HomeMy WebLinkAboutStaff Report 402-09,;
City of Palo Alto
City Manager's Report
TO: HONORABLE CITY COUNCIL
FROM: CITY MANAGER DEP AR'rMENT: PUBLIC WORKS
DATE: OCTOBER 19, 2009 CMR:402:09
REPORT TYPE: ACTION
SUBJECT: Approval of Final Recommendations of the Compost Blue Ribbon Task
Force
EXECUTIVE SUMMARY
The Council-appointed Compost Blue Ribbon Task Force is forwarding its recommendations to
Council after studying organic materials management issues for six months. The recommendations
include short term recommendations for Palo Alto's current compost operation and longer term
recommendations which would follow closure of the Palo Alto Landfill.
RECOMMENDATION
Staff recommends that Council:
1. Accept the September 9, 2009 Palo Alto Compost Task Force Final Report ("Report") submitted
by the Compost Blue Ribbon Task Force (BRTF).
2. Direct staff to implement the short term recommendations for current compost operations
contained in the attached BRTF Report as modified by the Staff response (Appendix E of the
Report).
3. Provide direction to staff with respect to recommendations (B) through (1) in the Executive
Summary of the Report.
4. Confirm direction to staff that commercial garbage disposal at the Palo Alto Landfill is to resume
following Council action on the BRTF recommendations.
BACKGROUND
Council created the BRTF on January 12,2009, directing it to "evaluate and recommend alternatives
to address Palo Alto's composting needs." The motion adopted by Council in establishing the BRTF
is attached. An amendment adopted with respect to the motion directed "that when the priorities
(are) set for the composting facility locations that parklands will be considered as a secondary
priority after all other non-parkland options have been pursued."
DISCUSSION
The short term recommendations of the BRTF relating to current compost operations have been
reviewed by staff and that review is contained in Appendix E of the Report. Staff agrees with most
of the recommendations and is prepared to implement them, as noted. Staff does not recommend
implementing a small number of the recommendations for the reasons stated in Appendix E.
CMR:402:09 Page I of 3
With respect to the longer tenn recommendations of the BRTF, staff has not had sufficient time to
analyze the recommendations. However, it should be noted that the area referred to as the
Embarcadero Road! Airport site in the BR TF Report is part of the Palo Alto Airport and is currently
leased to the County of Santa Clara. Any use of this area would require approval from the County of
Santa Clara, the Federal Aviation Administration (FAA) and possibly the State Lands Commission.
Letters from FAA staff and from the Airport Association on Airport issues are attached (Attachments
C and D). Following further direction by Council, staff would provide a more detailed analysis of
the long tenn recommendations of the BRTF.
Commercial Garbage Disposal
On January 12,2009 Council passed a motion containing the following provision:
"The City shall suspend accepting commercial garbage at the Palo Alto dump while
awaiting City Council action on the recommendations of the BRTF."
Staff interprets this provision to mean that it is to recommence acceptance of commercial garbage
upon action by Council on the BRTF recommendations being forwarded by this CMR.
Recommendation #4 above requests continnation of this interpretation.
NEXT STEPS
The next steps are for staff to implement the appropriate short tenn recommendations and for
Council to provide direction to staff with respect to the longer tenn recommendations.
RESOURCE IMPACT
The resources needed to implement the short tenn recommendations of the BRTF as modified by
staff are not large, and some will save the City resources. The resources needed to implement the
longer tenn recommendations are very significant and would have to be estimated by staff and or
consultants prior to implementation.
POLICY IMPLICATIONS
The overall recommendations of the BRTF are consistent with the City's Zero Waste Operational
Plan and the Baylands Master Plan. The Embarcadero Road/Airport site referred to in the BRTF
recommendations is currently leased by the County of Santa Clara for airport related uses. The
Council has directed staff to develop a Business Plan for the airport and that plan is being prepared.
ENVIRONMENT AL REVIEW
Accepting the BRTF Report and implementing the short tenn recommendations are exempt under
15301 and 15304 of the California Environmental Quality Act (CEQA) Guidelines. Some fonn of
CEQA review would be needed with respect to the longer tenn recommendations of the BRTF.
ATTACHMENTS
Attachment A: Palo Alto Compost Task Force Final Report (September 2009)
Attachment B: January 12, 2009 Council Motion regarding the Compost BRTF
Attachment C: September 24, 2009 Letter from FAA Staff
CMR:402:09 Page 2 of3
.,..
Attachment D: October 14, 2009 Palo Alto Airport Association Comment" Letter
Attachment E: October 13, 2009 JCRC for the Palo Alto Airport Letter
PREPARED BY: Fi28:
PIDLBOBEL
DEPARTMENT HEAD:
CITY MANAGER APPROVAL:
CMR:402:09 Page 3 of3
PALO ALTO
COMPOST TASK FORCE
FINAL REPORT
SEPTEMBER 2009
Task Force Members
Steve Albertolle Craig Barney Maria Coladonato
Cedric de La Beaujardiere Jeremy Eddy Hilary Gans
Bryan Long Emily Renzel Bob Wenzlau
i
TABLE OF CONTENTS
I. Executive Summary................................................................................................... 1
II. Background................................................................................................................ 3
III. Mission and Criteria................................................................................................... 4
A) Mission.............................................................................................................. 4
B) Criteria.............................................................................................................. 4
IV. Approach of the Task Force..................................................................................... 11
V. Findings and Conclusions........................................................................................ 11
A) Acreage Requirement...................................................................................... 12
B) Composting Technologies .............................................................................. 13
C) Advanced Technologies.................................................................................. 13
D) Ranking Tool .................................................................................................. 15
E) Greenhouse Gasses......................................................................................... 16
F) Economic Impacts........................................................................................... 16
VI. Recommendations and Next Steps........................................................................... 17
A) Short Term Recommendations ....................................................................... 17
B) Recommendations for 2012............................................................................ 19
C) Recommendations for 2015-2021................................................................... 19
D) Next Steps....................................................................................................... 19
VII. Alternatives and “Pros and Cons”............................................................................ 20
A) Short Term (Operational) Alternatives........................................................... 20
B) 2012 Alternatives............................................................................................ 20
C) 2015-2021 Recommendation.......................................................................... 21
Appendix
A) Short Term Recommendations of the Task Force and Palo Alto Staff Response
B) Airport/Compost Issues
C) Integrating Airport and Compost Facilities
D) 2021 Location Screening (Task Force)
E) Task Force Activities
F) Greenhouse Gas Impacts (Bryan Long)
G) 2012 Cost Analysis (Aerobic Subcommittee)
H) Further Analysis
1
Palo Alto Compost Task Force
Final Report
September 2009
I. Executive Summary
Palo Alto’s Compost Task Force was initiated by City Council on January 12, 2009
and operated from March through September 2009. Its Council-assigned objective
was to “evaluate and recommend alternatives to address Palo Alto’s composting
needs.” Possible short-term
improvements to existing
operations were evaluated, as
well as longer-term
technology projects that
might reduce greenhouse gas
emissions, generate clean
energy, and lower rate-payer
costs. The Task Force found
that very substantial
greenhouse gas (GHG)
reductions can be achieved
by diverting food and other
wet organic wastes from
landfill disposal, and by
moving to advanced energy-
recovery technology for our
sewage, food, and yard
wastes.
The Task Force employed an initial screening to establish recommendations for
implementation by 2012. The Task Force subsequently used a software based
ranking tool to evaluate twelve potential locations and thirteen potential
technologies that could be implemented longer term, directed at 2021. The results
are somewhat grouped, resulting in five locations and five technologies showing the
greatest promise. With a desire to keep parkland as a distinctly secondary option,
the Task Force decided to link its short and long term recommendations into a
phased approach at a non-parkland site adjacent to the Water Quality Control Plant.
Accordingly, the key recommendations of the Task Force are:
A) Implement the Short Term Recommendations of the Task Force with respect to
current Palo Alto compost operations (Appendix A).
B) Begin work to establish an Anaerobic Organics Processing Facility at the
Embarcadero Road/Airport Site, with the expectation of bringing it online
between 2015 and 2021.
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C) Install an Aerated Static Pile Compost Facility at the Embarcadero Road/Airport
Site by 2012 or as soon thereafter as possible.
D) Cease composting at the current location when the Aerated Static Pile facility is
ready, or upon cessation of acceptance of yard trimmings due to landfill closure
(2012), whichever is sooner.
E) Take yard trimmings to the Z-Best facility (Gilroy area) for composting if the
Aerated Static Pile facility is not completed by cessation of acceptance of yard
trimmings.
Corollary recommendations of the task Force are:
F) While the Embarcadero Road/Airport is the most promising site at this time,
other sites adjacent to the Water Quality Control Plant should also be
considered.
G) The City should determine, in the near term, the availability of the current
commercial sites adjacent to the Water Quality Plant.
H) The City should utilize the upcoming Master Planning process for the Water
Quality Plant to continue to help analyze the long term (2015-2021) options for
organics material management within Palo Alto.
I) The City should add residential food scrap collection to the GreenWaste
contract as soon as practical.
J) The City should include small-scale pilot demonstration projects as part of the
process in selecting a long term (2015-2021) technology or technologies.
K) City staff should maintain the compost email list and webpage and continue to
notify Task Force Members and interested parties of proposed and final actions
and activities regarding organic materials management in Palo Alto.
While, in the long term, anaerobic processing appears preferable, a final technology
selection should depend upon an evaluation of responses to a Request for
Information (RFI) and, ultimately a Request for Proposals (RFP). Ultimately, the
selection of a suitable solution is an iterative process. Vendors require detailed
information regarding potential sites before they can provide accurate cost or design
estimates.
The Embarcadero Road/Airport site has a number of issues which were identified
jointly with the Airport Community and are contained in Appendix B. Should
Council decide to have this site fully considered, the next steps would be to:
¾ Develop sufficient preliminary design details to request FAA approval, and
¾ Prepare a companion plan for airport improvements to mitigate composting
facility impacts. A rough example of such a plan from several Task Force
Members is in Appendix C.
3
Available land is very limited and substantial challenges exist for all studied sites.
Because the Task Force evaluated sites and technologies in parallel, acreages and
site specific details could not be provided to assist vendors. The Task Force
envisions the City soliciting Requests for Proposals to obtain more specific
information pertinent to the decision-making process once the location has been
selected. Final site selection cannot occur now. Many challenges exist with the
Embarcadero Road/Airport Site which must be addressed. The overriding
recommendation of the Task Force is to select a technology which minimizes the
escape of methane currently occurring, and maximizes the extraction of energy
from Palo Alto’s organics.
II. Background
Palo Alto’s landfill is scheduled to cease waste acceptance in 2012. The current
compost facility is located on the landfill site, and is required to cease yard
trimmings acceptance shortly thereafter. The current plan, should nothing change,
is to transport yard trimmings to Z-Best’s compost facility near Gilroy. Many
community members were very reluctant to see this option become reality because
of the greenhouse gas emissions generated in transporting material there, and the
would be failure of the community to deal with its own residuals. Many of those
same community members did not want dedicated parkland (the current site) to
continue to be used for composting. This dilemma led to the formation of the
Compost Task Force. Finding a suitable site and a suitable technology has proven
to be extremely difficult.
The City of Palo Alto generates roughly 21,000 tons/year of segregated yard
trimmings, 12,000 tons/year of food scraps and 24,000 tons/year of sewage
biosolids. All three categories and other unsegregated organics are shown in Figure
1 below.
Sources of Organics
Other
1%
Yard
Waste
20%
Paper
24%Food
55%
Disposed
Organics
33% or
22,000 Tons
Bio Solids
36% or
24,000 Tons
Collected
Yard Waste
31% or
21,000 Tons
67,000 Tons Per Year
Figure 1
Composition of
Disposed Organics
4
III. Mission and Criteria
A) Mission
The Task Force established the following Mission for itself:
“The Compost Task Force mission is to evaluate and recommend
alternatives, in accordance with the Council’s 1/12/09 Compost
Action, to address Palo Alto’s organics material management needs,
within approximately six months. Short term improvements,
environmental impacts, economic impacts, permitting, location and
energy generation will be addressed. Locations on Palo Alto parkland
would be considered as a second priority after all other non-parkland
options have been pursued.”
The Mission summarized a more detailed directive Council approved when it
created the Task Force. In its directive, Council stated that the Task Force shall
“evaluate and recommend alternatives to address Palo Alto’s composting needs
. . .” The Task Force was specifically directed to evaluate the following:
1. Short Term Improvements to Current Operations
2. Environmental Impacts of Alternatives
3. Economic Impacts of Alternatives
4. Permitting of Alternatives
5. Prospective Locations of Alternatives
6. Energy Generation of Alternatives
The Council further directed: “that when the priorities are set for the
composting facility locations that parklands will be considered as a secondary
priority after all other non-parkland options have been pursued.” Council also
requested that the Task Force consider all three of the major types of organic
residuals: yard trimmings, food scraps and sewage biosolids.
B) Criteria
The following screening criteria were developed to eliminate alternatives for
which further analysis would not be productive:
1. Demonstrated Technology – The process should have been demonstrated,
preferably in the United States, at a large enough scale to insure success.
2. Permitability – There should be a reasonable possibility of success in
obtaining all needed permits.
3. Diversion Credits – Obtaining credit for diversion from landfilling under
AB939 should be possible for the process.
5
4. Acceptable for Yard trimmings – The process should, at a minimum, be
effective for yard trimmings. It is highly desirable that it also be effective
for food scraps and sewage biosolids.
5. City-Wide Scale – The process should be able to manage yard trimmings at
a city-wide scale, approximately 18,000 tons per year.
The Task Force researched various options with the goal of recommending a
class of alternatives, while refraining from specifying a particular technology.
Ultimately, the selection of a suitable solution is an iterative process. Many
vendors require detailed information regarding potential sites before they can
provide accurate cost or design estimates. Because the Task Force evaluated
sites and technologies in parallel, acreages and site specific details could not be
provided to assist vendors. The Task Force envisions the City soliciting
Requests for Proposals to obtain more specific information pertinent to the
decision-making process once the location has been selected.
Alternatives were evaluated for two time frames: 2012 and 2015-2021. The
first one coincides with Palo Alto Landfill closure. The second one allows
enough time for emerging technologies to be vetted and constructed. The above
Screening Criteria was used for the 2012 recommendations. To use it for the
2015-2021 recommendations would have screened out alternatives which may
well be viable by 2015-2021 as the processes are more fully demonstrated,
developed and permitted.
Another criteria used for 2012 was timing. If the process could not be
developed, permitted and installed by 2012, it was initially screened out.
With respect to 2015-2021, criteria were developed based upon Council
direction, stakeholder interests, and resources to be protected. These are shown
in Figure 2. The criteria were then re-categorized to relate to a) Location
(Where?) and b) Type of Process (What?). The “Where” and “What” criteria
are shown in Figures 3 and 4 respectively.
6
Compost Interests & Criteria
Attachment A 3/18/09 Figure 2
Council Direction Stakeholders Interests/ Resources Criteria
I. Short term improvements to
current composting
- neighbors
- city staff
- compost users
- short term impacts
- short term cost
- compost quality
- minimize impacts
- minimize net costs
- improve compost quality
II. Environmental impacts of
alternatives:
• Footprint
• Odor
• Dust
• Noise
• Energy use/generation
• GHG emissions
• Zero Waste
- community
- environmental advocates
• space
• odor
• dust
• noise
• energy
• GHGs
• air contam.
• water use
• water contam.
• unused residuals
• minimize space
• minimize odor
• minimize dust
• minimize noise
• minimize energy
• minimize GHGs
• minimize air contam.
• minimize water use
• minimize water contam.
• minimize unused residuals
• diversion from landfill
• maximize soil enrichment
III. Ability to handle:
• Organic materials
• Food scraps
• Sewage solids
• Other solid organics
• Reduce source generation
• Promote home composting
- effective for yard trimmingsorganic
materials
- effective for food scraps
- effective for sewage solids
-effective for other organics
- proven effectiveness
IV. Economic viability
- rate payers
- General Fund
- product marketability
- money
- financial certainty
- minimize net cost
- minimize cost fluctuations
V. Locations
- Open Space advocates
- affected land users
- nearby park users
- habitat
- regulatory agencies
- park land
- infrastructure land
(environmental impacts from above)
- maximize Byxbee Park creation
- maximize buffer zone
- minimize park use
- minimize neighbor impacts
- minimize traffic impacts
VI. Permitting/Timing - minimize permit problems
- minimize implementation time
VII. Other - regulatory agencies
- local elected government
- organics materials manage.
professionals
- Civic engagement
- business expansion
- local self sufficiency
- liability
- education
- free compost
- maximize local operations
and reuse
- minimize risks
- degree of education
- amount of free compost
7
Figure 3
8
Figure 4
9
Note: Description of Locations 1-12 are
found in Appendix D.
10
I
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• Does it minimize hard_to_dispose products?
• Does it minimize land use?
• Is the cost low?
D Can it be permitted and constructed in time?
• Is it eliigible for diversion credits?
D Does it minimize other environmental impacts?
• Does it minimize resource use?
• Is it flexible to handle waste types well?
• Does it minimize GHG?
Cumulative VVhat
Contributions to "What?" in 2021
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• Does it minimize hard_to_dispose products?
• Does it minimize land use?
• Is the cost low?
o Can it be permitted and constructed in time?
• Is it eliigible for diversion credits?
D Does it minimize other environmental impacts?
• Does it minimize resource use?
• Is it flexible to handle waste types well?
• Does it minimize GHG?
11
IV. Approach of the Task Force
The City established a website to make available to the public informational
documents which were prepared or used by the Task Force. The group met
regularly every two weeks for six months. The Task Force was coordinated by
Steve Emslie, Assistant City Manager and Phil Bobel, Environmental Compliance
Manager. There were no significant consultant resources available so the Task
Force divided into three research groups to study the available technologies -
aerobic, anaerobic, and high technology. The lack of consultant resources dictated
that most of the analysis be qualitative and not quantitative. This limited the extent
to which the Task Force could implement the Council directive to conduct analysis.
The Task Force held a half day Technology Seminar at which several experts
presented information and at which each of the subcommittees reported its findings.
In addition the entire Task Force toured the composting facility at Byxbee Park and
the Aerobic Subcommittee toured the Z-Best facility.
Staff Member Ken Torke provided a decision support software program through
which each Task Force member could rank sites and technologies. The output
from this exercise helped focus the Task Force and expedite decision making.
As the Council did not provide broad consulting support to augment the Task
Force’s analysis, this resource limitation caused the Task Force’s efforts to be
developed from a more principled approach than a rigorous analytic approach.
Given that the resources were not available for rigorous analysis, the Task Force’s
approach was to become informed of technologies, attributes of locations, and
considerations that informed the criteria that were applied. The Task Force enjoyed
a broad skill base that included knowledge of Palo Alto’s land use, solid waste
management, finance and accounting and greenhouse gas emissions. As such, this
principled approach allowed examining and ranking alternatives drawing upon
understandings gained across the term of the Task Force’s service. Only when a
recommendation was made toward the Embarcadero/Airport Site did the level of
analysis shift to consider more detailed site specific elements.
A chronology of Task Force activities is found in Appendix E.
V. Findings and Conclusions
This section presents a chronological review of the results of the Task Force’s work
and serves to answer some of the questions that may arise while reading the overall
report. During the Task Force’s six months together, numerous studies have been
performed and findings indicate there are many facets, most of them intertwined, to
be considered. For example: preservation of natural resources and parkland, the
need and desire to reduce green house gas (GHG) emissions, and the potential for
harvesting more useful by-products, beyond compost, from processing our organic
materials such as capturing gasses emitted by decaying matter to produce biofuels
or electricity to power vehicles or buildings.
12
An important realization was that “sequestering” carbon, or storing carbon in solid
forms so that the carbon molecules do not escape into the air, can take many forms.
(See Appendix F). For example, 30% of the carbon contained in yard trimmings is
lost as CO2 to the atmosphere as the plants decompose during the composting
process. Over time the finished compost applied in the soil decomposes further and
emits more CO2. However, regular application of compost increases the total
carbon sequestered in the soil, making composting a way to reduce total CO2
released to the atmosphere. If any of the organic materials is missed during the
collection process it ends up in landfill and the closed, oxygen-free environment
turns it into methane, an even worse outcome (See Appendix F) with respect to
GHG.
Upon further study, the Task Force realized that organic materials from food scraps
(vegetable scraps, fruit rinds, coffee grounds, oily pizza boxes, etc.) present an even
greater problem of methane generation in the landfill. Diverting food scraps from
the landfill would add volume to local composting operations to improve economies
of scale, and would increase both the amount of carbon sequestered and methane
avoided. The new GreenWaste Management contract requires that they begin
picking up food scraps from multi-family dwellings and commercial enterprises that
enroll in this program. While this commercial portion could represent
approximately two thirds of the food scrap volume, it may require additional
promotion to get 100% participation. Many cities are now offering single-family
collection programs which greatly increases the effectiveness of diversion of carbon
based materials away from the landfill and subsequent conversion into methane.
Based on discussions with Z-Best, food scraps can add complications to composting
such as vector control and eliminating some potential commercial uses. This issue is
greatly mitigated by utilizing covered static piles which protect and cover the
composting material throughout the conversion process, limiting vectors, particulate
matter being released into the air, and odors. We recommend the city consider
amending the GreenWaste agreement and add this service for pick up in residential
green bins as soon as possible.
By increasing the potential volume of compostable material stream with residential
food scraps and biosolids from the sewage plant, the higher volume (in tons per
year or TPY) was then supplied to vendors representing different technologies for
determining Palo Alto’s potential use of various technologies for composting. As
detailed elsewhere in this report, three sub-committees were formed that studied
publicly available consulting studies prepared for other cities, websites, articles and
contacting vendors to determine if they met our criteria and what their processes
might be. While the process and outcome are detailed elsewhere in the report, the
following are some findings and conclusions related to “What” we do:
A) Acreage Requirement
The acreage requirement for almost all technologies is about 4-6 acres. They
require space for trucks to dump the material, for grinding and loading, for
removal of the finished product and reloading into trucks. Some advanced
technologies claim to use less than 4 acres; however the Task Force did not see
clear evidence to support this. An outside expert consultant (Jim Binder)
13
pointed out that cost minimization and efficiency maximization result when the
site supports a straight path from beginning to end as opposed to having to
create artificial turns to fit a smaller or oddly shaped location.
B) Composting Technologies
Research on the state of composting technologies indicated that current
operations could be significantly improved both in terms of quality of output
and diversity of materials processed, by changing to an enclosed system.
Enclosing the operation speeds the decomposition process, minimizes odor and
release of particulate matter into the air and vector issues while improving the
quality of the final product. This can range from open aerated static piles where
forced air is used to speed decomposition, to enclosed static piles where the
organic matter is covered to capture the water and heat produced to speed the
process and minimize exposure of dust, odor and access to vectors. The cost of
aerated static piles is also much lower since it involves a simple cement floor,
aeration pipes, blowers and biofilters and covering material. For Palo Alto’s
organics stream an aerated static pile system would cost approximately $2.5
million.
C) Advanced Technologies
There are few commercial facilities with operating permits in North America for
advanced technologies such as wet anaerobic, low heat carbon cracking
technology for bio char production, or higher heat incineration called pyrolysis
or gasification. Bio char was identified early in our process as a very promising
because the carbon sequestering capability is very high. Using low heat
incineration, wood and trimmings are effectively turned into charcoal which can
then be ground and used as a soil amendment. The charcoal sequesters the
carbon for a much longer period of time than compost and is very beneficial as a
soil amendment. All of these technologies, while very promising, are still in the
early adoption phase where multiple vendors seems to have a unique approach
and standards are not widely accepted. Comparing the technologies involves
comparing vendors which makes the process dependent on individual vendor
cooperation. Presently, large city operations such as New York, Los Angeles,
Sacramento and Santa Barbara are getting much attention as they evaluate these
technologies. However, no final decisions have yet been made for these
jurisdictions.
For example, San Jose has announced that Harvest/Bekon may build an
anaerobic compost operation on Zanker Road in San Jose. The outputs of the
process will be compost, gas for combustion to generate electricity or for
liquefaction for use in cars. Bekon is an experienced German company that has
operations throughout Europe and other parts of the world. It is important to
note that Europe’s cost of energy and electricity are significantly higher than
current US costs and thus the return on investment is much greater. The Task
Force expects US oil prices to increase driving energy and transportation costs
higher. This would make the economics more similar to Europe and anaerobic
composting would become more attractive over the next several years.
14
Other advanced high temperature technologies are beginning to come on line
and were also evaluated. These technologies involve incineration at higher
temperatures and use the heat from burning the resultant synthetic gases to
generate electricity. The heat is high enough to change the molecular structure
of the waste so that the byproduct is a non-toxic ash that can be used in road
beds or disposed of in landfills. These technologies are only efficient if used to
incinerate the whole spectrum of municipal waste that presently ends up in
landfill including non-recyclable plastics, rubber, tires, medical waste and other
waste streams that currently end up in landfill. Adoption of these technologies
as a way to reach landfill diversion goals has been further complicated by
competing bills in the California legislature regarding the types of technologies
that qualify for diversion credit. One legislative proposal states that once a city
is recycling more than 50% of potential materials, it can use advanced
technologies to process municipal solid waste (trash and organic materials) and
receive diversion credits. The second proposal requires a minimum of 75%
recycling before advanced technologies qualify for diversion credit.
Once this debate is finalized there may be a way for Palo Alto to work
independently or with surrounding cities to utilize its entire municipal waste
stream for diversion credit which would greatly increase the contribution of
composting and waste disposal to the city’s goal of 100% GHG reduction.
Given the state of this industry, and the timing of the GreenWaste Management
contract, significant developments in this area are likely to be 7-10 years out.
However, given permitting, contracting and implementation timing this is an
area that Palo Alto needs to begin studying soon.
The logical progression of technology usage over time could flow as follows:
1. Yard trimmings plus the addition of food scraps and possibly biosolids in a
simple covered aerated static pile operation
2. Increased recycling efforts to reach 75% or greater of waste stream
3. Anaerobic digestion of organic materials
4. Use of advanced gasification technologies to minimize landfilling and
generate significant power for the City using the municipal waste stream
currently being sent to landfills.
An additional consideration, and part of the theme “What we do is more
important than where we do it”, is working with San Jose, Oakland or another
regional municipality and take our compostable stream to their anaerobic
facility. This would provide an opportunity to move the technology forward and
support development of the Task Force’s recommended anaerobic processing.
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For example, the geographical center of Palo Alto from a garbage collection and
transportation perspective (See GreenWaste Management Contract) is Silva
Avenue. Relevant distances for hauling follow:
¾ Distance to San Jose Zanker and Los Esteros Road locations: 12.5
miles
¾ Distance to Embarcadero Road site: 4.7 miles
¾ Net additional miles: 7.8
The downsides to teaming with San Jose could be the loss of long term control,
the loss of negotiating power (i.e. small fish – big pond), and the loss of
leadership that historically has benefitted Palo Alto.
D) Ranking Tool
As for the “Where” side of this discussion, the tool for the Task Force’s ranking
process are described and the output are included in this package. While no tool
is perfect, the Task Force considered the tool a significant decision making aid
and considered the following important factors:
1. Personal values: The Task Force members came with a set of core values
that consciously or unconsciously would be included in the process. The
decision making tool acknowledged this and allowed people to express their
values so that they would be both visible to all but also weighted equally for
each person. Thus the loudest voice or the most stubborn had no more
weight than the quietest.
2. Breadth of choices: The tool allowed unlimited choices for selection. Thus
several meetings were spent debating the precise definition of what
“adjacent to the Water Quality Plant” meant or whether the old Los Altos
treatment plant was a viable option for selection and so on. Adjacency to the
water treatment plant was discussed throughout the months because there
was appealing vacant land around it. City staff indicated it may be easier to
secure permits in this area. Further, the Water Quality Plant would be a
ready consumer of any power produced from any of the advanced
technologies and has a ready supply of recycled water which could be used
without the use of any incremental GHG’s to produce water if needed for
the composting process.
3. The outcome of the ranking process reinforced a choice near the Water
Quality Plant and gave it credibility among Task Force members. The
locations surrounding the water treatment plant clustered very clearly at the
top. Locations utilizing parkland did not do as well. Locations which
seemed unfeasible or impractical compared to others came out lower,
increasing confidence in the ranking tool.
16
E) Greenhouse Gasses
Substantial greenhouse gas (GHG) reductions can be achieved first by diverting
food and other wet organic wastes from landfill disposal, and then by moving to
advanced anaerobic digestion technology for our biosolids, food scraps, and
yard wastes. Non-local transport of our organic wastes contributes to GHG
emissions, but as can be seen from the chart below, how we process our organic
wastes matters much more than where that processing occurs.
Food scraps and other
moisture-rich
compostable wastes
quickly decompose in
landfills, releasing
substantial methane gas
long before methane
recovery systems are in
place. Achieving the
contract collection
target of our new
commercial,
institutional, and multi-
family residence
(C/I/M) food scraps
program will reduce
methane emissions by
at least 6,000 and as much as 15,000 metric tons (mT) of CO2 equivalent,
depending on emissions model assumptions. Surpassing our collection target or
implementing a single-family foodwaste collection program would reduce GHG
emissions even more.
The use of Advanced Anaerobic Digestion (AAD) facility to process our
wastewater sludge, C/I/M foodwaste, and collected yard wastes would reduce
CO2 emissions by an additional 14,000 mT of CO2 equivalent. A 50% increase
of total foodwaste collections (from the current target of 9,000 mT) would result
in an additional reduction of between 6,300 and 16,200 mT of CO2e.
Together, these steps could reduce our city’s GHG emissions by 2% to 4% from
the total emissions estimated in the Palo Alto Climate Action Plan. It should be
investigated whether some of this might qualify for carbon credit sales under the
emerging GHG Cap and Trade legislation.
F) Economic Impacts
Due to the complex nature of the technologies, the proprietary nature of vendor
information, and the lack of sufficient time, the Task Force was not able to
complete a quantitative economic analysis of alternatives. The Aerobic
Subcommittee completed initial work on the current Palo Alto compost
operation and the Z-Best (Gilroy) alternative and this work is contained in
Appendix G. A preliminary cost analysis of an aerated static pile operation at
the Embarcadero Road/Airport site for 2012 was begun by Task Force members
but engineering estimates do not yet exist. The next step City staff would have
17
to take for this alternative is to prepare an engineering estimate, should Council
so direct staff.
With respect to the 2015-2021 recommendations, engineering cost estimates of
the alternatives do not exist. Such estimates would have to be made as part of a
facilities planning process, which is one of the recommendations of the Task
Force.
VI. Recommendations and Next Steps
A) Short Term Recommendations
The following recommendations are being made with respect to current
operations at the Palo Alto compost facility. It is recommended that these be
implemented within 45 days of acceptance by Council:
1. Transition from potable to reclaimed water saving approximately 3,700,000
gallons per year of potable water.
2. Suspend sale of blends and only sell pure compost - Blends are mixture of
finished compost with imported materials like sand to create additional
landscaping materials. The blends are not achieving the goal to move
finished compost, especially since commercial disposal has been
discontinued at the disposal site, and those commercial contractors were a
primary customer. The yard has a throughput of about 600 tons per year at
$160 per ton.
3. Instead of utilizing chips for hog fuel with the requisite hauling to the
Central Valley, use the chips as Alternative Daily Cover (ADC) until the
landfill closes. (Estimated at 2,800 tons per year based on 2009 numbers.)
4. Limit Size of Finished Compost Stockpile - While the current excessive size
of the stockpile may be an anomaly based on the economy, a limit will
dictate actions before it becomes a nuisance as was observed by the Task
Group during the site visit. The maximum stockpiled amount should not
exceed 6,500 tons until 6 months prior to cessation of acceptance of yard
trimmings as part of the landfill closure. At that time, the maximum amount
stockpiled can rise to the amount needed for landfill closure.
5. Reduce Dust - The estimated 8,625 to 11,500 tons of compost material
needed for landfill closure should be managed to mitigate particulate loss,
including covering it, if necessary.
6. Increase the throughput of Finished Compost to Market:
¾ Enhance convenience and expand availability of free compost for
Palo Alto residents. (For example more convenient pickup
locations in town and more frequent or continuous availability of
finished compost.)
¾ Review the pricing range (current price to free) of Palo Alto
compost to improve the flow of material to the commercial market.
18
7. Improve space utilization toward 7.5 acres or less with a consolidated
footprint, for example:
¾ Locate all the materials handling operations (e.g., screening,
finished product storage, blending) closer together in the 7.5 acre
footprint and closer to the windrows to reduce transportation.
¾ Investigate combining windrows as volumes decrease.
¾ Limit width to 10 feet between windrows (width of the loader
bucket) to minimize area used.
¾ Maximize the length of the windrows for land use efficiency.
8. Enhance the final product by initiating improved protocol for compost
operations. For example:
¾ Materials need to move through the process on a clear and regular
cycle. This better serves commercial customers that can more
easily use a predictable and dependable supply.
¾ If the regular cycle cannot be maintained due to equipment
breakdown or lack of personnel, then material should be diverted
to SMaRT/Z-Best.
¾ Add 100 gpm of reclaimed water at the grinder to enhance quality.
¾ Grind directly into a trailer or A-T dump truck to deliver material
to the windrows.
¾ Increase water during windrow processing to 60% moisture
content to enhance quality.
¾ Turn more frequently 2x/week, minimum 1x/week
9. Contain composting cost by examining outside expenditures.
Recommendations include:
¾ Proactively send organic materials overflows to SMaRT station vs.
Half Moon Bay
¾ Avoid contracting out grinding services.
19
B) Recommendations for 2012
1. Install an Aerated Static Pile Compost Facility at the Embarcadero
Road/Airport Site by 2012 or as soon thereafter as possible.
2. Cease composting at the current location when the Aerated Static Pile
facility is ready, or upon cessation of acceptance of yard trimmings due to
landfill closure (2012), whichever is sooner.
3. Take yard trimmings to the Z-Best facility (Gilroy areas) for composting if
the Aerated State Pile facility is not completed by cessation of acceptance of
yard trimmings.
4. Seek ways to increase commercial/multifamily food scrap collection and
implement a single family food scrap collection program.
C) Recommendations for 2015-2021
It is recommended that Palo Alto begin work to establish an Anaerobic
Organics Processing Facility at the Embarcadero Road/Airport Site, with the
expectation of bringing it online between 2015 and 2021. However, it is not
recommended that the other technologies be ruled out now. Rather, it is
recommended that the process described in D(3) (below) be followed which
would ultimately result in final selection of the 2015-2021 technology.
D) Next Steps
The next steps suggested by the Task Force to implement the Task Force
recommendations are:
1. With respect to the Short Term (Operational) Recommendations, Palo Alto
staff should prepare and execute a brief Implementation Plan, reporting the
outcome to Council as soon as practical.
2. Council should direct Staff to prepare a timeline for execution of the Task
Force’s 2012 Recommendation – Aerated Static Piles on the Embarcadero
Road/Airport Site. The key components of that timeline are:
a. Resolution of the following issues and tasks associated with the
Embarcadero Road/Airport site:
¾ Roadway relocation
¾ Airport operations
¾ Future airport needs
¾ Existing utilities, easements and access
¾ Visual screening
¾ Baylands habitat protection
b. County, FAA, Corps of Engineers, and State Lands discussions and
issue resolution
c. CEQA documentation
20
d. Obtaining needed permits
e. Facilities planning
f. Design
g. Construction
h. Operations commencement
3. Council should direct staff to begin work on the Task Force’s 2015-2021
recommendations immediately following resolution of issues contained in
2.a above. Assuming that the issues associated with the Embarcadero
Road/Airport site are resolved, and Council determines that the site should
be used for Organics Materials Management, a facilities planning process
for that site for 2015-2021 should be initiated. The first step will be
consultant selection for preparation of a facilities plan and CEQA
documents, and an RFP for design and construction. The RFP process
would result in final selection of a particular technology, insuring that
developments in technology which occur in the next several years are fully
considered at the time Palo Alto makes its final decision.
VII. Alternatives and “Pros and Cons”
A) Short Term (Operational) Alternatives
The alternative to the Immediate Recommendations is to continue current
practices. City Staff have agreed to the majority of the recommendations and
most result in cost savings or small cost increases. Therefore a detailed
discussion of “Pros and Cons” is not provided here. The City Staff response
(Appendix A) explains the reasons that some of the recommendations are not
being targeted for implementation.
B) 2012 Alternatives
1. Recommended Alternative: Aerated Static Piles at Embarcadero
Road/Airport Site.
Pros:
¾ Avoids use of parkland
¾ Proximity to current site should facilitate permitting
¾ Fewer emissions than current operation (windrows)
¾ Continues composting locally avoiding impacts on neighbors
¾ Avoids CO2 and toxic diesel emissions from trucking to Gilroy
area
¾ Can accommodate food scraps
Cons:
¾ More costly than Z-Best facility near Gilroy
¾ Uses land desired by Airport users
21
¾ Issues associated with proximity to Airport and Baylands
¾ Unlikely able to be ready when needed (2012)
2. Fall-back Alternative: Z-Best Windrow Composting (Gilroy)
Pros:
¾ Avoids use of parkland
¾ Lower cost than Palo Alto facility
¾ Certain to be available and ready on time
¾ Produces compost similar to current Palo Alto facility
Cons:
¾ CO2 and toxic diesel emissions from trucking to Gilroy area
¾ Organics sent to another community, impacting them
¾ Windrow composting emissions greater than aerated static piles
3. Continuing Current Operations Alternative (Not Recommended)
(Note: The Task Force specifically recommended against this alternative.)
Pros:
¾ Continues composting locally
¾ Avoids CO2 and toxic diesel emissions from trucking to Gilroy
area
¾ Likely substantially easier to secure permits than the Embarcadero
Road/Airport site
¾ Likely to be ready when needed (2012)
Cons:
¾ Uses parkland
¾ Windrow composting emissions greater than aerated static piles
C) 2015-2021 Recommendation
1. Anaerobic Organics Composting at the Embarcadero Road/Airport site.
(Recommended Alternative)
Pros:
¾ Avoids use of parkland
¾ Proximity to Water Quality Control Plant should facilitate
permitting and operations
¾ Fewer emissions than current operation (windrows)
¾ Continue composting locally avoiding impacts on neighbors
¾ Avoids CO2 and toxic diesel emissions from trucking elsewhere
¾ Produces both energy (methane) and compost
¾ Less energy required than high-temperature processing
¾ Less costly than high-temperature processing
Cons:
¾ More costly than aerobic composting
¾ Uses land desired by Airport users
22
¾ Substantial issues associated with proximity to Airport, Baylands,
and Water Quality Control Plant
¾ Process does not control emissions at the same level as other
energy producing technologies
2. Other Energy Producing Technologies
(Note: The Task Force does not recommend ruling these out. Rather, the
Task Force recommends a selection process in which the City makes a final
choice once the location is finalized.)
Pros:
¾ Potentially fewer emissions than aerobic or anaerobic composting
¾ Avoids use of parkland
¾ Proximity to Water Quality Control Plant should facilitate
permitting and operations
¾ Continue composting locally avoiding impacts on neighbors
¾ Avoids CO2 and toxic diesel emissions from trucking elsewhere
Cons:
¾ Less likely to receive diversion credits than anaerobic composting,
but quite possible
¾ Consumes more energy than aerobic or anaerobic composting
¾ More costly than aerobic or anaerobic composting
¾ Uses land desired by Airport users
¾ Substantial issues associated with proximity to Airport, Baylands,
and Water Quality Control Plant
3. Other Non-parkland Locations at and/or Adjacent to the Water Quality
Control Plant
(Note: While the Task Force identified the Embarcadero Road/Airport Site
as the top choice, all non-parkland sites at or adjacent to the Water Quality
Control Plant scored almost the same in the ranking exercise. Site geometry
may, however, impact the feasibility of particular options.)
Pros:
¾ Synergies with Water Quality Control Plant operations
¾ Same type of land use as Water Quality Control Plant
¾ Area already has industrial activities
Cons:
¾ Depending on exact configuration, proximity to Airport,
neighboring businesses, Baylands, and Water Quality Control
Plant will all be issues
¾ Purchase of land could be an issue
4. Regional Locations (San Jose, Gilroy, and others)
(Note: Currently advanced technologies are not available at Regional sites,
although GreenWaste is considering one in San Jose – 12 freeway miles
from Palo Alto. Palo Alto should fully evaluate this option, should it
become available.
23
Pros:
¾ Could be less costly than a smaller Palo Alto facility due to
economies of scale
¾ Would not take up Palo Alto parkland or other Palo Alto land
Cons:
¾ CO2 and toxic diesel emissions from trucking
¾ Organics sent to another community, impacting them
Appendix A-1
Palo Alto Staff Response to Short Term Recommendations
1) Transition from potable to reclaimed water saving approximately 3,700,000 gallons
per year of potable water.
Staff has concerns about fecal coliform bacteria and higher salt content from the use of
reclaimed water and the resulting quality impact to the finished compost. However, Staff
accepts the recommendation with the condition that reclaimed water be used at the
composting facility exclusively until such time (if any) that testing shows that reclaimed
water is contaminating the compost with unacceptable levels of salts or bacteria or, if
sales of compost are affected by reduced quality of finished material.
2) Suspend sale of blends and only sell pure compost - Blends are mixture of finished
compost with imported materials like sand to create additional landscaping materials.
The blends are not achieving the goal to move finished compost, especially since
commercial disposal has been discontinued at the disposal site, and those commercial
contractors were a primary customer. The yard has a throughput of about 600 tons per
year at $160 per ton.
Staff accepts the recommendation for the following reasons: 1) the volume of compost
sold from the material yard has been impacted by the suspension of commercial refuse
disposal at the landfill that has resulted in commercial customers not hauling back
compost from the facility, and 2) it is a costly and labor intensive operation whose profit
is marginal. Furthermore, Staff believes that the materials yard operation can be
discontinued with only minimal interruption in compost sales. The blended material does
account for 17% of the overall sales so projected revenue will be reduced.
3) Instead of utilizing chips for hog fuel with the requisite hauling to the Central
Valley, use the chips as Alternative Daily Cover (ADC) until the landfill closes.
(Estimated at 2,800 tons per year based on 2009 numbers.)
Staff is already using chips as well as other ground green material for ADC. Staff
accepts the recommendation and agrees that ADC is a less expensive final disposition
than transporting the chips to the Central Valley for hog fuel, as long as ADC is counted
as diversion in accordance with AB939.
4) Limit Size of Finished Compost Stockpile - While the current excessive size of the
stockpile may be an anomaly based on the economy, a limit will dictate actions before it
becomes a nuisance as was observed by the Task Group during the site visit. The
maximum stockpiled amount should not exceed 6,500 tons until 6 months prior to
cessation of acceptance of yard trimmings as part of the landfill closure. At that time,
the maximum amount stockpiled can rise to the amount needed for landfill closure.
Staff accepts the recommendation and agrees that 11,500 tons can be a viable finished
compost stockpile limit with the existing operation. The current finished compost
stockpile was recently measured to be approximately 6,500 cubic yards
APPENDIX A
Appendix A-2
5) Reduce Dust - The estimated 8,625 to 11,500 tons of compost material needed for
landfill closure should be managed to mitigate particulate loss, including covering it, if
necessary.
It should be noted that the compost that will be used in the closure will not be produced
until late 2010. Staff agrees to continue implementing dust control measures in
accordance with our facility’s BAAQMD permit which include such protocols as water
suppression or other measures as necessary to stay in compliance with Air District
particulate emission standards.
6) Increase the throughput of Finished Compost to Market-
a) Enhance convenience and expand availability of free compost for Palo Alto
residents. (For example more convenient pickup locations in town and more frequent
or continuous availability of finished compost.)
b) Review the pricing range (current price to free) of Palo Alto compost to improve the
flow of material to the commercial market.
Staff acknowledges that throughput has been slow of late due to lack of landscaping
projects from the recession, drought, and the commercial disposal ban (trucks not picking
up compost after they drop off). Staff agrees with the recommendation to add more free
giveaway days for residents (currently there are 5 per year). Staff will also evaluate
whether significant volume discounts should be implemented to promote bulk sales when
finished compost supplies are large.
7) Improve space utilization toward 7.5 acres or less with a consolidated footprint, for
example:
a) Locate all the materials handling operations (e.g., screening, finished product
storage, blending) closer together in the 7.5 acre footprint and closer to the windrows
to reduce transportation.
b) Investigate combining windrows as volumes reduce.
c) Limit width to 10 feet between windrows (width of the loader bucket) to minimize
area used.
d) Maximize the length of the windrows for land use efficiency.
Staff believes that the current 7.5 acre footprint is optimized for its equipment, traffic
flow and operation. The current windrows lengths, volumes, orientations, and spacing
are designed for the specifications of the Scarab windrow turner. Staff believes that
combining windrows should be accomplished when the scarab is down. Staff will
implement the 10 feet width between windrows. Staff believes that for safety purposes
and operational flexibility the option needs to be kept open for placement of only the
finished compost pile outside of the 7.5 acres.
Appendix A-3
8) Enhance the final product by initiating improved protocol for compost operations.
For example:
a) Materials need to move through the process on a clear and regular cycle. This better
serves commercial customers that can more easily use a predictable and dependable
supply.
Staff believes that the compost produced by Palo Alto is already very high quality and the
materials move through the process on a clear and regular cycle. An exception to this
cycle occurred last year when there were excessive and unexpected equipment
breakdowns during the year.
b) If the regular cycle cannot be maintained due to equipment breakdown or lack of
personnel, then material should be diverted to SmaRT/ZBest.
Staff agrees that the curbside collected material should be diverted to SMaRT if
equipment problems warrant it and have already been implementing that system within
the last year. On two intervals in FY 08/09 staff instructed PASCO to take green material
directly to the SMaRT station.
c) Add 100 gpm of reclaimed water at the grinder to enhance quality.
Staff believes that the finished compost produced by the site is already a high quality
product and would not need further enhancement of this type. In addition the site does
not have the equipment to input this large amount of water during processing.
d) Grind directly into a trailer or A-T dump truck to deliver material to the windrows.
Staff believes that moving the portable grinder adjacent to the new windrows and pushing
the material in place is the most efficient way of delivering material from the ground pile
to the windrows. Also, the windrow pad is not comprised of baserock and a truck would
not be able to be used during the wet season.
e) Increase water during windrow processing to 60% moisture content to enhance
quality.
Staff believes that the finished compost produced by the site is already a high-quality
product and would not need further enhancement of this type. Very wet compost (55 to
60%) can become heavy and clumpy, making its application more difficult and delivery
more expensive. A preferred moisture percent for finished compost is 40 -50% (Test
Methods & Parameters from the US Composting Council, 2009).
f) Turn more frequently 2x/week, minimum 1x/week
Staff accepts this recommendation and agrees that this could be accomplished with
minimal cost and some benefit.
9) Contain composting cost by examining outside expenditures. Recommendations
include:
Appendix A-4
a) Proactively send organic materials overflows to SMaRT station vs. Half Moon Bay
b) Avoid contracting out grinding services.
Staff accepts this recommendation and agrees that overflows to SMaRT is the most cost
efficient way to manage excess green material. As mentioned earlier, staff is already
doing this. Staff accepts this recommendation and advises that we will only utilize
contractor services when equipment problems occur or if landfill labor is in short supply.
Appendix B-1
PRIORITIZED
Airport/Compost Issues
[August 27, 2009-Subcommittee Meeting Results]
A) Safety Issues
1. Compost would attract birds
2. Compost too close to Heliport
3. The proposal forces reduced separation between fixed-wing and helicopters
B) Approval Issues
1. FAA must approve – may take several years, if possible at all
2. County must approve or give up lease – will be difficult
C) Land is Needed for Other Purposes
1. Overflow area for landing helicopters
2. Tie-downs so taxiway can be enlarged
3. Hangers
4. Terminal Building
D) Economic Viability of Airport
1. Should not “jump ahead” of Economic Plan now being prepared
NEXT STEPS
1. Prepare sufficient detail about the proposal to:
a. Demonstrate resolution of safety issues
b. Request approval from FAA/County
2. Find solution to Airport facility needs
APPENDIX B
Appendix B-2
Airport/Compost Issues
Identified at 7/29/09 Compost Task Force Meeting
& Modified at 8/18/09 Subcommittee Meeting
Federal and County Requirements
¾ FAA must approve any non-airport use (per grants received by the Airport)
¾ Cannot cease airport use prior to 2026- otherwise FAA Grant repayment required
¾ Use of land must be consistent with safety plan (Santa Clara County Airport Land
Use Commission and FAA approvals of safety plan revisions needed)
¾ FBOs have leases until 2017
The 4-Acre Site is Need For:
¾ Tie-downs so taxiway can be enlarged
¾ New heliport site (safety)
¾ “Overflow” landing site with respect to current site
¾ New hangars
¾ New terminal/administration building
¾ Allow separation between fixed wing and helicopter operations
¾ Changes will be very expensive
Helicopter Pad
¾ Compost pile proximity to pad - too close; downwash would create dust and debris
Wildlife and Hazards
¾ Compost pile would attract animals and birds (including geese) – hazard to
airplane engines
¾ Land is occupied by burrowing owls – endangered species
National Defense Issues
¾ Civil Air Patrol functions are located at the Airport
Visual Impact
¾ Compost Facility would detract from appearance of the area.
City of Palo Alto
¾ City is working on a business plan
¾ Financial issues
¾ “No Intensification” Policy and “no expansion into open space” have prevented use of site
¾ The County’s Lease Expires 2017 – Palo Alto may take over operations then
¾ Transition of the airport to Palo Alto may or may not occur even earlier in 2012 –very
uncertain
Degree of Use of Palo Alto Airport
¾ Regional and busy airport that is greatly needed
¾ Should not drive air-traffic to other airports
¾ Airport is a Regional “Reliever” for other airport traffic
¾ Council supports airport
¾ New buildings and facilities badly needed
Compost Final Report
¾ Should identify options and pros/cons
Working Together
¾ Compost could produce methane which could ultimately be a source of fuel
Appendix C-1
Date: 9/09/2009
To: Palo Alto City Council
From: Craig Barney, Co-chair of Blue Ribbon Compost Task Force
Cedric de La Beaujardiere, Co-chair of Blue Ribbon Compost Task Force
Bob Wenzlau, Member Blue Ribbon Compost Task Force
Subject: A Suggested Integration of the Proposed Composting and Airport
Facilities That Mitigates Airport Land Loss by Enhancing Facilities
The Blue Ribbon Task Force identified the Embarcadero/Airport site as the
recommended location for continued local management of organics in Palo Alto. The
Council invited the Task Force to further consider this recommendation during the study
session, and subsequently initiated discussions with advocates for the Palo Alto Airport.
The development of the integration approach described herein was motivated by a request
of several council members to seek a compatible land use arrangement between the
airport and compost operations. This memo offers a potential arrangement of an airport
that accommodates compost operations, improves the environmental footprint, and
provides for needed development of airport facilities.
This approach was developed by Bob Wenzlau, Craig Barney and Cedric de La
Beaujardiere who served on the Task Force and also on the airport subcommittee that was
formed to address concerns introduced by airport advocates when the compost site was
announced.
This memo was not adopted by the Task Force or the Task Force’s Airport
Subcommittee. However, the concepts within this memo were discussed by the Task
Force, and time constraints to achieve the Council’s schedule prevented the Task Force’s
full consideration and approval.
The genesis of this approach formed around the concerns introduced and prioritized by
the airport advocates and the Task Force Subcommittee. Those concerns are found in
attachment to this memo. Among the concerns, and top ranked were the following:
• Maintenance of safety of operations.
• Loss of helicopter landing that occurs on the undeveloped land.
• Maintaining tie-down capacity for airplanes
• Provision for a variety of improvements including improved and expanded
heliport, terminal and taxi-way.
The airport advocates held an interest in maintaining and growing the airport including
use of the same four undeveloped acres targeted for composting. During discussions,
there was concern that the inherent loss of airport lands proved irreconcilable within the
short time frame to achieve a mutually agreeable approach. Ultimately the airport
APPENDIX C
Appendix C-2
advocates felt that there should be better alternatives given the concerns raised. This
memo, never the less, seeks to respond to Council’s request to create an integrated
approach.
The proposed plan was informed by several premises:
• The airport should improve safety, including taxiways and heliports.
• The solution should contribute to, and not harm, the financial viability of the
airport.
• The airport should improve its environmental sustainability measurement.
• The terminals should be replaced and better integrated with other airport facilities.
• Any disruption to adjoining land uses should be minimized including disturbing
the parks and the golf course.
There were several observations made by the authors that informed this plan. Current
helicopter landing are not consistent with existing aviation design requirements, and
undeveloped land has been informally used as a second substandard landing site. We
also learned that any terminal must exist between an automobile parking area and the
taxi-way to facilitate safe access to passengers. Additionally, numerous tie-downs on the
County lease portion of the airport (north side) are unoccupied. While this may be a
manifestation of the economy or the County’s pricing strategy, the vacancies presented
land that might be applied to a solution.
A proposed solution would have a physical component (the airport/compost layout), and
an organizational component (the financial and organization elements). The physical
component is framed by land use, safety, and the environment, while the organizational
component is framed by economic viability of the airport and its organizational
framework.
Physical Layout: A proposed layout,
shown on Figure 1 and 2, achieves an
approach toward the physical layout
accommodating the composting
operations and allowing for
improvements sought by airport
advocates:
• A new expanded terminal
building located just south of the
control tower and east of a road
serving airport and golf facilities
and an existing parking lot.
(Shown as red outlined structure
on Figure 1)
• A new heliport area providing
capacity for two helicopters, and
likely improving safety by
moving the location away from
the proposed compost / existing
duck pond area, and allowing for
a helicopter-safety-compliant
area.
Figure 1. Detail of New Terminal (T) and Heliports (H) near Existing
Tower
Appendix C-3
• Improvements resulting in five increased tie downs: 23 tie-downs are eliminated
near the tower to accommodate the heliport and new terminal, but 28 new tie-
downs are created at the site of the existing terminal (that would be rebuilt in this
proposal.)
• The improvements do not address the taxiways or hangars, but neither do they
impose any restrictions on achieving this. In fact, an airport advocate suggested
hangars could be added north of the control tower, an area near the proposed new
terminal location.
• The improvement uses no golf course or park property.
Furthermore, proposed improvements utilize existing roadways and parking lots, both of
which appear underutilized. The arrangement achieves integration of terminal and airport
operations by placing them on the common access road to the golf course and airport.
The existing fuel terminal remains and is undisturbed.
Figure 2: Location of Improved Terminal and Proposed Composting Site (with shifted Embarcadero Road)
Compost
Improvement
Area
Airport
Improvement
Area
Appendix C-4
Organizational Considerations: Integrating compost and airport operations provides
organizational and financial advantages. We anticipated many changes after the city
takes ownership, changes that can trigger accommodation of compost operations. As
suggested by one of the airport advocates, the compost operation by the City could be
designated a new Fixed Base Operator (FBO). When the FBO (in this case the compost
operation) pays land rent to the general fund, the land rent could contribute to airport
overhead, such as long-term funding of new terminals and heliports. These rent
payments, consistent with the four acres utilized, are approximately $400,000 per year.
The City, through its compost operation, and as a potential FBO, could also set as a goal
the use of biologically-generated methane for airport use. With sustainability fuels
integrated into the airport, the FAA might find Palo Alto’s airport a model of
sustainability in airport operations. One airport advocate thought that enhancing the
sustainability of the airport would ease expected regulatory bars set by the FAA and the
County.
Potential harmonizing of compost, airport operations within the framework of the
Baylands Master Plan moves Palo Alto toward a vision of a sustainable community that
develops innovative accommodations to land use challenges.
Appendix C-5
Airport/Compost Issues
Identified at 7/29/09 Compost Task Force Meeting & Modified at
8/18/09 Subcommittee Meeting
Federal and County Requirements
¾ FAA must approve any non-airport use (per grants received by the Airport)
¾ Cannot cease airport use prior to 2026- otherwise FAA Grant repayment required
¾ Use of land must be consistent with safety plan (Santa Clara County Airport Land
Use Commission and FAA approvals of safety plan revisions needed)
¾ FBOs have leases until 2017
The 4-Acre Site is Need For:
¾ Tie-downs so taxiway can be enlarged
¾ New heliport site (safety)
¾ “Overflow” landing site with respect to current site
¾ New hangars
¾ New terminal/administration building
¾ Allow separation between fixed wing and helicopter operations
¾ Changes will be very expensive
Helicopter Pad
¾ Compost pile proximity to pad - too close; downwash would create dust and debris
Wildlife and Hazards
¾ Compost pile would attract animals and birds (including geese) – hazard to
airplane engines
¾ Land is occupied by burrowing owls – endangered species
National Defense Issues
¾ Civil Air Patrol functions are located at the Airport
Visual Impact
¾ Compost Facility would detract from appearance of the area.
City of Palo Alto
¾ City is working on a business plan
¾ Financial issues
¾ “No Intensification” Policy and “no expansion into open space” have prevented use of site
¾ The County’s Lease Expires 2017 – Palo Alto may take over operations then
¾ Transition of the airport to Palo Alto may or may not occur even earlier in 2012 –very
uncertain
Degree of Use of Palo Alto Airport
¾ Regional and busy airport that is greatly needed
¾ Should not drive air-traffic to other airports
¾ Airport is a Regional “Reliever” for other airport traffic
¾ Council supports airport
¾ New buildings and facilities badly needed
Compost Final Report
¾ Should identify options and pros/cons
Working Together
¾ Compost could produce methane which could ultimately be a source of fuel.
Appendix D-1
2021 LOCATION SCREENING
Site Acreage*
1. A site solely within the RWQCP Uncertain
2.
A site (unspecified location) within and immediately adjacent to
the WQCP (This may include Nos. 2, 3, 4 and/or 6.)
Uncertain
3. Palo Alto Airport (assumes Airport closure). 100
4. The Embarcadero Road-Airport site (assume Airport continues to
operate)
4
5. Z-Best site (near Gilroy) Sufficient
6. A site centered in the RWQCP which may include Nos. 2, 3, 4
and/or 6 and may also include a small portion of Byxbee Hills
Park (current landfill), if necessary to provide a minimally suitable
site.
Uncertain
7. The LATP site 6+
8. The North Runway-Airport site (assume Airport continues to
operate)
22.5
9. The PA Landfill site 7+
10. An unspecified location on Stanford Land Uncertain
11. Regional site (other than Z-Best) Sufficient
12. An unspecified location to be purchased in the Palo Alto area.
(An example includes Park Avenue land South of Oregon
Expressway.)
Uncertain
*Note: Competing potential uses exist for any and all sites. No sites or portions thereof
have been reserved for organics materials management.
** Note: SCREENED OUT ON 6/17/09
** 2. The WQCP-Landfill Interface site 2.3
** 3. The Embarcadero Way City-Owned City site 2.6
** 6. An Embarcadero Way site to be purchased 3.6
** 10. The Police Building site 1.5
APPENDIX D
Appendix D-2
Appendix D-3
Appendix D-4
Appendix D-5
Appendix D-6
Appendix D-7
Appendix D-8
Appendix E-1
Task Force Activities
Meetings were held weekly in March of 2009 as the Task Force organized itself, selected Co-
Chairs, established procedures, and developed communication methods. As a group covered
by the Brown Act, agendas were published and posted as required. The City’s website was
used to share documents among Task Force members, and members of public.
Meetings were changed to every other week in April and continued through September when
the Task Force completed its work. Key accomplishments for each month were as follows:
March
¾ Administration/Organization
¾ Mission Statement Developed
¾ Timeline Developed
¾ Technical Subcommittees Formed
¾ Screening/Ranking Criteria Developed
April
¾ Screening/Ranking Criteria Developed
¾ Three Subcommittees Analyze Alternatives
o Aerobic
o Anaerobic
o High Tech
¾ Permitability of Alternatives Analyzed
May
¾ Greenhouse Gas Emissions Analyzed
¾ (“What” More Important than “Where”)
¾ Technologies Seminar Held
¾ Technology Timelines Analyzed
¾ Baylands History and Land Use Analyzed
¾ Task Force Report Outline Developed
¾ Input From California Integrated Waste Management Board Obtained
June/July
¾ Further Analysis of the following was accomplished:
o Aerated Static Piles (Aerobic)
o Dry Fermentation (Anaerobic)
¾ Screening and Ranking Alternatives was completed for the following
timeframes:
o Immediate (Operational) Changes
o 2012 Timeframe
o 2021 Timeframe
¾ Council Study Session was held on July 20, 2009
August/September
¾ Finalized Recommendations
¾ Finalized Brief Report
APPENDIX E
Appendix F-1
Greenhouse Gas Impacts of Palo Alto Organic Wastes
By Bryan Long 8/17/09
Summary
Substantial greenhouse gas (GHG) reductions can be achieved first by diverting food and
other wet organic wastes from landfill disposal, and then by moving to advanced
anaerobic digestion technology for our wastewater, food wastes, and yard wastes. Non-
local transport of our organic wastes contributes to GHG emissions, but as can be seen
from the chart below, how we process our organic wastes matters much more than where
that processing occurs.
Food wastes and other moisture-
rich compostable wastes quickly
decompose in landfills, releasing
substantial methane gas long
before methane recovery systems
are in place. Achieving the
contract collection target of our
new commercial, institutional,
and multi-family residence
(C/I/M) food waste program will
reduce methane emissions by at
least 6,000 and as much as
15,000 metric tons (mT) of CO2
equivalent, depending on
emissions model assumptions.
Surpassing our collection target
or implementing a single-family
foodwaste collection program would reduce GHG emissions even more.
The use of Advanced Anaerobic Digestion (AAD) facility to process our wastewater
sludge, C/I/M foodwaste, and collected yard wastes would reduce CO2 emissions by an
additional 14,000 mT of CO2 equivalent. A 50% increase of total foodwaste collections
(from the current target of 9,000 mT) would result in an additional reduction of between
6,300 and 16,200 mT of CO2e.
Together, these steps could reduce our city’s GHG emissions by 2% to 5% from the total
emissions estimated in the Palo Alto Climate Action Plan. It should be investigated
whether some of this might qualify for carbon credit sales under the emerging GHG Cap
and Trade legislation.
APPENDIX F
Appendix F-2
Palo Alto’s organic waste disposal currently contributes between 2.64% and as much as
7.74% of Palo Alto’s annual anthropogenic greenhouse gas (GHG) emissions, depending
on assumptions. The large variance in the estimate above is primarily due to differences
in estimates regarding how much methane is released from food scraps and other wet
compostable matter sent to the landfill (see “A Trip to the Landfill”, below). Once the
new GreenWaste program for institutional/multifamily food scraps composting is well
established, our organic wastes will still contribute between 1.76% and 5.64% of our
city’s total “footprint”.
Fortunately, methods and technologies exist that would allow us to substantially reduce
these GHG emissions,
1. A reduction of approximately 8,650 mT of CO2e1 could be realized by diverting
sewage sludge from incineration to energy-generating Advanced Anaerobic
Digestion (AAD).
2. A reduction of 5,300 mT CO2e, or more, could be realized by shifting organic
materials, food, and other compostables from composting to AAD.
3. Increasing commercial/multifamily collection rates or implementing a single-
family residence collection program would achieve reductions of between 1.4 mT
and 3.6 mT of CO2e per additional mT of food and organic materials diverted
from the landfill. A 50% increase of total collections from the current target of
9,000 mT would result in a reduction of between 6,300 and 16,200 mT of CO2e.
Together, these steps could reduce our city’s GHG emissions by 2% to 45% from the
total emissions estimated in the Palo Alto Climate Action Plan2. It should be investigated
whether some of this might qualify for carbon credit sales under the emerging GHG Cap
and Trade legislation.
Transportation of our organic wastes contributes less than 4000 (est.?) mT of CO2,
regardless of regional destination, and much of this is due to local collection. Insofar as
GHG reduction is concerned, how we process our organic waste is far more important
than where we process it. Nevertheless, city ownership of processing operations would
provide greater assurance of optimal GHG reductions, and would likely reduce long-term
costs to the ratepayers, since contract operators require a profit above capital and
operational costs and demand for these services is high.
Palo Alto’s Organic Waste GHG Sources
1 CO2e is CO2 equivalent, which translates the GHG impact of methane and other gases,
measured over a 100 year timeframe to the amount of CO2 that would have an equivalent
impact. See box section: The Methane Effect
2 The Palo Alto CAP estimates a total of 794,049 mT of CO2e from all sources. However
this is probably an underestimate due to overly conservative estimates of methane
emissions from landfilled wastes.
Appendix F-3
Primary organic waste sources of GHG emissions include:
TYPE OF ORGANIC WASTE ESTIMATED GHG EMISSIONS
Food scraps and other compostables sent to
landfill
21,000 – 61,000 mT CO2e (2008)
14,700 – 44,800 mT CO2e (2010 est.)3
Sewage sludge incinerated at WQCP 21,200 mT CO2
Yard clippings and other greenwaste
(compost)
15,000 mT CO24
Transportation and Processing < 4000 mT CO2 (??)
TOTAL (2008) Approx. 60,000 – 100,000 mT CO2e
As much as 41,000 mT of the above is considered “biogenic” in origin: CO2 that was
originally taken up from the atmosphere by plants through the process of photosynthesis
before being utilized by humans. Biogenic CO2 is not counted when calculating Palo
Alto’s “footprint” of anthropogenic (human caused) GHG emissions. For example, CO2
from composting operations is biogenic, as is CO2 released from landfills. Methane
released from landfills is counted as human caused, however, since decomposition under
natural conditions would not usually generate methane.
The Palo Alto Climate Action Plan estimates our city’s total anthropogenic emissions at
approximately 728794,000 mT of CO2e. Landfill-related emissions, however, are
probably underestimated. The CAP provides an estimate of 24,183 mT of annual landfill
waste-related emissions, including the “upstream” emissions associated with
manufactured goods. This was based on generic modeling software, and the assumption
that the landfill would have effective methane capture. Such models and assumptions
have come under criticism, however, because most landfills do not install methane
recovery for several years after disposal of waste into a “working cell”, and wet organic
wastes like food and grass will decompose within a few months (see “A Trip to the
Landfill” below). Thus for the higher food scraps estimate in the table above, the total
city emissions should be increased by an equivalent amount.
At the low end, anthropogenic emissions from the above listed organic waste categories,
prior to the new food scraps composting program, total about 19,000 mT, or about 2.6 4
% of a 728794,000 mT total. At the higher end, anthropogenic emissions total about
59,000 mT, or about 7.74% of a 768794,000 mT total. After the new commercial &
multifamily food composting program goes into effect, anthropogenic emissions from
these sources will be between 12,700 mT and 42,800 mT – equivalent to between 1.76%
and 5.64% of total city emissions.
3 Estimate for 2010 after new GreenWaste program for collection and composting of
institutional and multifamily residence food wastes.
4 Estimate based on 60% water content, 50% carbon content in dry material, and
complete release of carbon as CO2. A good bit of carbon is retained in the finished
compost, but most of this decomposes over time after application.
Appendix F-4
It is important to note, however, that as Palo Alto works to reduce our footprint, any
biogenic CO2 reductions achieved by sequestration or “green energy” production are as
effective as any anthropogenic CO2 reductions. For example, our current composting of
yard waste releases about 15,000 mT of biogenic CO2 per year. The same amount of
yard waste in an advanced anaerobic digestion facility will produce only 12,100 mT of
CO2, along with a substantial amount of methane. When that methane is burned as fuel,
the “missing” 2,900 mT of CO2 will be released. But without AAD, fossil gas would
have been burned instead of that methane, producing about the same 2,900 mT of CO2 in
addition to the 15,000 mT from composting.
Thus, AAD reduces net anthropogenic
emissions.
Food/Compostable Waste: A Trip to
the Landfill
Compostable organics compromised about 29%
of Palo Alto’s “black bin” and dumpster waste
sent to the Kirby Canyon landfill in 2008 (the
Palo Alto landfill is open only to “self-haul”
from Palo Alto residents). These landfilled
organic compostables add up to over 22,000
metric tons per year – a greater tonnage than our
yard waste composting operation handles.
More than half of the organic compostable
waste is food scraps.
Food scraps, and moisture rich compostable
waste like grass clippings, creates substantial
methane gas emissions when landfilled. These
wet organic wastes are dumped onto the open,
working face of the landfill, and quickly buried
under new incoming loads of waste. This
creates a moist, warm, low oxygen environment
in which anaerobic (low oxygen) decomposition
rapidly sets in.
Within 120 days, food scraps and grass
clippings may be nearly fully decomposed, with
substantial methane generation (Brown, et al, J.
Environ. Qual. 37:1396–1410 (2008))5. This
occurs long before any methane recovery
5 Landfill operations, design, climate, and waste composition will affect the timing and
degree of wet organics decomposition, but specific data for the Kirby Canyon landfill
was not available for this analysis. Our dry summer climate may reduce decomposition
during those months, but our relatively warm wet winters may have the opposite effect.
The Methane Effect
Methane (CH4) is a molecule
consisting of one carbon atom
surrounded by four hydrogen atoms.
It arises in many natural processes,
but is of particular concern to us as a
product of municipal waste disposal.
The specific molecular structure of
CH4 makes it much more likely than
a CO2 to absorb a heat photon.
Fortunately, methane is also not very
stable. In any seven year period, a
methane molecule has about a 50%
chance of breaking down into CO2
and H20 (water). In calculations
about climate change, therefore, the
effects of methane emissions are
calculated over a specified time
period, usually 100 years. Over a
period of 100 years, methane is 25
times more potent than an equal
amount (by weight) of CO2. Over a
period of 20 years, however, methane
is 72 times more potent than CO2!
This makes methane a prime target
for near-term GHG reductions while
we work on more difficult longer
term CO2 reductions. Reducing
methane emissions today provides
72 times the impact over the next 20
years than does reducing an
equivalent amount of CO2. (source:
IPCC)
Appendix F-5
systems are put in place (usually 2 years or more after disposal). Although some of this
methane will be oxidized to CO2 as it reaches the surface of the landfill, most will escape.
Use of simple GHG estimation models such as the EPA’s WARM calculator or ICCLI’s
CACP are inaccurate for food and grass waste if landfill recovery of GHG is assumed in
the model. The EPA WARM model can be run on food scraps and grass clippings under
the assumption of no methane recovery to get a better, but still conservative estimate of
GHG emissions. The EPA WARM model gives a conservative result of 21,940 mT of
CO2 equivalent emissions6 that would be avoided if our landfilled food, grass, and leaves
waste were composted instead of landfilled. Other research suggests that our annual
landfilled food, grass, and leaves may generate as much as 68,000 mT of CO2 e from
methane (Brown, et al, J. Environ. Qual. 37:1396–1410 (2008), compared with a
theoretical maximum of about 10,000 tons of CO2 if diverted to composting. The truth
probably lies somewhere in-between: Palo Alto could achieve GHG reductions of 1.4
mT to 3.6 mT of CO2e per mT of food and organic materials diverted from the landfill.
It must also be noted that the estimates above refer to 100 year CO2 equivalents.
However, methane reduction benefits are “front-loaded”, whereas most governmental
plans for CO2 reductions are “back-loaded”, putting off most of the necessary reductions
to future decades (see box “The Methane Effect). Keeping in mind that our City goals
for GHG reductions are based in our desire to keep the planet livable, we should welcome
measures that have their most significant impact in the near term. Using a 20-year CO2e
calculation, Palo Alto could achieve GHG reductions of an outstanding 4 mT to 12.3 mT
of CO2e per mT of food and organic materials diverted from the landfill!
A Good First Step: 2009 Compostables Collection
In 2009, Palo Alto begins a new program with our new waste hauler, GreenWaste, to
divert segregated compostable organics from the general waste stream, for composting at
ZBest in Gilroy. This program will serve only commercial and multifamily residential
buildings, not single-family residences.
Commercial and multifamily buildings generate around 16,900 mT of compostable
wastes annually, which includes compostable paper as well as food and yard waste.
The City’s contract with GreenWaste establishes a target of 9000 tons of segregated
compostables to be collected annually, with an incentive of $70 per ton for exceeding the
target and a penalty of $70 per ton for shortfalls. Experience from other cities (e.g., San
Francisco) suggests that this will be about 50% food and organic materials, and 50%
compostable paper and other compostables. Thus we can estimate that if the target of
6 CO2 Equivalent (CO2e) emissions converts the warming impact of methane (or other
GHGs) over 100 years into the amount of CO2 that would produce the same amount of
warming over the same amount of time. Metric tons of methane emissions can be
multiplied by 25 to get the 100-year CO2 equivalent (some models use 21 or 23 as the
factor, based on older estimates). Over a 20-year evaluation period, the CO2 equivalent
of methane would be much higher – a factor of 72.
Appendix F-6
9000 mT is reached, this will mean 4500 mT of food and organic materials diverted to
composting. This will result in GHG emissions reduction of between 6,300 and 16,200
mT of CO2e, which would be around a 1-2% reduction in our City’s total GHG footprint.
Next Steps: Improving and Expanding the Program
In auditing GreenWaste collections, the City should measure not just the total tonnage of
compostables, but the composition of what is collected. Increasing the percentage of
food scraps collected, compared especially with waste paper products, will have the most
significant benefit in terms of GHG reductions. If institutional/multifamily collection
efficiency could be increased to 75%, that would result in an additional 3,150 to 8,100
mT CO2e reduction. Expanding the program to serve single-family residences should
also be attempted, if costs are not prohibitive. A 50% efficient collection of single family
residence food scraps compostables would provide a 3500-9000 mT reduction in CO2e.
Sewage Sludge: Anaerobic digestion vs. Incineration.
Palo Alto incinerates approximately 24,000 mT of sewage sludge annually7. The
incineration of the sludge itself releases approximately 16,000 mT of CO28, while the
natural gas used to incinerate the sludge releases another 5200 mT of CO29. The end-
product of incineration is an ash that is landfilled as low-grade hazardous waste.
Many communities around the world are migrating to Advanced Anaerobic Digestion
(AAD) for processing of sewage sludge, sometimes on its own and sometimes along with
other municipal wastes. AAD would reduce 24,000 mT of sludge to between 3000 mT –
12,000 mT10 of digested sludge cake – a safe and low odor product containing no
detectable levels of pathogens that may be used as a valuable agricultural fertilizer11 .
More importantly, from 24,000 mT of sludge AAD could generate approximately 66,300
MMBTU of methane natural gas12, while saving an additional 100,000 MMBTU of
natural gas that would have been used for incineration. At current spot market prices for
natural gas13, the combined generated and saved natural gas is worth approximately
$548,790, and much more at retail prices.
7 Only about 35% of this is from Palo Alto, the rest is from neighboring communities. 8 2008 Palo Alto Emissions Report
9 Approximately half of this is methane gas captured from the landfill, but it is gas that
could be used for other purposes. 10 Different digestion technologies result in differences in end-product volume 11 Renewable Energy World April 27, 2009 Advanced Anaerobic Digestion: More Gas
from Sewage Sludge
12 24,000 mT wet, 25% solids, = 6000 mT dry = 13,260,000 lbs
= 66,300,000 cf CH4 = 66,300 MMBTU based on: EBMUD study, “Anaerobic Digestion
of Food Waste” March 2008; “Stable anaerobic digestion of food waste at both mesophilic and
thermophilic temperatures provides more gas production (6 to 8.5 ft3 CH4/lb TS applied) than digestion of
municipal wastewater solids (5 ft3 CH4/lb TS applied.)” Different anaerobic digestion
technologies may produce more or less CH4 gas. 13 Approximately $3.30 per MMBTU (NYMEX)
Appendix F-7
Even more importantly from a GHG perspective, total GHG reductions would equal
about 8650 mT of CO2. This is composed of 5200 mT of CO2 would be avoided by not
burning gas to fire the incinerator, and a 3450 mT CO2e “credit” from the methane
produced14. Thus the use of AAD could reduce CO2 emissions by between 8650, for
sewage sludge alone. The use of AAD for other municipal waste is considered below.
Advanced Anaerobic Digestion vs. Composting
Anaerobic digestion can also be utilized instead of composting for yard waste, food
scraps, and other compostable organics. As with composting, anaerobic digestion results
in an end-product suitable for agricultural soil conditioning15. AAD, however, captures
methane as “green energy” which provides a net CO2 reduction credit.
Based on 21,000 mT organic materials, AAD could generate approximately 55,700
MMBTU of CH4 natural gas16, with a resulting emissions reduction credit of
approximately 2900 mT CO2. If Palo Alto increased its collection of organic materials
from landscaping contractors, it would realize additional green energy.
For commercial and multifamily food and compostable waste, based on the current
GreenWaste collection target of 9000 mT, AAD could generate approximately 46,500
MMBTU of CH4 natural gas, with a resulting emissions credit of approximately 2400 mT
CO217. If we could realize 12,000 mT of commercial/multifamily collections (a 75% vs.
50% collection rate), these figures would increase to 69,700 MMBTU and 3,600 mT of
CO2. Any collection of single family residence food scraps and compostables would
provide a further increase.
The AAD process generates a biogas which is a mixture of methane and CO2 (usually
about 60% methane). The biogas is then either burned to generate electricity or “cleaned
14 Methane produced from AAD is “green” because it displaces an equal amount of fossil
natural gas that would otherwise be consumed. 1 ft3 CH4 combusted will result in 1 ft3 of
CO2 (Gas turbine handbook); CO2 at .00184212 g/cm3 * 28317.016 cm3/ ft3 = 52.16 g/ft3.
66,300,000 ft3 CH4 = 3458 mT CO2. This is the amount considered avoided from fossil
natural gas. 15 Quantity and market value may differ, however. In general, compost from 100%
organic materials will have higher market value than either food waste compost or
digested end-product.
16 21,000 mT @ 40% solids = 8,400 mT dry = 18,564,000 lbs
= 55,692,000 ft3 CH4 (conservative estimate, yield 50% less than food waste, below)
= 55,692 MMBTU (1 ft3 CH4 contains approximately 1000 BTU of energy) 17 assuming 9000 mT collected, 50% food, 50% paper:
4500 mT * 28% solids = 1260 dry mT
4500 mT * 50% solids = 2250 dry mT
= 7,735,000 lbs = 46,410,000 ft3 natural gas (6 ft3/lb, EBMUD 2008)
= 46,410 MMBTU CH4 = 2420 mT CO2 when combusted
Appendix F-8
and scrubbed” to produce a commercial quality CH4 natural gas. It is possible to capture
the CO2 as well, and sequester it, for much larger CO2 reduction credits. This will
involve significant additional capital and operational costs, however, and is not calculated
in this assessment.
Summary of GHG Reductions and Green Energy Production
CO2e Reduction MMBTUs
Diverting 9000 mT Food/Compost from Landfill 11,250 mT18 0
Utilizing AAD for Food/Compost above 2,400 mT 46,500
Diverting wastewater sludge from incineration19 5,200 mT 100,000
Utilizing AAD for sewage sludge 3,450 mT 66,000
Utilizing AAD for yard/organic materials 2,900 mT 55,700
Total 25,200 mT 268,200
The total reduction of 25,200 mT CO2e is almost 3.52% of Palo Alto’s total GHG
emissions as estimated in the Climate Action Plan. The total of 268,200 MMBTUs of
natural gas is worth about $885,000 at the current spot market wholesale price for natural
gas.
Further potential for reductions are:
CO2e Reduction MMBTUs
Diverting additional 4,500 mT Food scraps 5625 0
AAD for additional 4,500 mT Food scraps 1,200 23,250
Increasing yard/green collections 20% 580 11,140
Total 7405 34,390
Implementation
Achieving the GHG reductions and green energy productions listed above may be
accomplished in at least three ways:
1. by establishing contracts with waste management companies which specify
landfill diversion and CO2e reduction requirements (via AAD or other advanced
conversion technologies)
2. by design and implementation of an AAD facility owned by the City of Palo Alto
3. by partnership with other regional cities for the ownership and/or operation of a
regional AAD facility
18 Based on the average of the high and low estimates. 19 Natural gas not used for incineration that can be used for other purposes.
Appendix F-9
Waste management companies operating organics conversion facilities can achieve
economies of scale by serving numerous regional municipalities. However, regional
municipal demand for organic conversion services is likely to outstrip commercial
facility capacity for some time to come. Service providers will certainly capitalize on
high demand by charging a premium for GHG reducing services, and retaining all profits
from green energy production. On the other hand, for those municipalities willing to pay
the premium, contract services will avoid the capital investment and expertise
development required for city-owned facilities.
If Palo Alto is willing to invest capital and land in a city owned facility, or to partner with
other municipalities in building an AAD facility, utilities rate-payers would likely realize
the lowest long-term cost as revenues from green energy production will help offset
operational costs.
Background Information on Greenhouse Gases
Getting to Know the Greenhouse Gases
Greenhouse gases in the Earth’s atmosphere allow visible light photons from the sun to
pass freely to the earth, but tend to absorb passing infrared (heat) photons from the earth
and then re-emit those photons in any direction, including back where they came from.
Just as a blanket over your body retains your body heat, the blanket of greenhouse gases
retains the heat of the planet. Human-caused increases in the concentration of
greenhouse gases is like adding another blanket – on a hot summer night.
source: IPCC
Carbon Dioxide (CO2)
Of the primary greenhouse gases, CO2 is by far the most prevalent. Increasing levels of
CO2 in the atmosphere due to the human burning of coal, oil, and natural gas is the
primary culprit in climate change. CO2 is a very stable molecule: once in the atmosphere
it stays there, unless taken out by processes at the surface of the Earth, such as
Appendix F-10
photosynthesis by plants. The flow of CO2 into plants as they grow, and out of plants as
they die and rot, is a fairly balanced process20, and so changes in atmospheric CO2 levels
have been gradual, until the past couple of hundred years. The human extraction and
burning of fossil fuels (coal, oil, and natural gas) has created a dramatic, rapid rise in CO2
levels that is already creating climate change, ocean level rise and severe weather events.
Our best science suggests we must change our ways, and start reducing CO2 emissions by
at least 2% per year to prevent disastrous climate change.
Methane (CH4)
Methane is a molecule consisting of one carbon atom surrounded by four hydrogen
atoms. It arises in many natural processes, but is of particular concern to us as a product
of municipal waste disposal. The specific molecular structure of CH4 makes it much
more likely than a CO2 to absorb a heat photon. Fortunately, methane is also not very
stable. In any seven year period, a methane molecule has about a 50% chance of
breaking down into CO2 and H20 (water). In calculations about climate change,
therefore, the effects of methane emissions are calculated over a specified time period,
usually 100 years. Over a period of 100 years, methane is 25 times more potent than an
equal amount (by weight) of CO2. Over a period of 20 years, however, methane is 72
times more potent than CO2! This makes methane a prime target for near-term GHG
reductions while we work on more difficult longer term CO2 reductions. Reducing
methane emissions today provides 72 times the impact over the next 20 years than
does reducing an equivalent amount of CO2. (source: IPCC)
Nitrous Oxide (N2O)
Nitrous Oxide is released into the atmosphere from many natural processes, as well as
from the use of nitrate fertilizers in agriculture, decomposition of food and animal wastes
in landfills, the processing of sewage, and the burning of fossil fuels, (as well as trace
amounts from compost piles, dentist offices, whipped cream cans, and open pints of
Guinness!) N2O is a stable molecule, and is about 300 times more potent than CO2 over
100 years (289 times more potent over 20 years). Although composting generates some
N2O, the application of compost to agricultural fields can significantly reduce the need
for nitrate fertilizers and the consequent release of much larger amounts of N2O.
Advanced technologies like anaerobic digestion with cogeneration release even less N2O
than aerobic composting (Willis et.al., 2008).
Technologies
Aerobic Decomposition, Anaerobic Decomposition, Incineration and Pyrolysis
Aerobic (oxygen rich) decomposition occurs when organic materials decay in the
presence of air, as in a compost pile. In these conditions, micro-organisms break down
the complex, carbon and hydrogen rich molecules of organic matter primarily into water
20 Except when humans clear-cut forests, or when climate change causes major
vegetation pattern changes.
Appendix F-11
and CO2. Some trace amounts of methane and nitrous oxide may also be released, but in
a well-managed composting operation these emissions are negligible. A significant
amount of organic material remains in the finished compost, which will decay over a
period of years into CO2 and water.
Anaerobic (oxygen deprived) decomposition occurs when organic materials are buried, or
otherwise contained without exposure to air. In this case, micro-organisms and chemistry
cause the carbon and hydrogen molecules from the organics to form methane (CH4), in
addition to CO2 (where the oxygen atoms come from water molecules). The relative
production of CH4 and CO2 will vary according to conditions, but typically CH4 will be
50% or more of emissions by weight. Material remaining from anaerobic decomposition
is essentially the same as finished compost.
Incineration involves heating organic materials to a combustion temperature in the
presence of oxygen, and results in a complete release of all carbon, hydrogen, and
nitrogen into gas form. Properly managed, Nitrous Oxide emissions are minimal, and no
methane is released, so CO2 is the predominate GHG.
Pyrolysis involves heating organic materials to combustion temperature in the absence of
oxygen. This results in the production of “syngas” consisting primarily of methane and
CO2, and the production of liquid hydrocarbons “bio-diesel” and/or charcoal. Pyrolysis
differs from anaerobic digestion in that conversion depends solely on heat, not on
microbes
Appendix G-1
APPENDIX G
Appendix G-2
APPENDIX G
April 6. 2009
Mayor Drekmeier and Members of the Gty Council:
I received a free copy card so I used it to copy for you my latest version of the Com posting
Costs at Byxbee Park. r have submitted this information to our Composting Task Force as
weU.
CMR 178:09 in your packet this week includes information on contracts awarded by the City
Manager from July 2008 to December 2008. Included in those are the following items which
probably also pertain to the composting costs:
Ahem Rentals
Skylonda Equipment
Peterson Tractor
Peterson Tractor
Power Screen of No CA
Morbark Inc.
Extec West
Skylonda Equipment
Tractor Equipment Sales
TMT Enterprises Inc.
8/7/08
8/'15/08
9/r:f!/08
9/11/08
9/11 /08
9/15/08
7/10/08
8/14/08
8/27/08
9/26/08
27,149.14'
45,(XXJ.OO'
249,496.68
85,000.00'
27,000.00'
45,000.00'
40,000.00·
85,000.00
65,000,00·
98,000.00·
Water truck rental
Trucking Services
Purchase of Wheel Loader 950H
Caterpillar equipment, parts & service
Power screen parts and service
Wood grinder, parts& service
Compost screener rental (2nd year)
Trommel screen rental w. operator
PM & repairs for Landfill Equipment
Purchase of Com posting Material
The items from the above list that are not ioclyded* in my summary total $432,149.14 or
$20,58/ton, bringing the total per ton to $l2S.36/ton at Byxbee Park.
The Composting Task Force will be developing its own numbers, but this is where my numbers
are at the present time.
Sincerely,
Emily M. Renzel
1056 Forest Avenue
Palo Alto, CA 94301
April 6. 2009
Mayor Drekmeier and Members of the Gty Council:
I received a free copy card so I used it to copy for you my latest version of the Composting
Costs at Byxbee Park. I have submitted this infonnation to our Composting Task Force as
weU.
CMR 178:09 in your packet this week includes information on contracts awarded by the Gty
Manager from JuJy 2008 to December 2008. Included in those are the following items which
probably also pertain to the composting costs:
Ahem Rentals
Skylonda Equipment
Petersen Tractor
Peterson Tractor
Power Screen of No CA
Morbark Inc.
Extec West
Skylonda Equipment
Tractor Equipment Sales
TMT Enterprises Inc.
8/7/08
8/'15/08
9/09/08
9/11/08
9/11/08
9/15/08
7/10/08
8/14/08
8/27 /08
9/26/08
27,149.W
45,000.00'
249.496.68
85,000.00'
27,000.00'
45,000.00'
4O,OOO.(Xt
85,000.00
65,000.00·
98,000.00'
Water truck rental
Trucking Services
Purchase of Wheel Loader 950H
Caterpillar equipment, parts & service
Power screen parts and service
Wood grinder, parts& service
Compost screener rental (2nd year)
Tremmel screen rental w. operator
PM & repairs for Landfill Equipment
Purchase of Com posting Material
The items from the above list that are not ioclyded* in my summary total $432.149.14 or
$20,58/ton, bringing the total per ton to $125.36/ton at Byxbee Park.
The Composting Task Force will be developing its own numbers, but this is where my numbers
are at the present time.
Sincerely,
Emily M. Rcnzel
1056 Forest Avenue
Palo AJto, CA 94301
Appendix G-3
APPENDIX G
What it would cott 10 run the CODlpott Opention .... tadd...:loH operation in 8yxbee Puk by Emily R .... I 3/1","
I .... f/OI ra.;blUty U/UIOOQIoA IIU/OO ..... , ReeuI 3/1100 Reeul3/1IOO
S<dy CMlt. 116:09 .-01" beMfltI) C5l$ 1Jeaeft.)
LEA AMUai Pamjt Pee 0 0 0 0 fU,722 , U,722
s.&uilll 6; BeNftti ,
2lO,<XX) -.... S32a6oW (CMlt 116:09) ........ ''It/193 I""""'''''' ln RCSQ
(Dolly Poot2/3/09, 38lI»
$l39,IJU
~ r-x diIpoNl.ttendant (.VB $7'1..301) , 12.301
2 t::lau ~pmenl operltort (."1 $9l.909.75) $18!SAI9
1 ec:hnIdan $111,966
." offW~"""",,, 9< • .....-Solld W_ ,Mar Bnv."""""-
En SpedaliIt _ $1.l58,3t2 x .Of • , ",333
Contrlct Servlcea $178.00> $118.000 $i'18.000 (CMR 116:(9) $17"8,000 $118.000
BquI ...... (detoll bolow)
I 29,119 $171,898 (_ below) -(8.5 __ $101,163 $22J),64lI
... --""""' ... Clwpo 0 0 ,_ ($107 ..... 529,".) ,-,-Bwtpt-,150,000 $\30,101 IgIndlng) '''',000 (CMR 3117"') '180,000 $1......,
...... 0. 0 0 0 SII~ (ZWOP 5-13) ,,-$II~
MII ............. eam Q Q Q III. I'2WOP 1:131 S ilfUM LlUIII
T .... OpoaIbofC_ ........ mJJ.m rm.m 11,1«\.152 .,....,,,. ~" ....
1.5 .,. drop off I: windrow mo.1OI ",",000 S7!O,OOO $7St.'10 (Sloo,l88/aae) $151A1O ""1A1O 1 am ...... <qanIa yant. tWf omc. $1m.188 $100,188 $lIXJ.tM ..-SI,3OO,ooo s ...... m S ...... m SU",,," $>.237,76& ~U4 _ .. OIIMt ($175,000) ($175,000) ("15,000) ($115 _ ($115,000) ($115,000)
TnI<MM 11'·,. s"pm "pm IU'"", CEW P""" ~ 111..,_ 21,0lI0''''''''''' ...... "'" ....-....-......... --............
MbaIa-. ...... 2 ..... ,. $ U'I/tDn , ..,,"'"
COIt/loD rr 41,.,.,.ar)
$ 101.7"" , ... -
,. tan COIIt if ...... of """'u,
ia ROO II UNci ~u.,860 ~ Sll.l9t'tDn IlL"""" .,,..17/100 $L1L_
What it would cotI: 10 run lite CODlipoit Opention .... taDd-aloae operation in 8yxbee Puk by Emily R .... I 3/10/",
,-.......... blUty UII!/DO QIoA vu.vo ..... , RnouI3/1IfIJ RnouI3/1IfIJ -. CMlt 116:09 -UI~ badltI) ~ beadle.)
LEA Annuli. Pemit Pee 0 0 0 0 , U,722 • U,722
s.&ariftl 6; BeN8t11 2lO,<XXl -.... $32&664 (CMlt 116:09) .... , ... "11,793 I""""'''''' In RCSD (Dolly _2/3/",. 38lI>l
~ r---dlIpoIal.ttendant ('VB $T1..301)
"".lJ1! S l2J07
2 ~ ~pmenI: oper.tort (,yS $91.909.75) $185.319
1 ec:hnIdan $111.966
"'of..,.,~ou.=,S. . .....-SoIJd W_ ,Mar Env."""""'-
En SpedaliIt -Sl.l58,3t.2 x .06 -S ",333
Cootrltt Ser..,k .. SI"""" SI18,oo:1 Si7a1XXl (CMR 116.1)9) $178,oro SI78.ooo ........... ( ..... boIowl IU __ SI01,163 • 29,119 SI7I,8911 I ...... bolow) -S2'0 ....
.......... """"' .... CIwpo 0 D S_ltl07,ooo.,",,1l9) S_ S_ Budpt-S15O,OOO Suo,OOO IgtndIng) ._ (CMR 387"') '180...., $1I10,000 ""'0. 0 0 D SlIf,06C (ZWOt' 5-13) .1-'lIf,06C
M!lrjenmqI OM Q Q Q III. rzrNOP 1:131 '116M LlUII
T .... Opoallq C_ -.--mJ.m "" .... "-'" ~
....
1.5 ~ drop off I: windrow "",,,000 " .. ...., .-$7!I.'10 (Sloo.l88/aat) S1!1,t1O ""1.<10 1 acn ..... cqanla y .... ttaff omc. $100.188 '100.'" $100.181 -S1,3OO...., swo.m Swo.." $l.99l,750 $>.237,76& ~U" ....... ""'" ('175,000) 1'175,000) It''''_ Itl"'_ ISI75,OOO) It""....,) XnlCaM I1'ZIt-I"!pm 'Jpm I1l1tm C-. A"""
Cooo'Io •• .., _:tI,OIIO ~ f/IJUI/Ioa ....---.stiIon --n_
MlaaIa-. se.m.. 2.oN"" S Ul/ton • ""/Ioa
COIt/lon rt 41, .....
.101.1 .... ,0<._
,. ton...,.. U ...... of "tlt:tttd/u.,
1a ROO lI.eel 1u.,a60......,...., ,,1.1_ IIL_ $I1&U/Om --.... U., ...
Appendix H-1
Further Analysis
A) Short Term (Operational) Recommendations
The Task Force visited the current Palo Alto windrow composting operation,
received a briefing on the operation and received follow-up data from Public
Works Operation Staff. The Aerobic Subcommittee (joined by Hilary Gans)
reviewed the information provided with the following objectives in mind:
¾ Minimize expenditures and use of resources.
¾ Minimize the need for stockpiling finished compost.
¾ Maximize the conversion of yard trimmings to compost.
¾ Minimize dust.
¾ Maximize compost quality.
Based on these objectives, the Aerobic Subcommittee developed the specific
recommendations contained in Section VII. Of the Task Force Report.
B) “2012” and “2015 -2021” Recommendations
The year 2012 is anticipated to be the year in which the current Palo Alto
Compost Facility will cease accepting of yard trimmings, as a result of the landfill
reaching full capacity. Therefore it was essential for the Task Force to develop
recommendations for that timeframe.
Initially two longer term recommendations were considered – one for 2015 and
one for 2021. These were ultimately merged into one set of recommendations as
it appeared that it may be possible to implement any of the alternatives studied by
2015. Experts advised the Task Force that approximately 4 years would be
needed for permitting, CEQA, design and construction of an advanced technology
facility. An additional 2 years may be needed for full consideration by all Palo
Alto Commissions, Committees and the Council itself and for consultant
selection, preliminary analysis and land acquisition. A total of 6 years may
therefore be needed, and 2015 became the soonest achievable timeframe.
In its final deliberations, the Task Force linked its 2012 and 2015-2021
recommendations by recommending a phased approach at a single site. For that
reason, the time frames will described together below.
C) Perspective Locations (“Where”)
Initially, all sites were screened out for 2012 except Z-Best and the current Palo
Alto (Landfill) site because the Task Force concluded that no other sites could be
developed in time. However, the desire to avoid dedicated Parkland (the current
site) and the desire to keep composting local, were both so strong, that the
Embarcadero Road/Airport site was added back to the options, and ultimately
selected. The recommendations (Section VII) recognize that the 2012 timeframe
may not be met, and it may be necessary to take yard trimmings to Z-Best in the
interim. The Task Force recommendations make it clear that composting at the
current Palo Alto site should not continue beyond the currently planned cessation
APPENDIX H
Appendix H-2
of yard trimming acceptance. This recommendation follows Council guidance
that parklands only be considered “after all other non-parkland options have been
pursued.” Thus the recommended site is the vacant rectangle in the Southeastern
corner of the Palo Alto Airport, augmented by adjacent Water Quality Control
Plant land and the current roadway, totaling approximately 5.5 acres (see Figure 5
and 6). The key features of the proposed site are:
¾ The site does not use parkland.
¾ The site is local thereby minimizing transportation-derived greenhouse
gas generation and toxic diesel fuel emissions.
¾ The site is adequately sized, and could further draw upon about one-
half acre of space within the water pollution control plant to arrive at a
6-acre facility for accomplishing most organic waste management.
¾ As a plan that derives from the Council’s immediate attention and City
staff’s action, there is greater assurance that the program of the Task
Force will be pursued rather than forgotten if its direction were merely
strategic toward 2020.
There are no existing locations for local municipal-scale composting in Palo Alto
unless a new site is developed. Any existing vacant land has multiple competing
interests for its use, and is not a short-term practical choice. The Task Force also
found that any facility in Palo Alto would optimally be located near the existing
Water Pollution Control Plant given the benefit of proximity to its staff and
physical infrastructure, generation of wastewater-derived organics (biosolids)
which can be processed by the new facility, and production of treated water that
can be used by composting and other organics management options with a
minimum generation of GHG's to fulfill any water needs that may be required by
present and future technologies.
The City’s potential take-over of the Palo Alto Airport by 2012 creates a
possibility in which a new site can be developed concurrent with the time when a
new site is needed. This would allow the City to control the use and development
of the land as long as it does not interfere with airport operations. The Task Force
realizes that safety considerations, potential conflicts with federal grants that may
require the land to remain vacant past 2012, and other airport considerations may
Figure 5 Figure 6
Appendix H-3
potentially require fine tuning of the proposed site boundaries. Vacant land
between Embarcadero and the Water Pollution Control Plant is used for landscape
screening, which the proposal addresses by providing an adequate and substantial
landscape buffer to the new Embarcadero road site and all the way around the
proposed site for greenery, and an existing bio-filter for odor control. There is an
East Palo Alto sewer line and a 56-inch outfall line that may need to be re-routed
if significant construction takes place.
While the site is City-owned, it is not dedicated as parkland. There are
expectations for screening that would need to be maintained or developed as part
of this plan. There are also transportation impacts which are similar to existing
transportation, but which are none-the-less impacts, which would interfere with
access to the parkland. However, given the subtle change in Embarcadero’s
routing, little change might be noticed by Palo Altans.
As background, another site option considered by the Task Force is located
immediately Southeast of the Water Pollution Control Plant. This site is not
recommended for several reasons. The site would be on parkland. The site’s
southern extent would have been constrained by the edge of the landfill’s lift.
The site would have interfered with anticipated screening between the Byxbee
Hills Park and the water pollution control plant, and also have been too narrow
and small to accommodate a practical operation. Its access would have also
conflicted with the park.
The option of leaving Embarcadero Road as-is could also be explored. In this
case, composting would occur in the same approximated location, but without
moving the road. This has inherent disadvantages caused by the need to
landscape screen two facilities, and of limiting the storage at pre and post-
processed organics. Also, it forces a need to transport biosolids across
Embarcadero Road.
D) “What?” (Type of Organics Processing)
For the 2012 timeframe, an aerated static pile approach has been selected by the
Task Force. A static pile approach uses blowers instead of a scarab windrow
turner to provide air for the process, and uses fabric covers to control aeration.
This approach is offered by several vendors and offers significant advantages
including compactness, and dust and odor control. Figure 7 shows an aerated
static pile compost by Gore that is representative of the technology. The existing
windrow approach now applied appears to require more space, and entails greater
heavy equipment usage during the compost process. The static pile could permit
the beginning of food scraps composting from Palo Alto residences – a collection
not offered by the City now. Given that the recommended site is near the airport,
measures will taken to avoid attracting birds.
Appendix H-4
Because aerated static pile technology offers improvements over windrow
composting, and yet is not a fundamentally different technology, it is believed to
be the one more advance technology which could be permitted in time. Staff
discussions with the Air District find that permitting new urban sites for windrow
composting will be very problematic due to dust and emissions issues. Air
emissions from aerated static piles are controlled, and therefore it is believed that
the Air District permit can be readily obtained. Task Force discussions with the
Integrated Waste Management Board find them quite amenable to assisting with
the appropriate permitting actions for the upgrade of operations at a contiguous,
City owned location. The Embarcadero Road/Airport site is a contiguous, City
owned site.
Technologies which convert organic materials to energy (“conversion
technologies”) cannot be permitted, designed, and constructed in the 2012
timeframe. The Task Force studied all of the types of conversion technologies
and conducted a ranking exercise for them for the 2015-2021 timeframe. A
ranking exercise was also conducted for sites for those technologies for the 2015-
2021 timeframe. The ranking criteria are shown in Figures 3 and 4. Task Force
members individually assigned weightings to the criteria, and then numerically
ranked the criteria. Criterion Decision Plus software was then used to compute
overall scores for both the “Where?” (location) and the “What?” (type of process)
questions. Figures 8 and 9 show the results of the overall Task Force ranking.
Anaerobic Processing ranked highest and was selected by the Task Force as the
recommended technology for the 2015-2021 timeframe. The key attributes of
anaerobic processing are:
¾ Low energy requirements
¾ Production and capture of methane for energy production
¾ Lower costs than high-temperature processes
¾ Contained in a building with emissions controlled
¾ Produces compost
¾ Amenable to yard trimmings, food scraps, and sewage biosolids
Figure 7
Appendix H-5
Aerated Static Pile (ECS)
Anaerobic Dry Fermentation (Bekon/Havest)
(BEKON Dry Fermentation Plant, Munich-Germany)
Appendix H-6
The Embarcadero Road/Airport site was ranked in the top tier of sites for the
2015-2021 timeframe (Figure 10). The scores among the top tier sites were
almost identical. The key attributes of the Embarcadero Road/Airport site are:
¾ Can be augmented from 4 acres to 5.5 acres by combining with Water
Quality Control Plant land and relocating Embarcadero Road.
¾ Adjacent to Water Quality Control Plant with synergies for organics
management
¾ Not on parkland
¾ Fills in land use between two industrial type facilities – the Airport and
the Water Quality Control Plant
¾ Appears large enough for aerated static piles initially, with a transition
to anaerobic processing in the 2015-2021 timeframe.
E) “When?” (Timeframes)
Accomplishing this project requires approvals by Palo Alto commissions, state
regulatory agencies, an environmental impact report, and the design and
construction of the project - all this within 26 months. Fortunately, the proposal
may benefit from alignment of constituencies previous at conflict over the fate of
Figure 10
Appendix H-7
local composting and parkland. The proposal maintains local composting without
the use of parkland, and not interfering with other anticipated public projects.
The schedule anticipates three broad scheduling elements: Palo Alto City
governance, agency approvals, and project design and construction, all schedule
elements constrained by key events. The key events that bracket the schedule
include the end of composting at the current Byxbee Park (Landfill site) and the
availability of the airport property through its transfer back to the City of Palo
Alto.
As a practical approach, the schedule anticipates the use of the Z-Best regional
compost facility if the local compost operation cannot be readied by the time
current compost operations must cease. City staff should maintain the ability to
utilize the regional facility, but understand the goal to keep composting local, if
possible and practical. Therefore a Z-Best regional option might be necessary for
as much as 12 months.
The following are additional schedule considerations:
¾ City of Palo Alto Approvals. Staff has indicated an Environmental
Impact Report (EIR) will likely be necessary for this project, a process
that could take 18 months. While not a prerequisite for all
development activities, it is on the critical path for the project. The
EIR will be considered by the Planning and Transportation
Commission as well as the City Council. Preceding the EIR, the City
would need to procure planning and design contractors to develop the
basis of a project and EIR.
¾ State Permits. The Task Force visited with representatives of the
California Integrated Waste Management Board (CIWMB). We found
that the state seemed very accommodating to develop permitting
approaches to facilitate a composting operation. This is evidence that
composting is an alternative supported by the state instead of
landfilling. The accommodation could include the ability to extend the
boundaries of the disposal site to include new facilities.
¾ Project Construction. The duration of the design and construction of
the aerated static pile system has been derived from two representative
vendors. The design and construction for shifting Embarcadero, and
any necessary rerouting of the sanitary sewer from East Palo Alto
would need to be developed, but within the broad constraints of the
schedule do not seem critical.
The schedule for this project will need to be vetted further. The ability to access
airport land is critical to the success of the project, and the interest and approach
to win use of this land should be pursued by staff. However the availability and
general timing of this land is anticipated by this alternative. The Task Force
should consider developing more details prior to completion of their study.
Appendix H-8
F) Greenhouse Gasses
Substantial greenhouse gas
(GHG) reductions can be
achieved first by diverting food
and other wet organic wastes
from landfill disposal, and then
by moving to advanced
anaerobic digestion technology
for our wastewater, food
scraps, and yard wastes. Non-
local transport of our organic
wastes contributes to GHG
emissions, but as can be seen
from the chart below, how we
process our organic wastes
matters much more than where
that processing occurs.
Food scraps and other moisture-rich compostable wastes quickly decompose in
landfills, releasing substantial methane gas long before methane recovery systems
are in place. Achieving the contract collection target of our new commercial,
institutional, and multi-family residence (C/I/M) food scraps program will reduce
methane emissions by at least 6,000 and as much as 15,000 metric tons (mT) of
CO2 equivalent, depending on emissions model assumptions. Surpassing our
collection target or implementing a single-family foodwaste collection program
would reduce GHG emissions even more.
The use of Advanced Anaerobic Digestion (AAD) facility to process our
wastewater sludge, C/I/M foodwaste, and collected yard wastes would reduce
CO2 emissions by an additional 14,000 mT of CO2 equivalent. A 50% increase
G) Economic Impacts
Due to the complex nature of the technologies, the proprietary nature of vendor
information, and the lack of sufficient time, the Task Force was not able to
complete a quantitative economic analysis of alternatives. The Aerobic
Subcommittee completed initial work on the current Palo Alto compost operation
and the Z-Best (Gilroy) alternative and this work is contained in Appendix G. A
preliminary cost analysis of an aerated static pile operation at the Embarcadero
Road/Airport site for 2012 was begun by Task Force members but engineering
estimates do not yet exist. The next step City staff would have to take for this
alternative is to prepare an engineering estimate, should Council so direct staff.
With respect to the 2015-2021 recommendations, engineering cost estimates of
the alternatives do not exist. Such estimates would have to be made as part of a
facilities planning process, which is one of the recommendations of the Task
Force.
ATTA{;HMENT .H
MOTION: Council Member Burt moved, seconded by Council Member
Barton that the Council direct Staff to create a Blue Ribbon Task Force
(BRTF) to evaluate and recommend alternatives to address Palo Alto's
composting needs:
1) The Task Force would A) convene for approximately 6 months,
B) members would be chosen in a manner similar to City
Commissioners, C) candidates would submit an application. A
three member City Council sub-committee appointed by the
Mayor would determine the size and membership of the Task
Force.
2) The City shall suspend accepting commercial garbage at the Palo
Alto dump while awaiting City Council action on the
recommendations of the BRTF.
3) The City Manager would determine the City Staff liaison and
appropriate City Staff support to the BRTF.
For each alternative solution or technology, the BRTF would evaluate
the following:
1) Short Term Improvements
a. How might the City reduce the impacts and improve the
operation of our existing windrow composting.
2) Environmental Impacts
a. The environmental impacts of the alternative technologies
including, but not limited to footprint, odor, dust and noise
impacts.
b. Ability to compost food waste and sewage sludge.
c. Production of renewable energy in the process and
greenhouse gas impacts.
3) Economic Impacts
a. Economic impacts associated with the alternative
technologies, including but not limited to operating costs,
capital costs, cost avoidance and income generation.
4) Permitting
a. What are the permitting processes and timeframes for the
various technologies?
5) Prospective Locations
a. What viable locations for long term composting exist in or
adjacent to Palo Alto?
6) Energy Generation
a. What amount of energy might be produced through certain
composting technologies?
b. Can funds from the Calaveras Reserve be used for an
energy-producing composting facility?
c. To what extent could they address needs for local energy
generation and emergency power?
Council Member Burt clarified four points with regard to the Motion:
1) The memo does not permit extension or new permit applications to
be authorized for Staff to proceed on. 2) It does not authorize the
movement of the compost operation from its present site to an interim
site. 3) There has been no decision to extend the life of the landfill. 4)
No intention to determine the outcomes of the Task Force are
predetermined.
AMENDMENT: Council Member Espinosa moved, seconded by Council
Member Kishimoto that parkland would be considered only as the last
resort.
Vice Mayor Morton asked colleagues to vote against the Amendment.
He stated the technologies are not yet identified as to their land use
needs. He stated while it does not limit decisions explicitly, it colored
the options available for the Blue Ribbon Task Force. .
Council Member Klein stated he was also voting no on the
Amendment. He stressed anyone serving on the Task Force likely held
parkland in high regard.
Council Member Burt suggested a change in wording from last resort
to a prioritization of lands other than parkland to be considered first.
He stated this made parklands a secondary option after all other land
options.
AMENDMENT RESTATED: Council Member Espinosa moved,
seconded by Council Member Kishimoto that when the priorities were
set for the composting facility locations that parklands will be
considered as a secondary priority after all other non-parkland options
have been pursued.
AMENDMENT PASSED: 5-4 Burt, Espinosa, Kishimoto Schmid, Yeh,
yes
MOTION PASSED WITH AMENDMENT: 8-1 Schmid no
....
U.S. Department
of Transportation
Federal Aviation
Administration
September 24, 2009
Mr. Carl Honaker~ Director of Airports
County of Santa Clara
Roads and Airports Department
2500 Cunningham Avenue
San Jose, California 95148
Dear Mr. Honaker:
ATTACHMENTC
San Francisco Airports District Office
831 Mitten Road, Room 210
Burlingame, California 94010-1303
Subject: Proposed Composting Site at Palo Alto Airport
Palo Alto, California
It has come to the attention of the San Francisco Airports District
Office (ADO) that the City of Palo Alto may be considering locating a
composting site at Palo Alto Airport. Following our review of the
draft Compose Taskforce Report, we are providing comments based on the
following factors:
1. Airport land for the proposed site is airside property that
represents prime aviation use land.
2. The Airport Layout Plan (ALP) shows that the proposed site has
a planned aviation use.
3. The proposed project will prevent airport land from being used
for aeronautical purposes, in effect displacing future
aviation uses.
4. There is no landside property that is excess to airport needs
and that can be converted to a non-aviation use, including the
proposed site. It cannot be said that the proposed site is
"not needed for airport purposes."
5. The proposed composting site may create a wildlife hazard
problem for aircraft landing and taking off at the airport.
Palo Alto Airport is a busy General Aviation (GA) airport with 247
based aircraft and almost 169,000 operations. The airport serves the
civil aviation needs of the Santa Clara County and the clear and
present needs of civil aviation should not be sacrificed for a
composting facility.
These factors dictate against the proposal to locate a composting
facility on airport property. Justification does not exist to allow
airport property to be converted to a non-aeronautical use. In view of
the circumstances, the Federal Aviation Administration (FAA) cannot
.>-.---_ .. _----
.... ..
-2-
support the proposal and objects to the proposed use of airport land
for the composting site. We expect the City to comply with its siyned
Airport Sponsor Grant Assurances obligations about restricting
incompatible land uses as discussed under Section C, Sponsor
Certification, Paragraph 21, Compatible Land Use.
Please contact our office at (650) 876-2778, X627, should you have any
questions.
Airports Compliance Specialist
Attachment D
PALO ALTO AIRPORT ASSOCIATION
COMMENTS TO PALO ALTO CITY COUNCIL
ON THE REPORT OF THE
BLUE RIBBON COMPOSTING TASK FORCE
October 14, 2009
Palo Alto Airport Association Comments on the Report of the Blue Ribbon
Composting Task Force
Introduction
The final report (Report) of the Blue Ribbon Composting Task Force (TF) identifies four
acres of the Palo Alto Airport (Airport) as the "preferred alternative" wherein to locate an
aerobic composting plant. The Palo Alto Airport Association (p AAA) became aware of
the proposal due to a Palo Alto Weekly article. As a matter of completeness, fairness, and,
if nothing else, the desire to achieve the best sustainable result, the TF should have
expressly notified the Palo Alto Airport community of its consideration of using airport
property as soon as it anticipated making the airport a subject of its work. While the
airport community was invited to meetings after the Weekly article appeared, it was too
late to impact the decision-making process.
There is an implicit assumption in the site recommendation that airport functioning is of
low priority and serves only a small number of residents and has minimal useful public
purpose. The only "con" listed in the Report's alternative matrix is that "the land is
desired by airport users". It is also stated that the land is only occasionally used by
helicopter operations and is otherwise unoccupied. This is erroneous. Furthennore, the
P AAA disputes any claim that airport land is unused and available, and is unequivocally
opposed to the taking any airport land for non-aviation purposes.
Use of the Subject Airport Land
It is ironic that for years any proposed airport development of the subject area has been
restricted because it has been deemed "intensification of use" which is prohibited by the
Baylands Master Plan. Indeed, this is why the land has remained vacant. When the
COWlty installed security lighting the City of Palo Alto required that extensive
landscaping along Embarcadero Road be undertaken to mitigate the impact of the low
intensity lighting and to shield arriving Byxbee Park visitors from viewing a part of the
airport. This landscaping was not supported by Federal grants and was entirely paid for
by Airport users through the Airport Enterprise Fund. Incredibly, the TF now proposes
an industrial scale composting operation with piles of material awaiting processing and
finished product awaiting removal with heavy trucks carrying the material to and from
the operation--all of this on the exact same area declared off limits to even minimal
airport development. As a final indignity, all the landscaping demanded by the City
would be destroyed. It is hard to imagine a worse place for the composting operation,
considering the impact on park visitors using existing trails and interpretive exhibits a
mere two hundred feet from the proposed composting operation.
The Report's assessment of the use of the subject area is erroneous. In fact, it is regularly
used for helicopter operations, both as an unobstructed area for the many arrivals and
departures of the medical transport helicopters and regular training activities and personal
transportation using smaller machines. The TF's stating that only occasional use by
helicopters in some way makes the area attractive and available for alternative uses is
P AAA Composting Comments
Page 2
comparable to asserting that a portion of a railway right of way can be taken for
alternative uses because trains do not use it continuously.
The Palo Alto Airport Working Group (P AA WG) appointed by then-mayor Judy
Kleinberg, strongly affirmed the value of the airport to the community, citing critical
emergency response functions during an earthquake or other incident, support for local
business transportation requirements and economic value as an employer and supporter
. of medical and public service transportation requirements. In response, the City Council
established a time line to take over management of the airport from Santa Clara County by
2012, and subsequently authorized engaging a consultant to prepare a financial and
operational plan for City operation. The TF report fails to mention the P AA WG Report. i
FEDERAL ISSUES
The FAA provides a national, largely seamless and pervasive regulatory scheme for
airport operations and modifications for airports supported by FAA grants. The Airport
is a recipient of FAA grants and thus within the FAA's exclusive jurisdiction. FAA
approval of taking airport property is mandatory. Moreover, the Airport is a designated
regional reliever airport and recognized as a vital component of United States airspace.
The FAA operates and maintains the air traffic control tower. FAA grants require that
such facilities must continue to operate for at least twenty years subsequent to the grant
date. Palo Alto has regularly received such grant funding, and will require future grants
to maintain the Airport and make improvements required to meet applicable safety and
operational standards. Federal and State grants comprise some 97% of the funding for
airport infrastructure, and are essential for the operation of any public airport.
In a September 24, 2009 letter from the San Francisco Airports District Office to the
County Director of Airports, the FAA states its objection as follows:
" ... Justification does not exist to allow airport property to be converted to a oon-
aeronautical use. In view of the circumstances, the Federal Aviation
Administration (FAA) cannot support the proposal and objects to the proposed
use of land for the composting site. We expect the City to comply with its signed
Airport Sponsor Grant Assurances obligations about restricting incompatible land
uses discussed under Section C, Sponsor Certification, Paragraph 21, Compatible
Land Use."
The entire FAA letter appears as Exhibit A.1i
Effect on Airport Operations
The change in the Airport boundary and the proximity of the composting operations
would effectively eliminate helicopter operations from the area currently in use. Rotor
downdraft wpuld create unacceptable levels of dust and particulate matter blown from the
piles of material awaiting disposition. Moreover, the TF report fails to evaluate the
problem of attracting birds to the airport. FAA Advisory Circular 150/5200-33B (Exhibit
B)iil provides guidance in airport planning to avoid the dangers of attracting birds to the
airport area. In Section 2( e) it states: "Composting operations should not be located on
PAAA Composting Comments
Page 3
airport property. Off-airport property compo sting operation should be located no closer
than the greater of the following distances: 1,200 feet from any AOA or the distance
called for by airport design requirements ... " Some TF members have suggested and
mapped an alternative airport layout, moving helicopter operations away from the
proposed area and reducing.the number of available tiedown locations. This layout is
totally speculative and has not been evaluated by any qualified airport design experts.
Such evaluation is required as a prerequisite to FAA approval. Furthennore, no revenue
source for planning and implementing these very expensive changes has been identified.
The Airport is required to be self-supporting, and changes,required to modify the airport
layout to accommodate non-aviation activities (on what is now airport land) cannot be
covered pursuant to the limitations of the airport enterprise fund revenues. To the extent
that the TF report is approved, who will pay for all of this? Consider also that a proposal
for making lease payments to the airport enterprise fund for the land constitutes
transferring funds from the general fund to an airport enterprise fund and is inconsistent
with a self-supporting airport.
Changes Required to Meet FAA Airport Design Standards
The County of Santa Clara's draft Palo Alto Airport Master Plan 0/2006 (plan)iY states,
''The existing non-standard helipad and helicopter parking area should be considered for
replacement with a new heliport designed to comply with FAA heliport design criteria
including a separate parking space for one helicopter ... Alternatives to a new helipad
include 1) requesting a waiver from the FAA to allow continued use of the existing
helipad ... and 2) discontinue using the helipad and conduct all helicopter operations on
the runway." And: "Because of its circular configuration and the fact that it is the most
heavily utilized taxiway on the airport, Taxiway G is recommended to be reconfigured to
confonn to FAA taxiway design criteria."
Figure 1, below, shows the document's layout map. Helicopter operations are a vital part
of the airport's function and air-ambulance helicopters visit the airport several times daily
to refuel, including at night (night operations require greater safety margins). The Plan
details a relocated and expanded lighted heliport meeting FAA specifications using space
the TF assumes is available for composting. Increasing certain taxiway widths to meet
FAA specifications will also demand more of the subject area. In general, FAA grants
for airport improvements require that airport designs adhere to FAA specifications. The
layout map shows hangars located on the four acres which have been detennined to be a
primary feature to ensure profitable future airport operations. While these have been
deemed inconsistent with the Baylands Master Plan in the past, they surely would be
infinitely less intrusive than the proposed industrial compo sting operation. Nevertheless,
their inclusion in the Plan is viewed as a proposal but not a requirement for financial
independence.
County Relationship
Because the County currently holds a lease for the Airport, expiring in 2017, any removal
of land subject to that lease would require County agreement. Furthennore, the County
Business Plan for the Airport prohibits the County from negotiating an extension and
returns the Airport to the City in 2017, or sooner if desired by the City. The City is in a
PAM Composting Comments
Page 4
planning process with a view to taking the Airport over in 2012, recognizing that the
County is committed to doing only minimal maintenance until the airport is taken over by
the City.
Summary
While we do not dispute the environmental value of efficiently composting the materials
in question, there is no justifiable and compelling reason for taking airport land for the
proposed composting operation, an incompatible use of land within confines of the
Airport. The P AAA is not in a position to recommend alternatives, but notes that even if
some dedicated but undeveloped parkland in the vicinity of the water treatment plant
were to be used, the overall impact on developed parkland in the vicinity would be
substantially less than the TF's current recommendation to take Airport property. The
site recommended by the TF would hamper and make dysfunctional existing Airport
operations and seriously affect helicopter operations, thereby threatening public health
and safety. Adopting this site plan is not in the City's best interest and should be
rejected.
Respectfully submitted,
Ralph Britton
President
Palo Alto Airport Association
i The May 2007 Report of the Palo Alto Airport Working Group (PAA WG) can be found on the City's
website see: http://www.cityofpaloalto.org!cityagendalpublishlaU:port-workgroup/documentslPAA WG-
DraftReporlpdf
ii The FAA letter incorrectly identifies only 247 aircraft based at the airport. Counting aircraft in privately
leased hangars and tiedown space, the number is approximately 500.
ill The FAA Advisory Circular No. 150/520o-33B can be found on the FAA website; see
http://www.faa.gov/airportslresources/advison: circulws/media/150-5200-33B/150 5200 33b.pdf
Iv The December 2006 Palo Alto Airport Master Plan Report can be found on the County Airports'
Website, see: http://countyahports.orgldocs/MasterPlanlPAD Masterplan-complete.pdf
P AAA Composting Comments
Page 5
OHIU"TIIJ" 9U1LDNO AFIE'A
Figure .... '
Building Area Development Options
Palo AtID AIrPOI1
4-10
Figure 1, Proposed Changes, including new helipad and its safety zone.
PAM Composting Comments
Page 6
U.S. Department
of Transportation
Federal Aviation
Administration
Subject: HAZARDOUS WILDLIFE
A rrRACTANTS ON OR NEAR
AIRPORTS
Advisory
Circular
Date: 8/28/2007 AC No: 15015200-338
Initiated by: AAS-300 Change:
1. PURPOSE. This Advisory Circular (AC) provides guidance on certain land uses
that have the potential to attract hazardous wildlife on or near public-use airports. It
also discusses' airport development projects (including airport construction, expansion,
and renovation) affecting aircraft. movement near hazardous wildlife attractants.
Appendix 1 provides definitions of terms used in this AC.
2. APPLICABILITY. The Federal Aviation Administration (FAA) recommends that
public-use airport operators implement the standards and practices contained in this
AC. The holders of Airport Operating Certificates issued under Title 14, Code of
Federal Regulations (CFR), Part 139, Certification of Airports, Subpart D (Part 139),
may use the standards, practices, and recommendations contained in this AC to comply
with the wildlife hazard management requirements of Part 139. Airports that have
received Federal grant-in-aid assistance must use these standards. The FAA also
recommends the guidance in this AC for land-use planners, operators of non-
certificated airports, and developers of projects, facilities, and activities on or near
airports.
3. CANCELLATION. This AC cancels AC 150/5200-33A, Hazardous Wildlife
Attractants on or near Airports, dated July 27,2004.
4. PRINCIPAL CHANGES. This AC contains the following major changes, which
are marked with vertical bars in the margin:
a. Technical changes to paragraph references.
b. Wording on storm water detention ponds.
c. Deleted paragraph 4-3.b, Additional Coordination.
S. BACKGROUND. Information about the risks posed to aircraft. by certain wildlife
species has increased a great deal in recent years. Improved reporting, studies,
documentation, and statistics clearly show that aircraft. collisions with birds and other
wildlife are a serious economic and public safety problem. While many speCies of
wildlife can pose a threat to aircraft safety, they are not equally hazardous. Table 1
8/28/2007 AC 150/5200-338
ranks the wildlife groups commonly involved in damaging strikes in the United States
according to their relative hazard to aircraft. The ranking is based on the 47,212
records in the FAA National Wildlife Strike Database for the years 1990 through 2003.
These hazard rankings, in conjunction with site-specific Wildlife Hazards Assessments
(WHA), will help airport operators determine the relative abundance and use patterns of
wildlife species and help focus hazardous wildlife management efforts on those species
most likely to cause problems at an airport.
Most public-use airports have large tracts of open, undeveloped land that provide added
margins of safety and noise mitigation. These areas can also present potential hazards
to aviation if they encourage wildlife to enter an airport's approach or departure airspace
or air operations area (AOA). Constructed or natural areas-such as poorly drained
locations, detention/retention ponds, roosting habitats on buildings, landscaping, odor-
causing rotting organic matter (putrescible waste) disposal operations, wastewater
treatment plants, agricultural or aquaculture activities, surface mining, or wetlands-can
provide wildlife with ideal locations for feeding, loafing, reproduction, and escape. Even
smalrfacilities, such as fast food restaurants, taxicab staging areas, rental car facilities,
aircraft viewing areas, and public parks, can produce sUbstantial attraction'S for
hazardous wildlife.
During the past century, wildlife-aircraft strikes have resulted in the loss of hundreds of
lives worldwide, as well as billions of dollars in aircraft damage. Hazardous wildlife
attractants on' and near airports can jeopardize future airport expansion, making proper
community land-use planning essential. This AC provides airport operators and those
parties with whom they cooperate with the guidance they need to assess and address
potentially hazardous wildlife attractants when locating new facilities and implementing
certain land-use practices on or near public-use airports.
6. MEMORANDUM OF AGRI:EMENT BETWEEN FEDERAL RESOURCE
AGENCIES. The FAA, the U.S. Air Force, the U.S. Army Corps of Engineers, the U.S.
Environmental Protection Agency, the U.S. Fish and Wildlife Service, and the U.S.
Department of Agriculture -Wildlife Services signed a Memorandum of Agreement
(MOA) in July 2003 to acknowledge their respective missions in protecting aviation from
wildlife hazards. Through the MOA, the agencies established procedures necessary to
coordinate their missions to address more effectively existing and future environmental
conditions contributing to collisions between wildlife and aircraft (wildlife strikes)
throughout the United States. These efforts are intended to minimize wildlife risks to
aviation and human safety while protecting the Nation's valuable environmental
resources.
DAVID L. BENNETT
Director, Office of Airport Safety
and Standards '
ii
EXHIBIT A
FAA LETTER TO COUNTY AIRPORTS DIRECTOR
RE: PROPOSED TAKING OF PALO ALTO AIRPORT LAND
FOR COMPOSTING OPERATIONS
PAAA Composting Comments
Page 7
·" ....
o
U.S. Department
of Transportation
Federal Aviation
Administration
September 24, 2009
Mr. Carl Honaker, Director of Airports
County of Santa Clara
Roads and Airports Department
2500 Cunningham Avenue
San Jose, California 95148
Dear Mr. Honaker:
San FrancI8co Airports District OffIce
831 Mitten Road, Room 210
Burlingame, California 94010-1303
Subject: proposed Composting Site at Palo Alto Airport
Palo Alto, California
It has come to the attention of the San Francisco Airports District
Office (ADO) that the City of Palo Alto may be considering locating a
composting site at Palo Alto Airport. Following our review of the
draft Compose Taskforce Report, we are providing comments based on the
following factors:
1. Airport land for the proposed site is airside property that
represents prime aviation use land.
2. The Airport Layout Plan (ALP) shows that the proposed site has
a planned aviation use.
3. The proposed project will prevent airport land from being used
for aeronautical purposes, in effect displacing future
aviation uses.
4. There is no landside property that is excess to airport needs
and that can be converted to a non-aviation use, including the
proposed site. It cannot be said that the proposed site is
"not needed for airport purposes."
5. The proposed composting site may create a wildlife hazard
problem for aircraft landing and taking off at the airport.
Palo Alto Airport is a busy General Aviation (GA) airport with 247
based aircraft and almost 189,000 operations. The airport serves the
civil aviation needs of the Santa Clara County and the clear and
present needs of civil aviation should not be sacrificed for a
composting facility.
These factors dictate against the proposal to locate a composting
facility on airport property. Justification does not exist to allow
airport property to be converted to a non-aeronautical use. In view of
the circumstances, the Federal Aviation Administration (FAA) cannot
... -.-._------
-•
-2-
support the proposal and objects to the proposed use of airport land
for the compostinq site. We expoct the City to comply with itssl~fleu
Airport Sponsor Grant Assurances obligations about restricting
incompatible land uses as discussed under Section C, Sponsor
Certi£ication, Paragraph 21, Compatible Land Use.
Please contact our office at (650) 876-2778, X627, should you have any
questions.
Specialist
October 13, 2009
Palo Alto City Council
cc: Jim Keene, Phil Bobel
To the Palo Alto City Council,
Attachment E
David Creemer
Palo Alto, CA 94306
T +1650 814-0224
dayid@zachalY·copl
I am writing on behalf of the Joint Community Relations Committee (JCRC) ofthe Palo Alto Airport. As
you may know, we are a City Council directed committee, tasked with working to ensure the Airport's
value, service and impact in regards to the Palo Alto community (among other things). We are concerned
that we were not invited as a formal city.appointed committee to participate in the composting blue-
ribbon task foree, which I now understand may propose significant changes to the airport. Given our
broad and long connections to the many stake-holders with regards to the airport and the surrounding
Baylands area, I am surprised and dismayed at our non-inclusion, and am open to suggestions as to how to
more fonnalJy include our participation in the composting project.
Sincerely yours,
\
David Creemer,
Chair
J eRC for the Palo Alto Airport