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Staff Report 255-09
TO: HONORABLE CITY COUNCIL FROM: CITY MANAGER DEPARTMENT: UTILITIES DATE: JUNE 1,2009 CMR: 255:09 REPORT TYPE: REPORTS OF OFFICIALS SUBJECT: Adoption of Five Resolutions Relating to the Palo Alto Recycled Water Project: (1) Resolution Adopting a Mitigated Negative Declaration for the City of Palo Alto Recycled Water Project Pursuant to the California Environmental Quality Act; (2) Resolution Establishing a Water Capital Reserve Fund in Accordance with the State Water Resources Control Board's Requirements for State Revolving Fund Program; (3) Resolution Designating Certain Palo Alto Recycled Water Pipeline Project Expenditures to be Reimbursed by Proceeds From State Revolving Fund; (4) Resolution Establishing One or More Dedicated Sources of Revenue for Repayment of Funding Pursuant to the Federal Clean Water Act Amendments; (5) Resolution Repealing Resolution No. 8913 and Authorizing the City Manager to Sign and File a Financial Assistance Application and Execute a State Revolving Fund Financial Assistance Agreement in an Amount Not to Exceed $37 Million From the State Water Resources Control Board for the Design and Construction of the Palo Alto Recycled Water Pipeline Project EXECUTIVE SUMMARY The Palo Alto Recycled Water Project would expand the recycled water distribution system to serve additional customers in Palo Alto. The project has the potential to replace a significant part of potable water demands with recycled water for nonpotable needs such as irrigation and, in the future, interior uses such as toilet and urinal flushing and in industrial processes and cooling towers. The City has completed the environmental review of the project and this report recommends that Council adopt the environmental document supporting the project, the Final Mitigated Negative Declaration (Final MND). The Final MND is a tiered document within the scope of the 1995 Program EIR for the Water Reclamation Master Plan. The Final MND lists the mitigation measures that have been incorporated into the document and includes the response to comments received during the public review of the Draft MND. CMR: 255:09 Page 1 of 11 Since the cost of the project is high, staff has pursued outside funding, in the fonn of grants and loans. Due to the potential to receive Federal stimulus funds made available to the State Water Resources Control Board (SWRCB), additional project activities are required over the next few months. This report requests Council approval of resolutions in order to apply for SWRCB funds. Applying for the funds does not commit the City to proceed with the project. A recommendation to proceed will be presented to Council at a later date. RECOMMENDATION Staff recommends that Council adopt the following resolutions required by the State Water Resources Control Board for applying for grant or loan funds for the Palo Alto Recycled Water Project: 1. Adopting the Final Mitigated Negative Declaration (Final MND) for the City of Palo Alto Recycled Water Project pursuant to the California Environmental Quality Act; and 2. Establishing a water capital reserve fund in accordance with the State Water Resources Control Board's requirements for the State Revolving Fund Program; 3. Designating certain Palo Alto Recycled Water Pipeline Project expenditures to be reimbursed by proceeds from the State Revolving Fund; 4. Establishing one or more dedicated sources of revenue for repayment of funding pursuant to the Federal Clean Water Act Amendments; and 5. Authorizing the City Manager or designee to sign and file a financial assistance application and execute a State Revolving Fund Financial Assistance Agreement in an amount not to exceed $37 million from the State Water Resources Control Board for the design and construction of the Palo Alto Recycled Water Pipeline Project. BACKGROUND Palo Alto completed a Water Reclamation Master Plan (Master Plan) for the Palo Alto Regional Water Quality Control Plant (RWQCP) in 1992. Council adopted the accompanying Final Program Environmental Impact Report (PEIR) in 1995 (CMR 217:95). The Master Plan and the PEIR evaluated the development of a regional water reuse system that could ultimately provide service to the entire RWQCP service area. Benefits of the program include reduced effluent discharge from the R WQCP into San Francisco Bay and reduced reliance on potable water deliveries from the Hetch Hetchy system. The Master Plan presents a phased approach to the expansion of treatment, distribution, storage and use of recycled water. Phase 1 of the regional recycled water system has been in operation since 1980. It serves the Palo Alto Golf Course, Greer Park, the Emily Renzel Marsh, the Duck Pond, and the RWQCP. Phase 2 of the expansion, the Mountain View Recycled Water project, is under construction and is scheduled to be online by spring 2009. This proposed project, Phase 3, is the next increment of the RWQCP's ongoing expansion of its regional recycled water system and includes the construction of recycled water pipeline and associated facilities to provide an alternative water supply for non-potable uses. The project would initially serve approximately 900 acre-feet per year (AFY) of recycled water, mostly to customers in the Stanford Research Park Area. Future extensions could serve Stanford CMR: 255:09 Page 2 of 11 University and Los Altos Hills, as well as create a loop by making a second connection to the Phase 2 Mountain View Project. The predominant use of recycled water for the proposed project is landscape irrigation. Some uses, such as commercial and light industrial cooling towers or for toilet flushing inside buildings, could also be included at a later date. The State Water Resources Control Board (SWRCB) administers the State Revolving Fund (SRF) program. The SRF program has a fixed amount of funds available each fiscal year and provides loans to agencies on a first-come-first-served basis. Under this program, eligible projects can apply for loans with interest rates that are roughly half of the State General Obligation Rate. These favorable terms help lower total project costs. As part of the process to eventually apply for an SRF loan, applicants must prepare a Recycled Water Facility Plan and accompanying environmental documents for the project. In March 2007, the City applied for and received a planning grant for the preparation of a Facility Plan and accompanying environmental document from the SWRCB through the Regional Water Recycling Facilities Planning Grant Program for the Phase 3 project. The Facility Plan was completed in December 2008, and, in January 2009, the SWRCB approved the Final Facilities Plan for the Palo Alto Phase 3 project. On April 27, 2009, the Council received the completed Facilities Plan for the project (CMR: 203:09). According to the December 2008 Facility Plan, the total estimated cost for the project is $33.5 million in capital costs and $200,000 per year in operations and maintenance (O&M) costs. If the capital costs could be financed at an interest rate of 5.5% per year for 30 years, the annual cost, including O&M costs, is about $2.5 million, or a unit cost of $2,700 per AF. This cost is significantly higher than the current cost of high quality potable water from the San Francisco Public Utilities Commission (SFPUC) of $623 per AF and the projected costs of SFPUC water in FY 2019 of about $1,600 per AF. Staff will be presenting Council with a thorough discussion of the costs and benefits of the project in the near future and a recommendation on whether to proceed with the project. It is anticipated this analysis will incorporate the additional regulatory and economic factors that need to be considered over the life of the project in addition to SFPUC potable water comparisons. Given the cost challenges of the project, staff is actively pursuing all potential sources of funds, including those from the federal and state governments as well as from local or regional partners. If a zero interest loan for the project could be obtained from the SWRCB, then the effective annual cost, including O&M costs, would be about $1.32 million, resulting in a unit cost of recycled water of$1,460 per AF. If grant funds, or other outside funding, were received, the cost to Palo Alto would be reduced, further improving the cost-effectiveness of the project. DISCUSSION Mitigated Negative Declaration A Mitigated Negative Declaration (MND) was prepared in accordance with the California Environmental Quality Act (CEQA) for the Project. The MND is a tiered document within the scope of the 1995 Program EIR and identifies the potential impacts associated with the Palo Alto project and provides project-specific mitigation measures. CMR: 255:09 Page 3 of 11 Proposed Project The proj ect is comprised of three main structural elements (proposed pipeline, booster pump station with generator, and pump station at the RWQCP) and the Adaptive Management Program addressing recycled water usage. The proposed project would involve the construction of approximately 5 miles of 12-to 18-inch pipes, a 1,500 square-foot booster pump station, approximately 5 miles of lateral pipelines to over 50 use sites, and a pump station at the RWQCP. The proposed pipeline consists of the backbone pipeline and offshoots, or lateral pipelines. The proposed backbone pipeline alignment would begin with a connection point to the Mountain View Project near the intersection of East Bayshore Road and Corporation Way and make its way through the City to Hillview Avenue and Arastradero Road. Pipeline construction would typically require a minimum of one lane of traffic and the adjacent shoulder, resulting in a construction corridor approximately 20 feet to 30 feet wide. The proposed pipeline laterals, and portions of the pipeline would also pass through uses designated as Major Institution/Special Facilities. This land use designation provides for institutional, academic, governmental, and community service uses and lands that are either publicly owned or operated as non-profit organizations. The proposed pipelines would be buried and would not affect any surface land uses. The proposed booster pump station would be located at 2700 EI Camino Real (Mayfield Soccer Fields), a site designated as Multi-Family Residential. The proposed booster pump station would be located within lands that allow such facilities with appropriate use permits. The RWQCP pump station site is designated as Major Institution/Special Facility in the Palo Alto 1998 2010 Comprehensive Plan. Public Involvement The City has actively included stakeholders in recycled water related project planning. This involvement included preparation of the PEIR for the Recycled Water Master Plan in 1995, stakeholder workshops for the RWQCP's Long Term Goals Study (LTGS) preparation between 2000 and 2002, stakeholder workshops for the Mountain View Recycled Water Project facility planning in 2004, public meetings as part of Initial Study/ Draft Mitigated Negative Declaration (IS/MND) preparation for the Mountain View Project, and surveys of potential customers for the Palo Alto Recycled Water Market Assessment in 2006. Stakeholder involvement for this phase of the project has included: • Facility managers meeting on June 13, 2007. Facility managers manage a customer's utilities, such as energy use (electric and gas), water use, and wastewater. The Facility managers meeting included employees of large businesses such as Roche, Hewlett Packard and Varian, as well as public facilities such as parks (primarily for water use and irrigation). The facility managers are typically responsible for maintaining and operating irrigation systems and cooling towers on their properties. The facility managers were given an overview of the project and were given the opportunity to ask questions and make comments regarding the project. Comments received have been incorporated into this IS/MND. CMR: 255:09 Page 4 of 11 • Public scoping meeting for the proposed Project on September 18,2007. All interested members from the public were welcome to attend. The City specifically invited the LTGS stakeholders, who represent a wide range of environmental and socioeconomic interests of the communities, and the facility managers to attend and participate in the meeting. Announcements for the meeting were published in the Palo Alto Daily News and Palo Alto Weekly. A comment form was made available at the public scoping meeting for the public to send comments to the City and to be added to the mailing list for the Project. The project mailing list is used to send updates and notices about the Project. Comments received at the scoping meeting have been incorporated into this ISIMND. • Public participation meeting on April 6, 2009. A public meeting was held to discuss and receive comments on the Draft Mitigated Negative Declaration. The notice for the meeting was published in the Palo Alto Daily News on March 13th, 2009 and was also noticed on the City'S webpage. No comments were received at the meeting. • Public comments on the Draft Mitigated Negative Declaration. The City received seven comment letters from the following stakeholders on the Draft Mitigated Negative Declaration: o Canopy o Santa Clara Valley Water District o State of California (Department of Transportation, Department of Toxic Substances Control, and State Water Resources Control Board) o Stanford University Real Estate Office o Santa Clara Valley Transportation Authority The commenters provided input on numerous issues related to Biological Resources, Water Quality, Hydrology, Hazardous Materials, Traffic and Cultural Resources. The City has responded to comments with adjustments to the language in the Final MND when the comments warranted such a change. The Draft MND, the Response to Comments document and the Mitigation Monitoring and Reporting Program collectively comprise the Final MND (Attachment F). Potential tree and vegetation issues associated with using recycled water for irrigation purposes were the subject of concern for several commenters. The concerns were focused on the water quality of the recycled water, particularly the "salinity", or Total Dissolved Solids (TDS) content of the recycled water. These concerns were also addressed and are discussed in the following section. Irrigation Management The 1995 PEIR identified and discussed issues related to a regional recycled water program. The PEIR evaluated the potential impacts associated with recycled water use on soils, vegetation and plants. Note that mitigation measures in the PEIR reduce potential salinity impacts to a level of insignificance. CMR: 255:09 Page 5 of 11 Mitigation Measure (MM) 3.2-2: Reclaimed water users shall apply reclaimed water in quantities sufficient to leach accumulated salts through the root zone, shall monitor the effect of the reclaimed water on landscape vegetation over time, and shall take additional mitigation measures as necessary. The PEIR discusses implementation strategies that would fulfill the requirements of MM 3.2-2 and provides guidance on best irrigation water management practices that should be used and include the following activities: • Provide proper training and information regarding recycled water use (provided by the R WQCP to all recycled water use site managers); • Apply appropriate quantities of irrigation water to ensure leaching and maintain adequate surface drainage by recycled water use site managers; • Monitor the health and appearance of vegetation being irrigated with recycled water to identify any adverse effects (e.g., reduction in growth or plant death) by recycled water use; and • Implement other measures as needed, including, for example, one or more of the following: o Irrigate affected areas during nighttime hours; o Add soil amendments to the soil or the reclaimed water; o Replace salt-intolerant plants with salt-tolerant species; o Blend the reclaimed water with potable water or non-potable groundwater. In the 2009 MND, staff revisited the section on salinity in the original 1995 PEIR to reflect the current information related to this issue. Staff investigations did not reveal evidence that the use of recycled water during the fourteen years since the publication of the PEIR resulted in significant impacts to soils or vegetation for the numerous projects that have been delivering recycled water during that time frame. However, staff recognized in the MND that there are increased onsite management options (best management practices, or BMPs) to manage poor performance of certain trees irrigated with recycled water (primarily Redwood trees). The PEIR and MND found that the current salinity levels present in the recycled water are within a reasonable range in terms of suitability for irrigating trees, including Redwood trees, but that poor soils or poor drainage could lead to an accumulation of salts. (The PEIR identified soils within the project area as "good/fair" for recycled water irrigation). The project description in the MND includes an Adaptive Management Program (Program) that will be implemented as part of the project and adds further detail to the implementation strategies contained in the PEIR. The Program is comprised of steps and triggers that are summarized as follows: I. A site-specific baseline landscape conditions report will be completed for each site prior to connecting to the recycled water delivery system. Site characteristics will be recorded to determine baseline conditions of each site prior to recycled water application. 2. Monitoring of each site will occur each year for signs of tree decline on protected or street trees. A list of triggering criteria will be developed to identify signs of decline. 3. An extensive landscape study will be performed if a qualified professional determines it is necessary to do so to determine if observable decline is attributable to recycled water use. CMR: 255:09 Page 6 of 11 4. Best Management Practices (BMPs) are identified that will be implemented, if necessary, to address decline. These BMPs are a series of options that include site remediation choices and also include replacement of affected trees with more salt tolerant species or species better suited to the site. The Program is designed to address a complex issue and highlights many policy level questions related to appropriate uses of potable water, the changes that may be necessary to adapt to a water constrained world, and the policy decisions related to promoting a sustainable urban forest with emphasis on native species with higher recycled water tolerance. A key issue going forward will be planting trees and vegetation which are native to, or compatible with, the microclimates and soil conditions in the project area. Redwood trees, for example, are not native to the area and are both drought intolerant and typically require intensive management to attempt to maintain them in an environment they are not suited for. Therefore, the BMPs include the option of changing out non-natives over time. As the population increases in California, it appears likely that very high quality potable water supplies such as from the Hetch Hetchy regional water system will not be available for landscape irrigation at some point in the future. Although the mitigation measures described in the PEIR and the Program included in the MND fully address salinity concerns, potential recycled water users do have two additional options: First, the salinity strategies in the PEIR and the MND Program can and should be implemented ahead of recycled water application when baseline monitoring so indicates. Since the actual irrigation with recycled water will not occur for three years (and possibly longer), this time can and should be used to take preventative action where appropriate. Commenters raised the issue of not wanting to wait for signs of decline before acting. Since time is available, the envisioned baseline sampling can be conducted early on and used to make decisions on BMPs ahead of recycled water application where users believe such action is appropriate. Individual site owners are in the best position to make decisions related to the benefits and costs of maintaining onsite Redwood trees and similarly salt-sensitive species. Second, if, based on baseline or other data, users feel that the BMPs will not be sufficient in certain situations, they can request an exemption from the requirement to apply recycled water to Redwood trees or similarly salt-sensitive species. On April 28, 2008, Council adopted an ordinance to promote the use of recycled water (CMR 203:08, Ordinance No.5002) for irrigation, toilet and urinal flushing and trap priming. Section 16.12.050 of the Ordinance establishes an exemption process, as follows: "Requests for an exemption or adjustment may be made consistent with state law and shall be based on the finding by the Director of Public Works that the use of recycled water demonstrates an adverse effect to the applicant's landscaping installed prior to the effective date of the ordinance codified herein". The exemption process is an appropriate forum for property owners to establish that the record demonstrates the use of recycled water would harm Redwood trees or similarly salt-sensitive species at specific sites. The exemption process can be utilized to deal with the Redwood tree concern and the concern for similar species and landscaping. CMR: 255:09 Page 7 of 11 Lastly, staff anticipates that the RWQCP's efforts to reduce salinity levels in the recycled water will, in time, reduce the salinity level of the recycled water to a level comparable with the levels of other local groundwater sources (Attachment H). The RWQCP is working with its partner agencies to eliminate the infiltration of saline water wherever possible. Funding Application to the State Water Resources Control Board On February 17, 2009, President Obama signed into law the American Recovery and Reinvestment Act (ARRA) of 2009. Under the Clean Water SRF program, the SWRCB will receive approximately $280 million in additional funds. The bill language requires that states use at least 50 percent of the funding for additional subsidization, including principal forgiveness, negative interest loans and grants. There are no matching or cost-share requirements. Projects must be on a State priority list and must be ready to proceed to construction within 12 months of the date of enactment (February 17,2009). Since the project is already on the SRF project priority list, has a Final Facility Plan and is in the process of obtaining City Council approval of the environmental document, the project is in a small group of projects that are ready to apply for a SRF loan with the ARRA subsidy and meet the February 17,2010 construction deadline. The next step in the loan process is the submission of the following resolutions, which are part of the requirements ofthe SWRCB SRF loan process: 1. Capital Reserve Fund Resolution (Attachment B) The SRF program requires that the City establish a capital reserve fund for future rehabilitation of the project. Through the Capital Reserve Fund Resolution, Council agrees to utilize the existing Water Capital Reserve Fund for rehabilitation of the project in the future. 2. Reimbursement Resolution (Attachment C) The SRF program requires the City to advance funds to pay for certain tasks associated with the project, such as planning and design, which are eligible allowances and would be reimbursed by the SRF loan. Through the Reimbursement Resolution, Council will designate a maximum of $37 million in advance funding for expenditures, which shall be reimbursed by proceeds from the SRF for the construction of the project. 3. Dedicated Revenue Resolution (Attachment D) Section 603 of the Federal Clean Water Act Amendments requires each financing recipient to establish one or more dedicated sources of revenue for SRF assistance. The Dedicated Revenue Resolution dedicates the recycled water rates from customers in the plant's service area for the repayment of the SRF loan for the construction of the project. 4. Authority to Apply and Execute SRF Financial Agreement Resolution (Attachment E) On March 16, 2009, Council authorized the City Manager to apply for the SRF loan in an amount not to exceed $37 million for the design and construction of the project (CMR:162:09). Following this, the SWRCB informed staff that the Resolution to submit the CMR: 255:09 Page 8 ofll SRF Application could no longer be bifurcated from the Resolution to Execute the Agreement, as was previously done for the Mountain View Project. The current Resolution repeals the first Resolution (Resolution #8913, CMR: 162:09) and will authorize the City Manager or his designee to submit the application and, following Council approval of a funding strategy and final construction contract for the project, execute the SRF financial assistance agreement and any amendments with the SWRCB. The ARRA funds administered by the SWRCB represent a great opportunity to secure funds to proceed with the project. However, the tight timelines required to receive these funds present a challenge that will necessitate expedited action by staff and the Council. NEXT STEPS Council adoption of the Final MND and approval of these resolutions does not complete the SWRCB process. There are several remaining steps in the loan process and Council will be making decisions on the remaining steps before the SRF Financing Agreement can be secured. Staff is continuing the effort to secure a low interest SRF Financing Agreement with American Recovery and Reinvestment Act attributes that could significantly reduce project costs. This effort requires an expedited project schedule but preserves Council's discretion on various matters. The SWRCB will not execute any loan contract until the remaining steps are completed, and only after Council awards and executes a contract for the construction of the project. Staff is currently evaluating the economics of the project and developing the funding strategy for implementation of the project. Staff will develop a recommendation on whether to proceed with the project. Staffs recommendation will be discussed by the Utilities Advisory Commission (UAC) at its June 3rd meeting. Following this, staff will return to Council with a recommendation on the project in early July. If Council adopts the MND and approves the project, staff will submit the MND to the SWRCB for their review and inclusion in the SRF Application package. Anticipated Project Schedule Adoption of Mitigated Negative Declaration by Council Recommendation on Approval to Proceed with Project from UAC Council action on Approval to Proceed with Project Preliminary funding commitment from SWRCB Council Approval of Construction Contract RESOURCE IMPACT June 1,2009 June 3, 2009 July 6,2009 July 2009 Fall 2009 No new additional funds are associated with the approval of the MND or are required to submit the adopted resolutions to the SWRCB. Applying for SRF funds does not obligate the City to proceed with the project. The resource impact of proceeding with the project will be evaluated at the time that Council approval to proceed with the project is requested. CMR: 255:09 Page 9 of 11 POLICY IMPLICATIONS Continuing the exploration of expanded recycled water use in Palo Alto is consistent with Council policy. The Council has supported this goal through approval of the Water Integrated Resources Plan (WIRP) Guidelines in December 2003 [CMR:547:03], specifically, WIRP Guideline #3: Actively participate in development of cost-effective regional recycled water plans. Council's Sustainability Policy supports the development of recycled water, specifically in the Policy's statement to "reduce resource use and pollution in a cost-effective manner while striving to protect and enhance the quality of the air, water, land, and other natural resources." The City'S Comprehensive Plan contains Natural Environment Goal N-4: Water resources that are prudently managed to sustain plant and animal life, support urban activities and protect public health and safety. Specifically, Program N-26 addresses the use of recycled water: Implement incentives for the use of drought-tolerant landscaping and recycled water for landscape irrigation. ENVIRONMENTAL REVIEW The City of Palo Alto prepared a PEIR in 1995 to assess the environmental impacts associated with a regional recycled water program. The PEIR contained mitigation measures designed to reduce the regional recycled water program impacts to a less than significant level (Attachment G). The City's Recycled Water Project is within the scope of the Master Plan and the environmental effects of this expansion were examined, at a programmatic level, in the PEIR. To ensure that the project would not create new impacts not fully examined in the PEIR, the City'S Planning and Community Environment Department has prepared a Mitigated Negative Declaration (MND) for the project. The MND is a tiered document, within the scope of the PEIR and addresses project-specific impacts for the Palo Alto project. The NIND does not identify significant impacts associated with project activities that were not previously discussed in the PEIR. The MND does include mitigation measures in the areas of Biology and Transportation/Traffic that reduce any potential impacts to a less than significant level. Some comments were submitted on the issue of salinity impacts on redwood trees and other vegetation. This issue was adequately addressed in the PEIR, which included mitigation measures to address such impacts. Consistent with CEQA Guidelines Section 15168, subdivision (c)(3), the City incorporated these mitigation measures (in the form of the Adaptive Management Program described in the Mitigated Negative Declaration) into the project. Because this potential impact was already addressed and mitigated as part of the PEIR, there was no need for the Mitigated Negative Declaration to further analyze this issue or provide additional mitigation for it. CMR: 255:09 Page 10 of 11 The State Water Resources Control Board (SWRCB) requires recipients of grants and loans to formally approve project related environmental documents. A Resolution adopting the MND for the recycled water project (Attachment A) will be part of the Application to the SWRCB for the SRF loan. ATTACHMENTS A. Resolution Adopting a Mitigated Negative Declaration for the City of Palo Alto Recycled Water Project Pursuant to the California Environmental Quality Act B. Resolution to establish a water capital reserve fund in accordance with the State Water Resources Control Board's requirement of the State Revolving Fund Program for the design and construction of the Palo Alto Recycled Water Pipeline C. Resolution designating certain Palo Alto Recycled Water Pipeline Project expenditures to be reimbursed by proceeds from the State Revolving Fund D. Resolution establishing one or more dedicated sources of revenue for repayment of funding pursuant to the Federal Clean Water Act Amendments Resolution authorizing the City Manager to apply for and execute a State Revolving Fund Financial Assistance Agreement in an amount not to exceed $37 million from the State Water Resources Control Board for the design and construction of the Palo Alto Recycled Water Pipeline Project F. Final MND with Response to Comments and Mitigation Monitoring and Reporting Plan G. Ordinance No. 5002 -CMR 203:08 Adoption of an Ordinance to Promote the Use of Recycled Water H. Chart of RWQCP Recycled Water Annual Average Total Dissolved Solids 1. CMR 217:95 -Wastewater Reclamation Program-Findings and Recommendations J. Table 1-1 Impact and Mitigation Summary from 1995 Program EIR PREPARED BY: REVIEWED BY: DEPARTMENT APPROVAL: CITY MANAGER APPROVAL: CMR: 255:09 NICOLAS PROCOS ~senior Resource Planner ANE O. RA TCHYE ... Utilities Assistant Director, Resource Management VALE~ Director of Utilities ~~\N~4~ CURTIS WILLIAMS Director of Planning and Community Environment Page 11 ofl1 NOT YET APPROVED Resolution No. ---Resolution of the Council of the City of Palo Alto Adopting a Mitigated Negative Declaration for the City of Palo Alto Recycled Water Project Pursuant to the California Environmental Quality Act ATT ACHMENT A WHEREAS, Palo Alto completed a Water Reclamation Master Plan for the Palo Alto Regional Water Quality Control Plant (RWQCP) in 1992. The Master Plan evaluated the development of a regional water reuse system that could ultimately provide service to the entire RWQCP service area. Benefits of the program include reduced effluent discharge from the RWQCP into San Francisco Bay, reduced reliance on potable water deliveries from the Hetch Hetchy system, and a drought proof supply of water; and WHEREAS, in 1995, the Council adopted the Final Program Environmental Impact Report (PEIR) for the Master Plan pursuant to the California Environmental Quality Act, Public Resources Code section 21000 et seq. (CEQA) and the State CEQA Guidelines, California Code of Regulations, Title 14, section 15000 et seq.; and WHEREAS, the City circulated the PEIR for public comment from August 12, 1994 through September 26, 1994. A public hearing was held on December 14, 1994 before the Planning Commission. The City approved the PEIR on April 24, 1995 and filed a Notice of Determination on May 3, 1995 (State Clearinghouse # 1995100277); and WHEREAS, the City of Palo Alto Recycled Water Project (Project) is within the scope of the Master Plan and the environmental effects of this expansion were examined, at a programmatic level, in the PEIR. The Project would involve the construction of approximately 5 miles of 12 to 18 inch pipe to deliver approximately 900 acre-feet per year of recycled water for landscape irrigation within the City of Palo Alto and to the Stanford Research Park; and WHEREAS, to ensure that the Project would not create new effects that were not fully examined in the PErR, the City as the lead agency for the Project has prepared a Mitigated Negative Declaration for the Project pursuant to the California Environmental Quality Act, Public Resources Code section 21000 et seq. (CEQA) and the State CEQA Guidelines, California Code of Regulations, Title 14, section 15000 et seq. The Draft Mitigated Negative Declaration was released for a 30-day public comment period on March 19, 2009. A public meeting to hear public input on the Draft Mitigated Negative Declaration was held on April 6, 2009; and WHEREAS, while the PEIR was prepared to address the impacts associated with a regional recycled water system, the Mitigated Negative Declaration is a tiered document from the PEIR that addresses project specific impacts of the Palo Alto Recycled Water project; and 1 090528 syn 6050762 NOT YET APPROVED WHEREAS, the Mitigated Negative Declaration, including the project description, environmental checklist fonn, mitigation summary and monitoring and reporting plan, and appendices is attached as Exhibit A to this Resolution and by this reference incorporated herein; and WHEREAS, the City Council has reviewed and considered the infonnation contained in the Mitigated Negative Declaration, including comments received and the responses to those comments; and WHEREAS, the Mitigated Negative Declaration was prepared by the City and the city environmental consultants and reflects their independent judgment and analysis. There is no substantial evidence on the basis of the record as a whole that the Project will have a significant effect on the environment; and NOW, THEREFORE, the Council of the City of Palo Alto does RESOLVE as follows: SECTION 1. Mitigation Monitoring and Reporting Plan. The Mitigation Summary and Monitoring and Reporting Plan included in the Mitigated Negative Declaration attached as Exhibit A is hereby approved and adopted. SECTION 2. Findings. The City Council finds that the Project described in the MND is within the scope of the program approved in the PEIR, and that the PEIR adequately describes the activity for the purposes of CEQA. Some comments were submitted on the issue of the impacts of salinity in the recycled water on redwood trees and other vegetation. The Council finds that issue was adequately addressed in the PEIR, which included mitigation measures to address such impacts. Consistent with CEQA Guidelines section 15168, subdivision (c)(3), the City incorporated these mitigation measures (in the fonn of the Adaptive Management Program described in the Mitigated Negative Declaration) into the Project. Because this potential impact was already addressed and mitigated as part of the PEIR, the Council further finds that there was no need for the Mitigated Negative Declaration to further analyze this issue or provide additional mitigation for it. SECTION 3. Adoption and Project ApprovaL The City Council finds that the Mitigated Negative Declaration has been completed in compliance with CEQA and adopts and approves it. Consistent with CEQA Guidelines section 15168, subdivisions (c)(4) and (d)(3), the Mitigated Negative Declaration documents how the Project will not have any site-specific or other significant, unmitigated environmental impacts which were not already adequately described and addressed in the PEIR. The City Council hereby approves the Project, including the recommended project alignment, as described in the Mitigated Negative Declaration. The City Council has reviewed and considered the infonnation contained in the Mitigated Negative Declaration, staff reports, oral and written testimony given at public meetings on the proposed Project and all other matters deemed material and relevant before considering the Project for approval. 2 090528 syn 6050762 NOT YET APPROVED SECTION 4. No Recirculation Required. The City Council finds that no new significant information has been received that requires recirculation of the Mitigated Negative Declaration. INTRODUCED AND PASSED: AYES: NOES: ABSENT: ABSTENTIONS: ATTEST: City Clerk Mayor APPROVED AS TO FORM: APPROVED: Deputy City Attorney City Manager Director of Utilities 3 090528 syn 6050762 NOT YET APPROVED Resolution No. --- Resolution of the Council of the City of Palo Alto Establishing a Water Capital Reserve Fund in Accordance With the State Water Resources Control Board's Requirements for the State Revolving Fund Program ATTACHMENT 8 WHEREAS, on June 1, 2009 the CITY OF PALO ALTO (the "Agency") will consider adoption of a resolution authorizing the City Manager to apply for a State Revolving Fund (SRF) Financial Assistance Agreement to fund all or a portion of the cost of Palo Alto Recycled Water Pipeline Project (Project); and WHEREAS, the State Water Resources Control Board requires, as a condition of approval of the financial assistance, the establishment of a Capital Reserve Fund for future expansion, major repair or replacement costs for the Project: NOW, THEREFORE, the Council of the City of Palo Alto does RESOLVE as follows: SECTION 1. A dedicated Water Capital Reserve Fund exists, and SECTION 2. Said Water Capital Reserve Fund shall be administered, by the Agency, as required by the "Policy For Implementing The State Revolving Fund For Construction of Wastewater Treatment Facilities" adopted by the State Water Resources Control Board on February 16, 1995 and last amended on September 22,2005. SECTION 3. In 1995, the Council adopted a Final Program Environmental Impact Report (PEIR) for the Water Reclamation Master Plan for the Palo Alto Regional Water Quality Control Plant (RWQCP) pursuant to the California Environmental Quality Act, Public Resources Code section 21000 et seq. (CEQA) and the State CEQA Guidelines, California Code of Regulations, Title 14, section 15000 et seq. A Notice of Determination was filed on May 3, 1995. The City of Palo Alto Recycled Water Project (Project) is within the scope of the Master Plan and the II II II 1 090528 syn 6050764 NOT YET APPROVED environmental effects of this Project were examined, at a programmatic level, in the PEIR. A Mitigated Negative Declaration has been completed pursuant to CEQA to address project- specific impacts of the Project and will be considered for adoption by the City Council on June 1, 2009. INTRODUCED AND PASSED: AYES: NOES: ABSENT: ABSTENTIONS: ATTEST: City Clerk APPROVED AS TO FORM: Deputy City Attorney 090528 syn 6050764 Mayor APPROVED: City Manager Director of Utilities Director of Administrative Services 2 NOT YET APPROVED Resolution No. --- Resolution of the Council of the City of Palo Alto Designating Certain Palo Alto Recycled Water Pipeline Project Expenditures to be Reimbursed By Proceeds from State Revolving Fund ATTACHMENT C WHEREAS, the CITY OF PALO ALTO (the "Agency") desires to finance the costs of constructing and/or reconstructing certain public facilities and improvements relating to its water and wastewater system including a recycled water pipeline, certain treatment facilities, and other infrastructure (the "Project"); WHEREAS, the Project would involve the construction of approximately 5 miles of 12 to 18 inch pipe to deliver approximately 900 acre-feet per year of recycled water for landscape irrigation within the City of Palo Alto and to the Stanford Research Park. The Project is an expansion of the existing Regional Water Quality Control Plant Water Reuse Program; and WHEREAS, the Agency intends to finance the construction and/or reconstruction of the Project or portions of the Project with moneys ("Project Funds") provided by the State of California, acting by and through the State Water Resources Control Board (the "Water Board"); WHEREAS, the Water Board may fund the Project Funds with proceeds from the sale of obligations the interest upon which is excluded from gross income for federal income tax purposes (the "Obligations"); WHEREAS, prior to either the issuance of the Obligations or the approval by the Water Board of the Project Funds the Agency desires to incur certain capital expenditures (the "Expenditures") with respect to the Project from available moneys of the Agency; WHEREAS, the Agency has determined that those moneys to be advanced on and after the date hereof to pay the Expenditures are available only for a temporary period and it is necessary to reimburse the Agency for the Expenditures from the proceeds of the Obligations; NOW, THEREFORE, the Council of the City of Palo Alto does RESOLVE as follows: SECTION 1. The Agency hereby states its intention and reasonably expects to reimburse Expenditures paid prior to the issuance of the Obligations or the approval by the Water Board of the Project Funds. SECTION 2. The reasonably expected maximum principal amount of the Project Funds is $37,000,000. 1 090528 syn 6050763 NOT YET APPROVED SECTION 3. This resolution is being adopted no later than 60 days after the date on which the Agency will expend moneys for the portion of the Project costs to be reimbursed with Project Funds. SECTION 4. Each Expenditure by the Agency will be of a type properly chargeable to a capital account under general federal income tax principles. SECTION 5. To the best of our knowledge, this Agency is not aware of the previous adoption of official intents by the Agency that have been made as a matter of course for the purpose of reimbursing expenditures and for which tax-exempt obligations have not been issued. SECTION 6. This resolution is adopted as official intent of the Agency in order to comply with Treasury Regulation §1.150-2 and any other regulations of the Internal Revenue Service relating to the qualification for reimbursement of Project costs. SECTION 7. In 1995, the Council adopted a Final Program Environmental Impact Report (PEIR) for the Water Reclamation Master Plan for the Palo Alto Regional Water Quality Control Plant (RWQCP) pursuant to the California Environmental Quality Act, Public Resources Code section 21000 et seq. (CEQ A) and the State CEQA Guidelines, California Code of Regulations, Title 14, section 15000 et seq. A Notice of Determination was filed on May 3, 1995. The City of Palo Alto Recycled Water Project (Project) is within the scope of the Master Plan and the environmental effects of this Project were examined, at a programmatic level, in the PEIR. A Mitigated Negative Declaration has been completed pursuant to CEQA to address project-specific impacts of the Project and will be considered for adoption by the City Council on June 1,2009. II II II II II II II II II II II 2 070130 syn 6050763 NOT YET APPROVED SECTION 8. All the recitals in this resolution are true and correct and this Agency so finds, determines and represents. INTRODUCED AND PASSED: AYES: NOES: ABSENT: ABSTENTIONS: ATTEST: City Clerk APPROVED AS TO FORM: Deputy City Attorney 070130 syn 6050763 Mayor APPROVED: City Manager Director of Utilities Director of Administrative Services 3 NOT YET APPROVED Resolution No. --- Resolution of the Council of the City of Palo Alto Establishing One or More Dedicated Sources of Revenue for Repayment of Funding Pursuant to The Federal Clean Water Act Amendments ATTACHMENT D WHEREAS, the CITY OF PALO ALTO (the "Agency") desires to finance the costs of constructing and/or reconstructing certain public facilities and improvements relating to its water and wastewater system, including a recycled water pipeline, certain treatment facilities and other infrastructure (the "Project"); and WHEREAS, the Project would involve the construction of approximately 5 miles of 12 to 18 inch pipe to deliver approximately 900 acre-feet per year of recycled water for landscape irrigation within the City of Palo Alto and to the Stanford Research Park. The Project is an expansion of the existing Regional Water Quality Control Plant Water Reuse Program; and WHEREAS, the Agency intends to finance the construction and/or reconstruction of the Project or portions of the Project with moneys ("Project Funds") provided by the State of California, acting by and through the State Water Resources Control Board (the "Water Boards"); and WHEREAS, Section 603(d)(l)(C) of the Federal Clean Water Act Amendments require each financing recipient to establish one or more dedicated sources of revenue for State Revolving fund (SRF) financial assistance; and WHEREAS, Revenue will be considered dedicated when the municipality passes a resolution committing a source of funds for repayment; and NOW, THEREFORE, the Council of the City of Palo Alto does RESOLVE as follows: SECTION 1. The City of Palo Alto hereby dedicates the following source of revenue (City of Palo Alto Water Utilities Operating Fund, specifically recycled water rates to be collected from recycled water customers in the Regional Water Quality Control Plant's service area) to repayment of any and all State Revolving Fund financing for the Project. This dedicated source of revenue shall remain in effect until such financing is fully discharged unless modification or change of such dedication is approved in writing by the State Water Resources Control Board. SECTION 2. In 1995, the Council adopted a Final Program Environmental Impact Report (PEIR) for the Water Reclamation Master Plan for the Palo Alto Regional Water Quality Control Plant (R WQCP) pursuant to the California Environmental Quality Act, Public Resources 090528 syn 6050761 NOT YET APPROVED Code section 21000 et seq. (CEQA) and the State CEQA Guidelines, California Code of Regulations, Title 14, section 15000 et seq. A Notice of Determination was filed on May 3, 1995. The City of Palo Alto Recycled Water Project (Project) is within the scope of the Master Plan and the environmental effects of this Project were examined, at a programmatic level, in the PEIR. A Mitigated Negative Declaration has been completed pursuant to CEQA to address project-specific impacts of the Project and will be considered for adoption by the City Council on June 1,2009. INTRODUCED AND PASSED: AYES: NOES: ABSENT: ABSTENTIONS: ATTEST: City Clerk APPROVED AS TO FORM: Deputy City Attorney 090528 syn 6050761 Mayor APPROVED: City Manager Director of Utilities Director of Administrative Services 2 NOT YET APPROVED Resolution No. --- Resolution of the Council of the City of Palo Alto Repealing Resolution No. 8913 and Authorizing the City Manager to Sign and File a Financial Assistance Application and Execute a State Revolving Fund Financial Assistance Agreement in An Amount Not to Exceed Thirty-Seven Million Dollars From the State Water Resources Control Board for the Design and Construction of the Palo Alto Recycled Water Project ATTACHMENT E WHEREAS, the Palo Alto Regional Water Quality Control Plant (PARWQCP) operates a recycled water facility to treat wastewater prior to discharge; and WHEREAS, the City of Palo Alto is investigating expansion of the existing recycled water distribution system to serve customers within the City of Palo Alto; and WHEREAS, the State Water Resources Control Board provides low-interest financial assistance funding through the Clean Water State Revolving Fund Program for construction of publicly-owned wastewater treatment facilities, local sewers, sewer interceptors, water reclamation facilities, as well as expanded use projects such as implementation of nonpoint source (NPS) projects or programs, development and implementation of estuary Comprehensive Conservation and Management Plans, and storm water treatment; and WHEREAS, the State Water Resources Control Board presently has financial assistance funding available in the Clean Water State Revolving Fund (SRF) program to provide low-interest funding for construction to assist in funding the costs of the Palo Alto Recycled Water Pipeline project (the Project). WHEREAS, the Project is currently on the SRF Priority list, has a Final Facility Plan and staff will be seeking Council approval of the Draft Mitigated Negative Declaration in June 2009; and WHEREAS, the Project is in a position to apply for SRF financial assistance with American Recovery and Reinvestment Act attributes that could substantially reduce overall project costs; and WHEREAS, the Project may qualify for principal forgiveness so that the cost to the City to design and construct the project would be zero, and the SRF financial assistance would function as a grant; WHEREAS, the Council of the City of Palo Alto authorized staff's submission of an application for the SRF financial assistance on March 16, 2009, via Resolution No. 8319. 1 090528 syn 6050765 NOT YET APPROVED WHEREAS, City of Palo Alto staff has reviewed the application for State Revolving Fund financial assistance funding and other supporting information for the Project and has determined that the Project complies with the Water Resource Fund Guidelines; and WHEREAS, the State Water Resource Control Board has requested a modification to Resolution No. 8913 to incorporate the City Manager's ability to negotiate and execute a financing agreement and to certify disbursements on the City's behalf; and NOW, THEREFORE, the Council of the City of Palo Alto does RESOLVE as follows: SECTION 1. Resolution No. 8913 is hereby repealed. SECTION 2. The Council hereby authorizes and directs the City Manager or his designee to sign and file, for and on behalf of the City of Palo Alto, a financial assistance application with the State Water Resources Control Board in an amount not to exceed thirty- seven million dollars ($37,000,000.00) for the design and construction of the Project. SECTION 3. The City Manager or his designee is hereby authorized to negotiate and, following Council approval of a funding strategy and final construction contract for the Project, execute a financial assistance agreement and any amendments thereto, for and on behalf of the City of Palo Alto, from the State Water Resources Control Board. SECTION 4. The City of Palo Alto hereby agrees and authorizes the City Manager or his designee to certify that the City has and will comply with all applicable state and federal statutory and regulatory requirements related to any federal and state financial assistance received. SECTION 5. The City of Palo Alto hereby authorizes and directs the City Manager or his designee to negotiate and execute a financing agreement with the State Water Board and any amendments or change orders thereto, and to certify disbursements on behalf of the City of Palo Alto. SECTION 4. In 1995, the Council adopted a Final Program Environmental Impact Report (PEIR) for the Water Reclamation Master Plan for the Palo Alto Regional Water Quality Control Plant (RWQCP) pursuant to the California Environmental Quality Act, Public Resources Code section 21000 et seq. (CEQA) and the State CEQA Guidelines, California Code of Regulations, Title 14, section 15000 et seq. A Notice of Determination was filed on May 3, 1995. The City of Palo Alto Recycled Water Project (Project) is within the scope of the Master Plan and the 2 090528 syn 6050765 NOT YET APPROVED environmental effects of this Project were examined, at a programmatic level, in the PEIR. A Mitigated Negative Declaration has been completed pursuant to CEQA to address project- specific impacts of the Project and will be considered for adoption by the City Council on June 1, 2009. INTRODUCED AND PASSED: AYES: NOES: ABSENT: ABSTENTIONS: ATTEST: City Clerk APPROVED AS TO FORM: Deputy City Attorney 090528 syn 6050765 3 Mayor APPROVED: City Manager Director of Utilities Director of Administrative Services City of Palo Alto Recycled Water Project Response to Comments Document RMC IMlter am:Ehvironmml May 2009 ATT ACHMENT F 1. I ntrod uction 1.1 Purpose of the Final Initial Study/Mitigated Negative Declaration This report has been prepared to accompany the Public Draft ISIMND for the Palo Alto Recycled Water Project. The Public Draft IS/MND identified the environmental consequences associated with construction and operation of the proposed project, and recommended mitigation measures to reduce potentially significant impacts. This document (Response to Comments) responds to the comments on the Public Draft ISIMND and makes revisions to the Public Draft ISIMND, as necessary, in response to these comments. Together with the Public Draft ISIMND, this document constitutes the Final ISIMND for the proposed project. A Mitigation Monitoring and Reporting Program (MMRP) has been prepared for the proposed project and is included in this document as AppendixA. The Final ISIMND consists of the following: (a) The Public Draft ISIMND; and (b) Response to Comments document containing the following: • Comments received on the Public Draft ISIMND. • A list of persons, organizations, and public agencies commenting on the Public Draft ISIMND. • The response of the lead agency to significant environmental points raised in the review and consultation process. • Any other information added by the lead agency. 1.2 Environmental Review Process The Palo Alto Regional Water Quality Control Plant (RWQCP) and its member agencies prepared the Water Reclamation (now referred to as Recycled Water) Master Plan (Master Plan) for the Palo Alto RWQCP in 1992 and the accompanying Final Program Environmental Impact Report (EIR) in ] 995 (CH2MHill, 1995). The Master Plan included a phased approach to the expansion of treatment, distribution, storage, and use of recycled water and evaluated, at a program-level, development of a regional water reuse system that could ultimately provide service to the entire RWQCP service area including the cities of Palo Alto, Mountain View, Los Altos, East Palo Alto, Los Altos Hills, part of Menlo Park, as well as Stanford University. The Master Plan Program EIR addressed the environmental effects of the overall Water Reuse Program. The Master Plan Program EIR is a tiering document for all subsequent phases of the project, and provided analysis of the issues common to all of the phases. Tiering is the coverage of general matters in broader EIRs with subsequent narrower environmental document incorporating by reference the general discussions and concentrating solely on the issues specific to follow-up environmental document. The Master Plan Program EIR was certified and the project was approved on April 24, ] 995. On March 19, 2009, the City of Palo Alto (lead agency) released the Palo Alto Recycled Water Project Public Draft ISIMND for public review (State Clearinghouse No. 2009302065). The Public Draft ISIMND evaluates project-specific impacts of the Palo Alto Recycled Water Project, Palo Alto Recycled Water Project Page 1 Response to Comments Document which is the next phase of the Recycled Water Master Plan. The public review and comment period on the Public Draft ISIMND began on March 19,2009 and closed on April 17,2009. The City of Palo Alto City Council is scheduled to consider adopting the Final ISIMND (a finding that the ISIMND complies with the requirements of CEQA) at a regularly scheduled Council meeting on June 1,2009. Following the Final IS/MND adoption, the City Council may proceed with consideration of project approval actions. In accordance with CEQA Guidelines Section 15072, the City provided a Notice of Intent notifying the public of the publication of the Public Draft ISIMND. Additional notification was provided through the publication of a notice in the Palo Alto Weekly on March 13, 2009. During the 30-day public comment period, a public comment meeting was held on April 6, 2009 to discuss the proposed project and receive comments on the Public Draft ISIMND. The date, time, and place of the meeting were initially identified in the publication in the Palo Alto Weekly on March 13, 2009. A public meeting sign-in sheet was passed around at the meeting and is included in this document as Appendix B. One person attended the meeting. No comments were made at the meeting. 1.3 Report Organization Chapter 2 of this Response to Comments on the Public Draft ISIMND document contains copies of comment letters received during the comment period followed by the City's responses to those comments. Each comment is numerically coded in the margin of the comment letter, based on the number assigned for each letter (see Table 1 below) and the order of the comments. For example, the first comment in the letter from the California Department of Transportation is 1-1. Revisions to the Public Draft ISIMND are made as a staff-initiated change or in response to commenters. Text revisions are formatted in revision fashion: strikeouts indicate removed text and underlines indicate new text. Table 1-2 lists all persons and organizations that submitted comments on the Public Draft ISIMND during the comment period, the date of the letters, and the numbers used to identify each letter. Each communication is identified below by number, comment author and date. Table 1: Comment Letters Number I Comment Author, Title and Affiliation Comment Letter Lisa Carboni, District Branch Chief, Local Government Intergovernmental Review,California Department of Transportation .... 2 Patrick Lee, Project Manager, Brownfield and Environmental Restoration ..E~()gral11.L.C::.ClHf2mi~. D~PI'.!'!rn~'?l}tgLT9~ig.§.ubs1an~l).g()E1trol 3 i Catherine Martineau, Executive Director, CANOPY ~;;'H=m~",~"~'~~~ __ W"~,whW,,,,"H»0»,"m""'''' """', "'''"",,,,',<,,,,,,, . " ___ .'.'.'''''''' _ .. . '""' . _ m ¥ _ • 4 I Usha Chatwani, Associate Civil Engineer, Community Projects Review . Unit, Santa Clara Valley Water District 5 James Hockenberry, Environmental Scientist, State Water Resources Control Board Division of Financial Assistance .. . 6 . Roy Molseed, Senior Environmental Planner, Santa Clara Valley T ransportati()n Authority 7 William 1. Phillips, Senior Associate Vice President, and Jim Inglis, Director of Desi n & Construction, Stanford Universit Real Estate Office. Date April 8, 2009 April 14, 2009 ApriIJ~L~QQ9 April 15, 2009 April 16, 2009 April 16, 2009 April 17, 2009 Palo Alto Recycled Water Project Response to Comments Document 2. Individual Comments and Responses Palo Alto Recycled Water Project Page 3 Response to Comments Document U.£JC ftA.ll\,.LCIi'~.l V.I' 1. J:V\.1"l,::,rVK18 1.1.Vl''II 111 GRAND AVENUE P. O. BOX 23660 OAKLAND, CA 94623-0660 PHONE (510) 622-5491 FAX (510) 286-5559 TTY 711 April 8, 2009 ! J."; 0;;;",,;(,,7 .• ' .. ,., , APR 1 0 2009 Ms. Clare Campbell City of Palo Alto 250 Hamilton A venue Palo Alto, CA 94301 Dear Ms. Campbell: U(;t)(,., "c , , . GOrnn-Rlr\" .: 1[i1~; and ,ironment Flex your power! Be energy efficient! SCL-082-24.04 SCL082418 SCH2009032065 Palo Alto Recycled Water Project. Mitigated Negative Declaration (MND) Thank you for including the California Department of Transportation (Department) in the environmental review process for the proposed project. We have reviewed the MND for the proposed Palo Alto Recycled Water Project and have the following comments to offer. ; As kad:agency, the City of Palo Alto, is responsible for.al;Lprojectmitigation, including any needed improvements to state highways. The project's fair sJ;are contribution, financing, .. scheduling, implementation responsibilitIes 'and lead agency monitoring should be fully discussed forall proposed mitigation measures and the project's traffic mitigation fees should be specifically identified in the environmental document. Any required roadway improvements should be completed prior to issuance of project occupancy permits. An encroachment permit is required when the project involves work in the State Right of Way (ROW). Therefore, we strongly recommend that the lead agency ensure resolution of the Department's concerns prior to submittal of the encroachment permit application. Further comments will be provided during the encroachment pernlit process·as required; see the end of this letter for more infonnation regarding the encroachment pennit process. Cultural Resources The cultural resource study satisfies the Department's cultural resource legal requirements. Although there is no known site within State ROW for this project, should ground-disturbing activities take place within State ROWand there is an inadvertent archaeological or burial discovery, all construction within 50 feet of the find shall cease in compliance with CEQA, PRC 50:245, and D.epartment Standllfd Environmental Reference (SER} Chapter 2 (at http://ser.qot.ca.gov,). The Departmypt's CulturalR~source St.udies, Office, District 4; shall be inmi~c.iiately contact~d at (51O)286 .. 56~8.A staff arcQlJ,eolO,gist, will evaluate the finds within one business day,after contact. . . "Caltrans improves mobility across Califomia" ---. --------r---- April 7, 2009 Page 2 Permits Transportation Permit -Project work that requires movement of oversized or excessive load vehicles on State roadways, such as State Route (SR) 82 and US 101 requires a transportation permit that is issued by the Department. To apply, a completed transportation permit application with the determined specific route(s) for the shipper to follow from origin to destination must be submitted to the address below. Office of Transportation Permits, California DOT Headquarters P.O. Box 942874 Sacramento, CA 94274-0001 See the following website link for more information: http://www.dot.ca.gov/hq/traffops/permits/. Encroachment Permits Additionally, 'any work that encroaches onto the State ROW requires an encroachment permit that is issued by the Department. To apply, a completed encroachment permit application, environmental documentation, and five (5) sets of plans clearly indicating State ROW must be submitted to the address below. Traffic-related mitigation measures' will be incorporated into the construction plans during the encroachment permit process. Office'ofPermits California DOT, District 4 P.O. Box 23660 Oakland, CA 94623-0660 See the website link below for more information: http://www.dot.ca.gov/hq/traffops/developserv/pennits/ Should you require further information or have any questions regarding this letter, please call Jose L. Olveda of my staff at (510) 286-5535. I!:'&wu~ hv LISA CARBONI District Branch Chief Local Development -Intergovernmental Review c. Scott Morgan (State Clearinghouse) "Caltrans improves mobility across California" Comment Letter 1 -California Department of Transportation (Caltrans) Response to Comment 1-1 The City acknowledges its responsibility for all project mitigation. Potential impacts and mitigation measures related to traffic that may apply to the Caltrans right-of-way are discussed in the Transportation and Traffic Section on pages 86 to 92 of the Public Draft ISIMND. In accordance with CEQA Guidelines Section 15097, a Mitigation Monitoring and Reporting Program has been prepared and is a condition of approval for a project. Pursuant to CEQA, implementation responsibilities and lead agency monitoring are discussed in the Mitigation Monitoring and Reporting Program that has been prepared for the proposed project. As stated on page 25 of the Public Draft ISIMND, a Caltrans encroachment permit will be obtained prior to project construction. The City will comply with all requirements of the encroachment permit process and will work with Caltrans prior to the submittal of the permit to address any Caltrans concerns. As discussed on page 24 of the Public Draft ISIMND, one of the City's environmental commitments is to prepare a Traffic Control Plan as part of the project. The development of this Plan would provide the opportunity for the City to work with Caltrans directly regarding the traffic control measures that would be necessary within Cal trans right-of- way, thus ensuring that the Department's concerns would be addressed. All relevant permits will be obtained prior to project construction. Response to Comment 1-2 Environmental commitments integrated into the Project to protect Cultural Resources are discussed on page 20 of the Public Draft ISIMND. The Public Draft ISIMND states that "in accordance with CEQA Section 15064.5, if cultural resources are encountered during Project- related excavations, construction shall be halted or diverted to allow an archaeologist an opportunity to assess the resource." This is measure is consistent with the Caltrans measure. Refer to Response to Comment 5-3 for the revised first paragraph under Protection of Cultural Resources (on page 20 of the Public Draft ISIMND), which clarifies potential action taken should cultural resources be encountered during construction ofthe proposed project. Response to Comment 1-3 Refer to Response to Comment 1-1 above. Potential permits required for the proposed project are listed on page 25 of the Public Draft IS/MND. The City would obtain a Transportation Permit if the Project would require movement of oversized or excessive load vehicles on State roadways. In response to this comment, the Caltrans Transportation Permit has been added to the list of potential permits required for the proposed project on page 25. The fifth bullet on page 25 of the Public Draft ISIMND is revised as follows: • Caltrans Encroachment Permit and Transportation Permit; Palo Alto Recycled Water Project Page 4 Response to Comments Document " I ..:~ --.. I e Department of Toxic Substances Control Linda S, Adams Secretary for Environmental Protection April 14,2009 Ms. Clare Campbell Maziar Movas. saghi, Acting Director " le,.l ~ . 700 Heinz Avenue Race\ V Wschwarzenegger Berkeley, California 94710-2721"' . Governor A~R 15'1.009 i o~ Planning Departme~tv Env,ronment &commuml Palo Alto Department Planning and Community Environment 250 Hamilton Avenue Palo Alto, California 94301 Dear Ms. Campbell: Thank you for the opportunity to comment on the Initial Study IMitigated Negative Declaration for the City of Palo Alto Recycled Water Project (SCH # 2009032065). As you may be aware, the California Department of Toxic Substances Control (DTSC) oversees the cleanup of sites where hazardous substances have been released pursuant to the California Health and Safety Code, Division 20, Chapter 6.8. As a potential Responsible Agency, DTSC is submitting comments to ensure that the environmental documentation prepared for this project to address the California· Environmental Quality Act (CEQA) adequately addresses any remediation which may· be required to address any hazardous substances release. The proposed project consists of installation of a recycled water pipeline, a booster station and a pump station at the Regional Water Quality Control Plant (RWQCP) for the City of Palo and represents the next increment of the RWQCP's ongoing expansion of its regional·recycled water system. The project would involve the c6nstruction of approximately five miles of 12 to 18-inch recycled water pipelines. Soil excavation is expected. DTSC recommends that the historical uses of the area where construction activities will occur be discussed in the Initial Study IMitigated Negative Declaration. If the historical use of the area may have caused releases of hazardous substances, DTSC strongly. recommends that soil sampling be conducted. If sampling indicates that release of hazardous substances has occurred; impacts associated with construction activities should be addressed in the Initial StudylMitigated Negative Declaration. If the construction activities include the need for excavation of contaminated soil, the Initial Study IMitigated Negative Declaration should include: (1) an assessment of air impacts 'and health impacts associated with the excavation activities; (2} identification of any applicable local standards which may be exceeded by the excavation activities, * Printed on Recycled Paper I Ms. Clare Campbell April 14, 2009 Page Two including dust levels and noise; (3) transportation impacts from the removal or remedial activities; and (4) risk of upset should there be an accident at the Site. . Please contact me at (510) 540-3847 if you have any questions. Thank you in advance for your cooperation in this matter. Sincerely. Patrick Lee Project Manager Brownfield and Environmental Restoration Program Berkeley Office cc: Governor's Office of Planning, and Research State Clearinghouse . P. O. Box 3044 Sacramento. California 95812-3044 Guenther Moskat CSQA Tracking Center Department of Toxic Substances Control P.O. Box 806 . Sacramento, California 95812~0806 Comment Letter 2 -California Department of Toxic Substances Control Response to Comment 2-1 As discussed on page 67 of the Public Draft ISIMND, a search was conducted of the Department of Toxic Substances Control (DTSC) list of hazardous materials sites compiled pursuant to Government Code Section 65962.5, including Federal Superfund Sites National Priorities List (NPL), State Response Sites, Voluntary Cleanup Sites, and School Cleanup Sites. Results of this search are provided in Appendix E of the Public Draft ISIMND and include the name, type, status, and location of all sites located in the vicinity of the proposed alignment and pump stations. The pipeline would be constructed within roadways and would not cross any sites on the DTSC list of hazardous materials. As discussed on page 67 of the Public Draft ISIMND, the proposed project would not create a significant hazard to the public or the environment beyond the existing impacts of the hazardous materials sites and thus impacts are less than significant. The Public Draft ISIMND has adequately addressed this issue and has disclosed the results of the search in Appendix E. In addition, the City has included environmental commitments for the proper disposal of contaminated soil and/or groundwater and preparation and implementation of the Health and Safety and Hazardous Materials Management and Spill Prevention and Control Plans as part of the proposed project. These measures are discussed on pages 20 and 21 of the Public Draft ISIMND. In addition, Best Management Practices for construction/post-construction activities to control and minimize the potential contribution of pollutants to storm water runoff from these areas have been incorporated into the proposed project and are discussed on pages 21 and 22 of the Public Draft ISIMND. Palo Alto Recycled Water Project Page 5 Response to Comments Document Staff Catherine Martineau Executive Director Sharon Kelly Program Director Anwyn Hurxthal Development Mgr. Board of Directors Susan Rosenberg Chair Marty Deggeller Vice-Chair James Cook Treasurer Roy C. Leggitt, III Secretary Matthew Bahs Faye Brown Urban K. Cummings Susan Ellis Dave Muffly Brooks Nelson Forest Preston, III Advisory Committee Tony Ca rrasco Anne Draeger Herb Fong Patricia Foster Carroll Harrington Joe Hirsch Leannah Hunt Carol Jansen Jeanne Kennedy John McClenahan Mary MCCullough Scott McGilvray Betty Meltzer Nancy Peterson Carolyn Reller Jane Stocklin Lanie Wheeler Lauren Bonar Swezey CANOPY is a Palo Alto based nonprofit advocate for the urban forest and works to educate, inspire and engage the community as stewa rds of you ng and mature trees. April 14, 2000 City of Palo Alto Ms. Clare Campbell Project Planner Department of Planning and Community Environment 250 Hamilton Avenue Palo Alto, CA 94301 Dear Ms. Campbell, Thank you for giving us an opportunity to comment on the City of Palo Alto Recycled Water Project Initial Study Mitigated Negative Declaration dated March 18,2009. The following are Canopy's comments, most of which were communicated to the Palo Alto Utilities Advisory Commission at their April 1, 2009 meeting. We feel that the Mitigated Negative Declaration does not address the effect that the proposed distribution of recycled water might have on the Palo Alto urban forest. The mission of Canopy is to engage the community in growing and caring for our urban forest. Trees bring many tangible benefits to Palo Alto. These aesthetic, environmental, and social benefits translate into measurable economic payback for the investment made in the forest by the community. While Canopy is very aware of the water restrictions our communities are likely to face in the context of population growth, climate change, and the imperative to protect California's natural environment from which the bulk of our water comes from, and while Canopy supports water conservation efforts, this particular project raises some concerns and questions. The main problem associated with using recycled water for landscape irrigation is that this water typically contains high level of salts. Plants, unlike humans, cannot eliminate these salts and the accumulation of salts in the root area can be very detrimental to trees. 3921 East Bayshore Road Palo Alto, CA 94303 t: 650964 611 0 f: 650 964 6173 canopy.org Ms. C. Campbell 4/14/09 Page 2 of3 Recycled water produced by the Palo Alto Regional Water Quality Control Plant has been used for several years in some Palo Alto parks and was used during the last drought for street tree irrigation. It resulted in the decline and loss of many trees. There are other documented examples of the negative impact of recycled water on trees in the Bay Area. Canopy actually advocates planting drought tolerant and climate appropriate species that will eventually lead to a more sustainable forest. We currently are working with City staff on an urban forest master plan and tree list that will address this priority. However, in the meantime, we have a valuable mature forest composed in part of species that need irrigation in the summer to survive and continue to dispense their benefits. Because experts such as Nelda Matheny and Jim Clark of HortScience(l) warn that the outcome of recycled water irrigation projects depends on the complex interaction of several factors including the quality of the recycled water, the nature of soils, the species being irrigated, the method of irrigation, the availability of dual irrigation systems and the region's rainfall patterns, Canopy sees this proposed project as inherently risky and recommends that the risk be assessed before going forward. In particular, questions such as the following need to be answered: How many trees are present in the target area? How many of these are protected by the City of Palo Alto tree ordinance? How many are street or other public trees? How many are Coast redwoods? (most susceptible to salt damage) How many are drought tolerant? What is the nature of soils in the target area? What is the estimated value of the investment made in these trees? What is the replacement value of these trees? What is the value of the ecosystem services provided by these trees annually? Once an assessment of the value of these trees and the annual value of their benefits is made then the City will be in a better position to make a decision on whether the community is willing to take the risk of losing part of this asset and yearly payback it provides. Canopy recognizes the efforts made in the Mitigated Negative Declaration to include an Adaptive Management Program to address potential problems caused by the use of recycled water. Canopy 3921 East Bayshore Road Palo Alto, CA 94303 t: 650 964 6110 f: 650 964 6173 canopy.org Ms. C Campbell 4/14/09 Page 3 of3 However, we have two problems with this plan: We believe that the assessment should come before the construction of the project, not after it is built Canopy is also concerned with the cost of implementing the mitigation program for 14 years as this aspect of the project is not addressed in the Estimated Cost section of the City of Palo Alto Recycled Facility Plan document dated December 2008. In addition it is unclear who will bear the responsibility for, and financial burden of the implementation of the mitigation program. Thank you for your attention to these comments. Best regards, JM~t~ / . Catherine Martineau Executive Director (1) Matheny, N., and J. R. Clark. 1998. Managing landscape using recycled water. In: The Landscape Below Ground II. D. Neely and G. Watson, ed. International Society of Arboriculture. Champaign 11. Canopy 3921 East Bayshore Road Palo Alto, CA 94303 t: 650 964 611 0 f: 650 964 6173 canopy.org Comment Letter 3 -Canopy Response to Comment 3-1 As described on page 17 of the Public Draft MND, "The City of Palo Alto recognizes that the community tree canopy on private and public property is highly valued for its aesthetic qualities and environmental benefits. To maximize the use of recycled water for irrigation in combination with responsibly maintaining the urban forest canopy, the City has developed the Adaptive Management Program (Program) ... The Program will be implemented to avoid the potential effects of the recycled water use on protected and street trees ... " The City also would be required to comply with its Tree Ordinance (Chapter 8.10, Tree Preservation and Management Regulations) and the Tree Technical Manual, to achieve the City's tree preservation goals and natural resource conservation goals. As such, the Project would not only address specific issues associated with the use of recycled water on regulated trees (Le., protected, street, and designated treesY within the City, but would also indirectly address the effects of recycled water use on the City's urban forest. Section A. Aesthetics of the Public Draft ISIMND, discusses the potential for visual effects on City-designated scenic routes and view corridors from the application of recycled water as irrigation. As described on page 39, "[b]ecause the project integrates the Adaptive Management Program in addressing potential effects of recycled water use on trees, adverse effects on protected and street trees would be avoided." Response to Comment 3-2 The total dissolved solids (TDS) levels were 25 percent higher in the early 1990's (around 1200 PPM) and have declined since that time. As discussed on page 76 of the Public Draft ISIMND, "[i]t is estimated that [rehabilitation of the sewer collection system] and III [Inflow and Infiltration program] would reduce the TDS of the reclaimed water from 900 mg/l [milligram per liter] (1.35 dS/m [decisiemenlmeterD to approximately 700 mg/l (1.09 dS/m)." Although there is some evidence of potential impacts on trees from the use of recycled water, these impacts have not been conclusively shown; and such potential tree impacts were fully addressed in the Master Plan Program ErR. As described on pages 73 of the Public Draft ISIMND, "[t]he City's review did not determine conclusively that recycled water use was responsible for the decline of trees, although recycled water represents a change in irrigation strategy that could pose challenges for specific tree species, particularly Redwoods and possibly other trees requiring favorable acidic soil conditions for health. However, there have been reports of decline in redwoods throughout California in landscapes irrigated with both potable and recycled water (Downer 2004 as cited in HortScience, Inc 2005)." The Public Draft ISIMND recognizes there are a variety of factors that could contribute to the decline/loss of redwood and other salt-intolerant trees, including water quality, salt-sensitivity of plants, soil characteristics, and irrigation management (pages 73 and 74 of the Public Draft MND). Also noted in the Public Draft ISIMND are other agents that may also lead to decline of redwood trees, including climatic factors, fungal pathogens, and other diseases. Response to Comment 3-3 The City acknowledges Canopy's concerns about the use of recycled water as an irrigation source and its view that recycled water application is a risk. To reduce the perceived risk of using recycled water, the City has developed a proactive, precautionary strategy intended to address potential issues, if any, that may arise from the use of recycled water as irrigation on regulated 1 Protected, street, and designated trees are defined on pages 22 and 23 of the Public Draft ISIMND. Palo Alto Recycled Water Page 6 Response to Comments Document trees. This strategy is the Adaptive Management Program outlined on pages 17 -19 of the Public Draft ISIMND. The Program, which considers the City's Tree Ordinance and Tree Technical Manual, has been integrated into the Project such that it would be an essential component and would engage all Participants to be attentive to the protection of an important resource. The intent of the Program is to avoid any adverse effects to these trees through the process of identifYing the baseline conditions, monitoring annually, and taking appropriate action(s) as needed if any signs of decline symptoms were to appear. The framework of the Adaptive Management Program includes a Tree and Soil Conditions Monitoring Plan and Best Management Practices. The components of the Tree and Soil Conditions Monitoring Plan include the Site-Specific Baseline Landscape Conditions Reports, triggers/criteria, and monitoring. As described above, one of the components of the Tree and Soil Condition Monitoring Plan is a site-specific Baseline Landscape Conditions Report that would be developed to determine the existing conditions of individual sites. Specifically, "[tJhe report will include a field spot check of site characteristics by a qualified professional (e.g., consulting or registered arborist or horticulturist). Site characteristics include soil type, site drainage, number of existing trees that will be irrigated, number of protected trees, and health of existing trees. Photos of the existing site conditions will be included in the report with the findings of site conditions. This report will establish the existing conditions such that any changes in the health of the irrigated trees can be observed and, as needed, studied." The report, as outlined, would answer many of the questions that are identified by the commenter. The Baseline Landscape Conditions Report would be developed by the Participants (I.e., the City and its recycled water users) prior to connection to the Recycled Water system. The questions raised by the Commenter related to investment and replacement value of the trees are more properly addressed by the City's Tree Ordinance and the Tree Technical Manual. Because the City values its natural resources, it has established relevant regulations to protect regulated trees (I.e., protected trees, street trees and designated trees). The City's Tree Technical Manual establishes the "specific technical regulations, standards and specifications necessary to implement the Tree Ordinance ... and to achieve the City's tree preservation goals and natural resource conservation goals" (page 22 of the Public Draft MND). For example, Section 3.00 of the Tree Technical Manual outlines requirements associated with the removal and replacement of regulated trees. The question related to the "value of the ecosystem services provided by these trees" is beyond the scope of this Project. This question would be more appropriately addressed by the Urban Forest Master Plan that Canopy is currently developing with the City. Other components of the Tree and Soil Condition Monitoring Plan include triggers/criteria, monitoring, and an Extensive Landscape Study. As described on page 18 of the Public Draft ISIMND, "[t]he triggers would consist of a specific list of decline symptoms that can be observed and further studied as needed to determine whether the symptoms are attributable to recycled water use or other water-quality independent causes." Monitoring activities, which "provide the opportunity to observe changes in site-specific conditions before long-term decline effects result," would occur on an annual basis. The Plan also includes an Extensive Landscape Study that could be implemented to further study the cause of observable tree declines if they occur at individual properties. Response to Comment 3-4 The City acknowledges Canopy's concerns regarding the timing and cost of the Adaptive Management Program implementation. The Public Draft ISIMND has outlined the framework of the Program, but has not yet developed it in fulL The Program and its components (Tree and Soil Condition Monitoring Plan and Best Management Practices) would be refined in consultation Palo Alto Recycled Water Project Page? Response to Comments Document with a qualified professional (Le., consulting or registered arborist or horticulturalist) based on the most current information available at the time of its preparation. The formulation of the Program would be expected to occur in parallel with design of the project, prior to construction of the recycled water facilities. Site-specific, Baseline Landscape Condition Reports would occur at individual sites thereafter, but prior to connection to the recycled water system, as customers are registered. The implementation of the Program, including annual monitoring and actions associated with the BMPs has to occur during the life of the project, so to assess the response of the regulated trees to the use of recycled water. The cost of a project is not typically considered in the environmental evaluation. As such, the cost of developing and implementing the Adaptive Management Program was not identified in the Public Draft IS/MND. To respond to the commenter's questions, a discussion of responsibility and costs is provided here. It is anticipated that approximately $30,000 would be needed for the development of the Program by a registered arborist or horticulturalist; this cost will be borne by the City. The cost of the site-specific Baseline Landscape Conditions Reports (as outlined in the Program) will also be the responsibility of the City and will be included in the revised Operations and Maintenance (O&M) estimates that City Staff will submit to the Council on July 6, 2009 as part of project approval. The O&M estimate for the baseline landscape conditions reports, which is currently being determined, would be based on either the hiring of a standing consultant contracted to the City to perform the baseline studies over the 2-to 3-year time period leading up to projected recycled water deliveries or the retention of a part/full time City-employed Horticulturist. Individual site owners will be responsible for conducting and paying for the annual self certification that will be submitted to the City over the course of the 14-year monitoring period. Presumably, individual site owners have existing staff that currently maintain landscapes within the existing properties, thus minimizing the financial burden associated with hiring new staff to perform this task. The City does not anticipate issues related to recycled water use that cannot be addressed by the Adaptive Management Program, the RWQCP's efforts to reduce saltwater infiltration, and the exemption process in the existing Recycled Water Ordinance.2 If issues arise (i.e., decline symptoms are identified), corrective actions determined on a case-by-case basis will be the responsibility of individual site owners. Given that these issues are not anticipated and cannot be predicted without active monitoring that occur during recycled water use, such costs are not identified here. The City Council will consider the overall cost of the project when it takes action on adopting the Final ISIMND and approving the project. 2 On April 28, 2008, Council adopted an ordinance to promote the use of recycled water (CMR 203:08, Ordinance No.5002) for irrigation, toilet and urinal flushing and trap priming (also Chapter 16.12, Recycled Water, ofthe City of Palo Alto Municipal Code). Section 16.12.050 of the Ordinance establishes an exemption process, as follows: "Requests for an exemption or adjustment may be made consistent with state law and shall be based on the finding by the Director of Public Works that the use of recycled water demonstrates an adverse effect to the applicant's landscaping installed prior to the effective date of the ordinance codified herein." The exemption process is an appropriate forum for propelty owners to establish that the record demonstrates the use of recycled water would harm Redwood trees or similarly salt -sensitive species at specific sites. Palo Alto Recycled Water Project Page 8 Response to Comments Document April 15, 2009 Mr. Nicolas Procos City of Palo Alto Utilities City of Palo Alto 250 Hamilton Avenue Pato Alto, CA 94301 File: 31644 Various Subject: Recycled Water Facility Plan and Initial StudylDraft Mitigated Negative Declaration Dear Mr. Nicolas: 5750 ALMADEN EXPWY SAN JOSE, CA 95118-3686 TELEPHONE (408) 265-2600 FACSIMILE (40B) 266·0271 www.vatleywoter.org AN EQUAL OPPORTUNiTY EMPLOYeR It was brought to our attention on April 7'h, 2009, that the Palo Alto Recycled Water Facility Plan (Plan) and associated Draft Mitigated Negative Declaration (Neg Dec) were avaflable for review during this period that ends on April 17'h, 2009. The District staff reviewed the subject documents and following are our comments, District Policies The District encourages the use of recycled water to ensure water supply availability and sustainability to the community. Recycled water is a water supply that can be environmentally responsible, locally controlled, and available independent of the weather. Recognizing these benefits, the District Board has set policy to promote recycled water throughout Santa Clara County. Plan page x and elsewhere: The Plan inaccurately summarizes District Board Ends Policy E- 2.1.7 as stating "specifically that water recycling accounts for 5 and 10 percent of total water use in Santa Clara County in 2010 and 2020, respectively". While these are policy targets for recycled water, the policy states that the expansion of recycled water will be linked to community needs, planning documents, and other policies such as aggressively protecting the groundwater basins from contamination and the threat of contamination. lmportant policies related to the expansion of recycled water include: o E-2.1.6. The groundwater basins are aggressively protected from contamination and the threat of contamination. o E-2.1.7, Water recycling is expanded within Santa Clara County in partnership with the community, consistent with the District's Integrated Water Resources Plan (fWRP). reflecting its comparative cost assessments and other Board policies. o E-2.1.7.1. Target 2010, water recycling accounts for five percent of total water use in Santa Clara County. o E-2.1.7.2, Target 2020, water recycling accounts for ten percent oftotal water use in Santa Clara County. The mission of the Santa Claro Valley Water District is a healthy, sofe and enhanced quolity of living in Santa Clara County through wafershed stewardship and comprehensive management of water resources in a practical, cost-effective and environmentally sensilive manner. (.) Mr. Nicolas Procos Page 2 April 15, 2009 Salinity Management Plan page 3-12,13; Neg Dec page 22: The salinity management discussion in the Plan is limited to salinity impacts on redwood trees and how these impacts can be reduced, When describing salinity management strategies, the Plan states "Salinity has been a concern for potential Palo Alto recycled water users as well as Phase 1 and 2 customers, particularly as it relates to redwood trees", Salinity management strategies listed in the Plan include leaching salts below the root zone by apply a large volume of water that carries salts accumulated in the root zone further down into the soil profile, and increasing irrigation frequency, The Neg Dec states 'There is potential for the salts to build up in the soil as a result of recycled water use and the potential increase of salinity of groundwater. As part of the RWQCP's regional recycled water program, salinity management strategies have been identified and wilf be implemented as part of the proposed Project." The discussion of strategies and BMPs in the Plan defer to the City of Palo Alto RWQCP Water Reuse Program, The emphasis on salinity impacts to redwood trees and the reliance on the RWQCP strategies for meeting salinity management are inadequate, This Plan needs to assess long-term salinity impacts on the groundwater basin, not just impacts on redwood trees, Although the salinity strategies listed may benefit redwood trees, the potential impact to groundwater is not discussed. As stated on page 22 of the Neg Dec, recycled water permits typically require that irrigation rates match the evapo-transpiration rates of the plants being irrigated, which appears to be in direct conflict with the salinity management strategies listed in the Plan on page 13. These inconsistencies should be reconciled, and the salinity management strategies adjusted to address groundwater impacts as well. Groundwater Protection Plan page 3-4, 3-14, Neg Dec page 68,71-74,77: As stated on page 3-4 of the Plan, the water quality needs were assessed based on operational rather than regulatory concerns. On page 3- 14, the Plan states "Although impacts on groundwater beneficial uses associated with the recommended recycled water uses are anticipated to be insignificant, they should be considered during project implementation, .. " The Neg Dec rates the potential to degrade water quality as less than significant impact, and states that because of the limited amount of water anticipated to leach into the groundwater, this potential salt migration would not adversely impact groundwater quality from a public health standpoint This supposition is not supported with analysis in the document and is based on the adherence of the proposed project to all appropriate Title 22 to protect the public health. The District believes that the threshold of significance for groundwater protection should be based on the State Water Resources Control Board's Anti-degradation Policy rather than compliance with Title 22. The current RWQCP system supplies recycled water for irrigation to areas that are afforded some groundwater protection from the existence of a confining low permeability layer (often referred to as the confined zone area). The expansion of this system included in the Plan would provide recycled water to irrigation uses in the groundwater recharge area and areas upgradient of the recharge area, In 2004, the District completed an Advanced Recycled Water Treatment Mr. Nicolas Procos Page 3 April 15, 2009 Feasibility Study, Results showed that. compared to local surface water and groundwater, local tertiary treated recycled water is generally higher in total organic carbon, total dissolved solids, nitrate, phosphate, disinfection by-products (including THMs and NOMA), and some anthropogenic compounds, The study also foul')d that slight to moderate impacts to groundwater resources could be caused in certain areas of the groundwater basin if recycled water is used for irrigation, Neither the Plan nor the Neg Dec adequately discusses the potential of groundwater degradation from expanding recycled water use in the recharge area, The City should include a more thorough assessment of the potential for groundwater degradation based on the Anti- degradation Policy as well as the other goals and policies mentioned on page x, If that assessment finds the potential for degradation, adequate mitigation measures and BMPs should be identified in the Plan. Potential prohibitions to consider should include (but not be limited to) the following: o No recycled water used for irrigation shall be applied during periods of rainfall or when soils are saturated such that runoff occurs. o No recycled water used for irrigation shall be allowed to escape to areas outside the designated use area by surface flow or by airborne spray. o No recycled water used for irrigation shall be applied above the eva po-transpiration rate of the landscape. The Plan states that the impacts of recycled water on groundwater should be considered during project implementation. The potential for impacts to groundwater should be assessed in the Plan and Neg Dec, with appropriate mitigation measures defined in the Neg Dec. District Role in the Plan The acknowledgements in the Plan state that the Plan "represents a collaborative effort between the City of Palo Alto, RMC Water and Environment, and local stakeholders (Regional Water Quality Control Plant, SCVWD, and City of Palo Alto Utilities customers)." We thank you for generous acknowledgement and take the opportunity to clarify our role in the Plan. The District provided data during the Plan development but was not a party in the preparation of the Plan, Project Benefits to the District Plan page x and elsewhere: The Plan identifies potential benefits to the District from the Project as "Reduces dependence on imported potable water (Central Valley Project) for non~potabJe uses by progressing toward meeting countywide recycled water goals established in Policy E- .2.1.7; Prepares for regionalization of recycled water service, which allows for more operational flexibility." The Plan identifies as a benefit to the State Water Resources Control Board Nicolas Procos Page 4 April 15, 2009 (SWRCB) of "Benefits the Bay-Delta water system by aiding SCVWD to meet their countywide recycled water use policy." The District disagrees with this characterization of District benefits from this Project. The identified project area is within the City of Palo Alto, which currently relies exclusively on SFPUC Hetch-Hetchy project water for its potable water use. As such, this project will not reduce District imported water needs from the Central Valley Project or any other District imported water source. The second identified benefit to the District is unclear and needs to be better defined before the District can determine jf it is a valid District benefit. The project does reduce the City of Palo Alto's needs for imported water from the SFPUC. It is not clear if the reduction in Palo Alto's demand from the SFPUC translates to a benefit to the Bay-Delta; but the project as defined does not benefit the Bay-Delta through reduction in District imported water needs. Permits and Approvals The proposed alignment of the recycied water pipeline would cross three creeks -two crossings over Adobe Creek, one crossing over Barron Creek, and two crossings over Matadero Creek. Page 25 of the Neg Dec states that the proposed Recycled water Pipeline may be within SCVWD, SFPUC, ....... easements. The document identifies the need for obtaining permits for construction across creeks. The document must also state that in addition to the encroachment permits from the District for construction work within the District right of way in compliance with the District's Water Resources Protection Ordinance, an easement from the Santa Clara Valley Water District may be required to construct the pipeline within the District right of way. Abandoned Wells In order to protect groundwater quality and in accordance with District Ordinance 90-1, all existing wells (monitoring or supply wells) affected by this project need to be identified and properly registered with the District, and shall either be maintained or destroyed in accordance with the District's standards. Destruction of any well and the construction of any new wells, including monitoring wells, requires a permit from the District prior to construction. I can be reached either by phone at (408) 265~2607, extension 2731 or bye-mail at uchatwanl@valleywater.org with any further questions. Please refer to District file No. 31644 on any future correspondence. Sincerely, j}~ C~, Usha Chatwani, Associate Civil Engineer Community Projects Review Unit cc: C. Elias, S. Tippets, S. Ahmadi,S. Judd, P. John, H. Ashktorab, M. Sliva, V. De La Piedra, U. Chatwani, File 31644_51888uc04-15 Comment Letter 4 -Santa Clara Valley Water District The City appreciates the District's comments on the Facility Plan for the proposed project dated December 2008. It should be noted that the Facility Plan is a standalone document that is not part of the Public Draft IS/MND and was not subject to public review required under CEQA. Thus, this Response to Comments document responds only to those comments associated with the Public Draft ISIMND. The City will address comments on the Facility Plan directly with the District. Response to Comment 4-1 This comment is in reference to the Facility Plan, not the Public Draft IS/MND. As discussed above, the City will address comments on the Facility Plan directly with the District. Response to Comment 4-2 All water used in irrigation contains dissolved salts in varying types and quantities, and these salts are carried into the soil with the water whenever it is used. Subsequent use of the water by the plants leads to the concentration of salts in the soil. A portion ofthe salts that accumulate in soil from prior irrigations can be removed (leached) below the rooting depth if more irrigation water infiltrates the soil than is used by the plant; alternatively, the leaching can occur as a result of the percolation of winter-time precipitation. As noted in the Public Draft ISIMND, leaching is one of the corrective actions that can be implemented as part of the Adaptive Management Program to address salinity issues associated with redwood trees. Leaching of salts can add to the salt balance of an underlying groundwater body; therefore, the ability of that groundwater basin to "absorb" the leached salts must also be considered when using recycled water for irrigation over long periods of time. The proposed project involves the application of recycled water at agronomic rates over the Confined Zone of the Santa Clara Valley Groundwater subbasin. If salt accumulation occurs in shallow soils such that additional (non-seasonal) leaching is required, the recycled water may be applied at rates slightly higher than agronomic rates in order to provide the necessary leaching. Groundwater quality impacts from both the natural and artificial leaching of salts are anticipated to have minimal affects on the underlying aquifers. In the portion of Palo Alto where recycled water application is anticipated to occur, the Santa Clara Valley Groundwater subbasin is divided into two aquifer zones, separated by a low permeability aquitard. This aquitard minimizes the downward movement of constituents from the Upper Aquifer to the Lower Aquifer and therefore, will also minimize the potential movement of salts f)'om the Upper Aquifer down to the Lower Aquifer, the primary zone used for water supply. As indicated by a regional groundwater gradient from the hills towards the San Francisco Bay, there is regular groundwater movement in the Upper Aquifer driven by precipitation percolation that will aid in keeping upgradient salinity concentrations lower and move salts in the Upper Aquifer zone generally towards San Francisco Bay. Response to Comment 4-3 The Public Draft IS/MND has provided an adequate evaluation of water quality effects on public health associated with potential impact to groundwater (see pages 72 to 73). As noted in the comment, the current RWQCP system supplies recycled water for irrigation to areas that are afforded some groundwater proteetion from a confining low permeability layer. Increased distribution of recycled water will be solely on the east side of Highway 280, completely over the Confined Zone as shown in Figure 7 -"Santa Clara Valley Groundwater Basin" of the document A Comprehensive Groundwater Protection Evaluation for the South San Francisco Bay Basins (San Francisco Bay RWQCB, 2003). This figure, attributed to the Santa Clara Valley Water Palo Alto Recycled Water Project Page 9 Response to Comments Document District (SCVWD), is attached. According to this figure, the Forebay Zone in the Palo Alto area is located completely west of Highway 280, and therefore the proposed expanded recycled water project will have little impact to the Lower Aquifer as a result of the confining low permeability layer that defines the Confined Zone. This conclusion is consistent with that reached in the SCVWD's report entitled Advanced Recycled Water Treatment Feasibility Project (2004) which stated that "In the [Santa Clara Valley Groundwater] Subbasin, almost all of the existing recycled water use is over the confined zone and less concern is warranted here" and is anticipated to be true for other conservative constituents such as chloride. For nitrates, the application of recycled water at agronomic rates will allow for the uptake of nitrate (and related nitrogen constituents) by the plants. When combined with user modifications to account for the additional nutrients (i.e. reducing fertilizer use to account for the nitrogen present in recycled water), the potential downward migration of nitrates will be minimized. Finally, there is the potential that recycled water will contain disinfection by-products and other emerging contaminants. While the fate and transport of these constituents in the vadose zone and water table aquifers is not fully understood, initial studies (such as the one conducted at the University of California, Riverside by Xu et. al. 2008) indicate that soil aquifer treatment does appear to occur when recycled water is used for turfgrass irrigation. Additionally, per the District's analysis in the Advanced Recycled Water Treatment Feasibility Project (2004), "[i]n general, most of the other potential contaminants of concern, (Nitrate, TOC and other Emerging Contaminants), reviewed are of 'Insignificant (0)' to 'Slight (1)' concern in the confined zones of the [Santa Clara Valley Groundwater] Subbasin ... " due to the low volume applied (relative to all applied water basin-wide) and the low to moderate and inconsistent levels of emerging contaminants in the recycled water. The City agrees with the potential prohibitions recommended by the SCVWD as set forth in this comment and that they should be considered as conditions for use of recycled water for irrigation in Palo Alto. Page 72 of the Public Draft ISIMND has already identified the following prohibition: "Prohibition of the over-application or any direct runoff of applied recycled water (recycled water would be applied to landscaped areas at agronomic rates to meet the evapotranspiration requirements, which minimizes surface runoff)." Based on the discussion above, an assessment based on the Anti-degradation Policy (i.e., Water Resources Control Board's Resolution 68-16: State of Policy with Respect to Maintaining High Quality of Waters in California) is not warranted. However, to address the District's concerns regarding the quality of the groundwater basin, the following bullet has been added to the end of the Adaptive Management Program discussion on page 19, as follows: • The City will coordinate with Santa Clara Valley Water District to monitor water quality in the groundwater basin to assess any potential changes associated with project use of recycled water. Monitoring activities will be coordinated with the future salinity and nutrient management plan, to be developed for the Santa Clara Valley Groundwater Basin in accordance with the State Recycled Water Policy (adopted in 2009). Response to Comment 4-4 This comment is in reference to the Facility Plan, not the Public Draft ISIMND. As discussed above, the City will address comments on the Facility Plan directly with the District. Palo Alto Recycled Water Project Page 10 Response to Comments Document 5 o 5 r--- to Miles -----1 Location of Oross,..Seclion A-AI Santa OlaraGroundwate.r Figure 7: Santa Clara Valley Groundwater Basin (Source: Santa Clara Valley Water District) Response to Comment 4-5 This comment is in reference to the Facility Plan, not the Public Draft IS/MND. As discussed above, the City will address comments on the Facility Plan directly with the District. Response to Comment 4-6 The City acknowledges that an easement to construct the proposed pipeline within the District's right-of-way in compliance with the District's Water Resources Protection Ordinance may be required. In addition, if wells are affected by this project, the City would maintain/destroy wells in accordance with the District's standards and obtain necessary permits. In response to this comment, a District easement and permit for construction/destruction of wells have been added to the list of potential permits required for the proposed project. The second bullet on page 25 of the Public Draft IS/MND is revised as follows: • Santa Clara Valley Water District (SCVWD) -permit for construction across creeks / flood control channels, easement to construct the pipeline in SCVWD right-of-way and a permit prior to construction for destruction of any well or construction of any new well, including monitoring wells. Palo Alto Recycled Water Project Page 12 Response to Comments Document State Water Resources Control Board Linda S. Adams Secretary for Environmental Protection APR 1 6 2009 Ms. Clare Campbell City of Palo Alto Division of Financial Assistance 10011 Street· Sacramento, California 95814' (916) 341·5700 FAX (916) 341-5707 Mailing Address: P,O. Box 944212 • Sacramento, California' 94244-2120 Internel Address: http://www.waterboards.ca.gov 250 Hamilton Avenue Palo Alto, CA 94301 Dear Ms, Campbell: Arnold Schwarzenegger Governor INITIAL STUDY/MITIGATED NEGATIVE DECLARATION (IS/MND) FOR THE CITY OF PALO ALTO (CITY); PALO ALTO RECYCLED WATER PROJECT (PROJECT); SANTA CLARA COUNTY; CLEAN WATER STATE REVOLVING FUND (CWSRF) . NO. C-06-5171-110; STATE CLEARINGHOUSE (SCH NO. 2009032065) We understand the City is, pursuing CWSRF financing for the proposed Project. As a funding agency and a state agency with jurisdiction by law to preserve, enhance, and restore the quality of California's water resources, the State Water Resources Control Board (State Water Board) is providing the following information for the environmental document to be prepared for the. Project. . Please provide us with the following documents applicable to the proposed Project: (1) Two copies of the Draft and Final IS/MND, (2) the resolution adopting the MND and the Mitigation Monitoring and Reporting Program (MMRP) and making California Environmental Quality Act (CEQA) findings, (3) all comments received during the review period and the City response to those comments, (4) the adopted MMRP, and (5) the Notice of Determination filed with the Governor's Office of Planning and Research. In addition, we would appreciate notice of any hearings or meetings held regarding environmental review of any projects to be funded by the State Water Board. Under CEQA Guidelines Section 21081.6, the Lead Agency (in this case, the City) is required to adopt a MMRP along with the MND to ensure compliance with required mitigation measures during project implementation. The City has listed a number of mitigation commitments listed in the Project Description section. Under CEQA, the City must adopt actual mitigation measures that are feasible, enforceable, and capable of being monitored under an MMRP. If the City decides to pursue CWSRF financing, the City must include relevant mitigation measures in any areas of potential adverse impacts from Project construction or operation. The City has indicated potential impacts in the areas of Biological Resources and Traffic. These mitigation measures could also be included as part of the financing agreement between the State Water Board and the City if funding is provided to complete the proposed Project. The CWSRF Program is partially funded by the U.S. Environmental Protection Agency and requires additional "CEQA-Plus" environmental documentation and review. Three information sheets are included that further explain the environmental review process and some additional federal requirements in the CWSRF program. In addition, an environmental form is included for the City to submit should it pursue State Water Board funding. The State Water Board can consult directly with agencies responsible for implementing federal environmental laws and regulations. Any environmental issues raised by federal agencies or their representatives will need to be resolved prior to State Water Board approval of a CWSRF funding commitment for California Environmental Protection Agency o Recycled Paper Ms. Clare Campbell -2 -APR 162009 the proposed Project For further information on the CWSRF program please contact Ms. Michelle L. Jones at (916) 341-6983. It is important to note that prior to a CWSRF funding commitment, projects are subject to provisions of the Federal Endangered Species Act and must obtain approval from the U.S. Fish and Wildlife Service (USFWS), and/or National Marine Fisheries Service (NMFS) for any potential effects to special status species. Please be advised that the State Water Board can consult with USFWS, and/or NMFS on behalf of the City regarding all federal special status species the Project has the potential to impact jf the Project is to be funded under the CWSRF Program. The City will need to identify whether the Project will involve any direct effects from construction activities, or indirect effects, such as growth inducement, that may affect federally- listed threatened, endangered, or candidate species that are known, or have a potential to occur on-site, in the surrounding areas, or in the service area. Please identify applicable conservation measures to reduce such effects. Page 48 of the IS/MND states "Where access was limited or prohibited surveys were conducted from fence lines and/or by aerial photo interpretation." Please list the areas that were inspected by fence lines and/or aerial photo interpretation and explain why access to these sites was limited. Also, page 49 states "trenchless construction techniques will be used to install the pipeline at creek crossings." Please clarify the trench less technique (i.e., microtunneling, or suspension along the bridge) that will be used by the Project for creek crossings. Also, identify any mitigation measures, or permits required for the selected trenchless construction technique. Page 62 states that potential impacts to cultural resources "would be minimized through the implementation of the environmental commitments outlined in the Project Description and as a result, the impact is considered less than significant." The environmental commitments that will be implemented to protect cultural resources, on page 20, states that "if cultural resources are encountered during Project-related excavations, construction shall be halted or diverted to allow an archeologist an opportunity to assess the resource." Please note that mitigations need to be specific and enforceable. Additional federal requirements pertinent to the Project under the CWSRF Program include the following: A. Compliance with the Migratory Bird Treaty Act (Act): Ust any birds that are protected under this Act that may be impacted by the Project, and identify conservation measures to minimize such impacts. B. Air Quality Act: Identify air quality stUdies that may have been done for the Project. For those, Projects in non-attainment areas subject to maintenance plans: • Provide emission data for each criteria pollutant for which the area has been designated non-attainment or maintenance; and • Provide a summary of the emissions that are expected from both the construction and operation of the Project for each criteria pollutant in a non-attainment or maintenance area. California Environmental Protection Agency o Recycled Paper . Ms. Clare Campbell 3 - APR 1 6 2009 If emissions are above the federal de minimis levels, but the Project is sized to meet only the needs of current population projections that are used in the approved State Implementation Plan for air quality: • Quantitatively indicate how the proposed capacity increase was calculated using population projections. C. Protection of Wetlands: Identify whether or not the Project or construction activities will impact stream, flood control channels, or wetlands. D. Coastal Zone Management Act: Identify whether or not the proposed Project is in the Coastal Zone. Thank you once again for the opportunity to review the City's environmental document. If you have any questions regarding my comments, please feel free to contact me at (916) 341-5686, or by email atihockenberrv@waterboards.ca.gov . . Sincer~. . . I .. I A f (J 0iJl\\iA--~ ..J James Hockenberry Environmental Scientist Enclosures (4) cc: State Clearinghouse wlo enclosures (Re: SCH# 2009032065) P. O. Box 3044 Sacramento, CA 95812-3044 California Environmental Protection Agency o Recycled Paper Comment Letter 5 -State Water Resources Control Board Response to Comment 5-1 The City will provide the State Water Resources Control Board (SWRCB) with the required fonns, notices and documents. A MMRP has been prepared that includes all proposed mitigation measures identified in the Public Draft IS/MND. Refer to Appendix A for the completed MMRP. The City acknowledges ~hat prior to a Clean Water State Revolving Fund funding commitment, projects are subject to provisions of the Federal Endangered Species Act and must obtain approval from the U.S. Fish and Wildlife Service and/or National Marine Fisheries Service. Potential effects of the project on federally-listed threatened, endangered, or candidate species are discussed in the Biological Resources Section on pages 47 to 53 of the Public Draft IS/MND and mitigation measures are provided to reduce potential impacts to less than significant levels. Refer to Response to Comment 7-7 for further discussion of mitigation measures related to biological resources. Response to Comment 5-2 The following is a list of locations along the proposed pipeline alignment, alignment options and laterals where access for the biological resources field survey was restricted due to the presence of fences; most of properties are private and thus could not be entered. • Fabian Way and Adobe Creek -The creek was fenced off and there were no trespassing signs posted. • Middlefield Road and Adobe Creek The creek was fenced off and there were no trespassing signs posted. • Cowper Street between Maureen A venue and Kipling Street - A SCVWD fence blocked the entrance to creek. • Cowper Street and Matadero Creek - A SCVWD fence blocked the entrance to creek. • Alma Street from EI Dorado A venue to Page Mill Road -A fence was located along the south side of Alma Street separating the roadway from the Caltrans Railroad tracks. • Deer Creek Road south of Hillview Avenue A fence was located along the roadway separating the road from open space on the north side of Deer Creek Road. • South California A venue -There was a SCVWD fence on the creek on the east side of the South California A venue lateral. • The west side of the Page Mill Road lateral was fenced along the roadway. • The southwest comer of Arastradero Road and Page Mill Road was fenced off and the area looked to consist of open space and a garden. As described in Table 4 of the Public Draft IS/MND (page 17), all the creek crossings would be either constructed with the pipe attached to the side or in the roadway on the bridge, or through a trenchless pipeline construction technique. The specific technique to be used to install the pipeline at each location has not been detennined and will be detennined as part of project design. Of the creek crossings that may be required, only the crossing at Adobe Creek across US 101 may be completed through a trench less technique. There are several trenchless pipeline construction techniques that could be employ, including horizontal directional drilling, microtunneling, and jack-and-bore. A brief description of these methods is identified below. Palo Alto Recycled Water Project Page 13 Response to Comments Document • Horizontal directional drilling (HDD) is a process that uses a laser-guided and remotely- controlled boring machine and auger that is driven from a sending pit to a receiving pit. The drill bit is affixed on an articulating head at the lead end of the auger shaft; this articulating head provides the directional capability. As the auger shaft is driven forward, additional lengths of shaft are added at the sending pit until the drill bit daylights in the receiving pit. Material and equipment to be used would include a drilling rig and auger controls, shafts, pipe, fuser, excavator, trucks, and slurry handling containers. The work areas around the pits require adequate space to accommodate auger separation and associated equipment and slurry waste management practices. The sending pit area requires a 100-foot-square work area to accommodate drilling equipment, support equipment, and a sump for drilling slurry. Sump areas are required to contain the drilling slurry/fluids used during the HDD process and to capture the slurry/fluid once the initial hole is completed. HDD involves the use of drilling slurry as a drilling lubricant. The slurry is commonly a bentonite fluid; bentonite is a fine clay material. • Microtunneling is a process that uses a laser-guided and remotely-controlled boring machine that is driven from a sending pit to a receiving pit by means of a hydraulic jack. As the tunneling machine is driven forward, jacking pipe is added into the pipe string. The temporary sending and receiving bore pits will be about 15 feet deep. The jacking pit will require an open excavation of 15 feet by 40 feet. The receiving pit will require a 12- by 25-foot excavation. Microtunneling may involve the use of drilling fluid or bentonite slurry, a fine clay material, as a drilling lubricant. • Jack-and-bore is a multi-stage tunneling process consisting of constructing a temporary horizontal jacking platform and a starting alignment track in an entrance pit at a desired elevation. The pipe is then jacked by manual control along the starting alignment track with simultaneous excavation of the soil being accomplished by a rotating cutting head in the leading edge ofthe product's annular space. The ground up soil (spoil) is transported back to the entrance pit by helical wound auger flights rotating inside the pipe. Jack-and- bore typically provides limited tracking and steering as well as limited support to the excavation face. The analysis of potential impacts in the Public Draft ISIMND evaluates all trenchless techniques that may be used for construction. Therefore, no new mitigation measures would be required for the selected technique. Likewise, the permitting requirements would be the same for all techniques. Response to Comment 5-3 To be proactive about protecting sensitive resources, the City has incorporated into the Public Draft ISIMND environmental commitments into the project, including that associated with cultural resources. The cultural resources commitment shown on page 20 of the Public Draft ISIMND is enforceable. It identifies the standard methods for addressing cultural resources in the event that they are discovered during construction activities. In response to the commenter, the standard commitement has been clarified to be more specific. The following clarification of potential action taken should cultural resources be encountered has been added to the Public Draft IS/MND. The first paragraph on page 20 of the Public Draft ISIMND is revised as follows: In accordance with CEQA Section 15064.5, if cultural resources are encountered during Project- related excavations, construction shall be halted or diverted to allow an archaeologist an opportunity to assess the resource. The archaeologist will recommend what action, if any, is warranted. Measures might include preserving in situ the archaeological resource or an Palo Alto Recycled Water Project Page 14 Response to Comments Document archaeological monitoring or data recovery program. Prehistoric archaeological site indicators include chipped chert and obsidian tools, and tool manufacturing waste flakes, grinding implements such as mortars and pestles, and darkened soil that contains dietary debris such as bone fragments and shellfish remains. Historic site indicators include, but are not limited to, ceramics, glass, wood, bone, and metal remains. Response to Comment 5-4 The Public Draft IS/MND complies with all additional federal requirements pertinent to the project under the CWSRF Program. A. Birds protected by the Migratory Bird Treaty Act (MBTA) are listed on pages 52 and 53 of the Public Draft IS/MND and in Appendix C Biological Resources. Mitigation measures to minimize potential impacts are identified and presented on pages 57 and 58 of the Public Draft ISIMND. B. Construction and operational emissions for the proposed project were calculated using the lJRBEMIS model. Emissions generated by the proposed project would be less than significant based on Bay Area Air Quality District Thresholds of Significance, which take into account Federal criteria for air emissions. The quantified levels of emissions would be less than thresholds applied under the General Conformity Rule and, therefore, correspond with federal de minimis levels. In addition, greenhouse gases were calculated for the proposed project and it was determined that the project "would not make a cumulatively considerable contribution to global climate change associated with GHG emissions." The air quality analysis is provided on pages 42 to 46 of the Public Draft ISIMND and the greenhouse gas discussion is provided on pages 96 to 98 of the Public Draft ISIMND. C. Protection of Wetlands is discussed on pages 53 and 54 of the Public Draft ISIMND and mitigation is provided on pages 58 and 59 of the Public Draft ISIMND. Best Management Practices for wetlands, which are environmental commitments of the Project, are listed on page 21 of the Public Draft ISIMND. D. The proposed project is not in the Coastal Zone. As stated on page 79 of the Public Draft ISIMND, " ... the proposed Project would not conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the Project area." Palo Alto Recycled Water Project Page 15 Response to Comments Document B4/16/2B09 13:44 4083215787 VTA ENVIRON PLAN PAGE B2/B3 'f SAM'. <LARA ~ Valley TransportatlDn AuthDrlty April J 6, 2009 City of Palo Alto Plauning Department P.O. Box 10250 Palo Alto) CA 94303 Attention: 'Clare Campbell SUbject: Palo Alto Recycled Water Project Dear Ms. Campbell: Sauta Clara Valley Transportation Authority (VT A) staff have reviewed the Mitigated Negative Declaration for 5 miles of recycled water pipeline and pump stations in central Palo Alto. We have the following comments. Traffic Control Plan VTA requests the opportunity to review the full traffic control plans when they become available in order to determine if there are potential impacts to CMP facilities during constru.ction. We also recommend a media campaign to notify the public about the duration of the construction, lane closures, and potential detour routes. We recommend prohibiting construction before 9 a.m. and after 3 p,m. since the peak hour traffic on some of the CMP facilities in the area statts around 3.pm. Impacts to aus SeQdce Mitigation measure TRA~ 1 requires that damaged road surfaces be returned to pre-construction conditions or better. We assume this includes bus stop facilities also. Once the final pipeline route is determined) VTA would like to revi~ it to detennine which bus routes and bus stops will be impacted. VIA Conta&lI If construction involves cutting through 8. VT A pee bus stop pavement pad, a Cons1rUction Access Permit will be required and the project should include this requirement in the Special Conditions of the contract. The contractor should be directed to contact Debbie Dionne, Permits and Utility Loca.ting Services. at (408) 321-5824. 3331 N!lllh Flnl Slnel • San Jose, CA 95134.1906 • Admlnlslrallon 408.32U555 • ClIslomer Service 408.321.2300 94/16/2009 13:44 4883215787 VTA ENVIRON PLAN PAGE B3/83 <, City of Palo Alto . April 16, 2009 Page 2 If temporary relocation of bus stops is needed. the contractor should contaot Steve NewgreD. it (408) 952-4106 at least 72 hours in advance. Thank you for the opportunity to review this project If you have any questions, please call me at (408) 321.-5784. (l01h{ Roy Molseed Senior Environmental Planner RM:kh cc: Samantha Swart, VIA PA.0901 Comment Letter 6 -Santa Clara Valley Transportation Authority Response to Comment 6-1 Comment noted. The Traffic Control Plan will be made available for review by VTA when it becomes available. Notification requirements will be included in the Traffic Control Plan as appropriate. The construction schedule for the proposed project is discussed on page 14 of the Public Draft ISIMND. Construction would occur between the hours of 9 a.m. and 4 p.m. Monday through Friday on arterial and collection streets in order to maintain compliance with the City'S Traffic Control Requirements. Construction other than on arterial and collection streets would occur between the hours of 8 a.m. and 6 p.m. Monday through Friday. Construction would occur between 9 a.m. and 6 p.m. on Saturday for all construction areas. The City will consider limiting the construction hours on CMP facilities to 9 a.m. to 3 p.m. if deemed necessary and feasible. Response to Comment 6-2 Mitigation Measure TRA-I includes bus stop facilities in "damaged road surfaces". The final pipeline route will be available for review by VT A. Response to Comment 6-3 Comment noted. The City acknowledges that a VTA Construction Access Permit may be required if construction involves cutting through a VT A PCC bus stop pavement pad. The II th bullet is added on page 25 of the Public Draft IS/MND as follows: • Santa Clara Valley Transportation Authority -Construction Access Permit if construction involves cutting through a VT A PCC bus stop pavement pad. Palo Alto Recycled Water Project Page 16 Response to Document April 17, 2009 Ms. Valerie Fong City of Palo Alto Utilities 250 Hamilton Avenue Palo Alto, CA 94301 STANFORD UNIVERSITY Re: Initial StudyfMitigated Negative Declaration for Palo Alto Recycled Water Project Dear Ms. Fong: Stanford University appreciates the opportunity to comment on the draft Initial StudylMitigated Negative Declaration for the City of Palo Alto's Recycled Water Project. Stanford supports efforts to decrease potable water use using water resources efficiently, implementing water conservation measures, and incorporating water-efficient infrastructure into new facilities. However, the draft ISIMND presents several serious concerns regarding the environmental impacts that would result from Palo Alto's Recycled Water Project. Stanford's major concern relates to the adverse effects on trees due to the increased salinity in the irrigation water. As the ISIMND recognizes, recycled water contains more salt than typical irrigation water derived from potable supplies and this increased salt content can adversely affect trees such as coastal redwoods that are sensitive to salinity. Unfortunately, the ISIMND declines to make a significance finding on this critical issue. Given the importance of redwood trees to the City's urban landscape and to the appearance and value of the Stanford Research Park in particular (which the Recycled Water Project is designed to serve), the IS!N.fND should include a finding on whether the impact on trees from using high salinity irrigation water is significant. As discussed below, we believe the facts show that this is a significant impact. The ISIMND includes an Adaptive Management Program that is designed to detect and respond to adverse effects on trees, but there are significant concerns as to whether this program will adequately protect redwoods and other trees after they have already been exposed over time to high salinity irrigation water. The program also defers analysis of adverse impacts to a future date, and it is not clear whether the program is feasible given the extent and expense of the future studies that would be required. STANFORD REAL ESTATE OFFICE 2755 Sand Hill Road, Suite 100 • Menlo Park, CA 94025 'T: 650.926.0300' F: 650.854.9268 RE: Initial StudylMitigated Negative Declaration for Palo Alto Recycled Water Project April 17,2009 Page 2 Stanford's second concern relates to the facilities that the City plans to install at the Mayfield Soccer Fields. The IS/MND states that there will be no significant impacts resulting from these facilities based on the fact that the Project will be subject to the City's design review process in the future. The ISIMND should include a complete evaluation now of the aesthetic and land use impacts associated with locating Project facilities at the Mayfield Soccer Fields, and of any mitigation measures necessary to lessen those impacts, instead of deferring this evaluation to a future process that will only occur after the City has already approved the Project. Finally, the ISIMND relies on deferred mitigation for impacts to biological resources. The IS/MND should clarify the specific measures that will be used, so that their effectiveness can be fully evaluated before the Project is approved. Each of these concerns is discussed separately below. Stanford looks forward to working cooperatively with the City to resolve these issues. A. The Impacts Resulting from Increased Salinity Warrant a Finding of Significance and a More Complete Environmental Evaluation As the ISIMND recognizes, "[ r]ecycled water is characteristically higher in alkaline salts than typical irrigation water derived from potable supplies and may cause decline in acidic favoring tree species." ISIMND at p. 73. The ISIMND explains that even after inflow and infiltration controls to reduce the intrusion of salty groundwater into the sewer collection system, recycled water from the Palo Alto Regional Water Quality Control Plant would have a total dissolved solids of 700 milligrams per liter, as compared to 100- 300 mgll in the existing water supply. ld. at pp. 73, 76. The ISIMND further explains that a recent study "found that Palo Alto recycled water was the most saline recycled water studied." Id. at p. 75, fn.14 (citing Oster 2009). The ISIMND further recognizes that salts can build up in poorly drained soils. As the ISIMND explains: [SJalt buildup in poorly drained soil may create a long-tenn inability of the soil to absorb and provide water availability to the tree roots .... Because salts are not absorbed by the vegetation or broken down in the subsurface, they have the potential to build up in the root zone in poody drained soils and affect tree health. Id. at 73. In turn, soils with higher silt and clay content are more affected by salt buildup than other soils, because they are less well drained. See id. at p. 75 ("soils with higher silt and clay content are more affected by water quality than other soils"). For this reason, HortScience has recommended that "[uJse of recycled water should be avoided in areas of poor drainage, since those areas cannot be leached." Nelda Matheny and James R. Clark, Designing Landscapes Using Recycled Water (dated Nov. 17,2005) at p. 2. STANFORD REAL ESTATE OFFICE 2755 Sand Hill Road, Suite 100 • Menlo Park, CA 94025 'T; 650.926.0300 • F: 650.854.9268 RE: Initial StudylMitigated Negative Declaration for Palo Alto Recycled Water Project April 17, 2009 Page 3 This is a significant issue for the Stanford Research Park. Based on Stanford's experience with various projects at the Stanford Research Park, subsurface conditions consist of predominately moderately to highly expansive clays overlying interbedded layers of sands and clays, with the sand layers tending to contain clayey or silty fmes, In other words, the soils at the Stanford Research Park are the types of soil that are susceptible to salt buildup. Additionally, the ISIMND recognizes that certain tree species, such as coastal redwoods, are particularly sensitive to salinity. See, e.g., IS/MND at p. 75 (coastal redwoods are sensitive to total soil·water salinity regardless of the type of salt causing the salinity). HortScience explains generally that, as irrigation water is applied to soils, some of the salts in the water remain in the soiL "As these salts accumulate in the soil, plant toxicity may occur. Salt toxicity is first expressed as stunting of growth and yellowing of foliage. Burning of the edge ofleaves and defoliation usually occurs. In severe cases, plants are killed." Matheny and Clark, Designing Landscapes Using Recycled Water, at p. 2. Further, as Oster's recent study points out, "Coastal redwood is the primary plant species of concern. Observed leafburn and tree death have been associated with irrigation with recycled water, indicating coastal redwood is very sensitive to salinity, sodium, chloride or a combination of all three." Oster 2009, at p. 1. The 2007 study by Barnes et al. similarly explains: Sodium and chloride, two of the main constituents in the treated recycled water, have been suspected of causing the decline of redwood trees in the California South Bay Area where this water has been used to irrigate public landscapes such as parks and golf courses. Symptoms noted on some redwoods irrigated with recycled water include leaf necrosis and in severe cases, branch and whole tree death. Barnes et aI. 2007, at p. 2. The study concludes that "[t]he response of Sequoia sempervirens 'Aptos Blue' to the salinity treatments in this study indicates a cleat increase in detrimental effect with increasing treatment concentration." ld. at p. 26 (emphasis added). In an email communication to Stanford, Nelda Matheny of HortScience summarizes the problem as follows: [M]y experience with redwoods is that they are very sensitive to salts and usually begin to show toxicity symptoms within one to years of its application. Redwoods must be irrigated frequently because they have no drought tolerance. Each irrigation adds salt, and over time the salts in the soil accumulate to damaging concentrations. I have observed mature redwoods significantly damaged after 3 years of irrigation with recycled water. Email communication from Nelda Matheny to Jim Inglis (Apr. 17,2009). In addition to redwoods, HortSciences has identified a number of other salt sensitive plant species, such STANFORD REAL ESTATE OFFICE 2755 Sand Hill Road, Suite 100 • Menlo Park, CA 94025 'T: 650.926.0300 • F: 650.854.9268 RE: Initial StudylMitigated Negative Declaration for Palo Alto Recycled Water Project April 17,2009 Page 4 as Japanese maple, crape myrtle, southern magnolia, London plane, wisteria, etc., which may be harmed by use of recycled water. Matheny and Clark, Designing Landscapes Using Recycled Water, Table 3. The Stanford Research Park contains many redwoods and other plant species that could be negatively affected by high salinity irrigation water. Not surprisingly, the IS/MND recognizes that when trees are exposed to increased stress by an environmental change such as irrigation with recycled water with a higher salt content, "they may exhibit signs of decline." ISIMND at p. 75. The IS/MND further recognizes that "increased salt content in the recycled water and poor drainage could affect the biological health, appearance (dieback), or mortality of existing protected, street, and designated trees." ld. The ISIMND, however, declines to make a finding of significance regarding this impact, based on the statement that there is no definitive correlation between recycled water use and the decline in redwood trees. ld. at p. 74. Stanford does not believe this is a correct statement given the current state of the scientific evidence, which shows that increased salt content in irrigation water can have significant adverse effects on redwood trees. In any case, to the extent there are any disputes, uncertainties or unresolved issues in the scientific record, the matter should be resolved through the full EIR process, not through the adoption of a Negative Declaration. The IS/MND contains an Adaptive Management Program that is designed to detect and respond to adverse impacts to trees, but there are several concerns regarding the program's effectiveness and feasibility. First, the program is not proven and it is unclear whether the measures in the program will be effective. As explained in Oster's recent study, "[ w lith even the best management, excess salinities may not be preventable." Oster 2009, at p, Ii. As Nelda Matheny ofHortSciences explains: I do not think that it is possible to maintain healthy redwoods with recycled water containing high concentration of sodium and chloride using conventional techniques and water-conserving irrigation schedules. It may be possible with adjustments to management practices such as leaching, abundant inigation, and application of amendments to help leach salts. These modifications have yet to be tested in field applications. Email communication from Nelda Matheny to Jim Inglis (Apr. 17,2009) (emphasis added). For this reason, HortSciences recommends avoiding use of recycled water with salt sensitive species such as coastal redwoods. HortSciences recommends that if salt sensitive plantings cannot be avoided, irrigation of these plantings should use "separate systems providing potable water." Matheny and Clark, Designing Landscapes Using Recycled Water; at p. 5 & Table 3. Another recent publication on the use of recycled water for irrigation similarly explains that plant species should be selected that are more tolerant to salinity, as several tree species "did not grow well using reclaimed water, mainly because of the relatively high salinity leveL" Laosheng Wu et aI, Safe STANFORD REAL ESTA1E OffiCE 2755 Sand Hill Road, Suite 100 • Menlo Park, CA 94025 'T: 650.926.0300 • F: 650.854.9268 RE: Initial Study/Mitigated Negative Declaration for Palo Alto Recycled Water Project April 17,2009 Page 5 Application o/Reclaimed Water in the Southwestern United States (March 2009) (UC peer reviewedlPublication 8357), at p. 17. Another problem is that the Adaptive Management Program is designed to address salinity impacts only after redwoods and other landscaping have been exposed over time to high salinity irrigation water and adverse impacts have been observed. But by that time, the program may be too late to reverse the negative effects. As Oster's recent study notes, "[ s ]ince salinity damage to trees is difficult to reverse, it may be that a reduction in salinity of the applied water, once recycled water has been used for several years, will not be effective in saving trees." Oster 2009, at p. ii. Third, the program is based on future studies that are designed to determine whether the impacts on trees from high salinity irrigation water are adverse, how adverse those impacts are, and how the impacts will be mitigated. The ISIMND should not defer the evaluation of these important Project issues to a future date. Fourth, the program requires an expensive set of baseline, monitoring and landscape studies --all leading to a potential end result of ceasing recycled water use due to adverse effects on landscaping, or replacing trees that have died as a result of such adverse effects with salt tolerant species. This raises the question of who will pay for the studies and how they will be implemented --and more broadly whether the Adaptive Management Program would be an effective, cost-effective and feasible mitigation program to address the impacts on trees of high salinity irrigation water. A final concern with the analysis of salinity impacts is that the IS/MND does not evaluate the effects on creeks and biological resources, such as federally protected species, resulting from runoff of high salinity irrigation water. Matadero Creek mns through the Stanford Research Park site and the creek supports habitat for federally listed species. The ISIMND should fully evaluate these impacts in order to provide the public and the City with a complete and accurate picture of the Project's effects on the environment due to increased salinity. In sum, while Stanford fully supports the goal of reducing potable water use, this Project presents serious concerns in terms of its salinity impacts on trees and wildlife. The widespread death of redwood trees resulting from high salinity irrigation water would have a profound negative affect on the vitality and value of the Stanford Research Park, one of the nation's leading business parks. More importantly for CEQA purposes, the widespread loss of redwood trees would have a variety of significant environmental ramifications --including severe aesthetic impacts resulting from the loss of valued urban canopy; significant effects on the City's natural biological environment; conflicts with land use plans and policies that call for the protection of trees; and reduced absorption of C02, thereby leading to increased contributions to global climate change. STANFORD REAL ESTATE OFFICE 2755 Sand Hill Road, Suite 100 • Menlo Park, CA 94025 ·T: 650.926.0300 • F: 650.854.9268 RE: Initial StudylMitigated Negative Declaration for Palo Alto Recycled Water Project April 17, 2009 Page 6 B. The Aesthetic and Land Use Compatibility Impacts Resulting from the Booster Pump Station and Back-up Generator Warrant Further Evaluation in the ISIMND The ISIMND states that the visual character of the Mayfield Soccer Fields would be maintained, based on the fact that the booster pump station would be constructed underground and any aboveground structures "would go through architectural review during the design phase of the project and would satisfy the requirements of the Architectural Review Board." ISIMND at p. 39. But the architectural review process would not occur until after the City has approved the Project. Any impacts from an aesthetic or land use compatibility perspective associated with above-ground structures at the Mayfield Soccer Fields (including a back-up generator as well as any above-ground facilities needed to provide security or access) should be evaluated now as part of the CEQA review for this Project, instead of being deferred to a future process following Project approval. C. The ISIMND Should Clarify the Mitigation Measures for Impacts to Biological Resources To address the Project's impacts on biological resources) the ISIMND relies on several mitigation measures that are deferred. For example, the ISIMND provides that if red- legged frogs or western pond turtles are identified, the appropriate resources agency (the U.S, Fish & Wildlife Agency or the California Department ofFish & Game) will be consulted to detennine the extent of potential impacts and "to identify measures necessary to avoid, minimize, and mitigate these impacts, such as obtaining an incidental take permit (for CRLF) or developing an exclusion or relocation program." IS/MND at p. 57. It is not clear, however, what the mitigation measures will be and whether such measures (when they are developed) will be effective. Similarly, with respect to impacts on nesting birds, the ISIMND provides that if active nests are encountered, "species- specific measures shall be prepared by a qualified biologist) in coordination with the CDFG and other appropriate agencies." ld. Further, with respect to impacts on California clapper and black rails, the IS/MND states that upon the completion of surveys, "survey results shall be submitted to the USFWS and CDFG for a final decision on the possibility of doing work during the breeding season." ld. at p. 58. It would be helpful for the ISIMND to provide more specificity on the biological mitigation that would be implemented, D. Conclusion Stanford recognizes the challenges that our community faces in securing an adequate water supply and the clitical importance of water conservation for our community's future. Stanford is committed to water-saving practices and infrastructure throughout its planning and operations, This particular Project, however, raises several concerns that STANFORD REAL ESTA1E OFFICE 2755 Sand Hill Road, Suite 100 • Menlo Park, CA 94025 'T: 650.926.0300 • F: 650.854.9268 RE: Initial StudylMitigated Negative Declaration for Palo Alto Recycled Water Project Aprill?,2009 Page? warrant a more thorough evaluation, so that the public and the City can make an informed evaluation of the Project's adverse impacts on the environment; as compared to its benefits. We appreciate your consideration of these comments. Please feel free to contact us if you have any questions. Sincerely yours, William T. Phillips -l;~ ~ Senior Associate Vice President Director of Design & Construction Attachments STANFORD REAL ESTA 1E OFFICE 2755 Sand Hill Road, Suite 100 • Menlo Park, CA 94025 ·T: 650.926.0300 • F: 650.854.9268 Jim Inglis From: Sent: To: Nelda Matheny [Nelda@hortscience.com] Friday, April 17, 2009 8:13 AM Jim Inglis Subject: recycled water Hi Jim, Page 1 of 1 ---------------_._-------- I'm only in the office for a few minutes, so I haven't had time to put much together for you. Attached is a short manuscript about some of the issues with using recycled water in landscapes. As I mentioned on the phone, my experience with redwoods is that they are very sensitive to salts and usually begin to show toxicity symptoms within one to two years of its application. Redwoods must be irrigated frequently because they have no drought tolerance_ Each irrigation adds salt, and over time the salts in the soil accumulate to damaging concentrations. I have observed mature redwoods significantly damaged after 3 years of irrigation with recycled water. I do not think that is it possible to maintain healthy redwoods with recycled water containing high concentrations of sodium and chloride using conventional techniques and water-conserving irrigation schedules. It may be possible with adjustments to management practices such as leaching, abundant irrigation, and application of amendments to help leach salts. These modifications have yet to be tested in field applications_ As for coast live oak, it is quite tolerant of salt. Coast live oak can be maintained in a healthy condition when irrigated with recycled water. In general, drought tolerant species that require only infrequent irrigation are well suited for recycled water. Feel free to share this information and my opinions with others. Nelda Nelda Matheny HortScience, Inc. 2150 Rheem Dr., Suite A, Pleasanton CA 9254840211 4/17/2009 DESIGNING LANDSCAPES USING RECYCLED WATER by Nelda Matheny and James R. Clark HortScience, Inc. 2150 Rheem Dr., Suite A Pleasanton CA 84588 9254840211 Use of recycled water for landscape irrigation is increasing as supplies of potable water become limited. Recycled water can be an abundant source of inexpensive water or in some cases, the only source available for irrigation. Recycled water usually contains higher concentrations of some salts than potable (drinking) water. The maximum concentration of the salts is regulated by the state. However, those regulations are aimed at human and wildlife tolerances, not plant tolerances. Some plants are more sensitive to salts than animals and may be damaged when irrigated with water containing moderate to high salts. Assessing recycled water quality Water may contain ions or salts that are toxic to certain plants. While good quality water is suitable for use for irrigation of most any plant, poor quality water may inhibit plant growth or reduce health. For recycled water, the quality depends on the components of the water entering the treatment path, as well as the type of use before treatment. For instance, recycled water from municipal sources in which water softeners are used has a higher level of sodium than the water entering the system. During sewage treatment many of the inorganic compounds including salts and heavy metals are retained. Salts can be removed from recycled water through the process of reverse osmosis, although that is an advanced treatment that is not normally performed for water used in landscape irrigation. The quality of a given recycled water source may vary through the year. In California, the quality of recycled water usually is better during the rainy season (winter) than during the periods of summer and fall drought. Water quality data may be requested from the treatment facility, or sample may be collected and analyzed by a laboratory. When requesting water quality data from the treatment facility ask for the range in measurements in addition to the annual averages normally reported. Water quality reports usually emphasize constituents of concern for human health. In some cases additional testing may need to be performed. In the context of landscape irrigation, water quality refers to the presence and concentration of: total salts (TOS, ECw) as well as several specific ions (GI, Na, 8), bicarbonate, pH, trace elements and nutrients (N, P, K) (Table 1). Guidelines for interpreting water quality data are provided in Table 2. 1 Adapted from Matheny, N., and J. R. Clark. 199B. Managing landscape using recycled water. In: The Landscape Below Ground II. D. Neely and G, Watson, ed. International Society of Arboriculture. Champaign IL. ©HortScience. Inc. Designing Sites Using Recycled Water HortScience, Inc., Nov. 17, 2005 Page 2 Table 1: Constituents of recycled water that affect landscape plants and soils (After Pettigrove and Asano 1985) Constituent Measured Parameter Reason for Concern Dissolved inorganics Total dissolved solids Excessive salinity may damage some (TDS); electrical plants. Specific ions such as chloride, conductivity (Ecw); specific sodium, boron are toxic to some plants elements (Na, Ca, Mg, Cl, Sodium may pose soli permeability B) problems. Hydrogen ion activity pH The pH of water affects metal solubility (e.g. Fe, Mn, Zn, AI) as well as alkalinity of soils. Heavy metals Nutrients Residual chlorine Suspended solids Specific elements (e.g. Cd, Zn, Ni, Hg) Nitrogen, phosphorus, potassium _ Free and combined chlorine. Suspended solids Some heavy metals accumulated in the environment and are toxic to plants. Primary concern is for plants with high levels that are ingested by animals, N, P and K are essential nutrients for plant growth, and their presence normally enhances the value of water for irrigation. When discharged into the aquatic enVironment, Nand P can lead to the growth of undesirable aquatic life. When discharged in excessive amounts on land, N can lead to the pollution of groundwater. Excessive amounts of free available CI (.0.05 mg/L C12) may cause leaf·tip burn and damage sensitive plants. However, most chlorine in recycled water is in a combined form, which does not cause plant damage. Excessive amounts of suspended solids cause plugging in lrrigati()n sYS}..€::c.m.:..:.s::..:. __ Designing Sites Using Recycled Water HortScience, Inc., Nov. 17,2005 Page 3 Table 2: Interpretive guidelines for water quality for landscape irrigation. Species vary in tolerance to waler quality. The poorer the water, the more severe are restrictions on species use. (After Pettygrove and Asano, 1985) Parameter Salinity TDS, mg/I ECw, dS/m or mmho/cm Permeabilitya SAR Specific ion toxicitl Boron (B) (mg/I) Chloride (CI) Surface irrigation (mg/I) Sprinkler irrigation (mg/l) Sodium Surface irrigation (SAR) Sprinkler irrigation (mg/l) Miscellaneous effects Nitrogen (Total-N, mgll) Bicarbonate (HC03) Sprinkler irrigatIon pH Residual chlorine Sprinkler irrigation (mg/l) Water quality for landscape irrigation Good Fair <450 <07 6 <0.5 <140 <100 <3 <70 <5 <90 <1.0 450-2000 07-3.0 6-9 0.5-1.0 140-350 >100 3-9 >70 5-30 90-500 Normal range 6.5-8.4 1.0-5.0 >2000 >3.0 >9 >1.0 >350 >9 >30 >500 >5.0 a Permeability affects infiltration rate of water into the soil. Evaluate using ECw and SAR together. At a given SAR, infiltration rate increases as salinity (ECw) increases. b Plant sensitivity to specific ions varies widely. Total salts. Salinity is the most important measure of water quality for landscape plants. It is expressed as total dissolved solids (TDS) and electrical conductivity (ECw)' When water is applied to SOils, some of the salts in the water (notably Na, CI and 8) remain in the soil. As these salts accumulate in the soil, plant toxicity may occur. Salt toxicity is first expressed as stunting of growth and yellowing of foliage, Burning of the edge of the leaves and defoliation usually follows. In severe cases, plants are killed. The degree of the problem depends on the sensitivity of the plant to salts and the concentration of the accumulated salts in the soil. Specific ion toxicity. While salinity expresses the total salt content, 11: will not adequately identify potential toxicities from specific ions. Chloride (CI), sodium (Na) and boron (B) concentrations in recycled water can and often do cause injury to sensitive plants. Boron in particular must be evaluated independently of other salts. It is toxic in such low concentrations «1 ppm), that its presence will not be reflected in the general salinity measurement. Designing Sites Using Recycled Water HortScience, Inc, Nov. 17,2005 Page 4 Sodium and chloride concentrations are particularly important if irrigation will be supplied by sprinkler. Plants will absorb both ions through their foliage. Toxicity through foliar absorption will occur at much lower concentrations than through soil absorption, particularly under high evapotranspiration conditions. The toxicity symptoms of the specific ions are often difficult to distinguish from each other. Leaf chlorosis and marginal burning are typical. Necrosis associated with boron is often black in color and may appear as small spots near the leaf margin. As with salinity. plant tolerance to individual ions is highly species-specific. Some plants, like Indian hawthorn (Raphiolepis indica), can tolerate boron in excess of 7 ppm. Others like photinia (Photinia x Frasen) are injured at 05 ppm. Furthermore, a plant may be relatively tolerant of boron, but highly sensitive to chloride. Little information is available to help develop lists of sensitivity of plants to specific ions. The landscape manager must rely primarily on experience and observation. Sodium adsorption ratio. In addition to affecting plants directly. sodium can have negative effects on soil structure. It may cause dispersion of soil aggregates if present in high concentrations. This decreases both drainage and soil aeration which may cause plant decline and death. Soils high in clay are particularly susceptible to breakdown of aggregates by sodium. Sodium hazard to soils is usually assessed from the sodium adsorption ratio (SAR), a value calculated from the sodium, calcium and magnesium concentrations. However, the permeability problems that can be caused by a high SAR can be partially offset by salts in the water. A more accurate measure of potential problems in irrigation water is the adjusted sodium adsorption ratio (adj RNa) calculated from the salinity, bicarbonate, calcium, sodium and magnesium concentrations of the water. Bicarbonate. Bicarbonate affects plants through its influence on pH and interaction with sodium. High bicarbonate can cause iron chlorosis symptoms in plants. Water high in bicarbonate. carbonate and calcium and/or magnesium can result in a white precipitate forming on foliage under sprinkler irrigation. Irrigation hardware is also susceptible to damage from bicarbonates. The preCipitates can clog drip emitters. When bicarbonate combines with calcium or magnesium in soils, calcium carbonate and magnesium carbonate preCipitate out. Consequently the SAR of the soil increases, and permeability to water may become a problem. The bicarbonate hazard to soils can be evaluated by calculating the residual sodium carbonate (RSC). The RSC is the sum of the carbonate and bicarbonate ions minus the sum of calcium and magnesium ions. Water with an RSC>2.5 meqll can develop permeability problems. Heavy metals. Heavy metals are rarely present in water in sufficient quantities to be directly toxic to plants. However, most metals become tied up in the soil and their concentrations increase over time. Water quality criteria take the accumulation of the elements with many years of irrigation into account, and provide maximum concentrations with long-term use in mind. Effluent derived from domestic sources does not usually have problems with trace elements. Nutrients. One of the advantages of using recycled water for landscape irrigation is that it contains plant nutrients and reduces Ihe needs for application of fertilizer. Nitrogen (NH4• N03). phosphorus (P20s) and sulfur (S04) are the constituents of greatest benefit. Their concentrations are considered when evaluating recycled water to determine fertilization needs (Harivandi, 1988). Recycled water usually contains most of the micronutrients needed by plants. A negative aspect of this fertility involves storage of recycled water. Ponded nutrient-laden water develops algae and other aquatic weed problems more rapidly that potable water. Designing Sites Using Recycled Water HortScience, Inc .• Nov. 17. 2005 Page 5 Designing and managing landscapes irrigated with recycled water The potentiaf problems to plants and soils can be minimized in a variety of ways, including both management and design. All of the management techniques require monitoring soil chemical and moisture characteristics, as well as plant responses. The main concerns are salinity and pH .. In addition, monitor water quality regularly because constituents can vary seasonally. When designing new landscapes that will be irrigated with recycled water consider the following in the design: 1. Determine what the salt content of the recycled water will be. Check with the recycled water provider for a water analysis to determine concentrations of sodium, boron, and chloride. You may be able to access this information on the water agency's web site. 2. Avoid using salt-sensitive species. A list of species often damaged when irrigated with recycled water is provided in Table 3. If saft sensitive plantings cannot be avoided, irrigate on separate systems providing potable water. 3. Identify and solve drainage problems prior to planting. Good drainage is essential to using recycled water. Acljusting finish grades, eliminating hardpans and improving soil structure are methods to improve drainage. 4. Evaluate soil characteristics before planting. Soils should be tested for chemical and physical characteristics prior to planting to evaluate their suitability for irrigation with recycled water. Unfavorable conditions such as high sodium or chloride should be treated before planting to the. extent possible. When managing sites irrigated with recycled water, consider the following: 1. Minimize salt accumulation in the root zone. Minimizing salt accumulation is important to both avoid leaf burn and to avoid salt stress that can predispose plants to other problems. It is accomplished by leaching with heavy irrigations to flush accumulated salts below the roots. Annual rains may be adequate to maintain soil salinity within tolerable levels in some cases (heavy rainfaU, well- drained soil). Where soils are heavier, leaching with good quality water may be needed during the growing season to lower salt levels. Use of recycled water should be avoided in areas with poor drainage, since those areas cannot be leached. 2. Lower sodium concentrations in solis. If sodium concentrations become too high, drainage is impaired. Incorporating calcium (in the form of gypsum) into the soil and leaching can reclaim soil structure. Routine light applications of gypsum may be advantageous to avoid sodium problems. 3. Decrease fertilizer applications. Because recycled water contains significant amounts of nitrogen, phosphorus and potassium, applications of fertilizer can be reduced and in some instances, eliminated. 4. Increase irrigation frequency. Irrigation with recycled water should occur more frequently to dilute soil solutes, avoid water stress and minimize toxicity. 5. Moderate soil pH. Most plants tolerate a wide range in soil pH. As the pH of the soil begins to rise, however, acid-requiring plants may develop iron deficiency. Should chlorosis symptoms develop. the soil pH could be lowered by applying sulfur, or individual plants can be fertilized with iron to alleviate symptoms. 6. Monitor plant health. Additional stress factors caused by salts should be considered in the park's pest management program. Plant health must be monitored closely to identify stress-related problems that may develop. Some Designing Sites Using Recycled Water HortScience, Inc., Nov. 17,2005 Page 6 examples are bark beetles (Ips) on pines (Pinus), borers on alder (Alnus), and canker (Seridium cardinale) on cypress (Cupressus macrocarpa). 7. Monitor soil chemical changes. Soil conditions should be monitored through sampling programs to identify need leaching or other soil treatments. In most cases, soils should be sampled at the beginning and end of the irrigation period. Recycled water can be an abundant, cost-effective source for irrigation. The landscape designers and managers should consider the quality of the water, soil chemical and physical conditions and sensitivity of landscape species to water constituents when planning and managing landscapes irrigated with recycled water. Literature Cited Harivandi. Ali. 1988. Irrigation water qua/i1y and turf grass management. Calif. Turfgrass Culture. 38(3,4):1-4. Pettygrove, G. and T. Asano. 1985. Irrigation with Reclaimed Municipal Wastewater-A Guidance Manual. Lewis Publishers, Chelsea, ML Designing Sites Using Recycled Water HortScience, Inc., Nov. 17,2005 Pagel Table 3: Landscape species prone to damage when irrigated with water having moderate to high salt concentrations. Scientific name Acer japonica A/nus rhombifolia Alnus cordata Betula pendula Camelia jamponica Celtis sinensis Cinnamomun camphora Citrus spp. Clivia miniata Clytostoma callistegioides Cymbidium spp. Dicksonia antarctica Dietes iridioides Enobotrya japonica Escalfonia x exoniensis 'Fradesii' Eucalyptus ficifolia Euca/yptus nicolii Eucalyptus sideroxylon Euryops pectinatus Fragaria chi/oensis Gardenia angusta Geijera parv/flora Ginkgo bi/oba Howea fosteriana Hydrangea macrophylia /lex comuta 'Burford ii' Lagers/roemia indica Liquidambar styraciflua Liriope muscar! Lophostemon conferta (Tristania) Magnolia grandiflora Michelia champaca Morus alba Musa spp. Nandma domestica Nephrolepis spp. Philodendron Phoenix robe/enii Photinia fraseri Pinus thunberg;; Pinus torreyana Platanus x acer/folia Podocarpus graci/ior Podocarpus henkelii Podocarpus macrophyl/us Prunus cerasifera 'Atropururea' Prunus iIIicifolia Iyonii Quercus rubra Rhododendron sp. Rosa cultivars Common name Japanese maple White alder Italian alder European white birch Camelia Chinese hackberry Camphor Orange, lemon Clivia Violet trumpet vine Orchid Tasmamian tree fern Fortnight lily Loquat Escallonia Red-flowering gum Peppermint gum Red iron bark Euryops False strawberry Gardenia Australian willow Maidenhair tree Kantiapalm Hydrangea Burford hofly Crape myrtle Sweetgum Big blue lily turf Brisbane box Southern magnolia Charnpaca Mulberry Banana Heavenly bamboo Sword fern Philodendron Pygmy date palm Photinia Japanese black pine Torrey pine London plane Fern pine Long-leafed yellow wood Yew pine Purple leafed plum Catalina cherry Red oak Rhododendron Rose Designing Sites Using Recycled Water HortScience, Inc., Nov. 17, 2005 Page 8 Table 3: Landscape speci.es prone to damage when irrigated with water having moderate to high salt concentrations, continued. Scientific name Sequoia sempervirens Sarcococca ruscifolia Spathodea campanulata Sophora japonica Tabebuia sp. Tibouchina urvilleana Tifia cordata Viburnum tinus Wisteria sinensis Xylosma congestum lamia furfuracea lelkova serrata Common name Coast redwood Sweet box African tulip tree Japanese pagoda tree Trumpet tree Princess flower Little-leaf linden Viburnum Wisteria Xylosma Cardboard palm Zelkova -------------------------------------- Comment Letter 7 -Stanford University Response to Comment 7 ~1 The City acknowledges Stanford University's concerns about the use of recycled water as an irrigation source for certain types of trees and the effects of such use on the appearance and value of the Stanford Research Park. Responses to the University's individual concerns are provided below. Response to Comment 7-2 As described on page 1 of the Public Draft ISIMND, and reiterated in Section 1.2 of this Response to Comments document, the Palo Alto R WQCP and its member agencies prepared the Water Reclamation Master Plan for the Palo Alto R WQCP in 1992 and the accompanying Final Program EIR in 1995 (CH2MHill, 1995). The two main goals of the Master Plan were to: "1) reduce demand on drinking water supplies by providing recycled water suitable for non-potable uses and 2) reduce metal discharge and improve overall water quality to the San Francisco Bay in part by reducing wastewater discharge to the bay." The Master Plan included a phased approach to the expansion of treatment, distribution, storage, and use of recycled water and evaluated, at a program-level, development of a regional water reuse system that could ultimately provide service to the entire RWQCP service area including the cities of Palo Alto, Mountain View, Los Altos, East Palo Alto, Los Altos Hills, part of Menlo Park, as well as Stanford University. The Master Plan Program EIR addressed the environmental effects of the overall Water Reuse Program and included a focused, project-level review of one specific project the Foothill Main Project. "The Foothill Main Project would have established an initial distribution system running from the RWQCP to the Santa Cruz Mountain foothills, a storage reservoir in the foothills southwest of Stanford University, and the use of recycled water for landscape irrigation at Stanford, several city parks, and a highway interchange. The project was never built." Because the proposed project is one phase of the Master Plan, this Public Draft ISIMND tiers from the Master Plan Program EIR. Section 3.3, Salinity, soils, and Vegetation of the Master Plan Program ErR evaluates potential impacts to soils and vegetation from salinity and other reclaimed (recycled) water constituents at the proposed water use sites as a result of recycled water use as landscape irrigation. As indicated on page 3-13 of the Master Plan Program EIR, "there are no established numerical standards for determining whether the salinity in reclaimed water would cause significant environmental impacts as a result of using the water for landscape irrigation. The deleterious effects of using irrigation water with high salinity concentrations are usually seen through substantially diminished plant growth and possibly plant mortality. These effects are typically mitigated through water management programs and the replacement of less salt-tolerant species with more -salt tolerant species, such that the visual appearance of the landscape is not substantially altered. The periodic replacement of less salt-tolerant vegetation to more salt-tolerant species is typically not considered in itself to be a significant impact, as long as the salt-tolerant species remain healthy and are an aesthetically pleasing component of the landscape." Because of the lack of numeric thresholds, the Master Plan Program EIR identified qualitative thresholds for the following constituents: salinity, sodium, chloride, boron, and bicarbonate. The project evaluated impacts for both the Foothill Main Program as well as at a program level of detail. The conclusions are similar, as described below. The Master Plan Program ErR concluded that there would be beneficial, no, or less-than- significant impacts for the following associated with recycled water use: Palo Alto Recycled Water Project Page 17 Response to Comments Document • By using reclaimed water for landscape irrigation (which contains nutrients), the quantities of chemical fertilizers needed to maintain desirable vegetative growth would be reduced. As such, this would be a beneficial effect; • With the indicated electrical conductivity of the recycled water from the RWQCP, there would be little or no impact on the soils from sodium; • Due to their very low concentrations, constituents other than total salinity and sodium, including trace metals, would have no short-or long-term impacts on soils; and • The concentrations of boron and bicarbonate are not high enough to cause significant impacts on turf grasses or landscape plantings. The Master Plan Program EIR concluded potentially significant but mitigable impacts for the following: • The recycled water salinity concentration was determined not high enough to prevent the use of the reclaimed water for landscape irrigation, although it is high enough to potentially cause adverse impacts to some vegetation (e.g., reduction in growth and/or undesirable appearance from leaf damage). "Based on the available data, only very sensitive landscape species are likely to be affected. If such effect is realized to an unacceptable point, these species can be replaced with more tolerant species, which has been shown to be an acceptable mitigation measure and is a common practice in reclaimed water irrigation program" (page 3-19 of the Master Plan Program EIR). It was concluded that some degree of special management would be required in using the recycled water to control the effects of salinity and chloride on soils and vegetation and that with implementation of best management practices (BMPs) all of the impacts would be mitigated to a level of insignificance. Pages 3-20 and 3-21 of the Master Plan Program EIR identify Mitigation Measure 3.2-1, which would reduce potentially significant impacts to a level of Insignificance. The measure would require the following: • that recycled water users apply recycled water in quantities sufficient to leach accumulated salts through the root zone; • that recycled water users monitor the effects of the recycled water on landscape vegetation over time; • that recycled water users take additional actions as necessary: o adequate leaching can be accomplished by regularly applying about 15 to 20 percent more water than the evapotranspiration requirement of the turf during normal irrigation, applying two or three extra heavy irrigations during non-wet years; o providing good subsurface and surface drainage; and o employment of appropriate management practices. • Mitigation Measure 3.2-1 further states that the implementation of best irrigation water management practices should incorporate the following activities: o Provide proper training and information regarding recycled water use (provided by the RWQCP to all recycled water use site managers; Palo Alto Recycled Water Project Response to Comments Document o Apply appropriate quantities of irrigation water to ensure leaching and maintain adequate surface drainage by recycled water use site managers; o Monitor the health and appearance of vegetation being irrigated with recycled water to identifY any adverse effects (e.g., reduction in growth or plant death) by recycled water use site ground keepers; and o Implement other measures as needed, including, for example, one or more of the following: • • • Irrigate affected areas during nighttime hours; Add soil amendments to the soil or the reclaimed water; Replace salt-intolerant plants with salt-tolerant species; • Blend the reclaimed water with potable water or nonpotable groundwater. It should be noted that when the evaluation was completed in the early 1990s, the salinity of the recycled water, as represented by its electrical conductivity, or EC, was much higher than the levels that will be delivered during implementation of the proposed project (previously 1.6 mmho/cm compared to 1.09 dS/m = 1.09 mmho/cm). Similarly, the sodium and chloride levels have reduced since the early 1990s. The effects of recycled water use for irrigating landscape vegetation were addressed in the Master Plan Program EIR, as described above. The project as previously analyzed in the Master Plan Program ElR, with the elevated concentrations of salinity, sodium, and chloride compared to the concentrations of the current recycled water, were determined to be potentially significant, but would be reduced to a level of insignificance with implementation of Mitigation Measure 3.2-1 of the Master Plan Program EIR. Because the Master Plan Program EIR has adequately addressed this issue, a project-specific EIR would not need to be prepared to reevaluate this issue. The City has taken the information provided in the Master Plan Program EIR and the adopted mitigation measure that would reduce potential effects of recycled water use to a level of insignificance and integrated them into the Project Description as an Adaptive Management Program (further described below and in the response to Comment 7-3). The framework of the Adaptive Management Program is consistent with Mitigation Measure 3.2-1 of the Master Plan Program EIR. In addition, the City has provided more up-to-date information regarding salinity and redwood trees. However, the conclusions of these studies would not change the conclusions regarding this impact. Since the certification and approval of the Master Plan Program EIR, some new infonnation has been developed regarding the use of recycled water on redwood trees. Because the City is concerned about its regulated trees\ it has developed a project that proactively addresses public concern and discloses the scientific data available regarding the issue of recycled water use for irrigation. As described on page 73 of the Public Draft ISIMND, "City staff investigated public concerns regarding the use of recycled water when applied globally as the primary source of irrigation for existing trees. The City's review did not determine conclusively that recycled water use was responsible for the decline of trees, although recycled water represents a change in irrigation strategy that could pose challenges for specific tree species, particularly Redwoods and possibly other trees requiring favorable acidic soil conditions for health." Due to the lack of definite correlation that linked the decline and/or loss of trees to recycled water use, the lack of "quantitative thresholds to evaluate the effects of recycled water use from this project on redwood 3 Regulated Trees identified in the Tree Technical Manual include the following: protected trees, street trees and designated trees. Please see the response to Comment 7-3 for definitions of these trees. Palo Alto Recycled Water Project Page 19 Response to Comments Document trees and the multitude of factors that can contribute to such declines of redwood trees," this impact was not found to be significant. In response to the commenter's concern about subsurface conditions of Stanford lands, it should be further noted that soils throughout the project area were classified in terms of their suitability to receive recycled water. As stated on page 3-12 of the Master Plan Program EIR, "(t]he classification scheme considered five soil characteristics as criteria, including surface permeability, subsurface permeability, root penetration, occurrence of high water table, and occurrence of alkali, all of which relate to the ability of the soil to carry salts in the irrigation water below the root zone. Using these criteria, the Master Plan identified and mapped areas with three soils classes, including good ("no problem anticipated"); fair ("may require some special management practices in some cases"); and very poor ("difficulties anticipated, very likely required management practices and some sites may be unsuitable")." " ... Most of the entire program area (Stanford Research Park included] covers soils classified as either good or fair for reclaimed water irrigation by Master Plan. A relatively narrow band of soils at the northeastern border of the program area, bordering the San Francisco Bay, was the only area with soils identified as very poor for water irrigation" (page 3-12 of the Master Plan Program EIR). As part of public disclosure, the Public Draft ISIMND acknowledges the variety of factors that can contribute to the health of redwood trees. This includes water quality, salt-sensitivity of plants in the landscape, soil characteristics, and irrigation management. In addition, other agents that can cause decline in redwood trees include climatic factors, fungal pathogens, and other diseases. "Redwood trees are native to cool, foggy coastal areas in forest situations where the conditions differ drastically from those planted in the Bay Area landscape" (page 74 of the Public Draft ISIMND). As such, they may be sensitive to salinity. It should be noted that "there have been reports of decline in redwoods throughout California in landscapes irrigated with both potable and recycled water (Downer 2004 as cited in HortScience, Inc 2005)" (page 73 of the Public Draft ISIMND) Given this information, the correlation between decline of redwood trees and the use of recycled water is unclear. As concluded by Barnes et al., 2007 (p. 27), "it is clear that redwoods can tolerate EC values in the range typical for recycled waters if irrigation is properly managed." Given the reasons described above, a separate EIR would not need to be prepared. The issue was adequately analyzed in the Master Plan Program EIR, and further addressed in the Public Draft ISIMND. The Public Draft IS/MND has also integrated into its project description an Adaptive Management Program that is consistent with the Master Plan Program ErR Mitigation Measure 3.2-1 that was adopted to reduce the potential effects of recycled water use to a level of insignificance. No change in the discussions of salinity and recycled water effects to redwood trees are warranted in the Public Draft ISIMND. Thus, by including the Adaptive Management Program, the City is complying with CEQ A Guideline Section lS168(c)(3), which requires incorporation of prior mitigation measures into later activities. It should be noted that the State Water Resources Control Board adopted a statewide Recycled Water Policy on February 3,2009 to establish uniform requirements for the use of recycled water. As stated in the policy, "(t]he State Water Board finds that the use of recycled water in accordance with this Policy, that is, which supports the sustainable use of groundwater andlor surface water, which is sufficiently treated so as not to adversely impact public health or the environment and which ideally substitutes for use of potable water, is presumed to have a beneficial impact. Other public agencies are encouraged to use this presumption in evaluating the impacts of recycled water projects on the environment as required by the California Environmental Quality Act (CEQA)." It should also be noted that although the Policy encourages Palo Alto Recycled Project Response to Document public agencies to presume the beneficial effect of recycled water, the Public Draft ISIMND for this project does not make that assumption. Rather, it provides disclosure of the issue related to recycled water use and integrates a proactive and precautionary approach that addresses concerns if they materialize. To further allay the commenter's concern about the potential effects of recycled water use on its trees, the City will propose to modifY Chapter 16.12, Recycled Water, of the City of Palo Alto Municipal Code that requires the use of recycled water for landscape irrigation, such that recycled water is not mandated for use on Redwood trees. The change will allow individual users to decide whether to take the "risk" described by the Commenter. This approach was taken in Phase 2 of the Master Plan Program in Mountain View. Response to Comment 7-3 To show the City's commitment to preserve the community's tree canopy, the City has taken a proactive, precautionary approach to avoid potential effects, if any, that could occur associated with the use of recycled water. "As described on page 17 of the Public Draft ISIMND, "[t]o maximize the use of recycled water for irrigation in combination with responsibly maintaining the urban forest canopy, the City has developed the Adaptive Management Program (Program)." The Program is described on pages 17 19 of the Public Draft ISIMND and its components reiterated in the response to Comment 3-3 above. The Program is designed such that it can be adapted to address any potential issues that may arise. Due to the differing conditions of the recycled water service area, a management approach that has a set framework but allows for flexibility in responding to site-specific conditions is appropriate. The annual monitoring required as part of the project would allow for continuous observation/inspection of changes that may occur from baseline conditions at individual sites during the life of recycled water irrigation. Although the Program has not yet been developed in full, it is the intent of the City to work with a consulting or registered arborist or horticulturalist to develop the details of a plan that is feasible and can be implemented by the Participants (City and recycled water users). The details of the Program will include Best Management Practices that can be implemented in the event any triggers (e.g., symptoms of decline) are observed. This adaptive approach would allow for multi-tier responses to the changed condition, such as adjustments to the irrigation strategy, modifications to the drainage systems, modifications of the landscape palette, or even the ultimate cessation of recycled water irrigation application as needed if decline symptoms appear. It should be noted that the Adaptive Management considers both the City's Tree Ordinance and the Tree Technical Manual to guide the protection of the City's trees. The goal of the Program would be to protect regulated trees identified in the City's Tree Ordinance, including the following: • Protected Trees: All Coast Live Oak, Quercus agrifolia, Valley Oak, Quercus lobata trees that are 11.5-inches or greater in diameter (36-inches in circumference measured at 54- inches above natural grade) and Coast Redwood, Sequoia sempervirens trees that are 18- inches or greater in diameter (57-inches in circumference measured at 54-inches above natural grade) and Heritage Trees, individual trees of any size or species designated as such by City Council per the Palo Alto Municipal Code (PAMC) Section 8.10. • Street Trees: All trees growing within the street right-of-way (publicly-owned), outside of private property. In some cases, property lines lie several feet behind the sidewalks. A permit from the Public Works Department is required prior to any work on or within the dripline of any 'street tree' per PAMC Section 8.04. • Designated Trees: All trees, when associated with a development project, that are specifically designated by the City to be saved and protected on a public or private property which is subject to a discretionary development review per PAMC Section 18.76. Palo Alto Recycled Water Project Page 21 Response to Comments Document To more specifically respond to the commenter's statement "that the Adaptive Management Program is designed to address salinity impacts only after redwoods and other landscaping have been exposed over time to high salinity irrigation water and adverse impacts have been observed" (p. 5), the City would like to clarify that there would be sufficient time prior to implementation of the project (i.e., before recycled water use is initiated) for Participants to perform any necessary, preventative actions (as appropriate) to prepare for receiving recycled water. Implementation of the project is anticipated to take at least two to three years, but the development of the Adaptive Management Program could start right away. Since time is available, the envisioned baseline assessment (i.e., site-specific Baseline Conditions Report) could be conducted early on so that Participants can make individual decisions on whether any of the BMPs identified in the Program should be implemented ahead of recycled water application. This would address the commenter's issue of not wanting to wait for signs of decline before acting appropriately. If, based on baseline conditions report or other data, Participants feel that the BMPs will not be sufficient in certain situations, they can request an exemption (Section 16.12.050 of the Ordinance) from the requirement to apply recycled water to Redwood trees or similarly salt- sensitive species. The exemption process is an appropriate forum for property owners to establish that the record demonstrates the use of recycled water would harm Redwood trees or similarly salt-sensitive species at specific sites. The exemption process can be utilized to deal with the Redwood tree concern and the concern for similar species and landscaping. Staff anticipates that the RWQCP's efforts to reduce salinity levels in the recycled water will, in time, reduce the salinity level of the recycled water to that comparable to the best local groundwater. Currently, saline groundwater is entering sewer lines and increasing salinity levels in the recycled water. The R WQCP is working with its partner agencies to eliminate the infiltration of saline water wherever possible. As part of Program development, the issue of responsibility and cost to implement the Program will be determined (see also Comment 3-4). As an emphasis, it should be noted that the Program incorporates a precautionary approach to avoid potential impacts, if any, that may result from recycled water use. Response to Comment 7-4 The use of recycled water is not anticipated to affect creeks and other biological resources, such as federally protected species, resulting from runoff of high salinity irrigation water. DPH requirements that are applicable to the proposed Project to protect public health would be also be relevant to protect creeks and biological resources. The general requirements included in Title 22, Article 4, Section 60310 -Use Area Requirements focus on application and management specifications for various water uses. As identified on page 72 of the Public Draft IS/MND, one of the general requirements is as follows: "Prohibition of the over-application of any direct runoff of applied recycled water (recycled water would be applied to landscaped areas at agronomic rates to meet evapotransporation requirements, which minimizes surface runoff). It should be noted that page 3-17 of the Master Plan Program EIR states that "a leaching fraction of approximately 20 percent can typically ensure adequate leaching. This level of leaching fraction can be maintained without excessive surface runoff." As such, runoff of high salinity irrigation water and subsequent effects on receiving water bodies and other biological resources are not anticipated. Palo Alto Recycled Water Project Page 22 Response to Comments Document Response to Comment 7·5 As described on page 17 of the Public Draft MND, "The City of Palo Alto recognizes that the community tree canopy on private and public property is highly valued for its aesthetic qualities and environmental benefits" and thus incorporated the Adaptive Management Program into the project. The purpose of the Program is to prevent such an instance by taking appropriate actions when first signs of symptoms occur. The incorporation of the Program is intended to avoid effects of recycled water on visual and biological resources (see pages 38 to 39, and 55 of the Public Draft IS/MND). As such, Project implementation would not conflict with land use plans and policies that call for the protection of trees. Participants would still be required to comply with the Tree Ordinance and the Tree Technical Manual in preserving protected trees andlor replacing non-protected, street trees. Therefore, the City does not anticipate the widespread death of redwood trees resulting from the use of recycled water. Response to Comment 7·6 While the Public Draft ISIMND adequately evaluates the project's effects on the visual environment, once the Project is approved, additional CEQA review will be completed as part of the Architectural Review Board (ARB) process. Projects within the City that follow the Architectural Review Board (ARB) process would result in a less-than-significant impact. The ARB is charged with design review of all new construction, and changes and additions to commercial, industrial and multiple-family projects. Relevant goals and purposes of ARB include: • Promote orderly and harmonious development of the City • Promote visual environments which are of high aesthetic quality and variety and which, at the same time, are considerate of each other. The ARB Application Review Process is rigorous and first requires City staff review of the project for compliance with City standards and consistency with the City of Palo Alto Municipal Code, Zoning Ordinance, Architectural Review Board Ordinance, and other regulations and guidelines. Thereafter, ARB considers the project at a public hearing to approve the Project, approve the project with conditions, continue the project to another ARB meeting, or deny the project. The ARB process is applied consistently for all projects within the City with standards that ensure the protection of the visual character of the City. As such, further evaluation, if required, will be completed during the ARB process. Response to Comment 7-7 As noted in the Public Draft IS/MND, page 49, trenchless construction would be used to install the pipeline at creek crossings, thereby avoiding impacts to habitat for California red-legged frog (CRLF) and western pond turtle (WPT). However, some in-channel work may be needed for the pipeline crossing at Adobe Creek due to the limited accessibility of the side of the overpass to which the pipeline would attach. This location has been evaluated and the potential for occurrence of CRLF and WTP is considered low because then channel is unvegetated and concrete-lined. Nevertheless Mitigation Measure BIO-l requires that construction of the crossing be limited to the dry season when flows are reduced and CRLF and WTP are unlikely to be present. Mitigation Measure BIO-2 also would require preconstruction surveys be conducted if in-channel work is needed at Adobe Creek, and lays out procedures to be followed in the unlikely event that either CRLF or WTP are found in the construction area. Thus, the mitigation is clear on the measures that would be employed by specifically identifying that either an exclusion or relocation program would be implemented in coordination with the appropriate resources agency. Palo Alto Recycled Water Project Page 23 Response to Comments Document Mitigation that includes removal and exclusion is generally standard practice, which was included by the U.S. Fish and Wildlife Service in their Programmatic Biological Opinion for impacts to California red-legged frog (USFWS 1999). The mitigation measure for the protection of nesting birds has been identified. While it is correct that the Public Draft IS/MND states that species specific measures would be developed in consultation with appropriate agencies, Mitigation Measure BIO-3 specifically describes the actions that would be included. As noted on page 57 of the Public Draft IS/MND, "At a minimum, construction activities in the vicinity of nests shall be deferred until the young have fledged and an exclusion buffer zone shall be established. CDFG typically recommends a minimum exclusion buffer of 25 feet for songbird nests, and 200 to 500 feet for raptor nests, depending on the species and location. The perimeter of the nest-setback zone shall be fenced or adequate demarcated with staked flagging at 20-foot intervals, and construction personnel shall be restricted from the area." The mitigation measure goes on to identify reporting requirements. As such, this measure provides specific mitigation for nesting birds. Regarding mitigation for California clapper rails and black rails, specific mitigation is provided in Mitigation Measure BIO-4. For example, conducting construction outside of the breeding season or starting construction prior to the breeding season to prevent birds from establishing nests in surrounding habitat are included as part of the mitigation measure. If it is not feasible to conduct work according to this schedule, then preconstruction surveys would be completed. If, based on the survey, USFWS and CDFG do not agree that work can be conducted during the breeding season, then construction of the portion of the pipeline east of US-1 0 1 would not start until after the end of the breeding season. As such, mitigation measures for biological resources have not been deferred. Clear, implementable mitigation measures are presented in the Public Draft ISIMND. These mitigation measures are included in the MMRP that is a condition of approval for the proposed project. No changes to the mitigation measures are necessary. Response to Comment 7-8 The City has adequately disclosed and evaluated potential issues associated with implementation of the proposed project. The City has incorporated into the Project an Adaptive Management Plan and as relevant, included mitigation measure to address such issues. Palo Alto Recycled Water Project Response to Comments Document 3. IS/MND Revisions Staff-Initiated Text Changes The following changes in the text of the Public Draft ISIMND were made by City of Palo Alto staff. Clapper Rail Mitigation Section D, Biological Resources, of the Public Draft ISIMND evaluates the potential for clapper and black rails to occur within the project area and identifies survey requirements in Mitigation Measure BIO-4 to address potential impacts. Specifically, it states that "protocol-level surveys are only necessary during the installation of the pipeline east of US-lO 1" but does not callout specific requirements for the proposed pump station at the RWQCP. A staff-initiated change has been made to clarify this mitigation. As discussed on page 51 of the Public Draft ISIMND, "[p ]otential foraging and nesting habitat for clapper rails does not occur in much of the study area. However, the RWQCP is located within the Baylands Preserve, which contains northern coastal salt marsh habitat that supports potential habitat for clapper rails. There are several occurrences of clapper rail recorded in the CNDDB within a five-mile radius of the Project...the potential for construction-related activities to adversely affect clapper rails is considered low given the existing levels of human-related disturbances [e.g., operation of the RWQCP, and foot and bicycle traffic on nearby trails] in the Project vicinity, but the USFWS and CDFG typically recommend surveys be conducted for projects within 700 ft of potential nesting habitat to avoid disturbance of clapper rails during the nesting season (Browning, 2006)." Because the potential for construction-related activities to adversely affect clapper rails is considered low given the existing levels of human-related disturbances, it should be clarified that although protocol-level surveys are not required for the proposed pump station at the RWQCB, a pre-construction survey for clapper rails would be needed during the nesting season if construction occurred within 700 feet of potential clapper rail nesting habitat, and construction did not begin before the start of the nesting season. Revisions to Mitigation BIO-4 are shown below. BIO-4: Avoid disturbing nesting California clapper and black rails during the installation ofthe pipeline in alignment Option 1 or alignment Option 2 east ofUS-lOl and construction ofthe pump station at the RWQCP. To avoid substantial adverse effects to nesting California clapper rails and black rails, installation of alignment Option 1 or alignment Option 2 east of US-I Oland construction of the pump station at the RWQCP should either be conducted outside of the breeding season for clapper rails (in general, February 1st through August 31st) or construction activities east ofUS-IOI and at the RWQCP site should be started prior to the breeding season and disturbance activities continued throughout the spring to prevent birds from establishing nests in surrounding habitats. This would prevent abandonment of eggs or young that could occur if nesting establishes prior to construction activities. If this is not feasible, a qualified biologist shall conduct the following: 1) protocol-level surveys for clapper rails (following methods outlined in the Draft Survey Protocol: California Clapper Rail (Rallus longistrostris obsoletus)(USFWS 2000) for Option 1 or 2 pipeline alignments east of US-lOI; 2) pre-construction survey for the California Clapper Rail for construction at the proposed RWOCP within 700 feet of potential nesting habitat; and 3) pre- construction surveys for Califol11ia black rail to determine presence or absence of rail breeding activity in the vicinity of the Project. A qualified biologist is an individual who has experience conducting protocol-level surveys for California clapper rails, and experience surveying for Palo Alto Recycled Water Project Page 25 Response to Comments Document California black rails using a standardized tape call-back response protocol. Prior to commencement of the surveys for Option 1 or 2 pipeline alignments east of US-1 0 1, the biologist shall prepare a brief letter report describing the survey design and submit it to the USFWS (for California clapper rail only) and CDFG for review and approval. Upon the completion of the surveys, survey results shall be submitted to the USFWS and CDFG for a final decision on the possibility of doing work during the breeding season for the clapper and black rail. Protocol-level surveys are only necessary during the installation of the pipeline east of US-1 01. If construction activities east of US-10 1 are conducted outside the breeding season, no surveys would be necessary. Additional Footnote The following footnote is added to page 73 of the Public Draft ISIMND, as footnote 12, All subsequent footnotes would be renumbered accordingly. City staff investigated~ub1ic concerns regarding the use of recycled water when applied globally as the primary source of irrigation for existing trees,. The City's review did not determine conclusively that recycled water use was responsible for the decline of trees, although recycled water represents a change in irrigation strategy that could pose challenges for specific tree species, particularly Redwoods and possibly other trees requiring favorable acidic soil conditions for health. 12 "Mr. Dockter et al. Fall 2008 reconnaissance of recycled water sites in four cities. Various degrees of tree decline (redwoods and other conifers) symptomatic of recycled water use in poorly drained soils were observed. October 28, 2008 sites: Pac Trust, 2000 Wyatt Dr, Santa Clara. Washington Wilson School; 1840 Benton, Santa Clara. Present were, Dave Dockter, Environmental Planner, Barrie Coate (Barrie Coate & Associates), Michael Santos CHortScience, Inc.), Brian Bagley, (The Villages Golf & Country Club Facilities). Catherine Martineau, (Canopy Director), Susan Rosenberg, (Canopy Board Member). October 29,2008, Mr. Dockter reviewed the Greer Park, Palo Alto site. November 1, 2008 Mr. Dockter reviewed the sites at Fairchild Imaging 1801-1851 McCarthy Boulevard, Milpitas and 1215 Borregas Drive, Sunnyvale." Changes in Response to Public Comments The following changes have been made in response to comments from the public. Please refer to the individual comments for the explanation of the change. 1. The following revisions have been made to the Potential Permits and Approvals Required section on page 25 of the Public Draft ISIMND o Caltrans -Encroachment Permit and Transportation Permit; o Santa Clara Valley Water District (SCVWD) -permit for construction across creeks I flood control channels, easement to construct the pipeline in SCVWD right-of-way and a permit prior to construction for destruction of any well or construction of any new well, including monitoring wells. o Santa Clara Valley Transportation Authority -Construction Access Permit if construction involved cutting through a VT A PCC bus stop pavement pad. 2. First paragraph on page 20 of the Public Draft IS/MND is revised as follows: In accordance with CEQA Section 15064.5, if cultural resources are encountered during Project-related excavations, construction shall be halted or diverted to allow an Palo Alto Recycled Water Project Page 26 Response to Comments Document archaeologist an opportunity to assess the resource. The archaeologist will recommend what action, if anv, is warranted. Measures might include preserving in situ the archaeological resource or an archaeological monitoring or data recovery program. Prehistoric archaeological site indicators include chipped chert and obsidian tools, and tool manufacturing waste flakes, grinding implements such as mortars and pestles, and darkened soil that contains dietary debris such as bone fragments and shellfish remains. Historic site indicators include, but are not limited to, ceramics, glass, wood, bone, and metal remains. 3. A third bullet item has been added to the end of the Adaptive Management Program on page 19 of the Public Draft ISIMND to address groundwater issues. The City will coordinate with Santa Clara Valley Water District to monitor water quality in the groundwater basin to assess any potential changes associated with project use of recycled water. Monitoring activities will be coordinated with the future salinity and nutrient management plan, to be developed for the Santa Clara Valley Groundwater Basin in accordance with the State Recycled Water Policy (adopted in 2009). Palo Alto Recycled Water Project Page 27 Response to Comments Document References California Regional Water Quality Control Board, San Francisco Bay Region. 2003. A Comprehensive Groundwater Protection Evaluation for the South San Francisco Bay Basins. May. Santa Clara Valley Water District. 2004. Advanced Recycled Water Treatment Feasibility Project. August. State Water Resources Control Board. 1968. Resolution 68-16: State of Policy with Respect to Maintaining High Quality of Waters in California. Xu, J., W. Chen, L. Wu, R. Green and A.C. Chang. 2008. Leaching of Pharmaceutical and Personal Care Products (PPCPs) and Disinfection By-Products (DBPs) in Turfgrass Soils Irrigated with Reclaimed Water. University of California, Riverside, Department of Environmental Sciences. Palo Alto Recycled Water Project Page 28 Response to Comments Document Appendix A -Mitigation Monitoring and Reporting Program City of Palo Alto Recycled Water Project Mitigation Monitoring and Reporting Program May 2009 The following is a summary of mitigation measures integrated into the project which are adequate to reduce all potentially significant impacts to a less-than-significant level. The MMRP is organized in a table format, keyed to each significant impact and each mitigation measure incorporated into the project The tables following each measure provide a breakdown of how mitigation measures would be implemented, who would be responsible, and when it would occur. They consist of four column headings which are defined as follows: • Implementation Procedure: If needed, this column provides additional information on how the mitigation measure will be implemented. • Monitoring and Reporting Actions: This column contains an outline of the appropriate steps to verifY compliance with the mitigation measure. • Monitoring Responsibility: This column contains an assignment of responsibility for the monitoring and reporting tasks. • Monitoring Schedule: The general schedule for conducting each monitoring and reporting task, identifYing where appropriate both the timing and frequency of the action. A. BIOLOGICAL RESOURCES BIO-l: Creek Protection. The following measures would be implemented to avoid, minimize, or otherwise offset potential adverse effects to California red-legged frogs (CRLF) and Western pond turtles (WPT), and their habitats prior to and during the installation of the sections of pipeline crossing Adobe Creek at US-lOI, Matadero Creek at Hillview Avenue, and Barron Creek at Miranda Avenue. These measures are not applicable to Adobe Creek at Middlefield Road as no suitable habitat is present. • A SWPPP that complies with the statewide General Permit administered by the California State Water Resources Control Board for the National Pollutant Discharge Elimination System (NPDES) shall be developed and implemented to protect the water quality of the creeks that lie in the study area. Appropriate erosion and sediment control and non-sediment pollution control (i.e., sources of pollution generated by construction equipment and material) Best Management Practices (BMP) shall be prescribed in the Stormwater Pollution Prevention Plan (SWPPP), and erosion and sediment control material included in the SWPPP shall be celtified as weed free. • Construction activities associated with the installation of the sections of pipeline crossing Adobe Creek at US-JOI, Matadero Creek at Hillview Avenue, and Barron Creek at Miranda Avenue shall be limited to the dry season (in general, between June 15th through October 15th) when flows are reduced and CRLF and WPT are least likely to be present. • A qualified biologist shall conduct a worker education program prior to the onset of construction activities associated with the installation of the sections of pipeline crossing Adobe Creek at US- 101, Matadero Creek at Hillview A venue, and Barron Creek at Miranda Avenue. Construction workers shall be briefed on, at a minimum, a description of the CRLF and WPT and their habitats, the general measures that are being implemented to conserve CRLF and WPT for the Project, and the boundaries within which the creek crossing may be accomplished. A fact sheet conveying this information shall also be prepared for distribution to the workers. • A qualified biologist shall be retained to monitor the construction activities associated with the installation of the sections of pipeline crossing Adobe Creek at US-lO 1, Matadero Creek at Hillview A venue, and Barron Creek at Miranda A venue. The biologist shall have expertise in the areas of CRLF and WPT biology and ecology, amphibian and reptiles/habitat relationships, and biological monitoring. The biologist shall also monitor performance of construction site management practices for the purpose of identifYing and recommending measures to avoid any condition that could adversely affect CRLF and WPT or their habitat. The City and their contractor, upon notification from the biologist, shall halt activities causing the condition affecting CRLF and WTP or their habitat. Work shall only resume with approval from the biologist. • Food and food-related trash items associated with construction workers shall be enclosed in sealed containers and regularly removed from the work area to deter potential predators. • All staging areas and fueling and maintenance of vehicles and other equipment shall occur at least 60 feet from any riparian habitat, creek, or other water body to ensure that habitat contamination does not occur from such activities. IMPLEMENTATION MONITORING AND ! MONITORING MONITORING PROCEDURE REPORTING ACTIONS RESPONSIBILITY SCHEDULE The Director of the Utilities The Director of Planning and Director of Planning and Prior to and during Department incorporates into Community Environment Community Environment construction. contractor sped fications the reviews contractor requirement to prepare and specifications. Retain a copy implement a SWPPP. of the SWPPP in the Project file and at the construction : site. The Director of the Utilities The Director of Planning and Director of Planning and Prior to construction Department includes Community Environment Community Environment construction period limitations reviews construction and other requirements in specifications. contractor specifications and procedures. Qualified biologist appointed The Director of Planning and Director of Planning and Prior to construction by the Director of the Utilities Community Environment. Community Environment Department conducts a worker All worker education education program informing program material is included workers about location of in the Project file. CRLF and WPT habitats, general habitat conservation measures, and allowable boundaries for the creek crossing. Contractor implements Sign-off by qualified Director of Planning and During construction measures in the program. biologist that measures are rommllnitv Environment 'U1~ Retain and allaJifi~d IllUlllLUI I BIO-2: Conduct surveys for CRLF and WPT prior to the installation of the section of pipeline crossing Adobe Creek at Hwy 101, and avoid impacts to CRLF and WPT, if present. If the Adobe Creek crossing at Hwy 101 requires in-channel work, a qualified biologist shall conduct pre- construction surveys following standard visual encounter techniques to confinn presence or absence of CRLFs and WPTs in the work area. At minimum, the biologist shall be familiar with distinguishing physical characteristics of all the life stages of the CRLF, and identifYing WPTs. The biologist shall conduct at least one day and one night survey within one week of construction activities. Surveys shall be conducted, at minimum, 300 feet (ft) up-and downstream of the creek crossing. With the exception of compliance with Measure BIO-l, if no individual CRLFs or WPTs are encountered, no further mitigation would be required. However, if CRLFs and/or WTPs are found, construction activities shall be postponed and the appropriate resources agency (U.S. Fish and Wildlife Service [USFWS] for CRLF and California Department of Fish and Game [CDFG] for WPT) shall be consulted to determine the extent of potential impacts to CRLFs and/or WPTs and to identifY measures necessary to avoid, minimize, and mitigate these impacts, such as obtaining an incidental take penni! (for CRLF) or developing an exclusion and relocation program. IMPLEMENTATION MONITORING Al'ID MONITORING I MONITORING PROCEDURE REPORTING ACTIONS RESPONSIBILITY SCHEDULE The Director of the Utilities Director of Planning and Director of Planning and Prior to construction Department retains a qualified Community Environment. Community Environment biologist to conduct a prc-Retain pre-construction· construction survey (day and . survey results in the Project night). . file. If CRLF and/or WPTs are Director of Planning and Director of Planning and Prior to construction. encountered during the survey, Community Environment. Community Environment postpone construction Retain records of activities and contact the communication and decisions appropriate resource agency. in the Project file. The qualified biologist Director of Planning and Director of Planning and Prior to construction. implements measures required • Community Environment. Community Environment by Resource Agencies. Reports identifYing that the measures have been completed retain in the Project file. BIO-3: Avoid disturbing nesting birds. To avoid disturbance to nesting common yellowthroat and other migratory birds and raptors (e.g., American kestrel, northern harrier, white-tailed kite), one of the following measures shall be implemented: • Conduct the installation of the proposed aligrrment, alignment options, laterals, and the construction of pump station during the non-breeding season (September 1st through January 31st); OR • Conduct pre-construction surveys for nesting birds if construction activities are to take place during the nesting season (in general, February 1st through August 31st). Pre-construction surveys shall be conducted by a qualified biologist no more than three days prior to the onset of construction activities to confinn presence or absence of active nests in the Project vicinity. The extent of the area to be surveyed shall be determined by the biologist considering (1) the nature of the construction activities, (2) the existing level of human-related disturbances, and (3) the availability of suitable nesting habitat in the Project vicinity. If active nests are encountered, species-specific measures shall be prepared by a qualified biologist, in coordination with the CDFG and other appropriate agencies, and implemented to prevent direct loss or abandonment of the active nest. At a minimum, construction activities in the vicinity of nests shall be deferred until the young have fledged and an exclusion buffer zone shall be established. CDFG typically recommends a minimum exclusion buffer of 25 feet for songbird nests, and 200 to 500 feet for raptor nests, depending on the species and location. The perimeter of the nest-setback zone shall be fenced or adequately demarcated with staked flagging at 20-foot intervals, and construction personnel shall be restricted from the area. A survey report by the qualified biologist verifying that the young have fledged shall be submitted to City for review and concurrence of the City is required prior to initiation of construction activities within the nest-set-back zone. IMPLEMENTATION MONITORING AND MOMTORING MONITORING PROCEDURE REPORTING ACTIONS RESPONSIBILITY SCHEDULE The Director ofthe Utilities Director of Planning and Director of Planning and Prior to construction Department includes Community Environment Community Environment construction period limitations reviews contractor and requirements in contractor specifications. specifications and procedures to avoid disturbance to nesting common yellowthroat and other migratory birds and raptors. If construction activities are Director of Planning and Director of Planning and Prior to construction planned during the nesting Community Environment. Community Environment season, the Director ofthe Retain pre-construction Utilities Department retains a survey results in the Project qualified biologist to conduct file. a pre-construction survey. If active nests are encountered Director of Planning and Director of Planning and Prior to construction. during the survey, the Community Environment. Community Environment qualified biologist prepares Retain records of species-specific measures, in communication and decisions coordination with CDFG. in the Project file. Contractor implements Sign-off by qualified Director of Planning and During construction appropriate avoidance biologist that measures are Community Environment measures if construction implemented. Retain and qualified biologist activities occur during the monitoring reports in Project breeding season. file. BIO-4: Avoid disturbing nesting California clapper and black rails during the installation of the pipeline in alignment Option 1 or alignment Option 2 east of US-lOt and construction of the pump station at the RWQCP. To avoid substantial adverse effects to nesting California clapper rails and black rails, installation of alignment Option 1 or alignment Option 2 east of US-I Oland construction of the pump station at the RWQCP should either be conducted outside of the breeding season for clapper rails (in general, February 1 st through August 31st) or construction activities east of US-lO 1 and at the R WQCP site should be started prior to the breeding season and disturbance activities continued throughout the spring to prevent birds from establishing nests in surrounding habitats. This would prevent abandonment of eggs or young that could occur if nesting establishes prior to construction activities. If this is not feasible, a qualified biologist shall conduct the following: 1) protocol-level surveys for clapper rails (following methods outlined in the Draft Survey Protocol: California Clapper Rail (Rallus longistrostris obsoletus)(USFWS 2000) for Option 1 or 2 pipeline alignments east of US-l 01; 2) pre-construction survey for the California Clapper Rail at the proposed RWQCP within 700 feet of potential nesting habitat; and 3) pre-construction surveys for California black rail to determine presence or absence of rail breeding activity in the vicinity of the Project. A qualified biologist is an individual who has experience conducting protocol-level surveys for California clapper rails, and experience surveying for California black rails using a standardized tape call-back response protocoL Prior to commencement of the surveys for Option 1 or 2 pipeline alignments east of US-101, the biologist shall prepare a briefletter report describing the survey design and submit it to the USFWS (for California clapper rail only) and CDFG for review and approval. Upon the completion of the surveys, survey results shall be submitted to the USFWS and CDFG for a final decision on the possibility of doing work during the breeding season for the clapper and black rail. Protocol-level surveys are only necessary during the installation of the pipeline east of US-IO 1. If construction activities east of US-l 0 1 are conducted outside the breeding season, no surveys would be necessary. If construction activities are planned during the breeding season, the Director ofthe Utilities Department retains a qualified biologist to contact USFWS regarding survey protocols and conduct pre- construction surve s. Contractor implements relevant measures, if necessary, in the program if construction activities occur during the breeding season. Director of Planning and Community Environment. Retain all records of communication with USFWS / CDFG and pre-construction survey results in the Pr~ject file. i Sign-off by qualified biologist that measures are implemented. Retain monitoring reports in Project file. Director of Planning and Community Environment Director of Planning and Community Environment and qualified biologist ORING SCHEDULE Prior to construction During construction BIO-5: Conduct protocol-level Burrowing owl (BUOW) surveys prior to the installation of the pump station proposed at the RWQCP, and avoid impacts to owls, if present, during project construction. A qualified biologist shall conduct a protocol-level survey for burrowing owl following the methods outlined in the Burrowing Owl Survey Protocol and Mitigation Guidelines. A survey for owls shall be conducted during the breeding season at the RWQCP site (in general, February 1st through August 31st, peaking between April 15th and July 15th). If no owls are observed using the site during the breeding season surveys, winter surveys shall be conducted. Winter surveys shall be conducted between December 1st and January 31 st, during the period when wintering owls are most likely to be present, if necessary. A complete owl survey consists of four site visits, on separate days and during weather that is conducive to observing owls outside their burrows. If no owls are found during the breeding or winter season surveys, no further mitigation shall be required, provided construction activities or destruction of suitable burrows commence within 30 days of the date of the last survey. Otherwise, a pre-construction survey for owls shall be conducted no more than 30 days prior to the onset of construction activities. If surveys confin11 presence of owls on the site, mitigation measures shall be incorporated into the proposed project, in coordination with CDFG, to avoid and/or minimize impacts to burrowing owls, their burrows and foraging habitat on the site. The following measures shall be taken into consideration: 1) occupied burrows shall not be disturbed during the nesting season, unless a qualified biologist approved by the CDFG verifies through non-invasive methods that either: a) the owls have not begun egg-laying and incubation; or b) that the juveniles from those burrows are foraging independently and capable of independent survival; 2) to offset the loss of foraging and burrow habitat on the project site, a minimum of 6.5 acres of foraging habitat per pair or unpaired resident bird, shall be acquired and permanently protected; 3) when destruction of occupied burrows is unavoidable, existing unsuitable burrows shall be enhanced (e.g., enlarged or cleared of debris) or new burrows shall be created (e.g., installing artificial burrows) at a minimum ratio of 1:1 on protected lands; 4) if owls must be moved away from the disturbance area, passive relocation techniques shall be used rather than trapping; and 5) the project sponsor shall provide funding for long-term management and monitoring of the protected lands. IMPLEMENTATION MONITORING AND MONITORING MONITORING PROCEDURE REPORTING ACTIONS RESPONSIBILITY SCHEDULE Qualified biologist appointed Qualified biologist. Retain Qualified biologist. Prior to construction. by the Director of the Utilities results of the survey in Department conducts Project file. protocol-level burrowing owl surveys. If surveys confirm presence of Director of Planning and Director of Planning and Prior to construction owls on the site, mitigation Community Environment Community Environment measures, prepared in reviews contractor and qualified biologist coordination with CDFG, shall specifications. Retain records be incorporated into the of communication and construction specifications. decisions in the Project file. Contractor implements Sign-off by qualified Director of Planning and During construction mitigation measures. biologist that measures are Community Environment implemented. Retain and qualified biologist monitoring reports in Project file. BIO-6: Protection of Sensitive Communities. The following measures would be implemented prior to the onset of construction activities associated with the installation of alignment Option 1 or alignment Option 2 and the laterals adjacent to sensitive natural communities (e.g., northern coastal salt water marsh, coastal freshwater marsh, willow riparian habitat) to avoid potential adverse affects to these communities. • The limits of work shall be clearly delineated on all construction plans and silt fencing and/or construction fencing shall be installed around the work area, where extending beyond hardscaped areas. A qualified biologist shall monitor the fence installation and the fencing, at a minimum once per week, to ensure that the fence remains intact and functional, and that no encroachment has occurred into adjacent sensitive communities. • A qualified biologist shall brief construction workers on the location of sensitive communities that shall be preserved and the importance of avoidance. • Encroachment into adjacent commwlities shall be prohibited by construction workers, and storage of materials or equipment shall be prohibited in these areas. • In accordance with the SWPPP to be prepared for the Project, appropriate erosion and sediment control, and non-sediment pollution control (i.e., sources of pollution generated by construction equipment and material) BMPs shall be implemented to protect sensitive habitat adjacent to the Project. Erosion and sediment control material included in the SWPPP shall be certified as weed free. IMPLEMENTATION MONITORING ~"'ID MONITORING MONITORING PROCEDURE REPORTING ACTIONS RESPONSIBILITY SCHEDULE The Director of the Utilities Director of Planning and Director of Planning and Prior to construction Department includes Community Environment Community Environment construction limitations and reviews contractor requirements in contractor specifications. specifications and procedures. Qualified biologist appointed Qualified biologist. Record Qualified biologist. Prior to construction. by the Director of the Utilities of communication retain in Department briefs workers on Project file. the location and avoidance of sensitive communities. Contractor installs fencing. Sign-offby qualified Director 0 f Planning and Prior to construction biologist that measures are Community Environment implemented. Retain and qualified biologist monitoring reports in Project tile. Qualified biologist inspects Sign-off by qualified Director of Planning and During construction construction sites. biologist that measures are Community Environment implemented. Retain and qualified biologist monitoring reports in Project file. BIO-7: State and Federal Permits. If in-channel work is necessary for the Adobe Creek crossing at Hwy 101 in alignment Option 1, federal and state authorization will be obtained prior to the onset of construction activities. Prior to the onset of construction activities, a Department of the Army 404 Permit application shall be submitted to the U.S. Army Corps of Engineers (USACE), an Application for 401 Water Quality Certification and/or Report of Waste Discharge shall be submitted to the San Francisco Regional Water Quality Control Board (R WQCB), and a Lake or Streambed Alternation Notification shaH be submitted to the CDFG for impacts to Adobe Creek at U8-101. These permits must be obtained before the project is implemented. Mitigation measures associated with these permits may include minimization measures such as implementation of construction site management practices (i.e., erosion and sediment control measures) and seasonal work restrictions. Impacts to potentially jurisdictional features shall not occur until the permits are received from the appropriate regulatory agencies, or correspondence is received from the agencies indicating that a permit is not required. lfin-channel work is required for Adobe Creek at Hwy 101 in Alignment Option I, the Director ofthe Utilities Department obtains relcvant ermits. Director of Planning and Community Environment. Retain all permits in the Project file. MONITORING RESPONSIBILITY Director of Planning and Community Environment MONITORING SCHEDULE Prior to and during construction Director of the Utilities Director of Planning and Director of Planning and Prior to construction Department incorporates into Community Environment Community Environment construction specifications reviews construction permit requirements. specifications. Contractor implements permit Sign-off by qualitied Director of Planning and During construction requirements. biologist that requirements Community Environment and are implemented. Retain qualified biologist monitoring reports in Project file. B. TRANSPORTATION AND TRAFFIC TRA-l: Return Roads to Pre-construction Condition. Following construction, the City shall ensure that road surfaces that are damaged during construction are returned to their pre-construction condition or better. IMPLEl\-tENTA TION PROCEDURE The Director of the Utilities Department includes road restoration requirements in contractor specifications. Contractor restores road surfaces to pre-construction condition. TRA-2: Detours. MOl\1TORING A REPORTING ACTI Director of Planning and Community Environment reviews construction specifications. Retain monitoring report in the project file. Director of Planning and Community Environment Director of Planning and Community Environment 1\10NITORING SCHEDULE Prior to construction After construction! final inspection. During construction, the City shall use detour signing for vehicles, bicycles, and pedestrians on alternate access streets when temporary full street closure is required. IMPLEl\-1ENTATION MONITORING AND MONITORING MONfTORING PROCEDURE REPORTING ACTIONS RESPONSIBILITY SCHEDULE The Director of the Utilities • Director of Planning and Director of Planning and Prior to construction Department includes road • Community Environment Community Environment restoration requirements in reviews construction contractor specifications. specifications. Contractor installs detour Retain monitoring report in Director of Planning and During construction signage if full street closure the project file. Community Environment occurs. Appendix 8 -Public Meeting Sign-In Sheet ~l ~e ("-""'-lUGe JS1ibW-@) ~~~ 12~-OZ.LV . ~(!ttJ h (L6j ~(0 u City of Palo Alto Recycled Water Project Initial Study I Mitigated Negative Declaration March 2009 City of Palo Alto Department of Planning and Community Environment California Environmental Quality Act DRAFT MITIGATED NEGATIVE DECLARATION I. DESCRIPTION OF PROJECT Date: March 19,2009 Project Name: Palo Alto Recycled Water Project Application Nos.: Not Applicable Address of Project: Various Applicant: City of Palo Alto Utilities Owner: City of Palo Alto 250 Hamilton Avenue Palo Alto, CA 94301 Project Location and Description: Project Location The project site is located in Central Palo Alto; Stanford University. Project Description The Project consists of the installation of a recycled water pipeline, a booster pump station, and a pump station at the Palo Alto Regional Water Quality Control Plant (RWQCP) for the City of Palo Alto and represents the next increment of the R WQCP' s ongoing expansion of its regional recycled water system. The proposed Project would involve the construction of approximately 5 miles of 12 to 18-inch recycled water pipelines, a booster pump station, approximately 5 miles of lateral pipelines to over 50 use sites, and a pump station at the RWQCP. The Project would initially serve approximately 900 AFY of recycled water, mostly to the Stanford Research Park Area. Future extensions could serve Stanford University and Los Altos Hills, as well as provide a loop by making a second connection to the Phase 2 Mountain View Project. The predominant use of recycled water for this Project is landscape irrigation. Some industrial use, such as commercial and light industrial cooling towers, could also be included at a later date. Palo Alto Water Project Page 1 StudylMitigated Negative Declaration II. DETERMINATION In accordance with the City of Palo Alto's procedures for compliance with the California Environmental Quality Act (CEQA), the City has conducted an Initial Study to determine whether the proposed project located in Central Palo Alto and Stanford University could have a significant effect on the environment. On the basis of that study, the City makes the following determination: The proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION is hereby adopted. X Although the project, as proposed, could have a significant effect on the environment, there will not be a significant effect on the environment in this case because mitigation measures have been added to the project and, therefore, a MITIGATED NEGATIVE DECLARATION is hereby adopted. The attached initial study incorporates all relevant information regarding the potential environmental effects of the project and confirms the determination that an EIR is not required for the project. In addition, the following mitigation measures have been incorporated into the project: Mitigation Measures Creek Protection BIO-l: Creek Protection. The following measures would be implemented to avoid, minimize, or otherwise offset potential adverse effects to California red-legged frogs (CRLF) and Western pond turtles (WPT), and their habitats prior to and during the installation of the sections of pipeline crossing Adobe Creek at US-l 0 1, Matadero Creek at Hillview Avenue, and Barron Creek at Miranda Avenue. These measures are not applicable to Adobe Creek at Middlefield Road as no suitable habitat is present. • A SWPPP that complies with the statewide General Permit administered by the California State Water Resources Control Board for the National Pollutant Discharge Elimination System (NPDES) shall be developed and implemented to protect the water quality of the creeks that lie in the study area. Appropriate erosion and sediment control and non-sediment pollution control (i.e., sources of pollution generated by construction equipment and material) Best Management Practices (BMP) shall be prescribed in the Storm water Pollution Prevention Plan (SWPPP), and erosion and sediment control material included in the SWPPP shall be certified as weed free. • Construction activities associated with the installation of the sections of pipeline crossing Adobe Creek at US-I01, Matadero Creek at Hillview A venue, and Barron Creek at Miranda A venue shall be limited to the dry season (in general, between June 15th through October 15th) when flows are reduced and CRLF and WPT are least likely to be present. • A qualified biologist shall conduct a worker education program prior to the onset of construction activities associated with the installation of the sections of pipeline crossing Adobe Creek at US-101, Matadero Creek at Hillview A venue, and Barron Creek at Miranda A venue. Construction workers shall be briefed on, at a minimum, a description of the CRLF and WPT and their habitats, the general measures that are being implemented to conserve CRLF and WPT for the Project, and the boundaries within which the creek crossing may be accomplished. A fact sheet conveying this information shall also be prepared for distribution to the workers. Palo Alto Recycled Water Project Page 2 Initial StudylMitigated Negative Declaration • A qualified biologist shall be retained to monitor the construction activities associated with the installation of the sections of pipeline crossing Adobe Creek at US-lO 1, Matadero Creek at Hillview A venue, and Barron Creek at Miranda A venue. The biologist shall have expertise in the areas of CRLF and WPT biology and ecology, amphibian and reptileslhabitat relationships, and biological monitoring. The biologist shall also monitor performance of construction site management practices for the purpose of identifYing and recommending measures to avoid any condition that could adversely affect CRLF and WPT or their habitat. The City and their contractor, upon notification from the biologist, shall halt activities causing the condition affecting CRLF and WTP or their habitat. Work shall only resume with approval from the biologist. • Food and food-related trash items associated with construction workers shall be enclosed in sealed containers and regularly removed from the work area to deter potential predators. • All staging areas and fueling and maintenance of vehicles and other equipment shall occur at least 60 feet from any riparian habitat, creek, or other water body to ensure that habitat contamination does not occur from such activities. Protection of California red-legged frogs and Western Pond Turtle BIO-2: Conduct surveys for CRLF and WPT prior to the installation of the section of pipeline crossing Adobe Creek at Hwy 101, and avoid impacts to CRLF and WPT, if present. If the Adobe Creek crossing at Hwy 101 requires in-channel work, a qualified biologist shall conduct pre- construction surveys following standard visual encounter techniques to confirm presence or absence of CRLFs and WPTs in the work area. At minimum, the biologist shall be familiar with distinguishing physical characteristics of all the life stages of the CRLF, and identifYing WPTs. The biologist shall conduct at least one day and one night survey within one week of construction activities. Surveys shall be conducted, at minimum, 300 feet (ft) up-and downstream of the creek crossing. With the exception of compliance with Measure BIO-l, if no individual CRLFs or WPTs are encountered, no further mitigation would be required. However, if CRLFs andlor WTPs are found, construction activities shall be postponed and the appropriate resources agency (U.S. Fish and Wildlife Service [USFWS] for CRLF and California Department of Fish and Game [CDFG] for WPT) shall be consulted to determine the extent of potential impacts to CRLFs andlor WPTs and to identify measures necessary to avoid, minimize, and mitigate these impacts, such as obtaining an incidental take permit (for CRLF) or developing an exclusion and relocation program. Protection of Nesting Birds BIO-3: Avoid disturbing nesting birds. To avoid disturbance to nesting common yellowthroat and other migratory birds and raptors (e.g., American kestrel, northern harrier, white-tailed kite), one of the following measures shall be implemented: • Conduct the installation of the proposed alignment, alignment options, laterals, and the construction of pump station during the non-breeding season (September 1st through January 31st); OR • Conduct pre-construction surveys for nesting birds if construction activities are to take place during the nesting season (in general, February 1st through August 31st). Pre-construction surveys shall be conducted by a qualified biologist no more than three days prior to the onset of construction activities to confirm presence or absence of active nests in the Project vicinity. The extent of the area to be surveyed shall be determined by the biologist considering (1) the nature of the construction activities, (2) the existing level of human-related disturbances, and (3) the availability of suitable nesting habitat in the Project vicinity. Palo Alto Recycled Water Project Page 3 Initial StudylMitigated Negative Declaration If active nests are encountered, species-specific measures shall be prepared by a qualified biologist, in coordination with the CDFG and other appropriate agencies, and implemented to prevent direct loss or abandonment of the active nest. At a minimum, construction activities in the vicinity of nests shall be deferred until the young have fledged and an exclusion buffer zone shall be established, CDFG typically recommends a minimum exclusion buffer of 25 feet for songbird nests, and 200 to 500 feet for raptor nests, depending on the species and location. The perimeter of the nest-setback zone shall be fenced or adequately demarcated with staked flagging at 20-foot intervals, and construction personnel shall be restricted from the area. A survey report by the qualified biologist verifying that the young have fledged shall be submitted to City for review and concurrence of the City is required prior to initiation of construction activities within the nest-set-back zone. Protection of California clapper and black rails BIO-4: Avoid disturbing nesting California clapper and black rails during the installation of the pipeline in alignment Option 1 or alignment Option 2 east of US-lOl and construction of the pump station at the RWQCP. To avoid substantial adverse effects to nesting California clapper rails and black rails, installation of alignment Option 1 or alignment Option 2 east ofUS-lOI and construction of the pump station at the RWQCP should either be conducted outside of the breeding season for clapper rails (in general, February 1st through August 31st) or construction activities east of US-l Oland at the R WQCP site should be started prior to the breeding season and disturbance activities continued throughout the spring to prevent birds from establishing nests in surrounding habitats. This would prevent abandonment of eggs or young that could occur if nesting establishes prior to construction activities. If this is not feasible, a qualified biologist shall conduct protocol-level surveys for clapper rails (following methods outlined in the Draft Survey Protocol: California Clapper Rail (Rallus longistrostris obsoletus)(USFWS 2000) and pre-construction surveys for California black rail to determine presence or absence of rail breeding activity in the vicinity of the Project. A qualified biologist is an individual who h;::lS experience conducting protocol-level surveys for California clapper rails, and experience surveying for California black rails using a standardized tape call-back response protocol. Prior to commencement of the surveys, the biologist shall prepare a brief letter report describing the survey design and submit it to the USFWS (for California clapper rail only) and CDFG for review and approval. Upon the completion of the surveys, survey results shall be submitted to the USFWS and CDFG for a final decision on the possibility of doing work during the breeding season for the clapper and black rail. Protocol-level surveys are only necessary during the installation of the pipeline east ofUS- 101. If construction activities east of US-l 01 are conducted outside the breeding season, no surveys would be necessary. BIO-S: Conduct protocol-level Burrowing owl eBUOW) surveys prior to the installation of the pump station proposed at the RWQCP, and avoid impacts to owls, if present, during project construction. A qualified biologist shall conduct a protocol-level survey for burrowing owl following the methods outlined in the Burrowing Owl Survey Protocol and Mitigation Guidelines. A survey for owls shaH be conducted during the breeding season at the RWQCP site (in general, February 1 st through August 31 st, peaking between April 15th and July 15th). If no owls are observed using the site during the breeding season surveys, winter surveys shall be conducted. Winter surveys shall be conducted between December 1 st and January 31 st, during the period when wintering owls are most likely to be present, if necessary. A complete owl survey consists of four site visits, on separate days and during weather that is conducive to observing owls outside their buTI'ows. If no owls are found during the breeding or winter season surveys, no further mitigation shall be required, provided construction activities or destruction of suitable burrows commence within 30 days of the date of the last survey. Otherwise, a pre-construction survey for owls shall be conducted no more than 30 days prior to the onset of construction activities. Palo Water Project Page 4 IHHJL;;a",uNegative Declaration If surveys confirm presence of owls on the site, mitigation measures shall be incorporated into the proposed project, in coordination with CDFG, to avoid andlor minimize impacts to burrowing owls, their burrows and foraging habitat on the site. The following measures shall be taken into consideration: 1) occupied burrows shall not be disturbed during the nesting season, unless a qualified biologist approved by the CDFG verifies through non-invasive methods that either: a) the owls have not begun egg-laying and incubation; or b) that the juveniles from those burrows are foraging independently and capable of independent survival; 2) to offset the loss of foraging and burrow habitat on the project site, a minimum of 6.5 acres of foraging habitat per pair or unpaired resident bird, shall be acquired and permanently protected; 3) when destruction of occupied burrows is unavoidable, existing unsuitable burrows shall be enhanced (e.g., enlarged or cleared of debris) or new burrows shall be created (e.g., installing artificial burrows) at a minimum ratio of 1: 1 on protected lands; 4) if owls must be moved away from the disturbance area, passive relocation techniques shall be used rather than trapping; and 5) the project sponsor shall provide funding for long-term management and monitoring of the protected lands. Protection of sensitive communities BIO-6: Protection of Sensitive Communities. The following measures would be implemented prior to the onset of construction activities associated with the installation of alignment Option 1 or alignment Option 2 and the laterals adjacent to sensitive natural communities (e.g., northern coastal salt water marsh, coastal freshwater marsh, willow riparian habitat) to avoid potential adverse affects to these communities. • The limits of work shall be clearly delineated on all construction plans and silt fencing andlor construction fencing shall be installed around the work area, where extending beyond hardscaped areas. A qualified biologist shall monitor the fence installation and the fencing, at a minimum once per week, to ensure that the fence remains intact and functional, and that no encroachment has occurred into adjacent sensitive communities. • A qualified biologist shall brief construction workers on the location of sensitive communities that shall be preserved and the importance of avoidance. • Encroachment into adjacent communities shall be prohibited by construction workers, and storage of materials or equipment shall be prohibited in these areas. • In accordance with the SWPPP to be prepared for the Project, appropriate erosion and sediment control, and non-sediment pollution control (Le., sources of pollution generated by construction equipment and material) BMPs shall be implemented to protect sensitive habitat adjacent to the Project. Erosion and sediment control material included in the SWPPP shall be certified as weed free. State amtFederal Permits BIO-7: State and Federal Permits. If in-channel work is necessary for the Adobe Creek crossing at Hwy 101 in alignment Option 1, federal and state authorization will be obtained prior to the onset of construction activities. Prior to the onset of construction activities, a Department of the Army 404 Permit application shall be submitted to the U.S. Army Corps of Engineers (USACE), an Application for 401 Water Quality Certification andlor Report of Waste Discharge shall be submitted to the San Francisco Regional Water Quality Control Board (RWQCB), and a Lake or Streambed Alternation Notification shall be submitted to the CDFG for impacts to Adobe Creek at US-lO 1. These permits must be obtained before the project is implemented. Mitigation measures associated with these permits may include minimization measures such as implementation of construction site management practices (i.e., erosion and sediment control measures) and seasonal work restrictions. Impacts to potentially jurisdictional features shall not occur until the permits are received from the appropriate regulatory agencies, or correspondence is received from the agencies indicating that a permit is not required. Palo Alto Recyclcd Water Project Page 5 Initial Study/Mitigated Negative Declaration Restoration of Roads TRA-l: Return Roads to Pre-construction Condition. Following construction, the City shall ensure that road surfaces that are damaged during construction are returned to their pre-construction condition or better. TRA-2: Detours. During construction, the City shall use detour signing for vehicles, bicycles, and pedestrians on alternate access streets when temporary full street closure is required. 3/18/09 Prepared by Project Planner Date Palo Alto Recycled Water Project Declaration TABLE OF CONTENTS City a/Palo Alto ................................................................................................................... 1 PROJECT DESCRIPTION .................................................................................................. 1 PROJECT OVERVIEW AND BACKGROUND ....................................................................... 1 Project Overview ..................................................................................................................... 1 Background ............................................................................................................................. 1 Stakeholder Involvement ........................................................................................................ 3 PROJECT OBJECTIVES AND NEED ...................................................................................... 4 Need for Project ...................................................................................................................... 4 Project Objectives ................................................................................................................... 4 EXISTING FACILITIES ............................................................................................................ 4 Regional Plant ......................................................................................................................... 4 Current Sites With Recycled Water Use ................................................................................. 7 PROPOSED PROJECT .............................................................................................................. 7 Pipelines .................................................................................................................................. 7 Booster Pump Station .............................................................................................................. 9 RWQCP Pump Station .......................................................................................................... 14 Potential Sites for Recycled Water Use ................................................................................ 14 Schedule and Construction Methods ......................................................................................... 14 Equipment / Staging .............................................................................................................. 17 Adaptive Management Program ........................................................................ : .................. 17 Environmental Commitments ................................................................................................... 19 Dust Control .......................................................................................................................... 19 Protection of Cultural Resources .......................................................................................... 20 Storage, Handling, and Use of Hazardous Materials in Accordance with Applicable Laws ............................................................................................................................................... 20 Proper Disposal of Contaminated Soil and/or Groundwater ................................................ 20 Health and Safety and Hazardous Materials Management and Spill Prevention and Control Plans ...................................................................................................................................... 21 Emergency Access Strategies ............................................................................................... 21 Best Management Practices .................................................................................................. 21 Compliance with CCR Title 22 and Local Legislation ......................................................... 22 Public Outreach and Education ............................................................................................. 22 Compliance with the Tree Technical Manual ....................................................................... 22 Compliance with Local Noise Ordinance ............................................................................. 23 Power Generator Design/Noise ............................................................................................. 24 Traffic Control Plan .............................................................................................................. 24 Potential Permits and Approvals Required ............................................................................... 25 Alternatives to the Proposed Project ......................................................................................... 25 Pipeline Alternatives ............................................................................................................. 25 CEQA Compliance .................................................................................................................... 32 Palo Alto Recycled Water Project Page i Initial StudylMitigated Negative Declaration ENVIRONMENTAL CHECKLIST FORJ.\1 ...................................................................... 33 A. AESTI-IETICS .............................................................................................................. 37 B. AGRlCULTURAL RESOIJRCES ............................................................................... 41 C. AIR QUALITY ............................................................................................................ 42 D. BIOLOGICAL RESOURCES ..................................................................................... 46 E. C1JL TURAL RESOURCES ......................................................................................... 59 F. GEOLOGY, SOILS AND SEISMICITY .................................................................... 63 G. HAZARDS AND HAZARDOUS MATERIALS ........................................................ 65 H. HYDROLOGY AND WATER QUALITY ................................................................. 68 1. LAND USE AND PLANNING ................................................................................... 78 J. MINERAL RESOURCES ............................................................................................ 80 K. NOISE .......................................................................................................................... 80 L. POPULATION AND HOUSING ................................................................................ 83 M. PlJ~LIC SERVICES .................................................................................................... 84 N. RECREATION ............................................................................................................. 85 O. TRANSPORTATION AND TRAFFIC ....................................................................... 86 P. UTILITIES AND SERVICE SYSTEMS ..................................................................... 93 Q. MANDATORY FINDINGS OF SIGNIFICANCE ..................................................... 95 Report Preparation ............................................................................................................. 99 LIST OF FIGURES Figure 1: R WQCP Ongoing Expansion Phases .............................................................................. 2 Figure 2: Proposed Project Facilities .............................................................................................. 5 Figure 3: RWQCP Service Area ..................................................................................................... 7 Figure 4: Proposed Booster Pump Station Location on Proposed Pipeline Alignment.. .............. 10 Figure 5: Proposed Booster Pump Station Site ............................................................................. 1 1 Figure 6: Sample Booster Pump Station Layout 1 ........................................................................ 12 Figure 7: Sample Booster Pump Station Layout 2 ........................................................................ 13 Figure 8: Proposed RWQCP Pump Station Location ................................................................... 15 Figure 9: Recycled Water Users .................................................................................................. .26 Figure 10: Alternative Analysis Reaches ...................................................................................... 27 Figure 11: Reach 1 Alignment Alternatives ................................................................................. 28 Figure 12: Reach 2 Alignment Alternatives ................................................................................. 29 Figure 13: Reach 3 Alignment Alternatives ................................................................................. 30 Figure 14: Reach 4 Alignment Alternatives ................................................................................. 31 Figure 15: Regional Map .............................................................................................................. 34 LIST OF TABLES Table 1: Proposed Backbone Pipeline Alignment .......................................................................... 8 Table 2: Booster Pump Station Preliminary Design Criteria ........................................................ l1 Table 3: RWQCP Pump Station Preliminary Design Criteria ...................................................... 14 Table 4: Construction Methods at Creek and Road Crossings ..................................................... 17 Palo Alto Recycled Water Project Page ii Initial Stud.y/Mitigalcd Negative Declaration Table 5: Proposed Pipeline Alignment ......................................................................................... 88 Table 6: ISININD Authors ............................................................................................................. 99 Appendix A -Potential Recycled Water users Appendix B Emissions Calculations Appendix C -Biological Resources Appendix D -Cultural Resources Appendix E Hazardous Materials Palo Alto Recycled Water Project Page iii Initial StudylMitigated Negative Declaration List of Abbreviations AFY BAAQMD BAWSCA BUOW Cal/OSHA CAP CDFG CEQA CFR City CMU CNDDB CNPS CPAU CRLF CWA CY dB dBA DPM ElR ft gpd gpm hp IS/MND Ldn LTGS acre-feet per year San Francisco Bay Area Air Quality Management District Bay Area Water Supply and Conservation Agency burrowing owl California Occupational Safety and Health Administration Clean Air Program California Department of Fish and Game California Environmental Quality Act Code of Federal Regulations City of Palo Alto concrete masonry unit California Natural Diversity Database California Native Plant Society City of Palo Alto Utilities California red legged frog Clean Water Act cubic yards decibel A weighted decibel diesel particulate matter Environmental Impact Report feet gallons per day gallons per minute horsepower Initial Studyl Draft Mitigated Negative Declaration average 24-hour noise level Long Term Goal Study Palo Alto Recycled Water Project Page iv Initial StudylMitigated Negative Declaration MBTA mgd MRZ NDMA NEPA NMFS NPDES OSHA PG&E psi PUE ROG ROW RWQCB RWQCP SAA SCVWD SFPUC SWPPP SWRCB TDH THMs US-lOt USACE USFWS UV WPT Migratory Bird Treaty Act million gallons per day mineral resource zone N -Nitrosodimethy lamine National Environmental Policy Act National Marine Fisheries Service National Pollutant Discharge Elimination System Occupational Safety and Health Administration Pacific Gas and Electric pound per square inch Public Utility Easement reactive organic gas right of way California Regional Water Quality Control Board Palo Alto Regional Water Quality Control Plant streambed alteration agreement Santa Clara Valley Water District San Francisco Public Utilities Commission Storm Water Pollution Prevention Plan State Water Resources Control Board total dynamic head Trihalomethanes U.S. Highway 101 US Army Corps ofJ.JHr;,H, .... ,." US Fish and Wildlife Service ultraviolet western pond turtle Palo Alto Recycled Water Project Page v Initial StudylMitigated Negative Declaration This page left blank intentionally. Mu<lY/NlItIgatectNegative Declaration PROJECT DESCRIPTION This chapter provides a description of the proposed Palo Alto Recycled Water Project (Project), which consists of the installation of a recycled water pipeline, a booster pump station, and a pump station at the Palo Alto Regional Water Quality Control Plant (RWQCP) for the City of Palo Alto (Palo Alto or the City). PROJECT OVERVIEW AND BACKGROUND The following sections provide a brief overview of the proposed Project, a description of the project background, and a discussion of stakeholder involvement. Project Overview This Project is the next increment of the RWQCP's ongoing expansion of its regional recycled water system. Phase 1 has been in operation since 1980 and serves the Palo Alto Municipal Golf Course, Greer Park, the Emily Renzel Marsh, and the RWQCP. Construction of Phase 2 (Mountain View Recycled Water project) began in the summer of2007 and is expected to be complete in early 2009. The proposed Project (Phase 3) would be sponsored by the City of Palo Alto Utilities (CPAU). It would initially serve approximately 900 acre-feet per year (AFY) of recycled water, mostly to customers in the Stanford Research Park Area. Future extensions could serve Stanford University and Los Altos Hills, as well as create a loop by making a second connection to the Phase 2 Mountain View Project. The predominant use of recycled water for the proposed Project is landscape irrigation. Some industrial use, such as commercial and light industrial cooling towers, could also be included at a later date. Figure 1 provides an overview of the proposed alignment and pipe laterals within the context of the RWQCP's ongoing recycled water expansion. Please refer to Figure 2 Project Facilities for a detailed view of the proposed Project including the proposed alignment, laterals, alignment options and pump stations. Background Palo Alto's Water Reuse Program began in the early 1980s with the delivery of recycled water to Shoreline Golf Links. The system was substantially modified to include the Palo Alto Municipal Golf course, Greer Park, and the Renzel Marsh. Palo Alto then completed a Water Reclamation Master Plan (Master Plan) for the Palo Alto RWQCP in 1992 and the accompanying Final Program Environmental Impact Report (EIR) in 1995 (CH2MHill, 1995). The Palo Alto RWQCP developed the Master Plan in conjunction with its member agencies to address two main goals: 1) reduce demand on drinking water supplies by providing recycled water suitable for non-potable uses and 2) reduce metal discharge and improve overall water quality to the San Francisco Bay in part by reducing wastewater discharge to the bay. The Master Plan includes a phased approach to the expansion of treatment, distribution, storage, and use of recycled water. The Program EIR evaluated, at a program-level, development of a regional water reuse system that could ultimately provide service to the entire RWQCP service area including the cities of Palo Alto, Mountain View, Los Altos, East Palo AHo, Los Altos Hills, part of Menlo Park, as well as Stanford University. The Program EIR addressed the environmental effects of the overall Water Reuse Program and included a focused, project-level review of one specific project the Foothill Main Project. The Foothill Main Project would have established an initial distribution system running from the RWQCP to the Santa Cruz Mountain foothills, a storage reservoir in the foothills southwest of Stanford University, and the use of recycled water for landscape irrigation at Stanford, several city parks, and a highway interchange. The project was never built. Palo Alto Recycled Water Project Page 1 Initial StudylMitigated Negative Declaration Figure 1: RWQCP Ongoing Expansion Phases The Program EIR acknowledged that the Foothill Main Project might or might not be the first project implemented and indicated that no specific arrangements or commitments with potential users had been made. However, by providing project-level CEQA analysis of that project, the Program EIR provided detailed analysis of a potential project that could be representative of the overall Water Reuse Program in terms of the environmental setting affected, the nature and potential for significant impact, and the appropriate types of mitigation. In December 2001, the RWQCP published a Long-Term Goals Study (LTGS) Report that concluded a one-year, stakeholder driven effort to develop long-term goals for the RWQCP. Water recycling was identified as a key priority for the RWQCP. In addition, developing recycled water activities was considered as a key means to achieve a number of the other long-term goals such as improving water supply reliability, providing a dependable, locally controlled water source, and reducing reliance on imported water. Funding opportunities from the State Water Resources Control Board (SWRCB) triggered the RWQCP decision in May 2003 to move forward with Phase 2 of the of the Palo Alto RWQCP's ongoing expansion of its regional recycled water system, the Mountain View/Moffett Field Area Reclaimed Water Pipeline Proj ect (Mountain View Project). The Mountain View Project is one of the projects identified in the 1992 Master Plan. In 2004, the Palo Alto Recycled Water Project Page 2 Initial StudylMitigated Negative Declaration RWQCP completed a facilities plan (RMC, 2004) and initiated design for the Mountain View Project. Design for the Mountain View Project was completed in early 2007. The Mountain View Project will replace an existing deteriorating pipeline to Shoreline Golf Course in Mountain View and extend the pipeline to serve the Mountain View-Moffett Field area. The pipeline replacement will restore the golf course connection and will provide recycled water services to the Shoreline community. Construction for the Mountain View Project began in the summer of 2007. Palo Alto Municipal Golf Course, the RWQCP, Emily Renzel Marsh, and Greer Park are the existing major users of recycled water. The Mountain ViewlMoffett Field Area Reclaimed Water pipeline is sized to serve future users in the City of Palo Alto via several connections at Embarcadero Road and Bayshore Avenue, at Greer Park, and at San Antonio Road. In 2006, CPAU completed a Recycled Water Market Survey Report (RMC, 2006) as a preliminary effort to determine potential locations of recycled water use within the City of Palo Alto. The objectives of the study were to review and update the list of potential recycled water users in the City of Palo Alto and to update the proposed Project cost estimate for the delivery of recycled water to the City of Palo Alto and future expansions. The Project included site investigations, market analysis, conceptual Project design, and preparation of a financing and revenue plan. The market survey estimated a total city-wide recycled water demand of 1,870 acre-feet per year (AFY), excluding Stanford University, and recommended an alignment that would convey water from the R WQCP through the City of Palo Alto, with a target customer base at the Stanford Research Park. The proposed Project would supply recycled water to the Stanford Research Park area. Stakeholder Involvement The City, through the RWQCP, has actively included stakeholders in recycled water related projects. This involvement included EIR preparation for the Recycled Water Master Plan in 1992, stakeholder workshops for the LTGS preparation between 2000 and 2002, stakeholder workshops for the Mountain View Recycled Water Project facility planning in 2004, public meetings as part of Initial Study/ Draft Mitigated Negative Declaration (IS/MND) preparation for the Mountain View Project, and surveys of potential customers for the Palo Alto Recycled Water Market Assessment in 2006. Stakeholder involvement for this Project has included: • Facility managers meeting on June 13, 2007. Facility managers are staff who manage a property's utilities, such as energy use (electric and gas), water use, and wastewater. The Facility managers meeting included employees of large businesses such as Roche, Hewlett Packard and Varian, as well as public facilities such as parks (primarily for water use and irrigation). The managers are typically responsible for maintaining and operating irrigation systems and cooling towers on their properties. The facility managers were given an overview of the Project and were given the opportunity to ask questions and make comments regarding the Project. Comments received have been incorporated into this IS/MND. • Public scoping meeting for the proposed Project on September 18, 2007. All interested members from the public were welcome to attend. The City specifically invited the LTGS stakeholders, who represent a wide range of environmental and socioeconomic interests of the communities, and the facility managers to attend and participate in the meeting. Announcements for the meeting were published in the Palo Alto Daily News and Palo Alto Weekly. A comment form was made available at the public scoping meeting for the public to send comments to the City and to be added to the mailing list for the Project. The Project mailing list is used to send updates and notices about the Project. The Project description is posted on the City of Palo Alto website. Comments received at the scoping meeting have been incorporated into this IS/MND. Additional involvement is planned in the future, including another meeting with facility managers. Palo Alto Recycled Water Project Page 3 Initial StudylMitigated Negative Declaration PROJECT OBJECTIVES AND NEED Need for Project Recycled water use is expanding in the South San Francisco Bay Area. Key goals of the City of Palo Alto, the RWQCP and its partners, and other stakeholders such as the Santa Clara Valley Water District (SCVWD), are water supply management and improving protection of the San Francisco Bay by reducing the discharge of wastewater that could impact the sensitive Bay environment. A recycled water project within the City of Palo Alto would assist in achieving these goals. Project Objectives The primary objective of extending the recycled water pipeline into Palo Alto would be to allow the City to maximize recycled water as a supplemental water source, and would achieve the following: (l) Improve potable water supply reliability by conserving drinking water, currently used for irrigation and other non-potable uses, for potable purposes; (2) Provide a dependable, locally controlled non-potable water source; (3) Secure a non-potable water source that will be available even in droughts to serve irrigation and other non-potable uses; and (4) Reduce reliance on imported water. In addition, the Project would help RWQCP and its partners further conserve the San Francisco Bay by reducing the wastewater constituent mass loadings I to the Bay. Finally, the Project would provide the following benefits to the community: • • • • An alternative water supply for irrigation during droughts when potable water use is restricted; Beneficially reuse the wastewater generated by the City; Reduce future potable water supply infrastructure costs to the City; and Uphold state guidelines and policies relative to recycled water, including the California Water Code, Section 13510, and Section 461. EXISTING FACILITIES Regional Plant The RWQCP is located on the San Francisco Bay in the northeastern portion of the City of Palo Alto. Jt provides treatment and disposal of wastewater services to the cities of Palo Alto, Mountain View and Los Altos, the Town of Los Alto Hills, the East Palo Alto Sanitation District, and Stanford University, known collectively as the RWQCP Partners. Figure 3 shows the RWQCP service area. The RWQCP has a design average dry-weather flow capacity of39 mi1lion gallons per day (mgd) and a current flow of about 23 mgd. Although the disinfected effluent from the RWQCP predominantly discharged to the San Francisco Bay through an effluent outfall is treated to the disinfected secondary-23 2 recycled water level, the RWQCP has a 4 mgd recycled water facility that filters and disinfects the effluent to meet the requirements for tertiary treated water). The RWQCP has completed design of the ultra-violet (UY) disinfection facilities, which will increase the 1 Mass loading refers in this case to the net influx of chemical constituents entering the Bay. 2 See CCR Title 22 for a definition of secondary-23 recycled water. 3 Specifically the RWQCP treats effluent to meet the requirements for disinfected tertiary recycled water "unrestricted use" as defined in California Code of Regulations (CCR), Title Sections 60301 through 60355. Palo Alto Recycled Water Project Page 4 Initial StudylMitigated Negative Declaration Proposed Alignment Pipe Lateral Alignment Options -Option 1 -Option 2 -Option 3 RiVer N A 411 Proposed Pump Station This page left blank intentionally. Palo Alto Recycled Water Project Page 6 Initial StudyIMitigated Negative Do;!Claration recycled water production capacity to 6.45 mgd with the ability to further increase capacity to S.6 mgd in the future. Construction of the UV facilities is scheduled to start in June 2009 and be substantially completed in Fall 2010. Figure 3: RWQCP Service Area Current Sites With Recycled Water Use Recycled water is currently used at the RWQCP, the Palo Alto Municipal Golf Course, Emily Renzel Marsh, and Greer Park in Palo Alto, and is also trucked to construction sites throughout the region for dust control. PROPOSED PROJECT The Palo Alto Recycled Water Project proposes the construction of a recycled water pipeline and associated facilities to provide an alternative water supply for non-potable uses. The proposed Project would involve the construction of approximately 5 miles of 12-to IS-inch pipes, an up to 1,500 square-foot booster pump station, approximately 5 miles of lateral pipelines to over 50 use sites, and an up to 1,600 square-foot pump station at the RWQCP. The pipeline alignment consists of a proposed alignment and three alignment options, as shown on Figure 2. The Project would initially serve approximately 900 AFY of recycled water, mostly to the Stanford Research Park Area. Future extensions could serve Stanford University and Los Altos Hills, as well as provide a loop by making a second connection to the Phase 2 Mountain View Project. The predominant use of recycled water for this Project is landscape irrigation. Some industrial use, such as commercial and light industrial cooling towers, could also be included at a later date. Pipelines The proposed pipeline consists of the backbone pipeline and offshoots, or lateral pipelines. The pipeline would be located in urban areas, along existing road rights-of-ways (see Figure 2). The proposed backbone pipeline alignment would begin with a connection point to the Mountain View Project near the intersection of East Bayshore Road and Corporation Way. The pipeline would be constructed using trench less techniques under US- Palo Alto Recycled Water Project Page 7 lnitial StudylMitigated Negative Declaration 101, and would run along Fabian Way to East Meadow Drive where it would cross Adobe Creek. The pipeline would run along East Meadow Drive across Middlefield Road, and then continue along East Meadow Drive, Cowper Street, and EI Dorado Avenue to Alma Street, along Alma Street to Page Mill Road, and along Page Mill Road to EI Camino Real. The pipeline would continue across EI Camino Real, along Page Mill Road to Hanover Street, and along Hanover Street and Hillview A venue to Arastradero Road. Three pipeline alignment options would potentially replace segments of the proposed backbone pipeline alignment depending on constructability and design considerations. Roads included in the backbone pipeline alignment, including the options, are detailed in Table I and described below. Pipeline Alignment Option I would start from the new connection point to the Mountain View Project at the intersection of US-l Oland Adobe Creek, and would run along Adobe Creek. The pipeline would cross Adobe Creek on an existing bridge where it would run along West Bayshore Road and connect to the proposed pipeline alignment at Fabian Way. This option would replace the proposed pipeline alignment from the proposed East Bayshore Road and Corporation Way connection to Fabian Way. Pipeline Alignment Option 2 would begin at Colorado Avenue and US-lO 1 and would follow Colorado Avenue to connect to the proposed alignment at Alma Street. This option would replace the proposed alignment from the Adobe CreeklUS-l 0 1 connection up to the intersection of Colorado Avenue and Alma Street. Pipeline Alignment Option 3 would begin at the proposed alignment at the corner of Page Mill Road and EI Camino Real. The pipeline would connect to Hansen Way through the Palo Alto Square parking lot if a Public Utility Easement (PUE) could be obtained, or construction would take place on EI Camino Real. The pipeline would run along Hansen Way and use an existing PUE as a ROW through the parking lot connecting Hansen Way and Hanover Street. Alignment Option 2 would connect to the proposed alignment at Hanover Street. This option would replace the proposed alignment along Page Mill Road from EI Camino Real to Hanover Street, and along Hanover Street to Hillview A venue. A summary of the proposed alignment and alignment options, including roadway crossings and construction methods, is provided in Table 1 below. Further information on the pipeline can be found in Section 1.6 Schedule and Construction Methods. Lateral pipeline alignments would run along existing side streets from the proposed alignment or alignment options to serve individual users as shown in Figure 2. Table 1: Proposed Backbone Pipeline Alignment Alignment is on Starting Cross Street Ending Cross Street Construction Method at Roadwa ' Crossings ~~osed Alignment Under US-I0 1 E. Bayshore Rd. at Fabian Way Trenchless under 101 I Corporation Way Fabian Way West Bayshore Road East Meadow Drive Open-Cut Open-Cut; Potential East Meadow Drive Fabian Way Cowper Street trenchless section across Adobe Creek Bridge i Open-Cutl; Potential Cowper Street East Meadow Drive EI Dorado A venue trenchless2 sections across Barron Creek Bridge and Matadero Creek Bridge EI Dorado Avenue Cowper Street Alma Street ! Open-Cut Palo Alto Recycled Water Project Page 8 Initial Study/Mitigated Negative Declaration Page Mill Road Alma Street Hanover Street Mill Road Hanover Street Hanover Street Hillview Avenue Arastradero Road Open-Cut; Potential trenchless section under railroad crossing; Potential trenchless section under EI Camino Real Open-Cut; Potential trench less section across SFPUC Easement and Foothill Road Trenchless under 101 Open-Cut Alma Street Open-Cut I • Hanson Way Open-Cut Hanover Street Open-Cut I The open-cut construction method involves long, narrow excavations in the ground to accommodate the placement of the pipelines. 2 All of the bridge crossings would be trenchless (constructed with the pipe attached to the side of the bridge) or installed underneath the bridge. The construction method has not been finalized. Neither method would require work to be done in the creeks. Booster Pump Station A booster pump station would be constructed as part of the proposed Project to maintain a minimum delivery pressure of 65 pounds per square inch (psi) for the end users. Due to the change in elevation between the RWQCP and the end users on Hillview A venue (approximately 180 feet) and other sources of head loss4 in the pipeline, the pumps at the RWQCP cannot provide adequate pressure to convey water to the end users. Installing a booster pump station in Palo Alto along the alignment is a cost effective way to maintain minimum delivery pressure to customers. Figure 4 and Figure 5 show the proposed pump station location and aerial photograph of the surrounding area. 4 The head or pressure lost by water flowing in a pipe or channel, caused by the roughness ofthe pipe or channel walls. Palo Alto Recycled Water Page 9 Negative Declaration Figure 4: Proposed Booster Pump Station Location on Proposed Pipeline Alignment The proposed booster pump station would be located at 2700 El Camino Real, on the southeast comer of Page Mill Road and El Camino Real intersection at the Mayfield Soccer Fields (see Figures 4 and 5). The site is on the proposed alignment and located in a strategic area for delivering recycled water to the majority of demands along the pipeline. The park is Stanford property that is leased to the City of Palo Alto and has recently been refurbished with new fields. The proposed booster pump station would be constructed below grade at the site due to the prominent visual location and to avoid impacts to the existing park uses. The pump station would have a peak flow rate of 2,860 gallons per minute (gpm). This would require a total installed horsepower (hp) of 400 hp, including standby pumps. The pump station footprint would be approximately 50-ft x 30-ft (1,500 square feet ([sq. ft.]). Two sample booster pump station layouts are provided in Figure 6 and Figure 7. The booster pump station has not been designed and the layouts are provided only for reference. In addition to the booster pump station, a back-up generator may be installed at a later date if the recycled water is supplied for industrial use in the future. The back-up generator would be a stationary unit that would operate at greater than 50 hp. The back-up generator would only operate on a temporary basis under emergency conditions (e.g., outage). In the event that back-up generator is built, diesel fuel would be stored onsite. Fuel would be stored within double-walled concrete containers that prevent leakage. Likely, both the generator and storage would be bounded by a fence or structure (for security) and architectural treatment would be applied to integrate its fas:ade with sUlTounding uses. As adequate clearance would be needed for access to the facilities, the overall dimensions of the fenced area/structure could be up to 11 b x 7 b x 8 feet (length x width x height). The proposed generator facility would be designed to minimize noise. The proposed aboveground facility would require architectural review during the design phase of the project and would satisfy the requirements of the Architectural Review Board. Palo Alto Recycled Water Project Page 10 StudylMitigated Negative Declaration Figure 5: Proposed Booster Pump Station Site Mayfield Soccer Fields Southwest corner of the Page Mill Road and EI Camino Real intersection Table 2 shows the preliminary design criteria established for the needed booster pump station. Table 2: Booster Pump Station Preliminary Design Criteria Peak Hour Flow ratel Peak Flow Total Dynamic Head (TDH) Required Total Installed horsepower (approximate) Pump Station Footprint Backup Power Generator Notes 400 hp including standby pumps , Approximately 50-ft x 30-ft : May be required for reliability for industrial/commercial demands 1. Demands presented for the booster pump station include only irrigation users located on the proposed alignment downstream of the pump station. Palo Alto Recycled Water Project Page 11 Initial StudylMitigated Negative Declaration " ~ ~~lo~I------~--- Palo Alto Recycled Water Figure 6: Sample Booster Pump Station Layout 1 I I I I VAIMBl£ IF1wluEHcY 0IIMlI! I I ,,1!i" IIOTCR~ CDIIDI RECYCLED WATER PROJECT SAMPLE BOOSTER PUMP STATION LAYOUT Iii 1'~'~rra> S1i£.E'fNO Of X l'RQJfiCf NO 008419 £V.rn MAS£lt zooa Page 12 Initial StudyIMitigated Negative Declaration Figure 7: Sample Booster Pump Station Layout 2 _ AYMJat. ro~ POIDtIW.. Ml.I!lE _ -.rm:s b ~ CHfCK wv...V£ I I -.-a.E.~~ IIKll1lIItIIII'I"ROI. COlIER i I I!I ~Ii L"_" __ "" ____ """""""""""L' ___ --''--___ -'-___ --'-____ '--_____ --' ___________ ----' gu.~"10 1-1-------1 Palo Alto Recycled Water Project RECYCLED WATER PROJECT H(wtUIM) suuroo Of x SAMPLE BOOSTER PUMP STATION LAYOUT WITH OPTION FOR POTENTlAL FUTURE IMPROVEMENTS flWU'.Cf}«.i CO-B.009 DAn: ~IDilOOll Page 13 Initial M,t,,,,,t,,,; Negative Declaration RWQCP Pump Station Additional pumping capacity would be necessary at the R WQCP to achieve the minimum pressure criteria at the Phase 2 connection point during peak flows to accommodate the Palo Alto Project. The Phase 2 Project planning study and hydraulic model assumed that adequate pumping capacity would be available at the RWQCP to maintain minimum delivery pressure for its end users. The RWQCP has since designed a pump station at the facility to deliver 6.24 million gallons per day (MGD) of recycled water flows to Phase 2 users. These pumps, currently under construction, were not designed to provide capacity for the proposed Project during peak flow conditions. A hydraulic analysis of the 2-mile long pipeline from the RWQCP to the connection point determined that the Project would need additional pumping capacity to impart approximately 230 ft of TDH to match the hydraulic grade line established by the Phase 2 pumps during peak hour flow conditions, and to achieve the minimum delivery pressure of93 psi at the connection point. To achieve this additional pumping capacity, additional pumps would be needed at the RWQCP. Table 3 shows the preliminary design criteria established for the needed pumping capacity. A pump station could require a footprint of up to 40-ft x 42-ft and would be up to l2-ft tall. The pump station would be enclosed or covered and would be located within the areas shown in Figure 8. This structure has not been designed but is subject to the City's design review to address all aesthetic concerns. Table 3: RWQCP Pump Station Preliminary Design Criteria Description Criteria ~Total pU~jJstation capacity Peak Flow TDH Required Total Installed PP. (apprmdmat~) Pum Station Foot rint Potential Sites for Recycled Water Use 4:~ m&d (},~W.gpm) 230 ft 350 hp 40-ft x 42-ft x 12-ft The Palo Alto Project would serve approximately 97 users, delivering approximately 900 AFY or an average of 0.8 mgd. Non-residential landscape irrigation would be the largest use of recycled water for the Palo Alto Project. Irrigation would occur primarily during the night (between 10:00 p.m. and 6:00 a.m.) to maximize water use efficiency and minimize public contact. Other uses could include industrial and commercial use if added at a later date. A complete list of potential uses and potential recycled water users is provided in Appendix A. Schedule and Construction Methods Construction is tentatively scheduled to start in spring 2010 and would last approximately one year. Pipeline construction would typically require a minimum of one lane of traffic and the adjacent shoulder and/or bike lane (if they exist), resulting in a construction corridor approximately 20 feet to 30 feet wide. It is expected that the open trench construction within paved roadways would proceed at the rate of approximately 100 feet per day, with an overall work zone of 300 to 600 feet in length. Construction would occur for a relatively brief period of time at anyone location along the pipeline alignment, at most a few days. Construction would occur between the hours of 9 a.m. and 4 p.m. Monday through Friday on arterial and collection streets in order to maintain compliance with the City's Traffic Control Requirements. Construction other than on arterial and collection streets would occur between the hours of 8 a.m. and 6 p.m. Monday through Friday. Construction would occur between 9 a.m. and 6 p.m. on Saturday for all construction areas. Trenchless construction methods would be used for selected roadway and creek crossings. Trenchless construction methods minimize the area of surface disruption required for pipeline installation and include: jack and bore, micro-tunneling, directional drilling, and tunneling techniques. Palo Alto Recycled Water Project Page 14 Initial StudylMitigated Negative Declaration Figure 8: Proposed RWQCP Pump Station Location Palo Alto Recycled Water Project Page 15 Initial StudylMitigated Negative Declaration Hanging pipelines on existing bridge structures is another potential trenchless approach. Crossings where trenchless construction techniques would be implemented are shown in Table 4. Three creeks would be crossed by the proposed alignment, alignment options, and laterals: Adobe Creek, Barron Creek, and Matadero Creek. The creek crossings would be constructed as follows: • Adobe Creek. There are two Adobe Creek crossings. The first crossing is at the connection point to the Mountain View Project at the intersection of US-l Oland Adobe Creek. The pipeline would run from the connection point at the intersection of US-I Oland Adobe Creek, under US-I 0 1 via trenchless techniques or along the north side of Adobe Creek attached to the side of the underpass wall, then cross over Adobe Creek attached to the south side of the West Bayshore bridge and into the West Bayshore roadway after crossing the creek. The second crossing is on East Meadow Drive near US 101. The pipeline would be attached to the existing East Meadow Drive bridge on the downstream side of the bridge or installed in the roadway on the bridge. • Barron Creek. The alignment crosses Barron Creek on Cowper Street, where Cowper turns into a bridge over Barron Creek which flows in a concrete channeL The pipeline would either be installed attached to the downstream side of the bridge or installed in the roadway on the bridge. A lateral pipeline would be constructed at Miranda A venue using trenchless techniques. • Matadero Creek. There are two Matadero Creek Crossings. At the crossing at Cowper Street, Cowper turns into a bridge over Matadero Creek which flows in a concrete channeL The pipeline would either be installed attached to the downstream side of the bridge or installed in the roadway on the bridge. At the crossing at Hillview Avenue, Matadero Creek flows through a 12-foot wide box culvert below the roadway. The pipeline would be installed in the roadway, above the culvert. A trenchless railroad crossing would occur on Page Mill Road between Alma Street and Park Boulevard. Another trenchless crossing may occur on Hillview A venue at the intersection of Foothill Expressway to cross a San Francisco Public Utilities Commission (SFPUC) right-of-way (ROW). All pipeline construction would occur within public roadways. An easement from California Department of Transportation (Caltrans) would be required to construct the pipeline across and along US-lO 1. An easement from Santa Clara Valley Water District (SCVWD) would be required to cross all creeks. This includes easements in order to install a hanging pipe on the west and south side of bridges for two crossings of Adobe Creek. The booster pump station would be constructed on leased property at the Mayfield Soccer Fields. The pump station would be an underground facility and would be approximately 50 feet x 30 feet. The construction footprint for the pump station at the Mayfield Soccer Fields would be approximately 0.25 acres. The pump station proposed at the RWQCP would occur entirely within existing City property. Palo Alto Recycled Water Project Page 16 Initial StudylMitigated Negative Declaration Table 4: Construction Methods at Creek and Road Crossings Location I Crossing I Construction Method Adobe Creek Barron Creek Matadero Creek Page Mill Road Hillview A venue Equipment I Staging US 101 East Meadow Drive Cowper Street Cowper Street Hillview Avenue Railroad crossing between Alma Street and Park Boulevard : intersection of Foothill Expressway Foothill Expressway Trenchless or attached to existing overpass/bridge Installed on the downstream side of the bridge or installed in the roadway on the bridge Installed attached to the downstream side of the bridge or installed in the roadway on the bridge. Lateral pipeline trenchless crossing on Miranda Ave. Installed attached to the downstream side of the bridge or installed in the roadway on the bridge Installed in the roadway Trenchless Open-cut or Trenchless Open-cut or Trenchless Installation of the pipeline would require, but is not limited to, the following equipment: excavator, backhoe, front-end loaders, pavement saw, dump trucks, diesel generator, water tank, water truck, flat-bed truck, compactors, double transfer trucks for soil hauling, concrete trucks, and paving equipment (as needed). Equipment and vehicle staging would be accommodated either at each construction site (pipeline and pump station sites), or at a centralized staging area. Adaptive Management Program The City of Palo Alto recognizes that the community tree canopy on private and public property is highly valued for its aesthetic qualities and environmental benefits. To maximize the use of recycled water for irrigation in combination with responsibly maintaining the urban forest canopy, the City has developed the Adaptive Management Program (Program). The Program, as outlined below, is a component of the Project and participation is required of all users of recycled water. The Program will be implemented to avoid the potential effects of the recycled water use on protected and street trees and consists of the following components: Palo Alto Recycled Water Project Page 17 Initial StudylMitigated Negative Declaration • Tree and Soil Condition Monitoring Plan. A tree and soil condition monitoring plan will be developed for use at each user site. The Plan will include analysis required to determine the baseline conditions of the user site, track the effects of recycled water on trees, and determine the triggers for implementing Best Management Practices (BMPs). The Plan will be developed in consultation with a qualified professional (i.e., consulting or registered arborist or horticulturalist) and based on the most current information available. The plan will consist of the following framework. • Site-specific, Baseline Landscape Conditions Report: Prior to connection to the recycled water supply, the City and its recycled water users (collectively referre.d to as Participants) will develop a site-specific, baseline landscape conditions report to be filed with the City's Utilities Department. The report will include a field spot check of site characteristics by a qualified professional (e.g., consulting or registered arborist or horticulturist). Site characteristics include soil type, site drainage, number of existing trees that will be irrigated, number of protected trees, and health of existing trees. Photos of the existing site conditions will be included in the report with the findings of site conditions. This report will establish the existing conditions such that any changes in the health of the irrigated trees can be observed and, as needed, studied. • Triggers/Criteria: The Participants will consult with a qualified professional to determine the list of triggers that would initiate implementation of BMPs for protected and street trees. The triggers would consist of a specific list of decline symptoms that can be observed and further studied as needed to determine whether the symptoms are attributable to recycled water use or other water-quality independent causes. • Monitoring: The Participants will conduct annual inspections of the tree and soil conditions at the irrigation sites for a minimum of 14 years. Monitoring will consist of spot-checking the site characteristics (same as those identified for the baseline report) for any decline symptoms identified as part of the Tree and Soil Condition Monitoring Plan. If no decline symptoms are shown, then no additional actions will be required. If decline symptoms have been identified and are determined to be attributable to recycled water use based on the criteria established in the Plan, then the Participants will implement appropriate BMPs. Monitoring activities provide the opportunity to observe changes in site-specific conditions before long-term decline effects result. • Extensive Landscape Study: In the event that a qualified professional determines that a more extensive landscape study at an individual property is needed to determine the cause of observable tree decline, then such a study will be conducted. The extensive study, prepared by a qualified professional, will include an inventory of landscape species present, description of soil texture, structure and root development throughout its profile, and laboratory analysis of representative soil samples collected through the profile. A report of the findings and recommendations for corrective action if the decline symptoms are attributable to recycled water use (as specified in the Tree and Soil Conditions Monitoring Plan) will be prepared. The report will be filed with the CPAU and forwarded to the appropriate Participants (Parks, Public Works (PW) Operations, private tenant or landowner). The recommendations for the project can include the following: • Determine the need for drainage treatments; • Evaluate irrigation system performance to identifY locations of insufficient or excessive application; Identify modifications needed to the irrigation system, assess need to convert to drip irrigation, and evaluate efficacy of installing injection equipment; • Install soil moisture monitors to maintain appropriate soil moisture; Palo Alto Recycled Water Project Page 18 Initial StudylMitigated Negative Declaration • Design an irrigation schedule based on real-time evapotranspiration and data from soil moisture monitors that will maintain a moist soil; • Determine gypsum application volume and frequency; • Determine appropriate drainage system andlor leaching program for the site and establish limits of existing irrigation system; • Establish a monitoring program for soil sampling. Leaching programs and gypsum applications need to be adjusted to respond to results of the analyses. • Best Management Practices. The BMPs will focus on specific management methods to address potential decline symptoms attributed to recycled water use as determined by the Tree and Soil Monitoring Plan. The BMPs will be tied specifically to the triggers/criteria developed in consultation with a qualified professional. The BMPs can include, but are not limited to the corrective actions outlined below. These actions, which will be implemented by the Participants, are not presented in order of sequence. • Leach salts below the root zone: apply a large volume of water that carries salts accumulated in the root zone farther down into the soil profile. This method requires well draining soils; • Apply Gypsum: displaces sodium on clay particles so the sodium can be leached below the root zone. Gypsum is a chemical amendment; • Increase Irrigation: increase irrigation frequency to maintain moisture in the soil, to avoid salts from concentrating; • ModifY soil drainage to allow leaching, by physical manipulation, addition of manufactured drainage systems andlor other methods as technology becomes available; • ModifY irrigation system: avoid wetting foliage during application as plants are more sensitive to sodium and chloride when water is applied to the foliage compared to the soil; • Allow decline of existing trees but replace deceased trees with salt-tolerant tree species or species more suitable to the site. The ratio of replacement will be based on the requirements established in the Tree and Soil Condition Monitoring Plan; and • Cease recycled water irrigation of the affected property and replace with potable water. Environmental Commitments Dust Control During all phases of construction, the following dust control procedures shall be implemented: • Water all active construction sites at least twice daily; • Cover all trucks having soil, sand, or other loose material or maintain at least two feet freeboard on all trucks; • Apply water as necessary, or apply non-toxic soil stabilizers on all unpaved access roads, parking areas and staging areas at construction sites; • Sweep daily (with water sweepers) all paved access roads, parking areas, and staging areas at construction sites; • Sweep daily (with water sweepers) if visible soil material is carried illtO adjacent streets; • Water twice daily or apply non-toxic soil binders to exposed soil stockpiles; and Palo Alto Recycled Water Project Page 19 Initial Study/Mitigated Negative Declaration • Limit traffic speeds on unpaved areas to 15 miles per hour (mph). Protection of Cultural Resources In accordance with CEQA Section 15064.5, if cultural resources are encountered during Project-related excavations, construction shall be halted or diverted to allow an archaeologist an opportunity to assess the resource. Prehistoric archaeological site indicators include chipped chert and obsidian tools, and tool manufacturing waste flakes, grinding implements such as mortars and pestles, and darkened soil that contains dietary debris such as bone fragments and shellfish remains. Historic site indicators include, but are not limited to, ceramics, glass, wood, bone, and metal remains. Section 7050.5(b) of the California Health and Safety code will be implemented in the event that human remains, or possible human remains, are located during Project-related construction excavation. Section 7050.5(b) states: In the event of discovery or recognition of any human remains in any location other than a dedicated cemetery, there shall be no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent remains until the coroner of the county in which the human remains are discovered has determined, in accordance with Chapter 10 (commencing with Section 27460) of Part 3 of Division 2 of Title 3 of the Government Code, that the remains are not subject to the provisions of Section 27492 of the Government Code or any other related provisions of law concerning investigation of the circumstances, manner and cause of death, and the recommendations concerning treatment and disposition of the human remains have been made to the person responsible for the excavation, or to his or her authorized representative, in the manner provided in Section 5097.98 of the Public Resources Code. The County Coroner, upon recognizing the remains as being of Native American origin, is responsible to contact the Native American Heritage Commission (NAHC) within 24 hours. The Commission has various powers and duties to provide for the ultimate disposition of any Native American remains, as does the assigned Most Likely Descendant. Sections 5097.98 and 5097.99 of the Public Resources Code also call for " ... protection of inadvertent destruction." To achieve this goal, it is recommended that the construction personnel on the Project be instructed as to the potential for discovery of cultural or human remains, the need for proper and timely reporting of such finds, and the consequences of fail ure thereof. Storage, Handling, and Use of Hazardous Materials in Accordance with Applicable Laws The City shall ensure that all construction-related hazardous materials and hazardous wastes are stored, handled, and used in a manner consistent with relevant and applicable federal, state, and local laws. In addition, construction-related hazardous materials and hazardous wastes shall be staged and stored away from stream channels and steep banks to keep these materials a safe distance from near-by residents and prevent them from entering surface waters in the event of an accidental release. Proper Disposal of Contaminated Soil and/or Groundwater If contaminated soil and/or groundwater is encountered or if suspected contamination is encountered during Project construction, work shall be halted in the area, and the type and extent of the contamination shall be identified. A contingency plan to dispose of any contaminated soil or groundwater will be developed through consultation with appropriate regulatory agencies. If dewatering or hydrostatic testing of the pipeline is to occur during Project construction, the water will be discharged to the City's wastewater treatment plant rather than released into any drainage system, which would require prior approval from the San Francisco Bay RWQCB. Palo Alto Recycled Water Project Page 20 Initial StudylMitigated Negative Declaration Health and Safety and Hazardous Materials Management and Spill Prevention and Control Plans The City shall require the contractor to prepare a Health and Safety Plan and Hazardous Materials Management and Spill Prevention and Control Plan prior to commencement of construction that includes a project-specific contingency plan for hazardous materials and waste operations. The Health and Safety Plan shall be applicable to all construction activities, and shall establish policies and procedures according to federal and California Occupational Safety and Health Administration (OSHA) regulations for hazardous materials Health and Safety Plans. Elements of the plan shall include, but not be limited to, the following: • Discussion of hazardous materials management, including delineation of hazardous material storage areas, access and egress routes, waterways, emergency assembly areas, and temporary hazardous waste storage areas; • Notification and documentation of procedures; and • Spill control and countermeasures, including employee spill prevention/response training. Emergency Access Strategies In conjunction with the Traffic Control Plan for the Project, comprehensive strategies for maintaining emergency access shall be developed. Strategies shall include, but not be limited to, maintaining steel trench plates at the construction sites to restore access across open trenches and identification of alternate routing around construction zones. Also, police, fire, and other emergency service providers shall be notified of the timing, location, and duration of the construction activities and the location of detours and lane closures. Best Management Practices The City shall require contractors to file a Notice of Intent with the R WQCB indicting compliance with the National Pollutant Discharge Elimination System (NPDES) General Permit for Discharges of Storm Water Runoff Associated with Construction Activity (General Permit) and to prepare and implement a Stormwater Pollution Prevention Plan (SWPPP) outlining BMPs for construction/post-construction activities as specified by the California Storm Water Best Management Practices Handbook (ESA, 2003) and/or the Manual of Standards for Erosion and Sediment Control Measures (ESA, 2003). The BMPs include measures guiding the management and operation of construction sites to control and minimize the potential contribution of pollutants to stormwater runoff from these areas. These measures address procedures for controlling erosion and sedimentation, and managing all aspects of the construction process to ensure control of potential water pollution sources. Erosion and sedimentation control practices typically include: • Limiting construction to dry-weather months; • Installation of silt fencing and/or straw wattle; • Soil stabilization; • Revegetation of graded and fill areas with a standard erosion control mix (approved by a native habitat restorationist); • Runoff control to limit increases in sediment in stormwater runoff (e.g., straw bales, silt fences, drainage swales, geofabrics, check dams, and sand bag dikes); • Equipment maintenance shall be performed at least 100 feet from all water bodies and wetlands, with measures in place to contain spills of diesel fuel, gasoline, or other petroleum products. Drainage from all work sites shall be directed away from any water bodies or wetlands where feasible; • Prevent erosion of uplands and sedimentation of creeks, tributaries, and ponds; Palo Alto Recycled Water Project 21 Initial Study/Mitigated Negative Declaration • Minimize creek bank instability; • Prevent flooding; and • Return grades to preconstructed contours. A SWPPP that complies with the statewide General Permit administered by the California State Water Resources Control Board for the NPDES shall be developed and implemented to protect water quality of the creeks that lie in the study area. Appropriate erosion and sediment control and non-sediment pollution control (Le., sources of pollution generated by construction equipment and material) BMPs shall be prescribed in the SWPPP, and erosion and sediment control material included in the SWPPP shall be certified as weed free. In addition, the Project shall comply with R WQCB regulations and standards to maintain and improve the quality of both surface water and groundwater reserves. There is the potential for the salts to build up in the soil as a result of recycled water use and the potential increase of salinity of groundwater. As part of the RWQCP's regional recycled water program, salinity management strategies have been identified and will be implemented as part ofthe proposed Project. Compliance with CCR Title 22 and Local Legislation The proposed Project shall be designed and operated in accordance with the applicable requirements of California Code of Regulations (CCR) Title 22 and any other local legislation that is currently effective or may become effective as it pertains to recycled water. As proposed, the Project shall provide high quality recycled water to users. All landscape irrigation systems shall be operated in accordance with the requirements of Title 22 of the CCR, any other local legislation that is currently effective or may become effective as it pertains to recycled water and any reclamation permits issued by the San Francisco RWQCB. Reclamation permits typically require that irrigation rates match the evapotranspiration rates of the plants being irrigated. Irrigation will not occur within 50 feet of any domestic supply wells. Public Outreach and Education Signs will be posted at parks irrigated with recycled water that notifY people about the use of recycled water. The City will participate in public outreach and education efforts to inform local communities of the use of recycled water and the potential effects as well as benefits of recycled water. Compliance with the Tree Technical Manual The City of Palo Alto Tree Technical Manual (Dockter 2001) is a separately published document issued by the City Manager, through the Departments of Planning and Community Environment and Public Works to establish specific technical regulations, standards and specifications necessary to implement the Tree Ordinance (Chapter 8.10, Tree Preservation and Management Regulations), and to achieve the City's tree preservation goals and natural resource conservation goals. Section 2.00 specifically addresses the protection of trees during construction; its objective is to reduce the negative impacts of construction on trees5 to a less than significant level. Construction projects within the tree protection zone (TPZ) of Regulated Trees6 are required to implement protective practices prior to and during construction. The City would be required to retain a certified arborist to 5 Typical negative impacts identified in the City's Tree Technical Manual include the following: I) mechanical injury to roots, trunk or branches; 2) compaction of soil, which degrades the functioning roots and inhibits the development of new ones and restricts drainage, which desiccates roots and enables water mold fungi to develop; 3) changes in existing grade which can cut or suffocate roots; 4) alteration of the water table -either raising or lowering; 5) microclimate change, exposing sheltered trees to sun or wind; and 6) sterile soil conditions, associated with stripping off topsoil. 6 Regulated Trees identified in the Tree Technical Manual include the following: • Protected Trees: All Coast Live Oak, Quercus agrifolia, Valley Oak, Quercus lobata trees that are 1l.5-inches or greater in diameter (36-inches in circumference measured at 54-inches above natural grade) and Coast Redwood, Sequoia Palo Alto Recycled Water Project Page 22 Initial StudylMitigated Negative Declaration prepare a Tree Protection and Preservation Plan if any activity is within the dripline of a Protected or Designated Tree. The Plan must include an assessment of impacts to trees, recommended mitigation to reduce impacts to a less than significant level, and identification of construction guidelines to be followed through all phases of a construction project. Section 3.00 of the Tree Technical Manual outlines requirements associated with the removal and replacement of regulated trees. The standards and specifications for replacements of trees are dependent on the location where a Protected or Designated Tree would be replaced. If a tree is to be replaced on site, the replacement tree must be the same species unless the Director determines that another species would be more suitable for the location. The location of the replacement tree on site must be approved by the Director. If it is not possible to replace the tree on site, funding for the replacement of trees is calculated using a Tree Value Replacement Standard. The funding is then applied for planting of trees elsewhere. Compliance with Local Noise Ordinance For residential and non-residential property, construction, alteration and repair activities which are authorized by a valid city building permit shall be prohibited on Sundays and holidays and shall be prohibited except between the hours of 8:00 a.m. and 6:00 p.m. Monday through Friday, and 9:00 a.m. and 6:00 p.m. on Saturday, provided that the construction, demolition or repair activities during those hours meet the following standards: • No individual piece of equipment shall produce a noise level exceeding 110 dBA at a distance of 25 feet. If the device is housed within a structure on the property, the measurement shall be made outside the structure at a distance as close to 25 feet from the equipment as possible. • The noise level at any point outside of the property plane of the Project shall not exceed 110 dBA. • The holder of a valid construction permit for a construction project in a non-residential zone shall post a sign at all entrances to the construction site upon commencement of construction, for the purpose of informing all contractors and subcontractors, their employees, agents, materialmen and all other persons at the construction site, of the basic requirements of this measure. o The sign(s) shall be posted at least five feet above ground level, and shall be of a white background, with black lettering, which lettering shall be a minimum of one and one-half inches in height. o The sign shall read as follows: CONSTRUCTION HOURS FOR RESIDENTIAL (OR NON-RESIDENTIAL) PROPERTY (Includes Any and All Deliveries) MONDAY -FRIDA y. ....... 8:00 a.m. to 6:00 p.m.7 sempervirens trees that are l8-inches or greater in diameter (57-inches in circumference measured at 54-inches above natural grade) and Heritage Trees, individual trees of any size or species designated as such by City Council per the Palo Alto Municipal Code (PAMC) Section 8.10. • Street Trees: All trees growing within the street right-of-way (publicly-owned), outside of private property. In some cases, property lines lie several feet behind the sidewalks. A permit from the Public Works Department is required prior to any work on or within the dripline of any 'street tree' per PAMC Section 8.04. • Designated Trees: All trees, when associated with a development project, that are specifically designated by the City to be saved and protected on a public or private property which is subject to a discretionary development review per PAMC Section 18.76. 7 Construction of the proposed Project would occur between the hours of9 a.m. and 4 p.m. Monday through Friday on arterial and collection streets in compliance with City's Traffic Control Requirements. Palo Alto Recycled Water Project Page 23 Initial StudylMitigated Negative Declaration SA TURDA y. ........ 9:00 a.m. to 6:00 p.m. SUNDA Y/HOLIDA YS ........ Construction prohibited. Power Generator Design/Noise Where the generator facility would be constructed aboveground, a detailed analysis of the buildings' sound isolations will be conducted by a qualified acoustical consultant during the engineering design phase of the project for the site. A post-construction field sound measurement shall be conducted by an acoustical consultant to verifY that the project operational noise standards are in compliance with relevant City noise standards. Traffic Control Plan The City's Transportation Section will require the contractor to have a full traffic control plan prepared by a registered traffic engineer. The traffic control plan shall be in accordance with the City's Traffic Control Requirements and will show specific methods for maintaining traffic flows to minimize construction impacts on parking. There are several schools in the vicinity of the Project. These areas will be looked at more closely to determine whether the traffic control plan is appropriate or if additional measures are needed specific to school areas. Examples of traffic control measures to be considered include: • IdentifY all roadway locations where special construction techniques (e.g., directional drilling or night construction) would be used to minimize impacts to traffic flow; • Develop circulation and detour plans to minimize impacts to local street circulation. This may include the use of signing and flagging to guide vehicles through and/or around the construction zone; • Schedule truck trips outside of peak morning and evening commute hours; • Prohibit construction on collector and arterial streets during morning commute period before 9 a.m. and in the afternoon commute period after 4 p.m.; • Use haul routes, minimizing truck traffic on local roadways to the extent possible; • Consider detours for bicycles and pedestrians in all areas potentially affected by Project construction. Pedestrian and bicycle detours should not be required unless deemed necessary for safety reasons; • Use flagmen to maintain alternating one-way traffic while working on one-half of the street; • Use advance construction signs and other public notices to alert drivers of activity in the area; • Use "positive guidance" detour signing on alternate access streets to minimize inconvenience to the driving public; • Install traffic control devices as specified in the California Department of Transportation Manual of Traffic Controls for Construction and Maintenance Work Zones; • Develop and implement access plans for highly sensitive land uses such as police and fire stations, transit stations, hospitals and schools. The access plans would be developed with the facility owner or administrator. To minimize disruption of emergency vehicle access, ask affected jurisdictions to identifY detours, which will then be posted by the contractor. Notify in advance the facility owner or operator of the timing, location, and duration of construction activities and the locations of lane closures; • Store construction materials only in designated areas; and • Coordinate with local transit agencies for temporary relocation of routes or bus stops in work zones, as necessary. Palo Alto Recycled Water Project Page 24 Initial StudylMitigated Negative Declaration Potential Permits and Approvals Required The proposed facilities would be sited on leased land, within existing easements and through City and County lands (primarily streets). Portions of the pipeline may be within SCVWD, SFPUC and Pacific Gas & Electric (PG&E) easements. It is anticipated that permits / approvals will be required from the following agencies: • City of Palo Alto: Encroachment and Street Work Permit, Conditional Use Permit, Site and Design Review, and Architectural Review; • Santa Clara Valley Water District (SCVWD) permit for construction across creeks / flood control channels; • San Francisco Regional Water Quality Control Board (RWQCB): NPDES permit for construction activities and preparation of SWPPP; • San Francisco Bay Area Air Quality Management District (BAAQMD): Permit to Construct; authority to construct and permit to operate back-up power generator; • Caltrans Encroachment Permit; • CallOSHA -Underground Classification for tunnels; • California Department of Fish and Game (CDFG) -streambed alteration agreement (SAA) (although all creek crossings would be constructed with trenchless methods, a CDFG SAA may be required); • San Francisco Bay Conservation and Development Commission (BCDC) potential construction near the San Francisco Bay shoreline; • U.S. Army Corps of Engineers (USACE)-Department of the Army 404 Permit; and • San Francisco Regional Water Quality Control Board 401 Water Quality Certification and/or Report of Waste Discharge/ Alternatives to the Proposed Project The proposed Project may use federal funding, and thus would require compliance with the National Environmental Policy Act (NEPA). An Environmental Assessment (EA) under NEPA requires a brief description of the alternatives to the proposed action per Section 102(2)(E) of NEPA. In anticipation of the pursuit offederal funding for the proposed Project, alternatives are discussed below. Pipeline Alternatives A high-level review was conducted of alternative alignments for the Palo Alto recycled water pipeline. The purpose of the alternative analysis was to identify a backbone alignment that is cost-effective, serves the largest potential recycled water demand, and that has minimal utility, traffic, and constructability issues. The locations of the potential recycled water users within the Project focus area are shown on Figure 9. As shown in the figure, the greatest concentration of recycled water demand is located in the Stanford Research Park area of Palo Alto. The goal of the alternatives analysis was to develop backbone pipeline alignments to serve this largest concentration of users. Laterals to users located off the backbone alignment would be added after the backbone alignment was identified. Palo Alto Recycled Water Project Page 25 Initial StudylMitigated Negative Declaration Figure 9: Recycled Water Users Estimated Average Recycled Water Usage (AFY) 0 N .. 1·9 A • 10-24 25-100 Source: Recycled Water Market Survey Report (RMC, 2006) For the purpose of this alternatives evaluation, the recycled water pipeline was divided into four separate reaches, as delineated on Figure 10, each with unique alignment considerations. Pipeline alignments were analyzed for each reach to identify the most appropriate alignment for the area. Three reaches included several conceptual alignment alternatives (only one backbone alignment was identified for Reach 4). Four alternatives are identified for Reach 1, four alternatives for Reach 2, two for Reach 3, and one for Reach 4. Palo Alto Reeycled Water Projeet Page 26 Tnitial StudylMitigated Negative Declaration Figure 10: Alternative Analysis Reaches The sections below present the alternatives considered on a reach-by-reach basis. For a given reach, each alternative is described and illustrated on a map. The comparison criteria include raw construction cost, demand serviced, and general implementation issues such as traffic, utility, and constructability. Based on these criteria, a preferred conceptual alignment was recommended for each reach. A proposed alignment and viable alternatives were then identified for the length ofthe pipeline. Palo Alto Recycled Water Page 27 Declaration Reach 1 (see Figure 11): From connection point at Mountain View Recycled Water Pipeline at US-lOI and Adobe Creek to Middlefield Road. Alternative IA -From connection point at intersection of US-l 01 and Adobe Creek along Adobe Creek; across Adobe Creek on existing bridge; along W. Bayshore Rd, Fabian Way; across Adobe Creek; along E. Meadow Drive to Middlefield Rd. Alternative 1B -From new connection point at intersection of E. Bayshore Rd and US-l 0 1 by micro-tunneling across US-lOI; along Fabian Way; across Adobe Creek; along E. Meadow Drive to Middlefield Rd. Alternative IC -From connection point at intersection of US-lOl and Adobe Creek across Adobe Creek on pipeline bridge to be constructed; along W. Bayshore Rd; along Fabian Way; across Adobe Creek; along E. Meadow Drive to Middlefield Rd. Alternative ID -From new connection point at intersection of US-lOl and Matadero Creek; along Matadero Creek to Middlefield Rd. Figure 11: Reach 1 Alignment Alternatives Palo Alto Recycled Water Project Page 28 Initial StudylMitigated Negative Declaration Reach 2 (see Figure 12): From Middlefield Road to EI Camino Real. Alternative 2A -Along E. Meadow Drive, Alma St to Page Mill Rd; along Page Mill Rd to El Camino Real. Alternative 2B -Along E. Meadow Drive, Cowper St and EI Dorado Ave to Alma St; along Alma St to Page Mill Rd; along Page Mill Rd to El Camino Real. Alternative 2C -Along E. Meadow Drive, W. Meadow Drive, El Camino Way, El Camino Real to Hansen Way. Alternative 2D Along Matadero Creek to Alma St; along Alma St to Page Mill Rd; along Page Mill Rd to EI Camino Real (only compatible with Alternative ID). Figure 12: Reach 2 Alignment Alternatives Palo Alto Recycled Water Project Page Negative Declaration Reach 3 (see Figure 13): From El Camino Real to Hanover Street. Alternative 3A -From and across El Camino Real, along Page Mill Rd to Hanover St. Alternative 3B -From El Camino Real, along Hansen Way to Hanover St, through private property. (Only Works with Alternative 2C). Figure 13: Reach 3 Alignment Alternatives Palo Alto Recycled Water Project Page 30 Initial StudylMitigated Negative Declaration Reach 4 (see Figure 14): From Hanover Sf. to Arastradero Road. Alternative 4A Along Hanover St. and Hillview Ave., across Foothill Expressway, to Arastradero Road. Figure 14: Reach 4 Alignment Alternatives Proposed Pipeline Alignment Based on the criteria of recycled water demand served, utility, traffic, and constructability issues, and cost- effectiveness the proposed pipeline alignment was selected based on Alternatives IB, 2B, 3A, and 4A. The proposed Project is defined earlier in this document and shown in Figure 2. Alternative Backbone Pipeline Alignment For the purpose of environmental review, alternative backbone pipeline alignments were also included as alignment options should problems arise with the proposed alignment. The alignment options are defined earlier in this document and shown in Figure 2. The alignment options are based on the alternative analysis process and include the following: • Alignment Option 1, based on Alternative lA. From connection point at intersection of US-l Oland Adobe Creek, the pipeline would be located along Adobe Creek, under the US-l 0 1 overpass. The pipeline would then run along West Bayshore Rd and connect to the proposed alignment at Fabian Way. • Alignment Option 2, based on Alternative ID and 2D. Through coordination meetings with the SCVWO after the alternative analysis process, Alternatives 10 and 20 were modified due to construction issues along Matadero Creek. Alignment Option 2 begins at Colorado A venue and US-l Oland would follow Colorado Avenue to connect to the proposed alignment at Alma Street. PaJo Alto Recycled Water Project Page 31 Initial StudylMitigated Negative Declaration • Alignment Option 3, based on Alternative 3B. Alignment Option 3 would run along Hansen Way and use an existing PUE as a ROW through the parking lot connecting Hansen Way and Hanover Street. Alignment Option 2 would connect to the proposed alignment at Hanover Street. The alternatives discussed in this section were considered, but dismissed on the basis of constructability, feasibility, cost, and because none of the alternatives resulted in fewer environmental impacts than the proposed Project and alignment options. The impacts ofthe alternatives discussed above are the same as the impacts of the proposed Project due to the similar area and construction methods proposed. Please refer to the impact analysis for the proposed Proj ect below for a discussion of impacts. CEQA Compliance In compliance with Section 15000 of the CEQA Guidelines, the City of Palo Alto is the Lead Agency for compliance with the CEQA environmental review process for the Recycled Water Project. The City has conducted the CEQA process, including the preparation and circulation of this IS/MND, to provide to the public and Responsible and Trustee Agencies reviewing this project, information about the project's potential effects, both beneficial and adverse, on the local and regional environment. This Draft IS/MND was prepared in compliance with Section 15070 to 15075 of CEQA Guidelines of 1970 (as amended), and California Administrative Code, Title 14, Division, Chapter 3. In accordance with Section 15070, an MND shall be prepared if the following criteria are met: • There is no substantial evidence that the Project may have a significant effect on the environment; or • Where there may be a potentially significant effect, revisions to the Project would avoid or mitigate the effects to a point where clearly no significant effects would occur. In accordance with Section 15073 of the CEQA Guidelines, the document is being circulated to local, state, and federal agencies and to interested organizations and individuals who may wish to review and comment on the report. The 30-day public comment period is from March 19,2009 to April 17,2009. Written comments may be forwarded to: Clare Campbell City of Palo Alto 250 Hamilton Avenue Palo Alto, California 94301 650-617-3191 Clare.Campbell@CityofPaloAlto.org Supporting documentation listed in Section 4, References and Sources, is available for review during regular business hours at: City of Palo Alto Planning and Community Environment Civic Center, 5th Floor 250 Hamilton Avenue Palo Alto, California 94301 (650) 329-2441 Palo Alto Recycled Water Project Page 32 Initial StudylMitigated Negative Declaration ENVIRONMENTAL CHECKLIST FORM City of Palo Alto Department of Planning and Community Environment PROJECT DESCRIPTION 1. PROJECT TITLE Palo Alto Recycled Water Project 2. LEAD AGENCY NAME AND ADDRESS City of Palo Alto Department of Planning and Community Environment 250 Hamilton Ave. Palo Alto, CA 94303 3. CONTACT PERSON AND PHONE NUMBER Clare Campbell, Planner City of Palo Alto 650-617-3191 4. PROJECT SPONSOR'S NAME AND ADDRESS City of Palo Alto Utilities 250 Hamilton Avenue Palo Alto, California 94301 Contact: Nicolas Procos, (650) 329-2114 5. APPLICATION NUMBER Not Applicable 6. PROJECT LOCATION The proj ect site is located in the northern section of the City of Palo Alto, in the northern part of Santa Clara County, west of U.S. Highway 1 I) 1, as shown on Figure 15, Regional Map. The proposed alignment would begin with a connection point to the Mountain View Project near the intersection of East Bayshore Road and Corporation Way. The pipeline would be constructed using trenchless techniques under US-lOl, and would run along Fabian Way to East Meadow Drive where it would cross Adobe Creek again. The pipeline would run along East Meadow Palo Alto Recycled Water Project Page 33 Initial StudylMitigated Negative Declaration Drive across Middlefield Road, and then continue along East Meadow Drive, Cowper Street, and El Dorado Avenue to Alma Street, along Alma Street to Page Mill Road, and along Page Mill Road to El Camino Real. The pipeline would continue across El Camino Real, along Page Mill Road to Hanover Street, and along Hanover Street and Hillview A venue to Arastradero Road. The pipeline would run along side streets on lateral alignments from the proposed alignment or alignment options to serve individual users. Figure 2 in the Project Description shows the proposed pipeline alignment and the pipeline alignment options. These pipeline alignment options would potentially replace segments of the proposed alignment depending on constructability and design considerations. The proposed booster pump station would be located at the Mayfield Soccer Fields, 2700 El Camino Real, along the pipeline within the Project area. The proposed RWQCP pump station would be located at the RWQCP (2501 Embarcadero Way), which is within the Palo Alto Baylands Nature Preserve, on the easterly side of Embarcadero Way. Figure 15: Regional Map Palo Alto Recycled Water Project Page 34 Initial StudylMitigated Negative Declaration 7. GENERAL PLAN DESIGNATION: The Project would pass through a variety of land use designations. The proposed pipeline alignments (backbone and lateral) would traverse primarily land uses designated as Single Family Residential and Research / Office Park as identified in the Palo Alto 1998 2010 Comprehensive PlanS. Portions of the pipeline would also pass through uses designated as Major Institution / Special Facilities. This land use designation provides for institutional, academic, governmental, and community service uses and lands that are either publicly owned or operated as non-profit organizations. The proposed pipelines would be buried and would not affect any surface land uses. The proposed booster pump station would be located at 2700 EI Camino Real (Mayfield Soccer Fields) and is designated as Multi-Family Residential. The proposed booster pump station would be located within lands that allow such facilities with appropriate use permits. The RWQCP pump station site is designated as Major Institution/Special Facility in the Palo Alto 1998 -2010 Comprehensive Plan. 8. ZONING The pipeline alignments (backbone and lateral) would pass through a variety of zoning designations, including ROLM, Single-Family Residence District (R-l), Low Density Multiple- Family Residence District (RM-15), Medium Density Multiple-Family Residence District (RM- 30), PF, Two Family Residence District (R-2), Commercial Neighborhood District (CN), GM, Planned Community District (PN), Commercial Services District (CS), and RP. The pipeline would be located within the street right-of-ways and would not conflict with the existing zone districts. The proposed booster pump station at Mayfield Soccer Fields would be located on land zoned Public Facilities (PF) with an AS3 Combining Overlay District. The base PF zone district is designed to accommodate governmental, public utility, educational, and community service or recreational facilities. The proposed booster pump station, a utility facility use, requires a Conditional Use Permit to operate in the PF zone district. The RWQCP pump station site is zoned PF (D), Public Facilities with a Site and Design overlay. 9. PROJECT DESCRIPTION SUMMARY The Palo Alto Recycled Water Project (Project) proposes the construction of recycled water pipeline and associated facilities to provide an alternative water supply for non-potable uses. The project is comprised of three main structural elements (proposed pipeline, booster pump station with generator, and pump station at the RWQCP) and the Adaptive Management Program addressing recycled water usage. The proposed Project would involve the construction of approximately 5 miles of 12-to 18-inch pipes, a 1,500 square-foot booster pump station, approximately 5 miles of lateral pipelines to over 50 use sites, and an up to 1,600 square-foot pump station at the RWQCP. The proposed pipeline consists of the backbone pipeline and offshoots, or lateral pipelines. The proposed backbone pipeline alignment would begin with a connection point to the Mountain View Project near the intersection of East Bayshore Road and Corporation Way and make its way through the City to Hillview Avenue and Arastradero Road. Three pipeline alignment options would potentially replace segments of the proposed backbone pipeline alignment depending on constructability and design considerations. Pipeline construction would typically require a minimum of one lane oftraffic and the adjacent shoulder, resulting in a construction corridor approximately 20 feet to 30 feet wide. The proposed pipeline laterals, and 8 The Palo Alto Comprehensive Plan identifies Single Family Residential as uses including one dwelling unit on each lot as well as conditional uses requiring permits such as churches and schools. Palo Alto Recycled Water 35 Initial StudylMitigated Negative Declaration pipeline alignment options are discussed in more detail in the Project Description of this document and are shown on Figure 2. A booster pump station and generator would be constructed on the southeast comer of Page Mill Road and EI Camino Real intersection at Mayfield Soccer Fields. The pump station would have a peak flow rate of 2,860 gpm. This would require a total installed horsepower (hp) of 400 hp, including standby pumps. The pump station footprint would be approximately 50-ft x 30-ft (1,500 sq. ft.). A back-up generator may be installed at a later date if the recycled water is supplied for industrial use in the future. The pump station would be constructed below grade while the generator would be an above grade structure. The proposed booster pump station and back-up generator are described in more detail in the Project Description of this document. A new up to 1,600-square foot pump station would also be constructed at the RWQCP to deliver water into the Palo Alto recycled water system. The RWQCP is located within the Palo Alto Baylands Nature Preserve, on the easterly side of Embarcadero Way. Preliminary design criteria established for the pump station shows that the pump station would require a footprint of roughly 40-ft x 42-ft. Total pump station capacity would be 3,310 gpm and would provide approximately 230 feet of total dynamic head at the station. The total installed horsepower of the pump station would be approximately 350 hp. The design and siting of the pump station would comply with both the Baylands Master Plan (2008) and the Santa Clara County's Airport Master Plan (2006) for the Palo Alto Airport. The project also includes the Adaptive Management Program that is implemented to avoid any potential effects of recycled water use on protected and street trees. The program consists of the preparation and implementation of a Tree and Soil Condition Monitoring Plan and Best Management Practices. The "recycled water service area" refers to the area that would be served by the project (Le., where recycled water would be used for irrigation). It is anticipated that the Project would initially serve approximately 900 AFY of recycled water, mostly to the Stanford Research Park Area. Future extensions could serve Stanford University and Los Altos Hills, as well as provide a loop connecting to the Phase 2 Mountain View Project. The predominant use of recycled water for this Project is landscape irrigation. Some industrial use, such as commercial and light industrial cooling towers, could also be included at a later date. The term "study area" is used throughout this document and includes the proposed alignment and laterals, alignment options, the pump station locations, as well as the extent ofthe area anticipated to be disturbed during construction. 10. SURROUNDING LAND USES AND SETTING The Project is located within the City of Palo Alto and is in an urban area with commercial, residential, and industrial land uses as well as open space. Surrounding land uses are designated in the City of Palo Alto Comprehensive Plan Land Use map as Single Family Residential, Multiple Family Residential, Public Park, School District Lands, Major Institution / Special Facilities, Neighborhood Commercial, Service Commercial, Light Industrial, and Research / Office Park. The RWQCP, where a pump station would be located, is within the Palo Alto Baylands Nature Preserve. Surrounding uses include light manufacturing, office, and recreation (adjacent to Byxbee Recreation Area and near the Palo Alto Municipal Golf Course). The Palo Alto Recycled Water Project Page 36 Initial StudylMitigated Negative Declaration Baylands allows for passive recreational uses such as trails for walking, biking, and bird watching. A small-scale airport operated by the County of Santa Clara (Palo Alto Airport) is located north of the RWQCP. 11. OTHER PUBLIC AGENCIES • San Francisco Public Utilities Commission (SFPUC) -for crossing of Bay Division pipelines; • City of Palo Alto: Encroachment and Street Work Pennit, Conditional Use Pennit, Site and Design Review, and Architectural Review; • Santa Clara Valley Water District (SCVWD) -for construction across creeks / flood control channels; • San Francisco Regional Water Quality Control Board (RWQCB): NPDES pennit for construction activities and preparation of SWPPP; • San Francisco Bay Area Air Quality Management District (BAAQMD): Permit to Construct; authority to construct and penn it to operate back -up power generator; • Caltrans -Encroachment Permit; • CallOSHA -Underground classification for tunnels; • California Department of Fish and Game (CDFG) -streambed' alteration agreement (SAA) (although all creek crossings would be constructed with trenchless methods, a CDFG SAA may be required); • San Francisco Bay Conservation and Development Commission (BCDC) potential construction near the San Francisco Bay shoreline; • U.S. Army Corps of Engineers Department of the Army 404 Pennit; and • Regional Water Quality Control Board 401 Water Quality Certification and/or Report of Waste Discharge. ENVIRONMENTAL CHECKLIST AND DISCUSSION OF IMPACTS DISCUSSION OF IMPACTS The following Environmental Checklist was used to identify environmental impacts, which could occur if the proposed project is implemented. The left-hand column in the checklist lists the source(s) for the answer to each question. The sources cited are identified at the end of the checklist. Discussions of the basis for each answer and a discussion of mitigation measures that are proposed to reduce potential significant impacts are included. A. AESTHETICS Isupp","n.Info, .... tiOn Sources Potentially Potentially Less Than Resources Significant Significant Significant Issues Unless Impact . Would the project: Mitigation Incorporated a) Substantially degrade the existing visual ~ character or quality of the site and its 1 surroundings? b) Have a substantial adverse effect on a 1,2 ~ public view or view corridor? Palo Alto Recycled Water Project Page 37 StudylMitigated Negative Declaration No Impact I Issues and Supporting Information Sources Potentially Potentially Less Than Resources Significant Significant Significant Issues Unless Impact Would the project: Mitigation Incorporated c) Substantially damage scenic resources, y" including, but not limited to, trees, rock 1,2,4,52 outcroppings, and historic buildings within a state scenic highway? d) Violate existing Comprehensive Plan 1,2 policies regarding visual resources? , e) Create a new source of substantial light or glare which would adversely affect day or I y" nighttime views in the area? ±) Substantially shadow public open space 1,2 (other than public streets and adjacent sidewalks) between 9:00 a.m. and 3:00 p.m. from September 21 to March 21? DISCUSSION: The Palo Alto Recycled Water Project (Project) proposes the construction of a recycled water pipeline and associated facilities to provide an alternative water supply for non-potable uses. It is anticipated that during construction the project may create visual impacts, but due to the temporary nature of those effects, they would be less than significant. All components of the project that are seen from public views and create a permanent physical change, such as pipelines that will not be buried, new structures, or landscape changes, require design review (Architectural Review) by the City. The purpose of the design review is to promote visual environments which are of high aesthetic quality and variety and which, at the same time, are considerate of each other. The requirements of the design review reduce the Project's visual impacts to a less-than-significant level. As a preventative measure, the Project also includes the Adaptive Management Program (Program). This Program would assist the City and users of recycled water with specific protocol to follow in order to monitor and evaluate vegetation changes that may be caused by the use of recycled water. With this Program in place, the effects of using recycled water inappropriately and potentially causing visual effects to the City's urban tree canopy would be addressed. a) Less-than-Significant Impact. Construction of the proposed Project would be visible and would involve temporary impacts to aesthetic resources. Potential temporary impacts would include open trenches and the presence of construction equipment and materials. Existing landscaped vegetation and trees could also be damaged andlor removed during project construction. However, construction impacts would be temporary and are considered to be less than significant. Once built, the pipeline facilities would be buried underground or suspended under or along the side of existing bridges. The City of Palo Alto would repair any damage to roads and revegetate any disturbed landscaping. Implementation of such repairs and revegetation would ensure that the potential for short-term construction impacts would not become long-term visual impacts. The City has a practice of imposing a 5-year moratorium on cutting newly paved streets, with appropriate exceptions. Although not established for this reason, the moratorium indirectly limits visual impacts that could occur from continuous construction activities along anyone roadway segment. The Project is expected to be constructed beginning in 2010. No trench work would occur on streets that have been paved within the 5 years prior to construction unless an exception Palo Alto Recycled Water Projeet 38 Initial StudylMitigated Negative Declaration No Impact y" y" is needed and an agreement can be reached to allow for that exception. Where exceptions to the 5-year moratorium would be granted, impacts on public views from multiple construction activities along roadway segments would be considered less than significant due to the temporary and continuously-moving nature of construction activities. Visual character would be maintained at the proposed Mayfield Soccer Fields site, since the booster pump station would be constructed underground. Aboveground structures associated with the pump station and landscape changes would go through architectural review during the design phase ofthe project and would satisfy the requirements of the Architectural Review Board. Permanent changes to the visual condition of the R WQCP would result from construction of the pump station at the RWQCP. However, the pump station would be consistent with existing conditions at the plant. Electricity poles, paved roads, dirt roads, and existing facilities at the RWQCP are part of the scenic environment. The pump station would be shielded from public view by the existing vegetation, approximately 50 to 75 feet tall growing along the perimeter of the fenced RWQCP property. The pump station would be located within the developed RWQCP site, and although located in a passive park/nature preserve, the project would not interfere significantly with the park or impact the natural setting. The pump station would comply with the requirements of both the Baylands Master Plan and Santa Clara County's Airport Master Plan for the Palo Alto Airport. The pump station would be required to go through a Site and Design Review during the design phase of the project to ensure compliance with the City's regulations. Trees could be removed during construction activities; however, tree removal would comply with the City's Municipal Code to ensure that protected trees would remain on the project site and any designated trees removed would be replaced according to the Tree Canopy Replacement Formula, Tree Technical Manual, Section 3.30. Street trees would be replaced with species determined by PW Operations. The City would comply with the Tree Technical Manual regarding the avoidance, removal, and replacement of trees. Compliance with the Manual's practices would ensure that potential visual related impacts associated with tree removal would be less than significant. The project area includes the City-designated scenic route9 and view corridor in both directions along Page Mill Road (for the proposed alignment and pipe lateral), scenic route along Foothill Expressway (for the pipe lateral), major view corridors (looking south) along East Meadow Drive (proposed alignment), and other areas with extensive landscaping (e.g., the Palo Square area along Option 3 consists of extensively-planted, mature, coast Redwood protected trees per the Palo Alto Municipal Code 8.10). In areas where the existing site conditions are of poor quality, protected and street trees may be more sensitive to i1Tigation by recycled water (due to the higher levels of salts in the recycled water which can accumulate in the root zone due to the soil type and poor drainage). Under this scenario, the salt content in the recycled water could affect the health, and thus, the appearance of existing trees. Decline of substantial number of protected trees in the Page Mill scenic route or other extensively landscaped areas could change the City's visual character and quality. However, because the project integrates the Adaptive Management Program in addressing potential effects of recycled water use on trees, adverse effects on protected and street trees would be avoided. Please refer to Section H, Hydrology and Water Quality for a discussion of effects from recycled water use and to the Project Description for a discussion of the Adaptive Management Program. As stated above, the proposed project would go through Site and Design review during the design phase of the project and would satisfy the requirements of the City. The proposed pump station at 9 Scenic Routes. Palo Alto Comprehensive Plan, Land Use and Community Design Features, Map L-4. Palo Alto Recycled Water Project Page 39 StudylMitigated Negative Declaration the RWQCP would comply with the requirements of both the Baylands Master Plan and Santa Clara County's Airport Master Plan for the Palo Alto Airport. Therefore, impacts would be less than significant. b) Less-than-Significant Impact. The proposed Project components are not located in or near any scenic vistas and therefore would not have an impact on a scenic vista. The Proposed pipelines would be buried underground causing no permanent changes in the visual condition of the Project area. Due to the sensitive aesthetic nature of the Mayfield Soccer Fields site, the pump station would be constructed underground at this site. The existing snack and restroom building in the center of the fields is surrounded by a grove of mature designated treesJO that must be avoided, including the special rooting area beneath the surface pavers. The proposed generator associated with the booster pump station at the Mayfield Soccer Fields and the proposed pump station at the RWQCP would be the only aboveground structures associated with the proposed Project. These aboveground buildings would go through Site and Design / architectural review during the design phase of the project and would satisfy the requirements of the City and the Architectural Review Board. Alteration of public views at the sites of the above-ground facilities would be less than significant and no specific mitigation measures are required. Please refer to item a) above for a discussion of recycled water use and its effects on public views and view corridors. c) Less-than-Significant Impact. The proposed Project is not located near or within a state scenic highway; US-lO 1 is not designated as a Scenic Highway in the vicinity of the Project area (ESA, 2003). Therefore, the proposed Project would not damage scenic resources, including but not limited to rock outcroppings, and historic buildings within a state scenic highway. Please refer to item a) above for a discussion of recycled water use and its effects on the City's scenic resources. d) No Impact. The proposed Project would not violate any existing Comprehensive Plan policies regarding visual resources. The proposed Project would be constructed within existing roadways and/or utility corridors within commercial, industrial, and residential zonings within the City. For this reason, no impact is expected. The pump station proposed at the RWQCP would be consistent with existing conditions at the plant. The pump station would comply with the requirements of both the Baylands Master Plan and Santa Clara County's Airport Master Plan for the Palo Alto Airport. In addition, the project would include an Adaptive Management Program to address the effects of recycled water lise on to ensure that scenic qualities of the City are preserved. Please refer to Section H, Hydrology and Water Quality for a discussion of effects from recycled water use and to the Project Description for a discussion of the Adaptive Management Program. e) Less-than-Significant Impact. The proposed Project would not create a new source of substantial light or glare that would adversely affect day or nighttime views in the area. Nighttime construction activities are not anticipated. As described in the Project Description, construction would occur between the hours of 9 a.m. and 4 p.m. Monday through Friday on arterial and collection streets in order to maintain compliance with the City's Traffic Control Requirements. Construction other than on arterial and collection streets would occur between the hours of8 a.m. and 6 p.m. Monday through Friday. Construction would occur between 9 a.m. and 10 The existing grove of mature sycamore trees was the subject of previous entitlement, and includes a special engineered soil mix for rooting beneath the pavers. Palo Alto Recycled Water Project Page 40 Initial StudylMitigated Negative Declaration 6 p.m. on Saturday for all construction areas. However, if nighttime construction was to occur, it would be within the commercial section of the pipeline where traffic constraints might limit daytime construction. The Mayfield Soccer Fields pump station would be underground. Proposed above-ground facilities would not require substantial lighting. These aboveground buildings constructed as part of the Project would go through Site and Design / Architectural review during the design phase of the project and would satisfy the requirements of the City and the Architectural Review Board. Lighting conditions would not change at the RWQCP as a result of the proposed project. The impact would be less than significant. f) No Impact. The proposed Project would not substantially shadow public open space (other than public streets and adjacent sidewalks) between 9 a.m. and 3 p.m. from September 21 to March 21. As stated above, the proposed Project would be constructed within existing roadways and/or utility corridors within commercial, industrial, and residential zonings within the City. For this reason, no impact is expected. Mitigation Measures: None Required B. AGRICULTURAL RESOURCES In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. Issues and Supporting Information Resources Sources Potentially Potentially Less Than No Significant Significant Significant Would the project: Issues Unless Impact Mitigation Incorporated a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared 1,5 pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? b) Conflict with existing zoning for agricultural 1,2,5 c) use, or a Williamson Act contract? Involve other changes in the existing environment which, due to their location or 1 nature, could result in conversion of Farmland, to non-agricultural use? DISCUSSION: a) No Impact. The proposed Project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non- agricultural use. The proposed Project would be constructed within existing roadways and/or utility corridors within commercial, industrial, and residential zonings within the City or on Palo Alto Recycled Water Project Page 41 Initial Study/Mitigated Negative Declaration Impact ../ ../ ../ City owned or leased property. No farming or agriculture takes place within the Project area. As a result, the proposed Project would not affect agricultural practices and/or convert any farmland to non-agricultural usage. No mitigation is required or necessary. b) No Impact. The proposed Project would not conflict with existing zoning for agricultural use or a Williamson Act contract. As stated above, the proposed Project would be constructed within existing roadways and/or utility corridors within commercial, industrial, and residential zonings within the City. No farming or agriculture takes place within the Project area. As a result, the proposed Project would not conflict with existing zoning and/or a Williamson Act Contract No mitigation is required or necessary. c) No Impact. As mentioned above, the proposed Project would be constructed within existing roadways and/or utility corridors within commercial, industrial, and residential zonings within the City or on City owned or leased property. Therefore, the proposed Project would not involve changes in the existing environment, which, due to their location or nature, would result in the conversion of farmland or agricultural practices to non-agricultural use. No mitigation is required or necessary. Mitigation Measures: None Required c. AIR QUALITY Issues and Supporting Information Resources Sources Potentially Potentially Less Than Significant Significant Significant Would the project: Issues Unless Impact Mitigation Incorporated a) Conflict with or obstruct with implementation ofthe applicable air quality plan (1982 Bay 1,4 y" Area Air Quality Plan & 2000 Clean Air Plan)? b) Violate any air quality standard or contribute substantially to an existing or projected air quality violation indicated by the following: .... _ ...... L Direct andlor indirect operational emissions that exceed the Bay Area Air y" Quality Management District (BAAQMD) 1,6 criteria air pollutants of 80 pounds per day andlor 15 tons per year for nitrogen oxides (NO), reactive organic gases (ROG), and fine particulate matter of less than 10 microns in diameter (PMlO); II. Contribute to carbon monoxide (CO) concentrations exceeding the State y" Ambient Air Quality Standard of nine 1 parts per million (ppm) averaged over eight hours or 20 ppm for one hour( as demonstrated by CALINE4 modeling, which would be performed when a) project CO emissions exceed 550 pounds per day or 100 tons per year; or b) project traffic Palo Alto Recycled Water Project Page 42 Initial StudylMitigated Negative Declaration No Impact Issues and Supporting Information Res~urcesrources Potentially Potentially Less Than Significant Significant Significant Would the project: Issues Unless Impact Mitigation Incorporated would impact intersections or roadway I links operating at Level of Service (LOS) D, E or F or would cause LOS to decline to D, E or F; or c) project would increase traffic volumes on nearby roadways by 10% or more)? c) Result in a cumulatively considerable net increase of any criteria pollutant for which the ~ project region is non-attainment under an 1,6,4 applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)? d) Expose sensitive receptors to substantial levels e) f) of toxic air contaminants? 1 i. Probability of contracting cancer for the 1 Maximally Exposed Individual (MEl) exceeds 10 in one million ii. Ground-level concentrations of non-1 carcinogenic T ACs would result in a hazard index greater than one (1) for the MEl Create objectionable odors affecting a substantial number of people? 1 Not implement all applicable construction 1 emission control measures recommended in the Bay Area Air Quality Management District CEQA Guidelines? DISCUSSION: The proposed Project includes excavation activities and construction that would generate fugitive dust and other criteria pollutants. Construction contract provisions would include a dust abatement program as outlined in the Project Description. Daily combustion emission impacts from construction vehicles would not be significant due to the relatively small scale of the Project. Criteria pollutant emissions from these emission sources would incrementally add to regional atmospheric loading of ozone precursors during the construction period. Emissions calculations for construction and operation of the proposed Project are included in Appendix B. a) Less-than-Significant Impact. The proposed Project is located within the jurisdiction of the Bay Area Air Quality Management District (BAAQMD), the regional agency empowered to regulate air pollutant emissions from stationary sources in the Bay Area. BAAQMD regulates air quality through its permit authority over most types of stationary emission sources and through its planning and review process. The Project site is located in the San Francisco Bay Area Air Basin. This Basin is currently designated "non-attainment" for the state I-hour Palo Alto Ke,cvcledWater Declaration No I Impact ~ ~ ~ ~ ~ ozone standard. To meet planning requirements related to this standard, the BAAQMD developed a regional air quality plan, the Bay Area 2000 Clean Air Program (CAP), the BAAQMD's most recent triennial update of the 1991 Clean Air Plan. A significant impact would occur if a project conflicted with the plan by not mirroring assumptions of the plan regarding population growth and vehicle-miles-traveled. The proposed Project would accommodate popUlation growth because the Project would provide recycled water, making potable supplies more available, and thus increasing the overall supply of water. However, because growth in the City of Palo Alto is controlled by the Palo Alto Comprehensive Plan (Comprehensive Plan), the new water supply as a result of the proposed Project is not expected to result in increased development. The proposed Project would not generate new operational vehicle trips. Pump station maintenance would be completed as part of the regular maintenance trips that are already occurring in the Project area. The Project would not conflict with or obstruct with implementation of the 2000 CAP, and this impact would be less than significant. No mitigation is required. With respect to project conformity with the federal Clean Air Act, the Project's potential emissions are below minimum thresholds and are below 10 percent of the area's inventory specified for each criteria pollutant designated non-attainment or maintenance for the Bay Area. As such, further general conformity analysis is not required. b) Less-than-Significant Impact. The entire San Francisco Bay Area is currently designated "non-attainment" for the state PMw and PM2.5 standards, the state 1-hour and the national 8- hour ozone standards. The Bay Area is in "attainment" or "unclassified" with respect to the ambient air quality standards. As part of the effort to reach attainment of these standards, the BAAQMD has established thresholds of significance for several criteria air pollutants associated with both the construction and operation of projects. Specifically, a project is considered to have a significant regional air quality impact if it would result in an increase in emissions of 80 pounds per day of PM IO, reactive organic gases (ROG), or nitrogen oxides (NOx). ROG and NOx are both ozone precursors. Construction activities at the Project site would begin in the spring of 2010 and continue into the winter of 2010, and would include excavation and grading activities. For a discussion of construction haul trips during excavation activities refer to Section 2.16 Transportation and Traffic. Overall construction work would require the use of various types of mostly diesel- powered equipment, including bulldozers, wheel loaders, excavators, and various kinds of trucks. Construction activities typically result in emissions of particulate matter, usually in the form of fugitive dust from activities such as trenching and grading. Emissions of particulate matter vary day to day, depending on the level and type of activity, silt content of the soil, and the prevailing weather. In the absence of a dust control plan, construction activities may result in significant quantities of dust on a temporary and intermittent basis during the construction period. BAAQMD's approach to analyses of construction impacts as noted in their BAAQMD CEQA Guidelines is to emphasize implementation of effective and comprehensive control measures rather than detailed quantification of emissions. Construction and operation emissions calculations are included in Appendix B. With implementation of these dust control measures, described in the Project Description, the Project's construction-related dust impacts would be less than significant. Construction activities would also result in the emission of other criteria pollutants from equipment exhaust and construction-related vehicular activity. Emission levels for construction activities would vary depending on the number and types of equipment, duration of use, operation schedules, and the number of construction workers. While emissions of ROG and NOx from these sources would incrementally add to the regional atmospheric Palo Alto Recycled Water Project 44 Initial StudylMitigated Negative Declaration loading of ozone precursors during Project construction, these emissions are included in the emission inventory that is the basis for regional air quality plans. As such, construction emissions are not expected to impede attainment or maintenance of ozone standards in the Bay Area, and the Project's impact related to construction-vehicle emissions would be less than significant Once operational, emission sources resulting from Project operations would be associated with regular maintenance and inspection work. The potential back-up generator that may be installed at a later date could also result in emissions. However, this back-up generator would only operate on a temporary basis, and thus would not contribute significantly to project emissions. Construction and operation emissions calculations are included in Appendix B. Operational impacts would be considered less than significant No mitigation is required. c) Less-than-Significant Impact. As stated above, the proposed Project would be located within the Bay Area Air Basin, which does not meet state and federal health-based air quality standards for the state PMlO and PM2.5 standards, the state I-hour, and the national 8-hour ozone standards. The BAAQMD is active in establishing and enforcing air pollution control rules and regulations in order to attain all state and federal ambient air quality standards and to minimize public exposure to airborne toxins and nuisance odors. Air emissions would be generated during construction of the proposed Project, which could increase criteria air pollutants, including PMJO• However, construction activities would be temporary and would incorporate the implementation of a dust control plan. As mentioned above, upon completion of construction activities, emission sources resulting from Project operations would be associated with regular maintenance and inspection work. Given the limited number of trips that would be required, only limited emissions would be generated; these emissions would be expected to be well below BAAQMD guidelines. The potential back-up generator that may be installed at a later date could also result in emissions. However, this back-up generator would only operate on a temporary basis and thus would not contribute significantly to project emissions. Construction and operation emissions calculations are included in Appendix B. The proposed Project would not result in a cumulatively considerable net increase of any criteria air pollutants, and the Project impacts would be less than significant No mitigation is required. d) Less-than-Significant Impact. Sensitive receptors within the vicinity of the project area include schools, hospitals, and residences. Diesel emissions would result both from diesel- powered construction vehicles and any diesel trucks associated with Project operation. The potential back-up generator that may be installed at a later date could also result in emissions. However, this back-up generator would only operate on a temporary basis and thus would not contribute significantly to project emissions. Diesel particulate matter (DPM) has been classified by the California Air Resources Board as a toxic air contaminant for the cancer risk associated with long-term (i.e., 70 years) exposure to DPM. Given that construction would occur for a limited amount of time, that only a limited number of diesel trucks would be associated with operation of the Project, and that the potential back-up generator, if installed, would only operate on a temporary basis, localized exposure to DPM would be minimaL As a result, the cancer risks from the Project associated with diesel emissions over a 70-year lifetime are minimal. Therefore, the impacts related to DPM would be less than significant. Likewise, as noted above, with the implementation of a dust control plan, the Project would not result in substantial emissions of any criteria air pollutants either during construction or operation. Therefore, the Project would not expose sensitive receptors, including residents in the Project vicinity, to substantial pollutant concentrations. With the implementation of the dust control measures described in the Project Description, impacts to sensitive receptors would be less than significant. No mitigation is required. The probability of contracting Palo Alto Recycled Water Project Page 45 StudylMitigated Negative Declaration a) cancer from Project construction and/or operation for the Maximally Exposed Individual (MEl) would be very low and would not exceed 10 in one million. Ground-level concentrations of non-carcinogenic T ACs would not result in a hazard index greater than one for the MEL The RWQCP pump station would be located in the Baylands, within a nature preserve, where there are no residential uses and only limited commercial uses nearby. The pump station and related construction are not anticipated to expose sensitive receptors to TACs. e) Less-than-Significant Impact. During construction of the proposed Project, the various diesel-powered vehicles and equipment in use on site could create minor odors. These odors are not likely to be noticeable beyond the immediate area, and would be temporary in nature. Furthennore, the proposed Project would not include development of any uses of recycled water that are associated with objectionable odors. Given the extent to which the recycled water is treated, odors are not expected to be a problem at or near water use sites, at or near the pump station (which would underground or at the RWQCP), or in the event of a pipeline rupture. Therefore, odor impacts would be less than significant. No mitigation is required. £) No Impact. All applicable construction emission control measures recommended in the BAAQMD CEQA Guidelines would be implemented for the proposed Project. Mitigation Measures: None Required D. BIOLOGICAL RESOURCES Issues and Supporting Information Resources Sources Potentially Potentially I Less Than Significant Significant Significant Would the project: Issues Unless Impact Mitigation Incorporated Have a substantial adverse effect, either directly or through habitat modifications, on 1,2,7,8, any species identified as a candidate, sensitive, 9, 10, 11, ../ or special status species in local or regional 12, 13, plans, policies, or regulations, or by the 14, 15, California Department of Fish and Game or 16, 17 U.S. Fish and Wildlife Service? b) Have a substantial adverse effect on any riparian habitat or other sensitive natural 1,2,7,8, community identified in local or regional plans, 9,10,11, policies, regulations, including federally 12, 13, ../ protected wetlands as defined by Section 404 14, 15, of the Clean Water Act (including, but not 16, 17 limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? c) Interfere substantially with the movement of any native resident or migratory fish or wildlife 1,2,7,8, species or with established native resident or 9,10,11, ../ migratory wildlife corridors, or impede the use 12, 13, of native wildlife nursery sites? 14, 15, 16, 17 Palo Alto Recycled Water Project Page 46 Initial StudyfMitigated Negative Declaration No Impact Issues and Supporting Information Resources Sources Potentially Potentially Less Than No Significant Significant Significant Impact Would the project: Issues Unless Impact Mitigation Incorporated d) Conflict with any local policies or ordinances protecting biological resources, such as a tree 1,2,7,8, preservation policy or as defined by the City of 9, 10, 11, ../ Palo Alto's Tree Preservation Ordinance 12, 13, (Municipal Code Section 8.10)? 14, 15, 16, 17, 52 e) Conflict with any applicable Habitat 1,2,7,8, Conservation Plan, Natural Community 9,10, 11, ../ Conservation Plan, or other approved local, 12, 13, regional, or state habitat conservation plan? 14,15, 16,17 DISCUSSION: Biological Resources Setting With the exception of creek crossings and critical roadway crossings, the proposed pipeline alignment, alignment options, and lateral pipes would be installed using standard open trench construction techniques. Trenchless construction techniques (i.e., attaching to the side of existing structures, installing in roadways on bridges, or microtunneling) would be used to install the sections of pipeline crossing creeks that lie in the proposed alignment, alignment options, and laterals, as well as the section of pipeline crossing US-lO 1 at Corporation Way in the proposed alignment. Water quality effects to regulated trees and the Adaptive Management Program are discussed in item d below. In general, the proposed alignment, alignment options, booster pump station, and RWQCP pump station are located within existing roadways and/or disturbed areas (i.e., utilities right-of-ways, landscaped areas). Vegetation within these areas is generally limited to non-native grasses (turf and weedy vegetation) and a mix of native and ornamental trees and shrubs. The surrounding area is primarily urban and suburban in character, consisting predominantly of commercial, industrial, and residential uses. Scattered throughout this area are a variety of ruderal and urban habitats such as City parks (e.g., Hoover Park, Mitchell Park), athletic playing fields (e.g., Stanford/Palo Alto Community Playing Fields), roadway medians and shoulders, and landscaped grounds. The San Francisco Bay and its associated northern coastal salt marsh and coastal freshwater marsh habitats in the Palo Alto Baylands Natural Preserve (BayJands Preserve) occur to the northeast of the proposed Project, with a portion of the project site within the BayJands Preserve. Also, several creeks (e.g., Adobe Creek, Barron Creek, Matadero Creek) occur in the Project vicinity, portions of which support riparian habitat. The majority of the creeks that lie in the proposed alignment, alignment options, and lateral alignments are concrete-lined and/or culverted. a) Potentially Significant Unless Mitigation Incorporated. Christopher A. Joseph & Associates (CAJA) conducted a one-day reconnaissance-level field survey of the study area on September 19,2007. The purpose of this field survey was to assess the existing conditions of the study area, including characterizing and delineating the vegetation communities and wildlife habitats in the study area and evaluating the potential for these communities to support special-status plant and animal species, and to evaluate the potential impacts of the Palo Alto i""~'Y\"i"U Water Project Page 47 StudylMitigated Negative Declaration • proposed Project on those special-status species potentially occurring in the study area. In general, the survey was conducted by car where the pipeline alignments lie within roadways and by foot where the alignments and pump station locations lie within disturbed areas. Where access was limited or prohibited surveys were conducted from fence lines and/or by aerial photo interpretation. Prior to conducting the field survey, a list of special-status plants (Table I in Appendix C) and a list of special-status animals (Table 2 in Appendix C) that are known to occur or have the potential to occur in the vicinity of the study area were developed. These lists were based on review of available background information pertaining to biological resources in the vicinity of the study area. Information that was reviewed includes (1) the California Department of Fish and Game's (CDFG) California Natural Diversity Database (CNDDB) (CDFG, 2007), (2) the California Native Plant Society's (CNPS) Electronic Inventory (CNPS, 2007), (3) the U.S. Fish and Wildlife Service's (USFWS) list of federal and endangered species that occur in or may be affected by projects in the Palo Alto and Mountain View U.S. Geological Survey (USGS) 7.5 ~ Minute Quads (USFWS 2007); and (5) the Palo Alto Comprehensive Plan (Palo Alto, 2007). Each plant and animal species was then evaluated during the field survey for their potential for occurrence in the study area. Species rated as having a "medium" or "high" potential for occurrence or identified as "present" (refer to Table 1 and Table 2 in Appendix C) are discussed further below. Plants and animals rated as having "no" or "low" potential for occurrence are not discussed because these species are not likely to occur in the study area due to the fact that (1) the general habitat and/or micro-habitat requirements for the species are not present; (2) the species distribution does not include the study area; (3) the quality of the habitat in the study area likely precludes the species or discourages use of the habitat by the species; and/or (4) the species was not detected during the field survey; however, exceptions are California clapper rail (Rallus longirostris obsoletus), California black rail (Laterallus jamaicensis), and other migratory birds and raptors. These species are discussed due to the proximity of potential habitat within the Baylands Preserve and/or creek corridors east of the study area, and to the potential for construction-related activities to disturb these species, if present; although the potential is considered low given the existing levels of human-related disturbances (e.g., foot and bicycle traffic on the San Francisco Bay Trail and vehicular traffic on East Bayshore Road) in the surrounding area. Special-Status Plants Based on review of available background information, 60 special-status plants have been documented in the vicinity of the study area (Table 1 in Appendix C). Of these, 51 species have "no" potential and 9 have "low" potential for occurrence in the study area. No special- status plants have been identified as having a "medium" or "high" potential for occurrence or as "present" in the study area. The majority of the study area is hardscaped or landscaped, or has been previously disturbed by construction and operation of existing development, and is now dominated by non-native vegetation. Because ofthe level of disturbance and dominance of non-native vegetation, the study area is not likely to support any of the special-status plants evaluated and, therefore, the proposed Project is not expected to result in impacts to special- status plant species. A number of special-status plants listed in Table 1 of Appendix C could occur in habitats east of the study area. However, these habitats would not be disturbed by the proposed Project. Additionally, measures prescribed in item b) below would avoid impacts to those special-status plant species potentially occurring in adjacent habitats. Special-Status Animals Palo Alto Recycled Water Project Page 48 Initial StudylMitigated Negative Declaration Twenty-nine special-status animals have been documented in the vicinity of the study area (Table 2 in Appendix C). Of these species, 22 have "no" potential, 3 have "low" potential, and 21 have "medium" potential for occurrence in the study area, and 2 have been identified as "present". As discussed above, only those special-status species rated as having a "medium" potential for occurrence (burrowing owl (Athene cunicularialJ and salt marsh common yellow throat [Geothlypis trichas sinuosa]) and identified as "present" (California red-legged frog (Ran a aurora draytonii] and western pond turtle [Actinemys marmorata]) in the study area, as well as California clapper rail, California black rail, and other migratory birds and raptors are discussed in more detail below. Amphibians & Reptiles California red-legged frog California red-legged frog (CRLF) is federally-listed as threatened and is state designated as a species of special concern. CRLFs occur in different habitats depending on their life stage, the season, and weather conditions. They typically use a variety of aquatic (e.g. ephemeral ponds, intermittent streams, seasonal wetlands, springs, seeps, perennial creeks, artificial ponds, marshes, dune ponds, lagoons), riparian, and upland habitats. The common factor among habitats where CRLFs occur is the association with a permanent water source, ideally free of non-native predators (USFWS, 2002). Although CRLFs are largely absent from urban and suburban settings (Bulger, 2002), potential habitat is present in the study area within Matadero Creek at Hillview Avenue. Potential habitat is also present east of the study area within Matadero Creek and Adobe Creek downstream of East Bayshore Road and within Barron Creek downstream of Miranda Avenue. The other reaches of the creeks that lie in the proposed alignment, alignment options, and lateral alignments do not provide potential habitat for CRLF, as these reaches are unvegetated, concrete-lined and/or culverted, and are separated from potential upstream and downstream habitat by other reaches that similarly have been channelized and/or placed in culverts. Several occurrences of CRLF are recorded in the CNDDB within a five-mile radius of the study area, including an occurrence that encompasses the proposed alignment along Hillview Avenue at Matadero Creek. Tadpoles, juveniles, and adults have been observed in Matadero Creek between the Old Page Mill Road Bridge and Foothill Boulevard and in Deer Creek from the Matadero Creek confluence to Arastradero Road (CDFG, 2007). As discussed above, trenchless construction techniques will be used to install the pipeline at creek crossings. With the exception of the section of pipeline crossing Adobe Creek at US- 101 in alignment Option 1 (where some in-channel work may be needed), use of such techniques would avoid disturbance to the creeks and their associated riparian habitat, where present, thereby, avoiding direct impacts (e.g., harassment, injury, mortality) to CRLFs. However, installation of the sections of the pipeline crossing Matadero Creek at Hillview A venue and Barron Creek at Miranda A venue in the proposed alignment could result in indirect impacts (e.g., temporal loss of habitat due to increased levels of human disturbance, decreased water quality due to unintentional releases of construction materials into the creek) to CRLF, in areas supporting suitable habitat for CRLFs, due to the proximity of potential habitat upstream and/or downstream of these crossings. Mitigation Measure BIO-l would be implemented prior to and during the installation of the sections of pipeline crossing Matadero Creek at Hwy 101, Matadero Creek at Hillview Avenue, and Barron Creek at Miranda A venue to avoid indirect impaets to CRLFs, if present. Installation of the section of pipeline crossing Adobe Creek at US-l Olin alignment Option 1 may require some in-channel work due to the limited accessibility of the side of the overpass Palo Alto Recycled Water Project Page 49 StudylMitigated Negative Declaration to which the pipeline would attach. Although the potential for occurrence of CRLFs at this location is considered to be low because of the existing conditions (i.e., unvegetated, concrete-lined channel), there is potential for construction activities to result in direct and indirect impacts to CRLFs due to the proximity of potential habitat downstream. Mitigation Measure BIO-l and Mitigation Measure BIO-2 would be implemented prior to and during the installation of the section of pipeline crossing Adobe Creek at US-WI to avoid substantial adverse affects to CRLFs and thus the impact would be less than significant. Western Pond Turtle Similar to the CRLF, the western pond turtle (WPT) is associated with a variety of aquatic habitats, both permanent and intermittent, including rivers, creeks, small lakes and ponds, marshes, irrigation ditches, and reservoirs. Although WPTs spend much of their lives in water, they require terrestrial habitats for nesting. They also may overwinter (meaning a period of reduced or no activity during the winter which may include periods of a hibernation-like state of reduced physiological activity) on land and may spend part of the warmest months in aestivation (meaning an inactive state that individuals enter in the hottest weeks of the year) on land. The WPT is designated as a species of special concern by the CDFG. Potential habitat for WPTs occurs within portions of the creeks that lie in and adjacent to the study area, including those identified as supporting potential habitat for CRLFs. Also, several occurrences of turtles have been recorded in the CNDDB within the Project vicinity. The data on occurrence of CRLFs in Matadero Creek between Old Page Mill Road Bridge and Foothill Boulevard and in Deer Creek from the Matadero Creek confluence to Arastradero Road also includes observations of WPTs (CDFG, 2007). Similar to CRLFs, installation of the sections of pipeline crossing Matadero Creek at Hillview Avenue and Barron Creek at Miranda A venue in the proposed alignment could result in indirect impacts to WPTs. Also, the installation of the section of pipeline crossing Adobe Creek at Hwy 101 in alignment Option 1 could result in direct and indirect impacts to WPTs. Mitigation Measure BIO-I would be implemented prior to and during the installation of the sections of pipeline crossing Matadero Creek at US-WI, Matadero Creek at Hillview Avenue, and Barron Creek at Miranda A venue to avoid indirect impacts to WPTs, if present. Mitigation Measure BIO-l and Mitigation Measure BIO-2 would be implemented prior to and during the installation of the section of pipeline crossing Adobe Creek at US-l 0 1 to avoid indirect and direct impacts to WTPs. Birds Salt Mash Common Yellowthroat Salt marsh common yellowthroat is designated a species of special concern by the CDFG. This species inhabits thick, tangled vegetation, particularly in wet areas. In Santa Clara County, common yellowthroat is a regular breeder and is fairly common in the fall, winter, and spring, and common in the summer (Bousman, 2005). Nesting sites for common yellowthroat may be over water, in emergent aquatic vegetation, dense shrubs, or other dense growth. Nests are typically on or near (within 10 centimeters [4 inches]) the ground. The nesting season generally extends from early April to mid-July, with peak activity in May and June. The study area does not support potential nesting habitat for common yellowthroat. However, common yellowthroat may occasionally forage in the study area, particularly east of East Bayshore Road in the vicinity of alignment Option 1 and alignment Option 2, and Palo Alto Recycled Water Project Page 50 Initial StudylMitigated Negative Declaration potential nesting habitat is present in the marsh and riparian habitats within the Baylands Preserve. There are several occurrences of common yellowthroat recorded in the CNDDB within a five mile-radius of the study area, including one of five breeding pairs from 1985 at the end of Mayfield Slough, at the junction with Matadero Creek, and one of two breeding pairs from 1985 at Adobe Creek just east ofUS-IOI (CDFG 2007). Because of the presence of potential foraging habitat in the study area and the proximity of potential nesting habitat to the Project, construction-related activities (e.g., noise and vibration from construction equipment, increased human activities) associated with installation of the pipeline in alignment Option 1 or alignment Option 2 east of US-I 0 I could adversely affect nesting common yellowthroats, if present; although this potential is considered low given the existing levels of human-related disturbances in Project vicinity. Mitigation Measure B10-3 would be implemented prior construction activities associated with installation of the pipeline in aligrunent Option I or alignment Option 2 east of US-l 0 I to avoid substantial adverse effects to common yellowthroats. California Clapper Rail California clapper rail is federaUy-and state-listed as endangered. The clapper rail is a year- round resident of the San Francisco Bay associated with salt and brackish marshes traversed by tidal sloughs. In the South and Central San Francisco Bay, clapper rails typically inhabit salt marshes dominated by pickleweed (Saiicornia virginica) and cordgrass (Spartina foliasa). Nesting begins in late March, peaking in late-April and May, and extends into early July. Potential foraging and nesting habitat for clapper rails does not occur in much of the study area. However, the RWQCP is located within the Baylands Preserve, which contains northern coastal salt marsh habitat that supports potential habitat for clapper rails. There are several occurrences of clapper rail recorded in the CNDDB within a five-mile radius of the Project. As discussed above, the potential for construction-related activities to adversely affect clapper rails is considered low given the existing levels of human-related disturbances in the Project vicinity, but the USFWS and CDFG typically recommend surveys be conducted for projects within 700 ft of potential nesting habitat to avoid disturbance of clapper rails during the nesting season (Browning, 2006). Mitigation Measure BIO-4 would be implemented to avoid substantial adverse effects to clapper rail, if present. California Black Rail Similar to the California clapper rail, the California black rail inhabits tidal marshes, but it can also occur in freshwater wetlands. The black rail is state-listed as threatened and its occurrence in Santa Clara County is very rare or casual in the fall and winter (Bousman 2005). Black rails nest in high portions of salt marshes, shallow freshwater marshes, wet meadow, and flooded grassy vegetation. Most nesting areas are vegetated by fine-stemmed emergent plants, rushes, grasses, or sedges. Nesting sites in coastal California are characterized by taller vegetation, greater vegetation coverage and height of alkali heath (Frankenia grandi/alia), higher insect abundance, and lower amphipod abundance. In general, the nesting season for the black rail extends from February through August, peaking in early May. There are records indicating that black rail nest in the South San Francisco Bay, but these records are old and it is believed that this species may have disappeared from this area as a breeding species (Evens, 1999/2000). Black rails do occur in the South San Francisco Bay during the winter months. Because evidence is lacking as to where wintering rails in the South Bay go during the breeding season (Evens, 1999/2000), as well as proof (e.g., Palo Alto Recycled Water Project Page 51 StudylMitigated Negative Declaration vocalizations heard or observations recorded) of presence in the South Bay during the breeding season (Bartes, 2006), black rails could still be nesting in the South San Francisco Bay. Black rails are rarely heard calling and even more rarely seen. As with clapper rails, the potential for construction-related activities east of Hwy 101 to adversely affect black rails is considered low given the existing levels of human disturbance in the Project vicinity. However, Mitigation Measure BIO-4 would be implemented to avoid substantial adverse effects to black rail, if present. Burrowing Owl Burrowing owl (BUOW) is designated a species of special concern by the CDFG. It is a resident of open habitats (e.g., annual and perennial grasslands and deserts and arid scrub lands with bare ground or low-growing vegetation) and requires burrows for protection, cover, and nesting. BUOWs typically use burrows made by fossorial mammals, such as California ground squirrels (Spermophilus beechyi) or American badger (Taxidea taxus), but will also use man-made structures (e.g., culverts, concrete, asphalt, wood piles). BUOWs may use a site for breeding, wintering, foraging, and/or migration stopovers, and show moderate to high site fidelity (Le., re-using general areas and even particular burrows year after year). Depending on the location, the nesting season occurs between February 1st and August 31st. The study area provides potential foraging and nesting habitat for BUOWs, particularly within the grassland habitat on the site proposed for the pump station at the R WQCP. The grassland habitat in the vicinity of the pipeline lateral off the southern end of the backbone alignment on Hillview A venue, and the ruderal habitat east of the San Francisco Bay Trail and East Bayshore Parkway also provide habitat for BUOWs; however, the potential for occurrence within these habitats is considered low given the existing conditions (lack of burrow donors and/or intensity of human-related disturbances). There are several occurrences of BUOW recorded in the CNDDB within a five-mile radius of the study area. Although no individual owls or evidence of owl use (e.g., white-wash, pellets, prey remains) were observed on the site at the RWQCP during a September 2006 field survey, BUOWs could use the burrows on the site and, if present, could be adversely affected by installation of pump station for the proposed project. Mitigation Measure BIO-5 would be implemented prior to the onset of construction activities to avoid substantial adverse effects to BUOW. Other Migratory Birds and Raptors In addition to the bird species discussed above, habitats in the Project vicinity, particularly the northern coastal salt marsh, coastal freshwater marsh, and willow riparian habitats east of the study area, support potential nesting habitat for other migratory birds and raptors, such as Alameda song sparrow (Melospiza melodia pusillula), American kestrel (Falco sparverius), northern harrier (Circus cyaneus), red-winged blackbird (Agelaius phoeniceus), western meadowlark (Sturn ella neglecta), white-tailed kite (Elan us leucurus), and yellow warbler (Dendroica petechia brewsteri). Also, the roadway overpasses and recreational bridges crossing creeks in the study area support potential nesting habitat for those species that attach their nests to structures, such as cliff swallow (Petrochelidon pyrrhonota). Although only some of these species are protected by the CDFG and/or USFWS, the majority, if not all, are protected under the Migratory Bird Treaty Act (MBT A). With a few exceptions, most birds are considered migratory under the MBT A. The MBT A prohibits taking, killing, possessing, transporting, and importing of migratory birds, parts of migratory birds, and their eggs and nests, except when specifically authorized by the Department of Interior. As used in the act, the term "take" is defined as meaning, "to pursue, hunt, capture, collect, kill or attempt to Palo Alto Recycled Water Project Page 52 Initial StudylMitigated Negative Declaration pursue, hunt, shoot, capture, collect or kill, unless the context otherwise requires." Disturbances that cause nest abandonment and/or loss of reproductive effort or loss of habitat upon which these birds depend would be in violation of the MBT A, as well as other state and federal regulations for those species specifically protected by these agencies. Mitigation Measure BIO-3 would be implemented prior to Project construction to avoid substantial adverse effects to other nesting migratory birds and raptors. Implementation of Mitigation Measures BIO-I, BIO-2, BIO-3, and BIO-4 would reduce potential adverse effects to special-status animal species to a less than significant level. b) Potentially Significant Unless Mitigation Incorporated. Existing vegetation communities and wildlife habitats in the study area were characterized during a one-day reconnaissance- level field survey on September 19,2007. Prior to conducting the field survey, a review of available background information was conducted pertaining to sensitive natural communities in the Project vicinity, including the USFWS National Wetland Inventory Maps (Mountain View and Palo Alto 7 :h Minute Quads), the CNDDB (a five mile search radius from the study area), and the Palo Alto Comprehensive Plan (Palo Alto 2007). Based on the background review, the vegetation communities and wildlife habitats identified in the study area during the field survey were evaluated to determine if they are considered sensitive by local or regional plans, policies, regulations, or by the CDFG or USFWS. Methods similar to those for the pipeline and the booster pump station at Mayfield Soccer Fields were used to determine if the vegetation communities and wildlife habitats identified on the site proposed for the pump station at the RWQCP are considered sensitive by local or regional plans, policies, regulations, or by the CDFG or USFWS. Although there are several sensitive natural communities documented as occurring in the vicinity of the RWQCP (e.g., northern coastal salt marsh, serpentine bunchgrass, valley oak woodland), the site proposed for the installation of the pump station does not support any of these communities or habitats. Consequently, the installation of the pump station for the proposed project would not have a substantial adverse effect on any riparian habitat or other sensitive natural community. Several sensitive natural communities are documented as occurring in the Project vicinity, including (but not limited to) northern coastal salt marsh, valley oak woodland, and serpentine bunchgrass. With the exception of the creeks (reaches of Adobe Creek, Barron Creek, and Matadero Creek), which will be further discussed under item c), and the riparian habitat along Matadero Creek at Hillview A venue and Barron Creek at Miranda A venue, the study area does not support any of the other sensitive communities documented in the Project vicinity. However, a number of these communities occur adjacent to the study area. Northern coastal salt marsh and coastal freshwater marsh are present within the Baylands Preserve, and willow riparian is present along Adobe Creek downstream of East Bayshore Road. Also, Matadero Creek upstream of Hillview A venue, Barron Creek downstream of Miranda A venue and near the intersection of Hillview A venue and Arastradero Road support riparian habitat that is contiguous to that in the study area. Although there are trees along the north bank of Adobe Creek at Middlefield Road, these are not considered "riparian vegetation". The creek is concrete-lined in this reach and the vegetation is associated with the adjacent parking lot. The Project would not result in direct impacts (e.g., removal or damage) to the riparian habitat in the study area, as trenchless construction techniques would be used to install the sections of pipeline crossing Matadero Creek at Hillview A venue and Barron Creek at Miranda A venue. However, the riparian habitat could be indirectly impacted by the adjacent construction activities, such as inadvertent damage from equipment or vehicle staging or Palo Alto Recycled Water Y' """10''''"'''' Negative Declaration construction site runoff. Also, the sensitive communities within the Baylands Preserve and creek corridors downstream of East Bayshore Road could be indirectly impacted by construction activities associated with the installation of alignment Option I, alignment Option 2, and the RWQCP pump station. While the RWQCP is located within the Baylands Preserve, the pump station site consists of disturbed land and construction would be confined to that area. Measures prescribed above in item a) would avoid indirect impacts to the riparian habitat along Matadero Creek at Hillview A venue and along Barron Creek at Miranda Avenue. Mitigation Measure BIO-6 would be implemented to avoid indirect impacts to sensitive natural communities within the Baylands Preserve and creek corridors downstream of East Bayshore Road. As mentioned in the discussion above, the reaches of Adobe Creek, Barron Creek, and Matadero Creek that lie within the study area are considered sensitive and are potentially subject to regulation by the u.s. Army Corps of Engineers (USACE) under Section 404 of the Clean Water Act (CWA). These features are also subject to regulation by the RWQCB under Section 401 of the CW A, and the CDFG under Section 1600 of the California Fish and Game Code. With the exception of the Adobe Creek crossing at US-IOI in alignment Option I, the installation of the pipeline and construction of the booster pump station would not result in direct impacts (Le., placement of dredge or fill material) to potentially jurisdictional waters. Installation of the proposed alignment, alignment options, and the laterals would be completed using trenchless construction techniques. Also, construction of the booster pump station would not result in impacts to potentially jurisdictional waters, as no potential jurisdictional waters or wetland are present at the proposed location. Except for the Adobe Creek Crossing at US-I 0 1, the project would not have any direct impacts to these potentially jurisdictional waters, since as the pipeline, as stated above, would be installed using trenchless construction techniques. Construction activities associated with the installation of the sections of pipeline at creek crossings could result in indirect impacts (e.g., decreased water quality) to potentially jurisdictional waters. Implementation of Mitigation Measure BIO-6 would ensure that potentially jurisdictional waters would not be indirectly impacted by construction activities. Although the installation of the section of pipeline crossing Adobe Creek at Hwy 101 in alignment Option 1 would be installed using trenchless construction techniques, some in- channel work may be necessary due to the limited accessibility of the side of the overpass to which the pipeline would attach. If in-channel work is necessary, jurisdictional waters could be temporarily impacted by the placement offill material. Mitigation Measure BIO-7 would be implemented to avoid substantial adverse effects to jurisdictional waters. No federally protected wetlands, as defined by Section 404 of the Clean Water Act are present on the site proposed for the pump station at the RWQCP. c) Less-than-Significant Impact. Although portions of the study area likely serve as travel routes for wildlife species adapted to urban and suburban environments as they move within their home ranges in search for food, cover, and other needs, installation of the proposed alignment, alignment options, lateral pipes, and construction of the booster pump station would not substantially interfere with the movement of these species. Construction of the proposed Project would result in temporary and permanent impacts to habitats that are already frequently disturbed andlor developed. Additionally, the Project would not impede the use of any native wildlife nursery site. The site proposed for the pump station at the R WQCP is not within a known movement corridor for wildlife species and does not support habitat considered to be suitable for a native wildlife nursery site. Palo Alto Recycled Water Project Page 54 Initial StudylMitigated Negative Declaration d) Less than Significant Impact. The Palo Alto Comprehensive Plan (Palo Alto 2007) and the Palo Alto Municipal Code provide protection to biological resources within the City's limits. The City's Comprehensive plan defines policies for protecting creeks and riparian areas, wetlands, urban forest, and wildlife. Implementation of measures prescribed in items a), b), and c) above would ensure conformance with local regulations. Regulated trees (protected trees, street trees growing within the street right-of-way, and designated trees) could be removed during the construction of the booster pump station and as such could conflict with the City's Municipal Code and the Tree Technical Manual. Any necessary tree removal would occur on City owned land, PUB, or on leased or private property (e.g., Mayfield Soccer Fields). Protected trees would remain. Designated trees would be protected or replaced according to the Tree Canopy Replacement Formula, Tree Technical Manual, Section 3.30, and street trees would be replaced with species determined by PW Operations. Tree removal of non-protected trees could occur on City owned land, PUE, private property (e.g., Mayfield Soccer Fields), or leased land. The City must comply with the Tree Technical Manual regarding the removal and replacement of trees. Compliance with the Manual's practices would ensure that potential conflicts would be considered less than significant. The installation of the proposed alignment, alignment options, and laterals at creek crossings could require work within SCVWD's jurisdiction. Such activities would conflict with the SCVWD's Water Resources Protection Ordinance (Ordinance 06-1). Prior to the onset of construction activities, an encroachment permit application shall be submitted to the SCVWD. Modification or use of facilities andlor easements within SCVWD jurisdiction shall not occur until the permit is received, or correspondence is received indicating that a permit is not required. All Coast Live Oak, Valley Oak, and Coast Redwood of specific diameters, and Heritage Trees are protected under the PAMC Section 8.10 (Tree Ordinance). Protected trees are located throughout the proposed recycled water service area. In areas where the existing site conditions are of poor quality, particularly areas with poor drainage, protected trees may be more sensitive to irrigation by recycled water (due to the higher levels of salts in the recycled water which can accumulate in the root zone due to the soil type and poor drainage). Under this scenario, the salt content in the recycled water could result in the decline of the biological health of protected trees. However, because the project integrates an Adaptive Management Program in addressing potential effects of recycled water use on trees, adverse effects on protected trees would be avoided. Please refer to Section H, Hydrology and Water Quality for a discussion of effects on trees from recycled water use and to the Project Description for a discussion of the Adaptive Management Program. Installation of the pump station at the RWQCP would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. The pump station would comply with the requirements of both the Baylands Master Plan and Santa Clara County's Airport Master Plan for the Palo Alto Airport. The trees on the site proposed for the pump station at the RWQCP are not protected by City of Palo Alto's Municipal Code Chapter 8.10. e) No Impact. No Habitat Conservation Plans, Natural Community Conservation Plans, or other local or regional plans have been adopted within the City, which encompasses the study area; therefore, no impacts are anticipated and no specific mitigation measures are required. Mitigation Measures: Palo Alto Recycled Water Project 55 Negative Declaration The following mitigation measures address the potential impacts of the Project to biological resources within or adjacent to the study area. Implementation of these measures would reduce potential impacts to a less-than-significant level. BIO-l: Creek Protection. The following measures would be implemented to avoid, minimize, or otherwise offset potential adverse effects to CRLFs and WPTs, and their habitats prior to and during the installation of the sections of pipeline crossing Adobe Creek at US-lOI, Matadero Creek at Hillview A venue, and Barron Creek at Miranda Avenue. These measures are not applicable to Adobe Creek at Middlefield Road as no suitable habitat is present. • A SWPPP that complies with the statewide General Permit administered by the California State Water Resources Control Board for the NPDES shall be developed and implemented to protect the water quality of the creeks that lie in the study area. Appropriate erosion and sediment control and non-sediment pollution control (Le., sources of pollution generated by construction equipment and material) BMPs shall be prescribed in the SWPPP, and erosion and sediment control material included in the SWPPP shall be certified as weed free. • Construction activities associated with the installation of the sections of pipeline crossing Adobe Creek at US-lOI, Matadero Creek at Hillview Avenue, and Barron Creek at Miranda Avenue shall be limited to the dry season (in general, between June 15th through October 15th) when flows are reduced and CRLF and WPT are least likely to be present. • A qualified biologist shall conduct a worker education program prior to the onset of construction activities associated with the installation of the sections of pipeline crossing Adobe Creek at US- 101, Matadero Creek at Hillview Avenue, and Barron Creek at Miranda Avenue. Construction workers shall be briefed on, at a minimum, a description of the CRLF and WPT and its habitats, the general measures that are being implemented to conserve CRLF and WPT for the Project, and the boundaries within which the creek crossing may be accomplished. A fact sheet conveying this information shall also be prepared for distribution to the workers. • A qualified biologist shall be retained to monitor the construction activities associated with the installation of the sections of pipeline crossing Adobe Creek at US-IO 1, Matadero Creek at Hillview A venue, and Barron Creek at Miranda A venue. The biologist shall have expertise in the areas of CRLF and WPT biology and ecology, amphibian and reptiles/habitat relationships, and biological monitoring. The biologist shall also monitor performance of construction site management practices for the purpose of identifying and recommending measures to avoid any condition that could adversely affect CRLF and WPT or their habitat. The City and their contractor, upon notification from the biologist, shall halt activities causing the condition affecting CRLF and WTP or their habitat. Work shall only resume with approval from the biologist. • Food and food-related trash items associated with construction workers shall be enclosed in sealed containers and regularly removed from the work area to deter potential predators. • All staging areas and fueling and maintenance of vehicles and other equipment shall occur at least 60 feet from any riparian habitat, creek, or other water body to ensure that habitat contamination does not occur from such activities. BIO-2: Conduct surveys for CRLF and WPT prior to the installation of the section of pipeline crossing Adobe Creek at Hwy 101, and avoid impacts to CRLF and WPT, if present. If the Adobe Creek crossing at Hwy 101 requires in-channel work, a qualified biologist shall conduct pre- construction surveys following standard visual encounter techniques to confirm presence or absence of CRLFs and WPTs in the work area. At minimum, the biologist shall be familiar with distinguishing Palo Alto Recycled Watcr Project Page 56 Initial StudylMitigatcd Negative Declaration physical characteristics of all the life stages of the CRLF, and identifying WPTs. The biologist shall conduct at least one day and one night survey within one week of construction activities. Surveys shall be conducted, at minimum, 300 ft up-and downstream of the creek crossing. With the exception of compliance with Measure BIO-l, if no individual CRLFs or WPTs are encountered, no further mitigation would be required. However, if CRLFs and/or WTPs are found, construction activities shall be postponed and the appropriate resources agency (USFWS for CRLF and CDFG for WPT) shall be consulted to determine the extent of potential impacts to CRLFs and/or WPTs and to identify measures necessary to avoid, minimize, and mitigate these impacts, such as obtaining an incidental take permit (for CRLF) or developing an exclusion and relocation program. BIO-3: Avoid disturbing nesting birds. To avoid disturbance to nesting common yellowthroat and other migratory birds and raptors (e.g., American kestrel, northern harrier, white-tailed kite), one of the following measures shall be implemented: • Conduct the installation of the proposed alignment, alignment options, laterals, and the construction of pump station during the non-breeding season (September 1st through January 31st); OR • Conduct pre-construction surveys for nesting birds if construction activities are to take place during the nesting season (in general, February 1st through August 31st). Pre-construction surveys shall be conducted by a qualified biologist no more than three days prior to the onset of construction activities to confirm presence or absence of active nests in the Project vicinity. The extent of the area to be surveyed shall be determined by the biologist considering (1) the nature of the construction activities, (2) the existing level of human-related disturbances, and (3) the availability of suitable nesting habitat in the Project vicinity. If active nests are encountered, species-specific measures shall be prepared by· a qualified biologist, in coordination with the CDFG and other appropriate agencies, and implemented to prevent direct loss or abandonment of the active nest. At a minimum, construction activities in the vicinity of nests shall be deferred until the young have fledged and an exclusion buffer zone shall be established. CDFG typically recommends a minimum exclusion buffer of 25 feet for songbird nests, and 200 to 500 feet for raptor nests, depending on the species and location. The perimeter of the nest-setback zone shall be fenced or adequately demarcated with staked flagging at 20-foot intervals, and construction personnel shall be restricted from the area. A survey report by the qualified biologist verifying that the young have fledged shall be submitted to City for review and concurrence of the City is required prior to initiation of construction activities within the nest-set-back zone. BIO-4: Avoid disturbing nesting California clapper and black rails during the installation of the pipeline in alignment Option 1 or alignment Option 2 east of US-101 and construction of the pump station at the RWQCP. To avoid substantial adverse effects to nesting California clapper rails and black rails, installation of alignment Option 1 or alignment Option 2 east of US-lO 1 and construction of the pump station at the RWQCP should either be conducted outside of the breeding season for clapper rails (in general, February 1st through August 31st) or construction activities east of US-lOl and at the RWQCP site should be started prior to the breeding season and disturbance activities continued throughout the spring to prevent birds from establishing nests in surrounding habitats. This would prevent abandonment of eggs or young that could occur if nesting establishes prior to construction activities. If this is not feasible, a qualified biologist shall conduct protocol-level surveys for clapper rails (following methods outlined in the Draft Survey Protocol: California Clapper Rail (Rallus longistrostris obsoletus)(USFWS 2000) and pre- construction surveys for California black rail to determine presence or absence of rail breeding activity in Palo Alto Recycled Water Project Page 57 StudylMitigated Negative Declaration the vicinity of the Project. A qualified biologist is an individual who has experience conducting protocol- level surveys for California clapper rails, and experience surveying for California black rails using a standardized tape call-back response protocol. Prior to commencement of the surveys, the biologist shall prepare a brief letter report describing the survey design and submit it to the USFWS (for California clapper rail only) and CDFG for review and approval. Upon the completion of the surveys, survey results shall be submitted to the USFWS and CDFG for a final decision on the possibility of doing work during the breeding season for the clapper and black rail. Protocol-level surveys are only necessary during the installation of the pipeline east ofUS-lOl. If construction activities east ofUS-lOl are conducted outside the breeding season, no surveys would be necessary. BIO-5: Conduct protocol-level BUOW surveys prior to the installation of the pump station proposed at the RWQCP, and avoid impacts to owls, if present, during project construction. A qualified biologist shall conduct a protocol-level survey for burrowing owl following the methods outlined in the Burrowing Owl Survey Protocol and Mitigation Guidelines. A survey for owls shall be conducted during the breeding season at the RWQCP site (in general, February 1st through August 31st, peaking between April 15th and July 15th). If no owls are observed using the site during the breeding season surveys, winter surveys shall be conducted. Winter surveys shall be conducted between December 1st and January 31st, during the period when wintering owls are most likely to be present, if necessary. A complete owl survey consists of four site visits, on separate days and during weather that is conducive to observing owls outside their burrows. If no owls are found during the breeding or winter season surveys, no further mitigation shall be required, provided construction activities or destruction of suitable burrows commence within 30 days of the date of the last survey. Otherwise, a pre-construction survey for owls shall be conducted no more than 30 days prior to the onset of construction activities. If surveys confirm presence of owls on the site, mitigation measures shall be incorporated into the proposed project, in coordination with CDFG, to avoid and/or minimize impacts to burrowing owls, their burrows and foraging habitat on the site. The following measures shall be taken into consideration: 1) occupied burrows shall not be disturbed during the nesting season, unless a qualified biologist approved by the CDFG verifies through non-invasive methods that either: a) the owls have not begun egg-laying and incubation; or b) that the juveniles from those burrows are foraging independently and capable of independent survival; 2) to offset the loss of foraging and burrow habitat on the project site, a minimum of 6.5 acres of foraging habitat per pair or unpaired resident bird, shall be acquired and permanently protected; 3) when destruction of occupied burrows is unavoidable, existing unsuitable burrows shall be enhanced (e.g., enlarged or cleared of debris) or new burrows shall be created (e.g., installing artificial burrows) at a minimum ratio of 1:] on protected lands; 4) if owls must be moved away from the disturbance area, passive relocation techniques shall be used rather to trapping; and 5) the project sponsor shall provide funding for long-term management and monitoring of the protected lands. BIO-6: Protection of Sensitive Communities. The following measures would be implemented prior to the onset of construction activities associated with the installation of alignment Option 1 or alignment Option 2 and the laterals adjacent to sensitive natural communities (e.g., northern coastal salt water marsh, coastal freshwater marsh, willow riparian habitat) to avoid potential adverse affects to these communities. • The limits of work shall be clearly delineated on all construction plans and silt fencing and/or construction fencing shall be installed around the work area, where extending beyond hardscaped areas. A qualified biologist shall monitor the fence installation and the fencing, at a minimum once per week, to ensure that the fence remains intact and functional, and that no encroachment has occurred into adjacent sensitive communities. • A qualified biologist shall brief construction workers on the location of sensitive communities that shall be preserved and the importance of avoidance. Palo Alto Recycled Water Project Page 58 Initial StudylMitigated Negative Declaration • Encroachment into adjacent communities shall be prohibited by construction workers, and storage of materials or equipment shall be prohibited in these areas. • In accordance with the SWPPP to be prepared for the Project, appropriate erosion and sediment control, and non-sediment pollution control (Le., sources of pollution generated by construction equipment and material) BMPs shaH be implemented to protect sensitive habitat adjacent to the Project. Erosion and sediment control material included in the SWPPP shaH be certified as weed free. BIO-7: State and Federal Permits. Ifin-channel work is necessary for the Adobe Creek crossing at Hwy 101 in alignment Option 1, federal and state authorization will be obtained prior to the onset of construction activities. Prior to the onset of construction activities, a Department of the Army 404 Permit application shall be submitted to the USACE, an Application for 401 Water Quality Certification and/or Report of Waste Discharge shall be submitted to the San Francisco RWQCB, and a Lake or Streambed Alternation Notification shall be submitted to the CDFG for impacts to Adobe Creek at US-I0 1. These permits must be obtained before the project is implemented. Mitigation measures associated with these permits may include minimizations measures such as implementation of construction site management practices (i.e., erosion and sediment control measures) and seasonal work restrictions. Impacts to potentially jurisdictional features shall not occur until the permits are received from the appropriate regulatory agencies, or correspondence is received from the agencies indicating that a permit is not required. E. CULTURAL RESOURCES Issues and Supporting Information Resources Sources Potentially Potentially Less Than No Significant Significant Significant Impact Would the project: Issues Unless Impact Mitigation Incorporated • a) Directly or indirectly destroy a local cultural 1,2, 18- resource that is recognized by City Council 38,57 ..;-resolution? b) Cause a substantial adverse change in the 1,2,lS-'..;-significance of an archaeological resource 38,57 pursuant to 15064.5? c) Directly or indirectly destroy a unique 1,2, IS- paleontological resource or site or unique 38, 57 ..;-geologic feature? d) Disturb any human remains, including those 1,2, 18-../' interred outside offorrnal cemeteries? 38,57 e) Adversely affect a historic resource listed or 1,2, 18- eligible for listing on the National and/or 38,57 ..;-California Register, or listed on the City's Historic Inventory? f) Eliminate important examples of major periods 1,2, 18- I ..;-of Cali fomi a history or prehistory? 38, 57 Palo Alto Recycled Water Project Page 59 Initial StudylMitigated Negative Declaration DISCUSSION: Cultural Resources Setting Records Search Records searches of pertinent survey and site data were conducted at the Northwest Information Center (NWIC) at Sonoma State University by William Self Associates (WSA). The initial record searches (File No. 07-0362, 07-1299) covered the entire project area and a one-quarter mile radius adjacent thereto. A later record search (File No. 07-1326) was conducted at the request of Cookie Him of the Division of Financial Assistance, at the State Water Resources Control Board, upon an initial review of the report for the purpose of examining the archaeological potential of closely associated areas located between the proposed routes of the pipeline backbone and laterals. Previous surveys, studies and archaeological records were accessed as they pertained to the project area. The record search included a review of the California Inventory of Historic Resources (1976), the Historic Property Directory (Office of Historic Preservation current computer list), NWIC records of archaeological sites and surveys, GLO Plats, historic maps, and other pertinent historic data available at the NWIC for Santa Clara County. Although no previously recorded archaeological sites exist within the proposed project area, the records search indicated that 11 previously recorded archaeological sites and one previously recorded isolate are located within Y4-mile of the project area (see Table 2-1 in Appendix D), and four sites are in the added areas between and around the proposed pipeline backbone and lateral options (see Table 2-2 in Appendix D). Survey Methods A field reconnaissance of the proposed Palo Alto Recycled Water Project (see Appendix D) was conducted on September 17, 2007 by WSA Staff Archaeologist, Melinda Hickman, M.A. Due to the extensive development in the APE, a windshield survey was conducted. As the APE is centered almost entirely on roadways paved in concrete, a windshield survey was considered suitable for this reconnaissance. This method of surveying involves traveling through the APE in order to search for standing historic structures and undeveloped parcels of land that may exhibit evidence of buried cultural resources. The proposed pump station at the RWQCP is situated in an area within which WSA Project Director, Eric Strother, M.A. RP A, conducted a pedestrian survey on October 30, 2006, as part of another project at the RWQCP. The results of this survey are being used for the current proposed project due to its applicability. All areas identified as being potentially sensitive for cultural materials were examined for the presence of historic or prehistoric site indicators. Historic site indicators include, but are not limited to foundations, fence lines, ditches, standing buildings, objects or structures such as sheds, or concentrations of materials at least 50 years in age, such as domestic refuse (glass bottles, ceramics, toys, buttons or leather shoes), or refuse from other pursuits such as agriculture (e.g., metal tanks, farm machinery parts, horse shoes) or structural materials (e.g., nails, glass window panes, corrugated metal, wood posts or planks, metal pipes and fittings, etc.). Prehistoric site indicators include, but are not limited to areas of darker soil with concentrations of ash, charcoal, bits of animal bone (burned or unburned), shell, flaked stone, ground stone, or even human bone. No historic or prehistoric cultural resources were observed within the APE. Native American Consultation WSA contacted the Native American Heritage Commission (NAHC) by letter on August 31, 2007, requesting information on sacred lands and a contact list of local tribal representatives or most likely Palo Alto Recycled Water Project Page 60 Initial StudylMitigated Negative Declaration descendents (MLD). A response was received from the NAHC on September 14, 2007 noting, "A record search of the sacred land tile has failed to indicate the presence of Native American cultural resources in the immediate project area." The letter also provided a list of Santa Clara County Native American Contacts. Due to the potentially sensitive nature of previously unrecorded prehistoric cultural resources that could be encountered in the project area, WSA contacted the local Native American representatives to solicit comment on the project's environmental documentation. On September 18, 2007, WSA Staff Archaeologist Melinda Hickman contacted by letter each of the listed Native American Contacts, explaining the nature of the project and soliciting comments and any additional information the individuals might have regarding cultural resources in the project area. No response to the letter solicitations was received. On October 2, 2007, WSA placed follow-up telephone calls to all of the individuals on the contact list. All solicited comments are reported in Appendix D. Sample consultation letters are provided in Appendix D. On October 23, 2006, on behalf of another project at the RWQCP that also encompassed the area of the proposed pump station, WSA had contacted the NAHC by letter, requesting information on sacred lands and a contact list of local tribal representatives or MLD. The results of that request are being used for this project due to their applicability. A response to the October 23rd request was received from the NAHC on October 27, 2006, noting, "A record search of the sacred land file has failed to indicate the presence of Native American cultural resources in the immediate project area." The letter also provided a list of Santa Clara County Native American Contacts. Due to the potentially sensitive nature of previously unrecorded prehistoric cultural resources that could be encountered in the project area, WSA contacted the local Native American representatives to solicit comment on the project's environmental documentation. WSA Project Manager Eric Strother contacted by letter each of the listed Native American Contacts, explaining the nature of the project and soliciting comments and any additional information the individuals might have regarding cultural resources in the project area. No responses to the consultation letters were received. On November 28, 2006, and again on November 29, 2006, WSA placed follow-up telephone calls to all of the individuals on the contact list. Messages were left when possible. No responses to the phone calls were received. All solicited comments are reported in Appendix D. Sample consultation letters are provided in Appendix D. Geoarchaeologicallnvestigation Mr. David Devries, Principal and Soils Scientist of Mesa Technical, Berkeley, California, prepared a geoarchaeological analysis of the Project area. The purpose of the study was to evaluate archaeological sensitivity for buried cultural features, within soils and sediments to be disturbed by Project-related construction activity. The Geoarchaeologicai Investigation, provided in appendix D, describes the archaeological sensitivity for each of the mqjor soil types within the Project area. These soil types include basin soils, recent/fan and floodplain soils, upland soils, terrace soils, and older alluvial fan soils. Basin soils comprise a large part of the APE (40-50 percent of the Project area) and are mapped on low ground in close proximity to the Bay. All are on formerly wet or seasonally wet grassland that is now diked, drained, and reclaimed. The archaeological potential of these deposits would be lower than for more recent fan deposits, because the food rich Bay would have been at a greater distance, and thus the land would have been less likely to have been occupied on a sustained basis. Approximately 30 percent of the APE is mapped as recent/fan and floodplain soils. These soils developed on recent alluvial fan material, near the distal edges of their fans, from sandstone and shale sediments. Their relatively fine texture indicates a low energy depositional environment, thus favoring the undisturbed burial of any cultural features that happen to be present. In particular, the investigation Palo Alto Recycled Water Pr~ject Page6l Initial StudylMitigated Negative Declaration concluded that areas comprised of Zamora soils are archaeologically sensitive, especially near Barron Creek and Matadero Creek, given the presence of stable land surfaces in close proximity to the creeks. Older fan soils lie exposed along the western edge of the Santa Clara Valley, where they have not been buried by recent fan sediments. The archaeological potential of these soils is identified as low, not only because of their age, but also because of the clay-like, very firm, sticky, and very plastic properties of the subsoil, which would make habitation or use difficult and unpleasant for much ofthe year. Small areas of upland soils are mapped within the APE, which consist of shallow residual soils developed on bedrock. The upland soils are on hillsides, with areas of rock outcrops. Erosion is a constant factor in keeping these soils shallow, and genetically young. The archaeological potential for deeply buried sites is low; artifacts are more likely to be at the surface, perhaps chronologically mixed and concentrated, as the matrix of fine soil material washes downslope, leaving a residuum of relatively heavy cultural materials in place. Soils located along stream terraces have a high potential for harboring buried archaeological sites, because recent (first terrace) soils are often flat, dry, easy to dig, and very near to the water of their parent stream. Unlike alluvial fans and floodplains, they do not occupy broad swaths of the landscape, so the high cultural potential is concentrated within a relatively small area, and limited to a small fraction of the Project area. a-t) Less-than-Significant Impact. The two records searches conducted in support of the Cultural Resources Report indicated that no National or State listed historical or prehistorical sites occur within the project APE. Ten previously recorded archaeological sites and one previously recorded isolate are located within 1f4-mile of the Project area thereby indicating a potential for encountering previously unrecorded cultural resources. The Project would not cause a substantial adverse change to any previously recorded historical or archaeological resources, but portions of the project are located within areas of archaeological sensitivity. In addition to the records search and site survey, the NAHC was contacted by letter on August 31, 2007 requesting information on sacred lands and a contact list of local tribal representatives or MLD. Responses were received from the NAHC on September 14, 2007 noting, "A record search of the sacred land file has failed to indicate the presence of Native American cultural resources in the immediate project area." On October 23, 2006, on behalf of another project at the RWQCP that also encompassed the area of the proposed pump station, WSA had contacted the NAHC by letter, requesting information on sacred lands and a contact list oflocal tribal representatives or MLD. The results of that request are being used for this project. A response to the October 23rd request was received from the NAHC on October 27, 2006, noting, "A record search of the sacred land file has failed to indicate the presence of Native American cultural resources in the immediate project area." Although the records search, windshield survey, and consultation with Native Americas failed to indicate the presence of human remains within the vicinity of the project, the subsurface excavation required for construction of the project could potentially disturb or destroy previously undiscovered archaeological resources or human remains from both prehistoric and historic time periods, if they are present. However, this impact would be minimized through the implementation of the environmental commitments outlined in the Project Description and, as a result, the impact is considered less than significant. Mitigation Measures: None required. Palo Alto Recycled Water Project Page 62 Initial StudylMitigated Negative DecIaration F. GEOLOGY, SOILS AND SEISMICITY Issues and Supporting Information Resources Sources Potentially Potentially Less Than No Significant Significant Significant Impact Would the project: Issues Unless Impact Mitigation Incorporated a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: i) Rupture of a known earthquake fault, as delineated on the most recent Alquist- Priolo Earthquake Fault Zoning Map ~ issued by the State Geologist for the area or based on other substantial evidence of a 4,39,34, known fault? Refer to Division of Mines and Geology Special Publication 42, 41,42 ii) Strong seismic ground shaking? 2,4,39, ~ 34,41, 42 iii) Seismic-related ground failure, including .2,4,39, ~ liquefaction? • 34,41, 42 iv) Landslides? 2,4,39, ~ 34,41, 42 b) Result in substantial soil erosion or the loss of 1,4 ~ topsoil? c) Result in substantial siltation? 1,4 ~ d) Be located on a geologic unit or soil that is 2,4,39, unstable, or that would become unstable as a 34,41, ~ result of the project, and potentially result in 42 on-or off-site landslide, lateral spreading, subsidence, liquefaction or collapse? e) Be located on expansive soil, as defined in ~ Table I 8-1-B of the Uniform Building Code 1,2,4, (1994), creating substantial risks to life or 39,34, property? 41,42 f) Have soils incapable of adequately supporting the use of septic tanks or alternative waste 1 ~ water disposal systems where sewers are not available for the disposal of waste water? g) Expose people or property to major geologic hazards that cannot be mitigated through the 2,4,39, ~ use of standard engineering design and seismic 34,41, I safety techniques? 42 DISCUSSION: a) Less-than-Significant Impact. The proposed Project would not expose people to substantial adverse risks of loss, injury, or death from fault rupture, strong seismic groundshaking or Palo Alto Recycled Water Project Page 63 Initial StudylMitigatcd Negative Declaration related ground failure since the proposed Project does not include construction of habitable structures. Risk of pipeline rupture is low, and would not result in substantial adverse risk to people in the Project area. The site is not located within an Alquist-Priolo "Earthquake Fault Zone" for fault rupture hazard, and the potential for fault rupture to damage the pipeline is considered low (ESA, 2003). Areas of the project site are classified as having a high liquefaction potential. The pipeline alignments are located near reclaimed tidal bay lands and an area classified as having a high liquefaction potential. The proposed pipeline alignments and pump station at the Mayfield Soccer Fields would not be within the reclaimed tidal baylands area; however, the RWQCP pump station would be located within the Baylands Nature Preserve, which is in an area classified as having high liquefaction potential. Adherence to generally accepted construction practices would ensure that potential liquefaction impacts are less than significant. Landslide potential is considered low due to the flat terrain at the Project site. Extreme earth movement could impact the integrity of the proposed Project as the result of pipeline rupture. Because the pipeline is located within a previously graded, engineered, and developed area, potential for ground failure is considered to be low. b,c) Less-than-Significant Impact. Construction activities involving soil disturbance, such as excavation, stockpiling, and grading would result in increased erosion, sedimentation and siltation to surface waters. Substantial erosion is considered unlikely because of the relatively small scale of earthmoving activities necessary for Project implementation. Implementation of standard engineering erosion-control techniques described in the Project Description would ensure that potential impacts to water quality are less than significant. d) Less-than-Significant Impact. The pipeline alignment is located in an area that would experience very strong to violent shaking in the event of a major earthquake along the San Andreas or Hayward Fault. With proper engineering, the construction and operation of the proposed Project is not expected to result in any significant adverse short-or long-term impacts related to geology, soils, or seismicity. e) No Impact. The proposed pipeline alignment, laterals, and pipeline options, are not located in expansive soils as defined by the Uniform Building Code (UBC). The existing RWQCP facilities in the vicinity ofthe proposed RWQCP pump station site are supported on piles and the boring log for construction of the fixed film reactors at the RWQCP indicates bay mud. The presence of bay mud indicates the likely presence of expansive soils as defined by the UBC. If necessary, the proposed pump station would be constructed on piles to reduce the potential impacts of expansive soils. f) No Impact. No septic tanks are proposed for the Project. Therefore, no impacts are anticipated. g) No Impact. The proposed project would not expose people or property to major geologic hazards that cannot be mitigated through the use of standard engineering design and seismic safety techniques. With proper engineering, the construction and operation of the proposed Project is not expected to result in any significant adverse short-or long-term impacts related to geology, soils, or seismicity. Mitigation Measures: None required. Palo Alto Recycled Water Project Page 64 Initial StudylMitigated Negative Declaration G. HAZARDS AND HAZARDOUS MATERIALS Issues and Supporting Sources Potentially Potentially Less Than No Information Resources Significant Significant Significant Impact Issues Unless Impact Would the project: Mitigation Incorporated a) Create a significant hazard to the public or the environment through the routine transport, use, 1,4,43 ../ or disposal of hazardous materials? b) Create a significant hazard to the public or the environment through reasonably foreseeable 1,4,43 ../ upset and accident conditions involving the release of hazardous materials into the environment? c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or 1,43 ../ waste within one-quarter mile of an existing or proposed school? d) Construct a school on a property that is subject 1,43 to hazards from hazardous materials ../ contamination, emissions or accidental release? e) Be located on a site which is included on a list ../ of hazardous materials sites compiled pursuant 1,2,43 to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? f) For a project located within an airport land use plan or, where such a plan has not been 1,44 ../ adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? g) For a project within the vicinity of a private airstrip, would the project result in a safety 1,44 ../ hazard for people residing or working the project area? h) Impair implementation of or physically interfere with an adopted emergency response 1,2 ../ plan or emergency evacuation plan? i) Expose people or structures to a significant risk ofloss, injury, or death involving wildland 1,2 ../ fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands? j) Create a significant hazard to the public or the environment from existing hazardous materials 1 ../ contamination by exposing future occupants or users of the site to contamination in excess of soil and ground water cleanup goals developed for the site? Palo Alto Recycled Water Project Page 65 Initial StudylMitigated Negative Declaration DISCUSSION: a) Less-than-Significant Impact. Operation of the proposed Project would not involve the routine transportation, use, storage, and/or disposal of hazardous materials. However, construction of the proposed Project could temporarily increase the transport of materials generally regarded as hazardous that are used in construction activities. It is anticipated that limited quantities of miscellaneous hazardous substances, such as gasoline, diesel fuel, hydraulic fluids, paint, and other similar materials would be brought onto the Project site, used, and stored during the construction period. The types and quantities of materials to be used could pose a risk to the public and/or the environment. In addition, construction of the proposed Project could result in the exposure of construction workers and residents to potentially contaminated soils due to improper removal of existing hazardous materials on site andlor leakage from the underground storage tanks (USTs) that could potentially be in the area or other historic releases of hazardous materials to soil or groundwater in the area. As discussed in the Project Description, hazardous materials will be stored, handled and used in accordance with applicable laws. Contaminated soil and/or groundwater will be disposed of properly. As part of the proposed Project, a Health and Safety Plan and a Hazardous Materials Management and Spill Prevention and Control Plan will be developed and implemented. Potential impacts are considered to be less than significant. No mitigation is required. In the event that a back-up generator is built at the proposed booster pump station location (at Mayfield Soccer Fields), diesel fuel would be stored onsite. Fuel would be stored within double-walled concrete containers that prevent leakage. Because the facility would be used during emergencies, it would not require the routine transport, use, or disposal of diesel fuel. As such, the operation of the generator would not create a significant hazard to the public or the environment and impacts would be considered less than significant. b) Less-than-Significant Impact. The construction of the proposed Project could create an additional significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. As with all construction activities, the potential exists for accidents to occur, which could result in the release of hazardous materials into the environment. As discussed in the Project Description, hazardous materials will be stored, handled and used in accordance with applicable laws. Contaminated soil and/or groundwater will be disposed of properly. As part of the proposed Project, a Health and Safety Plan and a Hazardous Materials Management and Spill Prevention and Control Plan will be developed and implemented. Potential impacts are considered to be less than significant Hazardous materials releases due to the operation of the proposed project are not anticipated. No mitigation is required. c) Less-than-Significant Impact. Three schools (El Carmelo Elementary School, Fairrneadow Elementary School, Jane L. Stanford Middle School]) are located within one-quarter mile of the proposed pipeline alignment. In addition, other facilities used by children, including the soccer fields located on a site previously occupied by Mayfield School (the school has not existed for 30 plus years), Cubberly Community Center, and Mitchell Park Community Center and Library are located nearby. Schools in the project vicinity also include Gunn High School and Jordan Junior High School. Although construction activities would require the use of some hazardous materials, due to the short duration and limited extent of construction activity, the potential for accidental release of hazardous materials associated with Palo Alto Recycled Water Project Page 66 Initial StudylMitigated Negative Declaration construction activities to affect nearby school children would be considered less than significant. No mitigation is required. d) No Impact. The project does not propose to construct a school on a property that is subject to hazards from hazardous materials contamination, emissions or accidental release. As a result, no impacts are anticipated and no mitigation is required. e) Less-than-Significant Impact. A search was conducted of the Department of Toxic Substances Control list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 including Federal Superfund Sites National Priorities List (NPL), State Response Sites, Voluntary Cleanup Sites, and School Cleanup Sites. The proposed Project is located near a number of State Response Sites, and one Evaluation Site. A list of sites within the City of Palo Alto is presented in Appendix E. The proposed project would not create a significant hazard to the public or the environment beyond the existing impacts of the hazardous materials sites. As a result, the impact is considered less than significant. £) Less-than-Significant Impact. The RWQCP is located approximately 1,000 feet south of the Palo Alto Airport. Construction and/or operation of the proposed Project, including the pump station at the RWQCP, would not adversely affect the airport or airport operations, including, noise, take-offs, landings, flight patterns, safety, light, navigation, or communications between aircraft and the control tower within the Project area. The proposed pump station would comply with all requirements of the Santa Clara County's Airport Master Plan for the Palo Alto Airport. As a result, no impacts are anticipated and no mitigation is required. g) No Impact. The proposed Project is not located within the vicinity of a private airstrip. As a result, no impacts are anticipated and no mitigation is required. h) Less-than-Significant Impact. During construction, installation of pipelines along roadways could block access to nearby roadways for emergency vehicles. In conjunction with the Traffic Control Plan for the Project, comprehensive strategies for maintaining emergency access shall be developed (see Project Description). As part of the emergency access strategies, police, fire, and other emergency service providers would be notified of the timing, location, and duration of the construction activities and the location of detours and lane closures. Potential impacts during construction are considered to be less than significant. Once construction is completed, operation of the proposed Project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. i) No Impact. The proposed Project would not be located in an area where there is the risk of wildland fire. Therefore there is no potential to expose people or structures to a significant risk ofloss, injury or death involving wildland fires. j) No Impact. The Project would not create a significant hazard to the public or the environment from existing hazardous materials contamination by exposing future occupants or users of the site to contamination in excess of soil and ground water cleanup goals developed for the site. The proposed project consists of a pipeline that would be constructed within existing roadways and/or utility corridors within commercial, industrial, and residential zonings within the City and pwnp stations associated with pipeline operation. These facilities would not house occupants or be used by the general public. As part of the proposed Project, a Health and Safety Plan and a Hazardous Materials Management and Spill Prevention and Control Plan will be developed and implemented. Thus there would be no impact. Palo Alto Recycled Water Project Page 67 Initial StudylMitigated Negative Declaration Mitigation Measures: None required. H. HYDROLOGY AND WATER QUALITY Issues and Supporting Information Resources Sources I Potentially Potentially I Less Than No Significant Significant Significant Impact Would the project: Issues Unless , Impact Mitigation Incorporated a) Violate any water quality standards or waste 1,4,45, discharge requirements? 51,53, ~ 54,55, 56 b) Substantially deplete groundwater supplies or interfere substantially with groundwater ~ recharge such that there would be a net deficit in aquifer volume or a lowering ofthe local groundwater table level (e.g., the production 1,2,4 rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted)? c) Substantially alter the existing drainage pattern of the site or area, including through the 1,4,45 ~ alteration ofthe course of a stream or river, in a manner which would result in substantial i erosion or siltation on-or off-site? d) Substantially alter the existing drainage pattern of the site or area, including through the 1,4,45 ~ alteration ofthe course ofa stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on-or off-site? e) Create or contribute runoff water which would exceed the capacity of existing or planned 1,4,45 ~ stormwater drainage systems or provide substantial additional sources of polluted runoff? It) Otherwise substantially degrade water quality? 11,4, 45 ~ g) Place housing within a lOO-year flood hazard ! I area as mapped on a federal Flood Hazard 1 ~ Boundary or Flood Insurance Rate Map or other flood hazard delineation map? h) Place within a IOO-year flood hazard area 1,2 structures which would impede or redirect ~ flood flows? i) Expose people or structures to a significant risk I ofloss, injury or death involve flooding, 1,2 including flooding as a result ofthe failure of a I ~ levee or dam or being located within a lOO-year i I Palo Alto Recycled Water Page 68 Initial StudylMitigated Negative Declaration Issues and Supporting Information Resources Sources Potentially I Potentially I Less Than No Significant Significant Significant Impact Would the project: Issues Unless Impact Mitigation Incorporated flood hazard area? j) Inundation by seiche, tsunami, or mud flow? 1 ../ k) Result in stream bank instability? 1,2 ../ DISCUSSION: Setting The general hydrogeologic setting underlying the entire Project area is a broad system of coalescing alluvial fans that extend from the range fronts west of the Proj ect area to the present shoreline of the Bay to the east. The sediments were deposited by streams flowing from surrounding mountains into the Santa Clara Valley and comprise the regional aquifers and aquitards (Le., deposits through which water does not readily flow) within the basin. The basin fill is generally more fine-grained near the Bay, and the coarsest sediments are usually near the range front in abandoned stream channels or near the apex of an alluvial fan. Groundwater occurs under both confined (under an aquitard that restricts percolation of water directly from the surface) and unconfined conditions (no aquitard over the groundwater) within the Project area. Groundwater movement is generally toward the Bay in both shallow and deep aquifers (i.e., water- bearing deposits). There is a downward vertical component of flow between adjacent coarse-grained deposits caused by regional groundwater pumping. Recharge of the aquifers occurs mainly along the mountain front where rainfall, streamflow, and deep percolation of applied water infiltrate the land surface. The alluvial deposits beneath the Stanford area are 700 to more than 900 feet thick beneath the present channel of the San Francisquito Creek, which runs near Stanford University to the southwest of the project area. Sediments are characterized by lenticular beds of poorly sorted gravel, sand, silt, and clay that are variable in thickness and grain size within short distances. The local aquifers and aquitards do not appear to be continuous over short distances; however, regionally the discontinuous sand bodies interfinger to form a predominantly sandy zone that can be recognized throughout large areas. Data suggest that near Stanford there is a shallow aquifer above about 150 feet below ground surface (bgs) and a deeper aquifer system below this depth. There are up to three fine-grained clay layers that impede vertical movement of groundwater at about 150, 200, and 300 feet bgs. The aquitards tend to thicken and become more laterally continuous toward the Bay. All of the production wells in the area draw most of their water from the deeper aquifer system, which is the zone below 300 ft bgs. The City of Palo Alto owns ten production wells, five of which have been abandoned. Stanford University owns four production wells, one of which has been abandoned. Stanford University, which is located near the project area, is located near the apex of the San Francisquito Creek alluvial fan. The primary constituents of concern in the RWQCP's recycled water with regard to groundwater quality are inorganic salt ions, considered collectively as total dissolved solids (TDS). Although a variety of subsurface investigations have been performed throughout the project area, most of these investigations have been conducted under the purview of the R WQCB as the result of underground petroleum storage tank releases, and most of the data collected are for petroleum hydrocarbons. Based on the inorganic lVU'.l);''''OU Negative Declaration ! water quality data that were obtained for the Palo Alto RWQCP Wastewater Reclamation Program Draft EIR, deep aquifer TDS concentrations appear to range from approximately 400 to 600 mg/I. These TDS concentrations are generally representative of groundwater within the Project area for both deep and shallow aquifers, and may be higher than concentrations actually present in more shallow groundwater (CH2MHill 1995). Hydrology The proposed pipeline alignment lies within two different flood zones as defined by the Federal Emergency Management Agency (FEMA). These zones are described below. Zone AE. (Base Flood Elevations determined). The elevation of the base flood (Le., IOO-year flood level) has been determined by FEMA to be 8 feet above mean sea level. Zone X. Zone X is described as an area of moderate risk of flooding (roughly speaking, outside the 100- year flood but inside the 500-year flood limits), or, for AO zones, where the IOO-year flood will be less than a foot deep. All of Palo Alto has been detennined to be subject to some risk of flooding, and it is inaccurate to say that a given property is "not in a flood zone" simply because it is not in a Special Flood Hazard Area. Zone X covers most of the area within which project facilities would be located. While some risk of flooding exists, structures within Zone X areas are not considered to be at substantial risk of flooding. Most of the Project area is located within Zone X. The northeast part of the project area between Middlefield Road and US-lOl and the proposed pump station site at the RWQCP are located in Zone AE. This area includes the pipeline alignments east of 101 and alignments along Fabian Way, East Meadow Drive, Matadero Creek and Colorado Avenue, as well as the RWQCP. Storm water Pollution and Regulation Stonnwater runoff channeled into Matadero Creek and other creeks within the Project area carries pollutants, including sediments, motor oil, car exhaust, chemicals, eroded soil, detergents, paints, and any other discarded material carried through the stonn drain system. These sediments and pollutants build up and contribute to the degradation of the Bay's water quality and biological health. Water quality is regulated by the federal NPDES Program, which controls and reduces pollutants to water bodies from point and nonpoint discharges. The NPDES program is administered within the Project area by the San Francisco Bay R WQCB. Projects disturbing more than one acre of land during construction are required to file a notice of intent to be covered under the State NPDES General Construction Permit for discharges of Stonnwater associated with construction activity. In order to receive a permit for proposed Project construction activities, the City would be required to propose measures that are consistent with the State General Construction Permit and with the RWQCB's recOlmnendations and policies. Discussion During construction, standard erosion control techniques would be implemented, as described in the Project Description, to ensure any construction-related water quality impacts are less than significant. Operation of the Project would be conducted in accordance with all applicable federal and state requirements, as discussed in the Project Description, thereby mitigating any potential operational-related water quality impacts. Project implementation would not affect any Wild and Scenic River designated waterways. Installation of the proposed pipeline would not substantially alter the drainage patterns in the Project vicinity because of the relatively small amount of impermeable surfaces that would be installed. Additionally, all paved surfaces will be regraded and paved per their original fonn and all unpaved surfaces will be regraded and revegetated per their original form. The proposed Project would not place housing within the IOO-year flood hazard area as defined by the FEMA. Palo Alto Recycled Project Page 70 Initial StudylMitigated Negative Declaration a) Less-than-Significant Impact. Operation of the proposed Project would be conducted in accordance with all applicable federal and state requirements. The major federal legislation governing the water quality aspects of the proposed Project is the Clean Water Act, as amended by the Water Quality Act of 1987. The State of California's Porter-Cologne Water Quality Act (Division 7 of the California Water Code) provides the basis for water quality regulation within California. The SWRCB administers water rights, water pollution control, and water quality functions throughout the state, while the nine RWQCBs conduct planning, permitting, and enforcement activities. The Porter-Cologne Water Quality Control Act designates the SWRCB responsible for formulating and adopting state policy for water recycling, while the California Department of Public Health (DPH) is responsible for establishing uniform statewide reclamation criteria to ensure that the use of recycled water would not be detrimental to public health. Recycled water regulations were published by the California Department of Health Services (DHS), which was the agency in charge of establishing reclamation criteria before DPH was formed. Water Quality effects on Public Health There are no federal standards governing water recycling and reuse in the United States, although the U.S. Environmental Protection Agency has sponsored the preparation of Guidelines for Water Reuse (ESA, 2003). Many states, including California, have developed water recycling regulations. In all cases, the regulations have been established with the objective of protecting public health and allowing for the safe use of recycled water. The DPH established water quality criteria, treatment process requirements, and treatment reliability criteria for reclamation operations, which are set forth in Title 22, Division 4, Chapter 3, of the CCR. The RWQCB has responsibility for reviewing proposed recycled water projects, and for issuing water recycling requirements through the RWQCB's permitting process. DPH has the responsibility for reviewing proposed water recycling projects, and for providing comments and/or recommendations to the RWQCB. Water Quality effects on Public Health associated with direct exposure to recycled water: The existing Title 22 Water Recycling Criteria address treatment requirements for three types of recycled water uses: Landscape Irrigation, Recreational Impoundments, and Industrial Uses. The treatment requirements are intended to protect public health based on the expected degree of human contact with recycled water under each type of use. Treatment requirements are expressed as treatment process requirements (e.g., bio-oxidation, coagulation) as well as performance standards (e.g., disinfection standards and contaminant reduction). The existing Title 22 standards are among the most stringent standards in the world for public health protection, and are about 100 times more stringent than comparable standards established by the World Health Organization. Since the adoption of Title 22 in 1978, the use of recycled water for non-potable (not fit to drink) uses has expanded throughout the state and is projected to continue to grow over the next several decades. Under Title 22, the RWQCP's tertiary recycled water qualifies for "unrestricted reuse", which allows the highest allowable uses, including landscape irrigation and use in recreational impoundments. To be used as a source supply for this designation, the recycled water shall be at all times adequately oxidized, coagulated, clarified, filtered, and disinfected water. To be considered adequately disinfected, the median number of coliform organisms in the recycled water may not exceed a Most Probable Number (MPN) of2.2 per 100 milliliters over a seven-day period. The DPH has also produced specific requirements applicable to recycled water use areas receiving recycled water that meets Title 22 Water Recycling Criteria. The requirements that Palo Alto Recycled Water Project Page 71 Initial StudylMitigated Negative Declaration are applicable to the proposed Project to protect public health are contained in Title Article 4, Section 60310 Use Area Requirements. The requirements focus on application and management specifications for various recycled water uses, including general use requirements, landscape irrigation requirements, impoundment requirements, and agricultural reuse area guidelines. General requirements include: • Posting signs to inform the public in areas where recycled water is in use; • Confining recycled water to authorized use areas; • Restricting irrigation of disinfected tertiary recycled water within 50 feet of any domestic water supply well; • Use of purple recycled water distribution and transmission system piping to indicate that it contains recycled water; • Prohibition of the over-application or any direct runoff of applied recycled water (recycled water would be applied to landscaped areas at agronomic rates to meet the evapotranspiration requirements, which minimizes surface runoff); and • Other requirements designed to ensure that recycled water use does not adversely affect public health. The City of Palo Alto receives potable drinking water from the SFPUC regional system. SFPUC water is currently treated with chlorarnines for disinfection. Not as widespread as the use of chlorine, the use of chloramines as a disinfectant in drinking water has occurred for many years. Although a weaker disinfectant than chlorine, chloramines are generally more stable, especially in distribution systems. Chloramines generally do not react as readily with organic matter in the treated water supplies, dramatically reducing the potential formation of disinfection by-products (DBPs). The chloramines used in the disinfection of the SFPUC's water do not survive the addition of sewage and treatment by the City of Palo Alto and thus will not persist in the recycled water. The recycled water would be disinfected for distribution and there would be residual chlorine in the distributed recycled water maintained through the addition of sodium hypochlorite at the RWQCP. Water Quality effects on Public Health associated with potential impact to groundwater: Nitrates in the recycled water are readily taken up by plants when recycled water is applied at agronomic rates, as required. No significant amount of nitrates would therefore be transported through the root zone into the soil column and into the groundwater. Salts may potentially leach into the groundwater during the wet season or in case of over- irrigation (for "flushing" purposes for example). Because of the limited amount of water (and therefore salt amounts) anticipated to leach into the groundwater, this potential salt migration would not adversely affect groundwater quality from a public health standpoint. Metals are not absorbed by the vegetation or broken down in the subsurface and thus can accumulate in the soil and may potentially leach into the groundwater during the wet season or in case of over-irrigation. However, metals are present in recycled water in such minute quantities that, if this migration were to occur, the concentrations would be extremely low, if even detectable, and would not adversely affect groundwater quality from a public health standpoint. Recycled water could potentially contain trace amounts of pharmaceutical compounds such as antibiotics, steroids, antidepressants, pain killers, estrogen and other hormones (endocrine disruptors). These compounds can pass through the body unmetabolized or partially Palo Alto Recycled Water Project Page 72 Initial StudyIMitigated Negative Declaration metabolized, and can be present in domestic wastewater in the range of a few parts per billion to a few parts per trillion. These and other compounds are collectively known within the water industry as "micropollutants", and are not presently regulated at the federal, state or local level, although their environmental fate, transport, and health effects are the subject of on-going research. Current treatment methods (including physical, chemical and biological processes) at the RWQCP remove some pharmaceutical compounds and micropollutants from the wastewater. These compounds may be present in the recycled water at minute concentrations, near or below current analytical detection limits. The presence of trace amounts of these compounds in the recycled water would not adversely affect landscape irrigation or any other proposed uses of the recycled water within the Project area. Natural processes, such as biological and photo-degradation at or below the ground surface will further break down residual contamination. Residual traces of chemicals, if any, will not adversely affect groundwater quality. With recycled water applied at agronomic rates, it is unlikely that the minute quantities of these compounds, if present, could migrate through the soil and into groundwater. If this migration were to occur, the concentrations would be extremely low, if even detectable. Adherence of the proposed Project to all appropriate Title 22 requirements would ensure that potential impacts to water quality or public health would be less than significant. Water Quality effects on Regulated TreesllRecycled water is characteristically higher in alkaline salts than typical irrigation water derived from potable supplies and may cause decline in acidic favoring tree species. Additionally, salt buildup in poorly drained soil may create a long-term inability of the soil to absorb and provide water availability to the tree roots. Recycled water from the RWQCP would have estimated total dissolved solids (TDS) of700 milligrams per liter (mg/I), after the RWQCP and its partners implement targeted high- TDS water inflow and infiltration reduction projects; this compares to TDS of 100 mg/l to 300 mg/l in existing water supply. Because salts are not absorbed by the vegetation or broken down in the subsurface, they have the potential to build up in the root zone in poorly drained soils and affect tree health. City staff investigated public concerns regarding the use of recycled water when applied globally as the primary source of irrigation for existing trees. The City's review did not determine conclusively that recycled water use was responsible for the decline of trees, although recycled water represents a change in irrigation strategy that could pose challenges for specific tree species, particularly Redwoods and possibly other trees requiring favorable acidic soil conditions for health. However, there have been reports of decline in redwoods throughout California in landscapes irrigated with both potable and recycled water (Downer 2004 as cited in HortScience, Inc 2005). HortScience conducted an independent study for the City of Palo Alto RWQCP to evaluate the effects of the RWQCP's recycled water on redwood trees in the Mountain ViewlMoffett area. The study evaluated redwood trees at five sites based on the factors identified below (2005): • Water quality: In general, the poorer quality the water, the more likely plants will be injured; 11 Regulated Trees include Protected, Street, and Designated trees as defined in the Project Description (in the discussion regarding the Tree Technical Manual). Palo Alto Recycled Water Project Page 73 Declaration • Salt-sensitivity of plants in the landscape: Plants vary widely in their tolerance to salts. Salts and boron sensitive plants have less tolerance to use of recycled water than do more salt tolerant species. • Soil characteristics: As a rooting environment, the soil holds the water and elements for root uptake. Some constituents in recycled water can have negative effects on the soil as they concentrate over time. Three soil characteristics are of key importance including chemical attributes of the soils (concentration of salts and existing pH), texture of the soil (fine [clay] vs. coarse [sandy soils]) and the soil drainage (whether salts can be leached). • Irrigation method and frequency: Plants are more sensitive to sodium and chloride toxicity when the water is applied to the foliage as opposed to the soil. The study found that the response of an existing landscape to irrigation with recycled water depends on the degree to which soil will become affected and the tolerance of plant materials to salts and specific ions (HortScience, Inc 2005). The reports states that "[t]he work to date has not fully answered why redwoods have been affected while other landscape species and some redwoods were largely unaffected. There appeared to be relationships among soil moisture, rooting depth, and tree condition. Trees in good condition were in better-watered sites and had deeper roots than trees in poor condition. This suggests that irrigation management is an important contributing factor. Soil texture and structure are also likely important because of their effects on water movement through the soils and root development" (HortScience, Inc 2005). The study also found that there are other agents that can cause decline in redwood trees. Existing and potential problems with redwood trees independent of irrigation water quality and the factors described above (HortScience Inc. 2005) include the following: • Climatic factors: Redwood trees are native to cool, foggy coastal areas in forest situations where the conditions differ drastically from those planted in the Bay Area landscape. Rather than moisture in the air and soil, redwood trees planted in Bay Area landscapes experience prolonged periods of warm, dry weather, low rainfall and infrequent fog. These conditions promote physiological stress. • Fungal pathogens: For example, Cylindrocarpon found in redwoods in the South Bay is known to cause root rot, although none have bcen reported as exclusive redwood pathogens. • Other diseases: Other diseases that have caused decline in redwood trees include Botryosphaeria canker, Phytophthora root rot, and Armillaria root rot. In addition, the insect pest, Aspidotus nerri, mayor may not contribute to redwood tree decline. There is not a definitive correlation between recycled water use and decline in redwood trees. Thus, the HortScience study concludes that recycled water may be used for landscape irrigation in the Mountain View/Moffett area as long as site management and possibly water quality adjustments are implemented. In 2005, the Santa Clara Valley Water District (SCVWD) engaged researchers from the University of California to investigate soil and plant constraints on the quality of recycled water, and proposc water qualities and management practices that would enable sustainable use of those waters (Oster 2009). Paio Alto Recycled Watcr Project Page 74 Initial StudylMitigated Negative Declaration Three studies were conducted as part of the SCVWD-funded research effort, and the findings were released at a workshop on February 17, 2009 12 • Researchers acknowledged that the factors that determine effects on coast redwood trees are those identified in the 2005 HortScience study: water quality, site conditions, irrigation method and frequency, and plant tolerances and requir~ents (Matheny 2009). The major findings of the three projects were summarized in the Solutions Project Report, A Cooperative Investigation by the Santa Clara Valley Water District, the City of Mountain View and South Bay Water Recycling. The findings are as follows (Oster 2009): • Coastal redwoods are sensitive to total soil-water salinity independent of the type of salt causing the salinity. The goal of sustainable water management for redwoods would be to maintain soil-water salinity levels in the root zone between 1 and 2 decisiemenlmeter (dS/m) 13 and to allow levels to approach 3 dS/m with caution and intensive monitoring of both the soil and the leaf bum of redwood trees. • Considerable excess water over that consumed by the plants will need to be applied for the long-term, sustainable irrigation of redwoods. 14 • Careful water management will need to be applied (e.g., apply water beneath the tree canopy, monitor the soil water content in the root zone, apply sufficient water to maintain soil water contents at targeted levels, periodically adjust the crop coefficient so that the targeted soil water contents are achieved, etc.) • As needed, application of gypsum to increase salinity and reduce sodium levels in the soil, which would improve infiltration rates. In their study of the tolerance of coast redwood to sodium and chloride, Barnes et. al (2007) found that if proper leaching is not employed to carry the salts out of the root zone, even at relatively low conductivity, salt can accumulate in the soil profile. The study concludes that "it is clear that redwoods can tolerate EC [electrical conductivity15] values in the range typical for recycled waters if irrigation is properly managed." Beaudette and Singer (2007) evaluated a subset of Santa Clara County soils for susceptibility to structural degradation from irrigation. They found that "soils that were the most sensitive to low EC solutions had the lowest sand content and highest CEC [cation exchange capacity] 16. Soils that were the least sensitive to low EC solutions had the highest sand content and lowest CEC." In other words, soils with higher silt and clay content are more affected by water quality than other soils. To maintain soil structure, infiltration rate, and 12 These studies included: 1) a survey of soil salinity using electromagnetic induction at Shoreline Links and Villages Golf Course to bench mark existing salinity conditions; 2) soil studies to determine the impacts of water quality on soil hydraulic properties; and 3) plant studies to determine the salt tolerance of coastal redwood (Oster 2009). 14 Oster found that Palo Alto recycled water was the most saline recycled water studied. The leaching fractions required to obtain the soil-water salinities between 2 and 3 dS/m range from 0.05 to greater than 0.4 depending on whether redwood responses to the soil-water salinities in the upper portion ofthe root zone or the whole root zone. 15 Electrical conductivity is a measure of a material's ability to conduct an electric current. Electrical conductivity is commonly measured as a decisiemen/meter (dS/m) and approximates to 640 ppm of salt. Current Palo Alto recycled water measures approximately 1.35 dS/m. Inflow and Infiltration reduction projects could reduce the electrical conductivity to 1.09 dS/m. 16 Cation exchange capacity (CEC) is the capacity ofa soil for ion exchange of positively charged ions between the soil and the soil solution Palo Alto Recycled Water Project Page 75 Initial StudylMitigated Negative Declaration percolation rate of soils with accumulated salts, careful site specific management will need to be employed. 17 No standards have yet been established for boron, sodium, and chloride in redwood tissues or salts in irrigation water. Lacking quantitative thresholds to evaluate the effects of recycled water use from this project on redwood trees and the multitude of factors that can contribute to such declines of redwood trees, such declines cannot be solely and directly linked to irrigation with recycled water. As such, a CEQA detennination is not made for this specific issue area. The discussion in this document provides a disclosure of the most up-to-date information on the possible effects of recycled water use on trees and the strategy that can avoid substantial decline of the City-designated protected and street trees. Precautionary Strategies. The project proposes to irrigate existing trees within the City that grow on a variety of public and private properties (e.g., in medians, planter-strip right-of-way areas, adjacent residential, commercial and Stanford Research Park lease areas) with recycled water. Certain soil conditions in the Palo Alto area are not suitable for many tree species. When such trees are exposed to increased stress by an environmental change (i.e., global recycled water use or prolonged drought) they may exhibit signs of decline. The City recognizes that many factors can contribute to this decline and that the increased salt content in the recycled water and poor drainage could affect the biological health, appearance (dieback), or mortality of existing protected, street, and designated trees (Dockter 2009). To address this potential scenario, the City intends to be proactive by implementing an Adaptive Management Program. As part of this strategy, the City will implement a Tree and Soil Monitoring Plan and BMPs to address adverse effects by site remediation or replacement of existing species with species better suited to the area. The Adaptive Management Program is described in detail in the Project Description. In addition to the Tree and Soil Condition Monitoring Plan that is part of the Adaptive Management Program, the RWQCP and its partners are actively addressing the issue of salinity in its recycled water as part of the City ofP&lo Alto RWQCP Water Reuse Program. Strategies identified under the program consist of the following: • The Inflow and Infiltration (III) program. Much of the salinity in the recycled water the RWQCP produces is due to salty groundwater infiltrating into the sewer collection system. Palo Alto and Mountain View are looking into rehabilitating the worst of these sewer pipes, which will reduce salt water infiltration into the sewers. It is estimated that and III program would reduce the TDS of the reclaimed water from 900 mg/l (1.35 dSlm) to approximately 700 mg/l (1.09 dSlm). 17 "Sodium can alter the physical and chemical properties of soils causing long-term damage to its structure and management." (Shainberg and Singer, 1990 as referenced in Beaudette and Singer 2007) "Larger sodium fractions in the soil solution and on the soil's exchange complex lead to increased soil swelling and dispersion ... Swelling can be caused both by high levels of sodium, and by low total salt concentrations. In the case of a sodic soil [a soil that contains sodium levels high enough to adversely impact soil structure and crop production], the monovalent sodium ion on the exchange complex causes clay platelets to move apart. Jfthe conditions which caused the soils to swell are modified (either the sodium levels are lowered or total electrolyte levels raised), it is possible that soils may go through the reverse process, dewatering or shrinking. Because the original particle associations and orientations are retained, soil shrink-swell is a reversible process. In contrast, dispersion is an irreversible process where re- flocculation of soil particles does not result in the original particle associations and orientations. Dispersion is the condition of separated soil particles and is also affected by sodium and electrolyte concentration." (Beaudette and Singer 2007). Palo Alto Recycled Water Project Page 76 Initial StudylMitigated Negative Declaration b) No Impact. The City of Palo Alto receives potable drinking water from the SFPUC regional system. Use of tertiary recycled water would reduce dependence on SFPUC water. The proposed project would not require any groundwater withdrawals or involve substantial construction of impermeable surfaces such that groundwater recharge would be reduced. Therefore, the project would not result in any adverse effects to groundwater resources. c,d,e) No Impact. The proposed pipeline would be installed within existing roadways and connected to existing pipelines. Project implementation would not affect any Wild and Scenic River designated waterways. Ground cover or surface pavement above installed pipelines would be restored after construction to maintain existing drainage patterns. The Project would add minimal additional impervious surface through the installation of above-ground structures (RWQCP pump station and structure for the generator). However, the volume of runoff produced by this additional pavement is not significant relative to the overall volume of local runoff. The pump station locations would be designed to direct runoff to the local storm water system, thereby alleviating the potential for flooding and/or erosion. Use of BMPs during construction would minimize the potential for flooding or erosion during construction. Therefore, the installation of the proposed pipeline and above-ground structures would not substantially alter the existing drainage patterns in the Project vicinity because of the relative small amount of additional impermeable surfaces that would be installed as result of Project implementation and the restoration of disturbed landscape areas. Overall, storm drainage conditions would not be expected to change; therefore, the proposed Project would have no impact on existing flood conditions. f) Less-than-Significant Impact. Without mitigation, earthmoving activities associated with pipeline construction would contribute to soil erosion and subsequent degradation in water quality. Implementation of standard erosion control techniques during Project construction activities, as discussed in the Project Description, would ensure potential water quality impacts are less than significant. Construction activities of one acre or more are subject to the permitting requirements of the NPDES General Permit for Discharges of Storm Water Runoff Associated with Construction Activity (General Permit). The Project sponsor must submit a Notice of Intent to the San Francisco RWQCB prior to the Permit requires the preparation and implementation of a formal SWPPP which must be prepared before construction begins. The SWPPP includes specifications for BMPs implemented during Project construction to control sedimentation or pollution concentration in storm water runoff, and defines conditions for complying with the SWRCB NPDES permit requirements. Implementation of the SWPPP starts with the commencement of construction and continues through Project completion. Upon completion of the Project, the sponsor must submit a Notice of Termination to the RWQCB to indicate that the construction is complete. g,h,i) No Impact. Executive Order 11988 requires federal agencies to prepare floodplain assessments for actions located within or affecting floodplains; and similarly, Executive Order 11990 places similar requirements for actions in wetlands. As previously noted, structures within FEMA Flood Zone X areas are not considered to be at substantial risk of flooding. Most of the Project area is located within Zone X. Part of the Project area is located in FEMA Flood Zone AE. Within the Project implementation corridor, 110 adverse impacts relative to flooding are anticipated. The Project does not propose homes or other above-grade structures to be constructed within the lOa-year floodplain and does not include structures that would impede or redirect flood flows. The proposed booster pump station would not be within the lOa-year floodplain. Project design of above-ground structures, including the pump station at the RWQCP, would include site grading and repaving so as to not impede or PaIo Alto Recycled Water Project Page 77 Initial StudylMitigated Negative Declaration I redirect flood flows. There are no dams in the vicinity of the project, so there would be no risk of inundation from dam failure. Therefore, no impacts relative to flooding are anticipated. j) No Impact. The Project area is not subject to seiches, tsunamis, or mudflows, and no impacts are anticipated. k) Less than Significant Impact. Construction activities involving soil disturbance, such as excavation, stockpiling, and grading would result in increased erosion, sedimentation and siltation to surface waters. Substantial erosion that could lead to stream bank instability is considered unlikely because of the relatively small scale of earthmoving activities necessary for Project implementation. Implementation of standard engineering erosion-control techniques, as discussed in the Project Description, would ensure potential impacts stream bank stability are less than significant. Mitigation Measures: None required. I. LAND USE AND PLANNING Issues and Supporting Information Resources Sources Potentially Potentially I Less Than No Significant Significant Significant Impact Would the project: Issues Unless Impact Mitigation ! Incorporated a) Physically divide an established community? 1 ~ b) Conflict with any applicable land use plan, policy, or regulation of an agency with 1,2,3, ~ jurisdiction over the project (including, but not 45 limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? • c) Conflict with any applicable habitat 11,2 conservation plan or natural community ~ conservation plan? ~ .. d) Substantially adversely change the type or intensity of existing or planned land use in the 1,2 ~ area? e) Be incompatible with adjacent land uses or with 1, 2, 3, I the general character of the surrounding area, 45 I ~ including density and building height? f) Conflict with established residential, 1,2,3 recreational, educational, religious, or scientific ~ uses of an area? I g) Convert prime farmland, unique farmland, or • 1, 5 Iv" farmland of statewide importance (farmland) to I non-agricultural use? DISCUSSION: Palo Alto Recycled Water Project Page 78 Initial StudylMitigated Negative Declaration I ! I a) No Impact. The proposed Project would not physically divide an established community. The proposed Project is located in Santa Clara County, within the City limits of Palo Alto. The proposed pipeline would be constructed within existing roadways and/or utility corridors within commercial, industrial, and residential zonings within the City. The Mayfield Soccer Fields pump station site is on Stanford property that is leased to the City. The proposed pump station at the RWQCP would be located entirely within the existing RWQCP property Therefore, the proposed Project would not result in a disruption, physical division, or isolation of existing residential or open space areas. As a result, no impacts are likely or anticipated. b) No Impact. The proposed Project would be constructed on land leased by or owned by the City of Palo Alto. The proposed pipeline would be constructed within existing roadways and/or utility corridors within commercial, industrial, and residential zonings within the City. The proposed locations for the pump stations are located on City owned or leased land in the following zones as defined in the Palo Alto Comprehensive Plan: mUltiple family housing (Mayfield Soccer Fields Site) and Major Institution/Special Facility (RWQCP). The project would require Architectural Review / Site and Design review during the design phase to satisfY the requirements of the Architectural Review Board and the City. In addition, a conditional use permit would be required for the booster pump station site. Compliance with these relevant City regulations would ensure that the proposed Project would not conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the Project area. Therefore, no impacts are anticipated and no mitigation is required. c) No Impact. The proposed Project would not conflict with the provisions of an adopted Habitat Conservation Plan, Natural Conservation Community Plan, or other approved local, regional, or state habitat conservation plan. As stated above, the proposed Project would be constructed within existing roadways and/or utility corridors within commercial, industrial, and residential zonings within the City. For this reason, no impact is expected. d,e,f) No Impact. The proposed project would not substantially, adversely change the type or intensity of existing or planned land use in the area, be incompatible with adjacent land uses or with the general character of the surrounding area, including density and building height, or conflict with established residential, recreational, educational, religious, or scientific uses of an area. As stated above, the proposed Project would be constructed on land leased by or owned by the City of Palo Alto, and within existing roadways and/or utility corridors within commercial, industrial, and residential zonings within the City. For this reason, no impact is expected. g) No Impact. As stated in the Agricultural Resources section of this IS/MND, the proposed Project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use. The proposed Project would be constructed within existing roadways and/or utility corridors within commercial, industrial, and residential zonings within the City or on City owned or leased property. No farming or agriculture takes place within the Project area. As a result, the proposed Project would not affect agricultural practices and/or convert any farmland to non- agricultural usage. No mitigation is required or necessary. Mitigation Measures: None Required Palo Alto Recycled Water Project Page 79 Initial StudylMitigated Negative Declaration J. lVIINERAL RESOURCES I Issues and Supporting Information Resources Sources I Potentially Potentially Less Than ! NoImpact I Significant Significant Significant Would the project: Issues Unless Impact Mitigation Incorporated a) Result in the loss of availability of a known mineral resource that would be of value to the 1,2,46 region and the residents of the state? b) Result in the loss of availability of a locally- iI, 2, 46 I important mineral resource recovery site delineated on a local general plan, specific plan I or other land use plan? DISCUSSION: a) No Impact. The proposed Project site is not located on a site that is identified as a significant source of mineral resources. Specifically, the proposed Project is not located in an area identified as containing mineral resources classified MRZ-2 by the State geologist that would be of value to the region and the residents of the state. As a result, the proposed Project would not result in the loss of availability of known mineral resources; therefore, no impact is expected. No mitigation is required. b) No Impact. The Palo Alto Comprehensive Plan does not identifY any locally important mineral resources or recovery sites in the proposed Project area. Further, as discussed in (a), the proposed Project would be unlikely to result in the loss of availability of a mineral resource deposit that has been identified as a mineral resource of value. Therefore, no adverse impacts are anticipated and no mitigation is required. Mitigation Measures: None Required K. NOISE ../ ../ I Issues and Supporting Information Resources ! Sources Potentially Potentially Less Than No Impact Significant Significant Significant Would the project: Issues Unless Impact Mitigation Incorporated ! a) Exposure of persons to or generation of noise levels in excess of standards established in the ../ local general plan or noise ordinance, or 1,2, 47 I applicable standards of other agencies? I ! b) Exposure of persons to or generation of excessive ground borne vibrations or ground 1,2 ../ borne noise levels? _ ....... c) A substantial permanent increase in ambient noise levels in the project vicinity above levels 1,2 ../ existing without the project? d) A substantial temporary or periodic increase in I ambient noise levels in the project vicinity 1,2 Palo Alto Recycled Water Project Page 80 Initial StudyIMitigated Negative Declaration Issues and Supporting Information Resources Sources Potentially Potentially Less Than No Impact I Significant Significant Significant I Would the project: Issues Unless Impact Mitigation Incorporated above levels existing without the project? ~ e) For a project located within an airport land use plan or, where such a plan has not been 1,44 ~ adopted, would the project expose people residing or working in the project area to excessive noise levels? 1) F or a proj ect within the vicinity of a private ! airstrip, would the project expose people 1,2 ~ residing or working in the project area to excessive noise levels? g) Cause the average 24 hour noise level (Ldn) to I increase by 5.0 decibels (dB) or more in an 1,47 ~ existing residential area, even if the Ldn would remain below 60 dB? • h) Cause the Ldn to increase by 3.0 dB or more in an existing residential area, thereby causing the 1,47 ~ Ldn in the area to exceed 60 dB? i) Cause an increase of3.0 dB or more in an existing residential area where the Ldn 1,47 ~ currently exceeds 60 dB? j) Result in indoor noise levels for residential 1,47 ~ development to exceed an Ldn of 45 dB? k) Result in instantaneous noise levels of greater than 50 dB in bedrooms or 55 dB in other 1,47 ~ rooms in areas with an exterior Ldn of 60 dB or '--... greater? I) Generate construction noise exceeding the ~ daytime background Leq at sensitive receptors 1,47 by 10 dBA or more? DISCUSSION: a, g-l) Less-than-Significant Impact. The proposed Project is located in a commercial and residential area with potential sensitive receptors, and within a nature preserve where there are no residential receptors and only limited commercial, industrial, and recreational uses nearby. The nearest existing sensitive receptors to the Project site are residences along the proposed pipeline alignment. The Palo Alto Comprehensive Plan indicates that major sources of noise throughout the Project area are primarily streets with high traffic volumes. Other major sources of noise within the Project area are trains. Ambient noise measurements were not taken for the purpose of this ISIMND. However, according to Map N-3 of the Comprehensive Plan, Noise Exposure Contours, ambient noise levels, measured as Ldn, in the prqject area range from 60 decibels (dBA) in residential, commercial and light industrial areas to 70 dBA along major thoroughfares. The construction and/or operation of the proposed project would not result in significant noise impacts because the project would comply with the City noise regulations. Palo Alto Recycled Water Project Page Initial StudylMitigated Negative Declaration The proposed Project has the potential to generate noise during the construction phase through the use of equipment and construction vehicle trips. Construction activities would be temporary in nature, and related noise impacts would be short-term. For construction, the Palo Alto Municipal Code Chapter 9.10, Noise, states that no individual piece of equipment shall produce a noise level exceeding 110 dBA at a distance of 25 feet. If the device is housed within a structure on the property, the measurement shall be made out- side the structure at a distance as close to 25 feet from the equipment as possible. Construction of the proposed Project would generate temporary and intermittent noise. Peak noise levels generated by most types of construction equipment would be around 80 dBA within 50 feet, although depending on the type of equipment used could produce noise levels in excess of 90 dBA within 50 feet, for short periods of time. Noise levels would fluctuate depending on the particular type, number, and duration of use of various pieces of construction equipment. Back-up beepers associated with trucks and equipment used for material loading and unloading at the staging area would generate significantly increased noise levels over the ambient noise environment in order to be discernable and protect construction worker safety as required by OSHA (29 CFR 1926.60 I and 29 CFR 1926.602). Residences in the vicinity of the work areas would thus be exposed to these elevated noise levels. Construction activities associated with the pump station at the RWQCP would not exceed ambient noise levels, as the R WQCP is an industrial area with elevated noise levels due to plant operation. Construction equipment noise would be minimized during project construction by muffling and shielding intakes and exhaust on construction equipment (per the manufacturers' specifications) and by shrouding or shielding impact tools. All equipment would have sound- control devices no less effective than those provided by the manufacturer.. In addition, the City would require in construction specifications that the contractor place all stationary noise generating construction equipment as far away as possible from sensitive receptors or in an orientation minimizing noise impacts (e.g., behind existing barriers or storage piles). Construction would occur between the hours of 9 a.m. and 4 p.m. Monday through Friday on arterial and collection streets in order to maintain compliance with the City's Traffic Control Requirements. Construction other than on arterial and collection streets would occur between the hours of 8 a.m. and 6 p.m. Monday through Friday. Construction would occur between 9 a.m. and 6 p.m. on Saturday for all construction areas. Compliance with the Palo Alto Municipal Code and Noise Ordinance would ensure that impacts related to construction noise would be less than significant. For operation aside from construction, the Palo Alto Municipal Code Chapter 9.10 Noise states that for commercial and industrial property, no person shall produce, suffer, or allow to be produced by any machine or device, or any combination of same, on commercial or industrial property, a noise level more than eight dB above the local ambient at any point outside of the property plane. (Ord. 4634 § 2 (part), 2000) Policy N-41 of the Palo Alto Comprehensive Plan states that a project should be considered to cause a significant degradation of the noise environment ifit would cause the average 24-hour noise level (Ldn) to increase by 5.0 dB or more in an existing residential area, even if the Ldn would remain below 60 dB or if it would cause the Ldn to increase by 3.0 dB or more in an existing residential area, where it would cause the Ldn to exceed 60 dB or where the Ldn currently exceeds 60 dB. Operation of the proposed pipeline and laterals would not result in noise impacts. The pipeline would be buried underground, and thus would not create noise. Operation of the pump station along the alignment (at Mayfield Soccer Fields) would not increase ambient noise because it would be located underground. For aboveground structures Palo Alto Recycled Water Project Page 82 Initial StudylMitigated Negative Declaration a) associated with the pump station, all building openings, including air ventilation, would employ acoustical rated louvers and silencers as appropriate to reduce noise propagation to the outside of the building. Motor noise from the proposed pump station at the R WQCP would be negligible given the existing ambient noise from other facilities already in operation at the site Compliance with the Palo Alto Municipal Code and Noise Ordinance and design of the pump station to meet the City's noise standards would ensure that impacts related to operational noise are less-than-significant. b) Less-than-Significant Impact. Operation of the proposed Project would not generate excessive groundborne vibration or noise impacts. Construction of the proposed Project could likely result in minor and temporary increases in ground borne vibration or noise, however, construction activities would be temporary. Compliance with the Palo Alto Municipal Code and Noise Ordinance and design of the pump stations to meet the City's noise standards would ensure that impacts associated with the exposure of persons to or generation of excessive ground borne vibration or groundborne noise levels would be less than significant. c) Less-than-Significant Impact. Once constructed, operation of the pipeline would not result in noise impacts. The pump station at the Mayfield Soccer Fields site would be underground, and the booster pump station at the R WQCB would be in an enclosed building designed to meet the City's noise standards. Pumps and associated electrical mechanical components would be enclosed within a building constructed of CMU or other structurally sound-isolated construction materials. All building openings, including air ventilation, would employ acoustical rated louvers and silencers as appropriate to reduce noise propagation to the outside of the building. Thus the impact will be less than significant. d) Less-than-Significant Impact. Project construction activities may lead to a temporary increase in ambient noise levels in the Project vicinity. Compliance with the Palo Alto Municipal Code and Noise Ordinance would ensure that temporary or periodic increases in ambient noise levels in the Project vicinity would be less than significant. e) Less-than-Significant Impact. The Palo Alto Airport is located across Embarcadero Road from the RWQCP. The existing airport noise exposure at the RWQCP would remain unchanged. There are no residences in the area of the RWQCP pump station site and workers at the project site are not expected to be exposed to excessive noise levels from airport noise. As a result, the impact would be less than significant and no specific mitigation is required. f) No Impact. The Project is not located within the immediate vicinity of a private airstrip and would not affect any aircraft operations. No impact is expected. Mitigation Measures: None Required L. POPULATION AND HOUSING Issues and Supporting Information Resources Sources Potentially Potentially Less Than No Impact Significant Significant Significant Would the project: Issues Unless Impact Mitigation Incorporated Induce substantial population growth in an ./ area, either directly (for example, by proposing 1,45,49, new homes and businesses) or indirectly (for 50 Palo Alto Recycled Water Project Page 83 Initial StudylMitigated Negative Declaration Issues and Supporting Information Resources Sources Potentially Potentially Less Than No Impact Significant Significant Significant Would the project: Issues Unless Impact Mitigation Incorporated example, through extension of roads or other infrastructure)? b) Displace substantial numbers of existing housing, necessitating the construction of 1 I v" replacement housing elsewhere? c) Displace substantial numbers ofpeopJe, I 1 necessitating the construction of replacement v" housing elsewhere? d) Create a substantial imbalance between 1 v" employed residents and jobs? e) Cumulatively exceed regional or local 1 Iv" population projections? I DISCUSSION: a-e) No Impact. The proposed Project is in response to a need to improve water supply management and reliability, and improve the San Francisco Bay by reducing the discharge of substances that could impact the sensitive Bay environment The proposed Project would not displace existing housing, involve construction of new housing, create imbalance between employed residents and jobs, or exceed regional or local population projections. As a result, the proposed Project is anticipated to have no impacts. Mitigation Measures: None Required M. PUBLIC SERVICES Issues and Supporting Information Resources I Sources I Potentially Potentially Less Than ~No Impact Significant Significant Significant Would the project: Issues Unless Impact Mitigation WOuldthe project result in substantial adverse Incol'Porated physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any ofthe public services: a) Fire protection? 1 v" ........... - b) Police protection? 1 v" c) Schools? 1 :j' Palo Alto """.;;v"",u Water Project Page 84 Initial StudylMitigated Negative Declaration Issues and Supporting Information Resources Sources Potentially Potentially Less Than No Impact Significant Significant Significant Would the project: Issues Unless Impact Mitigation Incorporated d) Parks? I ../ e) Other public facilities? I ../ DISCUSSION: a-e) No Impact. The proposed Project would not change the existing demands for public services (e.g., fire and police protection, schools, parks). The Project is in response to a need to improve water supply management and reliability, and improve the San Francisco Bay by reducing the discharge of substances that could impact the sensitive Bay environment. As a result, the proposed Project is anticipated to have no impacts. Mitigation Measures: None Required N. RECREATION Issues and Supporting Information Resources Sources Potentially Potentially Less Than No Impact Significant Significant Significant Would the project: Issues Unless Impact Mitigation Incorporated a) Would the project increase the use of existing neighborhood and regional parks or 1 ../ other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? b) Does the project include recreational facilities or require the construction or 1 vi" expansion of recreational facilities which might have an adverse physical effect on the environment? DISCUSSION: a-b) No Impact. The proposed Project would not change the existing demands on recreational facilities. The Project is in response to a need to improve water supply management and reliability, and improve the San Francisco Bay by reducing the discharge of substances that could impact the sensitive Bay environment. Parking for recreation at Mayfield Soccer Fields would be temporarily impacted by construction activities in the parking lot where the underground pump station would be located (see the discussion in Transportation and Traffic below). However, construction would be temporary and recreation activities on the fields would not be impacted. The use of existing recreational facilities in the vicinity of the RWQCP would not be impacted by the proposed project. The pump station would comply with the requirements of the Baylands Master Plan. As a result, the proposed Project is anticipated to have no impacts. Palo Alto Recycled Water Project Page 85 StudylMitigated Negative Declaration I Mitigation Measures: None Required O. TRANSPORTATION AND TRAFFIC Issues and Supporting Information Resources Sources Potentially • Potentially Less Than No Impact Significant Significant Significant Would the project: Issues Unless Impaet Mitigation Ineorporated a) Cause an increase in traffic which is ~ substantial in relation to the existing traffic load and capacity of the street system (i.e., 1,2,4,45 result in a substantial increase in either the number of vehicle trips, the volume to capacity ratio on roads, or congestion at intersections)? b) Exceed, either individually or cumulatively, ~ a level of service standard established by the 1 county congestion management agency for designated roads or highways? c) Result in change in air traffic patterns, including either an increase in traffic levels 1,44 ~ or a change in location that results in substantial safety risks? d) Substantially increase hazards due to a ~ design feature (e.g., sharp curves or 1,45,48,49 dangerous intersections) or incompatible uses (e.g., farm equipment)? e) Result in inadequate emergency access? 1,45,48,49 ~ i t) Result in inadequate parking capacity? I ~ 1,45,48,49 g) Conflict with adopted policies, plans, or ~ programs supporting alternative 1,45,48,49 transportation (e.g., pedestrian, transit & bicycle facilities)? h) Cause a local (City of Palo Alto) intersection to deteriorate below Level of Service (LOS) ~ D and cause an increase in the average 1,45,48,49 stopped delay for the critical movements by four seconds or more and the critical volume!capacity ratio (VIC) value to increase by 0.01 or more? i) Cause a local intersection already operating at 1,45,48,49 LOS E or F to deteriorate in the average ~ stopped delay for the critical movements by four seconds or more? ! j) Cause a regional intersection to deteriorate 1,45,48,49 from an LOS E or better to LOS F or cause ~ critical movement delay at such an intersection already operating at LOS F to increase by four' seconds or more and the critical VIC value to increase by 0.01 or more? Palo Alto Recycled Water Project Page 86 Initial StudylMitigated Negative Declaration Issues and Supporting Information Resources Sources Potentially Potentially I Less Than I No Impact Significant Significant Significant Would the project: Issues Unless Impact :vtitigation Incoroorated k) Cause a freeway segment to operate at LOS F or contribute traffic in excess of 1 % of 1,45,48,49 ../ segment capacity to a freeway segment already operating at LOS F? I) Cause any change in traffic that would increase the Traffic Infusion on Residential 1,45,48,49 ../ Environment (TIRE) index by 0.1 or more? m) Cause queuing impacts based on a comparative analysis between the design ../ queue length and the available queue storage 1,45,48,49 capacity? Queuing impacts include, but are not limited to, spillback queues at project access locations; queues at tum lanes at intersections that block through traffic; queues at lane drops; queues at one intersection that extend back to impact other intersections, and spillback queues on ramps. n) Impede the development or function of 1,45,48,49 1../ planned pedestrian or bicycle facilities? 0) Impede the operation of a transit system as a 1,45,48,49 ../ result of congestion? p) Create an operational safety hazard? 1,45,48,49 ../ DISCUSSION: Pipeline installation activities would temporarily disrupt transportation and circulation patterns in the vicinity of the Project. Table 5 shows roadways affected by the project and construction methods at roadway crossings. The Project could significantly affect roadway segments and intersections on all pipeline segments if the construction zone were to reduce the travel width during peak: traffic periods. Potential conflicts along the major pipeline route as well as along the lateral routes could occur between construction traffic and bicyclists and pedestrians. Traffic is generally heavy along Alma Street and Mill Road. The intersection of Page Mill Road and El Camino Real is a major traffic intersection, as is the intersection of Hillview Avenue and Foothill Expressway. Temporary effects on traffic could increase the potential for accidents, emergency access, displacement of on-street parking, and disruptions to transit service. The City has a practice of imposing a 5-year moratorium on cutting newly paved streets, with appropriate exceptions. No trench work would occur on streets that have been paved within the 5 years prior to construction unless an exception is needed and an agreement can be reached to allow for the exception. The implementation of a Traffic Control Plan, which is described in the Project Description, and implementation of the mitigation measures identified below would ensure that all traffic impacts are mitigated to a less-than-significant level. Palo Alto Recycled Water Project Page 87 Initial StudylMitigated Negative Declaration Table 5: Proposed Pipeline Alignment Alignment is on: Starting Cross Street Ending Cross Street Construction Method at Road"ay Crossings Proposed Alignment Under US-I 0 1 E. Bayshore Rd. Fabian Way Trenchless under 101 Fabian Way West Bayshore Road East Meadow Drive Open-Cut ! Open-Cut; East Meadow Drive Fabian Way Cowper Street Potential trenchless section across Adobe Creek Bridge Open-Cut; Cowper Street East Meadow Drive EI Dorado Avenue Potential trenchless sections across Barron Creek and Matadero Creek EI Dorado A venue Cowper Street Alma Street Open-Cut Alma Street EI Dorado A ven ue Page Mill Road Open-Cut Open-Cut; Potential trenchlessl section Page Mill Road Alma Street Hanover Street under railroad crossing; Potential trenchless section under EI Camino Real I Hanover Street Page Mill Road Hillview A venue Open-Cut Open-Cut; Hillview A venue Hanover Street Arastradero Road Potential trenchless section across SFPUC Easement and Foothill Expressway ~ ......... Pipeline Alignment Option 1 Adobe Creek US-1OI West Bayshore Road i Trenchless under 101 West Bayshore Road Adobe Creek Fabian Way Open-Cut Pipeline Alignment Option 2 Colorado A venue US-101 Alma Street Open-Cut . Pipeline Alignment Option 3 i EI Camino Real Page Mill Road Hanson Way Open-Cut Palo Alto Square Parking Hanson Way Hanover Street I Open-Cut I All the bndge crossmgs would be trenchless (constructed WIth the pIpe attached to SIde ofbndge) or Installed m the bridge in a trench. The construction method has not been finalized. Neither method would require work to be done in the creeks. Palo Alto Recycled Water Page 88 Initial Negative Declaration • I a,b) Potentially Significant Unless Mitigation Incorporated. The proposed alignment and alignment options would be installed within roadway rights-of-way using standard open-cut trenching techniques by means of speed shoring or trench box bracing. Traffic-generating construction activities related to pipeline installation would consist of the daily arrival and departure of construction workers to the work site; trucks hauling equipment and materials to the work site daily; and the hauling of excavated spoils from, and import of new fill to, each work site. Each pipeline construction crew would consist of an estimated 10 workers. Construction equipment used for pipeline construction would include backhoes, front-end loaders, dump trucks, flatbed delivery trucks, cranes, compactors, concrete trucks, and paving equipment. Based on the estimated crew size, and assuming some overlap in construction activities at the work site, construction worker trips traveling to and from the work site are not anticipated to exceed 10 round trips (20 one-way trips) per day. This would not be substantial relative to background traffic conditions. Project-generated trips would fall within the daily fluctuations of traffic volumes for nearby roadways. Therefore, this short-term increase in vehicle trips would not significantly affect level of service and traffic flow on roadways. Pipeline construction would typically require a minimum of one lane of traffic and the adjacent shoulder, resulting in a construction corridor approximately 20 feet to 30 feet wide. It is expected that the open trench construction within paved roadways would proceed at the rate of approximately 100 feet per day, with an overall work zone of 300 to 600 feet in length. Typical roadway excavations encompass a single lane and part of the shoulder and/or bike lane, should they exist, although full road closures may be required along narrower streets (e.g., EI Dorado and Cowper streets). However, impacts would be relatively brief at anyone location along the pipeline alignment, at most a few days. The City of Palo Alto would repair any damage to the road due to construction. The City has a practice of imposing a 5-year moratorium on cutting newly paved streets, with appropriate exceptions. No trench work would occur on streets that have been paved within the 5 years prior to construction unless an exception is needed and an agreement can be reached to allow for that exception. If paving occurs farther into the future, the effect of the moratorium will be reevaluated to determine whether roads that are included in the proposed Project have been recently paved at that time. The construction footprint for the booster pump station at the Mayfield Soccer Fields would be approximately 0.25 acres. The final proposed pumping facility would be approximately 50 feet by 30 feet. The RWQCP pump station would require a footprint of roughly 40 feet x 42 feet. It is estimated that up to 100 cubic yards (CY) of trench spoils would be hauled off-site daily, and 95 CY of new fill would be imported daily. Using an average haul load of 10 CY per truck, this would amount to up to 21 truck haul round trips (42 one-way trips) generated per work day. Accounting for the delivery of pipes and other construction components (which would be shipped on demand to the Project site throughout the construction period), the total number of off-site construction truck trips would be approximately 22 round trips (44 one- way trips) per work day and not typically during the peak periods. These additional trips include material (pipes) delivery approximately twice a week, fuel shipments once a day, and maintenance trucks that would come by once a week. This would not be substantial relative to background traffic conditions. Project-generated trips would fall within the daily fluctuations of traffic volumes for nearby roadways. Therefore, this short-term increase in vehicle trips would not significantly affect level of service and traffic flow on roadways. Palo Alto Recycled Water Project Page 89 Initial StudylMitigated Negative Declaration The proposed pipeline would follow within and/or cross several roadways. The exact placement of the pipeline in the roadways is not known at this time, but regardless of where it would be installed, pipeline installation activities would temporarily disrupt existing transportation '611d circulation patterns in the vicinity. Impacts would include direct disruption of traffic flows and street operations. Pipeline installation would result in a reduction in travel lanes and on-street parking. Pipe installation work within and/or across high traffic volume arterials could significantly affect traffic flow and operation at these locations. The Project would affect roadway segments and intersections on the pipeline alignment during construction. Limiting construction to off-peak times, returning roads to pre-construction conditions (Mitigation Measure TRA-I) and implementing a traffic control plan, which is described in the Project Description would ensure that traffic impacts are less than significant. There are several schools in the vicinity of the Project. These areas will be looked at more closely to determine whether the traffic control plan is appropriate or if additional measures are needed specific to school areas. c) No Impact. The proposed Project does not involve use of air transit, nor is it expected to cause any change in air traffic patterns. No impact is expected and no mitigation is required. d) Potentially Significant Unless Mitigation Incorporated. The Project would not change the configuration (alignment) of area roadways, and would not introduce types of vehicles that are not already traveling on area roads. However, heavy equipment operating adjacent to or within road right-of-way would increase the risk of accidents, as could the increased congestion resulting from lane and/or road closures. Potential conflicts also could occur between construction traffic and bicyclists and pedestrians and there is also potential for an increase in accidents resulting from limited lines of sight due to construction. The contractor will prepare and implement a traffic control plan in accordance with professional engineering standards prior to construction, including compliance with roadside safety protocols, so as to reduce the risk of accident. Specific requirements that may be included in the traffic control plan are identified in the Project Description. Thus, implementation of the traffic control plan would ensure temporary increases in the potential for accidents would be less than significant. Mitigation Measure TRA-l would ensure that roads are returned to their pre-construction condition or better. There are several schools in the vicinity of the Project. These areas will be looked at more closely to determine whether the Traffic Control Plan is appropriate or if additional measures are needed specific to school areas. e) Less-than-Significant Impact. The proposed Project would have temporary effects on traffic flow due to lane/road closures and added truck traffic during construction which could result in delays for emergency vehicle access in the vicinity of the Project or restriction to adjacent land uses. Through the development of the traffic control plan and comprehensive strategies for maintaining emergency access (described in the Project Description), the contractor will establish methods for maintaining traffic flow in the Project vicinity and minimizing disruption to emergency vehicle access along the construction route. If proper detours are not provided for streets that may require closure during construction activities, significant impacts could occur. Identification of detours (see Measure TRA-2), in addition to implementing a traffic control plan and emergency access strategies (described in the Project Description) would ensure that traffic impacts are less than significant. There are several schools in the vicinity of the Project. These areas will be looked at more closely to determine whether the traffic control plan is appropriate or if additional measures are needed specific to school areas. Palo Alto Recycled Water Project Page 90 Initial StudylMitigated Negative Declaration f) Less-than-Significant Impact. The proposed Project would create limited new, temporary parking demand for construction workers and construction vehicles as the crew moves along the installation alignment. The Project would not require a substantial number of construction workers along the construction alignment; therefore, the number of parking spaces required would not be substantial. If certain alignment options are selected, existing on-street parking may be temporarily displaced. However, given the proposed rate of new pipe installation, impacts to on-street parking would be relati vely brief at anyone location along the alignment. Some parking at the Mayfield Soccer Fields would be temporarily lost by the construction activities in the parking lot where the underground pump station would be located. The construction area would be fenced off from the rest of the parking area for safety and security purposes and would not be usable during construction. Because these disruptions would be of limited duration and the parking area surrounding the permanent footprint of the pump station would be restored to its pre-construction condition, the impact would be considered less than significant. The City's Utilities Department will work with the Parks and Recreation division to ensure coordination of construction activities to minimize loss of parking at the Mayfield Soccer Fields. Construction of the proposed pump station at the R WQCP would create a temporary parking demand for construction workers and construction vehicles at the plant. The RWQCP has an existing staging area with sufficient parking spaces for construction projects. Through development of the traffic control plan, the construction contractor would establish methods for minimizing construction effects on parking. Specific requirements that may be included in the traffic control plan are identified in the Project Description. Implementation of the traffic control plan would ensure potential impacts associated with potential temporary displacement of parking would less than significant. There are several schools in the vicinity of the Project. These areas will be looked at more closely to determine whether the traffic control plan is appropriate or if additional measures are needed specific to school areas. g) Less-than-Significant Impact. The proposed Project would not cause a demand for alternative transportation. In addition, the proposed Project would have no long-term impact on alternative transportation facilities. Construction could temporarily impact buses accessing bus stops along the proposed construction corridor. Bus stops would be temporarily moved and signs would be posted at the temporary bus stops. This could result in an impact to ort- street parking as several spots could become the 'new' temporary bus stop. However, given the proposed rate of new pipe installation, impacts to alternative transportation would be relatively brief at anyone location along the alignment. h-m) Less-than-Significant Impact. As stated in checklist item a,b) above, traffic-generating construction activities related to pipeline installation would consist of the daily arrival and departure of construction workers to the work site; trucks hauling equipment and materials to the work site daily; and the hauling of excavated spoils from, and import of new fill to, each work site. Each pipeline construction crew would consist of an estimated 10 workers. Construction equipment used for pipeline construction would include backhoes, front-end loaders, dump trucks, flatbed delivery trucks, cranes, compactors, concrete trucks, and paving equipment. Based on the estimated crew size, and assuming some overlap in construction activities at the work site, construction worker trips traveling to and from the work site are not anticipated to exceed 10 round trips (20 one-way trips) per day. The total number of off- site construction truck trips would be approximately 22 round trips (44 one-way trips) per work day. These additional trips include material (pipes) delivery approximately twice a week, fuel shipments once a day, and maintenance trucks that would come by once a week. Palo Alto Recycled Water Project Page 91 Initial StudylMitigated Negative Declaration This would not be substantial relative to background traffic conditions. Project-generated trips would fall within the daily fluctuations of traffic volumes for nearby roadways. Therefore, this short-term increase in vehicle trips would not significantly affect level of service and traffic flow on roadways. The Project would affect roadway segments and intersections on the pipeline alignment during construction. Limiting construction to off-peak times and implementing a traffic control plan, which is described in the Project Description, would ensure that traffic impacts are less than significant. There are several schools in the vicinity of the Project. These areas will be looked at more closely to determine whether the Traffic Control Plan is appropriate or if additional measures are needed specific to school areas. Refer to checklist item a,b) for additional discussion. n) Less-than-Significant Impact. The proposed Project would not impede the development or function of planned pedestrian or bicycle facilities. The proposed Project would have temporary effects due to lane closures during construction which could result in detours for pedestrian and bicycle flow and use of temporary facilities in the vicinity of the Project during the construction period. Through the development of the traffic control plan, the contractor will establish methods for maintaining pedestrian and bicycle facilities in the Project vicinity and minimizing disruption to these facilities along the construction route. Implementation the Traffic Control Plan would also ensure potential impacts associated with temporary effects on planned pedestrian and bicycle facilities would be less than significant. There are several schools in the vicinity of the Project. These areas will be looked at more closely to determine whether the Traffic Control Plan is appropriate or if additional measures are needed specific to pedestrian and bicycle facilities near school areas. 0) Less-than-Significant Impact. The proposed Project would have no long-term impact on operation of a transit system as a result of congestion. Construction could temporarily impact buses accessing bus stops along the proposed construction corridor. Bus stops would be temporarily moved and signs will be posted at the temporary bus stops. This could result in an impact to on-street parking as several spots could become the 'new' temporary bus stop. However, given the proposed rate of new pipe installation, impacts to alternative transportation would be relatively brief at anyone location along the alignment. p) No Impact. The proposed Project would not increase safety risks. Mitigation Measures: With the incorporation of the following mitigation measures, potential temporary impacts are considered to be less than significant. TRA-l: Return Roads to Pre-construction Condition. Following construction, the City shall ensure that road surfaces that are damaged during construction are returned to their pre-construction condition or better. TRA-2: Detours. During construction, the City shall use detour signing for vehicles, bicycles, and pedestrians on alternate access streets when temporary full street closure is required. Palo Alto Recycled Water Project Page 92 Initial StudylMitigated Negative Declaration P. UTILITIES AND SERVICE SYSTEMS Issues and Supporting Information Resources Sources Potentially Potentially Less Than I No Impact Significant Significant Significant Would the project: Issues Unless Impact : Mitigation Incorporated a) Exceed wastewater treatment requirements of the applicable Regional Water Quality 1,4,45 ../ Control Board? b) Require or result in the construction of new water or wastewater treatment facilities or ../ expansion of existing facilities, the 1,4,45 construction of which could cause significant environmental effects? c) Require or result in the construction of new ../ storm water drainage facilities or expansion 1,4,45 of existing facilities, the construction of which could cause significant environmental effects? d) Have sufficient water supplies available to serve the project from existing entitlements 1,4,45 ../ and resources, or are new or expanded entitlements needed? e) Result in a determination by the wastewater treatment provider which serves or may 1,4,45 ../ serve the project that it has inadequate capacity to serve the project's projected demand in addition to the provider'S existing commitments? f) Be served by a landfill with sufficient permitted capacity to accommodate the 1 ../ project's solid waste disposal needs? g) Comply with federal, state, and local statutes 1 and regulations related to solid waste? ../ h) Result in a substantial physical deterioration 1 of a public facility due to increased use as a ../ result of the project? DISCUSSION: Project operation would not result in any exceedance of wastewater treatment requirements, since the use of recycled water would be in accordance with Title 22 and the RWQCB-issued NPDES permit. The project would include construction of an underground pump station at the Mayfield Soccer Fields site and a pump station at the RWQCP, but would not increase the need for additional off-site storm water drainage facilities. No wastewater would be generated, so no impacts would occur concerning the regional wastewater treatment facilities. No long-term waste generation would be associated with the Project, and the construction contractor would be required to comply with all pertinent regulations regarding the disposal of solid waste. Palo Alto Recycled Water Project Page 93 Initial StudylMitigated Negative Declaration . a) No Impact. The Project is limited to construction and operation of a recycled water pipeline, an associated booster pump station, and a pump station at the RWQCP. Pipeline and pump station operation and use of recycled water would be in accordance with Title 22 and the RWQCB-issued NPDES permit. Waste Discharge Requirements for use of recycled water would detail any wastewater treatment and monitoring requirements held by the RWQCP. Therefore, Project implementation would not result in any exceedance of wastewater treatment requirements. b) No Impact. The proposed Project consists of distribution pipelines, an associated booster pump station, and a pump station at the RWQCP. The Project is proposed in order to provide for the beneficial use of recycled water within the City of Palo Alto and provides benefits to both wastewater and water resources management, through provision of a disposal mechanism and providing a reliable irrigation supply source. c) Less-than-Significant Impact. Ground cover above distribution pipelines would be restored to prior existing conditions. In addition, the use and amount of irrigation water would not increase due to change in source of water. Therefore, the Project would not increase the need for additional off-site storm water drainage facilities. d) No Impact. The Project does not require entitlements; therefore, no impacts would occur. e) No Impact. The proposed Project is limited to distribution facilities and associated pump stations and would not generate wastewater for treatment. Therefore, no adverse effects on the regional wastewater treatment facilities are anticipated f) No Impact. Solid waste generation would be limited to construction activities, and would not affect available solid waste disposal capacity in the region. No long-term solid waste generation would be associated with the Project. g) No Impact. The contractor would be required to comply with all pertinent regulations regarding the disposal of solid waste generated by construction activities; therefore, no impacts would occur. h) No Impact. The proposed Project would not result in a substantial physical deterioration of a public facility due to increased use. The proposed Project is limited to distribution facilities and associated pump stations and would not add significant use to a public facility. Therefore, no impacts would occur, Mitigation Measures: None Required Palo Alto Recycled Water Project Page 94 Initial StudylMitigated Negative Declaration Q. MANDATORY FINDINGS OF SIGNIFICANCE Issues and Supporting Information Resources Sources Potentially Potentially Less Than No Impact Significant Significant Significant Would the project: Issues Unless Impact Mitigation Incorporated a) Does the project have the potential to degrade the quality of the environment, ../ substantially reduce the habitat of a fish or 1,2, 7, 18 wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? b) Does the project have impacts that are individually limited, but cumulatively ../ considerable? ("Cumulatively considerable" 1,4, 7, 18, means that the incremental effects of a 45,49 project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)? c) Does the project have environmental effects 4,45,49 which will cause substantial adverse effects ../ on human beings, either directly or indirectly? DISCUSSION: a) Less-than-Significant Impact. During construction activities, the proposed project has the potential to adversely affect the environmental resources in the vicinity of the project However, all potentially significant impacts would be reduced to a less than significant level with the mitigation measures included as part of this Initial Study. The reduction of discharge would have a beneficial impact on the South Bay. b) Less-than-Significant Impact. The proposed Project involves the installation of a recycled water pipeline to serve existing irrigation needs at parks, schools and businesses. Recycled water would also be used for dust control. The proposed Project would contribute to cumulative impacts in conjunction with other projects in the area but these impacts would not be significant. The Master Plan EIR evaluated multiple phases the recycled water program. Temporary (construction-related) impacts to water quality, air quality, traffic, and noise would be mitigated through construction BMPs to prevent storm water runoff, excessive noise and air emissions, and traffic delays. Also, projects in the area would not be constructed in the same time period, which would also minimize impacts. Proposed alignments were identified based upon available roadway routes, and would not result in a disproportionately high and adverse human health or environmental effects on minority populations or low-income popUlations. Palo Alto Recycled Water Project Page 95 Initial StudylMitigated Negative Declaration The proposed Project would impact traffic along the pipeline alignment during the construction period. Other projects within the City in the project area could have a cumulative effect on traffic. The contribution to traffic from the proposed project would not be considerable. Global Climate Change Less-than Significant-Impact. The potential effect of greenhouse gas CGHG) emissions 18 on global climate change is an emerging issue that warrants discussion under CEQA. Unlike the pollutants discussed in the Air Quality section that may have regional and local effects, GHGs have the potential to cause global changes in the environment. In addition, GHG emissions do not directly produce a localized impact, but may cause an indirect impact if the local climate is adversely changed by its cumulative contribution to a change in global climate. Individual projects contribute relatively small amounts of GHGs that when added to all other greenhouse gas producing activities around the world result in increases in these emissions that have led many to conclude is changing the global climate. However, no threshold has yet been established for what would constitute a cumulatively considerable increase in GHGs for individual development projects. The State of California has taken several actions that help to address potential global climate change impacts. Although not originally intended to reduce GHG emissions, California Code of Regulations Title 24 Part 6: California's Energy Efficiency Standards for Residential and Nonresidential Buildings, was first established in 1978 in response to a legislative mandate to reduce California's energy consumption. The standards are updated periodically to allow consideration and possible incorporation of new energy efficiency technologies and methods. In 2006, the California State Legislature adopted AB 32, the California Global Warming Solutions Act of 2006. AB 32 describes how global climate change will impact the environment in California. The impacts described in AB 32 include changing sea levels, changes in snow pack and availability of potable water, changes in storm flows and flood inundation zones, and other impacts. The list of impacts included in AB 32 may be considered substantial evidence of environmental impacts requiring analysis in CEQA documents. AB 32 focuses on reducing GHG emissions in California. The GHG emissions reductions found in AB 32 and Executive Order S-3-05, signed in June 2005, are consistent with the climate stabilization models produced by the International Panel on Climate Change (IPCC). These climate stabilization models show that if GHG emissions are reduced to the levels shown in Executive Order 8-3-05, the climate will stabilize at approximately a 2 degree Celsius rise, ave11ing the worst impacts associated with global climate change. GHG as defined under AB 32 include: carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. AB 32 requires the California Air Resources Board (ARB), the State agency charged with regulating statewide air quality, to adopt rules and regulations that would achieve GHG emissions equivalent to statewide levels in 1990 by 2020. In June 2008, the California's Office of Planning and Research (OPR) issued an interim Technical Advisory on the role of CEQA in addressing climate change and GHGs. As part of the advisory, OPR asked ARB staff to recommend a method for setting statewide thresholds of significance for GHG emissions, to encourage consistency and uniformity in the CEQA analysis for GHG emissions throughout the state. ARB is currently developing recommended 18 GHGs as defined under AB 32 include: carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride Palo Alto Recycled Water Project Page 96 Initial StudyfMitigated Negative Declaration statewide interim thresholds of significance for GHGs that may be adopted by local agencies for their own use. On October 24, 2008, ARB released the Preliminary Draft Staff Proposal on the Recommended Approaches for Setting Interim Significance Thresholds for Greenhouse Gases under the California Environmental Quality Act. The proposal, which is currently undergoing public review, focuses on common project types that, collectively, are responsible for substantial GHG emissions -specifically, industrial, residential, and commercial projects. The report proposes a quantitative threshold of 7,000 metric tons of CO2 equivalent per year (MTC02e/year) for operational emissions (excluding transportation) associated with industrial projects, and performance standards for construction and transportation emissions. ARB staff intends to make its final recommendations on thresholds in 2009, but currently no quantitative, significant criterion has been adopted for determining impact significance. According to the OPR interim. Technical Advisory, in the absence of clearly defined thresholds for GHG emissions, CEQA requires that lead agencies disclose and mitigate such emissions to the extent feasible whenever the lead agency determines that the project contributes to a significant, cumulative climate change impact. The advisory recommends identifying and quantifying, to the extent possible, GHG emissions, assessing the significance of the impact, and identifying alternatives or mitigation measures to reduce impact significance, as appropriate. In the absence of adopted significance thresholds for GHG emissions, the following discussion is provided to disclose the potential effects of the proposed Project (from both construction and operation) on global climate change. The Project would generate GHGs during construction and ongoing operations. During construction, the operation of heavy construction equipment during trenching and pipeline installation would be the primary source of GHGs. However, these emissions would in effect be temporary and would cease upon completion of construction. For that reason and given the relatively small-scale of construction, the Project is not expected to result in a net increase in GHG emissions that would significantly delay or hinder the State's ability to meet the reduction targets contained in California Governor's Executive Order S-3-05 and the impact is considered less than significant. However, given that ARB is currently recommending mandatory performance standards for construction activities, the Project will include the following measures that will help reduce the Project's GHG emissions: • The contractor shall reduce emissions through any of the following options or others that achieve reduction in overall emissions: use late-model engines, low-emission diesel products or alternative fuels (e.g., Lubrizol, Puri NOx, biodisel fuel) in all heavy duty off-road equipment. • The contractor shall minimize idling time to 10 minutes for all heavy-duty equipment when not engaged in work activities, including on-road haul trucks while being loaded or unloaded onsite. • A City-approved Solid Waste Diversion and Recycling Plan (or such other documentation to the satisfaction of the City) will be in place prior to project construction. The Plan shall demonstrate the diversion from landfills and recycling of all nonhazardous, salvageable and re-useable wood, metal, plastic and paper products during construction and demolition activities. The Plan or other documentation shall include the name of the waste hauler, their assumed destination for all waste and recycled materials, and the procedures that will be followed to ensure implementation of this measure. Following construction and with commencement of recycled water deliveries, the Project's operation is expected to generate minor quantities of GHG emissions over the long-term. The primary sources of GHG emissions would be associated with periodic vehicle trips for Palo Alto Recycled Water Project Page 97 Initial StudylMitigated Negative Declaration maintenance and new electrical load associated with operation of the pump stations. Assuming the most-conservative operational scenario in which the pumping stations are operated 24 hours a day and 7 days a week, the calculated GHG emissions would be approximately 1240 MTC02e/year19, less than the interim thresholds for industrial projects proposed by ARB. Further, ongoing operations and maintenance vehicle trips would generate negligible GHG emissions and are not expected to deviate from baseline conditions. The operation of the pump stations is estimated to have a net electric usage increase over current pumping operations for potable water delivery to the future recycled water customers. However, the electric load associated with the Project would take power from the City of Palo Alto electric utility (CPAU). Although electricity usage could increase as a result of project use, CPAU has made a significant commitment to purchase renewable "green" energy supplies and expects that the recycled water system would benefit from current efforts to increase supplies from resources with reduced GHG footprints. The Project could also subscribe to a CPAU commercial green pricing rate schedule so that there is no cumulative GHG increase contribution from the Project20• From a regional and statewide perspective, recycled water projects offer flexibility in reducing the need to pump potable water from distant locations for local deliveries. Considering the nexus between energy use and water delivery in California, recycled water projects could play an increasing role in future attempts to reduce both GHG emissions and energy consumption associated with any additional water deliveries. Given the overwhelming scope of global climate change, it is not anticipated that a single development project would have an individually discernable effect on global climate change (e.g., that any increase in global temperature or rise in sea level could be attributed to the emissions resulting from one single development project). Rather, it is more appropriate to conclude that the GHG emissions generated by the proposed Project would combine with emissions across the state, nation, and globe to cumulatively contribute to global climate change. In an effort to make a good faith effort at disclosing environmental impacts and to conform with the CEQA Guidelines [§16064(b)], it is the City's position that, based on the nature and size of this project, the proposed Project would not impede the state's ability to reach the emission reduction limits/standards set forth by the State of California by Executive Order S- 3-05 and AB 32. For these reasons, this Project would not make a cumulatively considerable contribution to global climate change associated with GHG emissions. As such, impacts are considered less than significant. Mitigation Measures: None Required 19 The calculations are based on emission factors derived from the California Climate Action Registry PowerfUtility Protocol Public Reports (as of June 2008) and the Emissions from California Air Resources Board, Greenhouse Gas Inventory, 1990 2004 (November l7,2007). The emissions factors are based on PG&E's utility specific verified electricity C02 Emissions factors for 2004. These calculations, presented in Appendix B, are estimates of expected project emissions from the new pump station operation only, including carbon dioxide and methane generation, the combination of which are representative ofGHG emissions. 20 Palo Alto Green is a voluntary renewable energy program that allows customers to offset their energy use by paying a premium on their utility bill. The money is collected by the City to buy Renewable Energy Credits which in turn fund renewable energy projects statewide. Palo Alto Recycled Water Project Page 98 Initial StudylMitigated Negative Declaration Report Preparation Report Authors Table 6: IS/MND Authors Authors Role I Backuroulld Y cars RMC Water and Environment 222 Sutter Street, Suite 700 San Francisco,CA 94108 Mike Matson, P .E. Senior Technical Advisor BS, Civil Engineering, University of Cali~()I"l'1il;l, Berkeley 22 . ........... , .... . Helene Kubler, P.E. Erin Bibeau Kevin P.E. Robin Cort Leslie Dumas, P.E. Suet Chau Proj ect Manager, QA/QC Environmental Lead J.>r()J~ct Engineer , Technical Review , Hydrology and Water Quality, Traffic Environmental Planner Ch~topher~~ . ..J{)~~epltand Associates Aindrea Jensen William Self Associates Eric Strother Cultural Resources Palo Alto Recycled Water Project Page 99 , BS, Environmental Engineering, Toulouse, France MS, Environmental Engineering, Stallford Universi!)" California 7 , BA, Environmental Policy, Colby College MES, Masters in Environmental Science and Management, University of California, Santa B~b~a 8 BS, Civil Engineering, University of Virginia MS, Environmental Engineering, Universi!y()fCaliforniGl'I3~rkeley 3 BS, Biology, Stetson University Ph.D., Ecology, State University of New York at Stony Brook , BS, Civil Engineering, Virginia . Polytechnic Institute and State University MS, Civil Engineering, University of California,I3erkeley BA, Environmental Science, University of California,fjerkeley BS Wildlife Management, Humbold! State Universi!y ... ~~~,.~~. , BA, Anthropology, California State University, Chico MA, Anthropology, California State Universi , Ha ward 25 21 11 7 10 Initial StudylMitigated Negative Declaration SOURCE REFERENCES 1. Project Team's knowledge of the site and the proposed project 2. City of Palo Alto. 2007. Palo Alto Comprehensive Plan. July 17,2007. 3. Palo Alto Municipal Code, Title 18 -Zoning Ordinance 4. Environmental Science Associates. 2003. Palo Alto Regional Water Quality Control Plant Recycled Water Pipeline Project Initial Study and Draft Mitigated Negative Declaration. Prepared for the Palo Alto Regional Water Quality Control Plant. October 2003. 5. California Department of Conservation Division of Land Resource Protection. Farmland Mapping and Monitoring Program. Internet website: http://www.consrv.ca.gov/dlrp/fmmp/index.htm. Accessed on December 3, 2006. 6. Bay Area Air Quality Management District. BAAQMD CEQA Guidelines, Assessing the Impacts of Projects and Plans, December 1999. Internet website: http://www.baaqmd.gov/plnlceqalceqa_guide.pdf. Accessed on December 2, 2006. 7. Field reconnaissance conducted by a biologist from Christopher A. Joseph & Associates, September 19,2007 8. California Department ofFish and Game (CDFG). 2007. California Natural Diversity Database (CNDDB) Rarefind [CD-ROM], Wildlife Habitat Data Analysis Branch, California Department ofFish and Game. Sacramento: California. 9. U.S. Fish and Wildlife Service (USFWS). August 16,2007. Federal Endangered and Threatened Species that Occur in or May be Affected by Projects in the Palo Alto (428B) USGS 7.5 Y:z Minute Quad. Sacramento (CA): Sacramento Fish and Wildlife Office. Accessed on September 13,2007 from http://www.fws.gov/sacramento/es/ssp lists. 10. Bartens, Debra. December 5, 2006. Personal Communication with Debra Bartens, Palo Alto Baylands Preserve. Phone conversation with Aindrea Jensen. 11. Bousman, W. G. 2005. A Checklist of the Birds of Santa Clara County, California. Santa Clara Valley Audubon Society. April 2005. 12. Browning, James. September 1,2006. Personal Communication James Browning, Biologist, USFWS. Phone conversation with Aindrea Jensen. 13. Bulger, J. B., Norman J. Scott Jr., and Richard B. Seymour. 2002. Terrestrial activity and conservation of adult California red-Ieggedfrogs Rana aurora draytonii in coastalforests and grasslands. Biological Conservation 110(2003) 85-95. 14. California Native Plant Society (CNPS). 2007. Inventory of Rare and Endangered Plants (online edition, v7- 07c). California Native Plant Society, Sacramento. Accessed on September 13,2007 from http://cnps.orglinventory. 15. Evens,J. 1999/2000. Mystery of the marsh: the California black rail. TidelineVoI19No.41-3. Available from http://www.fws.gov/desfbay/ArchiveslRail/BlackRail.htm. 16. U.S. Fish and Wildlife Service (USFWS). 2002. Recovery Plan for the California Red-legged Frog (Rana aurora draytonii). U.S. Fish and Wildlife Service, Portland, Oregon. viii + 173 pp. 17. U.S. Fish and Wildlife Service. 2000. Draft Survey Protocol: California Clapper Rail (Rallus longistrostris obsoletus ). 18. Field reconnaissance conducted by William Self Associates Senior Archaeologist, Eric Strother, M.A., RPA., September 17, 2007 Palo Alto Recycled Water Page 100 lVlH,'l:S'''!OU N,,,,,,tivp Declaration 19. California State Office of Historic Preservation (OHP). 2006 Historic Property Directory. Data File for Santa Clara County, September 18, 2006, page 38. California Department of Parks and Recreation. 20. California State Office of Historic Preservation (OHP). 1976. California Inventory of Historic Resources. California Department of Parks and Recreation. 21. California State Office of Historic Preservation (OHP). 1989. Survey of Surveys. California Department of Parks and Recreation. 22. California State Office of Historic Preservation (OHP). 1990 California Historical Landmarks. California Department of Parks and Recreation. 23. California State Office of Historic Preservation (OHP). 1992 Caltfornia Points of Historical Interest. California Department of Parks and Recreation. 24. California State Office of Historic Preservation (OHP). 2006. California Register of Historical Resources. California Department of Parks and Recreation. 25. Kroeber, A. L. 1925. Handbook of the Indians of California. Bureau of American Ethnology of the Smithsonian Institution. Bulletin 78, Washington. 26. Kyle, D.E. 1990. Historic Spots in California, 4th Edition. Stanford University Press, Palo Alto, Ca. 27. Letter from the Native American Heritage Commission, August 31, 2007. 28. Levy, R. S. 1978a. Costanoan. In Handbook of North American Indians, edited by R. F. Heizer, pp. 485-495. vol. 8: California, W. C. Sturveyant, general editor. Smithsonian Institution, Washington, D.C. 29. Levy, R. S. 1978b. Eastern Miwok In Handbook of North American Indians, edited by R. F. Heizer, pp. 398- 413. vol. 8: California, W. C. Sturtevant, general editor. Smithsonian Institution, Washington, D.C. 30. Moratto, M. J. 1984. California Archaeology. Academic Press, Orlando, Florida. 31. National Park Service. 2006. National Register of Historic Places. Washington, DC. 32. Northwest Information Center of the California Historical Resources Information System. 2006. Cultural Resource Record Search (File No. 06-335). Requested by William Self Associates, Inc., Orinda, California, October 23,2006. 33. Fredrickson, D. A. 1973. Spatial and Cultural Units in Central California Archaeology. In Toward a New Taxonomic Framework for Central California: Essays by James A. Bennyhoff and David A. Fredrickson, edited by R. Hughes, Contributions of the University of California Archaeological Research F aGility 15. Berkeley. 34. Toulouse, Julian Harrison. 1971. Boule Makers and Their Marks. Thomas Nelson Inc., New York. 35. General Land Office Plat Map (GLO). 1883. T55 R2W Mount Diablo Base Meridian. Rancho Rinconada del Arroyo de San Francisquito Plat Map 36. General Land Office Plat Map (GLO). 1861. Confirmed to Heirs of Maria Antonia Mesa. 37. Thompson and West. 1876. Historical Atlas Map of Santa Clara County, California. San Francisco. United States Geologic Survey (USGS) 38. Thompson and West. 1899. Palo Alto Quadrangle Topographic Map (reprinted in 1906). 39. Alquist-Priolo Earthquake Fault Zoning Map Palo Alto Recycled Water Project Page 101 Initial StUidy/lVlitiigatled Negative Declaration 40. Hart, E.W. and Bryant, W.A. Fault-rupture hazard zones in California: California Department of Conservation, Division of Mines and Geology Special Publication 42. 1997 (revised). Internet website: ftp://ftp.consrv.ca.gov/pub/dmglpubs/sp/SP42.pdf. Accessed on December 3, 2006. 41. California Department of Conservation California Geological Survey. Seismic Hazard Zones -Mountain View Quadrangle. Official Map Released: October 18, 2006. Accessed on-line at http://gmw.consrv.ca.gov/shmplhtml/pdCmaps_no.html on December 3,2006. 42. Required compliance with the Uniform Building Code (UBq Standards for Seismic Safety and Windload 43. California Department of Toxic Substances Control. DTSC's Hazardous Waste and Substances Site List (Cortese List). Internet website: http://www.dtsc.ca.gov/SiteCleanup/Cortese_List.cfm. Accessed on December 3, 2006. 44. Palo Alto Airport Master Plan Report, December 2006 45. RMC Water and Environment. Palo Alto Regional Water Quality Control Plant Disinfection Facility Plan Report. June 2007. Prepared for the City of Palo Alto. 46. Stinson, M. C., M. W. Manson, J. J. Plappert. Mineral Land Classification Map: Aggregate Resources Only- Alameda and Santa Clara Counties. California Division of Mines and Geology, 1982. 47. U.S. Environmental Protection Agency. Noisefrom Construction Equipment and Operations, Building Equipment, and Home Appliances. December 1971. 48. CH2MHill, Inc. "Final Environmental Impact Report Palo Alto Regional Water Quality Control Plant Wastewater Reclamation Program." April 1995. 49. RMC Water and Environment. 2004. "Final Report Mountain View/Moffett Field Area Water Reuse Project, Regional Recycled Water Facilities Planning Study." State Water Resources Control Board Water Recycling Project No. 3212-010. Prepared for Palo Alto Regional Water Quality Control Plant. March 2004. 50. RMC Water and Environment. 2006. City of Palo Alto -Recycled Water Market Survey Report Final Report. July 2006. 51. HortScience, Inc. Evaluation of Use of Recycled Water on Redwoods in the Mountain View I Moffett Area. January 2005. 52. City of Palo Alto Department of Planning and Community Environment. Tree Technical Manual, City of Palo Alto Standards & Specifications, Palo Alto Municipal Code, Chapter 8.10.030. June 2001. 53. Dockter, Dave. City of Palo Alto Arborist/Landscape Advisor. Personal Consultation. January 2009. 54. Oster, -J.D. Irrigation with Recycled Water in Santa Clara County: Limitations and Potentials, 2009. 55. Barnes, Corey S., L.R. Oki, and R.Y. Evans. Determining the Tolerance of Coast Redwood, Sequoia Sempervirens 'Aptos Blue' to Sodium and Chloride, 2007. 56. Beaudette, B.M. and M.J. Singer, Evaluation of Local Soils for Susceptibility to Structural Degradation from Irrigation, 2007. 57. William Self Associates, Cultural Resources section for the Palo Alto Recycled Water Facility Project ISIMND. March 2009. Palo Alto Recycled Water Page 102 Initial StudylMitigated Negative Declaration APPENDIX A POTENTIAL FUTURE USERS Palo Alto Recycled Water Facility Plan Demand Analysis Potential Customer Location Alta Mesa Memorial Park 695 Arastradero Rd f"=---Roche Bioscience 3431 Hillview Ave Hewlett Packard 3000 Hanover St Agilent Technologies 3500 Deer Creek Rd VA Palo Alto Health Care 3801 Miranda Ave ~bberley Community Center 4000 Middlefield Rd Hewlett Packard 1501 Page Mill Rd VM Ware (formerly Stanford & Hines) 3401 Hillview Ave Gunn Senior High School 780 Arastradero Rd Mitchell Park 600 E. Meadow Dr DPIX 3406 Hillview Ave Clark Park Old Trace Road Terman Park 655 Arastradero Rd Genencor International, Inc 925 Page Mill Rd CPI 811 Hansen Way Lockheed Missiles & Space 3251 Hanover St Varian, Inc. 3120 Hansen Wy Stanford & Hines Interest 6()O Hansen Way Equity Office Properties 4001 Miranda Ave Stanford & Hines Interest 925 Page Mill Rd Dow Jones & Co 901 California Ave EPRI 3420 Hillview Ave Hoover Park 2901 Cowper St Beckman Instruments 1050 Page Mill Rd Palo Alto Research Center 3333 Coyote Hill Rd Robles Park 4116 Park Blvd F=>age Mill Rd Prop, Inc 1801 Page Mill Rd SAP Labs, Inc 3410 Hillview Ave Wilson/S/G/R 650 Page Mill Rd Tibco Software Inc 3301 Hillview Ave ,- Primary Type of Use irrigation irrigation, commercial irrigation, commercial irrigation irrigation irrigation irrigation, commercial irrigation irrigation irrigation irrigation, commercial irrigation irrigation irrigation irrigation_ irrigation commercial irrigation irrigation irrigation irrigation jrriQation irrigation irrigation irrigation irrigation irrigation irrigation irrigation irrigation Annual Average Demand On-Site Retrofit I Irrigation Annual Estimate System Conversion Demand (AFY) (MGD) Required 92.9 0.083 Yes 76.7 0.068 Yes --- 58.8 0.052 Yes -----40.5 0.036 Yes 37.7 0.034 Yes 29.4 0.026 Yes 29.2 0.026 Yes ----~------ 29.2 0.026 Yes 26.1 0.023 Yes ~_.25.7 0.023 Yes -21.0 0.019 Yes 20.0 0.018 Yes 19.9 0.018 Yes 19.2 0.017 Yes 18.5 0.016 Yes 15.3 0.014 Yes --- 13.8 0.012 Yes 13.6 0.012 Yes 13.3 0.012 Yes 12.8 0.011 Yes 12.7 0.011 Yes .. -J 12.7 ---0.011 Yes 12.6 0.011 Yes --- 12.2 0.011 Yes - 11.8 0.011 Yes 11.5 0.010 Yes 11.3 0.010 Yes -_.-------- 11.2 0.010 Yes -------10.9 0.010 Yes 10.4 0.009 Yes Stanford Hospital and Clinics -------~~ Yes 2670 Hanover St irrigation 9.6 0.009 -~ ~-~ Palo Alto Square 3000 EI Camino Real irrigation 9.1 0.008 Yes Agilent Technologies 1601 California Ave irrigation 8.6 .~~~ O.OOB Yes ----~ Yes DNAX Research Institute 901 S. California Ave. irrigation B.3 0.007 Ramos Park 800 E. Meadow Dr irrigation I ~- 7.6 0.007 IYes SAP Labs, Inc 3473 Deer Creek Rd irrigation 7.4 0.007 Yes Jane L Stanford Middle School 480 E. Meadow Dr irrigati()rl 7.3 0.007 Yes ----.- Xerox COIP 3400 Hillview Ave ir~igation 7.2 0.006 Yes Alza 1501 California Ave irrigation, commercial 6.6 0.006 Yes .- Page Mill Center 1530 Page Mill Rd irrigation 6.6 0.006 Yes f-----'" ~ ~~~~ ----~ Carramerica Reality Corp 3075 Hansen Wy irrigation 6.4 0.006 Yes Lockheed Missiles & Space 3176 Porter Dr irrigation 6.3 0.006 Yes EI Carmelo Elementary School 3024 Bryant St irrigation 6.2 0.006 Yes ()ur Lady of the Rosary School/Church 3290 Middlefield Rd irrigation 6.2 0.006 Yes Wilson/S/G/R 950 P§lg~ Mill Rd inrigCition 6.1 0.005 Yes ~ .. Matadero Creek 3172 Porter Dr irrigation 5.6 0.005 Yes ~-~ ~c CV Therapeutics, Inc. 1651 Page Mill Rd irrigation 5.1 0.005 Yes 495 Java Drive Assoc 1001 Page Mill Rd irrigation, commercial 5.0 0.004 Yes ------- Marcus & Millichap, Inc. 777 California Ave irrigation 5.0 0.004 Yes Trinet Essential 1661 Page Mill Rd irrigation 4.6 0.004 Yes ---- Pkwy Ore/Pg Mill 16~0 Page Mill Rd irrigation 4.3 0.004 Yes 340 Portage Housing 340 Portage irrigation 4.2 0.004 Yes Jane L Stanford Middle School 500 E. Meadow Dr irrigation 4.1 0.004 Yes EPRI 3412 Hillview Ave irrigation 4.0 0.004 Yes ~-~ Stanford & Hines Interest 3150 Porter Dr irrigation 3.6 0.003 Yes ~;~ C& J Management 3165 Porter Dr irrigation 3.3 0.003 Yes Stanford & Hines Interest 3421 Hillvew Ave irrigation 3.1 0.003 Yes U!liversity Club of PA 3277 Miranda Ave irrigation 3.0 0.003 Yes Cameron Park 2101 Wellesley St irrigation 2.9 -0.003 Ye~_ - Mozart Development 3300 Hillview Ave irrigation 2.B 0.003 Yes Stanford Hospital and Clinics 2690 Hanover St ir~igation 2.B 0.002 Yes Varian Medical Systems -~-~ 3100 Hansen Wy irrigation 2.6 0.002 Yes Foothills Club 3351 Miranda Ave irrigation 2.6 0.002 Yes Stanford & Hines Interest 3170 Porter Dr irrigation 2.4 0.002 Yes Simpson Thacher & Bartlet 3330 Hillview Ave irrigation 2.3 0.002 Yes ~-~ ~-~ ECI Deer Creek LLC 3408 Hillview Ave irrigation 2.3 0.002 Yes !iV:E3ops.com Inc 3340 Hillview Ave irrigation ----_ ~.:3_ ~ _~O.OO~ _ Yes ~~--... -.---~--~---.. -- Paine Webber, Inc 775 Page Mill Rd irrigation 2.1 0.002 Yes .- Legato Systems 3210 Porter Dr ir£igation 2.0 0.002 Yes [Werry Park 2100 Dartmouth St irrigation 2.0 0.002 Yes Tibco Software Inc 4015 Miranda Ave irrigation 2.0 0.002 [Yes 'NYSE ._. 845 Page Mill Rd irrigation 1.9 0.002 Yes -_. Mitchell Park 3800 Middlefield Rd irrigation 1.9 0.002 Yes Hewlett Packard 3200 Hillview Ave irrigation 1.9 0.002 Yes Stanford & Hines Interest 3180 Porter Dr irrigation 1.8 0.002 Yes ECI Deer Creek LLC 3495 Deer Creek Rd irrigation 1.8 0.002 Yes -~ Weisshaar Park 2298 Dartmouth St irriga!ion 1.7 0.002 Yes ._. Fairmeadow Elementary School 490 E. Meadow Dr irrigation 1.6 0.001 Yes Pkwy Cal/Birch 2771 Birch St irrigation 1.6 0.001 Yes Hewlett Packard 3215 Hillview Ave irrigation 1.6 0.001 Yes CNF Transportation Inc 3240 Hillview Ave irrigation 1.6 0.001 Yes Cprognostics 900 Hansen Wy irrigation 1.5 0.001 Yes .. Wilson/S/G/R 601 California Ave irrigation 1.5 0.001 Yes l=Tr1negan, Henderson LLP •.. .-_ .. _- 700 Hansen Way irrigation 1.5 0.001 Yes Nanosys, Inc 2625 Hanover St irrigation 1.4 0.001 Yes -=-----:--. Parkway 370 Grant Ave irrigation 1.4 0.001 Yes ~ 850 Assoc C/O WSJ Prop 850 Hansen Wy irrigation 1.2 0.001 Yes Mayfield Park 2302 Wellesley St irrigation 1.0 0.001 Yes VMWare Inc 3305 Hillview Ave irrigation 1.0 0.001 Yes ~. Parks Dept 900 Arastradero Rd irrigatiol'l 0.8 0.001 Yes - Cooley Godward LLP 3175 Hanover St irrigation 0.8 0.001 IYes r-:,-' 1290 Page Mill Rd irrigation 0.7 0.001 Yes Carten -Trust Tibco Software Inc 3303 Hillview Ave irrigation 0.7 0.001 IYes f---.. -- Mitchell Park Library 3700 Middlefield Rd irrigation 0.7 0.001 Yes Fire Station 2675 Hanover St irrigation 0.7 0.001 1)'1 _~ - 1101 E Meadow Housing 1101 E. Meadow Dr irrigation 0.6 0.001 Yes 2450-2500 EI Camino Housing 2450 EI Camino Real irrigatLon 0.6 0.001 IYes ._. Wilson/S/G/R 975 Page Mill Rd irrigation 0.6 0.000 Yes f---. ---- Pkwy Cal/Birch 480 California Ave irrigation 0.5 0.000 IYes ~~ldPark 2300 Wellesley St irrigation 0.5 0.000 Yes Marcus & Millichap, Inc. 2626 Hanover St irrigation 0.5 0.000 Yes _. ~rian Medical Systems 3450 Hillview Ave irrigation 0.5 0.000 Yes Pkwy Aras 1055 Arastradero Rd irrigation 0.5 0.000 Yes rpkwy Ore/Pg Mill ._. 130 Sheridan Ave irrigation _~4-__ .JLOQL_ .'fe_s _. _____ . ___ -~""---------... ~ Tibco Software Inc 3307 Hillview Ave irrigation 0.4 0.000 Yes ----- Stanford Univ 1454 Page_Mill Rd irrigation 0.4 0.000 Yes Pkwy EI Camino 3101 EI Camino Real irrigation 0.4 0.000 Yes Wells Fargo Bank, NA 505 California Ave irrigation 0.3 0.000 Yes .----- Fire Station 3600 Middlefield Rd irrigation O.~ 0.000 Yes RWI Group 835 Page Mill Rd irrigation 0.3 0.000 Yes ~ .. 94.0 E Meadow Housing 940 E. Meadow Dr irri9~tiol1 0.3 0.000 Yes 2701 EI Camino housing 2701 EI Camino Real irrigation 0.3 0.000 Yes Pkwy Cal/Birch 2600 Birch St irrigation 0.3 0.000 Yes Equity Office Properties 4005 Miranda Ave irrigation 0.2 0.000 Yes ---- Pennie & Edmonds LLP 3300 Hillview Ave irrigation 0.2 0.000 Yes City of Palo Alto 475 Cambridge Ave irrigation 1~0.2 0.000 Yes R R Donnelley Financial 855 California Ave irrigation 0.2 0.000 Yes Nanosys, Inc 2627 Hanover St irri9~tion 0.2 0.000 Yes I-c-.. Pkwy Alma/Fairmdw 3615 Alma St irrigation 0.2 0.000 Yes ~.--2400 Hanover St _0:2 Yes Avery Construction irrigation 0.000 ----P~wy EI Camino 2501 EI Camino Real irrigation 0.2_ 0.000 Yes I:l~wy Park Blvd 3490 Park Blvd irrigation 0.1 0.000 Yes Pkwy Cal/Birch 394 California Ave irrigation 0.1 0.000 Yes Substation 1151 E. Meadow Dr irrigation 0.1 0.000 Y, -----a.aoo--Dow Jones & Co 1701 Page Mill Rd irrigation 0.1 Yes Pkwy Cal/Birch 444 California Ave irrigCition 0.1 0.000 Yes .- Substation 3297 Park Blvd irrigation 0.1 0.000 Yes Parkway 3360 Park Blvd irrigation 0.0 0.000 Yes Substation 3620 Middlefield Rd irrigation 0.0 0.000 Yes Substation 800 Hansen Way irrigation 0.0 0.000 Yes _.. . 3625 Alma St irrigation 0.0 0.000 Yes Pkwy Alma/Falrmdw i-0.000 .. - Varian Medical Systems 3075 Hansen Wy irrigation 0.0 Yes Space Systems Loral 3825 Fabian Way commercial 0.0 0.000 Yes ----- 1451-1601 California Housing 1451 California commercial 0.0 0.000 Yes 969 0.86 This page left intentionally blank APPENDIX B EMISSIONS CALCULATIONS RMe Project: Aspect: Estimate T Constants Palo Alto Recycled Water Project Air Quality Calculations Level Total Volume of Excavation/Disturbance Total Area of Excavation/Distrubance Mont"s, construction Days, ccnstruction 979,230 ftA3 173,230 ftA2 11.8 354 olume 36.268 CY 3.98 ae Djstrubed Emissions ractor Emissions per Emissions Emissions per Construction Equipment Emissions (ydA3) Igmlyd3) Emissions (kg) day (kg/day) (Ibs) day (lbs/day) Heali)' and Ught Duty Construction Equipment PM 10 CO ROG NOx SOx 35601 2.2 35601 138 35601 9.2 35601 42,4 35601 4.6 Area of Excavation! Length of 78 0.22 173 4913 13.88 10831 328 0.93 722 1509 4.26 3328 164 0.46 381 Disturbance Disturbance Emissions Emissions Emissions Exposed Soil Emissions (ac) (days) (Ibs/ae/day) (Ibs/day) (Ibs) PM 10 due -to ConstruetiOriActivities 51 Ibs per acre per day 3.98 354 51 203 71600 This conservatively assumes that the entire area of excavation is exposed all at once Average 0.49 30.60 2.04 9,40 1.02 Gallons of Average Average Annual Average Fuel Burned EmiSSions factor Annuat El'nissions per Emissions Emissions per Emissions due to operation (gal) (gm/gal) Emissions (kg) <lay (kg/day) (Ibs) day (Ibslday) Backup Power Generator for booster pump station PM 10 CO ROG NOx SOx Booster pump station assumptions: hours use per yea r gallons per hour gallons per year 413012008 10: 39 AM Cales based on assumptions below and Reali)' andT[gfi[ Duly Construction Equipment 359 8 2.9 0.01 6.3 359 511 183.2 0.50 404.0 359 34 12.2 0.03 26.9 359 157 56.3 0.15 124.1 359 17 6.1 0.02 13.4 22 16.3 358.6 hrs gallhr gallyr assume 2 days of use (2x8hrs) + monthly testing (12x.5hr) SD230-16T3 230kW John Deere Page 1 of 1 0.02 1.11 0.07 034 004 Date: February 26, 2008 Project Number. 0038-009 Prepared by: K. Smith BAAQMD CEQA Guidelines, 1996 BAAQMD CEQA Guidelines, 1996 BAAQMD CEQA Guidelines, 1996 BAAQMD CEQA Guidelines, 1996 BAAQMD CEQA Guidelines, 1996 EPA standards from BAAQMD CEQA Guidelines, 1996 BAAQMD CEQA Guidelines, 1996 BAAQMD CEQA Guidelines, 1996 BAAQMD CEQA Guidelines, 1996 BAAQMD CEQA Guidelines, 1996 BAAQMD CEQA Guidelines, 1996 AQ calcs Palo Alto RW Pump GHG Emissions New Pump Station 400 HP/hr = 298.28 KWh Total Annual KWh ::: Totallbs/C02/year= Total metric tons/C02/year= Totallbs/CH4/year ::: Total metric tons/CH4/year= Project Total MTC02e/yr Assumptions Pumps run via electrical grid 1 HP/hr = 0.7457 KWh 400 HP pump Operations assumed 24/7 0.5662 Ibs/C02 emitted per KWh 2,204.62 Ibs = 1 metric ton 0.000029 Ibs/CH4/KWh (2) Source(s): 2548504.32 1442963.146 654.5178516 73.90662528 0.033523521 1241.76302 WPCF Pump Improvements 350 HP/hr = 260.995 KWh Total Annual KWh = Totallbs/C02/year= Total metric tons/C02/year= Totallbs/CH4/year ::: Total metric tons/CH4/year::: (1) California Climate Action Registry Power/Utility Protocol Public Reports (as of June 2008). http://www.dimateregistry.org/CARROT/public/reports.aspx 2286316.2 1294512.232 587.1815698 66.3031698 0.030074648 (2) Emissions from California Air Resources Board, Greenhouse Gas Inventory, 1990 -2004 (November 17, 2007 version), available on line at http://www.arb.ca.gov/cc/inventory/data/data.htm. Consumption data from California Energy Commission, http://www.energy.ca.gov This page left intentionally blank APPENDIX C BIOLOGICAL RESOURCES 'cientific Nart1t.! CcmmonName canthomintha duttonii San Mateo thom~mint canthamintha lonceniola Santa Clara thorn~ming Ilium peninsuiare vaT. Franciscan onion msiru:kia /unaris Ibent·flowe",.! fiddleneck rctostaphy/os tmdersonii I Santa Cruz manzanira rCfostaphylw montartJensis 1 Montam manzanita Tabid Special~Sutus Plants Evaluated for Potentiai to Occur wlthin tbe Study Area. SensitivitvlRe2Ulatorv Statust Regulatory Status CllFG Sensitivity Rank CNllllB CNP FESA ! CESA I Global State List IB,II FE SU List42 List 18,2 05T2 S2.2 1 List IB,21 02 S2.2 1 List IB,21 G2 52? 1 List IB,21 G2 52,2 Genera) Habitat haparral, valley and foothill rasslandlserpentinite ismontane woodland, valley and foothill jgrasslandlclay. vo~canjc, often serpentinite ICoastal bluff scrub, cismonlllllc woodland, I valley and foothill grassland I ISroadlcafed upland forest, chaparral, North Coast coniferous forest/openings, edges IChaparrai (maritime), coastal scrub Blooming fuWl Apr-Jun Mar-Jun May-11m Mar~Jun I Nov-Apr Jan-Mar Elevation ~ 50-300 No 80-1200 No 100-300 Low 3-500 Low 60-730 No 150-500 No Dis("llssion pf Potential Although grassland habitat is present in thl.: vicinity ofthc ral off the southern cnd of the backbone alignment Avenue and at the location proposed for the racilitic! at the Regional Plant, San Mateo thorn~mint occurrence is belicvoo to be extitpate.d . The srudy area does not supp<>rt habita15 this species typically inhabits, southom IW' ,mm,w Avenue, this area appear, to (e,g., mowed. foot traffic) and the vegc:ta1lon predominanteiy non-natiw grasses and herbs. There arc no recorded occurrences of this species in the CNDDB within a ti mile radius of the pipeline alignment The study area does not support habitats this species typically inhabits. The study area docs not support habitats this specilJs typically inhabits. Additionally, the study area IS below the elevation range occupied by Montara manzanita. This species is known from only approximately 10 occurrences in San Mat4.."'O COUIlt); 1,2,3 2,3,4 I 1.2 ;ot.~ti'l fo~n isdentific Name ICommon Name Genera) Habitat Discussion of Potential Source' Occurrence CNPS The study area docs not support habila1s this species typically !Arctostaphylos regismonrana IKings Mountain manzanita I List IB.21 IBroadleafe<! upland for .. ~ chaparral. Northl I I linhabits. Additionally, the study area is below the devation G2 S2.2 Coast coniferous forestlgrnnitic or lan·Apr 305·730 No range occupied by this spec.i1w'S. The nearest recorded occurrenc~ 1,2.3 sandstone of Kings Mountain manzanIta in thl.; CNDOB to the pipdinc alignment is approximately fivt! miles to the northwcdt h the marshlands cast of the study area support po[~nti ~traga/us pycnostachyus var. I_SIal m.",h milk-vetch I List IB.21 ICoastai dunes (mesic). coastal scrub, I I habitat, the study an::a docs not support this habitat or other G21'2 S2.2 marshes and swamps (coastal salt, Apr-Oct 0-30 N. habitats coastal. marsh milk~veh;h typically inhabits. f)'Cnostochyus streamside.) Additionally, there are no l'\.."COrded occummces of this species theCNDDB Although there are OliO recordl.!d o«:ummce of alkali llulk~vetct ~stragalus tene!' var tenef' lalkaIj milk-vetch 1 List IB.21 Iplayas. valley and foothill grassland (adobel in the CNDDB that encompasses the study arc~ these GlT! SI.I Mar-Jun 0-60 Low OCCurrences are possibJ)' extirpatA;d, Also, the habitat within thd i. 2, 3, 4 clay), vernal pools/alkalIne study area included in the mappjng ofthes!! occurrences is mostly urban and/or rudcraJ, Although grassland habitat is prescnt at the location proposed fl the additional facilities at the Regional Plant, this area is fairly ~triplex depf'cssc/ Ibrittlcscale I List IB.21 IChenopod scrub. mcadows and seeps, I I Idisturbed ..,d the vegetation is limited 10 predominanlcly non- G2Q Sl.l playas. valley and foothill grassland. vernal May~Oc[ 1-320 No native grasses and herbs. Additionally, this species was not pools/alkaline, clay observed during the 2006 ficld survcy. There arc no recorded occummces ofthjs species in the CNDDB within a five mile: radius of the Regional Planl. Although grassland habitat is prescnt in the vicinity of the pipeline lateral off the southern ,--nd of thc backbone aiig on Hillview Avenue and at the ioca1:1on proPOSt,,'!l for the IChcnopod scrub. meado,,~ and ""'ps, I additional facilities at the R.:giooaJ Plant, San Joaquin spcarscaJ J.!triplex joaquiniana ISan Joaquin spearscale 1 UstlB.21 G2 S2.l playas. and valley and foothill Apr-Oct l·g35 N. is presumed extirpated in Santa Clam Count51. AdditjonaHy, thr.!1 1,2 grassland habitat in th.: study areaeithcr appli!ars to be frequent! disturbed (e,g., mowed, foot traffic) or is known to be (e.g., weed~\\lhacked. grazed), and the vcg~tation is limited to predominantcly non-native grasses and herbs. No alkalinli! Although grassland habitat is prr;:sent in the vicinity of the I pipeline lateral off the southern end of the backbonli! alignm>!lU I I on HilIvlew Avenue and atth~ location proposed forme Calochortus umbel/crus IOakland star·tulip I List4.2 I G3 S3.2 Mar~May 100-700 No additional facilities at the Regional Plant. this dther appears 10: • frequently disturbed (e.g" mowed. foot traffic) Of is known to b (e.g., weed~whacked. grazed), and the vegetation is limited to preciominanrely non-native grasses and herbs. No s.:rpcntinite soils/substrates are prus~nt at these locations eith.:;r, 'ompanula exigua Chaparral (rocky, .snally o:rpentinite) No The study areadOt."S not support habitats this species typical I) 2,5 inhabits. -~~ -----~~-~~ ~ ~~ ----- Sensitivin::/Re:uJatoD: Statu§l .'leiPAtine Nam. Common Name CDFG Sen.itivity Rank General Habitat Blooming ~ Potentia) for Discussion of PQtential ~ Regulatory Status CNDDB Period (meters) Occurrenc,? ;;.&5 FESA CESA Global State .. - Although there are multiple extant occurrences of Congdon's tarplant recorded in the CNDDB within five miles of the study area4 and grassland habitar is present in the vicinity of the pipeline :lateral offthc southern t!'nd of the backbone alignment on Hillview A\'cnue and at the location propoSi!d fur the Centromadia patryi ssp. congdonii Congdon's tarplant List IB.2 G4T3 53.2 Valley and foothill grns.land (alkaline) May-Oct 1·230 No additional facilities at the R£:gional Plant, this hab.itat either 1,2,3,4 (Nov) appears to be mquemiy disturbed {c.g .• mowed, foot traffic) or is known to be (e.g., wccd-v.'hacked, grazed), and the-vegetation is iimitl."d to predominantely non-nativl! gmsS\:s and herbs Additionally> no alkaline soHs/substra.tcs are prescnt at these locations and this species v,:as not observed during CAlA's reconnaissance-IeIWel surveys. ----- ChorizelntM cuspidala vat. Coastal bluff scrub, coastal dunes, coastal The study area docs not support habitats this species typically San Francisco Bay spineflower List IB.2 021'2 S2.2 Apl'Jul (Aug) 3·215 No inhabits. AdditlonaHy, this species is not known from Santa I cuspldala prairie> coastal scrub/sandy Clara Count1. ..- Chaparral (maritime), Cismontane The study area does not support habitats this speck"S typically Chorizanthe robusta Vat. rabusla robust splneflower ListlB.1 FE G2T1 SU woodland (openings), Coastal dunes, Apr·Sep 3·300 No inhabits, Additionally, this species is pn:sulned extirpated from 2 Coasllll scrublsandy or gravelly Santa CI"" CountY .. -1-... -.. -.. -~. .- Although grassland habitat is pres\!l1t in the vicinity of the pipeline lateral off the southern ald of the backbone alignmenl on Hillview Avenue and at the location proposed for the additional facilities at the Regional Plant. fountain thistle is Chaparral (openings), cismontane known frorn only five occurrence in the vicinity of CrystaJ irSIum fOMnale vat.jontinate fountain thistle ListlB.I FE CE G2Tl SI.I woodland, valley and fuothill Jun-Oct 90~175 No Springs Reservoi". Additionally, the grassland habilal in the 1.2 grassland/serpentinite seeps study area either appears to be fiequcntly disturbed (e.g., mowed,. foot traffic) or is known to be (e,g., weed-whacked, grazed), and the vegetation is limited 10 prcdominantely ncn- native grasses and herbs, No scrpentinin: soilslsubstrattls are present at these locations either . ~. . ~. '---.~ . ~ ... ~ . 1-. Lost thistle is presumed extirpated in Santa Clara Count5' This :irsium praeteriens lost thistle List lA GX SX unknown Jun-Jul 0·100 No species is known from onJy two collections from Palo Alto {last 1,2,3,4 in 1901); perhaps represents a. Ci1!o-ual introduction from thl,) Old WorldS .~. Clarkia breweri Brewcrs clarkia List 4.2 03 S3.2 Chaparral. cismontane woodland, coastal Apr-Iun 215·1000 No The study area does not support habitats this species typIcally 5 ~otU:n serpentioite inhabits. -~ .. ~-(Apr)M'y. ._ .. f-----~ .. The study area docs not support habitats this species typically Clarkia concinna ssp. aulomixa Santa Clara red ribbons List 4.3 05'11'2' S3.3 Chapanal, cismontane woodland Jun.{JuIL_ 90~1500 No inhabits, 5 . ~. . ~ . t--.. ~ . _ .. ~ t----. CoJlin'lia mullica/or San Francisco collinsia List IB.2 G2 S2.2 Closed-cone coniferous fon:st, coastal Mar·May 3()·250 No The study an:a does not support habitats this s~cies typical!:; 1,2,3,4 serub1sometimes serpentinite inhabits. ----- , Although the marshlands east ofthc stud)' area support suitable babitat and there are n."'COrd~d occurrences of Point Reyes bied's Cordykrn/hus maritimus ssp. Point Rt::yt::s bird's~beak List IB.2 G4rr2 S2.2 ~rshes and swamps (coastal salt) Jun.()ct ()·lO No beak in the CNDDB within a five mile radius ofthl! study an,::a 1,2,3,4 ~Jurlris this speiccs is presumed extirpated in Santa Clara Count? Additionally, the study an:a does not support habilats this speci typically inhabits, Lower montane coniferous forest, north _ .. ~ f-----. Cypripediumfascicu/atum clustered tady's-sHpper List 4.2 G4 S3.2 dout coniferous forestlusually serpentInite Mar· Aug 100·2435 No The study area d~ not support habitats this spccil:s t) plcaIl) 5 i seeps and streambanks inhabits. -----!Delphinium calijornicum ssp. Chapanal (openings), cismontanc woodlan The study area does not support habitats this species typicall~ 'nterius Hospital Canyon larkspur List IB.2 031'2? 52' (mesic) Apr-Jun 230·1095 No inhabits. 5 SensitivitylRei,YlatQD:: Statusl --------- l.clentil1c Name CDFG Sensitivity Rank Blooming ~ Potential for Source ~ Common Name Regulatory Status General Habitat Discussion of Potential :l'mDB Period ~ CNPS FESA CESA Global State Potential habitat occurs along portions of Barron Creek and Bwadleafed upland forest, dosed-conc Matadero Creek that IiI.': in the study atl!a, Additionally. there is Dirru occldehtalis .. vestem leatheTWood List IB.2 G2G3 5253 coniferous forest, chaparral, cismontanl.': Jan-Mar (Ap') 50-395 Low recorded occurrence ofwesrem Jcathcrwood in the CNDDS 1,2,3,4 woodland. North Coast conifetOLm forust. approximately one mile nonhw~st of the pipdjnc aiignmeiir I riparian fore1., riparian woodland/mesic However, this species was not observed during CAJA's reconnaissanccMlevcl survey, AlthQugh grassJand habitat lS pn."SCnt tn the vicinity of the pipeline lateral off the southr;::m cnd of the batkbool.': alignment on Hillview Avenue, this area appears to be frequcntly disturbe Mogonum luteolum va:, canirrum Tiburon buckwheat List 3.2 05T3Q 53.2 Chaparral. coastal prairie. vailey and Jun-Sl,.':p 10-500 No (e.g,. mowed, foot traffic) and the vegetation is limited to 1 foothiU grassland/serpentinite pre<iominantcly non-native.: grasses and h.erbs. No seIpl!nlinitc soils/substrates is presefll at this location either. Additionally, there an~ no occurrences of Tiburon buckwh~at in the CNDDB within a five mile radius ofthl! pip.:line a1ignme~l Urriogonum nudum var. derurf'enJ' Chaparral. cismontane WOOdland, lower The !i."'tudy area does not support habitats this species typically Ben Lemond buckwheat Lb11Rl 051'2 52.1 montane coniferous fOrest {maritime Jun-Oct 50-800 No 1,2 ponderosa pine sandhdls)/sandy inhabits. ---~~~~------ Cisrnontane woodland {often serpentinite, The study area does not support habitats this speci<..-s typically jE,riophyllum loti/ohum San Mateo wooHy sunflower List IB.I FE CE 01 51.1 May-Jun 45-150 No inhabits, San Mak."O wool! y sunt10wcr is known from two extar 1, Oti roadcuts) occurrences in San Mateo Count}~. I£ryngium aristulatum var. hooveri Hoover's button--ceiery List IB.I 051'2 S2.1 Vemalpools Jul 0-45 No The study area docs not support habitats this sp~cil:s typically 1,2,3,4 inhabits, Although grassland habitat is present in the viciniLy ofth~ pipeline lateral off the southl:rn end of the backbone alignmt!nt on Hillview Avenue, Hiltsbrougb chocolatcd lily is fl.':striclcd to Cismontane woodland. valIey and foothill the Hillsborough arei, Additionally, the grassland habitat is firitillaria bijlora var, ineziana Hillsborough cbooolau lily List IB.l OIQTIQ SI.! grassland/serpentinite Mar~Apr 150-150 No frequently disturbed (Io:,g., mowed. foot traffic) and dl\:" I vegetation is limited to prodominantel y non-native grasses and herbs, No serpentinite soiis/substraa--s an; present at tllis locatio either and the :'1Udy area is below the elevation range occupied by Hillsborough chocolate lily. Although th\! grassland habitat in the vicinity oflhl; pipeline lateral oft'the southern end oftht:: backbone alignment on Hillview Avenue and at the location proposed for thlo: additional Cismontane wood1. coastal prairie, facilities at the Rl.o.gional Plant appear CO be or arc fn:qucndy disturbed (e.g., mowed, \wl.':d~whacl;.ed, foot trnffic) and the ritilJaria Ii/iacea fragrant fritillary ListlR2 02 52.2 ooas:tal scrub, vaHey and foothiU Feb-Apr 3-410 Low vegetation is limited to predominantely non·native grasses and 1,1,3 .grasshmd/oftcn serpentinite herbs, marginal habitat for fragrant fitillary is present at thcSl:: location. The nearest recorded occurrence of this $p\.!dcs in the CNDDB is approxiJl\atdy three mii!:s west of the pipeline alignment. -~- SensitivityfRegulatory Statu~ SdentificNJmJJt ICQmmOD Name Regulatory Status CDFG Sensitivity Rank CND B CNPS FESA CESA Global 1 State 'esperolinon conges1t1m IMarin wcstern flax I List IB.ll IT I CT I G2 52.1 'vim slrobilirJQ jLoma Prieta hoim l.iS! IB.2 G2 S2.1 fsthenia c;onjugens Cant ... Costa goldfields LiS! lB. I I FE GI Sl.l ,thyrus jepSOnii var, jepsonil I Delta lui. pea I liS! IB.21 051'2 52.2 'ssingia arachnQidea I Cr~./stal Springs Icssingia I List IB.21 Gl S1.2 General Habitat I Blooming I ~ I Potentjal for hd2lI !.!!Wwl ~ !Chaparral, valley and foothill grassiand/5('Irpentinite ICismon!llnc woodland, piay.lS (alkaline), valley and foothill grassland, vemal pools/mesic I~:~~~~)and swamps (freshwater and Cismonta.ne woodland. coastal scrub. Vallei land fOothill grassland/serpentinite, often roadsides Apr~Jul Mar-Jun May·)ul (Sep) Apr·Jon lul-Oct 5·310 No 30~860 Low 0-470 No 0-4 No 1·880 No 60·200 No Discussion Qf Potential I~ land San Mateo counties'. Additionallv. the J<IllSsland habl"" 1,1 1,2 I, the marshlands cast of the study area ~uppOrt suitable habitat fur this spc:cics, the study area docs not support this habitat, Additionally, then: an:: no known populations in Santa CI .... CoWltY. The study area does not support habitats this species typically 1,2 inhabits, Although grassland habitat is prescnt in the vicinity oftffi; pipeline lateral off the southern end ofthc backbone alignment on Hillview Avenue, Crystal Springs kssingia is: kno, .. "n only Ifrom seven occurrences ncar Cl)'stal Springs Reservoir, San Mateo --~;;iti-;ib:!~C:2.!!latoa Statusl PM •••• ' 'M CDFG Sensitivity Rank Blooming Elevation 1~,.;··tlRc Name Common N.me Regulatory Status General Habitat 0,., •• ,"",,' Discussion of PotentiaJ Sourci Period ~ CNDDB CNPS FESA CESA Global Stat. ----- Although grassland habitat is present in the vieinityofth~ pipeline lateral off the southern end ofth.: backbone alignment on Hillview A venue and at the location proposed for the Broadleafed upland forest. coastal scrub, additional tacihties at the Regional Plant. these areas either ~ssingia holaleuca woolly-headed lessingia List 3 -03'/ 53 lower montane coniferous forest, valley an Jun-Ocr 15-305 Low appear to be frequently disturbed (e,g., mowed, foot traffic) or 1,2 foothill grassland/clay, serpentinite are know to be (e.g., weed-whacked, grazed) and the vegetation is limIted to predominant.:ly non~natiw grasses and OOth't TIus species was nOt obscnll!d during CAJA's feconnaissane;:~It:vd surveys. -------- Broadleafed upland forest. closed~cone Although the marshlands cast of the study area support suitabl~ coniferous rorest, coasta1 prairie, coastal habitat for this spcci~s, the study area docs not support this ilium 11'I(]ritimum coOS: lily ListlB,I 02 S2.l scrub, marshes and swamps (freshwater), May-Aug 5-335 No habitat. Additionally, there are no known populations in Santa I North Coast coniferous forest/sometimes Clara County roadside -----------------f..---- I The study area does not support habitats this speck~ typically lupinus eximius San Mateo tree lupine List 3.2 02Q 52.2 Chapamd, coastal scrub Apr-Jul 90-550 No inhabits. Additionally. San Mateo tree lupint! is known only I from San Mateo County and, possibly, Sonoma Cound', -------- I Although there are multiple occurrences of arcuate bush mallo\ ... ~aJaco/hamnus arcuotus arcuate bush mallow UstIB.2 G2Q S2.2 Chaparral, cismontane woodland Apr-Scp 15-355 No ~rded in the CNDDB within a five mjle radIus of the pipdin 1,2, > alignment''", the study area does not support habitats this species typically inhabits, ------ Although riparian habitat is present along portions of the crooks ~aJacothamnus davidsonii Chaparral. cismontane woodland, coastal (Barron Creek and Matadcro Cr..:ck) that lie in the study area an Davidson's bush mallow List lB.2 Gl S!.l Iun-Jan 185-855 No there is a recorded occurrene;: oftlus species in the CNDDB 1,2,3 scrub, rparian woodland within five miles oflhe pipeline aJignmcdt thu study area is below the elevation range occupied by Davidon's bursh mallow, --------\--------..... jMalacolhamnus haJiii Hall's bush mallow List 1B,2 GIQ 51.2 Chaparral, coastal scrub May-Sop 1[1-760 No The study area docs not support habjtats this species typcially 1,2 inhabits, Although grassland habitat is present in the vicinity of the pipeline lateral off the southern end of the backbone alignment on Hillview A venUe and at the location propOsed for ttw Broadlcafed upland forest. chapalTal, additional facilities at the R¢gional PJant, these areas either 'Micropus amphibolus Mt. Diablo cottonweed List 3.2 03 53.21 cismontane woodland. valley and foothill Mar-May 45-&25 Low appcarto be frequently disturbed (e,g., mowed. fuottraffic) Of 1,2 grassland/rocky are know to be (e.g., weed-whacked, grazt."d) and v1".'gctation is limited to predominanteiy non-native grasses and herbs. Additionally. there are no recorded occurrences of this species iJ the CNDDS within a five mile radius of the study are! ~onardeJJa antonina ssp, anfonina The study area does not support habitats this species t},ptcaHy San Antonio Hills monardclla List> G4T3Q S3? Chapaml, CismonllU1e woodland Jun-Aug 500-1000 No inhabits. Additionally, it is below tk elevation range OIXupit:'d 2 I.. .. _L. by the species, $ensitivi!yfRe&ulatgQ: Sta1!!~1 :cientiflC Name lCoIDmon Name CNPS 'Onardella villosa ssp. globose lrobust mooardella I List1B.21 G51'2 ravarretia mysersii ssp, myer!lii lpincusltiofl navam..'!ia I List IB.II GITI 'ediculan~" dudleyi /Dudley's lousewort I List1B.21 I CR I G2 'efUacJwefa bel/idiflora whitc~rayed pentachacta List IB.ll FE CE GI 'e':lderidia gairdneri ssp, gairdneri IGairdner's yampah I List4.2 I GSTI 'iperio candida lwhite~flowered rein orchid I List 3 I G3G4 State S2.2 Sll S2.2 SLI S3,2 S3.2 Gener'al Habitat ~ Period upland forest (cpooiogs), I I Ichaparral (openings), cismontane . Jun-Jul (Au ) woodland. coastal scrub, valley and foothdl g grassland IVemal pOOls/ofico acidk Chaparral (maritime), cismontanc I Iwoodland, North Coast coniferous forest, valley and foothill grassland Cismontane woodland. valley and foothill grassland (oficn "q>entinite) Broadleafcd upland fores~ ehaparral, coastal prairie, valley and foothill grassland( vernal pools/vernally mesic Broadleafed upland forcs~ Lower montane coniferous forest. North Coast coniferous I forest/sometimes serpentinite May Apr-Jun Mar-May Jun-Oct May-Sop I Discussion of Potential I Source' grassland habitat is present in the vicinity ofthl.! llcral off the sou~m end of the backbone alignment on Hillview Avenue and at the location proposed for the I ladditiOIllll facilities at the Ikgion.1 Plant, these areas either appear to be rrequently disturbed (e.g,. mowed, foot traffic) or 100-91S Low are kno'm to be (e.g., vlced-whackl.'O, graz~d) and wgetation is! 1,2,3 Hmited to predominantely non~na1ive gnlSSt:s and herbs. & -"-' ~ ••• H... tudy area 15 sJightly 1x;low thl.! elevation rangl ;::cies. There n~st reoord0d occurrrencc of the CNDDB to the pipclin~ alignment is southwest The study area d(X;s not support habitats this s~cies typicaU y 20-330 No linhabits. Pincushion navarTl.'tia is known from fcv,{cr than 20 occurrences in Amador. Calaccra, Mcr~"d, Placer, and 1,2 Sacramento oountic~. habitat is pre:St:nt in the vicinity of the the southen on Hillview Avtmue and at the additional facilities at the: Regional Plant.. Dudley's IOU$cwort is Iknown only from Monterey, San Luis Obisp,,-and San Marco 60-900 No countiess. Additionally, thiS sp!.."CJes is known from fewer than 14 1,2 occurrences within these counties. Tht grassland habitat in the be frequently disturbed (e.g., m(M'cd. foot ) be (e.g., w\lt.ld-whacked, grazed), and limited to predominantely non-native grasses and 35-620 No 0-365 No 30-1310 I No SensitiYit:i/Re~ulatg!J: StAtui ,;n, iCommoo Na, CDt'G Sensitivity Rank ~ Elevation Potential for ~ Regulatory Sta tus General Habitat DistussioD of Potential NOD!! (meters) Occurrgll,i CNPS FESA CESA Global State IPlagiobolhrys cNorisianus var. Chaparr.d, coastal prairie, coastal The study area docs not support habitats this spt1cics typicallY jchorisianus COOMs' popcorn~flower List IB.2 G311Q SU scrub/mesic Mar·Jun 15·160 No inhabits, Additionally, Choris' popcorn~flower is known from I i only Santa Cruz. San Francisco, and San Mateo CQunti0S ----- Although the marshland habitat east of the study area supports Plagjohcthrys g/ab.r Meadows and seeps (alkaline), marshes ane suitable habitat for this 5,,*,,'1:il.")s, the study area docs not support hairll."SS popcorn-flower List lA GH 5H Mar·May 15·180 No habitats hairless popcom~tlowcrtypica11y inhabits. Additionall~, 1,2 swamps (coastal salt) this spccies is p!\!sumed extinct in Alameda, Mann, San Benito, and Santa Cl .... countid. --------------'----. Although thc marshlands east ofthc study arl:a support suitable habitat and there ar¢ n,;cordcd. oc(""Um::nc¢s of sitmdl:f-Ica\'()d lPolamogelon fili/ormis slender-leaved pondweed List 2.2 05 SIS2 Marshes and swamps (assorted shallow May~Jul lO0-2,150 No pondwecd in the CNDDB within a mde of the study .rei, the 1,2, l. 4 freshwater) study area is below the devation range OC\:upied by this $pcci~s. Additionally, this species is presum~d <xtirpawd in Santa Clara County5 !----"" Although grassland habitat IS present in the vicinity of~ i pipeline lateral ottthe southern end of me backbonl: aJignmcnt Cismontane woodland. north coast on HillView A venue and at the location propos!!d for the !Rammculus lubbli Lobb's aquatic buttercup Lisc4.2 04 53.2 conIferous forest, valley and foothill Feb·May 15,410 No additional facilities al the Regional Plant. ~ areas either 5 gmssJand. vernal pools/mesic appear to be freqml'ntly disturbed (e.g., mowed, foot traffic) or are kno.,.\, to be (e.g., weed-whacked, grazed) and vegetation is limited to predomjnantely non-native grasses and herbs Additionally, mesic conditions an; not present ",,- Although grnssland habitat is present in the vicinity of the pipeline lateral off the southern end of the backbone alignment on Hillview Avenu<. San francisco campion is known from Coastal blufl'serub, chaparnJ, coastal Mar-lun fewer than 20 OCCUIronCl:S in Santa Cruz, San Francisco, San $ilene venu;ul1da ssp. YereCftnda San }o'rancisco campion Li,t IB.2 05T2 82.2 prairie. coastal scrub, vaIley and foothill (Aug) 30-645 No Ma!eo~ and Sutter countie~ Additionally. thl,! grassland habitat I grassland/sandy at this location appears to be frequcntly disturbed (0.,8" mowi!d, foot traffic) and the vc:gctation is limited to predominantcly non native grasses and hem. No sandy sods/substrates an: present at this location either. f", ,,,-,, 1- Although grassland habitat is present at the location proposed ~ the additional facilities at !.he ~gional Plant, this area is fairly Streptanthus albidus ssp. most beautifuJ jewel~flo\ver List IB2 02T2 S22 Chaparral. cismontane woodland, valley (Mar) Apr, 94·I,OOn No disturbed and tht: vegetation is hmi~d to predominantdy non~ 2 peramoenus and foothill grassland/serpentinite Sep (<k,) native grasses and herbs. Additionally, there an: no recorded occurrences of this species within a five mile radius ofthc study area4 ,,,-f "-,, Although the marshlands cast of the study area support suitable iuaeda califomica California seabJite List lB.! FE 01 Sl.I Marshes and swamps (coastal salt) lul·<kt 0-15 No habitat for Ca1ifomia seablite, the study area does not. Califom' L2 seablite was fonnerly known from San Francisco Bay Arl:a; however, it has been extirpated by deVt!lopmen1:. ------,,------- Trijolium depauperawm Vat. ,jSal,ne clover Marshes and swamps. valley and foothill Although the marshland habitat east of thl: study area supports rydrophilum Li>t IB2 0511'1 S2.2? grassland (mesic, alkaline), vernal pools Apr~Jun 0·300 No s.uitable habitat for this spt..oocics. tfu: study area does not support I habitats saline clover typically inhabits. SensitivitJ:/Re~latoo: Status! ICommon Name CDFG Sensitivity RJtnk General Habitat Blooming Elevatinn Potential for I Source~ ~cientific N(J,m~ Regulatory Status Discussioll of Potential CNDDB PeFiod l!!!.m!:n Occurrenci CNPS I FESAICESA Global State f--~~~~ I r Although the-re is grassland habitat In the vicinity of the pipelirl lateral off the southern end of the backbonl! alignrne-nt on Hiilview Ave-nue and at the location proposed for the additional facilities at the Regional Plant and there are recorded occurrences of this species in the CNOOB ,capcr-tiuitcd 1ropidocarpum capparldeum lcapt.'f~fruitcd tropidocarpum I List IB.!I 01 SI.1 IValleyand roQthili grassland (alkaline hillsj Mar-Apr 1 1-455 No Itropidocarpum is pre-sumed extirpated in Alame-da, Contra I 1,2,3,4 anta Clara, and fe/MIme N:' SensitivityJRe:ulato!l: Statusl EleVAtion Potential fOT CDFG SenSitivity Rank General Habitat Blooming Discussion of Potential Source:>' Cpmmop Name Regulatory Status CNDD8 Period (meters) Occurrencel __ CNPS _I FESA~ CESA.1 _Global _.L~._ --------------~ ---- I SensitivitylRcgulatory Status Codes: FD = FodC'rn11y dc1isted {monitored for 5 years} Gt/S! .;: ExucmeIy endang.:red: less than 6 viable clement oecurrena,'S (EOs) OR less than 1,000 individuals OR less than 2,000 a.c:tl!s: G2IS2 e;:: Endangered: 6-20 EOs OR 1,OOO~3,OOO individuals OR 2,000-10,000 acres; G3-1S3 = Restricted range, rare: 21-80 EOs OR 3,OOO~IO,OOO indivtduals OR 10,000- 50,000 acres; G41S4 = Apparently sccut\!~ some factors exist to cause some concern such as narrow habitat or continued threats; OJ/55 = Demorumably secure~ contmonly found throughout its historic range~ OnTn = Subspecies receive a T-rank attach~ to the G~rank, Grank reflects the condition of the entire species and T-rank reflects the global situation of just the subspecit:s; m-USH:: All sites historical, the element has not been seen for at least 20 year~ but suitable habitat exi$1s; GX!SX:: AU site cxtirpated, this element is extinct in the wild (0.1 """ very thrl!atcncd, 0"2:::: threatened, 0.3 = no current throats known) List California.. but more conunon elsewhere~ LIst 3 = Plants about which more information is needed: List 4 = Limited dIstribution (.1 = Seriously endang\.':rud in California I: of oceurrer.C¢S threatenedlhigh degrece ofimmediacy ofthreatJ~ 2 = Fairly endangered. in California [2(J~8o<'/ooccurrences threatened]; .3 Not very endangered in California l<20"/n of occummces threatcm .. -d or no current threats known!) 1 Potential for Occurrene<:: "no" = species listed as having "'no" potentia) for oecurrence in the project area are those speeies for which:(l) there is no suitilile habitat present in the project area (i.e., habitats in the project area are unsuitable for the species requirements le.g., foraging. breeding, cover, substrate. elevation, hydrology. plant community. disturbance regime> etc,}); and/or (2) the project arua has been surveyed during the proper time of year with negative results for the species; "low" ~ specics listed as having a "Iow" potential for occurrence in the projL"Ct area are those spl.!'Cil!s for which: (I) then; arc no known records of OC{;UJ1'ence in the vicinity of the project area; andlor (2) there IS marginal or vcry limited suitable habitat present in the project area: "medium!! ;;; spccros listed as having a '''medium''' potential for occurrence in the project area are those species for wbich: (1) there arc known records of occurrence in the vicinity of the project area; andlor (2) there is marginal suitable habitat present in the project area; "high" = species listed as having a "high" potential for occurrence in the project area are those species fur which: (1) there are known records of occurrence in the vicinity oftm:: project area (there are many records andlor records in close pro~imity); andlor (2) there is suitable habitat present in the project ma; "present" ;;; species lisb:d as .... present" in the project ma are those species for which: (1) the species was/has been observed in thc project area. l Sour",,: 1 ~ Search of lb. California Native Plant Society'S On-line Inventory (CNPS 2007) of the Palo Alto (4288) USGS 7.5-Minute Quad and the eight surrounding qllllds (Cupertino 1421DJ, L. HOIld.!429Dj, Mountain View [428A], Mindego Hi1l1428CL Ncwarl< 1447DI, Redwood Pomt 1447q San M3lcO 1448DJ, and Woodside [429A]); 2 ~ Search of the California Native Plant Soeietys On-line Inventory (CNPS 2007) of the MOWltaln View (428A) USGS 75-Minute Quad and the eight surrounding quad, (Cupertino [428D), Miipi1lls (4278), Mind.go tliIl1428C], Ncwarl< 144 7DI, Nile" [446C[. Palo Alto [428BJ. Redwood Point [447C), and San Jose West [427C]; 3 "" Seateh of the California Natura! Diversity Database (Biogeographic Data Branch, California DepamtlentofFish and Game 2007) QCcum:nces within a five mite radiupqmline alignment; 4::::: Search of the California Natural Diversity Database (Biogeographic Data Branch, California Department of Fish and Game 2007) occurrences within a five mile radius of the location proposed for the additional facilities at the Regional Plant; ,5 = Review of the Palo Alto Comprehensive Plan. 4 California Department of Fish and Game (CDFG). 2007. California Natural Diversity Databasu (CNODB) Rarefine fCD _ROM]. Wildlife Habitat Data Analysis Branch, California Dl!partmt:nt of Fish and Game. Sacramento: California. ~ California Native Plant Society. 2007, Inventory of Rare and Endangered Plants (online r;:dition, v7-07a). California Native Plant Society, Sacramento. AcceSSl.--ci on January 19, 2007 from hnp:IJenps.org/invenrDry Table 2 Special-Status AnimaJs Evaluated for Potential to Occur within the Study Area. I Common Name General Habitat Pg!ential {or Dis.::ussion of Pot~ntial lentifu: Name ~ CESA Coastal mountains near San Francisco Bay. in the fog-belt of steep north facing slopes thar receive little direct sunlight :Found near proliftc growths of the larval food plant. stonecrop (,'.;eJ;ml sparhllii/o/illm ). which i. Blow growning sueculant_ Stonecrop is \ \Th. study ar .. does not,upPor! habitat this species typically nllcphrys mossii bayensis ISan Bruno elfin butterlly I FE I G30m I 81 I associated with rocky outcrops thaloccur al 900 to 1.075 foot No inhabits. Additionally, It is bclow the elevation range I 3,4 elevation. Adult food plants not fully determined; Montara occupied by the species Mountain colonies are suspected to use Montara Mountain manzanita (Arctostaphylos monlaraensis ) and huckleberry (Vaccil1ltml ovatum) Shallow, serpentine-derivt:d soils in natlve grasslands supporting Although there is a recorded occurrence of Bay checkerspot bay checken;pot butterlly I IT G5Tl 81 parval host plants, dwarf pllllltain (Plantago ",,,-10 ) or purple No butterliy in the CN~DB approximaedy four mil .. west of the I U, 4, 5 owl's clover (Castilleja den:.iflora or CasliJlt'ja cxserla). pIpelIne alIgnment , the study area does not support babItat this species typically inhabits. Vernal pOOl tadpole FE G2G3 S2S3 Inhabits vernal pools containing dear to highly turbid water, No The study area does not support habitats this species typically shrimp ranging in si~ in the Central Valley and San Francisco Bay Area. inhabits_ "i"tt':", "W_dlihl' ,.;;,".1 i"',h"$i!I!, Ranges from Mexico to at ll!8St Alaska in marine waters, and forages in estuaries and bays ranging from San Francisco Bay to esc sc' G3 5182 IBnbsh Columbia Currently believed to spa"" regualarlyin the I No poe study area does not supprt habitats this species typically green sturgeon Fr' Rogue River, Klamath Rjver Basln. and the Sacramento River inhabits_ Spawning IS known to occur infrequently in the Umpqua river and is suspected to occur, to an unmo"," extent, in the South Fork of the Trini!)' River and the Eel River. Brackish shallow lagoons and lower stream reaches where the Prefer a sand substrate tidewater goby CSC FE OJ S2S3 I~"P~'~" .v, u,~~ .... uu, ~~ ,uund on rocky, mud. and silt No IThe study area does not support habitats this species typically substrates as well. Found in ..... -aters with salinity levels from 0 to 42 ppt. temperature levels from 8: to 25 degrees Celsius. and water depths from 25 to 200 centimeters_ Bay upstream through the Delta in Contra Costa. The study area is outside of the delta smelt's distribution (delta tronspacijlcus Idelt.smelt IT CT Gl 81 1~1<Ullento, San Joaquin, Solano, and Yolo counties. Delta smelt No smelt are endemic to the upper San Francisco Estuary) and it __ I~. --found at salinities> 10 ppt. :MOst often at salinitles < 2 does not support habilat this s~ies typically inhabits, populations from Punta Gorda in northem and including the San Lorenro River in central. California, as well as populations in tributaries to San Francisco Bay, excluding the Sacramento-San Joaquin River system. as well The study area does nol support habitat this species typically I coho salmon -Central las four artificial propagation programs: the Don Clausen fish inhabits; channalization and other flood control projects have IOncorhynchus kisutch C8C FE CE' G4 52? Hatchery Captive Broodstock Program, Scott CreeklKing Fisher No drastically reduced flsh habitat in the creeks (Le., Adobe 3,4 California coa;1 ESU Flats Conservation Program, Scott Creek Captive Broodstock Creek, Ba.rroo. Creek, and Matadero Creek) within the study Program, and the Noyo River Fish Station Egg-Take Program. area' Spawn in cool. clt:N streams featuring: suitabie gravel size, depth, and current velocity. Streamside vegetation and cover area essential fur steelhead fry survivaL Name IContmonName mykiss I.teelhead -Central Valley I IT I GlT2Q I S2 mykiss IT I G5T2Q I 82 l!oncorhynchus Isllawytscha ST G5TlQ SI Ioncorhynchus lShawytscha FE SE G5TIQ SI IT G2G3 S2S3 IIRl'mn m~l"nrn drayronii red-legged frog CSC IT G4T2T3 S2S3 General Hllgital populations below natural and manmade in the Sacramento and San Joaquin Rivers and excluding steelhead from San Francisco and San It'aDlO Days and their tributaries, as weJl as two artiCJal propagation I ---------.• L -"-leman NFH and Feather River Hatchery Spa'M1 in cooL. clear streams featuring suitable nd current velocity, Streamside vegetation and fur steelhead fry sUIVlvaL and manmade I Valley \.-reeK• ana an unnamea mDutary to Contel13 :Slough (commonly referred to as Red Top Creek), excluding the open oak woodlands; necessary hahitat _ :Jude ground squirrel or gopher burro'WS for I underground retreats, and breeding ponds such as seasonal vernal lX'oIs or slow-moving streams that do nOl support fish or frog populations. and foothills in or near permanent sources of deep water shrubby or emergent riparian vegetation (may disperse and after periods of rain). Requires 11-20 weeks of water for larval development. Potential fgr Or.c:urrence1 No Low No No Present Illi< "'''Q''Ml'<> tential I~~~.~;~:rea is outside of the Centra) Valley sfeelheaus of tidal gates at the mouth ofMatadero and Adobe rally preclude the passage of steelhead, the gates lare ~ically closed d~rin~ the upstream migration periods AAA ... __ ~ll •• channaltwlon and other flood control projects reduced fish habitat in the creeks within the area is outside of the Central Valley steelhead's upstream of culvert crossing and dO'MlStream of East Adobe Creek downstream of East Bay,hore BatI'On Creek upstream and downstream of Mrandu Foothill Expressway. Additionally, there are recorded occurrences of (,RLF in the C'NDDB wrtllln radius of the study area, including one occurrence the pipeline backbone along HiUview at Matadero Creek' l,4 I 3,4,5 3, 3,4 2,3,4, 1,2,3,4, Name marmorafa pond turtle Isharp-shinned hawk cunicu/aria owl iBrach,Yramphu$ marmomlUs murrelet CSC CSC (nesting) esc (burowing sites) G3G4 S3 G5 S3 G4 S2 IT CE (nesting) (nesting) G3G4 Sl Genera1 Habitat permanent or nearly permanenl bodies of water and areas for basking such as panially submerged rocks or floating vegetatIon mats or open mud banks. open woodland, coniferous, mixed, or deciduous. coniferous in more northern mountrunous portion of ery habitat is boreal forest YOWl£. dl.'.:nse, mixed Or lconiferous woodlands are preferred for nesting. Migrates through along ridges, lakeshores, and coastlines. grasslands,. especially prairie, plains, and savanna, lIn open areas such as vacant lots near human habitation or airports, and roosting in burrow dug by mamma!, or by owl (rarely). near-shore; nests inland along coast from Eureka to Oregon or and from Half Moon Say to Santa Cruz. Generally nests IOld-growth forests, characterized by large trees, multiple canopy ~rs. and moderate to high canopy closure. In California, nests tvoica1ly found in coastal redwood and Doug!as~fir forest. are located close enough to the marine environment for the to fly to and from nest sites Potential for OccuTrencel Present No Medium N. Discussion of Potential habitat for _tern pond trutle (WPT) area within Matadero Creek upstream :ui vert crossing and downstream of East Bayshore IRoad, Adobe Creek downstream of East Bayshore Road, and ~ upstream and do\HllStream of Miranda Avenue Expressway. Addit recorded occurrences of WPT in Bayshore Parkway, the study area does not support !potential foraging or nesting habitat for this species. Burrows during CAJA's reconnaissance-level survey in at the Regional Plant in 2006 and in the east of the San Francisco Bay Trai) and East way in 2007; however. no evid¢noo of BUOW No burro\NS or burrow donors (i,e" fossorial were observed in the grassland habitat in the the pipeline larera! off the southern end of the alignment on Hillview Avenue, There are multiple occurrences of BUOW in the CNDDB within a five radius of the study area?, SourceJ 2.5 1,2 Cc>mmonName ~-~r= I ~tDB Gl.bal~ State nivosus I western snowy plover esc Fr G4D 82 (nesting) esc G5 S3 (nesting) petechia brewsteri Iyeliow warbler CSC GST3? 82 (nesting) lrichas sinuosa common esc GS12 S2 General Habitat roast population breeds primarily on coastal beaches from Washington to southern Baja California" Mexico. Breeds 'above the high ridelme on coastal beaches, sand spits, !dune-baoked beaches, sparsely~v.getated dunes, beach", at creek and river mouths, and salt pans at lagoons and estuaries. In winter. I !lIlIIIY .fthe beaches used for nesting as well as on vdlere they do not nest,. in man-made salt ponds, and on flats. mellllows, grasslands, and cultivated fields. Perches on l"'vWW V' on stumps or posts. Nests on the ground, conunonJy near low shrubs, in tall weeds or reeds, sometLmes in bog; or on .~-_&'1~ ... ,",._1.., above water, or on knoll of dry ground. or on ground near water, or on dry marsh vegetation. in lowland and riparian woodlands dominated by I ICOttonwoods (populus sp.), alders (Alnus sp.), or willows (Salix sp.), and other small trees and schrubs typical of low. open-canopy woodland dense growth ofvegetarion associated with moist lenvironments, Inhibits freshwater marshes, coastal swales, SWllrllTlV riparian thickets, brackish marshes, salt marshes, and disturb«! weed fields and grasslands that border soggy Psmmtill for Discussion of Potential I SJwru' ~l Although snO'W)' plover is a regular breeder in Santa Clara County~ it is a very rare or casual species throughout the No y~e. The study area does not support habitat this species I 1,2,3 typically inhabits; however, there are multiple recorded occcurrencesofsnowy plover in the CNDDB Within a five mile radius of the study area7• of northern hamer in Santa Clara COWlty is fairly the fall, winter, and spring. and common in the . Additionally, this species is a regular breeder in the county. Although the study area does not support potenita! N. foraging or nesting habitat, the marshland areas east of the 1,2 study area provide potential habitat There are nlultlple rel.'Orded occurrences of northern harrier in the (NDDS within ,.. 'f: mile radius of the study arei. Additionally, this species observed during CAJA's reconn81ssance-ievel field survey 2007 foraging in the adjacenT marshlands. is a neotropical migrant and occurrence of this .,.y ......... " ... in Santa Clara County is very rare or casual in the fall land winter, Wlcommon in the spring and summer IU Although No the study area does not suPPOrt potential nesting habitat for Medium 2,5 Name Name ~ black rail FP CT om Sl mclodia pusilhda IAla.meda song sparrow CSC GST2? S2? langtrostris obsoletus clapper rail FP FE CE G5Tl 51 g..'i'temula altliIJanlm browni least tem FP G4T2T3 S2S3 General Habitat of salt marshes bordering south arm of the San Francisco ·ted to areas affected by tides where flow is unimpeded although levees hosting upland plants (e.!\C. coyote wris pilularis ], California wild rose [Rosa I. and willows [Salix spp.]) are used occasionally. trion tolerated may be: continuous mats of vegetation (Salicornia spp.) marshes and seaside chaparral, travel in channels created by water flow and runways mammals. bays and lagoons, nesting on the adjacent open sandy dunes, or disturbed sites. Nesting IS hmited to colonies in IIlcisoo Bay. Sacramento River delta. and areas along San Luis ObiSpO County to San Diego County. Potential for Occurrence1 N. Distussion of Potentia) sparrow a regular breeder and common throughout the in Santa Clara COtUltylO Although the study area does upport potential nesting habitat, the marshland areas east study alea provide potential nesting and foraging There are multiple occurrences of song sparrow in the within a five mile radius of the study area' I Occurrence of least tern in the spring and fall is very rare or and in the summer is rarelO Although the study area Source"' 1,2,5 1,2,5 :U,4, "support habit.t this species typically inhabits. tiler. I 1,2,3,4 recorded oc.ccurrences of least tern in the CNDDB IWlthln a five mile radius of the study area? Name bal CSC G5 rav1l.'entris Isalt marsh h"""'" mouse I FP FE CE GIG2 vagrans halicoeres I:;:'_~:::-~' wandering CSC G4T1 laxus IAmerican badger CSC GS I SensirivitylRegulalory Status Codes· FESA: Federal Endangered Species Act of 1972 as amended FE; Federally listed as Endangered; FT ~ Federally listed as Threatened; FD ~ Federally delisted (monitored fur 5 years) CESA: California Endangered Species Act CE ~ State listed as Endangered; CT ~ Stale listed as Threatened; CR ~ Stale listed as Rare CNDDB' Caljfornia Natural Diyer~itv Database S3 and grasslands, often neat rocky outcropS and water. I 1 ..... ~u .. .uJ' roosts in rock crevice or building.l~ often in cave, tree ,.. mine, etc .. Prefers narrow crevices In caves as hibernation only in the I11aI>hesofCorte Madera. Richmond, and South Bay. Critiatliy dependent on dense cover and tat is pickleweed. Seldom foW1d in cordgrass or SIS2 1 .... " .. _. V\,l.\j;.a.;><.> (Scirpus maril.imus) In marshes \\,-ith an upper zone • , , halophytes (salt-tolerant plants), mice use this escape the higher tides, and may even spend a of their lives there, Mice also move into the during the highest winrer tides. SI IInhabits tidal salt marsh plains above cordgrass zone, moist, fower pickteweed~dominated marsh. with abundant invertebrates, tidal a.nd flood escape habitat in the South San Francisco Bay. open areas and may also frequent brushlands with little , Although badger may prefer habitats lh1th more for digging burro'M>, which are used for dens, escape, S4 land predation. the hard-baked earth in the middleofan unpaved stacie. When inactive, occupies underground are elliptical shaped and eight or more inches in ~ ~2 Low No No Low Discussion of Potentia) supports marginal foraging habitat for this ,articularly in the vicinity of Matadero Creek of Hanover Street and downstream of Hwy iO 1, IAdobe Creek downstream of Hwy 101, Batton Creek in the vicinity of Miranda Avenue and Foothili Expressway, and at 1,2 the site proposed for the additional fadlilies at the RegionaJ dditionally, individuals could use the trees in and to the study area for day and night roosts, however, intensity of humarHeia1ed disturbances in the vicinity of study area likely discourages the usc by bats. The study area does not support habitat this species typically inhabits; however, there are multiple recorded occurrences of salt rnarth harvest mouse in the CNDDB within a five mile II 2 J 4 radius of the study area"!, "lhe closest occurrence is withm 600 "" feet east ofHwy 101 and Maladero Creek (i.e., easl of alignment option 2). salt marsh VoIOndering shrew in the CNDDB 1 within a five mile I 1,2 fadi us of th~ study area Although there are multiple recorded occurrences of badger in the CNDDB witrun a five mile radius of the study area1, these occurrences are from the early 1980s and no badger burrows were observed in the sfudy area during C AJA 's recoruwssa level surveys. Additionally, the intensIty of human-related disturbances in the vicinity of the study area likely discourages ~,--of the grassland and MIera! habitAts in the study area GIISI ~ Extremely endangered: less than 6 viable element occurrences (EO,) OR less than 1.000 individuals OR less than 2,000 acres; G21S2 = Endangered: 6-20 EO, OR 1,000-3,000 indlviduals OR 2,000-10,000 acres; G3/SJ = Restricted range, rare: 21·80 EOs OR 3,000-10,000 individuals OR 10,000-50,000 acres; O4/S4 Apparently secure; some factors ex.ist to cause some concern such as narrow habitat or continued threats; G51S5 = Demonstrably secure~ commonly found throughout its historic tange~ OnTn = Subspecies r~eive aT-rank attached to tb~ (i-rank, Grank reflt!:cts the condition of the entire species and T-rank reflects the global situation of'just the subspecies~ GHlSH "'" All sites historical. the element has not been seen for at least 20 year, but suitable habitat exists~ GX!SX "'" AU site extirpated, this element is extinct in the wild (O"i :::: very threatened, 0.2 = threatened" OJ "'" no current threats known) CDFG: Cal ifornia Department ofFish and Game CSC = Species of Special Concern; FP ~ Fully Protected ";:;;;;;;;;' ;!~f;:'>;;}~'i!; "~'iii:::;;; y status' t:;cietdifte Name CQmmonName Reguilltory Status C[)FG Sensitivity Rank ~I rn;;1~ Q!Q!)B !;!~!!eral H!!.!liUIS Potential for Occurrencl Di§cussion of Pgt~ntial ~J _<:;Iobal I State 2 PotentiaJ for Occurrence: "no" "" species listed as having 'no" potential for occurrence in the project area are those species for 'Which:(l) there is no suitable habitat present in the project area (i.e., habitats in the project area are unsuitable for the species requirements [e.g .• foraging. breeding, cover, substrate. elevation. hydrology, plant community, disturbance regime, etc,])~ andfor (2) the project area has been surveyed during th~ proper time of year with negative results for the species; "loW' "" species listed as having a "low" potential for occurrence in the project area are those species for v.hich: (1) there are no kr,.o\W records of occurrence in the vicinity of the project area; and/or (2) there is marginal or very limited suitable habitat present in the project area; 'lmedium" ;:;; specles listed as having a "medium" potential for occurrence in the project area are those species for which: (1) there are knO'WTI records of occurrence in the vicinity of the project area; and/or (2) there is marginal suitable habitat present in the project area; "high" = species listed as having a "high" potential ror occurrence in the project area are those species for whIch: (I) there are known records of occurrence in the vicinity of the project area (there are many records and/or records in close proximity); and/or (2) there is suitable habitat present in the project area; Jlpresent" =: species listed as "present" in the projec1 area are those species for which: (1) the species wasIhas been observed in the project area !l Source: 1 :;:: Search of the California Natural Diversity Database (Biogeographic Data Branch, California Department ofFish and Game 2(07) occurrences within a five mile radius ofpipeJine aJjgnment; 2:;:: Search of the CalifornJa Natural Diversity Database (Biogeographic Data Branch, California Department ofFish and Game 2001) occurrences within a five mile radius of the site proposed for the additional facilities at the Regional Plant; 3 """ Review of the U.s. Fish.and Wildlife Service Sacramento Office's list of FederaJ Endangered and Threatened Species that Occw in or may be Affected by Projects in the Mountain View (428A) USGS 7.5-Minute Quad: 4 = Review of the U$, Fish and Wildlife Service Sacramento Office's list of Federal Endangered and Threatened Sped", that Occur in or may be Affected by Projects in the Palo AltO (428B) USGS 7,5-Minute Quad; 5 ~ Review of the Palo Alto Comprehensive Plan, 4SC refers to the Species of Concern list established by NMFS effective 15 Apr. 2004. The SC designation refers to the north DPS which includes spawningpOpuiations north of the Eel River (inclusive) "The FT designation refers to the southem DPS which includes all spa\l\lOingpopuatlions south of the Eel River. 'CESA listing is limited to coho salmon south of San Francisco Bay , California Department ofFish and Game (CDFG), 2007, California Natural Divmity Database (CNDDB) Raeefine [CD_ROM], Wildlife Habitat Data Analysis Branch, California Department ofFish and Game Sacramento: CalifOrnia. • Salsbery, David, Senior Fisheries Biologist, Santa Clara Valley Water District San Jose, California. September 21, 2007 -phone oonversarion with Aincirea Iensen, 9 Leidy. RA. US. Becker, B.N. Harvey. 2005. Historical distribution and current status of stee!headlrainbow trout (Oncorhynchus mykiss) in streams of the San Francisco Estuary> California Center for Ecosystem Management.and Restoration. Oakland. C'A "Bousman, WG 2005, A Checklist of the Birds of San III Clara County, California. Santa Clara Valley Audubon Society, April 2005, " Evens, I, 199912000, Mystery of the marsh: the Califumia black mil, Tide/ine Vol 19 No.4 1-3, Available from http://www,!\,,,,gov/des!bay/ArchiveslRailiBlack_RlULhtm · CH RISTOPH ER A. JOSEPH & ASSOCIATES Plann MEMORANDITM To: Erin Darling, Environmental Scientist From: Aindrea Jensen, CAJA Senior Biologist Date: November 9, 2007 Subject: Palo Alto Recycled Water Project Additional Facilities -Biological Resources Section of ISIMND As requested Christopher A. Joseph & Associates (CAJA) has completed the biological resources impact analysis for the installation of the additional facilities (pump station and storage tank) proposed at the Palo Alto Regional Water Quality Control Plant (Regional Plant) for the Palo Alto Recycled Water Project (proposed project). This memo is intended to provide RMC Water and Environment with the information necessary to incorporate the site proposed for the additional facilities at the Regional Plant into the Biological Resources section of the Initial Study (IS)lMitigated Negative Declaration (MND) that CAJA prepared and submitted to RMC on October 3, 2007 (revised October 23, 2007). The information is grouped below into major subsections consistent with those in the Biological Resources section of the IS/MND previously completed for the proposed project. Setting Overview The site proposed for the additional facilities at the Regional Plant to be included in the "study area" previously defined in the Setting Overview subsection on page 2 of the Biological Resources section of the ISIMND for the proposed project is behind the existing Maintenance Building & Warehouse and below the intersection of Embarcadero Road and Byxbee Park Entrance Road. This area is less than one-acre in extent and is fairly disturbed. It was landscaped in the 1970s when the Regional Plant was built to visually screen the facility from the traveling public on Embarcadero Road and Byxbee Park Entrance Road.l Since then plant species typically adapted to disturbed environments have colonized the site. In order to manage the vegetation, the site is weed- whacked andlor grazed.2 Existing vegetation consists of non-native grasses and herbs and a mix of native and non- native trees and shrubs. Various land uses surround the site, including (but not limited to) major institution/special facilities (palo Alto Municipal Airport), public parks (Palo Alto Municipal Golf Course), and commerciaL The San Francisco Bay and its associated northern coastal salt marsh and coastal freshwater marsh habitats in the Palo Alto Baylands Natural Preserve (Baylands Preserve) occur to the east of the site directly beyond Byxbee Park Entrance Road. Discussion a) CAJA completed a one-day reconnaissance-level field survey of the site proposed for the installation of the additional facilities at the Regional Plant on September 11,2006. This survey was completed in preparation of the environmental document for the Ultraviolet (UV) Disinfection Facility Project, as the site proposed for the Palo Alto Recycled Water Project at the Regional Plant is the same site that was initially proposed for the UV Disinfection Facility Project. The former project has since been relocated to another site within the Regional Plant? CAJA also completed a windshield survey of the site on September 26, 2007. The purpose of the Personal Communication. Daisy Stark (City of Palo Alto). September II, 2006. Field meeting with Shannon Lucas (CAJA staff). Personal Communication. Daisy Stark (City of Palo Alto). September II, 2006. Field meeting with Shannon Lucas (CAJA staff). Personal Communication. Marilyn Bailey (RAtC Water and Environment, Inc.). November 8, 2007. Phone conversation with Aindrea Jensen (CAJA staff). 179 H Street. Petaluma. CA 94952 Phone 707 283-4040. Fax 707 283-4041. E-mail info@cajaeir.com • Web www.cajaeir.com Los Angeles. Santa Clarita. Agoura Hills. Petaluma. Oakland. Mammoth Lakes 5 6 CHRISTOPHER A. JOSEPH & ASSOCIATES September 2006 survey was to assess the existing conditions and to evaluate potential impacts to biological resources from site development. The September 2007 survey was to verifY that the existing site conditions have not substantially changed from those observed in 2006. Prior to conducting the 2006 field survey, CAJA developed a list of special-status plant and animal species that are known to or have the potential to occur in the vicinity of the site. This list was based on CAJA's reviewed available background information pertaining to the biological resources in the vicinity of the site including (but not limited to) (1) the Department ofFish and Game's (CDFG) Natural Diversity Database (CNDDBt; (2) the U.S. Fish and Wildlife Service's (USFWS) list of federal endangered and threatened species that occur in or may be affected by projects in the Palo Alto (428B) and Mountain View (428A) US. Geological Service (USGS) 7.S-Minute Quadrangles5; and (3) the California Native Plant Society's (CNPS) Electronic Inventorl. Each species was then evaluated during the field survey for their potential for occurrence on the site. For the purposes of this analysis, CAJA updated this species list based on a more recent review (November 8, 2007) of the databases and official lists. Because the majority of the special-status plants and animals documented in the vicinity of the Regional Plant are included in Table I and Table 2 of the Biological Resources section of the ISIMND previously completed for the proposed project, these tables were revised to incorporate (l) species that were not identified in the background review for the pipeline alignment options or the booster pump station locations and (2) reference to the site proposed for the additional facilities at the Regional Plant (refer to attached tables). Although the total number of special-status species evaluated for their potential for occurrence in the study area were increased and the rating of the potential for occurrence for some of the species were changed as a result of including the site at the Regional Plant in the analysis, only one additional special-status species (burrowing owl [Athene cunicularia]) needs to be incorporated into the Biological Resources section of the IS/MND for the proposed project. Also, the text of the introductory paragraphs for the special-status plant and animal discussions need to be revised to reflect the changes in number of species evaluated and their rating for occurrence in the study area. Refer to the following subsections. Special-Status Plants Five additional special-status plant species (brittlescale [Atriplex depressa], robust spineflower [Chorizanthe robusta var. robusta], San Antonio Hills monardella [Monardella anton ina ssp. antonina], white-flowered orchid [Piperia candida], and most beautiful jewel-flower [Streptanthus albidus ssp. peramoenus]) were incorporated into Table 1. Including these species a total of 60 special-status plants have been documented in the vicinity of the study area. The text of the introductory paragraph for the special-status plant discussion in Biological Resources section of the ISIMND should be revised as follows: Based on CAJA 's review of available background information,:£. special-status plants have been documented in the vicinity of the study area (Fable 1). Of these, 47-51 species have "no" potential and eighE nine have "low" potential for occurrence in the study area ... Similar to the habitats within the pipeline alignment options and the booster pump station locations for the proposed project, the habitats within the site proposed for the additional facilities at the Regional Plant are not California Department of Fish and Game. 2006 California Natural Diversity Database (CNDDB) Rarefind [CD-ROM}, Wildlife Habitat Data Analysis Branch, California Department of Fish and Game. Sacramento: California U.S Fish and Wildlife Service. November 15, 2006. Federal Endangered and Threatened Species that Occur in or may be Affected by Project in the Mountain View (428A) and Palo Alto (428B) U.SG.S 712 Minute Quadrangles. Sacramento Fish and Wildlife. Accessed November 15, 2006. Available from http://www.fivs.gov/sacramento/es/ssp_lists California Native Plant Society. November 15, 2006. Inventory of rare and endangered plants of California. California Native Plant Society, Sacramento. Accessed November 15, 2006. Available from http://cnps.web.aplus.netlcgi-binlinvlinventory.cgi 179 H Street. Petaluma. CA 94952 Phone 707283-4040 • Fax 707 283-4041 • E-mail info@cajaeir.com • Web www.cajaeir.com Los Angeles. Santa Clarita. Agoura Hills. Petaluma. Oakland. Mammoth Lakes CHRISTOPHER A. JOSEPH & ASSOCIATES likely to support any of the special-status plants evaluated because ofthe level of disturbance and dominance of non-native vegetation. Special-Status Animals No additional special-status animals were incorporated into Table 2. However, the ratings of the potential for occurrence for some of the species changed as a result of including the site proposed for the additional facilities at the Regional Plant in the study area. The most notable change is burrowing owl (BUOW). BUOW was previously considered to have a "low" potential for occurrence in the study and is now considered to have a "medium" potential. The text of the introductory paragraph for the special-status animal discussion in the Biological Resources section of the ISIMND should be revised as follows: ... Of these species, :JJ have "no" potential, three have "low H potential, and ene two htm have "medium" potential for occurrence in the study area, and two have been identified as "present" ... As discussed above, only those special-status species rated as having a "medium" potential for occurrence (Qurrowing owl [Athene cunicularial and salt marshcommon yellow throat [Geothlypis trichas sinuosa]) and identified as "present" (California red-Ieggedfrog [Rana aurora draytonii] and western pond turtle [Actinemys marmorata]) in the study area, as well as California clapper rail, California black rail, and other migratory birds and raptors are discussed in more detail below ... Also, a discussion of BUOW and measures to avoid impacts to this species should be incorporated in the Biological Resources section ofthe ISIMND for the proposed project. Refer to the discussions provided below. Birds Burrowing Owl Burrowing owl (BUOW) is designated a species of special concern by the CDFG. It is a resident of open habitats (e.g., annual and perennial grasslands and deserts and arid scrublands with bare ground or low-growing vegetation) and requires burrows for protection, cover, and nesting. BUOWs typically use burrows made by fossorial mammals, such as California ground squirrels (Spermophilus beechyz) or American badger (Taxidea taxus), but will also use man-made structures (e.g., culverts, concrete, asphalt, wood piles). BUOWs may use a site for breeding, wintering, foraging, and/or migration stopovers and show moderate to high site fidelity (Le., re-using general areas and even particular burrows year after year). Depending on the location, the nesting season occurs between February 1 st and August 31 st. The study area provides potential foraging and nesting habitat for BUOWs, particularly within the grassland habitat on the site proposed for the additional facilities at the Regional Plant. The grassland habitat in the vicinity of the pipeline lateral off the southern end of the backbone alignment on Hillview Avenue and the ruderal habitat east of the San Francisco Bay Trail and East Bayshore Parkway also provide habitat for BUOWs; however, the potential for occurrence within these habitats is considered low given the existing conditions (lack of burrow donors and/or intensity of human-related disturbances). There are several occurrences of BUOW recorded in the CNDDB within a five-mile radius of the study area. Although no individual owls or evidence of owl use (e.g., white-wash, pellets, prey remains) were observed on the site at the Regional Plant during CAJA's September 2006 field survey, BUOWs could use the burrows on the site and, if present, could be adversely affected by installation of additional facilities for the proposed project. Mitigation Measure BIO-5 would be implemented prior to the onset of construction activities to avoid substantial adverse effects to burrowing owl. b) Methods similar to those described in the Biological Resources section of the ISIMND previously completed for the proposed project were used to determine if the vegetation communities and wildlife habitats identified on the site proposed for the additional facilities at the Regional Plant are considered sensitive by local or 179 H Street. Petaluma. CA 94952 Phone 707 283-4040. Fax 707 283-4041 • E-mail info@cajaeir.com • Web www,cajaeir.com Los Angeles. Santa Clarita. Agoura Hills. Petaluma. Oakland. Mammoth Lakes CHRISTOPHER A. JOSEPH & ASSOCIATES regional plans, policies, regulations, or by the CDFG or USFWS. Although there are several sensitive natural communities documented as occurring in the vicinity of the Regional Plant (e.g., northern coastal salt marsh, serpentine bunchgrass, valley oak woodland), the site proposed for the installation of the additional facilities does not support any of these communities or habitats. Consequently, the installation of the additional facilities for the proposed project would not have a substantial adverse effect on any riparian habitat or other sensitive natural community. c) No federally protected wetlands, as defined by Section 404 of the Clean Water Act are present on the site proposed for the additional facilities at the Regional Plant. d) The site proposed for the additional facilities at the Regional Plant is not within a known movement corridor for wildlife species and does not support habitat considered to be suitable for a native wildlife nursery site. e) Installation of the additional facilities at the Regional Plant would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. The trees on the site proposed for the additional facilities at the Regional Plant are not protected by City of Palo Alto's Municipal Code Chapter 8.10. 1) The site proposed for the additional facilities at the Regional Plant is not located within an area covered by a Habitat Conservation Plan, Natural Conservation Community Plan, or other approved local, regional, or state habitat conservation plan. Mitigation Measures In addition to Mitigation Measnre BIO-S outlined below for BUOW, Mitigation Measure BIO-3 and Mitigation Measure BIO-4 in the Biological Resources section of the ISIMND previously completed for the proposed project should be implemented to reduce potentially significant impacts to California clapper rail (Rallus longirostris obsoletus), California black rail (Laterallus jamaicensis), and other migratory birds and raptors on and/or in the vicinity of the site proposed for the additional facilities at the Regional Plant. Also, the text of these later mitigation measures should be revised to incorporate reference to the site at the Regional Plant. Mitigation Measure BIO-S: Conduct protocol-level BUOW survey prior to the installation of the additional facilities proposed at the Regional Plant and avoid impacts to owls, if present, during project construction. A qualified biologist shall conduct a protocol-level survey for burrowing owl following the methods outlined in the Burrowing Owl Survey Protocol and Mitigation Guidelines 7. A survey for owls shall be conducted during the breeding season (in general, February lSI through August 3 IS" peaking between April 151h and July 15th). If no owls are observed using the site during the breeding season surveys, winter surveys shall be conducted. Winter surveys shall be conducted between December 1 st and January 31 s" during the period when wintering owls are most likely to be present, if necessary. A complete owl survey consists of four site visits, on separate days and during weather that is conducive to observing owls outside their burrows. If no owls are found during the breeding or winter season surveys, no further mitigation shall be required, provided construction activities or destruction of suitable burrows commence within 30 days of the date of the last survey. Otherwise, a pre-construction survey for owls shall be conducted no more than 30 days prior to the onset of construction activities. If surveys confirm presence of owls on the site, mitigation measures shall be incorporated into the proposed project, in coordination with CDFG, to avoid and/or minimize impacts to burrowing owls, their burrows and foraging habitat on the site. The following measures shall be taken into consideration: 1) occupied burrows shall not be disturbed during the nesting season, unless a qualified biologist approved by the CDFG verifies through non- invasive methods that either: a) the owls have not begun egg-laying and incubation; or b) that the juveniles from California Burrowing Owl Consortium. 1993. Burrowing Owl Survey Protocol and Mitigation Guidelines. 179 H Street. Petaluma. CA 94952 Phone 707283-4040. Fax 707 283-4041 • E-mail info@cajaeir.com • Web www.cajaeir.com Los Angeles. Santa Clarita. Agoura Hills. Petaluma. Oakland. Mammoth Lakes CHRISTOPHER A. JOSEPH & ASSOCIATES Research those burrows are foraging independently and capable of independent survival; 2) to offset the loss of foraging and burrow habitat on the project site, a minimum of 6.5 acres of foraging habitat per pair or unpaired resident bird, shall be acquired and permanently protected; 3) when destruction of occupied burrows is unavoidable, existing unsuitable burrows shall be enhanced (e.g., enlarged or cleared of debris) or new burrows shall be created (e.g., installing artificial burrows) at a minimum ratio of 1: I on protected lands; 4) if owls must be moved away from the disturbance area, passive relocation techniques shall be used rather to trapping; and 5) the project sponsor shall provide funding for long-term management and monitoring of the protected lands. Summary In summary, installation of the additional facilities at the Regional Plant for the proposed project could adversely affect special-status animals, including BUOW, California clapper rail, California black rail, and other migratory birds and raptors. However, implementation of Mitigatiou Measures BIO-3, BIO-4, and BIO-S would reduce potentially significant impacts to these sensitive species to a less-than-signijicant level. No sensitive plants or vegetation communities or jurisdictional wetlands or waters would be adversely affected by the installation of the additional facilities at the Regional Plant. Also, the additional facilities would not interfere with or impede the use of wildlife movement corridors or nursery sites. Please do not hesitate to contact me if you have any questions or concerns regarding our analysis for the site proposed for the additional facilities at the Regional Plant for the proposed project or incorporating this analysis into the previously completed Biological Resources section of the ISIMND. 179 H Street. Petaluma. CA 94952 Phone 707 283-4040. Fax 707 283-4041 • E-mail info@cajaeir.com • Web www,cajaeir,com Los Angeles. Santa Clarita. Agoura Hills. Petaluma. Oakland. Mammoth Lakes This page left intentionally blank APPENDIX D CULTURAL RESOURCES Issues (and Supporting Information Sources): V. CULTURAL RESOURCES --Would the Project: a) Cause a substantial adverse change in the significance of a historical resource as defined in §IS064.S? b) Cause a substantial adverse change in the significance of a unique archaeological resource pursuant to § IS064.S? c) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? d) Disturb any human remains, including those interred outside of formal cemeteries? CULTURAL SETTING Potentially Significant Im12act o o o o Less Than Significant With Less Than Mitigation Significant No Incor12oration Im12Qcr Impact o o o o o o o o Evidence gathered from archaeological sites in the region (Fredrickson 1973; Moratto 1984) indicates that this part of Santa Clara County is known to have been occupied, at least intermittently, for the past 6,000 years or longer. Decades of archaeological investigation indicate that a discrete archaeological entity based on the intensive use of shellfish, a subsistence strategy reflected in both coastal and bay shore midden deposits, thrived in the Bay Area (Moratto 1984). The ethnographic inhabitants of the area at the time of historic contact with Europeans were the Ohione or Costanoan group of Native Americans, who are known to have established villages in the project vicinity (Kroeber 1925; Levy 1978a, b). The groups inhabiting these discrete villages were independent political entities, each occupying specific territories defined by physiographic features. Access to the natural resources of the territories was controlled by each group. Although each group had one or more permanent villages, their territory contained numerous smaller camp sites used as needed during a seasonal round of resource exploitation. Mission Santa Clara, founded in 1777, controlled much of the land in the Santa Clara Valley (approximately 80,000 acres) until secularization in the 1830s. Mission lands were used primarily for the cultivation of wheat, com, peas, hemp, flax, and linseed, and for grazing cattle, horses, sheep, pigs, goats, and mules. By the late 1840s, the Santa Clara Valley drastically changed in the wake of the U.S. victory of the Mexican -American War (1846-1848), and the gold rush of 1849. Open land used for Palo Alto Recycled Water Project MND 2-1 WSA/203213 agricultural purposes and cattle ranching under Mexican rule, was now home to newly arrived American settlers and "squatters" who were quick to take possession of the fertile valley. Leland Stanford was a business man who in 1852 moved from New York to Sacramento. He earned a fortune which allowed him to gain political office as Governor. Following his time as governor, he concentrated his efforts in successfully building the first transcontinental railroad with the Central Pacific Railroad. This company was later merged with Southern Pacific Railroad. In 1870, Stanford purchased the Rancho San Francisquito, which includes portions of modem day Palo Alto. On this land, which he named Palo Alto, he established a farm dedicated to breeding pedigree race horses. In 1884, Stanford's only son died at the age of sixteen. As a memorial to him, Stanford established a university which was opened for classes in 1891. Today, Stanford University is one of the most prestigious private universities on the West Coast (Hoover et al. as cited in Kyle 1990: 418-419). The oldest parts of Palo Alto were once called Mayfield and College Terrace. ·In 1867, Mayfield was established as a town although the first school house dates to 1855. The town is named after one of the early farms owned by Sarah Wallis, who was the first president of the California Suffrage Association. Subsequent to its founding, Mayfield earned a reputation for the thirteen unruly saloons in town. Stanford disapproved of alcohol and used his influence to modifY that reputation. He convinced an associate, T. Hopkins, to purchase a 740 acre tract ofland and prohibit the sale of alcohol on the property. In 1894, the town was incorporated and became known as Palo Alto, to which Mayfield was annexed in 1925. In 1889, the area between Stanford University and Mayfield was settled. Originally it was called University Terrace but later was subsumed into the growing City of Palo Alto (Hoover et al. as cited in Kyle 1990: 420). In the twentieth century, Palo Alto benefited from technological growth in Silicon Valley. Currently, the city continues to be an economic center for the technology industry. Xerox, Amazon.com, Lockheed Martin, and Hewlett-Packard are major technology firms that maintain offices in Stanford Research Park. DISCUSSION Records searches of pertinent survey and site data were conducted at the Northwest Information Center at Sonoma State University (NWIC). The records were accessed by using the Palo Alto and Mountain View USGS 7.5-minute quadrangle maps, Township 6 South, Range 2 West, and Township 6 South, Range 3 West in Santa Clara County. The initial record searches (File No. 07- 0362, 07-1299) covered the entire project area and a one-quarter mile radius adjacent thereto. A later record search (File No. 07-1326) was conducted at the request of Cookie Him of the Division of Financial Assistance, at the State Water Resources Control Board, upon an initial review of the report for the purpose of examining the archaeological potential of closely associated areas located between the proposed routes of the pipeline backbone and laterals. Previous surveys, studies and archaeological site records were accessed as they pertained to the project area. The record search included a review of the California Inventory of Historic Resources (1976), the Historic Property Directory (Office of Historic Preservation current computer list), NWIC records of archaeological sites and surveys, GLO Plats, historic maps, and other pertinent historic data available at the NWIC for Santa Clara County. Palo Alto Recycled Water Project MND 2-2 WSA!203213 Although no previously recorded archaeological sites exist within the proposed project area, the records search indicated that 11 previously recorded archaeological sites and one previously recorded isolate are located within Y4-mile of the project area (Table 2-1), and four sites are in the added areas between and around the proposed pipeline backbone and lateral options (Table 2-2). A total of 49 cultural resources studies have been conducted, including 15 studies within some portion of the project area (Table 2-3), 25 studies have been conducted within )4-mile of the project area (Table 2-4), and 9 studies in the added areas between and around the proposed pipeline backbone and lateral options (Table 2-5). Site # CA-SCL-3 CA-SCL-708 CA-SCL-585 CA-SCL-622 TABLE 2-1 PREVIOUSLY RECORDED ARCHAEOLOGICAL SITES WITHIN 114 MILE OF THE PROJECT AREA Description .. , . . ... Prehistoric occupation site composed of dark friable soil with shell, fire cracked rock (FCR), bone and lithic material. The site is bisected by Matadero Creek and is estimated to be 1O,000m2, and more than 120cm deep. Artifacts noted include flaked and ground stone tools (mortars and projectile points), one charm stone, whole Olivella beads and fractions and abalone shell pendants. Two prehistoric features observed at the site , include a lens of shell and a possible hearth composed of a deposit of FCR • and baked clay. Prehistoric occupation site composed of dark midden deposits. Archaeological matrix is interlaced with shell (oyster, bay mussel and horn snails), fire-cracked rock (FCR) and one chert flake. CA-SCL-708 is located at the intersection of Louis Road and Colorado A venue. The site covers an area of over 900 m2 but the depth of deposits remains unknown Prehistoric occupation site composed of black midden deposits located on the southeast bank of Matadero Creek. Artifacts types recovered consisted of shell and shell beads, grinding stones and pestles, chert cores and other unspecified lithic materials. Three human burials were also encountered and excavated. This was a salvage investigation conducted in 1985. Site boundaries were never determined due to construction constraints. Prehistoric occupation site composed of dark midden deposits approximately 90 cm deep. The site is located on Emerson Street in Palo Alto between Oregon Expressway and Colorado Street. The site covers an area 85 meters in length by 15+ meters in width. Artifact types observed in the matrix include shell (oyster, horn snail and mussel), FCR, faunal bone and Franciscan chert flakes. ! Prehistoric occupation site composed of ~ark midden deposit. The site is Reference Bocek 1985 Bocek 1990b Bocek and Rutherford 1985 Bocek 1987b [ ' estimated to be approximately 216,000 m . The depth of this site remains CA ...... -... S ..... C .. _L_-_6_24_L.:::un:...:r::.:e~co..::r..::d==ed==.:.:.:N:...:0_art_ifi_ac_t_s_w_e_r_e _re_c_o_v_er_e_d_o_r_e_n_co_u_n_t_er_e_d_b_u_t _ec_o_fi_ac_t_s_in_th_e---L __ E_n_gl_an_d_l_9_87_---1 form of FCR, shell (specifically Cerithidea) and crab claws were observed in the matrix. Palo Alto Recycled Water Project MND 2-3 WSAf203213 CA-SCL-628 CA-SCL-630 CA-SCL-631 CA-SCL-632 CA-SCL-716 CA-SCL-3-1 (ISO 3) Prehistoric occupation site composed of dark friable soils and several concentrations of chipped stone. Artifacts recovered on the surface include chipped stone cores, flakes and tool fragments. Various types of shell (including Olivella, oyster and hom snail) were also observed at the site. The site covers an area of 4,500 m2 while the depth remains unrecorded. It is suggested this site may be contiguous with CA-SCL-3 but this is undeterminable because Foothill expressway was built between the two. Prehistoric lithic scatter composed of nodules of untested chert, chert core fragments, reduction flakes and FCR. Site function was determined to be a lithic quarry due to lithic material in all stages of reduction. The site covers an area of approximately 250 m2• The depth of the site remains undetermined. The site is located on the north slope of Coyote Hill just south of Co ote Hill Road. Prehistoric lithic scatter composed of chert cores, flakes and tools. Due to the lack of untested cores, site function was determined to be a lithic workshop. One possible feature was encountered but remains unexcavated and could be the result of historic or modem activity. The site is located on the summit of Coyote Hill (proximal to CA-SCL-630 and CA-SCL-632) and covers an area of approximately 100 m2• Prehistoric lithic scatter composed of tested and untested chert cobbles, chert cores, reduction flakes and utilized flakes. Site function was determined to be a lithic quarry due to lithic material in all stages of reduction. The site is located on the southeast slope of Coyote Hill (proximal to CA-SCL-630 and CA-SCL-63l) and covers an area of approximately 15,000 m2• The extent of buried deposits remains unknown. Prehistoric occupation site composed of deposits of dark midden. Artifacts present in the matrix include shell (oyster, hom snails, bay mussel and abalone), FCR, baked clay, ash lumps, faunal bone complimented by Franciscan and Monterrey chert flakes. The site is located on the west bank of Matadero Creek; the highest concentration of material is at the street address of 717 Chimalus Drive. The area and depth of site remain unrecorded. Naturally occurring surface scatter of Franciscan chert located on the lower slope of the south side of Coyote Hill. One Franciscan chert core and two flakes were observed in the scatter of cobbles. This was designated the Arastradero Chert Source. TABLE 2-2 CULTURAL RESOURCES IN AREAS BETWEEN PIPELINE , A large, shallow midden containing shell, FCR, faunal bone, and human CA-SCL-597 ' remains. The site is located on the 700 block ofFlorales Drive, South Palo i Alto, between Solana and Amaranta Streets. Very large prehistoric midden and probable habitation site containing FCR, cerithidea, ostrea, flaked lithics, groundstone. Partially disturbed at time of Bocek 1987c Bocek 1987d Bocek 1987e Bocek 1987f Bocek 1991 Bocek and Martinez 1985 Bocek 1986b CA-SCL-600 recording by modem residential construction. Full extent of site uncertain, Van Zandt 1986 but generally located south of intersection of Alma Street and West Charleston Road in Palo Alto. Palo Alto Recycled Water Project tvlND 2-4 WSA/203213 I A large area of dark friable midden soil containing utilized flake tools made of Franciscan and Monterey Banded chert, faunal bone, shell, FCR, and CA -SCL-616 • charcoal. The site is located to the west of a paved bike path built on an old Southern Pacific right of way, which crosses Matadero Creek north of a V A hospital and south of Gunn High School. I CA-SCL-707 Survey # A badly disturbed earth midden containing shell and FCR. Heavily impacted by residential and road construction. The site is located at the I intersection of Alma Expressway and Adobe Creek, north-northeast of the . intersection of Alma Expressway and Rengstorff A venue, i TABLE 2-3 CULTURAL RESOURCE STUDIES WITHIN THE PROJECT AREA Date ! ••. :". '" Author ..................... .. ,.' ' Title Bocek 1987a Bocek 1990a '. .'. Santa Clara County Historic Property Survey Report, Oregon-Page Mill S-004883 1977 Expressway Intersection Improvements at EI Camino Transportation Agency Real, Palo Alto, CA S-005023 1982 Cartier, Robert I Cultural Resources Evaluation for a Parcel for land at • 3860 Middlefield Road in the City of Palo Alto, .. County of Santa Clara .,. S-008420 1981a Cartier, Robert Cultural Resources Evaluation of the Peter Coutts Hill project, Stanford University, County of Santa Clara Cultural Resource Evaluation of the Matadero Creek S-009442 1987 Cartier, Robert Flood Control Project in the City of Palo Alto, County of Santa Clara Technical Report of Cultural Resources Studies for S-011396 1989 BioSystems Analysis, Inc the Proposed WTG-WEST, Inc. Los Angeles to San Francisco and Sacramento, California, Fiber Optic Cable Project Hatoff, Brian, Barb Voss, Cultural Resources Inventory Report for the Proposed S-017993 1995 Sharon Waechter, Stephen Wee, and Vance Bente Mojave Northward Expansion Project S-022605 1999 • Cartier, Robert Cultural Resource Evaluation of the Sprint PCS Mitchell Park Project at 3600 Middlefield Road in the City of Palo Alto, County of Santa Clara Final Cultural Resources Inventory Report for Williams Communications, INC. Fiber Optic Cable S-022978 2000 Avina, Mike System Installation Project, San Francisco to Santa • Clara, San Francisco, San Mateo, and Santa Clara I Counties, Addendum 1 S-025159 2002 N d I k' J h d M' h 11 St I Archaeological Investigations for the 2950 West a 0 s I, 0 n, an IC e e . B h R d W' I C .. S' CA CI . • ays ore oa, Ire ess ommumcatlOns lte, ~r2U7H I Holson, John, Cordelia Sutch, ! Cultum} Rosou"" Roport fo< Son Bruno., Moun"in I S-025174 2002 and Stephanie Pau .. View Internodal Level 3 Fiber Optics Project in San ! Mateo and Santa Clara Counties, California S-027709 2003 Losee, Carolyn Cultural Resources Analysis for Cingular BA-351-02 Mayfield Station #2 Site (letter report) S-027908 2003 Environmental Science Palo Alto Regional Water Quality Control Plant I Associates Reuse Pipeline, Cultural Resources Inventory Report Nelson, Wendy, Tammara I Archaeological Inventory for the Caltrain S-029657 2002 Norton, Larry Chiea, and I Electrification Program Alternative in San Francisco, Reinhard Pribish San Mateo, and Santa Clara Counties, California Palo Alto Recycled Water Project MND 2-5 WSA/203213 I S-029698 S-033697 . SurveY#' S-004201 S-004279 S-006051 S-008589 S-008728 S-014246 S-014973 S-014974 S-OI4975 S-015928 S-016137 S-01669l S-017518 I S-OI8047 I S-020483 2005 ThaI, Erika ent Shelter, PG&E City of Palo Alto! SF- , 1080 Colorado A venue, Palo Alto, CA. 2007 Martorana, Dean Palo Alto Regional Water Quality Control Plant Reuse Pipeline, Santa Clara County, California: Date 1997 1976 1983 1981 1949 1992 1993 Cultural Resources Invento TABLE 2-4 CULTURAL RESOURCE STUDIES WITHIN ¥.t-MILE OF THE PROJECT AREA ,i'Author / "i i'",;,," C, " •• . ... Title' " . Anonymous Archaeological Reconnaissance of the Proposed Palo Alto Yacht Harbor Expansion. Riley, Lynn Archaeological Reconnaissance, Proposed Site of Sanitary Land Fill, Santa Clara County, California Archaeological Reconnaissance and Records Search Clark, Mathew for the Proposed Bryan Canyon/Kaiser Permanente Solid Waste Landfill Access and Transfer Stations Cultural Resource Evaluation ofthe Terman School Cartier, Robert Low-cost Housing Project near Arastradero and Pomona Avenue in the City of Palo Alto, County of Santa Clara i Caldwell, Warren Wendell i The Archaeology of the Stanford-Palo Alto Region Archaeological Resource Cultural Resource Evaluation of the Veterans Administration Medical Center Project in the City of Management Palo Alto, County of Santa Clara PG&E Archaeology,S limited scale tests along the Hammett, Julia proposed pipeline trench crossing of Matadero Creek (letter report) 1992 Hammett, Julia Archaeological Concerns Related to Lockheed's Toxic ! Substances Control Program (letter report) 1992 Bennett, J.M. Stanford Segment of Line 1091132; Cultural Resources Testing of Site CA-SCL-628 (letter report) 1994 ,Wizorek, Julie.C., and Jon I Reddington Matadero Creek Project, Archaeological Testing Program, Phase 11 ! Archaeological Field Inspection of the Page Mill 1994 i Holman, Miley Road and Foothill Road Expressway Improvement Project, Palo Alto, Santa Clara County, California Cartier, Robert, Julie C. Cultural Resource Evaluation ofthe Adobe Creek 1994 Wizorek, and Kim Holanda Project in the County of Santa Clara 1975 Jackson, Thomas L. An Archaeological Reconnaissance of the Junipero I Serra Boulevard Study (letter report) I I 994b Holman, Miley P. Archaeological Field Inspection of the Palo Alto Golf . Course, Palo Alto, Santa Clara County, California. Cultural Resources Assessment, Pacific Bell Mobile 1998a Price, Barry A. Services Facility SF-530-03,Palo Alto, Santa Clara County, California (letter report) Palo Alto Recycled Water Project lvlND 2-6 WSAI203213 i Psota, Sunshine I Review of Historic Resources for Site SF-142-02, 711 S-020910 I 1998 ! Colorado Avenue, Palo Alto, Santa Clara County, CA • (50001 84/98) (letter report) f Cultural Resources Survey of the Point to Point Web S-022704 2000 Ballard, Hannah • TV Service Connection, Santa Clara County (letter • report) Record Search Results for Sprint Spectrum's Personal S-023888 2001 Losee, Carolyn Communication Series (PCS) Wireless "Long's Drugs" Site (Ref# SF33XC572F) (letter report) Cultural Resources Reconnaissance Survey and S-026045 2000 Carrico, Richard, Theodore Inventory Report for the Metromedia Fiberoptic Cable Cooley, and William Eckhardt Project, San Francisco Bay Area and Los Angeles Basin Networks Cultural Resources in the Area ofthe Trail S-027020 2003 Jones, Laura Alignments Under Study by Santa Clara County in the Stanford Trails Supplemental Environmental Impact I Report Archaeological File Study of the 90 I San Antonio S-028669 2004a I Holman, Miley P. Road Project Area, Palo Alto, Santa Clara County, California Nextel Communications Wireless S-02923I 2000 BiIlat, Lorna • Telecommunications Service Facility-Santa Clara . County, Nextel Site No. (CA-017IA) 1 Page Mill i Road (letter report) Nextel Communications Wireless S-029233 n.d. Billat, Lorna Telecommunications Service Facility-Santa Clara County, Nextel Site No. (CA-087IA)1 Oregon EJg)resswaYiIetter r~ort) I Cultural Resources Analysis for Cingular Wireless S-030233 2004a . Losee, Carolyn Site BA -350-02, "California A venue Cal train Station", Palo Alto, California (letter report) Cultural Resource Study ofthe Middlefield & S-033281 2005 Supernowicz, Dana E. Meadow Dr. (Achieve School) Project, Cingular I Wireless Site No. SCFCCA2074F, 3860 Middlefield Road, Palo Alto, Santa Cou®,-, California 94303 TABLE 2-5 CULTURAL RESOURCE STUDIES IN AREAS BETWEEN PIPELINE AND LATERAL OPTIONS ~I))~ %-lVIILE) Survey # .'1 Date I····· .• ::'. Author .. ; . l"'> .•.•. <' ......r Title: ~'< ! Archaeological Survey Report, 04-SCL-1O 1, Portions 8345 1980 Melandry, Mara of P.M. 38.3/52/5, Improvements to Route 101 i between Route 17 and Embarcadero Road 10077 1988 Cartier, Robert, and Glory Anne I Archaeological Excavation at CA-SCL-600 on Adobe Laffey • Creek in the City of Palo Alto, County of Santa Clara Garaventa, Donna, Rebecca L. Cultural Resources Assessment for 1990 General Plan 12528 1991 Anastasio, Stuart A. Guedon, Update, City of Mountain View, Santa Clara County, Sondra Jarvis, Lisa A. Pujol, California J Steven 1. Rossa 16394 1994 Basin Research Associates, Inc. Recorded Archaeological Resources in Santa Clara CouIlty, California Palo Alto Recycled Water Project MND 2-7 WSA/203213 I 1998a I Price, Barry A. ! Cultural Resources Assessment, Pacific Bell Mobile 20343 • Services Facility SF-619-05, Palo Alto, San Mateo County Sawyer, Izaak, Laurie Pfeiffer, Archaeological Survey along Onshore Portions of the 22657 2000 Karen Rasmussen, Judy Global West Fiber Optic Cable Project Berryman • Completion of Archaeological Subsurface Augering at 25271 2001 Holman, Miley the Hiatt Rickey'S Hotel Project, 4129 EI Camino Real, Palo Alto, Santa Clara County (letter report) 28906 2004b Losee, Carolyn Cultural Resource Analysis for Cingular Wireless Site SF-971-01 "Block Buster" Palo Alto (letter report) I 2003 Historic Property Survey Report, Mission Bells 32250 Lapin, Philippe Project, State Route 82/Interstate 101, San Mateo and Santa Clara Counties, California Native American Consultation WSA contacted the Native American Reritage Commission (NARC) by letter on August 31, 2007, requesting information on sacred lands and a contact list of local tribal representatives or most likely descendents (MLD). A response was received from the NARC on September 14, 2007 noting, "A record search of the sacred land file has failed to indicate the presence of Native American cultural resources in the immediate project area." The letter also provided a list of Santa Clara County Native American Contacts. Due to the potentially sensitive nature of previously unrecorded prehistoric cultural resources that could be encountered in the project area, WSA contacted the local Native American representatives to solicit comment on the project's environmental documentation. On September 18, 2007, WSA Staff Archaeologist Melinda Rickman contacted by letter each of the listed Native American Contacts, explaining the nature of the project and soliciting comments and any additional information the individuals might have regarding cultural resources in the project area No response to the letter solicitations was received. On October 2, 2007, WSA placed follow-up telephone calls to all of the individuals on the contact list. All solicited comments are reported in Appendix A. Sample consultation letters are also provided in Appendix A. In early 2009, it was decided that a pump station is needed at the existing RWQCP as part of this proposed project. On October 23, 2006, on behalf of another project at the RWQCP that also encompassed the area of the pump station, WSA had contacted the Native American Heritage Commission (NARC) by letter, requesting information on sacred lands and a contact list of local tribal representatives or most likely descendents (MLD).The results of that request are being used for this addition to the current project. A response to the October 23rd request was received from the NAHC on October 27,2006, noting, "A record search of the sacred land file has failed to indicate the presence of Native American cultural resources in the immediate project area." The letter also provided a list of Santa Clara County Native American Contacts. Due to the potentially sensitive nature of previously unrecorded prehistoric cultural resources that could be encountered in the project area, WSA contacted the Palo Alto Recycled Water Project MND 2-8 WSA/203213 I i ! local Native American representatives to solicit comment on the project's environmental documentation. WSA Project Manager Eric Strother contacted by letter each of the listed Native American Contacts, explaining the nature of the project and soliciting comments and any additional information the individuals might have regarding cultural resources in the project area. No responses to the consultation letters were received. On November 28, 2006, and again on November 29, 2006, WSA placed follow-up telephone calls to all of the individuals on the contact list. Messages were left when possible. No responses to the phone calls were received. All solicited comments are reported in Appendix A. Sample consultation letters are provided in Appendix A. Geoarchaeological Background Mr. David Devries, Principal and Soils Scientist of Mesa Technical, Berkeley, California, prepared the following report on the geoarchaeological analysis of the Palo Alto Recycled Water Project Area. As discussed above, in early 2009, it was decided that a pump station is needed at the existing RWQCP as part of this proposed project. The RWQCP project area lies within a mile of Devries' study area, and is situated entirely on several feet of historic fill (at least) described as Made land [Ma] on the soil survey map, which is "areas consisting of a fill of earth and refuse over Alviso soil material or over Tidal Marsh" (Gardner et aI, 1958). Alviso Clay (An) is discussed in Devries' report (summarized below). Tidal Marsh soil (Ta), is "areas periodically covered by the tide and on which a rank herbaceous growth normally occurs," and "having practically no agricultural value". These two soils are very similar, both being flooded by sea water during high tides. As a result, Devries' assessment of Alviso Clay (below) applies equally to the Tidal Marsh soil. WSA has, therefore, concluded that Devries' original geoarchaeological analysis adequately addresses the soil types beneath the fill (or Made land) on which the additional project facilities are proposed at the RWQCP. The purpose of this study is to evaluate archaeological sensitivity for buried cultural features, within soils and sediments to be disturbed by construction activity. This report is based upon review of the older Santa Clara Area soil survey (Gardner et ai, 1958), mapped just before WWII, and more recent geotechnical reports by various authors for specific building sites within the Area of Potential Effect (APE). Early reconnaissance soil surveys, from about 1900-1920, and the first series of more detailed county soil surveys, such as Gardner's, are outstanding sources because oftheir emphasis upon the collection of primary data: the geomorphology, field observations, and detailed profile descriptions were obtained by Bureau of Soils and Soil Conservation Service career professionals who worked outdoors most of the time, in that era before Bay Area landscapes had been reshaped for urban use, before marshy areas had been completely diked and drained, natural levees and stream terraces destroyed, and sinuous drainages channelized. Such long term, labor intensive, precise field work by teams of experts is now expensive and rare, aside from the fact that original geomorphology may be unidentifiable on the present day, graded urban landscape. Since these soils were mapped, there has been much evolutionary change to the taxonomic and descriptive language that we use to discuss the soils. Yet, the soil physical and chemical attributes Palo Alto Recycled Water Project MND 2-9 WSA/203213 remain constant, though our perspective upon and interpretations ofthe raw data change. Gardner's pre-WWII soil mapping work was published with agricultural applications in mind, especially for the management of Santa Clara Valley's famed orchard crops. Yet the soil properties his team recorded are quite relevant to today's archaeological sensitivity interpretations, especially properties such as soil horizon colors, textures, pedogenetic relationships, and drainage. Geographically, the Palo Alto APE for cultural resources includes an approximately 2 mile by 4 mile area of southeastern Palo Alto, stretching northeast from the hills just south of Stanford University to the Bayhore Freeway, US-IOI. Geomorpho\ogically, the Palo Alto APE is similar to other urban landscapes ringing the central and south parts of San Francisco Bay, in that rolling foothills give way to broad swaths of older, then younger alluvial fan aprons, cut by recent streams which have eroded the uplands and older fans, then have deposited channel sands and gravel, shifted course, and built terraces, levees, and extensive floodplains along their descent to San Francisco Bay. A large part of the APE, 40-50%, has been mapped on low ground near the Bay as one of three types of heavy textured, poorly drained soils, members of the Clear Lake, Sunnyvale, or Alviso series. All are on formerly wet, or seasonally wet grassland that now has been diked, drained, and reclaimed. These soils are less affected by high water tables now, since drainage ditches or tile drains have been installed. Also, pumping for urban use, and formerly for agricultural irrigation, has lowered the local water table. The Clear Lake soils, on the upper rim of the basin, are highest in elevation and least affected by salt or lime accumulation. They probably represent former freshwater floodplain deposits. The Alviso soils occur on the lowest ground nearest the Bay, formerly tidal marsh, and are affected by sodium and other salts throughout their profiles. The Sunnyvale soils are intermediate, having more marly lime than the Clear Lake soils, but not so high sodium levels as the Alviso soils. Clear Lake clay, 0-1 % slopes. (Cm) In the study area, the Clear Lake clay occurs on nearly level ground in the highest topographic position of the basin rim soils, as stated above. Areas of Clear Lake soil are adjacent to young, well drained alluvial fan soils on the topographic high side, and adjacent to wetter, marine affected soils on the low side. Some soil properties relevant to the assessment of archaeological potential are the following: The Clear Lake clay has an A-C horizonation that has developed within deep alluvial deposits. These deposits have a montmorillonitic (shrinking-swelling) clay minerology and the soil developed from these deposits has a vertisolic (self-churning) taxonomic classification. The parent materials of today's Clear Lake clay accumulated slowly and steadily, probably as an alternating combination of freshwater floodplain deposits from creeks of the alluvial fans, and marine transgressive deposits from the Bay. Yet the xeric climate and lack of a year round high water table allowed the montmorillonitic soil minerals to dry and shrink each summer, resulting in deep, wide cracks. The cracks partially filled with surface soil each summer, then swelled shut again with the onset of the winter rains, as the soil minerals again absorbed water. Palo Alto Recycled Water Project MND 2-10 WSA 1203213 The A-C pattern of Clear Lake soil horizonation, and lack of a B horizon, thus does not reflect frequent episodes of deposition, as on an alluvial fan, but rather the constant top to bottom churning of the soil, making an undifferentiated mass of the top four feet. Blocks and prisms of soil slid against each other with each wetting and drying episode, forming smooth slickenside surfaces and destroying any stratigraphic integrity that subsurface cultural deposits may have once had. The Clear Lake soils are wet for nearly half the year, and thus not good sites for permanent camps, though being adjacent to wetter marshland, they may have been used for temporary hunting or fishing camps during the summer. Their massive structure, extremely hard dry consistence, and very sticky, plastic nature when wet, would have made them unappealing or impossible to dig for storage pits or burials. They are unlikely to have been used for those purposes, with well drained soils of better tilth so close at hand. We would rate the Clear Lake soils as having a low potential to contain buried features associated with sustained, long term occupation. While the the gentle, low energy environment of sedimentation would be very favorable to the undisturbed burial of whatever artifacts might be present as a result of seasonal use, subsequent cracking and shifting of the soil mass during wet-dry cycles would tend to destroy the features, and/or their stratigraphic relationships. Seasonal use artifacts might be present especially near locations where freshwater creeks flow into tidal wetlands. Alviso clay, 0-1 % slopes. (An) The Alviso clay occurs on level ground in a lower topographic position than the Clear Lake or Sunnyvale basin soils. Areas of Alviso soil are adjacent to the heavy textured Sunnyvale soil on the topographic high side, and adjacent to tidal marshlands on the low side. Some soil properties relevant to the assessment of archaeological potential are the following: The parent material of the Alviso clay is fine textured alluvium, similar to the parent material of the other basin soils in the study area. However, the source of the Alviso parent material is more likely to have been suspended mud from the Bay than alluvium from the hills above Palo Alto. The soil minerology is described as mixed rather than montmorillonitic, reflecting more diverse source rocks than those which contributed sediment to the Clear Lake soil. The Alviso soils do not shrink and swell to the degree that the Clear Lake soils do, so the vertisolic churning of the A horizon is absent. Furthermore, the Alviso clay has a saline water table at 2-3 feet depth, which limits vegetation to salt tolerant grasses and pickleweed, and keeps the entire profile moist or wet at most times. The consistently damp soil conditions and low energy environment of aggradation favor the development of buried A horizons, resulting in A-C-Ab-2C. .. paleosolic profiles. The A-C pattern of Alviso soil horizonation, and lack of a B horizon, reflects frequent episodes of deposition, without sufficient time for eluviation of clay to form a B horizon. The Alviso soils are wet or damp nearly all the time, and thus not good sites for sustained, semi-permanent camps. Just as with the Clear Lake clay, their heavy texture and hard, sticky, plastic nature would have made them unappealing or impossible to dig for storage pits or burials. Except as noted in the paragraph entitled "shell midden," below, we would rate the Alviso soils as having a low potential to contain buried features associated with sustained, long term occupation. However, lacking the Clear Lake's vertisolic churning, the gentle, low energy environment of sedimentation would be very favorable to the undisturbed burial of whatever artifacts might be present as a result of seasonal use. Again, seasonal use artifacts might be present especially near locations where freshwater creeks flow into tidal wetlands. Palo Alto Recycled Water Project MND 2-11 WSA 12032 13 Sunnyvale clay, 0-1 % slopes. (Sx) The Sunnyvale clay is mapped on large areas of level ground in an intermediate topographic position between the Clear Lake soils on the high side, and the Alviso soils on the low side. It is a black, calcareous clay. Like the Alviso and Clear Lake soils, the Sunnyvale soil developed from fine textured floodplain alluvium in a low energy depositional environment. However, since the soil is wetter than the Clear Lake, and drier than the Alviso, the Sunnyvale has unique properties: its mixed minerology reduces the seasonal cracking, swelling, churning tendencies of basin rim soils like the Clear Lake, and its drier topographic position than the Alviso makes the Sunnyvale soil relatively rich in lime (CaC03) but mostly leached free of sodium, the more soluble salt. The intermediate soil wetness regime and heavy texture makes the Sunnyvale a grassland or prairie soil, a mollisol. The high organic matter content near the surface (from the grass roots) and high calcium content throughout tend to flocculate the clay and promote a granular, workable soil tilth, except during summer, for longer periods than on the Clear Lake soils. Gardner reports occasional gravel in some locations, deep in the subsoil or in parent material. This would seem to indicate that the Sunnyvale in places overlays Zamora or Dublin fan deposit soils at depths of only 5-7 feet. Pedologically, the Sunnyvale clay and its underlying sediments have a high potential to contain buried paleosols, reflecting either the gentle depositional environment of the floodplain, or the more energetic environment of the lower alluvial fans. On and within these paleosols, archaeological sites undoubtedly exist, so the archaeological potential is high. However, considering the vast areas mapped to Sunnyvale soil, and the very small percentage of this area to be disturbed within the APE, the chances of actually encountering a site are low. Shell Midden The Alviso and Sunnyvale soils are mapped on large areas of bayside flood plain, characterized by late Holocene alluvium deposited in a gentle, low energy, aggradational environment. Such a sedimentation regime is ideal for the intact burial of archaeological features, despite the fact that the obdurate soil texture and poor drainage make the presence of such archaeological features unlikely within the greatest part of the land so mapped. However, invisible to us today, either because of historic agricultural land leveling, and subsequent urban usage, or because of being covered with a thin veneer of recent flood sediment, there are bound to be small areas of buried landforms such as former stream levees or low dunes, on land near the present or former bay shore. These areas have a high archaeological potential to contain midden deposits, because of offering dry soil within a fish and game rich marsh, sometimes with permanent fresh water nearby, as, for example, at the Berkeley shellmound at the mouth of Strawberry Creek. So it is appropriate to say that most areas of the Alviso and Sunnyvale soils have low potential, except for small areas near former creek channels, and near former dunes. Such areas could be very shallowly buried, and unmapped on soil surveys, as they are covered by a thin layer of fine textured recent sediment that is undistinguishable from the Sunnyvale or Alviso surfaces. Deeper Levels Scattered geotechnical data exist for that part of the APE located on basin soils, showing gravel deposits at depth. Soil report 1-13 (William F. Jones, Inc.; 1980) has logged at least 3 feet of sand Palo Alto Recycled Water Project MND 2-12 WSA/203213 and gravel below 18 feet of black silty clay, at boring # 1, with similar results in borings #2 and #3. Soil report 1-34 (Berlogar, Long & Associates; 1981) has logged peaty silty clay over clay with caliche to 19 feet, then sandy clay with gravel below, in boring #2. Likewise, soil report 1183 (Berlogar Geotechnical Consultants; 2006) logs sand and gravel lenses at depths from 16 to 38 feet in 3 borings; while soil report 2-83 (J.V. Lowney & Associates; 1988) has logged lenses of well graded sand at 17-19 feet. We interpret these to be indicative of mid Holocene or earlier fan deposits, from a time when water levels in the Bay were much lower, and the fans originating in the uplands to the southwest extended farther to the northeast. The peat and caliche within the boring indicate a subaerial depositional environment. The archaeological potential of these deposits would be lower than for more recent fan deposits, because the food rich Bay would have been at a greater distance, and thus the land would have been less likely to have been occupied on a sustained basis. Conversely, there are probably deeply buried shell middens along former bay shore, below tidal mudflats, well out from this project's APE, on land now flooded. Recent Fan & Floodplain Soils Approximately 30% of the APE surface soil has been mapped as either Dublin clay, Dublin clay loam, or Zamora clay loam. These soils developed on recent alluvial fan material, near the distal edges of their fans, from sandstone and shale sediments. The degree of profile development is low. These soils have Bt horizons, but only barely, probably indicating an age not greater than mid- Holocene. Their relatively fine texture indicates a low energy depositional environment, thus favoring the undisturbed burial of any cultural features that happen to be present. Their geographic position adjacent to the Clear Lake basin soils, and the shapes of some map units, is suggestive of interfingering sediment deposits, with non-vertisolic Dublin and Zamora soils developing in one place (favoring preservation of cultural features), and churning, vertisoIic Clear Lake soils developing at the surface nearby (favoring destruction of any archaeological record). These radical differences in soil behavior exist because of differing minerology and shrink-swell potential in the parent material. The Dublin soils are associated with small watersheds and intermittent streams, whereas the Zamora soils are associated with the larger watersheds and higher energy streams such as Stevens Creek, San Francisquito Creek, and Permanente Creek. Dublin clay, 1-3% slopes (Dh); Dublin clay, 3-6% slopes (Dg); Dublin clay loam, 1-3% slopes (DI) The Dublin series is mapped on gently sloping ground in an intermediate topographic position between the Clear Lake soils on the low side, and the Milpitas and Ohmer soils on terraces to the southwest. The Dublin is a black, nonca1cru;eous, heavy textured soil of fans and floodplains associated with small watersheds, the rounded grassy foothills of the urban fringe, rather than the mountainous uplands. The surface horizons crack upon drying, and thus would be likely to destroy stratigraphic relationships of artifacts formerly at the ground surface. However, the soils chum to a lesser degree than the Clear Lake soils; the lower Dublin horizons are more permeable, more friable, and better drained than the Clear Lake clay. While we would assign a high probability of the Dublin soils having buried paleosols, because of a high organic matter content and a rapidly aggrading geomorphological position, we would estimate the potential for deeply buried sites to be low, because of the rare or intermittent water supply in these small watersheds. For areas of the Palo Alto Recycled Water Project MND 2-13 WSA/203213 Dublin soils adjacent to Zamora soils, the potential for deeply buried sites would be greater, of moderate probability, because Zamora landforms are more likely to be near a permanent stream. Zamora gravelly clay loam, 1-3% slopes (Ze); Zamora silty clay loam, 1-3% slopes (Zf); Zamora clay loam, 0-6% slopes (Za) The Zamora series, like the Dublin, is mapped on gently sloping recent fans and floodplains. Zamora soils are old enough to show slight illuviation of clay in the B horizons, but not so old as to pre-date the possibility of human cultural usage. They are probably younger than mid-Holocene in age. The Zamora parent sediments were transported to their fan, floodplain, and low terrace positions by the area's larger streams, draining watersheds in the Santa Cruz Mountains. Indeed, the prevalent fan soils mapped by Gardner are combinations of Zamora (A-Bt-C), Yolo (A-C), and Sorrento (A-Ck) soil types, reflecting typical patterns of fan building, as the runoff wanders over the fan surface, and areas presently covered by gravelly or sandy deposits are then buried by finer material, silty clay loam and clay, as the channel shifts away. Over time, Bt horizonation develops on the less frequently flooded sediments. Zamora soils can present a very complicated three dimensional volume, a vertical APE that may show several buried surfaces, or none, depending upon the frequency and violence of the fan building storm events. Zamora soils are moderately well drained, and would most of the time have a drier surface than the adjacent (to the northeast) Clear Lake clay. The archaeological sensitivity ofthe Zamora soils is high, especially near Barron Creek and Matadero Creek, where the Zamora presence on both sides of the waterway indicates both a stable channel and long term stable land surfaces. Upland soils Small areas of upland soils are mapped withing the APE, in the Vallecitos, Gaviota, and Los Trancos series: Vallecitos clay loam, 20-35% slopes (Va); Gaviota loam, 20-35% slopes (Gk); Los Trancos stony clay, 10-35% slopes (Lg). These are shallow, residual soils developed on bedrock. The Vallecitos soil has an A-Bt-R horizonation, with hard, partially metamorphosed sedimentary rock at about 19" depth. The textural B horizon has developed directly from the weathering of the parent material, rather than from eluviation of clay from A to B horizons. The Gaviota loam has an A-R horizonation, with hard sandstone at 15"-25" depth. The Los Trancos soil developed from basic igneous rock, and is only 3"-10" deep. As with the Vallecitos soil, the fine texture results from the chemical weathering of the parent material into montmorillonitic clay minerals, rather than from long term, stable landscape processes such as gradual translocation of clay from A to B horizon. The upland soils are on hillsides, with areas of rock outcrops. Erosion is a constant factor in keeping these soils shallow, and genetically young. The archaeological potential for deeply buried sites is low; artifacts are more likely to be at the surface, perhaps chronologically mixed and concentrated, as the matrix of fine soil material washes downslope, leaving a residuum of relatively heavy cultural materials in place. We have also found on similar soils that bioturbation has thoroughly churned the cultural artifacts, if present, and there are likely to be isolated artifacts now resting directly on bedrock, that were once at the surface. Terrace soils Surrounding the upland soils in the southern and western parts of the APE are well developed stream terrace soils of the Ohmer and Milpitas series. Soils of stream terraces would seem to have a Palo Alto Recycled Water Project MND 2-14 WSAI203213 high potential for harboring buried archaeological sites, because recent (first terrace) soils are often flat, dry, easy to dig, and very near to the water of their parent stream. And unlike alluvial fans and floodplains, they do not occupy broad swaths of the landscape, so the high cultural potential is concentrated within a relatively small area. Yet not all terrace soils have a high archaeological potential, for reasons of age, drainage, or the presence of superior locations nearby. The Milpitas and Ohmer soils are moderately old, and both have impaired drainage because of claypan subsoils. The Milpitas soil especially has poor drainage, and is often saturated after winter rains. Milpitas loam, 3-10% slopes (Mg); Ohmer clay loam, 3-10% slopes (Oa); Ohmer Clay loam, 10-20% slopes (Oc) The Milpitas soils have an easily worked loamy surface horizon overlying, quite abruptly, a clay Bt horizon of more reddish color. This Bt horizon overlies sandy or gravelly alluvium, in some places partially consolidated, that is, becoming cemented with silica or iron in solution. The clay subsoil is a well developed Bt horizon, its sharp upper boundary, thickness, color, and substantially higher clay content (as compared to the A horizon) indicating a long period of landscape stability and soil development. The Ohmer soils are slightly less pronounced in their degree of development. Ohmer soils are darker in color at the surface, with a slightly less compact Bt subsoil. These soils are probably older than mid-Holocene, but the Milpitas soils appear to be older than the Ohmer soils, perhaps of early Holocene age. Despite their ideal geomorphic position, we would estimate the potential for deeply buried archaeological sites to be low in the Milpitas soil areas, because of their age. Since the Ohmer soils are less well developed, thus younger, we would estimate a higher probability of a Holocene paleosol buried beneath today's profile, and thus assign a moderate archaeological potential to the Ohmer soils. Older Fan soils Large areas of older fan soils lie exposed along the northeast foot of the uplands at the western edge of the Santa Clara Valley, where they have not been buried by recent fan sediments now mapped as Yolo, Zamora, and Dublin soils. Small areas of the Pleasanton and San Ysidro series are mapped within the project APE. Older fan soils, just as the older terrace soils described above, have well developed B horizons resulting from long periods oflandscape stability. Pleasanton gravelly loam, 1-3% slopes (Po); Pleasanton loam, 1-3% slopes (Ps)j Pleasanton loam, 3-10% slopes (Pr)j San Ysidro loam, 1-2% slopes (Sb) The Pleasanton soils are characterized by a thick A horizon, a loam to clay loam increase in texture from A to the rather deep Bt horizon, a slight reddening of color from A to Bt, and a "clear" boundary along the upper Bt transition, rather than an "abrupt" horizon boundary. These properties indicate moderate soil development, as opposed to strong or extreme development. The Pleasanton soils probably have a younger than mid-Holocene history. Their archaeological potential would be moderate on the west, where they border the Zamora and Dublin soils, but high in the east part of the APE, where they border San Antonio Creek. The San Ysidro soils have a strongly developed profile: a loam A horizon makes an "abrupt" transition to a clay Bt with columnar structure, bleached column tops, and continuous clay films bridging pores and coating peds. The C horizon is strongly calcareous; some of this lime is segregated. On a fan surface, these properties would Palo Alto Recycled Water Project MND 2-15 WSA/203213 indicate an older, very stable landscape history, probably early Holocene. On a valley floor, the strong profile development may indicate not only old age, but a long term regime of winter ponding and long periods of wetness after every rain. The archaeological potential of these soils is low, not only because of their age, but also because of the clayey, very firm, sticky, and very plastic properties of the subsoil, which would make habitation or use difficult and unpleasant for much of the year. Better, drier soils of the Ohmer and Milpitas series are close by, and would be preferentially favored. Survey Methods A field reconnaissance of the proposed Palo Alto Recycled Water Project (Appendix B, Figure 1) was conducted on September 17, 2007 by WSA Staff Archaeologist, Melinda Hickman, M.A. Due to the extensive development in the APE, a windshield survey was conducted. As the APE is centered almost entirely on roadways paved in concrete, a windshield survey was considered suitable for this reconnaissance. This method of surveying involves traveling through the APE in order to search for standing historic structures and undeveloped parcels of land that may exhibit evidence of buried cultural resources. The pump station that was proposed in early 2009 is situated in an area within which WSA Project Director, Eric Strother, M.A. RP A, conducted a pedestrian survey on October 30, 2006 for another proposed project at the RWQCP. The results of his survey are being used for the current proposed project. All areas identified as being potentially sensitive for cultural materials were examined for the presence of historic or prehistoric site indicators. Historic site indicators include, but are not limited to foundations, fence lines, ditches, standing buildings, objects or structures such as sheds, or concentrations of materials at least 50 years in age, such as domestic refuse (glass bottles, ceramics, toys, buttons or leather shoes), or refuse from other pursuits such as agriculture (e.g., metal tanks, farm machinery parts, horse shoes) or structural materials (e.g., nails, glass window panes, corrugated metal, wood posts or planks, metal pipes and fittings, etc.). Prehistoric site indicators include, but are not limited to areas of darker soil with concentrations of ash, charcoal, bits of animal bone (burned or unburned), shell, flaked stone, ground stone, or even human bone. No historic or prehistoric cultural resources were observed within the APE. Results ofthe Field Survey The survey will be discussed in order of pipe backbone and laterals, the three alignment options for the proposed pipeline, the booster pump station at Mayfield Soccer Fields, and finally the RWQCP. Pipe Backbone The APE for the pipe backbone consists of land developed for both residential and commercial use (see Appendix B, Figure 2). No undeveloped parcels ofland were encountered during the survey of Palo Alto Recycled Water Project MND 2-16 WSAI203213 the background right of way (ROW). In general, the APE east of Alma StreetlPark Boulevard is residential, while the sections west of this road are commercial. The commercial area consists primarily of office buildings with landscaping of grasses and trees. The eastern half of the pipe backbone is primarily residential. This section of the APE includes Fabian Way, East Meadow Drive, Cowper Street, EI Dorado Avenue and EI Carmelo Avenue (Appendix C, Photos 1 and 2). This residential area contains single-family homes on parcels with landscaped grass lawns. Commercial office buildings comprise the far eastern section of East Meadow Road Gust west of Highway 101). Due to the density of development and paved streets in this section of the pipe backbone, no cultural resources were observed. The western half of the pipe backbone is primarily commercial, composed of office buildings, a city park and complexes of buildings for various law and technology firms (Appendix C, Photos 3 and 4). This section of the APE includes Alma Street, Page Mill Road, EI Camino Real, Hansen Way, Hanover Street, California A venue, Hillview A venue and Miranda A venue. Similar to the eastern section of the pipe backbone, no cultural resources were observed due to the nature of the grass and tree cover that are the result of modern landscaping. Pipe Laterals A total of 10 areas of pipe laterals are included in the APE (Appendix B, Figure 2). These include areas on Middlefield Road, the far western section of East Meadow Road, st. Claire Drive, EI Carmelo Avenue, El Camino Real, Porter Drive, Hansen Way, Hanover Street, California Avenue, the parking lot between two office building, the southern portion of Page Mill Road, a landscaped green space between Hillview A venue and Deer Creek Road, Foothill Expressway, and Arastradero Road. The pipe lateral to be located on Middlefield Road is situated in a landscaped residential area where no cultural material was observed. The pipe lateral proposed on the eastern section of East Meadow Drive was also in a residential area where no cultural material was observed. A pipe lateral will be put in on St. Claire Drive; this is a residential area where no cultural material was observed. The pipe lateral on EI Carmelo A venue is the final pipe lateral in the residential area; no cultural material was observed on EI Carmelo A venue. The easternmost pipe lateral in the commercial area runs southeast from the intersection of EI Camino Real and Page Mill Road to the intersection of EI Camino Real and Hansen Way (Appendix B, Figure 2). At this intersection, the pipe will turn and continue southwest along Hansen Way to the bend in the road. The area on which this pipe lateral would lie is strictly commercial, with paved roads and landscaped green areas. This pipe lateral runs the same direction as alignment option three (see below). No cultural material was observed on this pipe lateral route. Another pipe lateral is proposed for a paved parking lot between two office buildings on Page Mill Road between EI Camino Real and Hansen Way. This parking lot was completely paved and no cultural material was observed. An additional pipe lateral will be placed on Hanover Street (the section northwest of Page Mill Road) and will continue south onto California Avenue. The portion of this pipe lateral on Hanover Street is located in a commercial district with office buildings. However, as this pipe lateral turns on to California A venue, the area changes to residential (Appendix C, Photo 5). No cultural material was observed in this section. This section of California Palo Alto Recycled Water Project MND 2-17 WSA12032!3 Avenue contains single-family homes with landscaped yards. No cultural material was observed in this area. A pipe lateral is proposed for the southernmost section of Page Mill Road within the APE. At the intersection of Page Mill Road and Porter Drive, the pipe turns east and continues until it terminates at the intersection of Porter Drive and Hanover Street (Appendix B, Figure 2). This section of pipe lateral continues through a developed commercial area. No cultural material was observed on this section of pipe lateral. An additional pipe lateral is proposed between Coyote Hill Road and Arastradero Road. This area is also commercial, containing office buildings with landscaped green spaces. No cultural material was observed in this area. The final proposed pipe lateral will run southeast from the intersection of Hillview Avenue and Foothill Expressway to the intersection of Foothill Expressway to Arastradero Road. At this intersection, the lateral turns and continues east along Arastradero Road where it passes Georgia A venue and terminated at the intersection of Arastradero Road and Willmar Drive (Appendix C, Photo 6). The majority of this pipe lateral will run through commercial property, while a small area is residential. The commercial area consists of the Palo Alto Veterans Affairs Hospital and Henry M. Gunn High School; the commercial area runs along the Foothill Expressway and continues along Arastradero Road. The easternmost finger of this pipe lateral, on Arastradero Road between Georgia Avenue and Willmar Drive, is residential on the west side of the street, while the east is Alta Mesa Cemetery. No cultural material was observed along this pipe lateral. Alignment Option One The APE of alignment option one begins at the intersection of East Bayshore Road and US-I0l. The APE continues along Fabian Way, then crosses Adobe Creek and proceeds onto East Meadow Drive to Middlefield Road (Appendix B, Figure 2). The western section of East Meadow Drive contains single family homes. At the intersection of East Meadow Drive and East Meadow Circle, the neighborhood changes from residential to commercial. The area of Fabian Way within the APE of alignment option one was also office buildings (Appendix C, Photo 7). Adobe Creek was observed during the survey. It has been channelized with concrete. No cultural material was observed within alignment option one. Alignment Option Two Alignment option two begins at the intersection of US 101 and Matadero Creek and travels southwest along Matadero Creek to Alma Street (Appendix B, Figure 2). The entire area of alignment option two is developed with either single-family homes or businesses. At Alma Street, the option two alignment continues northwest until it intersects Page Mill Road. Matadero Canal is located in this area of the APE. During the survey, the canal was dry. The canal was lined with concrete and no cultural material was observed in its vicinity (Appendix C, Photo 8). Matadero Creek is located in a residential area of single family homes, and runs between the fenced backyards. At Alma Street, alignment option two continues northwest The northeast side of Alma Street is composed of single family homes, while the southwest side of the street is office buildings. No cultural material was observed within the APE of alignment option two. Palo Alto Recycled Water Project MND 2-18 WSAf203213 Alignment Option Three Alignment option three includes a portion of EI Camino Real Gust south of Page Mill Road) and continues onto Hansen Way (Appendix C, refer to Photo 4). This portion of the APE is developed as a commercial area and includes office buildings with landscaped green areas of grass and trees. All land within alignment option three was developed. No cultural material observed within alignment option three. Alignment Option Four The proposed route of alignment option four runs along Colorado A venue from US Hwy 101 to Cowper Street where the street jogs west for one block (Appendix B, Figure 2 and Appendix C, Photo 9). This option follows the jog and continues along Colorado Avenue where it terminates at Alma Street. For the most part, Colorado Avenue is a residential area with the exception of the intersection of Colorado A venue and Middlefield Road. This intersection has commercial properties, such as a strip mall, a convenience store and a bank. The land on Colorado Avenue immediately surrounding this intersection changes to residential. These portions of the APE include up-scale single family homes with landscaped yards and ornamental trees and shrubs. All of Colorado A venue is paved in concrete. No cultural material was observed or encountered on the proposed route for alignment option four. Booster Pump Station at Mayfield Soccer Fields A booster pump station will be required adjacent to the western half of the pipe backbone. The booster pump station is located on the southeastern comer of the intersection of Page Mill Road and El Camino Real at the Mayfield Soccer Fields (Appendix C: Photo 10). The booster pump station location was inspected during the survey. No cultural material was observed at this location. Regional Water Quality Control Plant At the time of the field survey, the RWQCP was mostly (approximately 75%) paved and developed. Several standing buildings associated with the RWQCP facility were located at the plant. However, no historic buildings remain at the plant (50 years or older) and no cultural resources were observed in the paved area. The proposed project location in the northeast sections of the RWQCP was covered with dry grasses and weeds. Thick chaparral including Manzanita and Coyote Brush characterized the eastern and northeastern boundary of the plant, while the remaining portions of the project area were relatively open (Appendix C: Photos 11-14). Ground visibility was approximately 50%. Eucalyptus trees were observed in the northwest portion of the project area. A hand trowel was used to scrape back vegetation so that surface soils could be examined. Soil observed on the surface consisted of gravelly, silty clay that was yellowish-brown in color. The topography of the project area differed from that of the surrounding area. Imported fill deposited on the project area created a mounded, sloping terrain. Smaller dump piles of soil, some containing concrete, were observed in several areas. Modem debris was also observed throughout the project area, including bottle glass, plastic, and newspaper. Palo Alto Recycled Water Project lYfND 2-19 WSAi203213 Numerous pieces of highly fragmented historic debris, including ceramic plates, bottle glass, flat clear glass, ceramic tiles and pipe, were observed on the surface of the unpaved areas, particularly in the northern and northwestern portions of the plant. Artifacts collected include nine pieces of bottle glass from seven individual bottles, two sherds of ceramic tile, two fragments of flat glass, and three ceramic sherds, representing at least two pieces of kitchenware. It is clear from the fragmentary bottle glass that at least three of the bottles were machine-made. The first is represented by a single basal fragment with a partial embossed maker's mark (possibly a large diamond) and a portion of the circular seam often left by fully automatic bottle machines. The fragment is amber and likely came from a beer or similar beverage bottle. The second fragment, a clear basal piece, belonged to a small round bottle with a diameter of approximately I 7/8 in. A portion of the "diamond and 0" Owens-Illinois logo is visible on the base (with a '2' to the right of the mark and a '1' below it). Owens-Illinois operated in Toledo, Ohio, and this mark is typical of the period between 1929 and 1954 (Toulouse 1971:403). A separate partial mark, which includes an '8' in the central portion of the base, is also visible. The third bottle displaying evidence of its manufacturing technique is represented by two light cobalt blue fragments, which make up a substantial portion of the bottle's short neck and finish. The bottle was machine-made and the finish is externally threaded and would have been used with a threaded screw cap. The remaining bottles are represented by non-diagnostic body fragments in cobalt, clear, and amber. Two pieces of flat glass are also present. One piece includes two distinct layers of glass, one clear and one opaque white ("milk" glass). Its use is unknown. The first of the two ceramic tile sherds collected is 5116 in. thick with a buff body and white glaze. The second piece is 9/16 inches thick and has a reddish body with many small inclusions. Both green and black glaze is apparent on one side, and a maker's mark has been stamped on the reverse ('S ... / TILE'). A ceramic sherd with blue-on-white decoration was collected, as well as two sherds with green and pink decoration. All belong to small vessels, such as saucers or small bowls. Although only one of the artifacts collected contained a diagnostic maker's mark, the entire collection is consistent with the 1929-1954 date of manufacture attributed to that artifact. The R WQCP is located on fill. The sloped and mounded topography suggests that soil was moved from other areas within the RWQCP property, possibly related to facility expansion over the years. It is likely that the fragmentary historic artifacts found within the project area represent inclusions in the soils that were imported to the project area as a result of the filling process. It is also possible that the artifacts originated from the sanitary landfill, located adjacent and south of the R WQCP. The historic artifacts observed within the project area do not represent a discrete feature, however, it is possible that sub-surface historic features exist within the project area There is no surficial or archival data to suggest the presence of historic resources and their presence is considered unlikely. Although the R WQCP is located on historic fill, it is located within an area that was once marshy and that could have been attractive to prehistoric inhabitants in light of the proximity to brackish and fresh water resources. Although there is no surficial or archival data to indicate such, it is possible, but not likely, that prehistoric cultural resources exist beneath the layer of historic fill that comprises the project area. Palo Alto Recycled Water Project MND 2-20 WSA/203213 Standards of Significance CRITERIA OF SIGN1FICANCE Both the California Environmental Quality Act (CEQA) and National Historic Preservation Act (NHPA) guidelines require that the proposed project take into consideration the potential effect of the undertaking on cultural resources. In accordance with CEQA and NHP A regulations and requirements, if the project area has not been previously surveyed, or if surveyed and/or documented inadequately, a qualified archaeologist must then conduct a survey of all project components as a means of identifYing and assessing the potential impact of the project on known or predicted cultural resources. Site significance criteria are those contained in CEQA Section 15064.5 and in 36 CFR 60.4. CEQA contains provisions relative to preservation of historic (and prehistoric) cultural sites. Section 15126.4 of CEQA directs public agencies to "avoid damaging effects" on an archeological resource whenever feasible. If avoidance is not feasible, the importance of the site shall be evaluated to determine impact and develop mitigation measures. CEQA Section 15064.5 states: Generally, a resource shall be considered by the lead agency to be "historically significant" if the resource meets the criteria for listing on the California Register of Historical Resources (Pub. Res. Code SS5024.1, Title 14 CCR, Section 4852) including the following: (A) Is associated with events that have made a significant contribution to the broad patterns of California's history and cultural heritage; (B) Is associated with the lives of persons important in our past; (C) Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or (D) Has yielded, or may be likely to yield, information important in prehistory or history. Similarly, the National Register of Historic Places criteria (contained in 36 CFR 60.4) are used to evaluate resources when complying with NHP A Section 106. Those criteria state that eligible resources comprise: ... districts, sites, buildings, structures, and objects that possess integrity of location, design, setting, materials, workmanship, feeling, and association, and that (a) are associated with events that have made a significant contribution to the broad patterns of our history; or (b) that are associated with the lives of persons significant in our past; or (c) that embody the distinctive characteristics of a type, period, or method of construction, or that possess high artistic values, or that represent a significant distinguishable entity whose components may lack individual distinction; or (d) that have yielded or may be likely to yield, information important to history or prehistory. The National Register of Historic Places was established to recognize resources associated with the country's history and heritage. Guidelines for nomination are based on significance in American history, architecture, archaeology, engineering, and culture if present in resources that possess integrity oflocation, design, setting, materials, workmanship, feeling, and association. Palo Alto Recycled Water Project MND 2-21 WSA/203213 Potential Impacts and Recommended Measures Although the project area is located on land that has been developed, much of it is located within proximity to marshlands, creeks, and tributaries. This would have been attractive to prehistoric inhabitants, in light of the proximity to brackish and fresh water resources. Although there are no surficial or archival data to indicate such, it is possible, that prehistoric cultural resources exist beneath the surface within the project area. As with the potential for prehistoric cultural resources, there is no surficial or archival data to suggest the presence of historic resources, and their presence is considered unlikely. Nevertheless, ground-disturbing activities have the potential to directly impact unidentified cultural resources. Should such unidentified resources be encountered, Recommended Measure CR-l would ensure impacts to them are less-than-significant level. Measure CR-l: In accordance with CEQA Section IS064.S, if cultural resources are encountered during project-related excavations, construction shall be halted or diverted to allow an archaeologist an opportunity to assess the resource. Prehistoric archaeological site indicators include chipped chert and obsidian tools and tool manufacturing waste flakes, grinding implements such as mortars and pestles, and darkened soil that contains dietary debris such as bone fragments and shellfish remains. Historic site indicators include, but are not limited to, ceramics, glass, wood, bone, and metal remains. Although the record search and survey of the project area failed to indicate the presence of human remains within the vicinity of the proposed project, the subsurface excavation required for construction of the project could potentially disturb or destroy previously undiscovered human remains from both prehistoric and historic time periods, if they are present. This is considered a less than significant impact with the implementation of Recommended Measure CR-2. Measure CR-2: Section 70S0.S(b) of the California Health and Safety code will be implemented in the event that human remains, or possible human remains, are located during project-related construction excavation. Section 70S0 .S(b) states: In the event of discovery or recognition of any human remains in any location other than a dedicated cemetery, there shall be no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent remains until the coroner of the county in which the human remains are discovered has determined, in accordance with Chapter 10 (commencing with Section 27460) of Part 3 of Division 2 of Title 3 of the Government Code, that the remains are not subject to the provisions of Section 27492 of the Government Code or any other related provisions of law concerning investigation of the circumstances, manner and cause of death, and the recommendations concerning treatment and disposition of the human remains have been made to the person responsible for the excavation, or to his or her authorized representative, in the manner provided in Section S097.98 ofthe Public Resources Code. Palo Alto Recycled Water Project MND 2-22 WSA1203213 The County Coroner, upon recogmzmg the remains as being of Native American ongm, is responsible to contact the Native American Heritage Commission within 24 hours. The Commission has various powers and duties to provide for the ultimate disposition of any Native American remains, as does the assigned Most Likely Descendant. Sections 5097.98 and 5097.99 of the Public Resources Code also call for " ... protection of inadvertent destruction." To achieve this goal, it is recommended that the construction personnel on the project be instructed as to the potential for discovery of cultural or human remains, and both the need for proper and timely reporting of such finds, and the consequences of failure thereof. Palo Alto Recycled Water Project MND 2-23 WSA/203213 References Cited: Berlogar Geotechnical Consultants 2006 Report of January 13, 2006 to Standard Pacific Homes re Echelon subdivision, Palo Alto, California. City of Palo Alto file no. 1183. Berlogar, Long & Associates 1981 Report of March 4, 1981 re Baylands Bike Path, Palo Alto, California. Job no. 869-90. City of Palo Alto file no. 1-34. California State Office of Historic Preservation (OHP) 1976 California Inventory of Historic Resources. California Department of Parks and Recreation. 1989 Survey of Surveys. California Department of Parks and Recreation. 1990 California Historical Landmarks. California Department of Parks and Recreation. 1992 California Points of Historical Interest. California Department of Parks and Recreation. 2006 Historic Property Directory. Data File for Santa Clara County, September 18,2006, page 38. California Department of Parks and Recreation. California State Office of Historic Preservation 2006 California Register of Historical Resources. California Department of Parks and Recreation. Fredrickson, D. A. 1973 Spatial and Cultural Units in Central California Archaeology. In Toward a New Taxonomic Framework for Central California: Essays by James A. Bennyhoff and David A. Fredrickson, edited by R. Hughes, Contributions of the University of California Archaeological Research Facility 15. Berkeley. Gardner, R.A., F.F. Harradine, et al. 1958 Soil Survey of the Santa Clara Area, California. United States Department of Agriculture, Soil Conservation Service, in cooperation with University of California Agricultural Experiment Station. Series 1941, No. 17, issued June 1958. Washington D.C., Government Printing Office. J. V. Lowney & Associates 1988 Report of October, 1988 re Ford Aerospace Building, Palo Alto, California. Project no. 686-1. City of Palo Alto file no. 2-83. Kyle, D.E. 1990 Kroeber, A. L. 1925 Historic Spots in California, 4th Edition. Stanford University Press, Palo Alto, Ca. Handbook of the Indians of California. Bureau of American Ethnology ofthe Smithsonian Institution. Bulletin 78, Washington. Palo Alto Recycled Water Project MND 2-24 WSA/203213 Levy, R. S. 1978a Costanoan. In Handbook of North American Indians, edited by R. F. Heizer, pp. 485-495. vol. 8: California, W. C. Sturveyant, general editor. Smithsonian Institution, Washington, D.C. 1978b Eastern Miwok. In Handbook of North American Indians, edited by R. F. Heizer, pp. 398-413. vol. 8: California, W. C. Sturtevant, general editor. Smithsonian Institution, Washington, D.C. Moratto, M. J. 1984 California Archaeology. Academic Press, Orlando, Florida. National Park Service 2006 National Register of Historic Places. Washington, DC. Northwest Information Center of the California Historical Resources Information System 2006 Cultural Resource Record Search (File No. 06-335). Requested by William Self Associates, Inc., Orinda, California, October 23, 2006. Toulouse, Julian H. 1971 Bottle Makers and Their Marks. Thomas Nelson, New York, NY. William F. Jones, Inc. 1980 Report of May 27,1980 to the Carl Holvick company, re Smith Property Office Building (now 3805 E. Bayshore Road), Palo Alto, California. File no. 180052.1. City of Palo Alto file no. 1-13. Maps: General Land Office Plat Map (GLO) 1883 T55 R2W Mount Diablo Base Meridian. Rancho Rinconada del Arroyo de San Francisquito Plat Map 1861 Confirmed to Heirs of Maria Antonia Mesa. Thompson and West 1876 Historical Atlas Map of Santa Clara COW1ty, California. San Francisco. United States Geologic Survey (USGS) 1899 Palo Alto Quadrangle Topographic Map (reprinted in 1906). Palo Alto Recycled Water Project MND 2-25 WSA/203213 Appendix A Native American Contact Information WSA Consultants in Archaeology and Historic Preservation www.williolmself.wm August 31, 2007 Native American Heritage Commission 915 Capitol Mall, Room 364 Sacramento, CA 95814 RE: CULTURAL RESOURCES ASSES:r;kIElv'T OF THE PALO ALTO RECYCLED Jf<11ER PROJECT (PROJECl). PALO AL1V. SANTA CLARA COUNTY, CALIFORNIA De1r Native American Heritage Conmlission: William Self Associates, Inc. (WSA) has been contracted by Rl'\lfC to conduct a cultural resources assessment for the Palo Alto Regional Water Quality Control Plant's expansion of its regional recycled water system in the City of Palo Alto. The project area is located within an ullsectioncd portion of Township 6S. Range 2W, in Santa Clara COUllty. as depicted on the attached map. We bring this project to the attention of the Native American Heritage Conunission with the desire to obtain, from your office, pertinent infommtion reg'lrding prehistoric, historic and/or ethnographic land use and sites of Native American traditional or cultural value that might be known to exist within the project vicinity, as depicted in the Sacred Lands database or other tiles. We would also appreciate obtaining a list of interested Native American tribal entities or individuals for the project area. We have made contact with the California HistOlical Resources Information System at Sonoma State University to review their files as part of the background research 011 the project. We would appreciate a response, at your earliest convenience, should you have infonuation relative to this request. Should you have any questions, 1 can be reached at (925) 253-9070. Thanks again tor your assistance. Sincerely, WILLIAM SIU;I<' ASSOCIATES, INC. James M. Allan, Ph.D., RPA Vice-President Attachment William Self Associates, 1nc. E-mail: ,y~elJ@:Wi1Jj;UlJl;dfj;QIJJ CORl'ORATE OFFI(;E: San Francls() Bay Area PO 80)( 2192. 61 A VCllida de Orinda Orinda CA 94563 Phone: 925·253-9010; 925·254·3553 lax 09(13;2007 11:2u FAl 918 657 3390 ~AHC Jakld Kehl 720 North 2nd Street Patterson , CA 95363 jakki@bigvalley.net (209) 892-2436 (209) 892~2435 • Fax Amah MutsunTribal Band Valentin Lopez, Chairperson 3015 Eastern Ave, #40 Sacramento ,CA 95821 vIQpez®amahmutsun.Ofg (916) 481-5785 Amah MutsunTribaf Band Edward Ketchum 35867 Yosemite Ave Davis , CA 95616 aerieways@aotcom AmahlMutsun Tribal Bana Native American Contacts Santa Clara County September 12, 2007 AmahiMutsun Tribal Band Irene ZWierlein. Chairperson Ohlone/Costanoan 789 Canada Road OhloneiCostanoan Woodside , CA 94062 amah_mutsun@yahoo.com (650) 851-7747 -Home (650) 851 .. 1489 -Fax Indian Canyon Mutsun Sand of Costanoan Ann Marie Sayers, Chairperson Ohlone/Costanoan P.O. Box 28 OhlonelCostanoan Hollister , CA 95024 ams@garlic.com 831-631-4238 Muwekma Ohlone Indian Tribe of the SF Say Area Rosemary Cambra, Chairperson Ohione/Costanoan PO Box 360791 Ohlone I Costanoan Northem Walley Yokuts Milpitas , CA 95036 muwekma@muwekma.org 409-434-1668 40Q..434~1673 Michelle Zimmer, Cultural Resource Coordinator The Ohlone Indian Tribe Andrew Galvan POBox 3892 OhionelCostanoan Clear Lake I CA 95422 408-3754281 this 11&11& curront only !IS of the date Qf ihl& document. PO Box 3152 Mission San Jose. CA 94539 chochenyo@AOLcom (510) 656-0787 -Voice (510) 882-0527 -Cell (510) 681-9393 -Fax Ohlone/Costanoan BayMiwok Plains Miwok Patwin Distribution (It tb1911Gt does not rellflYe any person of GU!tutory t$GpOnstlllllty M (IefiMd In Sectlon 1050.5 of tl'le Health and S6fMY Code, $eotIon 5097.94 (If ttI$ Public IlUourcell Code and Section 5097.98 of the Public Raso_ Code. This IIGt Is oniy aPJ',lllcabie for cofIfacUng lOCal N$tIve Amoricans with reoard to cultum! resoun:etJ fOrtfte propoBlld j'Iafo AtID RIIcycIIId WOlf ptOjeet, Slinta ClMl County. 09:1S/2007 11:20 FAX 916 657 5.39a NARC Native American Contacts Santa Clara County September 12, 2007 Trina Marine Ruano Family Ramona Garibay, Representative 16010 Halmar Lane Ohlone/Costanoan Lathrop • CA 95330 Bay Miwok 510-300-5971 -cell Plains Miwok Patwin Thls list Is current only as of the date of this dO¢umel'lt tllstributlon (If thlallst does not rell(.!VI!) ttnv person of statutory reGpo/l$lblllty;!l$ defined 111 See-tlon 7'050.5 01 the Health and SOfcty Cooo. $OC1lon 5097.94 I1f the PublIC Aesourees Code ilnd Swtfoo 5007.00 Of th* Public R~ Oode. Thls list Is only applicable for contactlnsllocal Nlrtlve AmettcatUl with regard to c;ultural nl6OUl"OOS for the proposed Palo Alto Recyc;1ed WQ1()( proJect. Santa Clam Oounty. l4lo0.) WSA September 18, 2007 Jakki Kchl 720 North 2nd Street Patterson, CA 95363 Consultants in Re: Proposed Palo Alto Recycled Water Project, Santa Clara County Dear Ms. Kehl, and Historic Preservation William Self Associates, Inc. (WSA) has been contracted by RMC to conduct a cultural resources assessment for the Palo Alto Regional Water Quality Control Plant's expansion of its regional recycled water system in the City of Palo Alto. The project area is located within an unsectiol1cd portion of Township 6S, Range 2W, in Santa Clara County, as dt.-picted on the attached map. A record search of the sacred land file conducted by the Native American Heritage Commission (NAHC) failed to indicate the presence of Native American cultural resources in the immediate project area. However, the NAHC provided your name as a person who may have knowledge of sllch resources in the project area. WSA, on behalf of RMC and the RWQPC, would appreciate receiving any comments you may have regarding cultural resources or sacred sites issues within the immediate project area. If you could provide your comments in writing to the address below. or call our Native American coordinator, Mr. Eric Strother, we will make sure the comments are provided to the R WQPC as part of the environmental assessment of the project. Thanks for your assistance. Sincerely, Attachment P.O. Box 2192 61d Avenida de Orinda Orinda CA 94563 William Self ASSOCiates, Inc. Phone: 925-253-9070 Fax: 925-254-3553 Email;jlllllln(i9williamselfllSsoc.com Native American Contact Jakki Kehl Michelle Zimmer AmahlMutsun Tribal Band Valentin Lopez Amah Mutsun Tribal Band Irene Zwierlein AmahlMutsun Tribal Band Edward Ketchum Amah Mutsun Tribal Band Ann Marie Sayers Indian Canyon Mutsun Band of Costanoan Rosemary Cambra Muwekma Ohlone Indian Tribe Andrew Galvan The Ohlone Indian Tribe Ramona Garibay Trina Marine Ruano Family Palo Alto Recycled Water Project Record of Native American Contacts and Comments Addresses withheld to protect privacy DATE OF Response Date of NOTIFICATION to Letter Phone Comments LETTER (Date) Contact 9/18/07 No 10/02/07 Would like more info on project Response (Le. results of record search, map Letter of area and project description) 9/18107 No 10/02/07 Stated a high number of burials Response were encountered in this area of Letter Palo Alto and is likely to recommend construction monitoring and a Native American Monitor 9/18/07 No 10/02/07 Stated this project is out of his Response tribal area Letter 9/18/07 No 10/02/07 Left Message Response Letter 9/18/07 No 10/02/07 No phone number provided Response Letter 9118/07 No 10102/07 Likely will recommend Response construction monitoring and a Letter Native American Monitor, asked to be notified when earth movement begins and suggested Jasper Ridge Biological Preserve as a possible re-interment site for human remains (if needed) 9/l8/07 No 10102/07 No answer or means to leave a Response message Letter 9118/07 No 10102/07 Likely will recommend Response construction monitoring and a Letter Native American Monitor 9/18/07 No 10/02/07 Phone number was out of service Response Letter AppendixB: Maps of Project Area Project Vicinity Map WSA Figure 1 RMC Palo Alto Recycled Water Project Palo Alto, CA ~ ..... V:<>S((.uad~ WSA Project Location and Site Plan Map 0,,25 0.,5 1.5 _ _ Miles Palo Alto R""ycied Water Project Palo Alto, CA Appendix C Photographs Photo 1: Alignment of the pipe backbone at Cowper Street from the intersection of St. Claire Drive and Cowper Street view east. Photo 2: Alignment of pipe backbone at EI Dorado Avenue at the intersection of EI Dorado Avenue and Cowper Street view west. Photos 1 and 2 RMC Water & Environment Palo Alto Recycled Water Palo Alto, California Photo 3: Pipe backbone at Hillview Avenue between Hanover Street and Foothill Expressway view north. Photo 4: Pipe backbone/alignment option three at EI Camino Real at the intersection ofEI Camino Real and Hansen Way view north. Photos 3 and 4 RMC Water & Environment Palo Alto Recycled Water Palo Alto, California Photo 5: Pipe lateral route proposed for California Avenue view east. Photo 6: Pipe lateral route at the intersection of Arastradero Road and Georgia A venue view west. Photos 5 and 6 RMC Water & Environment Palo Alto Recycled Water Palo Alto, California Photo 7: Alignment option one at the intersection of East Meadow Road and Fabian Way view north. Photo 8: Alignment option two at Matadero Creek and Cowper Street view southwest. Photos 7 and 8 RMC Water & Environment Palo Alto Recycled Water Palo Alto, California Photo 9: Alignment option four and the intersection of Colorado Avenue and Louis Road view southwest. Photo 10: Booster Pump Station location at El Camino Real and Page Mill Road, view north. Photos 9 and 10 RMC Water & Environment Palo Alto Recycled Water Palo Alto, California Survey Photo 11: Northeast section of the RWQCP, view to the west. Survey Photo 12: Northeast section of the RWQCP, view to the southwest. Photos 11 and 12 RMC Water & Environment Palo Alto Recycled Water Palo Alto, California Survey Photo 13: Northeast section of the RWQCP, view to the south. Survey Photo 14: Northeast section of the RWQCP, view to the east Photos 13 and 14 RMC Water & Environment Palo Alto Recycled Water Palo Alto, California APPENDIX E HAZARDOUS MATERIALS EnviroStor Database Page 1 of 1 EnviroStor Database -I:1ACK_"[QJ;Nv:tRQS"[QR.HOME REPORT TIPS STATUS: All Statuses r~()l SEARCH CRITERIA: PALO ALTO, FEDERAL SUPERFUND SITES (NPL), STATE RESPONSE SITES, VOLUNTARY CLEANUP SITES, SCHOOL CLEANUP SITES PROJECT SEARCH RESULTS 15 RECORDS FOUND EXPORT TO EXCEL PAGE 1 OF 1 SITE NAME SlLE .. T'iI".E SIAIIJ.S ADDRESS. CITY ZlE .c.o.u.NIY 11EliCJ~.!E.nQN STATE CERTIFIED I OPERATION & 3180 HANOVER PALO SANTA AYDIN ENERGY MAINTENANCE LAND USE 94304 RESPONSE RESTRICTIONS STREET ALTO CLARA COHERENT INC STATE CERTIFIED I OPERATION & 3210 PORTER DR PALO 94304 SANTA RESPONSE MAINTENANCE ALTO CLARA HEWLETT PACKARD STATE REFER: RWQCB 1501 PAGE MILL ROAD PALO 94304 SANTA RESPONSE ALTO CLARA HEWLETT PACKARD STATE CERTIFIED I OPERATION & 3215 PORTER DRIVE PALO 94304 SANTA BUILDING 15 RESPONSE MAINTENANCE ALTO CLARA HEWLETT PACKARD STATE CERTIFIED I OPERATION & CORNER OF PAGE MILL PALO SANTA BUILDINGS 28A, B, AND RESPONSE MAINTENANCE RD AND PORTER ALTO 94304 CLARA C DRIVE HEWLETT-PACKARD (620-FEDERAL 620-640 PAGE MILL PALO SANTA SUPERFUND -REFER: RWQCB 94304 640 PAGE MILL ROAD) LISTED ROAD ALTO CLARA HILLVIEW PORTER STATE CERTIFIED I OPERATION & HILLVIEW AVENUE AND PALO 94304 SANTA PLUME RESPONSE MAINTENANCE PORTER DRIVE ALTO CLARA LOCKHEED MISSILES AND STATE CERTIFIED I OPERATION & 3170 PORTER DRIVE PALO 94304 SANTA SPACE CO BLDG 255 RESPONSE MAINTENANCE ALTO CLARA SMITHKLlNE AND FRENCH STATE CERTIFIED I OPERATION & 3400 HILLVIEW PALO 94304 SANTA LABORATORIES RESPONSE MAINTENANCE AVENUE ALTO CLARA SYNTEX STATE CERTIFIED I OPERATION & 3300 HILLVIEW AVE PALO 94304 SANTA RESPONSE MAINTENANCE ALTO CLARA TELEDYNE MEC STATE CERTI FlED I OPERATION & 3165 PORTER DR PALO 94304 SANTA RESPONSE MAINTENANCE ALTO CLARA TELEDYNE SINGER STATE CERTIFIED I OPERATION & 3176 PORTER DRIVE PALO 94304 SANTA RESPONSE MAINTENANCE ALTO CLARA VARIAN STATE CERTIFIED I OPERATION & 611 HANSEN WAY PALO 94304 SANTA RESPONSE MAINTENANCE ALTO CLARA WATKINS JOHNSON STATE CERTIFIED I OPERATION & 3333 HILLVIEW PALO 94304 SANTA COMPANY (SRP) RESPONSE MAINTENANCE AVENUE ALTO CLARA ZOECON/RHONE-FEDERAL EAST SAN POULENEC SUPERFUND -REFER: RWQCB 1990 BAY ROAD PALO 94303 MATEO LISTED ALTO DfSCLAIMER PLEASE EMAIL US WIlli YOUR SUGGESTIONS AND/OR COMMENTS 0.1171875 seconds http://www.envirostor.dtsc.ca.gov/public/search.asp?crnd=search&city=palo%20aito&zip... 10/11/2007 ORDINANCE NO. 5002 . ORDINANCE OF THE COUNCIL OF THE CITY OF PALO ALTO ADDING CHAPTER 16.12 (RECYCLED WATER) TO TITLE 16 OF THE PALO ALTO MUNICIPAL CODE TO REQUIRE THE USE OF RECYCLED WATER FOR IRRlGATION, TOILET AND URINAL FLUSIDNG AND TRAP PRIMING The Council of the City of Palo Alto does ORDAIN as follows: ATTACHMENT G SECTION 1. Findings and Declarations. The City Council finds and declares as follows: (a) Potable water is one of our most precious natural resources and is becoming increasingly scarce in the semiarid State of California (b) The use of treated, nonpotable water for construction, toilet and urinal flushing and irrigation will increase the amount of potable water available for other uses in the City. The City of Palo Alto is dedicated to conserving the potable water supply, and this Chapter will assist in preserving this precious conunodity. (c) Recycled water is. a sustainable water source that reduces potable water consumption and is not subject to rationing during drought. After careful study, the City Council has determined that recyCled water shall be used within the boundaries of Recycled Water Project Areas for construction, toilet and urinal flushing and irrigation purposes whenever it is available and beneficial to the customer. (d) In adopting this program, the Council has balanced the needs of all water users and through this ,implementation strategy will allow water users sufficient flexibility to meet their potable and nonpotable water needs. // /I 1/ II II II II II 1 080S 14 syn 60S0416 SECTION 2. A new Chapter 16.12 is hereby added to Title 16 of the Palo Alto Municipal Code to read as follows: SectioDS: 16.12.010 16.12.015 16.12.020 16.12.025 16.12.030 16.12.035 16.12.040 16.12.045 16.12.050 16.12.055 16.12.060 16.12.065 16.12.070 16.12.010 (a) (b) (c) (d) (e) (f) 080514 syn 6050416 Definitions. CHAPTER 16.12 RECYCLED WATER Compliance with state and local regulations. Converting existing potable water users to recycled water for irrigation. Converting existing potable water users to recycled water for toilet and urinal f flushing and trap priming. New construction; recycled water for irrigation. New construction; recycled water for toilet and urinal flushing and trap priming. Recycled water permit required. Recycled water pennit conditions; verification of compliance. Exemptions and adjustments. Appeals. Failure to comply with this chapter. Monitoring. . Severability DefiDitioDs. "Dual plumbing" means a system of two sets of water pipes, one for recycled water for toilets and urinals and one for potable water for other interior uses. "F1oortrap priming" means the practice of adding water to traps beneath floor drains to ensure a barrier from sewer gas. . "Identified Customers" are entities purchasing water from the City of Palo Alto who are adjacent to a recycled water pipeline shown in a Final Palo Alto Recycled Water Project Plan. Identified customers do not include single family residences. "Recycled water' means wastewater treated by the Palo Alto Regional Water Quality Control Plant that meets State requirements for reuse. "Recycled Water Permit" means a permit issued by the City Manager or hislher designee to allow a customer to use recycled water at its facility. "Recycled Water Project Area" means a geographical area of the City designated by resolution of City Council as an area where recycled water will be served. 2 16.12.015 Compliance with state an-d local reglJlationtt. All users of recycled water shall comply with the California De?artment of Public Health regulations contained in Title 17 and Tide 22 of the California Code of Regulations, and with the Palo Alto Water Reuse Rules and Regulations for the use of recycled water. 16.12.020 Converting existing potable water users to recycled water for irrigatlon. ,Within the boundaries of any Recycled Water Project Area. Identified Customers who are notified by mail by the City shall use recycled water for irrigation when available. Any such notification shall include the (;onditions of llSC, pricing, and construct.ion -schedule for the City's recycled water pipeline and the connections to it. ' 16.12~025 Converting existing potable water users (with existing dual plumbing) to recycled water for toilet and urinal flushing and floor trap priming. For facilities with existing dual plumbing within the boundaries of any Recycled Water Project Area. Identified Customers shall use recycled water when it is available following notification by mail by the City that a conversion to recycled water for toilet and urinal flushing and floor trap priming purposes is required. Any such notification shall include the conditions of use, pricing, jUld construction schedule for the City' 5 pipeline and the connections to it. 16.12.030 (a) New construdioD;recycled water use for irrigation. All applications for land use permits, building permits and other discretionary actions for projects other than single family homes. within the boundaries of any Recycled Water Project Area, filed after the adoption of this ordinance, shaH include the following: (1) Plans demonstrating that recycled water will be used, when available, for all irrigation. (2) Consideration of plants suitable for irrigation with recycled water. (3) The installation of the on-site infrastructure necessary to connect the irrigation system to the City's recycled water supply when it becomes available. (b) All applications for land use pennits. building pennits and other discretionary actions for projects other than single family homes. in geographic areas not within the boundaries of a Recycled Water Project Area, where the total landscape area exceeds 1500 square feet, filed after the adoption of this ordinance, shall include the following: Og0514 syn60S0416 (1) Plans demonstrating that recycled water will be used, when available, for all irrigation. (2) Consideration of plants suitable for irrigation with recycled water. 3 (3) The installation of on-site infrastructure necessary to connect the site' s irrigation system to the City's recycled water supply when it becomes available. 16.12.035 New eonstrudiofl; recycled water use for toilet and urina] flushing and floor trap priming. (a) All applications for building pennits for new or remodeled buildings or groups of buildings within the boundaries of a Recycled Water Project Area, filed after the adoption of this ordinance, where the building square footage total, including both the original square footage and any addition, is greater than 10,000 square feet or where installation of 25 or more toilets and urinals is proposed, shall" incorporate dual plwnbing in the design of the facility to allow the use of recycled water, when it becomes available, for flushing toilets and urinals and priming floor traps. Dual plwnbing requirements shaH not apply to single family homes. (b) All applications for building pennits for new or remodeled buildings or groups of buildings in geographic areas not witWn the boundaries of a Recycled Water Project Area, filed after the adoption of this ordinance, where the·building square footage total, including both the original square footage and any addition, is greater than 100,000 square feet or where installation of 100 or more toilets and urinals is proposed, shall incorporate dual plumbing in the design of the facility to allow the use of recycled water, when it becomes available, for flushing toilets and urinals and priming floor traps. Dual plumbing requirements shall not apply to single family homes. (c) When dual plumbing requirements are triggered by remodeling, only those restroom facilities located within the remodel project area shall be required to incorporate dual plumbing. 16.12.040 Recycled Water Permit required. Upon Written notification pursuant to Sections 16.12.020 and 16.12.025 that recycled water is available and must be used, the recycled water customer shall obtain a Recycled Water Pennit by submitting a Recycled Water Pennit application, which shall include plans detailing the recycled and potable water distribution systems at the facility. A City representative shall review the plans and conduct a field inspection before the Recycled Water Penn it is issued. The applicant m,ust make any required changes as directed by the City before a Recycled Water Pennit may be issued. 16.12.045 Recycled water permit conditions; verification of compliance. The recycled water permit shall specify the requirements for the applicant's use of recycled water based on the Water Reuse Rules and Regulations adopted pursuant to 16.12.015, and shall require compliance with the California Department of Public Health regulations contained in Title 17 and Title 22 of the California Code of Regulations and with any additional requirements specified by the State Water Resources Control Board. Recycled water shall not be 4 080514 syn 6050416 f supplied to a facility until inspection by a City representative determines that the applicant is in . compliance with the pennit conditions. 16.12.050 ExemptiOI:tJ and adjustments. An application for an exemption or an adjustment to the requirements of this chapter shall be made to the Director of Public Works or hislher designee. Requests for an exemption or adjustment may be made consistent with state law and shall be based on the finding by the Director of Public Works that the use of recycled water demonstrates an adverse effect to the applicant's landscaping installed prior to the effective date of the ordinance codified herein. The Din~ctor of Public Works may ;:Uso COlisidcr any additional fadors, iududing any spcdnl costs or hardships which may be created by the use of recycled water. A written detemlination will be made on all requests for exemptions or adjustments within ten (10) business days and mailed to the applicant. If the exemption or adjustment is not granted, the applicant must fully comply with the requirements of this section. 16.12.055 Appeals. Denial of any application for an exemption and/or adjustment to the provisions of recycled water use may be appealed to the City Manager or hislher designee, whose decision shall be final. An application for appeal shall be filed with the City Clerk in writing within ten (10) business days after the Director of Public Works' decision and shall state the specific , grounds for the appeaL The City Manager or hislher designee shall hear the appeal within sixty (60) calendar days after the appeal has been filed with the City Clerk and shall issue a written decision within thirty (30) days. 16.12.060 Failure to comply with this chapter. In addition to existing penalties in state and local law'for violation of the provisions of this chapter, the City Manager or hislher designee may assess the following penalties, subject to the appeal provisions set forth above: (a) A water service surcharge of fifty percent (50%) of the general water service rate, as set forth in Utility Rate Schedule, for each billing period during which potable water is use.d:fot. i.rri3auon. (b) Continued use of potable water for inigation, after a written warning by the City Manager or hislher designee, may result in the discontinuation of water service supplied for irrigation by the City of Palo Alto following a noticed hearing. A charge as set forth in the City's administrative fee schedule shall be paid prior to the reactivation or restoration of water service. (c) Any use of recycled water in a manner contrary to the provisions of this title, is hereby declared to be a nuisance and may be abated in the manner provided for the abatement of nuisances in Chapter 9.56 of the Palo Alto Municipal Code. 5 O!OS 14 syn 6050416 16.12.065 Monitoring. Representatives of the City and the San Francisco Bay Regional. Water Quality Control Board shall be authorized to enter, the premises of any recycled water user to carry out inspections and monitoring to assure compliance with this chapter and applicable state of California regulations. 16.12.070 Severability. If any provision or clause of this chapter is held to be unconstitutional or otherwise invalid by any court of competent jurisdiction, such invalidity shall not affect other provisions of this dU.lpter, and clauses of this (~hapter are declared to he severable. SECTION 3. The Council hereby finds this ordinance is categorically exempt from the requirements of the California Environmental Quality Act ("CEQA") pursuant to Sections 15307 and 15308 of the CEQA Guidelines (exempting actions taken by regulatory agencies for the protection of natural resources and the environment), and pursuant to Sections 13554 and 13552.4 of the California Water Code (exempting projects which involve the repiping, redesign, or use of recycled water necessary to comply with a requirement to use recycled water for toilet and urinal flushing or residential landscaping). II /I /I. /I II II II II II II II /I II 6 080514 syn60S0416 SECTION 4. This ordinance shall be effective on the thirty-first day after the date of its adoption. INTRODUCED: PASSED: AYES: NOES: ABSENT: ABSTENTIONS: April 28, 2008 May 12, 2008 BARTON, BURT, DREKMEIER, ESPINOSA, KISHIMOTO, KLEIN, MORTON, SCH.MID, YEH APPROVED AS TO FORM: ( ~'c! 'W. 801"lwL 15;puty ty Attorney 7 080514 syn 6050416 -..J -C) E -t/) "C .- 0 CI) "C (1) .2= 0 t/) .!!! 0 CG -0 I- 1200 1000 800 600 400 200 RWQCP Recycled Water Annual Average Total Dissolved Solids: 1993 ~ 2008 (short and long term projections included) Estimated TDS in 5-10 years if salt water infiltration fully agency resources O+------------,------------~------------,_------------r_----------~------~ 1990 1995 2000 2005 Year 2010 2015 ::x:---I --I ::x:- C"> :::::c :s:: rn ::z: --I ::::x:: TO: FROM: DATE: SUBJECT: BEQUEST ATTACHMENT I City of Palo Alto City Manager's Report H0NORABLE CITY COUNCIL CITY MANAGER DEPARTMENT: PUBLIC WORKS APRIL 24, 1995 C.MR:217:95 WASTEWATER RECLAMATION PROGRAM M_ FINDINGS and RECOMMENDATIONS This staff report requests that CoUncil certify the Wastewater Reclamation Environmental . Impact Report (EIR), but suspend the implementation of the projects included in theEIR .. It also requests that Council adopt a new Reclamation Policy. . In view of the uncertainties with respect to the need. for additional reclamation, it is recommended that the existing reclaimed water program not be expanded at this time. Future evaluation of the individuat projects in the EIR would be triggered by the conditions outlined in the Reclamation Policy of this rq>art. The Planning Commission has taken public comments and reviewed and approved the draft EIR as adequate under CEQA .. CMR:547:93, October 21, 1993, referred the wastewater reclamation program to the Utilities Advisory Commission (UAci for study· and recommendations. The reconimendation and the Reclamation Policy have been reviewed and approved by the UAC. Staff will bring back individual projects for review by the UAC and Council if and when an evaluation is triggered . . RECOMMENDATIONS Staff recommends that Council: 1. Certify that the final Environmental Impact Report (EIR) has been completed in compliance· with CEQA. and that it reflects the independent judgment of the Council. 2. Suspend iJnplementation of any of the projects studied in the EIR, and instead adopt a Reclamation Policy which includes continuation of the existing reclaimed water CMR:217:9S Page 1 of 11 . program and monitoring of the conditions that would trigger the future evaluation of the projects studied in the EIR. 3. Direct that at such time as staff believes that conditions exist which would trigger further evaluation of the projects, staff will submit s~ch information to the Utilities Advisory Commission for its review and recommendationS prior to submittal of the matter to the Council. 4. Direct staff to inform the UAC, and initiate the appropriate evaluations on any such triggered project, and submit the evaluations for review by the UAC and Council. POLICY IMPLICATIONS The City is firmly committed to protect the environment, using the most viable and cost effective approach. The Reclamation Policy is a· new policy which embodies this. commitment. The Reclamation Policy is consistent with the Watershed Management approach which ~ for the re-consideration of water quality standards, prior to individual project decisions, where the water q~ality standards are factors in the decision making process. The Reclamation Policy enumerates the conditions that would trigger future evaluation of the individual projects included in the EIR. The Reclamation Policy is consistent with the State policy, the Basin Plan for the Bay Area communities,and Palo Alto's Comprehensive Plan. Adoption. of the Reclamation Policy would allow the City to monitor and initiate future evaluations as needed. EXECUTIVE SlI\\fMARY This staff report provides the policy recommendations on the ~ogram.. The Program planning was initiated by the Regional Water Quality Control Plant (RWQCP) as a . requirement of the partner cities to serve two objectives: . 1. To reduce metals discharge to the Bay in order to meet the mass limit of the RWQCP discharge permit, and 2. To supplement the water supply. In 1994, the RWQCP met the permitted mass limits as a result of the combined efforts of source control, in-plant reduction, and the .~xisting reclamation. However, the RWQCP cannot guarantee future compliance for two reasons. First, the permit limits are being re- evaluated and may change. Second, the RWQCPoperated under very favorable low-flow conditions in 1994, which may change in the future. Therefore, it is necessary to keep the reclamation program expansion as an option for future re-evaluation. Another factor to consider is th~ concentration limit, which is also in the RWQCP permit. Reclamation reduces only the mass discharge and will not. reduce the discharge CMR:217:95 . Page 2 of 11 concentration. The concentration limit is also being re-evaluated at this time. More information will be available in the future for the evaluation on the need for' additional reclamation. From the wastewater discharge perspective, no further reclamation project is recommended at this time, but it is necessary to establish a policy which will enable reclamation as an option for future permit compliance if needed. From the water supply perspective, current water demand is below the City's supply capacity. The Utilities Department Integrated Resource Plan identified reclamation as one of several alternatives to supplement the future water supply. Although future demand may ex.ceed the City's supply, a recent market survey does not indicate substantial demand for reclaimed water. Therefore, no reclamation project is recommended at this time. However,the City should include reclamation as aD. option for future water supply evaluation. The proposed Reclamation Policy sets the following guidelines: . 1. The RWQCP will maintain the current reclamation projects (Shoreline Park, Greer Park, Palo Alto Golf Course, and water truck hydrants) . . 2. Evaluation of the projects covered in the EIR cOuld.be triggered by the following conditions: • Changes in the RWQCP discharge permit requirements • Increased mass loading to the RWQCP, • Requests by partner agencies or'other local agencies • Availability of federal or other funds • Supply side issues FISCAL IMPACT The Program poses no fiscal impact to the current fiscal year since no project is recommended for implementation at this time. The fiscal impacts of the Program will be addressed when, and if, a project under the Program is submitted for approval in the future. . ENVIRONMENTAL ASSESSMENT An environmental impact report (EIR) was prepared in accordance with CEQA. The EIR found no un-mitigable impact. The Utilities Advisory Commission has reviewed and commented on,the draft EIR. A public hearing was held on December 14, 1994 before the Planning Commission. The Planning Commission has taken public comments, and reviewed and approved the draft EIR as adequate under CEQA. A copy of the transcript of the public hearing is attached to this staff report. The final EIR is also being submitt~ concurrently to Council for certification. CMR:217:95 Page 3 ofll ATfACHMENTS Transcript of the Dec. 14,1994 public bearing Final Wastewater Reclamation EIR PREPARED BY: William D. Miks, Manager, Water Quality Control PlaIit J J. J. ,. DEPARTMENT HEAD REvmw:_-f!).~~I--~~~~ __________ _ CITY MANAGER APPROV AL: __ ~.j..-:~~~I-£-=~ ... " ........ !......-__ _ CMR:217:95 Page 4 of 11 City of Palo Alto City Manager's Report· SUBJECT: RWQCP Wastewater Reclamation Program _. Findings . and Recommendations . RECOMMENDATIONS Staff recommends that Council: " 1. Certify the fInal Environmental Impact Report (EIR) has been completed in compliance with CEQA, . and that it reflects the independent judgment of the Council. 2. Suspend implementation of any of the projects studied in the EIR, and instead adopt a Reclamation Policy which inclUdes continuation of the existing reclaimed water . program and momtoring of the conditions that would trigger the future evaluation of the projects studied in the EIR. . 3. Direct that at such time as staff believes that conditions exist which would trigger further evaluation of the projects, staff will submit such infonnation to the Utilities Advisory Commission for itS review and recommendations prior to sulnntttaI of the matter to the Council. 4. Direct staff to inform the UAC and initiate the appropriate evaluations on the trigger project and submit the eval1;18-tions for review by the UAC and Council. BACKGROUND . The Reclamation Program (Program) planning was initiated by the Regional Water Quality Control Plant (RWQCP) as a requirement of the partner cities to serve two objectives: 1. To reduce metals discharge to the Bay in order to meet the mass limit of the RWQCP discharge permit requirement, and 2. J'o supplement the water supply. The RWQCP discharge permit contains amass limit and a concentration limit on each pollutant. Among the pollutants,. the RWQCP has the greatest difficulty in meeting the . permit limitS for copper .. The RWQCPreduces its metals discharge through the combined efforts of source control, 'in-plant reduction, and reclamation. Source control reduces the concentration and, consequently, the mass of the metals in the influent to the plant. In~ CMR:217:9S Page 5 of 11 plant reduction reduces the.concentration and the mass prior to discharge; however, the reduction efficiency is dependent"on the loading of the plant. Reclamation diverts the plant discharge for reuse and, hence, reduces the mass;· but this has no effect on the discharge concentration. In 1994, the RWQCP met the mass limit for copper as a result of the combined efforts of source control, in-plant reduction and existing ~eclamation projects. However, the RWQCP cannot guarantee future compliance for two reasons. First, the permit limits are b~ing re-evaluated, and future requirements are not yet certain. Second, the RWQCP operated under very favorable conditions in 1994 --near record low flow, and, consequently, at a record high in-plant reduction efficiency. These favorable conditions may change in the future. The City needs to ensure that reclamation projects are available as an option for future compliance. To meet the concentration limit, the RWQCP launched a very aggressive source control program. In 1994, the RWQCP achieved a record high in-plant metals reduction effiCiency. Despite these efforts, the RWQCP has not been able to meet the copper concentration limit. The RWQCP continues to seek alternatives that will reduce the copper concentration. For as long as the concentration limit is more stringent than the mass limit, additional reclamation would not ensure full compliance. However, the concentration limit is also being re-evaluated at this time. More Information will be available in the future for the evaluation of the need for additional reclamation. From the discharge perspective, further reclamation projects are not recommended at this time. It is recommended that the . . . proposed policy be adopted to enumerate the conditions that would trigger future re- evaluation. From the watersupply perspective, the City's water demand is currently below its supply capacity. The Utilities Department conducted a study to evaluate supply-side and demand- side alternatives for the future water supply. The study, titled the Integrated Resource Plan, identified reclamation as one of several alternatives to supplement future water supply. Although it is anticipated that future water supply will be limited and more costly, a recent market survey does not indicate substantial demand for reclaimed water. Hence,· ~o project is recommended at this time. However, future water supply requirements may trigger further evaluation of reclamation projects in the Program. The City should include reclamation as an option for future water supply evaluation. POLICY IMPUCATIQNS The City is frr:nlJ.y committed to protect the environment using lbe most viable and cost effective approach. The Reclamation Policy is a new policy which embodies this commitment. The Reclamation Policy is consistent with the Watershed Management approach· which calls for the re-consideration of water quality standards, prior to individual project decisions where the water quality standards are factors in the decision making CMR:217:95 Page 6 of 11 process. The Reclamation Policy enumerates the conditions that would trigger future evaluation of the individual projects included in the EIR. The Reclamation Policy is consistent with the State policy , the Basin Plan for the Bay Area· communities, and Palo Alto's Comprehensive Plan. Adoption of the Reclamation Policy would allow the City to monitor and initiate future evaluations as needed. DISCUSSION There are five conditions that would trigger future evaluation to implement the projects under the Program. They are: ·1. Changes in the.RWQCP discharge permit requirements The Regional Water Quality Control Board (Regional Board) issues the RWQCP a discharge permit wlrich sets the limits on the Plant's discharge. The permit includes a total annual mass limit for each metal, as well as a concentration limit. The Regional Board has been directed by the State Board to reconsider the limits, using the best scientific information in establishing the basis of the limits. The Regional Board is in the process of revising the limits on copper discharge. At this time, it is uncertain what the copper mass and concentration limits will be. The RWQCP continues to seek new source control opportunities, but has not found sufficient new control measures to bring the RWQCP to compliance with the current copper concentration limit requirement. Therefore, RWQCP personnel are working cooperatively to ensure that the permit limits are re-evaluated by the Regional Board. Discussions with the Regional Board have been initiated in order· to establish reasonable concentration and mass permit limits that can be met and are responsive to the environmental needs. A letter from Mayor Simitian to the Chair of the Regional Board reinforced the City's request that the permit limits be reconsidered. The City is urging the Board to utilize the methodology recently used for New York . Harbor, which resulted in an increase in the copper limits for the City of New York and surrounding communities. When the Regional Board's re-evaluation is complete, and at the conclusion of the permit negotiation, more information will be available to determine whether additional reclamation projects will be needed to. meet the ultimate mass permit limit. At that time, the individual reclamation projects will be re-evaluated in light of the outcome of the negotiation .. 2. Increased mass loading to the RWQCP The Plant's metals discharge is .influenced by the flow, the concentration, and the removal efficiency through the Plant. The current flow through the Plant is near record low (23 mgd). Because of the low flow, the RWQCP is able to achieve CMR:217:95 Page 7 of 11 record high removal efficiency. Efficiency is typically inversely proportional to flow. In addition to decreasing removal efficiencies, high flows also bring more pollutants to the plant. Therefore, if the flow through the plant increases in the future, the mass loading would increase. Th~ RWQCP is permitted for 39 mgd,.and is obligated to the Partner cities to treat up to 39 mgdwithout permit violations. 3. Requests frQm partner agencies or other local agencies The cities of Menlo Park and Mountain View.have both expressed their desire for reclaimed water. The City of Menlo Park has conducted its market survey and is evaluating the economics of the Program that would benefit Menlo Park. It is possible that a reclaimed water project which benefits a partner agency woule). present no, or very little, fmancial impact to the City. . 4 . Availability of federal or other funds . Implementation of all the projects under the Program is estimated to increase the City's wastewater rate by approximately 11 percent and the water rate by 3 percent. Currently, there are no federal grant funds available for reclamation projects. However, a proposed bill in the Congress would provide 55 percent federal funding . for reclamation projects from the federal government. The first of Palo Alto's four reclamation projects is. included in this proposed bill. If this funding becomes . available, the economic impact to the City would be reduced by half. 5. Water supply issues From the perspective of the water utility, the value of reclaimed water is determined by comparing it to water from the wholesale supplier and to other supply-side and demand-side options. This analysis requir~s making assumptions about such things as the likelihood of drought, projected wholesale water costs and availability, and any additional costs required for the implementation of reclaimed water. Even if the water utility paid the same rate for reclaimed water as it pays San Francisco Water Department (SFWD) for potable water, this accounts for less than 25 percent· of the total reclamation project costs. Therefore, in order for water. supply issues to drive a reconsideration of reclaimed water, things wotild have to· change markedly. This section lists those issues which may lead to increases in the value of teclaimed water from a water supply perspective. . a. Water supply availability shortages The City's main water supplier, the SFWD,.may be forced to reduce its "safe yield" estimate for its system, due to unfavorable outcomes in a number of cases before regulatory review now and in the future. These cases include FERC relicensing of the Don Pedro Dam, State Water Resources Control Board review of water rights following the Bay-Delta accord, and any other. review of water rights or obligations of water diverters. Although SFWD would act to purchase .water to meet ·its CMR:217:9S Page 80f 11 obligations and the needs of its wholesale customers, it is conceivable that the price of the water would be extremely high and even competitive with reclamation. Short-term water shortages such as those due. to lack of precipitation or runoff, as experienced in the past, are also likely in the future. A more severe or longer term shortage than the 1986-1992 period is possible and may lead to a higher value for reclaimed water, which is always available ~egardless of drought conditions. b. RegUlatory or legislative initiative Regulators or legislators may require the use of reclaimed water for certain end uses as a condition of using water, retaining water rights or maintainins diversion facilities. Under this scenario, economic justification from a water. supply perspective would be superfluous. c. Advanced treatment for potable reuse Regulators are constantly updating the water quality requirements of reclaimed water and designating appropriate end uses for waters of various qualities.· At the same time, advances are befug made in treatment technologies and costs . . Ultimately, reclaimed water could be certified for direct potable reuse. . In that eventuality, a separate pipeline would not be required and the economics of reclaimed water may be favorable. Policy . . In view of the uncertainties with respect to the objectives of the Program, the following policies are recommended as a ro3.d map to the future implementation of the Program. I. The RWQCP will maintain the existing reclamation efforts. Although additional reclamation projects are not recommended at this. time, the existing reclamation projects are vital to the RWQCP's ability in meeting the current mass discharge limit requirement. Any reduction in the RWQCP's efforts to reduce metals discharge will be viewed unfavorably by the Regional Board and the environmental groups. If the existing reclaimed water system requires repair or replacement, the repair or replacement would be done in light of the Program requirements. n. Future evaluation of the projects under the Program could be triggered by any of the following conditions: 1. The City will evaluate the reclamation projects when the Regional Board completes its re-evaluation of the discharge limits, and at the conclusion of the permit negotiation. CMR:217:9S Page 9 Qf 11 · . 2. The City will evaluate the individual projects if the mass loading to the RWQCP increases substantially in the future. 3. The City will evaluate an individual project, if a request with an attractive financial arrangement is made by partner agencies or other local agencies for a reclamation project. 4. The ~ity will evaluate individual reclamation projects if federal or other funding becomes available. 5. The City will evaluate individual reclamation projects in the event of a severe or long-term water supply shortage. 6. The City will evaluate individual reclamation projects if regulators mandate the use of reclaimed water. 7. The City will evaluate further use of reclaimed water if reclaimed water quality becomes suitable for direct potable use. ALTERNATIVES From the wastewater side, the RWQCP continues to search for source coritrol alternatives. So far, additional source control measures have .not been identified that would ensure compliance. Construction of additional treatment process at tbe RWQCP does not appear to be an acceptable alternative from a cost perspective or an environmental protection perspective. Further discussion.of alternatives is included in the Environmental Impact Report, From the water supply side, the City has many alternatives to reclamation. The 1993 Integrated Resource Plan identified the.various alternatives. FISCAL IMPACT The Program poses no fIScal impact to the current fiscal year, since no project is recommended for implementation at this time. The impacts of the individual projects will be addressed when and if a project is s~bmitted for approval in the future. ENVIRONMENTAL ASSESSMENT An environmental impact report (EIR) was prepared in accordance with CEQA. The EIR found no un-mitigable impact. The Utilities Advisory Commission has reviewed and commented on the draft EIR. A public hearing was held on December 14, 1994 before the Planning Commission. The Planning Commission has taken public comments, reviewed, and approved the draft EIR as adequate under CEQA. Thefmal EIR is being submitted concurrently to Council for certification. CMR:217:95 Page 10 of 11 STEPSFQLLO~GAPPROVAL Upon adoption of the reclamation policy, staff will monitor the trigger events. Staff will report to the U AC and Council the occurrence of any event that would necessitate the evaluation of the reclamation project(s), and request UAC review and Council approval prior. to implementation of any project. CMR:217:95 . Page 11 of 11 Table 1~1 Impact and Mitigation Summary Palo Alto Wastewater Reclamation Program DEIR Note: All impacts shown here would be mitigable to Insignificance through incorporation of the corresponding mitigation measures into the proposed project. Environmental Category 3.2 SaUnity, Solis. and Vegetation Detailed discussions of impacts and mitigation are provided in Chapter 3. Potentially Slgnlncant Impact Foothill Main Proled 3.%-1. Several constituents found in the reclaimed water produced by the Regional Plant ~ blah enough to have the potential to cause slanificant impacts to solis and vegetation at Foothill Maln Project use sites as a result of applying the reclaimed water for landscape In'lgation. Proarall'! 3.1-1. Several constituenta found in the reclaimed water produced by the Regional Plant arc high enough to have the potential to cause aignificant impacta to .oila and vogetation at potential Wutewater Reclamation Proaram use sites as a result of applying the reclaimed water for landscape irrigation. Mltllation Measures Footbm Mall Protect 3.%-1. Reclaimed water users shall apply reclaimed water in quantities sufficient to leach accumulated salts through the root zone, shall monitor the affects of the reclaimed water on landscape vegetation over time. and shall take additional mitigation measures as necessary. Proaram . 3.%-%. Reclaimed water users shall apply reclaimed water in quantities sufficient to leach accumulated salts through the root zone, shall monitor the effects of the reclaimed wlter on landscape vegetation over time, and shall take additional mitigation measures as necessary. :J:> --I --I :J:> C":) I :s:: rn :z: --I Co- • ..-.•• r-. Table 1-1 Impact and Mitigati()D Summary Palo Alto Wastewater Reclamation Program DEIR Note: AU impacts shown here would be mitigabte to insignifacance through incorporation of the-corresponding mitigation measures into the proposed project. Detailed discussions of impacts and mitigation are provided in Chapter 3. Environmental Category 3.3 Groundwater Quality Potentially Significant Impact Foothill Main ProJect Impact 3.3-1. The use of reclaimed water for landscape irrigation under the Foothill Main Project could potentially result in a significant increll8c in the concentfations of TDS and chloride in the groundwater at one Of more of the water use sites. Procram Impact 3.3-1. The use of reclaimed water for landscape irrigatlon under the Wastewater Reclamation Program could potentlally result in a significant increase in the concentrations of TDS and chloride in the groundwater at one or more of the water use sites. :sPOIooi3OC2.WPS Mitigation Measures Foothill Main Prolect MItigation Measure 3.3-1. The Regional Plant retain the services of a qualified hydrogeologlst and shall establish a groundwater monitoring program for selected Foothm Main Project skes at which reclaimed water is used for landscape irrigation. This monitoring program shall be capable of identifying increases in TDS and/or chloride concentrations downgradicnt of the use sites as a result of reclatmed water use. If substantial increases in downgradient TDS and/or chloride concentrations are observed, the Regional Plant shall take additlonallteps, with the advice of the hydrogeologist. to reduce those constituent concentrations to acceptable levels. Program Mitigation Measure 3.3-1. The. Regional Plant retain the services of a qualified hydrogeotogist and shalt establish a groundwater monitoring program for selected Wastewater Reclamation Program sites at which reclaimed water is used for landscape irrigation. This monitoring program shall be capable of identifying Increases in TDS and/or chloride concentrations downgradient of the use sites as a result of reclalmed water use. If substantial Increases in downgradient TDS and/or chloride concentrations are observed, the Regional Plant shall take additional steps. with the advice of the hydrogeologist. to reduce those constituent concentrations to acceptable levels. i I .j ,I I Table 1 .. 1 Impact and MItigation Summary ·Palo Alto Wastewater Reclamation Program DEIR Note: All impacts shown here would be mitigable to insignificance through incorporation of the corresponding mitigation measures into the proposed project. Detailed discussions of impacts and mitigation are provided in Chapter 3. Environmental Category 3.12 CUltural Resources 3.t3 Aesthetics Potentially SigniFicant Impad Footblll Main Prolect 3.12-1. Construction of the reclaimed water storage rescl1Ioir at the Page Mill Quarry site could result in significant impacts to known and/or unknown archaeological resources. Proamm 3.11-1 .. Construction of future Wastewater Reclamation Program pipelines and/or resel1loin through open. undisturbed afeB!! or along streets or pipeline corridors bordered closely by historic properties could result .in significant impacts to prehistoric and/or historic cultural resources. depending on the site-specific conditions at the construction site. Promm 3.13-1. Construction of future Wastewater Reclamation Program resel1loir(s) in open, undisturbed areas. areas used heavily by recreatlonists. or ateB!! surrounded by residences. could result in significant impacts to the visual environment, depending on the site-specific conditions at the site and the specifications of the re5Cl1Ioir. SfQtOO13OC~.WP' Mitigation Measures Foothill Main Project 3.12-1. The existing archaeological site near the Page Mill Quarry resel1loir site shall be fenced and placed off-limits to aU construction activities, and an archaeologist shall be present during all excavation activities occurring in the immediate vicinity of Matadero Creek (from Old Page Mill Road to the resel1loir site). froaram 3.11-1. If and when additional pipeline routes and/or reservoir sites are selected. additional review shall be performed and measures Incorporated into the project to reduce potentially significant impacts to leS!l-than-signifieant levels. PrOlmm 3.1)-1. If and when additional reservoir sites are selected. additional review shall be performed and measures shall be incorporated into the project to reduce potentially slgnficant impacts to less-than-significant levels. -. •••• ··.··.·11 Table 1-1 Impact and Mitigation Summary Palo Alto Wastewater Reclamation Program DEIR Note: All impacts shown here would be mitigable. to insignificance through incorporation of the corresponding mitigation me8llures into the proposed project. Detailed discussions of Impacts and mitigation are provided in Chapter 3. Environmental Category 3.6 Biological Resources Potentially Slgnlncant Impact Foothill Main Proleet 3.6-1. Construction of the proposed Foothill Main Project pipeline could result in root damage to approximately 23 native trees. varying in dbh up to 40 inches. along Stanford Avenue between Bowdoin Street and Junlpero Serra Boulevard and at the Page Mill Quany Reservoir site. 3.6-2. Construction activities at the Page Mill Quarry reservoir site could tesult in adverse. erosion-related impacts to aquatlt; life residing in Matadero Creek and impacts to the trees comprising the riparian corridor along the creek. 3.6-3. Construction of the proposed Foothill Main Project pipeline could temporarily adversely affect approximately 250 square feet of a drainage swale that crosses the construction zones adjacent to Junipero Serra Boulevard. Protram 3.6-4. Construction of future Wastewater Reclamation Pro,ram pipelines through open, undisturbed areas or along streets or pipeline corridors bordered closely by vegetation could adversely affect native oak trees or other sensitive species within or adjacent to those pipeline routes. . SFOIOOI3OC1.WP'. Mitigation Measures 'oothOI Msdn Prolect 3.6-1. The Regional Plant or its contractor shall develop an Oak Protection and Replacement Mitigation Plan for the replacement of the native trees that would be removed or damaged during construction. 3.6-2. The Regional Plant or its contractor shall control construction- related erosion into Matadero Creek, based on the Erosion Control Plan identified in Mitigation Me8llure 3.4.1, Section 3.4 of this DBlR, and shall replace my oak trees within 1110 Matadero Creek riparian corridor removed as a result of construction activities. 3,6·3. The potentlalloss of stomwater quality enhancement values shall be mitigated by· measures to restore the swale to its condition prior to construction. rrocram 3.6-4. If any future program pipeUne routes would be located in proximity to native ttees, populations of threatened or endangered plant species, or vegetation potentially supporting threatened or endangered wildlife species, the Regional Plant shall retain the services of a qualified biologist to survey the areas potentially affected and identify steps to ensure the adequate protection of the resource. Protection measures shall include. but not necessarily be limited to. the establishment of buffer zones or the replacement of lost vegetation according to standards found acceptable by the CDFG . Table 1-1 Impact and Mitigation Summary Palo Alto Wastewater Reclamation Program DEIR Note: All impacts shown here would be mitigable to insignificance through incorporation of the Corresponding mitigation measures into the proposed project. Environmental Category 3.6 Biological Resources (continued) Detailed discussions of impacts and mitigation are provided in Chapter 3. Potentially Slgnlneant Impact Program 3.'·5. Construction activities at future Wastewater Reclamation Program reservoir sile(I). If any are developed. could result in advene impacts to nearby plant andlor animal communities or wildlife habitats depending on the site-specific conditions at th~ reservoir site. 3.6-6. Tho use of reclaimed water for marsh enhancement projects near the San Francisco Bay and/or construction of tho proj~1 compoiJ.ents could result in adverse impacts to the aquatic lire at or near the manh, depending on the sensitivity of that . aquatic life to constituentl in the reclaimed water and the construction actlvitles Rquired. Mitigation Measures Proaram 3.'.5. If and when an additional reservoir site is selected, and if that reservoir site would be located In proximity to native trees, populations of threatened or endangered plant species. or vegetation potentiaUy supportinS threatened or endangered wildlife species, the Regional Plant shall retain the services of a qualified biologist to survey the proposed site and identify steps to ensure the adequate protection of the resoUrte. Protection measures shall include. but not necessarily be limited to. the establishment of buffor zones or the replacement of tost vegetation according to standards found acceptable by the CDFG. 3.6-6. If and when a marsh enhancement project is proposed, the Realonal Plant sball retain the services of a qualified biologist to survey the proposed site and Identify ItepS to ensure the adequate protection of vegetation and wildlife within the marsb. This assessment shan include an evaluation of the potential for water quality and aquatic Ufe impacts as a result of usinS the m::lalmed water and the potential for construction-related impacts. Protection measures shall include. but not necealarily be limited to. avoidance of the resource potontlally affected, limited uac of the reclaimed water (or other .appropriatc water management practices), the establishment of buffer zones, or the replacement of lost vcsctation according to standards found acceptable by the CDFO. Table 1-1 Impact and Mitigation Summary Palo Alto Wastewater Reclamation Program DEIR Note; All impactll shown here would be mitigable to insignificance through incorporation of the corresponding mitigation measures into the proposed project. Detailed discussions of impacts and mitigation are provided in Chapter 3. Environmental Category Potentlany S_plncant Impact 3.11 I Foothill Main Prolett Traffic and 3.U-I. Closure of the bike lane in one direction of Embarcadero Circulation Road (cast of Highway 101) may result in a temporary significant impact. 3.11-2. Lane closure on Bast Bayshore Road may result in temporary significlUlt impacts from detours and may block bicycle flow along this roadway. '" 3.11-3. Lane closure on West Bayshore Road may result in temporary significant impacts from detours and may block bicycle . flow along this roadway. 3.11-4. Pipeline construction on Channing Avenue may temporarily block pedestrian and/or bus access to bus stops. 3.U-S. Lane closure on Newell Road may result in temporary significant impacts from detours. . SFOIOOI3OC:2.WP.5. Mlttgatlon Measures foothill Main Protect 3.11·1. The Regional Plant or its contractor shall maintain bike travel through the construction site along Embarcadero Road (east of Highway 101) by providing a temporary alternative bike lane through that area. 3.11-2. Use flaggers to control traffic along East Bayshore Road during lane closures between Bmbarcadero Road (east of Highway 101) and Laura Lane and provide a temporary alternative bike lane in the area. 3.11-3. Use naggers to control traffic along West 8ayshore Road during lane closures between the Highway 101 crossing and Bmbarcadero Road (west of Highway 101) and provide a temporary alternative bike lane in the area. ' 3.11-4. Coordinate with the Santa Clara County Transportation Agency to relocate bus stops along Channing Avenue during construction. as required to provide uninterrupted service. 3.U .. s. Use flaggers to coDtrol traffic along Newell Road during lane closures near Rinconada Park and the cultural center and library complex • Table 1-1 Impact and Mitigation Summary Palo Alto Wastewater Reclamation Program DEIR Note: All impacts shown here would be mit1lable to insignificance throulh incorporation of the conesponding mitigation measures into the proposed project. EnvIronmental Category 3.11 Traffic and Circulation (continued) Detailed discussions of impacts and mitigation arc provided in Chapter 3. Potentially Slgnlncant linpad 'ooth'" Main Prolect 3.U..6, The proposed crossing of Embarcadero Road at Newell Road could result in temporary significant impacts to traffic flow on Embarcadero, 3.U-7. The proposed crossing of HI Camino Real at Stanford Avenue could result in temporary signiDcant impac!s to traffic Dow on El Camino Real. 3.U"'. Lane closure on Stanford Avenue may result In temporary significant impacts from detours, l.Il-9. The proposed crossing of Junipero Serra Boulevard at Stanford Avenue could remit in temporary significant impacts to traffic flow and bicycle flow on Junipero Serra Boulevard. Proanun 3.n~tO. Bike and traffic lane closures as a result of future pipeline construction ac'tivitlet could result in temporary significant adverse impacts to tramc and ~irculation. 3.U-n. Pipeline construction within roadways on future piPeline routes may block pedestrian and/or bus access to bus stops. Mltlgatlon Measures Foothill Main Pmlecl 3.U..6, Implement a tane closure strategy for the Embarcadero Road crossing that limits the number of lanes closed at any given time and prevents closures during peak: traffic periods. 3.11-7. Implement a lane closure strategy for the El Camino Real crossing that limits the number of lanes closed at any given time and . prevents closures during peale traffic periods. 3,11-8. Use Oaggers to control traffic along Stanford Avenue during lane closures between Amherst Street and Junipero Serra Boulevard. 3,U-9. Implement a lane ctosure strategy for the JUDipero Serra Boulevard crossing that limits tbe number of lanes closed at any siven time and prevents closures during peak traffic periods. In addition, a temporary alternative bike lane will be provided in the area. Proanun l.U·10. The Regional Plant or Its contractor shall maintain bike and vchicle travel through the construction sites by providing temporary alternative bike and vehk:le lanes through those areas and through the Incorporation of additional measures into the project, such as the use of nllgers and off-peak construction houn, to meet all regulatory requirements and e~sure adequate traffic movement. 3.U-U. Coordinate with the Santa Clara County Transportation Agency and/or other appropriate transportation agencies to relocate bus stops along roadways during construction. as required to provide uninterrupted service . • • • • -.-.-• ..--~ .,.-.. ~ ~ .. ~.' ···8If··..::2':j~~·