wetlands and Waters of
the United States prior to Project-Related Impacts during Construction
The City will develop a wetland/waters of the United States mitigation monitoring plan (MMP),
subject to approval by the USACE, that will ensure no net loss of wetlands will result from the
Project's impacts. The details of site restoration, monitoring, and adaptive management will be
included in the MMP in compliance with the Clean Water Act. The MMP will include success criteria
that will be assessed by comparing performance during the monitoring period against objective and
verifiable, ecologically-based success criteria that reflect the goals and objectives of the site.
Examples of success criteria may include, but are not limited to: (1) period of inundation similar to
other wetlands of the same type in the South Bay region, (2) percent vegetation cover, and (3) plant
species composition similar to other wetlands of the same type in the South Bay region, all aimed at
replacing the functions and values that were lost in the wetland that was removed. The monitoring
period will be a 5-year period; the success criteria for this period must be satisfied in at least 3 of the
5 years, but if the success criteria are not so satisfied, then the monitoring period will be extended
from year to year until the success criteria are satisfied within a consecutive period of 3 years. The
City will retain a qualified biologist to conduct annual monitoring to assess establishment of wetland
vegetation and wetland function, and if necessary, implement adaptive management actions
(including replanting, nonnative species removal, etc.) to ensure that there is no net loss of wetland
habitat. Wetland compensation habitat will be set aside and protected in perpetuity through
appropriate legal means, consistent with U.S. Army Corps of Engineers' requirements and as
specified in permits. The City will be responsible for all associated costs and logistics.
The Project proposes to create and restore existing wetlands Within the Golf Course, resulting in a
total of 12.168 acres of wetlands. The plan will detail the amount and type of wetlands (based on the
Project's wetland delineation once verified) that will compensate (through preservation, creation,
and/or restoration) for Project impacts to existing wetlands/waters of the United States, and outline
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the monitoring and success criteria for the compensation wetlands/waters of the United States.
Once the plan is approved, the City will implement its wetland/waters of the state compensation
measures. Wetland creation and enhancement activities will be completed concurrent with the
completion of the Project, after which the City will retain a qualified biologist to monitor the
compensation features per theMMP.
Mitigation Measure BIO-9: Compensate for Loss of Protected Landscape Trees by planting
both On-Site and Off-Site, Consistent with Applicable Tree Protection Regulations
Regulated trees that are removed will be replaced through a combination of on-site replacement
with native Baylands-appropriate trees, protection of naturally-generated oak saplings in the
Arastradero Preserve and/or other Foothills locations, and restoration of two acres of native Bay
ecosystem areas in close proximity to the Project. The landscaping plan for tree mitigation will
specifically identify the locations where replacement trees, oak sapling protection, apd native Bay
ecosystem restoration areas are to be planted; mitigation will occur both on-site and offsite. Offsite
locations include Baylands locations near the Project site, the Arastradero Preserve and/or other
locations in the foothills. The on-site tree replacement will consist of the planting of 300 natjve trees
on the reconfigured golf course as part of the Project. The off-site tree protection will consist of the
placement of protective cages around 500 naturally-occurring oak saplings on the Arastradero
Preserve in order to prevent browsing by deer until the trees have matured adequately to ensure
their long-term survival. The off-site native Bay ecosystem restoration will consist of the planting of
two acres of native grasses and shrubs at a site or sites within the Baylands in close proximity to the
Project site. The final mitigation landscaping plan: will be subject to review and approval by the City.
Newly planted trees, protected saplings, and restored native Bay ecosystem areas will be monitored
by the City staff and/or a contactor at least once a year for five years. Each year, any vegetation that
does not survive will be replaced consistent with the City of Palo Alto Tree Technical Manual. Any
vegetation and/or native plant material that does not survive will be replaced and monitored for an
additional five years. After five years, monitoring of the newly planted trees, protected saplings,
and restored native Bay ecosystem areas will be continued, as needed, through fiscal year 2034,
predicated on the availability of funding. (
Mitigation Measure BIO-10: Protect Remaining Trees from Construction Impacts
Trees not designated for removal will be protected from damage during construction by the
installation oftemporary fencing and other methods determined necessary and prescribed in the
City of Palo Alto Tree Technical Manual such as, but not limited to, trunk wrapping, root mulching,
and access route gravelling, consistent with International Society of Arboriculture tree protection
zone recommendations. Fencing will be installed outside of the tree's dripline to keep construction
equipment away from trees and prevent unnecessary damage to or loss of regulated trees on the
project site. Any regulated trees retained on the site and located adjacent to construction activities
will be monitored monthly during the term of construction and replaced off-site if they do not
survive through the monitoring period. Consistent with Section 2.30 in the City of Palo Alto's Tree
Technical Manual!, an ISA certified arborist will conduct monthly inspections to monitor tree health
conditions and document such observations in a monthly inspection report. Additional tree
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protection practices may be required in accordance with the City of Palo Alto Tree Technical Manual
or at discretion of City staff.
Cultural Resources
Mitigation Measure CUL-1: Conduct Worker Awareness Training for Archaeological
Resources Prior to Construction
Prior to the initiation of any site preparation and/or start of construction, the applicant will ensure
that all construction workers receive training overseen by a qualified professional archaeologist
who is experienced in teaching nonspecialists, to ensure that forepersons and field supervisors can
recognize archaeological resources (e.g., areas of shellfish remains, chipped stone or groundstone,
historic debris, building foundations, human bone) in the event that any are discovered during
construction.
Mitigation Measure CUL-2: Stop Work if Cultural Resources, Including Human Remains, are
Encountered during Ground-Disturbing Activities
The applicant will ensure the construction specifications include a stop work order if prehistoric or
historic-period cultural materials are unearthed during ground-disturbing activities. All work within
100 feet of the find will be stopped until a qualified archaeologist and Native American
representative can assess the significance of the find. Prehistoric materials might include obsidian
and chert flaked-stone tools (e.g., projectile points, knives, scrapers) or tool making debris;
culturally darkened soil ("midden") containing heat-affected rocks and artifacts; stone milling
equipment (e.g., mortars, pestles, handstones, or milling slabs); and battered-stone tools, such as
hammerstones and pitted stones. Historic-period materials might include stone, concrete, or adobe
footings and walls; filled wells or privies; and deposits of metal, glass, and/or ceramic refuse. If the
find is determined to be potentially significant, the archaeologist, in consultation with the Native
American representative, will develop a treatment plan that could include site avoidance, capping,
or data recoveryl
Mitigation Measure CUL-3: Conduct a Preconstruction Paleontological Resources Field Survey
and Paleontological Resources Inventory and Evaluation
The City will retain qualified personnel with experience in vertebrate fossil monitoring and salvage
at construction sites to conduct a paleontological resources field survey with native soils to
determine whether significant resources exist within the Project site. The inventory and evaluation
will include the documentation and result of these efforts, the evaluation of any paleontological
resources identified during the survey, and paleontological resources monitoring, if the survey
identifies that it is necessary.
1 http://www.canopy.org/media /files /Tree% 2 OTecnicai %20 Man ual.pdf
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Mitigation Measure CUL-4: Conduct Worker Awareness Training for Paleontological
Resources Prior to Construction
Prior to the initiation of any site preparation and/or start of construction, the applicant will ensure
that all construction workers receive training overseen by a qualified professional paleontologist
who is experienced in teaching nonspecialists, to ensure that forepersons and field supervisors can
recognize paleontological resources in the event that any are discovered during construction.
Mitigation Measure CUL-5: Stop Work if Paleontological Resources are Encountered during
Ground-Disturbing Activities
If paleontological resources are discovered during ground-disturbing activities, work will stop in
that area and within 100 feet of the find until a qualified paleontologist with experience ih
vertebrate fossil monitoring and salvage at construction sites can assess the significance of the find
and, if necessary, develop appropriate treatment measures in consultation with the City and other
agencies as appropriate. Equipment operators, supervisors, inspectors, and other field personnel
will be required to report to the paleontology monitor any suspected fossil discoveries. The
paleontologist will have authority to halt or redirect excavation operations in the event of discovery
of vertebrate, plant, or invertebrate fossils until such time as their probable significance can be
assessed and, if potentially significant, appropriate salvage measures have been implemented.
The paleontologist will properly collect and document any large vertebrate remains and recognize
and appropriately sample and document any sedimentary bodies revealing small vertebrate
remains. Large bulk samples may be appropriate. Minimum documentation includes exact location
(GPS data), orientation, depth (elevation), and detailed geologic setting of any large-or small-
vertebrate finds" including detailed diagrams showing microstratigraphy in nearby excavations
supplemented with good-quality field photographs. Ifvertebrate fossils are discovered in spoils
piles during excavation, the paleontologist will make every effort to locate and record the original
site of the specimen(s) prior to disturbance.
Salvage of potentially significant specimens discovered in situ in excavated surfaces will be
conducted by the paleontologist in compliance with all safety regulations and with implementation
of aU feasible precautions. The onsite safety inspector will hold final authority to determine whether
each proposed salvage operation is consistent with established safety policies at the site. Excavation
equipment and operators will be made available for short periods to remove overburden above in
situ specimens, to improve safety conditions during salvage operations, or to aid in transport within
the site boundaries of any large salvaged specimens which cannot be safely transported by hand.
Any potentially significant fossils recovered during the monitoring and salvage phase will be
cleaned, repaired, and hardened to the level required by the repository institution, and will be
donated to that institution. Any collected bulk sediment samples having the potential for small fossil
vertebrate remains will be wet-or dry-screened and processed as necessary for recovery of the
included fossils. Details of requirements and conditions for transfer of salvaged specimens to the
repository museum will be arranged with the museum as soon as the scope of the salvaged
collection becomes apparent, and will be in accordance with the recommendations outlined in the
SVP Guidelines (1995).
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On completion of the above tasks, the supervising paleontologist will prepare a final report on the
implementation of the mitigation plan and results and submit it to the appropriate parties,
institutions, and government agencies.
Geology and Soils
Mitigation Measure GEO-1: Stockpile Topsoil during Earthwork Activities and Reuse the
Topsoil Onsite during Revegetation as Needed
The contractor(s) retained for construction and re-vegetation of the proposed Project will be
required to stockpile excavated native topsoil so it can be reused for re-vegetation on the Project
site as needed. To ensure maximum topsoil recovery, topsoil will be stockpiled separately from
other excavated materials.
Greenhouse Gas Emissions and Climate Change
Mitigation Measure GHG-1: Implement BAAQMD Best Management Practices for Construction
The City will require all construction contractors to implement the BMPs recommended by the
BAAQMD to reduce GHG emissions. Emission reduction measures will include, at a minimum, the
following measures.
• Use local building materials of at least 10 percent; and
• Recycle or reuse at least 50 percent of construction waste or demolition materials.
Hazards and Hazardous Materials
Mitigation Measure HAZ-1: Preparation and Implementation of a Spill Prevention, Control,
and Countermeasure Plan
The project applicant with prepare and implement a Spill Prevention, Control, and Countermeasure
(SPCC) Plan to minimize the potential for, and effects from, accidental spills of hazardous, toxic, or
petroleum substances during construction of the project. The SPCC will be completed before any
construction activities begin.
Mitigation Measure HAZ-2: Require Proper Storage and Handling of Potential Pollutants and
Hazardous Materials
The storage and handling of potential pollutants and hazardous materials, including, but not
necessarily limited to, gasoline, diesel, oils, paint, and solvents, will be in accordance with all local,
state and federal laws and other requirements. Temporary storage enclosures, double walled tanks,
berms, or other protective facilities will be provided as required by law. All hazardous materials will
be stored and handed in strict accordance with the Material Safety Data Sheets for each product. A
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copy of each Materials Safety Data Sheet will be submitted to the Project Engineer at the time of
delivery of the products to the Project site.
Mitigation Measure HAZ-3: Stop Work and Implement Hazardous Materials Investigations
and Remediation in the Event that Unknown Hazardous Materials Are Encountered
In the event that unknown hazardous materials are encountered during construction monitoring or
testing of soil suitability, all work in the area of the discovery will stop and a Phase II hazardous
materials investigation will be conducted to identify the nature and extent of contamination and
evaluate potential impacts on Project construction and human health. If necessary, based on the
outcomes of the Phase II investigation, the City of Palo Alto will implement remediation measures
consistent with all applicable local. state, and federal codes and regulations. Construction in areas
known or reasonably suspected to be contaminated will not resume until remediation is complete. If
waste disposal is necessary, the City of Palo Alto will ensure that all hazardous materials removed
during construction are handled and disposed of by a licensed waste-disposal contractor and
transported by a licensed hauler to an appropriately licensed and permitted disposal or recycling
facility, in accordance with local, state, and federal requirements.
Mitigation Measure HAZ-4: Implement Engineering Controls and Best Management Practices
during Construction
During construction the contractor shall employ use of engineering controls and BMPs to minimize
human exposure to potential contaminants. Engineering controls and construction BMPs shall
include but not be limited to the following.
• Contractor employees working onsite shall be certified in OSHA's 40-hour Hazardous Waste
Operations and Emergency Response (HAZWOPER) training.
• Contractor shall monitor area around construction site for fugitive vapor emissions with
appropriate field screening instrumentation.
Mitigation Measure HAZ-S: Prevent Mosquito Breeding During Project Construction
To prevent mosquito breeding during Project construction, the Contractor will ensure that standing
water that accumulates on the construction site is gone within four days (96 hours). All outdoor
grounds will be examined and unnecessary water that may stand longer than 96 hours will be
drained. Construction personnel will property dispose of unwanted or unused artificial containers
and tires. If possible, any container or object that holds standing water that must remain outdoors
will be covered, inverted, or have drainage holes drilled.
Hydrology and Water Quality
Mitigation Measure HYD-1: Use of Artificial Turf with High Permeability for Athletic Fields
In order to ensure for adequate groundwater infiltration as part of the Athletic Center Expansion,
which includes up to five full size athletic fields, the type of artificial turf (synthetic grass) in the
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City of Palo Alto Mitigation Monitoring and Reporting Program
athletic fields could be changed to a design that allows for increased surface-ground penetration
(City of Palo Alto 2012b). While artificial turf coating often allows for water to quickly pass through
the turf system, the overall drainage depends heavily on the quality of the underlying base. The City
may choose an artificial turf with a highly permeable base.
Mitigation Measure HYD-2: Installation of LID Measures to Improve Drainage in Detention or
Low-lying Areas
New detention or low-lying areas may require additional measures for drainage improvements. If
the depth and the area of the low-lying areas are not adequate, underground detention facilities or
additional drainage facilities would be implemented to improve drainage. Examples of drainage
improvements are storm chambers, or semi-elliptical shaped barrels with drain rocks for flow
dissipation. Water would be stored underground in the barrel through an inlet, and excess water
comes up to the surface and is discharged through the existing storm drain system.
Land Use and Planning
Mitigation Measure LU-l: Seek a voluntary referral or ensure that the provisions ofthe CLUP .
are met.
Prior to construction of the Athletic Center Expansion, the City will seek a voluntary referral from
the Airport Land Use Commission (ALUC) regarding the de~ign of the athletic center facilities.
Alternatively, as a member agency of the ALUC, the City will ensure that the provisions of the
Comprehensive Land Use Plan are met.
Recreation
,
Mitigation Measure REC-l: Provide Clearly Signed Detour for Pedestrians and Bicyclists
A clearly signed detour for the Bay Trail and Juan Bautista de Anza NHT will be provided during
closures of the Athletic Center parking lot and trail access point to maintain continuous access and
to avoid confusion for trail users. Notice regarding closure and/or detour will be provided 30 days
in advance. At a minimum, this notice will be provided at the trailhead, Friendship Bridge, City Hall,
and on City's website.
Transportation and Traffic
Mitigation Measure TRA-l: Develop and Implement a Construction Traffic Control Plan
Prior to issuance of grading permits, the construction contractor will develop the traffic control plan
in accordance with City's policies and submit for City approval. The plan will be implemented
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