HomeMy WebLinkAboutStaff Report 6424
City of Palo Alto (ID # 6424)
City Council Staff Report
Report Type: Action Items Meeting Date: 3/21/2016
City of Palo Alto Page 1
Summary Title: Council Site and Design Review of RWQCP Sludge Facility
Title: PUBLIC HEARING: Adoption of a Mitigated Negative Declaration and
Approval of a Site and Design Review Application for a new Two-Story, 7,500
Square Foot, 50-Foot tall Building Designed to Handle Sludge De-watering
and Truck Load-outs, With Adjacent Stand-by Generator, and a new Outdoor
Equipment Area Next to the Existing Incinerator, to be Placed Centrally on
the Regional Water Quality Control Plant Site at 2501 Embarcadero Way
From: City Manager
Lead Department: Planning and Community Environment
Recommendation
Staff recommends that Council approve the Mitigated Negative Declaration (Attachment G),
Mitigation and Monitoring Program (Attachment K) and the Record of Land Use (Attachment A)
approving the Site and Design Review and Architectural Review application for the new
dewatering facility at the Regional Water Quality Control Plant.
Executive Summary
The new two-story bio-solids dewatering facility, a 7,500 square foot (sf) building to be placed
centrally and in an open area on the Regional Water Quality Control Plant (RWQCP) site, is part
of a long term RWQCP plan to carry out the Biosolids Facility Plan (BFP) and the Organics
Facilities Plan (ORP). A recent overall update on the ORP and the related Measure E can be
found in Staff Report #6503 (Attachment E). The new facility will allow the RWQCP’s
incinerators to be retired. The existing incinerator building will be repurposed for a time, and
then demolished, as part of a future project.
The Initial Study/Draft Mitigated Negative Declaration (MND) for the project was revised
following two public hearings and submittal of public comments. The addendum provides
additional explanatory statements in response to those comments. The plans and documents
for this project, including the Draft Mitigated Negative Declaration, are viewable on the City’s
website at https://www.cityofpaloalto.org/civicax/filebank/documents/51102
(Architectural Review Board webpages) and at
http://www.cityofpaloalto.org/news/displaynews.asp?NewsID=3412 (Project webpage).
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The Site and Design Review application and MND were recommended by the Planning and
Transportation Commission (PTC) and Architectural Review Board (ARB). The project meets the
Site and Design Review objectives set forth in Palo Alto Municipal Code (PAMC) Chapter
18.30(G).060, and Architectural Review (AR) findings as set forth in the Record of Land Use
Action (Attachment A). The AR findings from PAMC Chapter 18.76, Section 18.76.020 were
utilized for this review. Council has not yet adopted the revised AR findings recommended by
the ARB and PTC, but is scheduled to review and adopt (or modify) these findings April 11,
2016.
The dewatering project is at the 90% design level of development. The project plans are
provided to Council as Attachment M and are viewable online via
http://www.cityofpaloalto.org/civicax/filebank/documents/50224
The “100%” design documents will be issued to prospective construction contractors as part of
the bid process. Staff is pursuing a low-interest loan from the State of California to cover
project costs. Staff will return to Council for approval of resolutions needed for the loan,
modifications to partner agreements to repay a proportionate share of the loan, the
construction contract, and a construction management contract.
Background
RWQCP Site and Project Overview
The dewatering facility is proposed on the 25-acre RWQCP site, zoned ‘Public Facilities’ (PF),
designated ‘Major Institutions/Special Facilities’ on the City’s Comprehensive Plan land use
map, and owned and operated by the City of Palo Alto. The non-City owned properties along
Embarcadero Way, designated in the Comprehensive Plan as Research/Office Park, are all
developed and zoned ROLM(E)-D-AD, which stands for ‘Research, Office, and Limited
Manufacturing’ District Sub-Distrist ‘Embarcadero’ with ‘Automobile Dealership’ Combining
District. The adjacent Baylands Nature Preserve, a major migratory bird stopover on the Pacific
Flyway, supports trails used by cyclists, runners, hikers and bird watchers. The plant treats
wastewater from the East Palo Alto Sanitary District, Los Altos, Los Altos Hills, Mountain View,
Palo Alto and Stanford University. The site is subject to policies of the 2008 Palo Alto Baylands
Master Plan, viewable at http://www.cityofpaloalto.org/civicax/filebank/documents/14882.
The proposed sludge dewatering building would be located southeast of the Incinerator
Building, and vehicle access would be provided from Embarcadero Way. All dewatering
operations will occur within the new building, where continuous machinery operations will be
isolated from the environment. No staff will permanently occupy the building; staff will
perform routing operation and maintenance of the facility. The building will house belt filter
presses, an interior truck loadout and other support areas, and will have a robust system for
odor control. The project includes a stand-by deisel engine generator and fuel storage in a sub-
base fuel tank. Simple site improvements are proposed to the landscaping, irrigation, paving
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and drainage systems. Though the project site is within 500 feet of the Baylands preserve, it
does not contain any native marshland or aquatic habitats, but it does contain significant
mature vegetation. The project is also located within the Airport Influence Area (AIA).
The project description (Attachment B), statement of landscape design intent (Attachment C),
Initial Study/Mitigated Negative Declaration (Attachment G) and addendum providing
responses to comments thereto (Attachment H) provide greater detail about existing conditions
on the site and the proposed project. A set of images to illustrate views of the project from
high point of the adjacent Byxbee Park are contained within Attachment D, a set of responses
to questions received from a commissioner and from a member of the public prior to the PTC
hearing. All three letters from Mr. Herb Borock are included within Attachment H, along with
responses thereto.
PTC and ARB Reviews
Both the PTC and ARB reviewed this project. The ARB performs architectural review following
PTC review and recommendation on the Site and Design Review application. The Site and
Design Review process is intended to ensure that development in environmentally and
ecologically sensitive areas will be harmonious with other uses in the general vicinity,
compatible with environmental and ecological objectives, and in accord with the Palo Alto
Comprehensive Plan.
The staff reports for the December 17, 2015 ARB study session, January 27, 2016 PTC hearing
and February 18, 2016 ARB hearing provided context and background information, including
summaries of previous public hearings. The ARB study session report is viewable at
https://www.cityofpaloalto.org/civicax/filebank/documents/50283. The PTC meeting minutes
are attached (Attachment F) and the January 27, 2016 PTC staff report is viewable at
http://www.cityofpaloalto.org/gov/boards/ptc/default.asp. The ARB meeting verbatim minutes
are attached (Attachment I) and the February 18, 2016 ARB staff report is viewable at
https://www.cityofpaloalto.org/civicax/filebank/documents/51102.
Planning and Transportation Commission Hearing
The PTC conducted a public hearing of the project and the associated MND, and recommended
approval on a 6-1 vote. The dissenting commissioner didn’t want to vote for the project until
the required clearance was received from the Federal Aviation Administration (FAA). The FAA
clearance (Attachment J) was since received, on February 18, 2016. Condition of approval 3(e)
in Attachment A requires placement of lights to address FAA requirements. There were two
public speakers; one speaker expressed interest in the study with respect to the airport plan.
The other speaker provided written comments on the MND regarding the topics of odor and
green house gases and his written comments, submitted on January 27, 2016, were addressed
in Attachment D. Public Works staff spoke to speakers’ concerns, which included the project’s
relationship to the Palo Alto Airport; discussion about the City’s obligation with respect to
review of this project for consistency with airport policies was provided within the ARB report,
as follow up. This topic is discussed briefly later in this staff report.
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Architectural Review Board Hearing
The ARB conducted a public hearing of the project and associated MND, and recommended
approval on a 4-1 vote, subject to removal of the green screens the applicant had proposed on
two sides of the building in an attempt to address items cited by the ARB during an earlier study
session. There was one speaker (Mr. Borock), who noted concerns regarding greenhouse gas
explanatory text, vegetation at the southerly edge of the site, and space for storage. Public
Works staff responded and further explanation is provided in the annotated, revised MND. The
ARB noted appreciation of the photosimulations and existing, recently installed landscaping.
Prior to the motion made to remove the green screens from the project, the dissenting ARB
member noted that his only objection to the project was the green screen design, which he felt
needed further work; though he did not state the reason why he then voted against the project,
the removal of green screens from the project may have resulted in his vote against the project.
Discussion
Site and Project Visibility
The RWQCP site can be viewed from surrounding properties west of the site (the business
park), south of the site (the capped landfill that is undergoing a transition to parkland), north of
the site (the Palo Alto Airport) and east and south of the site (Baylands Nature Preserve,
approximately 500 feet to the east and 800 feet to the south). The tall, dense thicket of privet
trees along the site’s eastern boundary creates a natural barrier between the site, the adjacent
roadways (Embarcadero Road and Harbor Road), and the preserve lands to the east. The site’s
southern edge is lined with trees. The plan set includes photo-simulations of the proposed
building viewed from the expanding Byxbee Park and Baylands Preserve. The aerial below
indicates the proposed location of the sludge dewatering and loadout facility just southeast of
the incinerator building. The new building and truck access route will be placed on land that is
currently open with no permanent structures. Other on-site functions and off-site views of the
site are indicated on the aerials and in photos in the attached application materials, and found
on the City’s website at the link provided earlier in this report.
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View from Embarcadero Road
The RWQCP site has frontage along Embarcadero Road, Embarcadero Way, and Harbor Road.
The closest building to Embarcadero Road, identified as a scenic route in the Palo Alto
Comprehensive Plan, is a one-story, Cor-Ten steel maintenance building seen as a rectangular
building in the above aerial and in the photo below. The nearby circular, low profile, recycled
water storage tank near Embarcadero Road is barely visible from Embarcadero.
The tallest building on the plant site, the 45’9” tall Incinerator Building, is barely visible from
Embarcadero Road due to existing mature and new vegetation along the site’s perimeter. The
vegetation also screens the five-foot-tall rooftop equipment atop the incinerator building from
Embarcadero Road, and other minor buildings and appurtenance on the site. The parapet of
the new building would be 4’3” taller than the incinerator building.
New Building and Support Facilities
The new 7,500 sf building and support facilities would be located in the middle of the RWQCP
site, where there are no existing buildings. The building will be a cast-in-place concrete
structure, with painted structural steel, profiled Cor-Ten steel panels and removable skylights.
The parapet would reach a height of 50 feet above grade. Above that, Cor-Ten steel guardrails
would extend two feet and one ventilation stack would extend 15 feet. The floor of the buidling
would be placed one foot above the 100-year base flood elevation of 10.5’. This will become
the tallest building on the site. The design is intended to complement the existing architectural
style at the treatment plant. The concrete walls will include horizontal reveals and exposed
form ties. The proposed natural, weathered concrete will have exposed form imprints.
Landscaping
The landscape design intent is to blend the new building into the existing landscaped site. Plant
material will be drought tolerant, native and non-native species selected to tolerate the
facility’s recycled water. Plantings are intended to interrupt views of the new building from off-
site locations. The intent statement (Attachment C) includes design objectives and plant
materials to be used. The areas proposed for new planting treatments include the ‘sharps’
pharmaceutical drop-off area, truck bay loading drive, building perimeter, public tour gathering
area, and Embarcadero Way exit driveway. Landscape plans show proposed screen landscaping
to limit views of the building from the Baylands Nature Preserve. Below is a photo simulation
that indicates screen landscaping at 10 years near Harbor Road.
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New plantings associated with this project will be seen from Harbor Road (18 36”-box sized
trees) as shown in the photo-simulation above, and from Embarcadero Way (three 24”-box and
six 15-gallon sized trees) as shown on the landscape plan above. Trees and vines are proposed
along the driveway from Embarcadero Way to the new building. The new trees on the west
side of the building include three Strawberry trees, three Incense Cedars, three Australian
Willows. New trees between the building and existing north soil bed filter include Strawberry
trees, Bottle trees, Incense Cedars, Willow-leafed Peppermint Eucalyptus trees, Australian
Willows and Canary Island Pines.
Vegetation, public art and signage installed near the Embarcadero Way driveway entrance to
the site in 2014 per the approved landscape plan are shown below.
On the following page is an image of plantings installed in 2014 along the perimeter of the site;
these plantings extended along a portion of Embarcadero Road, Harbor Road toward the
southern portion of the plant, and near Embarcadero Way. The 2014 project also included
interior landscaping intended to improve the aesthetics within the plant , create meeting areas
and safer way finding for the public tours, showcase recycled water use, demonstrate
sustainable landscape design. No additional vegetation is proposed along the southerly edge of
the plant, due prior Council action related to Measure E. The vegetation “gap” a member of
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the public cited, located on the south side of the plant, will not be filled in at this time; the 10-
acre former landfill site is held as a potential composting facility until 2021 per Measure E.
Compliance with Zoning Development Standards
The PF Public Facilities zone district is designed to accommodate governmental, public utility,
educational, and community service or recreational facilities. Public Facilities Development
Standards contained in PAMC Chapter 18.28 limit buildings to a maximum height of 50 feet, lot
coverage to 30% of the site’s area, and Floor Area Ratio (FAR) to 1:1. The project meets these
maximums, and the building placement is such that setbacks from property lines are much
greater than the minimum standards. The building parapet height of 50 feet meets the height
standard. The ventilation stack is shown as reaching a height of 65 feet or 15 feet above the
height limit in the PF zone district. PAMC Chapter 18.40 Section 18.40.090 ‘Height Exceptions’
allows exhaust fans to exceed the height limit of any zone district by 15 feet. There is no special
process or findings for this exception beyond the Site and Design Review process and
Architectural Review findings.
Comprehensive Plan Compliance
The following policies are relevant to the proposed project and are included in the RLUA:
POLICY L-5: Maintain the scale and character of the City. Avoid land uses that are
overwhelming and unacceptable due to their size and scale.
POLICY L-48: Promote high quality, creative design and site planning that is compatible
with surrounding development and public spaces.
POLICY N-29: All potential sources of odor and/or toxic air contaminants should be
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adequately buffered, or mechanically or otherwise mitigated to avoid odor and toxic
impacts that violate relevant human health standards.
POLICY N-37: Ensure the environmentally sound disposal of solid waste.
As noted, the proposed building is of a similar scale and materials to the tallest and most visible
structures on the project site, and the proposed central placement on the site and new
vegetation (at maturity) will help mitigate views of the new building from off site. The building
is designed with a “robust” odor control system to meet regional air quality standards. The
facility’s purpose is to “de-water” and “load out” waste.
2008 Baylands Master Plan and 2005 Design Guidelines
The 1998 Comprehensive Plan refers to the 1987 Baylands Master Plan (Plan), which was
updated in 2008. The Plan addresses the RWQCP on pages 181-194 and provides policies that
can be applied to the site (in “Overall” on page 65, “Flood Control” on page 257, and “Access &
Circulation” on page 242). The 2005 Site Assessment and Design Guidelines, Palo Alto Baylands
Nature Preserve document was prepared to help implement the Baylands Master Plan and the
Baylands-related Comprehensive Plan policies and programs. The link to these guidelines is as
follows: http://www.cityofpaloalto.org/civicax/filebank/documents/13318. The guidelines
document is intended to be used when designing or reviewing projects located in any part of
the Baylands. The Baylands Master Plan notes, “While the more specific guidelines are primarily
applicable to the dedicated parkland, the design principles and concepts should also be applied
in the service and commercial areas when designing or reviewing projects for compatibility with
the special aesthetic qualities and environmental conditions unique to the Baylands.” Staff and
the ARB looked at the project design with respect to the principles contained in the guidelines,
as outlined in the ARB staff report.
Comprehensive Plan Consistency with Respect to Palo Alto Airport
City staff determined the project is consistent with the Comprehensive Plan for the Palo Alto
Airport, because the project does not extend into the FAA Part 77 ‘imaginary surfaces.’ In late
January 2016, City staff submitted the required documentation to the FAA. On February 18,
2016, the FAA determined the new structure would not be a hazard to air navigation provided
the structure is marked and lighted in accordance with FAA Advisory circular 70/7460-1L. The
Part 77 map was presented to the PTC and is also included as an attachment to this report.
There are criteria for referring proposals (within the Airport Influence Area (AIA)) to the Airport
Land Use Commission (ALUC) for review. The sludge facility project does not meet the criteria
for either mandatory or voluntary referral to the ALUC; these criteria were provided in the ARB
report.
Palo Alto’s Transportation Element contains one goal with respect to the airport, and one policy
(Policy T-57). Goal T-10 states ‘A local airport with minimal off site impacts’ with the following
statement related to the goal:
“The Palo Alto Airport is a “business and recreational facility for northern Santa Clara
County, handling 250,000 landings and take-offs a year. Due to the short length of the
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runway and Federal Aviation Administration-imposed noise restrictions, use of the
Airport is limited to single-engine and light twin-engine aircraft.”
Transportation Element Policy T-57, states “Support the continued vitality and effectiveness of
the Palo Alto Airport without significantly increasing its intensity or intruding into open space
areas. The Airport should remain limited to a single runway and two fixed base operators. Palo
Alto will allow for improvement and only minor expansion of existing Airport facilities. In the
sensitive Baylands area, and immediately adjacent to homes in East Palo Alto, traffic and
aircraft noise should be minimized.”
A PTC member had noted a concern with the vent pipe with respect to airspace needs. If
significant changes occur at the airport requiring a new analysis of airspace needs, then the
vent pipe could be moved to accommodate any changes.
Timeline
The timeframe for construction of the new dewatering facility is estimated to be 24 months.
Policy Implications
Council has responsibilities as to expenditure of capital funds and service to the member
agencies using these facilities, in addition to taking action on the Site and Design Review
application and MND. The PTC was tasked with ensuring the Site and Design Review findings
were met, discussion of broad policy issues, review of the MND, and project compliance with
the Comprehensive Plan. The ARB was tasked with ensuring the Architectural Review findings,
Comprehensive Plan policies and programs, and Environmental Review issues related to
Aesthetics have been met or addressed, prior to forwarding its recommendation to Council.
Resource Impact
The construction cost of the project is estimated to be approximately $25 Million. The City is
applying for a loan from the State’s Revolving Fund for water quality improvement projects and
anticipates being successful. These low interest loans are currently running below 2% for a 30
year loan. Repayent begins upon completion of construction, approxinately two years from
now. The six Plant partners will pay their portion of the loan repayment costs. Palo Alto’s share
will be approximately 35 % of the total. More exact figures will be provided when the project
returns to Council for approval of the construction contract and related documents
Environmental Review
The attached Initial Study/Draft Mitigated Negative Declaration (MND, Attachment G) was
prepared by the City’s consultant, ch2m. The MND Notice of Intent (Attachment L) was
published and the Initial Study MND was made available for public review in City Hall and the
Development Center and on the City’s website for an initial 30-day period, and circulated to
state agencies by the State Clearinghouse. The only topic identified as having a potential
impact unless mitigated and requiring a mitigation measure was biological resources; namely,
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bird nesting (for which the mitigation measure is to address bird nesting concerns in
compliance with the Migratory Bird Treaty Act (MBTA)). Report Attachment K provides the
Mitigation Monitoring and Reporting Program related to this mitigation measure.
The PTC and ARB reviewed the MND together with the public comments and recommended
Council approval of both the MND and Site and Design Review application. The addendum to
the MND (Attachment H) was prepared to address public comments submitted prior to and
after the PTC review; no new impacts or mitigation measures have been identified. The MND
concludes, “Because the project would be located on an existing RWQCP, would be similar in
scale to existing features, and would meet the City’s approval findings, the visual character and
quality of views from the Palo Alto Baylands would not be substantially degraded. Impacts
would be less than significant.”
Attachments:
Attachment A: RLUA (DOC)
Attachment B: Project Description (PDF)
Attachment C: Statement of Landscape Design Intent (PDF)
Attachment D: QA Waldfogel and Borock (PDF)
Attachment E: Energy Compost Facility CMR #6503 (PDF)
Attachment F: Draft PTC minutes of January 27, 2016 (DOC)
Attachment G: ISMND December2015 (PDF)
Attachment H: IS comments and responses (addendum) (PDF)
Attachment I: ARB 2 18 16 Verbatim Minutes (DOCX)
Attachment J: FAA Determination 2016 (PDF)
Attachment K: Mitigation Monitoring and Reporting Program (PDF)
Attachment L: NOI to adopt MND to S. C. County - filed 12-14-15 (PDF)
Attachment M: Project Plans (Council only) (PDF)
ATTACHMENT A
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ACTION NO. 2016-
RECORD OF THE COUNCIL OF THE CITY OF PALO ALTO OF LAND USE ACTION FOR 2501
EMBARCADERO WAY: SITE AND DESIGN REVIEW AND MITIGATED NEGATIVE DECLARATION
(CITY OF PALO ALTO, APPLICANT)
On March 21, 2016, the Council approved the Mitigated Negative Declaration and the
Site and Design Review application for the sludge dewatering and load out facility at the Regional
Water Quality Control Plan in the PF(D) Public Facility with Site and Design Overlay Zone District,
making the following findings, determination and declarations:
SECTION 1. Background. The City Council of the City of Palo Alto (“City Council”)
finds, determines, and declares as follows:
A. On September 9, 2015, Palo Alto Public Works staff applied for Site and Design
Review of the sludge dewatering and loadout facility at the Regional Water Quality Control Plant
(RWQCP) in the PF(D) Public Facility with Site and Design Overlay zone district (“the Project”).
B. Following staff review, ARB study session review and preparation and
circulation of the draft Mitigated Negative Declaration (MND), the Planning and Transportation
Commission (“Commission”) reviewed the Project on January 27, 2016 and voted 6-1 to
recommend that Council approve the project and MND. The Commission’s actions are contained in
the CMR ID #6424.
C. Following Commission review, the Architectural Review Board (ARB) reviewed
the Project on February 18, 2016 and voted (4-1) to recommend approval, subject to removal of
green screens. The ARB’s actions are contained in the CMR ID #6424.
SECTION 2. Environmental Review. The City as the lead agency for the Project has
determined that the project is subject to environmental review under provisions of the California
Environmental Quality Act (CEQA) under Guideline section 15070, Decision to Prepare a Negative
or Mitigated Negative Declaration. An environmental impact assessment was prepared for the
project and it has been determined that, with the implementation of mitigations, no potentially
adverse impacts would result from the development and, therefore, the Project would have a less
than significant impact on the environment. The Mitigated Negative Declaration was made
available for public review beginning December 15, 2016 through January 13, 2016. The Initial
Study and Draft Mitigated Negative Declaration, and addendum thereto, are contained in CMR ID
#6424.
SECTION 3. Site and Design Review Findings
1. The use will be constructed and operated in a manner that will be orderly,
harmonious, and compatible with existing or potential uses of adjoining or nearby sites.
ATTACHMENT A
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The privately owned properties abutting and across the street from the Regional Water
Quality Control Plant (Plant) include sites fronting Embarcadero Way zoned ROLM(E)(D)(AD) and a
site at 2425 Embarcadero Way zoned “PC” (Planned Community PC 3020, a self storage facility
approved in 1977 with a rooftop wireless communication facility approved in 2002.) The publicly
owned properties abutting the site include the Palo Alto Recycling Center and Bixbee Park, and the
Palo Alto Airport is located across Embarcadero Road from the Plant. These publicly owned
properties are zoned Public Facilities with Site and Design Review (D) Overlay.
The new sludge facility and ancillary facilities will be compatible with the existing functions of the
Plant, which provides treatment and disposal of wastewater for the Cities of Palo Alto, Mountain
View, and Los Altos; the Town of Los Altos Hills; the East Palo Alto Sanitary District; and Stanford
University. The Plant is also the site for group tours of the facility, and City staff perform
administrative and maintenance duties in several buildings on the site. The proposed sludge
facility and ancillary facilities would be appropriately located in the center of the Plant site to
enable greater visual harmony with the nearby Bixbee Park. The project allows easy and orderly
truck access from Embarcadero Way, and the number of trucks accessing the site for operations
will not be incompatible with the existing nearby land uses, nor would they further impact the
existing and potential uses of adjoining or nearby sites. The new structures will be partially
screened from offsite views by existing structures and vegetation, to maintain the existing
relationship with the surrounding environment.
2. The project is consistent with the goal of ensuring the desirability of investment,
or the conduct of business, research, or educational activities, or other authorized occupations, in
the same or adjacent areas.
The Project will be consistent with other authorized on-site occupations, including
educational activities that take place during Plant tours, and authorized occupations in adjacent
areas. The design and size of the project are generally consistent with the existing buildings at the
facility, and the construction of all improvements will be governed by the regulations of the
current Zoning Ordinance, the Uniform Building Code, and other applicable codes to assure safety
and a high quality of development.
3. Sound principles of environmental design and ecological balance are observed in
the project.
The Project will implement appropriate sustainable building practices as deemed feasible.
The design is compliant with the California Green Building Standards Code (CalGreen), including
use of locally sourced and manufactured, reyclable cor-ten steel, energy-efficient and recyclable
concrete, and use of operational elements such as energy efficient motors, recycled water, and
eventual decommissioning of the incinerator building. Given the proposed Mitigation Measure,
the Project will not have a significant environmental impact as indicated by the proposed
Mitigated Negative Declaration for this Project.
4. The use will be in accord with the Palo Alto Comprehensive Plan.
ATTACHMENT A
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The Project, as conditioned, complies with the policies of the Land Use and Community
Design and the Natural Environment elements of the Comprehensive Plan; specifically, with the
following applicable policies:
POLICY L-5: Maintain the scale and character of the City. Avoid land uses that are
overwhelming and unacceptable due to their size and scale.
POLICY L-48: Promote high quality, creative design and site planning that is compatible
with surrounding development and public spaces.
POLICY N-29: All potential sources of odor and/or toxic air contaminants should be
adequately buffered, or mechanically or otherwise mitigated to avoid odor and toxic
impacts that violate relevant human health standards.
POLICY N-37: Ensure the environmentally sound disposal of solid waste.
The proposed building is of a similar scale and materials as the tallest and most visible structures
on the project site, and the proposed central placement on the site and existing and new
vegetation (at maturity) will help mitigate views of the new building from off site. The building is
designed with a “robust” odor control system to meet regional air quality standards. The facility’s
purpose is to “de-water” and “load out” waste. The project incorporates quality design that
recognizes the sensitive nature of the Baylands area as described in the Comprehensive Plan.
SECTION 4. Site and Design Approval Granted. Site and Design Approval is granted
for the project by the City Council under Palo Alto Municipal Code Section 18.30(G), subject to the
conditions of approval in Section 7 of this Record.
SECTION 5. Architectural Review Findings.
The design and architecture of the proposed improvements, as conditioned, complies with the
Findings for Architectural Review as required in Chapter 18.76 of the PAMC (grouped into six
categories below).
Comprehensive Plan and Purpose of ARB:
Finding #1: The design is consistent and compatible with applicable elements of the
Palo Alto Comprehensive Plan.
Finding #16: The design is consistent and compatible with the purpose of architectural
review, which is to:
o Promote orderly and harmonious development in the city;
o Enhance the desirability of residence or investment in the city;
o Encourage the attainment of the most desirable use of land and
o improvements;
o Enhance the desirability of living conditions upon the immediate site or in
o adjacent areas; and
o Promote visual environments which are of high aesthetic quality and variety and
which, at the same time, are considerate of each other.
The project is consistent with Findings #1 and #16 because:
ATTACHMENT A
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As noted in Section 3 of this RLUA, Site and Design Review Finding #4, the project meets
policies L-5, L-48, N-29 and N-37. The proposed building is of a similar scale and materials
as the tallest and most visible structures on the project site, and the proposed central
placement on the site and existing and new vegetation (at maturity) will help mitigate
views of the new building from off site. The building is designed with a “robust” odor
control system to meet regional air quality standards. The facility’s purpose is to “de-
water” and “load out” waste. The project incorporates quality design of an aesthetic
quality and variety appropriate to the RWQCP campus and the sensitive nature of the
adjacent Baylands Nature Preserve.
Compatibility and Character:
Finding #2: The design is compatible with the immediate environment of the site.
Finding #4: This finding of compatibility with unified or historic character is not
applicable to the project.
Finding #5: The design promotes harmonious transitions in scale and character in areas
between different designated land uses.
Finding #6: The design is compatible with approved improvements both on and off the
site.
The project is consistent with Findings #2, #4, #5 and #6 because:
There is no unified design or historic character along this portion of Embarcadero
Road/Embarcadero Way. The design and layout of the project takes into consideration the existing
conditions on site and adjacency to the surrounding industrial and natural environments. The
project includes mature tree preservation and new landscaping to improve screening of the
proposed, centrally located building; this will reduce potential impacts on public views from the
Baylands Nature Preserve. The building materials and design will be compatible with the palette
and design of industrial architectural style of buildings on the site (cast-in-place concrete, painted
structural steel, and profiled Cor-Ten steel panels). The project is not located in a transitional area
on the site and the building location far from the edge of the site which abuts the Baylands Nature
Preserve. The improvements are compatible with the existing plant use and the siting of the
building is compatible with future plans for improvements at the plant.
Functionality and Open Space:
Finding #3: The design is appropriate to the function of the project.
Finding #7: The planning and siting of the building on the site creates an internal sense
of order and provides a desirable environment for occupants, visitors and the general
community.
Finding #8: The amount and arrangement of open space are appropriate to the design
and the function of the structures.
The project is consistent with Findings #3, #7, and #8 because:
The new facility serves a utilitarian purpose and the structure’s simple design reflects this use. The
new building is centrally located on the site and ancillary facilities are nearby, including parking for
visitors, in an orderly and accessible manner for users of the facility. The building’s entry points are
clearly defined to promote safety, security, and wayfinding. The architectural design includes
ATTACHMENT A
5
skylights to allow daylight into the space and access for the maintenance or replacement of
equipment.
Circulation and Traffic:
Finding #9: Sufficient ancillary functions are provided to support the main functions of
the project and the same are compatible with the project’s design concept.
Finding #10: Access to the property and circulation thereon are safe and convenient for
pedestrians, cyclists and vehicles.
The project is consistent with Findings #9 and #10 because:
The project does not include nor require any changes to the vehicular site access from
Embarcadero Way; a new service drive (load-out entrance road) will be created off the main
driveway for trucks to access the Sludge Dewatering and Loadout facility, and adjustments will be
made to the existing internal vehicular driveway. No adjustments are proposed to the existing
parking spaces on the site. Concrete pedestrian ways are proposed to allow for adequate
circulation around the proposed facilities.
Landscaping and Plant Materials:
Finding #11: Natural features are appropriately preserved and integrated with the
project.
Finding #12: The materials, textures and colors and details of construction and plant
material are an appropriate expression to the design and function and compatible with
the adjacent and neighboring structures, landscape elements and functions.
Finding #13: The landscape design concept for the site, as shown by the relationship of
plant masses, open space, scale, plant forms and foliage textures and colors create a
desirable and functional environment on the site and the landscape concept depicts an
appropriate unit with the various buildings on the site.
Finding #14: Plant material is suitable and adaptable to the site, capable of being
properly maintained on the site, and is of a variety that would tend to be drought-
resistant and to reduce consumption of water in its installation and maintenance.
The project is consistent with Findings #11- #14 because:
The Project incorporates the minimal removal of vegetation and the installation of new native
trees to supplement screen trees planted in 2014. Along with heavy screen trees existing around
the property perimeter, the new screen trees will help further interrupt views of the new building
from Embarcadero Way (3 24”-box sized trees and 6 15-gallon sized trees), and from Harbor Road
(18 36”-box sized trees). New trees in front of the new building include three Strawberry trees,
three Incense Cedars, three Australian Willows; new trees between the building and existing north
soil bed filter include Strawberry trees, Bottle trees, Incense Cedars, Willow-leafed Peppermint
Eucalyptus trees, Australian Willows and Canary Island Pines. The selection of construction
materials, finishes and plantings is appropriate for this facility and the Baylands; they are simple in
form and use natural color tones and materials. The proposed native landscape design will
maintain the site’s character and provide visual screening for the new building. Two sides of the
new building will be partially screened with new vine plantings using a free standing mesh fence.
ATTACHMENT A
6
Sustainability:
Finding #15: The design is energy efficient and incorporates renewable energy design
elements including, but not limited to:
a. Careful building orientation to optimize daylight to interiors
b. High performance, low-emissivity glazing
c. Cool roof and roof insulation beyond Code minimum
d. Solar ready roof
e. Use of energy efficient LED lighting
f. Low-flow plumbing and shower fixtures
g. Below grade parking to allow for increased landscape and storm-water treatment areas
The project is consistent with Finding #15 because:
The proposed materials are durable. Cor-Ten steel has resistance to atmospheric corrosion,
negates the need for painting, is local sourced and manufactured, has a high proportion of
recycled content and is 100% recyclable. The concrete is resource efficient, durable, energy
efficient, creates minimal waste during construction, and is recyclable. The electrical design
includes the use of intelligent motor control centers which are energy efficient. Recycled water
will be used for all process water needs. The plant’s air emissions footprint will be reduce
following decommissioning of the incinerator building. In accordance with the City’s Green
Building Regulations, the building will satisfy the requirements for CALGreen Mandatory + Tier
2.
SECTION 6. Plan Approval.
The plans submitted for Building Permit shall be in substantial conformance with those
plans prepared by ch2m, consisting of 58 pages, dated February 2016 and received February 10,
2016, except as modified to incorporate the conditions of approval in Section 7. A copy of these
plans is on file in the Department of Planning and Community Development.
SECTION 7. Conditions of Approval.
The following conditions shall be addressed prior to any other permit application submittal.
This includes Building Permit, Excavation and Grading Permit, Certificate of Compliance, Street
Work Permit and Encroachment Permit but after the Planning entitlement approval.
1. Development Services:
The following comment is required to be addressed prior to any future related permit
application such as a Building Permit, Excavation and Grading Permit, Certificate of
Compliance, Street Work Permit, Encroachment Permit, etc, and is not required to be
addressed prior to the Planning entitlement approval:
The new facility will include an accessible path to and within the structure that meets
current accessibility standards of the CBC.
2. Utilities Electrical
All work must be done to CPA and NEC code. Customer is responsible for the
ATTACHMENT A
7
cost for changes to the existing electric system.
3. Planning and Community Environment
a. The plans submitted for Building Permit shall be in substantial conformance with plans
received on February 9, 2016, except green screen trellises shall be deleted and except as
modified to incorporate relevant conditions of approval and any additional conditions
placed on the project by the City Council. A complete copy of this Record of Land Use
Action shall be printed on the plans submitted for the Building Permit.
b. For the life of the project, all landscape and trees shall be reasonably well-maintained,
watered, fertilized, and pruned according to Nursery and American National Standards for
Tree, Shrub and Other Woody Plant Maintenance- Standard Practices (ANSI A300-1995) as
outlined in the Palo Alto Tree Technical Manual.
c. Any exterior changes to the building such as size, location, materials or signage are
subject to ARB review and approval prior to final issuance of occupancy/installation.
d. A Planning Division Final inspection will be required to determine substantial
compliance with the approved plans prior to the scheduling of a Building Division final.
Any revisions during the building process must be approved by Planning, including but
not limited to; materials, landscaping and hard surface locations
e. Plans submitted for building permit shall include the lights at the top of the stack in
accordance with FAA Advisory circular (70/7460-1 L, Obstruction Marking and Lighting,
red lights - Chapters 4,5(Red),&12).
f. During construction, any crane or similar equipment that requires FAA part 77
temporary approval shall be the minimum height needed to complete construction.
4. Public Works Engineering
a. Provide the following note on the Site Plan and Structural plans to indicate, “The proposed
project is a Substantial Improvement and shall comply with Palo Alto Municipal Code
Chapter 16.52 Flood Hazard Regulations and FEMA’s requirements.”
b. FLOOD ZONE: Add a note on the plans shall indicate that the Assessor’s Parcel 008-05-005
is located within FEMA’s Special Flood Hazard Area Zone AE where the base flood elevation
(BFE) was determined to be 10.5 as shown on the FIRM Panel Number 06085C0030H dated
May 18, 2009.
c. FLOOD ZONE CONSTRUCTION MATERIALS AND METHODS: Add a note on the Structural,
Architectural and Mechanical plans to indicate that all new construction and substantial
improved structures shall be constructed with flood-resistant materials and utility
equipment shall be resistant to flood damage as specified in FEMA’s technical bulletins and
Palo Alto Municipal Code Section 16.52.130. b
ATTACHMENT A
8
d. FLOOD ZONE CERTIFICATION: An Elevation Certification shall be provided for all structure(s)
and shall be prepared by a registered professional engineer or surveyor, and verified by a
community official to be properly elevated. Such certification and verification shall be
provided to the floodplain administrator based on PAMC section 16.52.130, and shall be
prepared at 3 stages of construction: with the construction documents, during
construction, and prior to building permit final. The elevation certificate prepared based on
the existing structure and the proposed construction, shall be scanned and attached with
the building permit construction documents. Certificates shall be prepared on the NAVD
e. The “Survey Requirements for Construction in the Special Flood Hazard Area” shall be
added to the plan set. A pdf copy of the documents titled Plan Insert for Elevation
Certification Requirements) is available on the City’s website
http://www.cityofpaloalto.org/gov/depts/pwd/forms_and_permits.asp under Flood
Zone Issues.
FLOOD ZONE VENTS: All new construction and substantially improved structures, with fully
enclosed areas below the lowest floor are useable solely for the parking of vehicles,
building access or storage, and which are subject to flooding shall be designed to
automatically equalize hydrostatic flood forces on exterior walls by allowing for the entry
and exit of floodwaters. This requirement shall comply with the guidelines set on FEMA’s
technical bulletins, including but not limited to TB1-08, TB6-93 and TB7-93. See PAMC
16.52.130.c.3 for minimum criteria. Plot and label the vent openings on the structural
details. There must be at least two openings for each enclosed area with 1 sq in of opening
for each 1 sq ft of enclosed area. These openings must be placed no more than 12 inches
above lowest adjacent grade. Provide on the drawings the following: a schedule showing
the areas enclosed; the area of each opening; the number of openings required; a detail
showing the location of the vent relative to adjacent grade; and the location of the
openings on the foundation plan.
These should also be incorporated into the structural drawings, since flood openings in the
foundation affect the structural engineer’s design. Guidelines for flood openings can be
found in FEMA Technical Bulletin 1-08, “Openings in Foundation Walls.”
f. DEMOLITION PLAN: Place the following note adjacent to an affected tree on the Site Plan
and Demolition Plan: “Excavation activities associated with the proposed scope of work
shall occur no closer than 10-feet from the existing street tree, or as approved by the
Urban Forestry Division contact 650-496-5953. Any changes shall be approved by the
same”.
g. GRADING PERMIT: The site plan must include a table that shows the earthwork (cut and
fill) volumes. If the total is more than 100 cubic yards, a grading permit will be required. An
application and plans including Rough Grading and Shoring Plans are submitted to Public
Works separately from the building permit plan set. The application and guidelines are
ATTACHMENT A
9
available on our Public Works website.
http://www.cityofpaloalto.org/gov/depts/pwd/forms_and_permits.asp
h. ROUGH GRADING: provide a Rough Grading Plan for the work proposed as part of the
Grading and Excavation Permit application. The Rough Grading Plans shall including the
following: pad elevation, elevator pit elevation, ground monitoring wells, limits of over
excavation, stockpile area of material, overall earthwork volumes (cut and fill), temporary
shoring for any existing facilities, ramps for access, crane locations (if any), tree protection
measures, etc.
i. LOGISTICS PLAN: The applicant and contractor shall prepare a construction logistics plan
for the work associated with the Excavation and Grading permit. Plan shall be submitted to
Public Works Engineering and shall address all impacts to the City’s right-of-way, including,
but not limited to: pedestrian control, traffic control, truck routes, material deliveries,
contractor’s parking, on-site staging and storage areas, concrete pours, crane lifts, work
hours, noise control, dust control, storm water pollution prevention, contractor’s contact.
The plan shall be prepared and submitted along the Grading and Excavation Permit. It shall
include notes as indicated on the approved Truck Route Map for construction traffic to and
from the site. Plan shall also indicate if the bus stop will need to be relocated.
j. SHORING PLAN: Provide a shoring plan for the existing utilities (if needed), to clearly
indicate how the new structures will be constructed while protecting the existing utilities. If
tiebacks are proposed they shall not extend onto adjacent private property, existing
easements or into the City’s right-of-way without having first obtained written permission
from the private property owners and/or an encroachment permit from Public Works. Plot
and label the tree protection measures on the shoring plans.
k. GEOTECHNICAL REPORT: Shall clearly identify the highest projected groundwater level to
be encountered will be ______ feet below existing grade.
l. DEWATERING: Due to proximity to the bay any excavation may require dewatering during
construction. Public Works only allows groundwater drawdown well dewatering. Open pit
groundwater dewatering is not allowed. Dewatering is only allowed from April through
October due to inadequate capacity in our storm drain system. The geotechnical report for
this site must list the highest anticipated groundwater level. We recommend that a
piezometer be installed in the soil boring. The contractor shall determine the depth to
groundwater immediately prior to excavation by using a piezometer or by drilling an
exploratory hole if the deepest excavation will be within 3 feet of the highest anticipated
groundwater level. If groundwater is found within 2 feet of the deepest excavation, a
drawdown well dewatering system must be used, or alternatively, the contractor can
excavate for the basement and hope not to hit groundwater, but if he does, he must
immediately stop all work and install a drawdown well system before he continues to
excavate. Based on the determined groundwater depth and season the contractor may be
required to dewater the site or stop all grading and excavation work. In addition Public
Works may require that all groundwater be tested for contaminants prior to initial
ATTACHMENT A
10
discharge and at intervals during dewatering. If testing is required, the contractor must
retain an independent testing firm to test the discharge water for contaminants Public
Works specifies and submit the results to Public Works.
Public Works reviews and approves dewatering plans as part of a Street Work Permit. The
applicant can include a dewatering plan in the building permit plan set in order to obtain
approval of the plan during the building permit review, but the contractor will still be
required to obtain a street work permit prior to dewatering. Alternatively, the applicant
must include the above dewatering requirements in a note on the site plan. Public Works
has a sample dewatering plan sheet and dewatering guidelines available on our
website. http://www.cityofpaloalto.org/gov/depts/pwd/forms_and_permits.asp
m. GRADING AND DRAINAGE PLAN: The plan set must include a grading & drainage plan
prepared by a licensed professional that includes existing and proposed spot elevations,
earthwork volumes, finished floor elevations, pad elevation, area drain and bubbler
locations, drainage flow arrows to demonstrate proper drainage of the site. See Palo Alto
Municipal Code Section 16.28 and Grading & Drainage Guidelines for Residential
Development form for guidelines.
http://www.cityofpaloalto.org/civicax/filebank/documents/2717
n. STORM WATER TREATMENT: This project shall comply with the storm water regulations
contained in provision C.3 of the NPDES municipal storm water discharge permit issued by
the San Francisco Bay Regional Water Quality Control Board (and incorporated into Palo
Alto Municipal Code Chapter 16.11). These regulations apply to land development projects
that create or replace 10,000 square feet or more of impervious surface, and restaurants,
retail gasoline outlets, auto service facilities, and uncovered parking lots that create and/or
replace 5,000 square feet or more of impervious surface. In order to address the potential
permanent impacts of the project on storm water quality, the applicant shall incorporate
into the project a set of permanent site design measures, source controls, and treatment
controls that serve to protect storm water quality, subject to the approval of the Public
Works Department. The applicant shall identify, size, design and incorporate permanent
storm water pollution prevention measures (preferably landscape-based treatment
controls such as bioswales, filter strips, and permeable pavement rather than mechanical
devices that require long-term maintenance) to treat the runoff from a “water quality
storm” specified in PAMC Chapter 16.11 prior to discharge to the municipal storm drain
system. Effective February 10, 2011, regulated projects, must contract with a qualified
third-party reviewer during the building permit review process to certify that the
proposed permanent storm water pollution prevention measures comply with the
requirements of Palo Alto Municipal Code Chapter 16.11. The certification form, 2 copies
of approved storm water treatment plan, and a description of Maintenance Task and
Schedule must be received by the City from the third-party reviewer prior to approval of
the building permit by the Public Works department. Within 45 days of the installation of
the required storm water treatment measures and prior to the issuance of an occupancy
ATTACHMENT A
11
permit for the building, third-party reviewer shall also submit to the City a certification
for approval
If pumps are required, plot and label where the pumps will be located, storm water runoff
from pumped system shall daylight onto onsite landscaped areas and be allowed to
infiltrate and flow by gravity to the public storm drain line. Storm water runoff that is
pumped shall not be directly piped into the public storm drain line.
o. Applicant shall be aware that the project may trigger water line and meter upgrades or
relocation, if upgrades or relocation are required, the building permit plan set shall plot
and label utility changes. If a backflow preventer is required, it shall be located within
private property and plotted on the plans. Similarly if a transformer upgrade or a grease
interceptor is required it shall also be located within the private property. Plot and label
these on the Utility plan.
p. The following note shall be shown on the plans adjacent to the area on the Site Plan:
“Any construction within the city right-of-way must have an approved Permit for
Construction in the Public Street prior to commencement of this work. THE PERFORMANCE
OF THIS WORK IS NOT AUTHORIZED BY THE BUILDING PERMIT ISSUANCE BUT SHOWN ON
THE BUILDING PERMIT FOR INFORMATION ONLY.”
q. Provide the following note on the Site Plan and Grading and Drainage Plan: “Contractor
shall not stage, store, or stockpile any material or equipment within the public road right-
of-way.” Construction phasing shall be coordinate to keep materials and equipment onsite
or within private property.
r. IMPERVIOUS SURFACE AREA: The project will be creating or replacing 500 square feet or
more of impervious surface. Accordingly, the applicant shall provide calculations of the
existing and proposed impervious surface areas with the building permit application. The
Impervious Area Worksheet for Land Developments form and instructions are available at
the Development Center or on our website. To determine the impervious surface area that
is being disturbed, provide the quantity on the site plan.
STORMWATER POLLUTION PREVENTION – The plan set shall include the “Pollution Prevention
– It’s Part of the Plan” An electronic copy of this plan is available on the City’s website.
http://www.cityofpaloalto.org/civicax/filebank/documents/2732
5. Fire
Install a NFPA 13 fire sprinkler, NFPA 24 underground fire service and NFPA 72 fire alarm
monitoring system.
ATTACHMENT A
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SECTION 8. Term of Approval.
1. Site and Design Approval. In the event actual construction of the project is not
commenced within two years of the date of council approval, and if such
approval is received prior to March 21, 2018, the approval shall expire and be
of no further force or effect, pursuant to Palo Alto Municipal Code Section
18.30(G).080, unless extended for an additional year by the Director of
Planning and Community Environment.
PASSED:
AYES:
NOES: ABSENT:
ABSTENTIONS:
ATTEST: APPROVED:
_________________________ ____________________________
City Clerk Director of Planning and
Community Environment
APPROVED AS TO FORM:
___________________________
Senior Asst. City Attorney
PLANS AND DRAWINGS REFERENCED:
1. Those plans prepared plans prepared by CH2mHill, consisting of 3 pages, dated and received
February 10, 2016.
ARB Submittal for Major Project
Component 1 Sludge Dewatering and Loadout Facility for the Regional Water Quality Control Plant
Site and Design Review
Prepared for City of Palo Alto
September 2015
ATTACHMENT B
Component 1 Sludge Dewatering and Loadout Facility for the Regional Water Quality Control Plant
Project Description
PREPARED FOR: Architectural Review Board/City of Palo Alto
COPY TO: Padmakar M. Chaobal/Regional Water Quality Control Plant
PREPARED BY: CH2M
DATE: September 2015
This project description summary is prepared for the City of Palo Alto (City) Architectural Review Board
(ARB) site and design review of the Sludge Dewatering and Loadout Facility project (proposed project) at the
Regional Water Quality Control Plant (RWQCP), Palo Alto, California. The proposed project would include
the construction and operation of a sludge dewatering and loadout facility at the City’s RWQCP.
Introduction and Background of the Project
The City of Palo Alto has operated the RWQCP for more than 80 years. Originally constructed in 1934, the
RWQCP is an advanced treatment facility that provides treatment and disposal of wastewater for the cities
of Palo Alto, Mountain View, and Los Altos; the Town of Los Altos Hills; the East Palo Alto Sanitary District;
and Stanford University. The RWQCP has undergone several expansions and upgrades throughout the years
and currently has a designed average dry weather flow capacity of 39 million gallons per day (MGD) and a
current average flow of about 18 MGD. The RWQCP effluent is partly discharged to the San Francisco Bay,
and partly diverted to the RWQCP recycled water facility for reuse.
The City’s vision for future biosolids management encompasses the need to address the RWQCP’s aging
solids handling infrastructure, to proactively comply with changing and uncertain regulations affecting
biosolids, and to respond to community goals to increase the beneficial use of recovered organic resources
city-wide. Pursuant to this vision, Palo Alto’s City Council has prioritized the decommissioning of the RWQCP
multiple-hearth furnaces (MHFs) by the year 2019. The MHFs currently incinerate the RWQCP wastewater
residuals, but the MHFs are at the end of their useful life; therefore, the City evaluated options for
wastewater residuals management. Hence, the City developed a Biosolids Facility Plan (BFP) that provides a
long-term roadmap to enable the City to reliably and sustainably manage and beneficially reuse the
wastewater solids produced at the RWQCP through year 2045. The BFP was developed as a companion
document to the City of Palo Alto Long Range Facilities Plan for the Regional Water Quality Control Plant
Final Report (LRFP) (Carollo Engineers, 2012). The BFP builds on the LRFP, allowing solids processing
recommendations in the BFP to move forward in concert with other planned improvements at the RWQCP
(as defined in the LRFP). Together, the two documents provide a comprehensive long-term plan for the
RWQCP.
The proposed project being submitted for site and design review is the dewatering and loadout facility, also
known as Component 1 of the BFP. The dewatering and loadout facility would have independent utility as a
backup sludge dewatering and haul off facility that can be used long-term even if additional BFP
components are not built.
Scope of the Project
The proposed project includes the construction of a new building to accommodate the installation of four
belt filter presses. The project also includes mechanisms to convey the resulting dewatered cake from the
belt filter presses to three storage bins, and to load the cake from the bins into trucks. These operations
1
PROJECT DESCRIPTION
would occur within the new sludge dewatering and loadout facility building. The new building would be a
two story, cast-in-place concrete structure that would contain space for the belt filter presses, truck loadout,
and other miscellaneous support areas. The facility would have a building footprint of approximately 7,500
square feet and a building height of 50 feet. The roof would include removable skylights over the belt filter
presses for the purpose of facilitating future removal/ replacement. These skylights would also provide light
into the room, reducing the need for electric lights during the daytime. Various minor modifications to the
yard piping system would be needed in order to accommodate the new facility. The location of the new
sludge dewatering and loadout facility is approximately in the middle of the existing RWQCP.
The three existing belt filter press feed pumps will be replaced with new but larger pumps and used to feed
the sludge from the existing sludge blend tank to the new belt filter presses. The facility would also include a
robust system for odor control. Both the new feed pumps and the new odor control equipment would be
installed outdoors on the existing feed pumps area adjacent to the existing sludge blend tank (located
immediately North of the new sludge dewatering and loadout facility).
In addition to the sludge dewatering and loadout facility itself, a standby diesel engine generator will be
installed to provide backup power. The generator is sized to handle the load for the facility as well as other
nearby facilities. Fuel storage will be provided by means of a sub-base fuel tank.
Existing and Proposed Uses
The sludge dewatering and loadout facility would be located on currently undeveloped land approximately
in the middle of the existing RWQCP. Therefore, there are no existing uses of the proposed site.
The proposed sludge dewatering and loadout facility would be part of the RWQCP solids processing system.
The belt filter presses are large machines that use physical pressure to separate solids from the liquid waste
stream (i.e., dewatering). All dewatering operations will occur within the new building, effectively isolating
the continuous machinery operations from the environment. Dewatered solids produced by the belt filter
presses – the “cake” – would be conveyed to the bins for offsite reuse. Trucks would enter the building
through a roll-up door on the northwest side, and would receive the cake load from the overhead storage
bins. Up to five trucks per day (counted as ten trips per day) are expected to fully haul the load generated by
the dewatering operations. The BFP provides several options for beneficial reuse within the Bay Area and
surrounding counties.
The project does not require specialized maintenance, and all facilities would undergo routine maintenance
as part of overall RWQCP operations. Also, the facility will not be permanently occupied; approximately 3
staff will access the facility as-needed for routine operations and maintenance.
Architectural Design Concept
The primary goal of this project is to deliver a high quality, cost effective process structure that integrates
seamlessly with existing plant operations and maintains flexibility for future growth. The new facility will be
designed for optimum functionality while complementing the existing plant architecture and surrounding
natural environment.
Relationship to Existing Conditions
The project is located on a vacant site within the existing RWQCP. The RWQCP is flanked by an industrial
business park and capped landfill to the south, in the process of being converted into parkland, the Palo Alto
Airport to the north, and the Baylands Nature Preserve to the east. The preserve is considered as one of the
best bird watching areas on the west coast and a major migratory stopover on the Pacific Flyway. There are
numerous hiking, running, and cycling trails around the plant.
The existing process structures within the plant share a similar industrial architectural style, utilizing a
material palette of cast-in-place concrete, painted structural steel, and profiled Cor-Ten steel panels.
2
PROJECT DESCRIPTION
Concrete walls are articulated with vertical flutes, horizontal reveals, and exposed form ties. Structures are
surrounded by simple landscaping, pavement, and drainage systems.
The vehicular approach to the proposed Sludge Dewatering and Loadout Facility is from the main plant
entrance, bypassing the existing Operations Building to the south and the Administration Building to the
north. The proposed facility will be situated between the Solids Incineration Building to the north and the
Primary Sedimentation Tanks to the south.
Design Criteria
The proposed architectural design addresses the City’s desire for a visually attractive facility which blends in
to the existing campus and the surrounding natural environment. A modern reinterpretation of the existing
material palette provides visual consistency and sets a precedent for future campus improvements. Existing
Baylands view sheds will be maintained by respecting local height limitations.
Architectural Design Objectives
• Emphasize functional and operational requirements, particularly pedestrian and vehicular access
• Provide safe, healthy, and comfortable workspaces for operations and maintenance staff
• Blend into natural surroundings of Baylands Nature Preserve
• Complement existing plant architecture and landscaping
• Respect public views from outside the plant perimeter
• Use consistent and practical forms, materials, finishes, and colors
• Design for durability, longevity, and low maintenance
• Provide educational opportunities for visitors and tour groups
• Establish architectural vocabulary for future facility improvements
Design Concepts
Key elements of the architectural design include clearly defined entries and circulation elements and
controlled views into process area from the building exterior. Various Cor-Ten steel cladding panels,
storefront glazing, and articulated vertical concrete surfaces will be utilized to express these concepts.
3
PROJECT DESCRIPTION
Figure (a) View from Northeast Figure (b) View from Southeast
Figure (c) View from Northwest Figure (d) View from Southwest
Panel Lift Doors
Building entry points are clearly defined to promote safety, security, and wayfinding. Panel lift doors are
proposed in lieu of coiling steel doors at several locations around the building exterior. They provide a low
maintenance entry system which operates via a series of lift straps controlled by a retraction motor to fold
the door in half. By acting as canopies when in the open position, they also allow for some protection from
the elements. At the building’s main staff entrance, the panel lift door will be held in the open position to
serve as a formal entry canopy. In keeping with the primary material palette, the folding door panels will be
clad in Cor-Ten steel. The truck loadout bay will have coiling doors at each end to meet the requirement for
impact and corrosion resistance.
Views into Facility
In order to provide educational and interpretive opportunities for visitors while restricting access to
operational spaces, several design features will allow views of activities and equipment from outside the
building. These features will also allow natural daylighting into various spaces to improve operator comfort
and safety. A perforated Cor-Ten screen wall will allow views into the rooftop cake storage bin area while
obscuring visibility from more distant views outside the plant. To allow visibility of the belt filter press room
from the adjacent sedimentation tanks, a large storefront window will be provided on the east wall. Narrow
windows at each landing of the building’s interior stairwell will allow views of people moving within the
facility. Finally, removable skylights will be located above each belt filer press, allowing daylight into the
space and access for the maintenance or replacement.
4
PROJECT DESCRIPTION
Materials and Color Palette
Cast-in-place Concrete
The structural concrete exterior will incorporate a uniform pattern of expressed plywood formwork with a
complementary configuration of exposed form ties. The expressed joint pattern will continue through to
adjacent cladding materials.
Cor-Ten Steel Panels
Also known as weathered or weathering steel, this material oxidizes over time to form an attractive
protective coating over the steel. The use of Cor-Ten provides continuity of materials with existing buildings
at the plant and the Baylands Preserve. Due to its 50+ year lifespan, the sustainable approach to the campus
is continued.
Cor-Ten Steel is proposed in several locations:
• Wall Cladding
A solid panel system will be post installed into the portions of the structural concrete walls, flush with
the exterior face. Panel sizes and locations will correspond with the concrete joints as well as standard
supplied panel dimensions. This will minimize the need for excess cutting and thus reduce waste.
• Perforated Screen Wall
Perforated panels will be attached to a steel screen wall structure around the outdoor cake storage
area, providing views into the space and allowing the space to remain unclassified.
5
PROJECT DESCRIPTION
• Exterior Stair Guardrail
The steel stair running along the east façade will incorporate solid panels to serve as a balustrade.
• Roof Guardrail
Perforated panels will be provided around the upper roof parapet to serve as a balustrade. It will be
fixed to the inside face of the parapet to prevent runoff on the concrete facade.
Sustainable Design Elements
The architectural design of the facility is compliant with the California Green Building Standards Code
(CALGreen Code).
Some key sustainable features of the proposed materials are summarized below.
Cor-Ten Steel
• The steel is allowed to rust and that rust forms a protective coating which provides increased resistance
to atmospheric corrosion
• Negates need for painting
• Locally sourced and manufactured (USA)
• High proportion of recycled content
• 100% recyclable
Concrete
• resource efficient (predominant raw material is limestone, the most abundant mineral on earth)
• durable
• energy efficient (absorbs and retains heat)
• minimal waste during construction
• recyclable (can be crushed and made into aggregate)
In addition to sustainable materials selection, the design of the facility includes operational elements that
will further enhance the RWQCP’s environmental impact. For example, the electrical design includes the use
of intelligent motor control centers (MCCs) which are energy efficient motors; and the use of recycled water
for all process water needs. The decommissioning of the multiple hearth furnaces (incinerator building) after
the new facility is operational for solids management will significantly reduce the plant’s air emissions
footprint.
Project Construction
The sludge dewatering and loadout facility would be constructed over a period of approximately 24 months,
beginning in April 2016 and continuing through Spring 2018. Project construction would consist of site
preparation and minor demolition activities; building construction; and equipment installation, startup, and
testing. Most of the construction activities would occur during building construction, which would include
modifications to nearby yard piping. Construction access would be from Embarcadero Way, and is expected
to average 10 vehicles per day (counted as 20 trips per day) over the construction period.
6
General Zoning Compliance Analysis for PF (D)
REQUIRED/ALLOWED PROPOSED COMPLIANCE
ADDRESS 2501 Embarcadero Way,
Palo Alto, CA 94303
-- --
ACCESSOR’S PARCEL
NUMBER
008-03-029 -- --
TOTAL SITE AREA 24.87 acres same yes
ZONING DISTRICT PF (D) same yes
HISTORIC CATEGORY NONE same yes
FLOOD ZONE AE10.5 same yes
FRONT (EMBARCADERO
WAY) SETBACK
20 ft. same yes
REAR YARD SETBACK 20 ft. same yes
SIDE YARD SETBACK 20 ft. same yes
MAXIMUM HEIGHT 50 ft. 50 ft. to parapet, with
10 ft. ventilation
system on top
yes
SITE COVERAGE 30% (existing 29.15%) 29.84%
MAXIMUM F.A.R. 1:1
TREE DISCLOSURE STATEMENT CITY OF PALO ALTO
Planning Division, 250 Hamilton Avenue
Palo Alto, CA 94301
(650) 329-2441
http://www.cityofpaloalto.org
Palo Alto Municipal Code, Chapter 8.10.040, requires disclosure and protection of certain trees located on private and public
property, and that they be shown on submitted and approved site plans. A completed tree disclosure statement must accompany
all permit applications that include exterior work, all demolition or grading permit applications, or other development activity.
PROPERTY ADDRESS: ______________________________________________________________________
Are there Regulated1 trees on or adjacent to the property? YES NO (If no, proceed to Section 4)
[Sections 1- 4 MUST be completed by the applicant. Please circle and/or check where applicable.]
1. Where are the trees? Check those that apply. (Plans must be submitted showing all trees over 4” diameter)
On the property
On adjacent property overhanging the project site
In the City planter strip or right-of-way easement within 30’ of property line (Street Trees)*
*Street trees1 require special protection by a fenced enclosure, per the attached instructions. Prior to receiving any permit, you must provide
an authorized Street Tree Protection Verification form. Contact Public Works Operations at (650) 496-5953 for inspection of type I, II or III
fencing (see attached Detail #605) required for all street trees.
2. Are there any Protected
1 or Designated1 Trees? YES (Check where applicable)NO
Protected Tree (s)
Designated Tree (s)
On or overhanging the property
3. Is there activity or grading within the dripline? (radius 10 times the trunk diameter) of these trees?YES NO
If Yes, a Tree Preservation Report must be prepared by an ISA certified arborist and submitted for staff review (see TTM 2, Section 6.25).
Attach this report to Sheet T-1,:Tree Protection, its Part of the Plan!”, per Site Plan Requirements.
4. Are the Site Plan Requirements** completed?YES NO
**Plans. Protection of Regulated trees during development require the following: (1) Plans must show the measured trunk diameter and canopy
dripline; (2) Plans must denote, as a bold dashed line, a fenced enclosure area out to the dripline, per Sheet T-1 and Detail #605 -
http://www.cityofpaloalto.org/trees/forms.htm (See also TTM2, Section 2.15 for area to be fenced)
I, the undersigned, agree to the conditions of this disclosure. I understand that knowingly or negligently providing false or
misleading information in response to this disclosure requirement constitutes a violation of the Palo Alto Municipal Code Section
8.10.040, which can lead to criminal and/or civil legal action.
Signature: __________________________ Print: ______________________________ Date: ____________
(Prop. Owner or Agent)
FOR STAFF USE:
Protective Fencing
Sections 5-6 must be completed by staff for the issuance of any development permit (demolition, grading or building permit).
5.Protected Trees. The specified tree fencing is in place. A written statement is attached verifying that
protective fencing is correctly in place around protected and/or designated trees. YES NO
(N/A if there are no protected trees, check here )
6.Street Trees. A signed Public Works Street Tree Protection Verification form is attached.YES NO
(N/A if there are no street trees, check here ).
_____________________________ 1 Regulated Trees – a) Street trees – trees on public property; b) Protected trees – Coast Live Oaks or Valley Oaks which are 11.5” in diameter or larger, Coast
Redwoods which are 18” in diameter or larger, when measured 54” above natural grade; and Heritage trees are trees designated by City Council; and c)
Designated Trees – commercial or non-residential property trees, which are part of an approved landscape plan. 2 Palo Alto Tree Technical Manual (TTM) contains instructions for all requirements on this form, available at www.cityofpaloalto.org/trees/technical-manual.html
S:\PLAN\PLADIV\Advance Planning\Arborist\Tree Program Information\Tree Disclosure Statement(TDS)\Tree Disclosure StatementFinal_3'07.doc Revised 03/04/07
Regional Water Quality Control Plant, 2501 Embarcadero Way, Palo Alto, CA 94303
Hamid Ghaemmaghami
DocuSign Envelope ID: D7F87601-4FB7-492E-A20D-22F19893CF8C
9/2/2015
AERIAL PHOTO – EXISTING CONDITIONS AND LOCATION OF NEW SLUDGE DEWATERING & LOADOUT FACILITY
PALO ALTO REGIONAL WATER QUALITY CONTROL PLANT
SEPTEMBER 3, 2015
SLUDGE DEWATERING & LOADOUT FACILITY
PALO ALTO REGIONAL WATER QUALITY CONTROL PLANT
Proposed Site - existing conditions – NORTHWEST VIEW
Proposed Site - existing conditions – SOUTHWEST VIEW (from Admin Building) Proposed Site - existing conditions – SOUTHWEST VIEW (from Primary Sedimentation Tanks)
Proposed Site - existing conditions – NORTHEAST VIEW
Incinerator Building
Primary
Sedimentation Tanks Trickling Filter
Incinerator Building
ATTACHMENT C
January 27, 2016
Commissioner Waldfogel questions related to FAA Height Restrictions and staff responses
Q1: Is there a map or analysis that the 65 foot RWQCP stack height complies with the Palo Alto
Airport height restriction map? Page 3‐9 of the attached report shows the obstruction height
contours but I can’t tell exactly where the plant is in relation to the FAA FAR part 77 obstruction
standards map (http://www.countyairports.org/docs/CLUP_PAO/PAOClupAdopted11‐19‐
08.pdf)
Staff Response Q1: The ventilation stack is at elevation 76.5 above mean sea level (MSL) (65
feet above finish floor). Based on Staff review of Figure 6 and the FAR Part 77 Surfaces, the
obstruction height limits for the Plant lie between 129 MSL and 154 MSL in the vicinity of the
new sludge dewatering building and 79 MSL at the northern corner of the Plant nearest the
airport. All of these obstruction heights are above the stack elevation of 76.5 MSL. To illustrate
this, staff will provide at Commissioners’ places the enlarged FAA height restrictions map with
the building site marked on the map (the FAA map, without the building site marked, is
provided below).
Q2: Even if the 65 foot stack is in the 79 foot contour it would be nice to get a readout from the
airport manager and/or the FAA FSDO and generally some analysis if this has any effect on the
airport business plan.
Staff Response Q2: The FAA’s review process is underway (the required form has been
filed). Staff’s interpretation of the height map (Figure 6, at places) is likely to be confirmed. The
ATTACHMENT D
process includes a review of the existing approach surfaces. The process will be completed
before issuance of building permits/commencement of construction. While the FAA does not
provide “readouts”, no problems are anticipated.
Herb Borock’s comments (paraphrased) on CEQA topic sections: Aesthetics, AQ (odors), and
GGH
Comment 1 – The MND should analyze views of the project from HIGH POINTS in the future
parkland (former landfill).
Staff Response C1: The photo below is taken from the high point (Designated as “ B” in the
attached schematic – first email attachment). The new building has been “photo shopped” in;
and becomes the highest building at the Plant, by a few feet. The third attachment to this
email is a view from “point B” to the Plant with existing conditions (no sludge facility photo‐
shopped in).
Comment 2 ‐ There is no substantial evidence to support the statements about odors (May
2015 tech memo about odor referenced).
Staff Response C2, Odor Control: The potential for odor impacts was fully assessed in the Initial
Study, with the conclusion that odor levels would be “substantially less” than the Bay Area
AQMD’s dilution‐to‐threshold (D/T) ratio of 5. The exact D/T ratio was unquantified in the Initial
Study because of some potential variations in the exact control technology to be used.
Notwithstanding this unquantified conclusion in the Initial Study text, appropriate calculations
were prepared as part of our record, and further refined in an updated version of the odor
control memo referenced by the commenter (dated August 4, 2015). As reported in the memo,
and in calculations performed at the time the Initial Study was prepared, the proposed odor
control technology would result in an expected D/T ratio of approximately 0.9 at the property
line. In addition, a more conservative model run was performed to assess a potential worst
case, which showed a maximum D/T ratio of approximately 1.5 at the property line. All
calculations were performed using the AERMOD dispersion model. These numbers support the
Initial Study conclusion that impacts would be less than significant.
Comment 3 ‐ The MND erroneously omits the emissions from project operations in the GHG
section.
Staff Response C3, Greenhouse Gas Emissions:
The Initial Study discusses impacts from both project construction and operation in Section
3.7.2. Given the extent of construction activities, impacts are quantified and compared to
regional greenhouse gas reduction strategies. Impacts from operation are negligible, and
potential emission sources – periodic testing of the backup generator and a nominal five truck
trips per day – are addressed qualitatively. Because the new facility would be powered by
electricity, there is limited onsite potential for greenhouse gas generation from equipment
operations. In response to the comment, we further examined the potential for impacts from
equipment operations, focusing on the potential for methane emissions from the new sludge
handling process, and determined that the bio‐solids residence time is so short that generation
of biogenic methane is not expected. No changes to the Initial Study are required. Also, it
should be noted that this project is a significant step in replacing the existing multiple hearth
incinerators, which will substantially reduce overall greenhouse gas emission from wastewater
treatment operations.
The second attachment, the Green House Gas factsheet, may help provide the “big picture” on
this topic.
GREENHOUSE GAS EMISSIONS
FACTSHEET
August 2015
*GHG emissions are calculated using the Local Government Operations Protocol, version 1.1 & include both anthropogenic and biogenic emissions.
GHG emissions associated with electrical usage and the switch to green electricity are included in the above totals. Excluding the purchase of green
electricity, the RWQCP decreased its GHG emissions by 20% between 2005 and 2014.
The Regional Water Quality Control Plant (RWQCP) is one of the City of Palo Alto’s major
greenhouse gas (GHG) emitting facilities. Since 2005, the RWQCP has undertaken numerous
initiaves to decrease GHG emissions. These initiatives include purchasing green electricity,
routinely tuning the sewage sludge incinerators to decrease natural gas consumption, and
utilizing landfill gas to further decrease natural gas used in the sewage sludge incinerators.
Since 2005, the RWQCP has reduced its GHG emissions by 43 percent. The RWQCP is
dedicated to reducing it’s GHG footprint and has incorporated GHG emissions as a key
decision‐making factor as it plans for a new biosolids treatment process and anticipated
nutrient removal requirements.
9%
16%
75%
2014 RWQCP Sewage Sludge Incinerator
GHG Emissions by Fuel Type
Landfill Gas
Natural Gas
Biosolids
1.7%
13%
0%
83%
2.3%
2014 RWQCP GHG Emissions by Source
Biological Treatment
Baylands Conversion
Electrical
Sewage Sludge
Incinerator
Office Comfort Heating
ENERGY USE FACTSHEET
August 2015
The Regional Water Quality Control Plant (RWQCP) is the City of Palo Alto’s major energy consuming facility.
Since 2005, the RWQCP has undertaken numerous initiaves to decrease and switch to greener energy options.
These initiatives include purchasing green electricity, routinely tuning the sewage sludge incinerators to
decrease natural gas consumption, and utilizing landfill gas to further decrease natural gas used in the sewage
sludge incinerators. The RWQCP is dedicated to reducing it’s energy footprint and is planning numerous
projects and evaluations to do so (Table 1). The RWQCP has incorporated energy usage as a key decision‐
making factor as it prepares for expanded recycled water demand and anticipated nutrient removal
requirements.
Table 1: Summary of Future Energy Projects &Evaluations Anticipated to Occur Between 2015 &2020
Energy Reduction Projects Energy Reduction Evaluations Future Energy Increase Projects
Decommission sewage sludge incinerator
Replace aeration basin diffuser
Install new controls (VFD) on motors
Trickling filter rehabilitation
New Pumping Plant rehabilitation
Install electrical meters and
load evaluations by process
area
Emerging technologies for
trickling filter and nitrification
optimization
New nutrient removal
treatment processes
Increased recycled water
production
Increased incoming
wastewater strength
0
5,000,000
10,000,000
15,000,000
20,000,000
25,000,000
2005 2006 2007 2008 2009 2010 2011 2012 2013 2014
El
e
c
t
r
i
c
i
t
y
(k
W
h
)
RWQCP Electrical Usage
Brown Electricity Green Electricity
0
10,000,000
20,000,000
30,000,000
40,000,000
50,000,000
60,000,000
70,000,000
80,000,000
0
200,000
400,000
600,000
800,000
1,000,000
1,200,000
1,400,000
2009 2010 2011 2012 2013 2014
Fu
e
l
Vo
l
u
m
e
(s
c
f
)
Fu
e
l
He
a
t
En
e
r
g
y
(t
h
e
r
m
s
)
Sewage Sludge Incinerator Auxiliary Fuel Usage
LFG ‐ Heat Energy NG ‐ Heat Energy LFG ‐ Volume NG ‐ Volume
City of Palo Alto (ID # 6503)
City Council Staff Report
Report Type: Informational Report Meeting Date: 2/22/2016
City of Palo Alto Page 1
Council Priority: Environmental Sustainability
Summary Title: Update on Energy/Compost Technologies
Title: Update on Energy/Compost Technologies, Measure E, and Organics
Processing
From: City Manager
Lead Department: Public Works
Recommendation
This report is provided for information only and requires no Council action.
Executive Summary
Programs developed and implemented in 2015 as part of Council’s direction to
extract energy and compost from the City’s organic residuals (wastewater solids,
food scraps and soiled paper, and yard trimmings) include: 1) 90% design level
reached on the sludge dewatering facility needed to phase out the wastewater
solids incinerators; 2) the July 2015 establishment of a new residential food scraps
collection program; and 3) the diversion of commercial and residential food
scraps, food-soiled paper and yard trimmings to a new dry anaerobic digester
(DAD) facility in north San Jose where energy and compost are recovered. All of
the City’s collected food and yard residuals are now sent to the type of facility
contemplated by Measure E. As part of the annual update to Council, staff has
continued to track emerging technologies for consideration on the Measure E
site. While no fundamentally new type of technology has emerged, staff will
monitor the development of gasification and pyrolysis type processes.
Background
ATTACHMENT E
City of Palo Alto Page 2
In May 2014, Council approved a four component Organics Facilities Plan (OFP)
(Staff Report #4744) to direct the processing of wastewater biosolids, food scraps,
and yard trimmings.
Component One: Biosolids Dewatering and Truck Haul-Out Facility.
Component Two: Wet Anaerobic Digestion Facility utilizing the thermal
hydrolysis process.
Component Three: Food Preprocessing Facility; preprocessed food scraps
would be fed into the anaerobic digester (component
two above).
Component Four: The pursuit of technologies to harness the energy and
resource potential of yard trimmings.
Council directed staff to look first at component four as a composting option for
yard trimmings on the 10-acre Measure E site. Council approved using existing
facilities to process food scraps and yard trimmings (Staff Report #5182) and
directed staff to return to Council annually with an update on new organics
processing technologies and opportunities. This report is that annual update.
Discussion
No New Technologies
Staff regularly review new organics processing technologies and opportunities
and receive information from technology providers. The main constraint that
prevented the development of a cost-effective facility on the Measure E site is still
the key factor – the site is too small to provide an economy of scale to process
enough material. Other factors that limit the development of new cost-effective
processing technologies include the low price of energy, high cost of construction
and permitting challenges. Staff will continue to investigate new technologies and
will prepare a long-term recommendation as part of a future update to the Zero
Waste Operational Plan in preparation for a new solid waste hauling and
processing contract in 2021.
Anaerobic Digestion at ZWED
All residential and commercial organics (food scraps and yard trimmings)
collected in green containers are now processed at the Zero Waste Energy
City of Palo Alto Page 3
Development (ZWED) Facility in north San Jose. These compostables are first
placed in large bunkers as part of a dry anaerobic digestion process where
methane is created and then combusted in engines to generate renewable
energy. The material from the digester is then cured and composted and
ultimately used as a soil amendment.
The residential curbside food scrap collection program started on July 1, 2015,
allowing residents to place food scraps and soiled paper in the green cart with
yard trimmings. Residents are using the program. Preliminary hauler data show
that the amount of material collected from July through October 2015 in the
green cart increased by 10 percent as compared to the same four months in 2014.
Additionally, GreenWaste of Palo Alto, the City’s contract solid waste hauler,
continues to add new commercial customer participants to the compost program.
On January 25, 2016, Council amended the Municipal Code, Chapter 5.20 (Staff
Report #6340), to require all businesses to subscribe to recycle and compost
services and comply with refuse sorting requirements. This “Recycling and
Composting Ordinance” could increase the commercial tons processed at ZWED
by 33%, diverting an additional 15,000 tons per year.
Dewatering and Anaerobic Digestion of Wastewater Biosolids
Staff continues to move forward with components one and two of the OFP at the
Palo Alto Regional Water Quality Control Plant (RWQCP). The 90% design
documents have been completed for the sludge dewatering and truck loadout
facility (i.e., Component One). This facility will allow the incinerators to be
decommissioned and the dewatered solids to be hauled to other facilities for
energy recovery and/or compost creation. An application for the Site and Design
Review process has been submitted to the Planning Department. A study session
and first meeting with the Architectural Review Board (ARB) has been held; the
project was also presented to the Planning and Transportation Commission. The
project is scheduled to go out to bid in the spring of 2016, with construction
completed in 2018.
The preliminary design of the anaerobic digesters at the RWQCP (i.e., Component
Two) has been prepared, resulting in the estimated cost rising from around $57.4
million to approximately $75 million plus. The next step is to re-evaluate the
planning and preliminary design and identify opportunities to lower costs,
City of Palo Alto Page 4
including continued evaluation of gasification and pyrolysis type processes.
Currently, staff is fully engaged in completing Component One.
City of Palo Alto Page 1
Planning and Transportation Commission 1
Draft Verbatim Minutes 2
January 27, 2016 3
4
EXCERPT 5
6
Public Hearing 7
8
2501 Embarcadero Way [File 15-PLN-00371]: Request by Public Works for Site and Design Review 9
of a new two-story, 7,500 square foot, 50-foot tall building designed to handle sludge de-watering and 10
truck load-outs, with adjacent stand-by diesel generator, to be placed centrally on the Regional Water 11
Quality Control Plant site, and a new outdoor equipment area next to the existing incinerator. The 12
proposed project is the construction and operation of the facility which would be a cast‐in‐place concrete 13
structure with skylights and containing belt filter presses, truck loadout, and other miscellaneous support 14
areas. The project includes minor modifications to the yard piping system and fuel storage in a sub‐base 15
fuel tank. Environmental Assessment: An initial study and a Draft Mitigated Negative Declaration have 16
been prepared in accordance with the California Environmental Quality Act (CEQA). Zone District: Public 17
Facilities (PF) Site and Design Combining District (D). For more information, contact Amy French at 18
Amy.french@cityofpaloalto.org 19
20
[The Commission took up this item after Item Number 2.] 21
Chair Fine: On our final item for tonight. Let me get my bearings. So this is 2501 Embarcadero Way. 22
Request by Public Works for a site and design review of a new two-story 7,500 square foot, 50-foot tall 23
building designed to handle sludge dewatering and truck load-outs, you'll have to describe to us what 24
that all is, with adjacent standby diesel generator to be placed centrally on the Regional Water Control 25
Plant site and a new outdoor equipment area next to the existing incinerator. You all can read the rest. 26
Just give me one moment. So this is our chance to evaluate the Mitigated Negative Declarations in the 27
attached report and to judge the four findings necessary for the Record of Land Use Action. We can 28
recommend approve and/or changes to accomplish the objectives of the Comp Plan or the Municipal 29
Code in this. With that, I believe we have Amy French to kick off our staff report. 30
31
Amy French Chief Planning Official: Thank you, yes. Amy French, Chief Planning Official. This process 32
is, as you know, a Site and Design Review. It begins with the Planning and Transportation Commission. 33
It is followed by Architectural Review, and finally ends up with the Council. And all along the way, we 34
have a Mitigated Negative Declaration that has been prepared, circulated through the State clearinghouse 35
for comments. We've received several comments, and we are in the process of addressing those. Some 36
of the comments were attached to your staff report. We also received comments today at the close of 37
business from the same gentleman who commented prior to that. We did receive comments from one of 38
the Planning Commissioners, and we shared responses to those comments via an at-places memo. 39
40
I might just direct you to the PowerPoint. This gives, sets out the dates and the process that we're in. 41
So next step, again, we're hoping to get to the ARB on February 18th and, as we go, we're developing. 42
The applicant is here, Phil Bobel from the Public Works Department. They're getting further along with 43
their plans, with the details that the ARB had asked for. 44
45
Again, the State clearinghouse routing of the Mitigated Negative Declarations was a 30-day review 46
process. It was sent out to a number of State agencies, as you can see here. One of those is the 47
Caltrans Aeronautics Division. The first I'd heard of that. It's an oversight commission, division of 48
Caltrans for aeronautics, and we are within close proximity to the airport, within a 10,000-foot radius 49
there. You can see the map up on the screen is the Federal Aviation Administration's height restrictions 50
map. In the location, and I'll just bring the little arrow down here where the Regional Water Quality 51
Control Plant, specifically the center of the site where the proposed sludge facility is to be located. The 52
height restriction is between 129 feet and 154 feet, I believe, and the proposed stack, ventilation stack 53
ATTACHMENT F
City of Palo Alto Page 2
for the building is to reach a height of 65 feet. We do allow in our Code ventilation stacks to be upwards 1
of 15 feet above the height limit. In this case, the height limit is 50 feet, and the public facilities here is 2
just basically a summary of that. We have filed with the Federal Aviation Administration group their 45-3
day review form that we are going to be hearing back about, to confirm our analysis of the height with 4
respect to the proposed height. This also goes to the County's Airport Land Use Commission 5
representative to, for dialog there. Some issues that have come up on the Mitigated Negative Dec have 6
been about odor and noise. More recently, again, yesterday, today we received some email from an 7
interested party who can't be here tonight. 8
9
And the applicant's here from Public Works and their consultants have looked at these and have answers 10
for some of these things. I put them up on the screen here. Finally, the Public Works folks have 11
prepared some really good illustrations. One of them is at places showing a view of this, the proposed 12
sludge facility before and after. On the left, I'll hold this up, is an image of what you can see today from 13
the Byxbee Park, kind of the new area of Byxbee Park that's been hydro-seeded of late, and then to the 14
right you'll see the Cor-Ten steel, the kind of rust-colored building that is the proposed sludge facility, 15
dewatering facility on the right image. I'm going to go ahead and let Phil Bobel take over. He has quite 16
a presentation to give. So I'm going to load that up. 17
18
Phil Bobel, Public Works Assistant Director: Jamie Allen is our Plant Manager. Kathy from CH2M Hill is 19
here, our designer, and Padam, our Senior Engineer at the plant is here. So our staff is part of the Public 20
Works Department, and I'm going to ask Jamie just to, in the interest of time, I know you probably don't 21
want to go into a lot of detail here, so he's going to give you an overview of the project, then I'm going 22
to take back over and in a little more detail address the comments that we've had so far from, really the 23
comments that we've had are just from three folks, but they were good comments, and I think they're 24
worth spending most of the time on those. So Jamie. 25
26
James Allen, Water Quality Control Plant Manager: Jamie Allen, Plant Manager, Public Works. The 27
treatment plant treats about 18 million gallons a day for six communities, Palo Alto, Los Altos, Los Altos 28
Hills, Stanford, Mountain View and the East Palo Alto Sanitary District. It's located at the end of 29
Embarcadero Road. There's the picture. It's got the airport and the golf course to the north, the Byxbee 30
Park and the old landfill to the south, and the Baylands to the east and a saltwater marsh we helped 31
convert to the west. It's 25 acres, industrial complex full of tanks, pumps. About 70 people work at the 32
facility to keep it running 24/7. We create recycled water as well. 33
34
We've had the incinerators in this building right here since 1972. By the time we retire them in about 35
2018, 2019, they'll be 46, 47 years old, and the main reason we're replacing them is that they're at the 36
end of their life, and they're also the largest City facility greenhouse gas contributor because of the 37
natural gas that we need to burn the sludge and run the air pollution control equipment. So we're happy 38
to get rid of them, and this project is the key piece to do that. This is a schematic. I'm not going to go 39
into this. Phil's going to take over here. 40
41
Mr. Bobel: I just wanted to quickly make sure, thanks Jamie, that everybody realized that, and we 42
admitted to you, that the sewage treatment plant is kind of the big power user among the City facilities 43
currently, and there you can see it's 27 percent of municipal operations. And the incinerator is the lion's 44
share of the emissions from the sewage treatment plant. Not surprising to most of you, I'm sure. So 45
that's what our incinerator looks like. Like Jamie says, we are all going to be glad when it goes away. A 46
major greenhouse gas savings is going to be that we won't have to use natural gas any longer. And 47
here's our projection of what this is going to do for greenhouse gases. So you can see the red bars 48
marching toward 2014, that's the latest data point on this graph, actual data point, and we've, we think 49
we've done some good things, and we've managed to reduce, but it'll be phasing out this incinerator 50
that'll really give us the real jump here and get us down to that extreme right-hand small bar where 51
we've minimizing our greenhouse gases from the facility. So we're all very excited about that. I want to, 52
we just wanted to make sure we made the connection. That's why we're doing this thing, is to be able to 53
phase out the incinerator. 54
55
City of Palo Alto Page 3
So here's our long-term facility plan footprint. It shows that brown area as the replacement area where 1
we build the facilities that will ultimately completely replace the incinerator. The project before you 2
tonight is just the dewatering facility and the truck off-haul facility. So it's an interim step that we'll be 3
utilizing for several years, where we do away with the incinerator, we dewater the solids and we take 4
them to most likely another sewage treatment plant where they'd be digested, because it's going to take 5
us a long time to build the very expensive digesters that most sewage treatment plants have. So this is 6
step one, is our dewatering facility that you're considering tonight, and it'll be along with the digesters 7
themselves in that brown area. So you can see it's sort of central to the plant. I'm not going to go into 8
that. 9
10
So here's our new facility. It's that yellow-colored thing. It's a subset of that brown area I showed you 11
in that last slide. And it's, if you recall that earlier photo, aerial, it's in an open space now, so we don't 12
need to demolish anything to build this dewatering facility, and that's good because demolishing is major 13
cost, major delay and also has environmental impacts. So we're essentially building in an area where 14
there hasn't been anything. Now immediately to the left of that is our incinerator which will eventually 15
get demolished, but that's not part of this project, to demolish that building. We're going to discontinue 16
use of the incinerator, but it's a big building with a lot of equipment in it, and we'll figure out the best 17
way to take it down over time. So that's where this building is, and this is what it looks like. 18
19
And we did have a study session with the ARB. Some of them said, gosh, this is a handsome building 20
quote/unquote, from two of them, handsome building. And another one had a different view, and I'll get 21
to that in a second when we look at the specific angles. But there's Cor-Ten steel, that's the kind of rust-22
colored stuff, and then there's concrete which is what most of our buildings are currently. So those are 23
essentially the two finishes that you see there, concrete and Cor-Ten steel. 24
25
And here is the west elevation that you see when you come into the plant, you will see when you come 26
into the plant. The doorway on the extreme left is where the trucks will come through while we're still 27
having to take this to another sewage treatment plant until we get our own digesters built. That's where 28
the trucks will come through. And this is our best depiction of what the concrete will look like. You'll see 29
the 4x8 panels, so it'll give it some grid, some definition, and then you see the pieces of Cor-Ten steel as 30
well. And this is what it looks photo-shopped into our, if you were at the front gate of the building, of 31
our plant looking essentially eastward from the front gate, this is what it looks like. And we're still, and 32
this is when I said one of the ARB members had some other ideas and used the word missed 33
opportunity, so we're taking another look at this western exposure to see if there's, is there something 34
more interesting we can do with respect to that angle, and I don't know if you want to get into that 35
tonight. It's, I suppose, mostly an ARB thing, but know that that is a thing that we are looking at, 36
possibly another window, possibly deeper scores in the concrete to give it more interest, possibly the 37
planting of more material. 38
39
I'll just show you right next to this, this is one of our tanks where we just did public art and planted these 40
vines, and so actually my favorite thing to do differently with our new building is get some vines growing 41
up next to it. We've had some success there, and I, it's actually really pretty right there. We have a 42
planting plan. You're looking down on the building in the center, and again I suppose it's mostly an ARB 43
thing, so I wouldn't go over the details of that, but that's one of our existing buildings. Shows that we 44
already have this kind of look to the concrete and this is probably what we're going to try to recreate, is 45
something that looks like our existing concrete at the other buildings. So the east elevation is the thing 46
that points toward the old yacht harbor, if you can sort of get your bearings, the opposite side from that 47
west elevation I was just showing you. This is what it would look like, and if we didn't do any successful 48
planting, this is how it would like with the current planting that that's there. So there's quite a bit of 49
planting, but this is a 50-foot building, so you can see it sticking above the existing vegetation. And with 50
that planting plan that I just showed you, well I'm showing it to you again, the architect's depiction of 51
what it would look like in, I believe it's 20 years is that, that basically we'd get the growth up, essentially 52
hiding it. So the north elevation doesn't get seen really from off the site at all, so I won't focus on that, 53
but the architect has some interesting ideas there which we liked because we'd probably use the same 54
plant I just showed you because we have it in other places, but I personally like the idea of trying to get 55
more vines growing up against the building. There that is again. 56
City of Palo Alto Page 4
1
So here's the fourth elevation, the south elevation. And it points toward the Byxbee Park, the closed 2
landfill part of Byxbee Park, and it has a combination of Cor-Ten steel and concrete. So we were asked, 3
of course, everybody wants to know well what it’s going to look like from Byxbee Park. So Byxbee Park, 4
this is an old picture, but it's the gray area. That's our old landfill, the new Byxbee Park, and we showed 5
some different exposures looking toward the sewage treatment plant. One commenter, I think Herb is 6
still here. Herb said you didn't go to the highest point in the landfill. Why don't you do that and see 7
what it looks like? Good idea, and our attorney said yeah, that was a good idea, and in fact why don't 8
you show it with and without the building, so we've done that, not in time for this slide show, but that's 9
the thing that Amy was talking about here. So we went up to the top of the hill, re-took the picture, 10
photo-shopped in our new building, and this is what it looks like. You might say this looks like a very far 11
distance away. Why did you do that? Well, we, if you go up the hill, you get further and further from 12
the thing, and these are very small slopes, so the maximum elevation at Byxbee Park is only 60 feet, but 13
you have to go quite a ways, another 1,000 feet to get there. So it looks a good bit smaller, but from 14
that closer elevation, this is what it looks like, and so our building is the one to the left, the tall thing to 15
the left. The tall thing to the right is an existing building. And here it was photo-shopped in with, 16
showing the Cor-Ten steel and so that is one of the two that you, views that you see here. 17
18
And I would just come back and show you this, because we had the comment from one of your own that 19
it was hard to read the figures here. And as Amy just said, if you blow this up and look at it carefully, 20
you find that our new building is right about here. So it's kind of between this 154-foot level and the 21
129-foot level, so that's the maximum elevation that the FAA would allow us to build. Of course, we're 22
way under that, but just Amy did misspeak a little bit. This is all in terms of mean sea level, so the mean 23
sea level value for our stack is 75, 76 ... 24
25
Male: 76.5. 26
27
Mr. Bobel: ... 76.5 whereas the drawings in other places you'll see us referring to that stack as 65 feet. 28
That's the height from the ground level, from our first-floor level. 29
30
So those are all the slides we had, but let me just sum up the other major comments that we've gotten 31
and some thoughtful ones from Herb Borock that I wanted to addressed. He asks, well wait a minute, 32
what about hydrogen sulfide gas, ammonia, odors? We know these things come from sewage sludge as 33
it sort of anaerobically decays sitting there. So remember this isn't a new feature really. It's replacing 34
the dewatering facility that we already have. Currently we have belt presses dewatering, and then go to 35
the incinerator. What we're going to be doing in the future, these, this belt press facility is 45 years old, 36
so it needs to be replaced, but we still need a dewatering belt press operation because we need to 37
reduce that weight of the material before we try to truck it anywhere. So this is a replacement of our 38
existing dewatering facility is the way to think of it. And CH2M Hill, our consultant, has tried to estimate 39
what are those kind of odor and health-related pollutants that you would be concerned about. And the 40
main ones are the ones that Herb mentioned. It's hydrogen sulfide, ammonia and just odors in general. 41
So our best estimate, engineering estimate is that those will not be any different than our current 42
situation. I won’t go into a lot of details, because it's kind of complicated. Our current situation and then 43
this new situation are a little bit different, but the bottom line is that our best engineering estimate is 44
there's not going to be an increase. There may even be a decrease, I hope, but certainly not an 45
increase. So from a CEQA perspective, there's no increase in any of those emissions or odor. So we 46
misstep, we took a, made a misstatement in part of the MND which we'll correct so that it's clear that 47
there isn't an increase there. 48
49
The other thing that came up was greenhouse gases that I already addressed, and I won't go back 50
through that, but you saw that dramatic decrease in greenhouse gases and so several people raised 51
greenhouse gases. I think we have a tremendous story there that's really one of the major reasons we're 52
doing this project in addition to the incinerator being 45 years old. So greenhouse gases, great story. 53
And I think those are the major comments. I just wanted to make sure to mention them. 54
55
City of Palo Alto Page 5
Chair Fine: Thank you. Is that all from the staff presentation? Excellent. Thanks so much. I think we 1
have two speaker cards. Let's go for those. 2
3
Vice-Chair Gardias: So we have two speaker cards. We have Herb Borock, followed by Ken Gottfredson. 4
Please take five minutes. 5
6
Herb Borock: Thank you, Chair Fine and Commissioners. Staff has said that people are going to be very 7
happy when we get rid of the incinerators, and the plan is to replace it with anaerobic digester. In 8
October 1972 everyone was happy that we put in incinerators that replaced anaerobic digesters, and it 9
was the memory of those that are summarized in (inaudible) Long Range Facilities Plan for the plant that 10
indicated the odor problems and also the fact that there was a much larger volume of sludge that needed 11
to be trucked away compared to the volume of ash that is being trucked. Phil Bobel, I had a 12
conversation with him which he essentially summarized regarding the sludge loader, dewatering and 13
load-out facility, and then the dewatering part of it replacing the existing belt filter presses. And so I 14
would think that it would be worthwhile in the MND to write that instead of just treating the new sludge 15
dewatering as if it's being compared to an existing condition where there isn't anything else going on 16
which is the way it seems to go, and that would then lead to the conclusion that he stated. 17
18
In regard to the greenhouse gases, if you look at the planned components of each of them taking place 19
for the project, then you would be saying that the greenhouse gases, as I understand it, would be a big 20
reduction because of the incinerator going away, but it's possible that component 2 will never happen, 21
and that we would continue doing either trucking out as we would in the interim or having a different 22
process. And in that case, you would have going from a state where you would have had the reduction 23
due to the incinerators being removed, and then you would be making a choice as to what will be the 24
new process and that would then be having an increase in greenhouse gases. It wouldn't be anything 25
like we have now, as I understand it, but when the idea of putting in anaerobic digester or doing 26
something else, I believe, we would have to consider that, and that would get into the comments that I 27
had about the cumulative effect. 28
29
My only other comment at this point relates to the Record of Land Use Action at the last item which was 30
the term of approval. And it says that the site and design review is good for three years, and I thought 31
that section of the Code said it was two years, and that's easily checked in the Code. Thank you. 32
33
Vice-Chair Gardias: Thank you. Next speaker is Mr. Ken Gottfredson. 34
35
Ken Gottfredson: Hi. I'll try and make this real quick. I'm from the airport, and I have a flying club 36
there. I have about 500 members, and a couple dozen flight instructors. And our concern is when they 37
do the 45-day review, I know you're underneath the plane, but there are other things that affect the 38
airport. There's, there could be a TERPS review which would possibly change the approach that goes in 39
there for IFR traffic. There's just recently an increase on the minimums because of the tower that went 40
in over Shoreline, and that wasn't, had anything to do with any height restrictions, but it did change the 41
approach, and it raised it 100 feet. And so during this FAA review, I just wondered if a TERPS study was 42
going to be included in that. Secondly, I know, from the smokestack, I don't know if it, if there's, when 43
air rises and small planes are flying over the rising air, if that's going to create some kind of turbulence 44
that might affect especially for a student pilot, it might create some kind of turbulence or something like 45
that. So I was hoping those two things would be addressed in the study. That's it. 46
47
Vice-Chair Gardias: Thank you. 48
49
Chair Fine: Thank you very much to both our speakers. Those were helpful. I'd like to turn it over to 50
the Commission for a round of questions. The first light I see is Commissioner Downing. 51
52
Commissioner Downing: If I could ask a question. What is the expected lifespan of this facility, of this 53
particular building that you're building right now? 54
55
Ms. French: Fifty years. 56
City of Palo Alto Page 6
1
Mr. Bobel: The equipment inside the building will all (inaudible) 50 years, but this concrete thing 2
(inaudible). 3
4
Commissioner Downing: So the reason why I'm asking is because it does seem clear that you guys are 5
taking account for the floodplains, (inaudible) at the 100-year flood rise built into this building. But 6
where I am getting concerned is, I mean there's studies out there saying that in the next 50 years we 7
can expect the 10-foot sea level rise, and that it seems like the flood rising, the height you've added for 8
that wouldn't account for the sea level rise as well. So what's the plan for that? How is that addressed 9
or what's the approach to that today? 10
11
Mr. Bobel: That's a great question, and it's larger than our sewage treatment plant, as you probably 12
know. So we're also working on a sea level rise staff report that's going to address in a general way that 13
question of should we be doing more at our City facilities and private-sector facilities for that matter than 14
raising the levees. Should we be changing our Building Code requirements to make say electrical stuff be 15
at a higher elevation or certain kinds of rooms be higher than our current 10.5 number? We're not taking 16
a different approach for this building than the rest of the City is taking or the rest of the City facilities are 17
taking, but it's a good question. We know we need to address it in all of the Baylands. 18
19
Commissioner Downing: You know, I think my concern is that for a lot of other buildings in Palo Alto, if 20
they don't get hit with it, I mean the worst thing that's going to happen is they're going to flood, they're 21
not going to be useful. My concern is that with this particular facility, if you guys flood, that, all of that 22
sludge ends up in the Bay, and that's a contamination that isn't present with the rest of the buildings that 23
we could be concerned about. And so that's why I'm asking about that, because I find that concerning, 24
because that's 50 years of 10-foot rise. You guys are 6 feet up, so less than 50 years you will be facing 25
that problem, so that's why I'm kind of pushing on that issue. 26
27
Mr. Bobel: It's a bigger question, though, than this particular building, I understand, but we've got 25 28
acres of buildings, and we know we need to address Citywide, you may be particularly worried about the 29
sewage sludge. Other people are more worried about our communications operations at the Municipal 30
Service Center or our airport or, everybody has their own pet facility or operation. Probably the cheapest 31
thing for the sewage treatment, if the City doesn't end up taking action that applies to facilities in 32
general, the sewage treatment plant would probably come back in and put in large pumps that would 33
keep the Bay at bay. 34
35
Commissioner Downing: If I could. How would that work? Where would these pumps go? 36
37
Mr. Bobel: Well, first you need a dike. You need a containment facility which we're working on now. 38
We're working through the safer project, the JPA project to increase the size and the heft of the levees 39
and the so-called shoreline study which is the Corps' project to tie it into the rest of our partners. So 40
between those two studies, step one is to increase the height of the levees, and then if nothing else 41
changes, the best double protection for us would be to have a different pumping system internal to the 42
plant. 43
44
Chair Fine: Vice-Chair Gardias. 45
46
Vice-Chair Gardias: Thank you. We actually talk with Chairman about the public participation, and we 47
always find valuable comments of the public that attends our meeting, and we want them to come and 48
attend our meetings frequently. And Mr. Borock is one of the frequent participants, and we value his 49
questions, and we would like to ask you just to answer the or provide the comments to the questions or 50
to the comments that they provided. So I don't know if I need to just go through this, but Mr. Borock 51
was talking about, what I understand was pretty much the carbon footprint in terms of this, how the 52
operations were restructured. And then also there was a comment about the land use that was for three 53
years. It should have been two years. And then Mr. Gottfredson was talking about FAA review and also 54
potential turbulence. So if you could just please address their comments. 55
56
City of Palo Alto Page 7
Mr. Bobel: Now? 1
2
Vice-Chair Gardias: Yes, please. 3
4
Mr. Bobel: So to start with the airport-related comments. We've, we're in a dual process with yours that 5
the FAA runs, and they will decide whether, what's the name of that? TERPS, thank you. They will 6
decide whether to do a TERPS review or not. And so that's sort of out of our hands, but the FAA process, 7
they're, they've received what they need from us, and they're running that through their system now. 8
And so we'll know that before we start construction or approve construction contracts on that. 9
10
And then the second comment also good, is what about a heated air release. So currently we have an 11
incinerator. So currently we have a lot more heated air than we will under, with this facility. This facility 12
will actually be a dramatic decrease in heated air rising above the, this treatment plant. So this stack 13
that looks so ominous there is the, a way to just protect our employees mostly and get the inside air from 14
that building up and out. It's not heated. It's just the air inside the building being exhausted. There're 15
actually two stacks. One is much lower that, where there's actually are more contaminated air that goes 16
through a two-step treatment process and then is, is then discharged. But again, that's not heated air, 17
and it's a dramatic reduction in the temperature of the Air. So the FAA can look at that if they choose to, 18
but they'll very quickly realize that this is a big plus. If there was any problem with the current situation, 19
this will reduce it. 20
21
And then Herb's comments; so Herb talked about the carbon footprint, and I was trying to address that 22
with this greenhouse gas factsheet, because all of the things one could ask about the carbon footprint 23
are all rolled up into these two data points, the current and then the 2019. So we took into account the 24
truck traffic, the amount of trips that we currently make with ash, and the amount that we make in 2019 25
with the raw sludge. We took into account the actual emissions from this process, and this is the net 26
result. So like I say, we think we have a extremely good carbon footprint story to tell, and it's one of the 27
biggest reasons we're doing this project. 28
29
Now, Herb had some other comments too that you didn't, which I tried to address and you didn't just 30
restate them. So I won't go back through them, but he had some other pollutants that he was 31
concerned about, and I tried to address those as we were going through the slides. 32
33
Vice-Chair Gardias: And that's a error, I think it was just an error of three years as opposed two years. 34
Is this ... 35
36
Mr. Bobel: I don't know. What the three year versus two year? 37
38
Cara Silver, Senior Assistant City Attorney: The Code does specify a two-year term for this permit, so 39
construction needs to start within two years of issuance of the Council's approval. 40
41
Mr. Bobel: Okay. We want to kill that dead. We want to start within a few months. 42
43
Vice-Chair Gardias: So it's going to be corrected. Very good. Thank you. If you don't mind. Thanks 44
very much for all this. 45
46
Mr. Bobel: Yeah, we'll change those things. And Herb also, one of the reasons that he went down a 47
certain path with his comments is that he was triggered by a statement in our MND which needs to be 48
changed. So I agree with you wholeheartedly. It definitely helps to have Herb going through this stuff. 49
So we'll make the changes that he helped us realize need to be changed. 50
51
Vice-Chair Gardias: Thank you very much. We appreciate you just making these changes and 52
responding to his comments. So if you don't mind, just I am going to have couple of questions from my 53
side. So in terms of the truck traffic; so there is, currently there are no trucks, so there is going to be, 54
could you tell us how many, how, what, how frequent would be the traffic, how large, what are the risks, 55
City of Palo Alto Page 8
and some other issues related with these trucking operations, the hours of the, of moving the sludge and 1
so forth? 2
3
Mr. Allen: At build out, it's up to five trucks a day. We'll probably start out with three, maybe four. And 4
that hauling contract which we'll bring to Council, we're going to look for a lot of operational flexibility so 5
that we have options to take it to various different treatment plants, but we'll be working that out in the 6
future. Right now we do one truck a week, the ash. So it's a 20:1 volume reduction using an incinerator, 7
so we do currently one ash haul-out a week. This will be for starters about 20 haul-outs a week let's say. 8
9
Mr. Bobel: The thing to know is the, one reason I'm personally excited about this project is we're 10
currently hauling the ash, sorry. We're currently hauling the ash to Beatty, Nevada, right Jamie? 11
12
Mr. Allen: We take it to a hazardous waste landfill because it's hazardous waste. 13
14
Mr. Bobel: And I forget how many miles that is, 300 approximately, I think. And so we're talking about 15
although three to five truck trips a day, I hope it can be to our neighboring Redwood City sewage 16
treatment plant which is only 20, 25 miles a day. So that's why when you do all the math on these truck 17
trips, you don't see a increase from this. 18
19
Vice-Chair Gardias: And then those trucks, I mean what's, I mean they will be loaded and leaving at 20
different, various times, because probably loading is going to take a while. 21
22
Mr. Allen: Loading is 10 to 15 minutes. 23
24
Vice-Chair Gardias: So but they will be ... 25
26
Mr. Allen: They might prefer off rush hour times, but they may, based on where they're taking it, they 27
may prefer daytime hours. So we're looking for maintaining flexibility when we set up that contract. 28
29
Vice-Chair Gardias: And what sort of trucks those are? Those are like lorries with open beds or what's ... 30
31
Mr. Allen: They're 40-foot long semis with roll, the bins that, the truck goes up so the sludge can slide 32
out the back, wherever they're going. 33
34
Vice-Chair Gardias: It's like gravel, right? 35
36
Mr. Allen: Right. 37
38
Vice-Chair Gardias: So I hope there is no risk of spilling the sludge or, because there is sometimes, and 39
gravel can spill on the motorway and puncture people's windshields. I don't think this would puncture 40
anybody's windshield, but the effect may be not pleasant. 41
42
Mr. Bobel: We haven't lost any ash yet, which is what we're currently hauling. 43
44
Vice-Chair Gardias: Thank you. So I have different comment about the structure itself which goes 45
beyond the purview, but out of curiosity. So there is, on the second floor, there is this perforated 46
weathering steel screen wall, and you provided sample of this. What is the purpose of this wall besides 47
screening? Does this have any physical use or is it just a decoration? 48
49
Mr. Allen: Yeah, it's just screening, an aesthetic value in screening of the equipment. 50
51
Vice-Chair Gardias: And the last comment is maybe from a different angle. So are you planning to open 52
this facility to public, to schools for I'll say educational facility? 53
54
Mr. Bobel: Jamie and I always disagree on this one. Go ahead, Jamie. 55
56
City of Palo Alto Page 9
Mr. Allen: Due to the industrial nature, it's not, it's only for authorized personnel, but people will be able 1
to walk around the outside of the building. 2
3
Mr. Bobel: We currently have school groups that tour the facility. We won't take them in this particular 4
building. It won't be too interesting to them anyway. 5
6
Vice-Chair Gardias: But they can see our (inaudible), they can see the basis, how this ... 7
8
Mr. Bobel: Yeah. They can see this building from the outside, and we'll have, we'll enhance and redo 9
our outreach materials so that they can see what is going on inside. 10
11
Vice-Chair Gardias: And the last question that's also not related. It's just a, there was on the edges of 12
the lot, there seem to be some unused land. Are you planning maybe just release this land for the public 13
in the future? It's like on the north end. 14
15
Mr. Allen: A lot of the perimeter areas are trees that screen the plant, screen the treatment plant so that 16
when people are using the Baylands or Byxbee Park, we are not intruding upon the visual space of the 17
Baylands. So we, if we were to lease it, we'd pretty much have to clear it and then it becomes an issue 18
of aesthetics in the park. 19
20
Mr. Bobel: Were you thinking of some of these areas where ... 21
22
Vice-Chair Gardias: That's right, on the left side. 23
24
Mr. Bobel: The left side? 25
26
Vice-Chair Gardias: Yeah. 27
28
Mr. Bobel: We'd have a lot of disappointed people if we tried to take some of those trees down, but that 29
is an option for some of our facilities, is to thin out or make that buffer smaller on Embarcadero Road 30
side. So we're considering that, but we're trying as hard as we can to keep stuff in the center of the 31
plant and keep all the vegetation that we can. 32
33
Vice-Chair Gardias: Because it's just, I know this is a different story. But there is a, for Greg Schmid and 34
myself, that we run 5 kilometers, 5,000, so there is this nice waving path that goes along your fence, and 35
then when you hit the road, then pretty much there is just a straight sidewalk, so it would be nice to 36
continue this farther along. 37
38
Mr. Bobel: Along Embarcadero Way? 39
40
Vice-Chair Gardias: That's right, Embarcadero Road. 41
42
Mr. Allen: That's the new landscaping project, Phil, where we put in a wavy path in the northern end of 43
the property. It ties in with the bike path. 44
45
Mr. Bobel: Have we done something that's prevented you from, I'm not following you exactly. 46
47
Vice-Chair Gardias: That's, the first part of this pathway is very welcoming. 48
49
Mr. Bobel: I see. 50
51
Vice-Chair Gardias: The second path, it's not, it looks like this, it's just a straight path, so it's not as nice 52
as the first portion. 53
54
Mr. Allen: Are you talking about that commercial building at the northwest corner? 55
56
City of Palo Alto Page 10
Vice-Chair Gardias: I'm talking about that portion from the incinerator building to the lower left corner. 1
2
Mr. Bobel: Maybe you can show us after ... 3
4
Vice-Chair Gardias: I will show you later. It's out of scope. 5
6
Mr. Bobel: We want to enhance all those trails around there. The current area where we're sort of 7
challenged is on the right-hand side of this. We have a complication of it being the so-called Measure E 8
site, and we're still finishing the capping on the landfill over on the right side of that drawing. So you'll 9
see an improvement there, and you'll be able to jog more successfully around that side soon. 10
11
Vice-Chair Gardias: Great. Thank you. 12
13
Chair Fine: Commissioner Tanaka. 14
15
Commissioner Tanaka: One quick question, and then I'd like to make a motion. So the quick question is, 16
so I guess in 1970 we had an aerobic digester, right? 17
18
Mr. Bobel: Nineteen what? 19
20
Commissioner Tanaka: Around 1970, a long time ago. 21
22
Mr. Bobel: Yeah. 23
24
Mr. Allen: We had an aerobic digester from 1934 to 1972. In the 1960s, the EPA said you cannot use 25
digesters anymore, because the electronics industry, heavy metals were disrupting the biological process, 26
and so the, that's what Herb mentioned. We had odors in the sludge that was being dewatered out 27
where the current landfill is. And so the digester didn't work, so we put in incinerators. Of course, since 28
then the metals have been removed from the sewage, and it would work if we put in digesters now. But 29
that's why we went with incineration at that time. 30
31
Commissioner Tanaka: So all the problems have been solved then. It will actually work now. 32
33
Mr. Bobel: Yeah, we're going full circle here. 34
35
MOTION 36
37
Commissioner Tanaka: I'd like to make recommendation, I'm sorry, a motion that, yeah, that we 38
recommend approval to the City Council. Here it is. We recommend approval of the Mitigated Negative 39
Declaration and the site and design review application for the sludge dewatering and load-out facility at 40
the Regional Water Quality Control Plant. 41
42
SECOND 43
44
Commissioner Alcheck: Second. 45
46
Chair Fine: Thank you, Commissioner Tanaka and Commissioner Alcheck. We have a motion on the 47
floor. I'll restate it in a little bit. I still have a few lights that I want to go through. I think next was 48
Commissioner Rosenblum. 49
50
Commissioner Rosenblum: My question was about the truck traffic, which was just addressed by 51
Commissioner Gardias. I have no other questions. 52
53
Chair Fine: My next light is Commissioner Alcheck. 54
55
Commissioner Alcheck: I yield (inaudible). 56
City of Palo Alto Page 11
1
Chair Fine: Commissioner Waldfogel. 2
3
Commissioner Waldfogel: Thank you. I think this is an important project, and we need to get it done. 4
I've been watching this for several years, and it's kind of, it's exciting to see the progress. But I think the 5
thing we, one thing we have to keep in mind is that now the airport is our City facility, and we don't want 6
to do anything that affects the evolving business plan for the airport. And in fact we have the option 7
under State law to, and Federal law, to set lower height limits or even to provide what's called a 8
navigation easement over the treatment plant to ensure aviation uses in that area. And as we know, 9
even the landscaping is a potential issue. The problem I have right now is that we didn't start the FAA 10
work until this week literally. And we know, we heard from of Mr. Gottfredson that obstructions that are 11
even under this FAR Part 77 surface can affect the instrument approach. They can affect aviation 12
operations. We haven't heard any analysis about whether construction will affect airport operations, 13
whether the approach will be taken out of service for certain days during construction because of crane 14
obstructions or other issues. And all these things affect the airport's business model, and so it's really 15
hard for me to support this today until we finish that work. So I guess one question is how long is it until 16
we finish that work, 'til we do a business model, a business impact analysis on the airport, 'til we 17
understand whether or not just if this meets the, this basic FAR Part 77, but if there are additional 18
impacts on air space. You know, that's not a question that I think anybody in this room can answer as of 19
this second, so when do we, when will we know the answers? 20
21
Mr. Bobel: As you probably know, the FAA says that their timeframe is a minimum of 45 days. And 22
you're right, we didn't start the process as soon as we should have. However, as a practical matter, 23
we're not anticipating any problems. We've talked to our Airport Manager, Andy Swanson. I've asked 24
him your question about the business plan. He doesn't envision modifying the business plan or, I'm just 25
not seeing how it would impact the business plan of the airport. So ... 26
27
Commissioner Waldfogel: But have we analyzed that? 28
29
Mr. Bobel: Huh? 30
31
Commissioner Waldfogel: Do we have any analysis? 32
33
Mr. Bobel: Of the business plan for the airport? 34
35
Commissioner Waldfogel: Do we have any analysis whether this, I mean since we don't know the impact 36
on airspace, do we know whether there's any impact on the airport or can we just commit that if there is 37
impact that we'll modify this project? 38
39
Mr. Bobel: I think we could commit to that, because there's so little likelihood. I mean, you've seen the 40
photographs. This is, just becomes one of many buildings at our sewage treatment plant that are of that 41
same ilk. As far as the cranes go, we submit the FAA form when we bring a new crane onsite already. 42
We had a 120-foot crane out there earlier this year, as you may know, and that's far taller than any of 43
our buildings. And so we're used to working with the airport on cranes. And will there be tall cranes out 44
there during construction? Yes. Have we had them out there many months out of the year? Yes, we 45
have cranes out there all the time, and we work with the FAA to alert them of that. So I just don't 46
foresee a problem. I mean, we, they didn't have a problem with our 120-foot crane. I can't imagine 47
they're going to have a problem with ... 48
49
Commissioner Waldfogel: You're actually, you're, I think that's a misleading response, because what the 50
FAA does with that filing is they will shut down a piece of airspace. I mean, if you say I'm putting a 51
temporary crane into an airspace, they issue a notice that says I'm shutting down something. So that is 52
a slightly misleading response. Until we talk, the tower manager isn't here, the Airport Manager isn't 53
here. We don't really know what we're talking about. 54
55
Mr. Bobel: The Airport Manager has said he doesn't anticipate any problems. I can tell you that. 56
City of Palo Alto Page 12
1
Male: Could I just say one thing (inaudible)? The Airport Manager isn't an expert on TERPS, and so he 2
isn't qualified to make (crosstalk). 3
4
Chair Fine: Let's keep public comment to public comments please. Thank you. 5
6
Mr. Allen: One thing the airport staff said is that the local staff do not make the determination of air 7
traffic safety. So asking us to make the determination of air safety isn't something that we do. But from 8
our analysis, we are below the obstruction height by 50 feet for our stack. And so we had to notify the 9
FAA because we were within a one-to-fifty surface within 10,000 feet of the end of the runway. That 10
triggers a notification requirement. Just because we notified the FAA doesn't mean that we created an 11
unsafe condition. So they, we had to submit this within 45 days before the start of construction which is, 12
it was submitted in time. We were not going to start construction within 45 days, and their review takes 13
30 to 90 days, but we're, like we said we're not anticipating any issues with the FAA. And Caltrans 14
Aeronautics has already reviewed the CEQA through the State clearinghouse, and they had no comment. 15
16
VOTE 17
18
Chair Fine: Thank you very much. I think we can all acknowledge the FAA will overrule any of us. With 19
that, I don't see any other lights. Shall we put this to a vote? So the motion as it stands is that we are 20
moving to recommend approval of the draft Mitigated Negative Declaration and approve the site and 21
design review application necessary for the Record of Land Use Action. Does that state (inaudible)? All 22
those in favor. All those against. One against. Thank you all so much. This item is closed. 23
24
MOTION PASSED 25
26
Commission Action: Commissioner Tanaka moved to approve staff recommendations, second by 27
Commissioner Alcheck. Passed 6-1 with Commissioner Waldfogel dissenting. 28
I. DESCRIPTION OF PROJECT
Date: December 15, 2015
Project Name: Palo Alto Regional Water Quality
Control Plant Sludge Dewatering and
Loadout Facility
Application Nos.: Not Applicable
Address of Project: 2501 Embarcadero Way
Assessor’s Parcel Numbers: 008-03-029
Applicant: City of Palo Alto Regional Water
Quality Control Plant
Owner: City of Palo Alto
250 Hamilton Avenue, 5th Floor
Palo Alto, CA 94301
Project Description and Location:
The proposed project would include the construction and operation of a sludge dewatering and truck loadout
facility at the Palo Alto Regional Water Quality Control Plant (RWQCP). The City’s vision for future biosolids
management encompasses the need to address the RWQCP’s aging solids handling infrastructure, to proactively
comply with changing and uncertain regulations affecting biosolids, and to respond to community goals to
increase the beneficial use of recovered organic resources city-wide. To respond to this, the City developed a
Biosolids Facility Plan (BFP) that provides a long-term roadmap to enable the City to reliably and sustainably
manage and beneficially reuse the wastewater solids produced at the RWQCP through year 2045. The BFP was
developed as a companion document to the City of Palo Alto Long Range Facilities Plan for the Regional Water
Quality Control Plant Final Report (LRFP). The BFP builds on the LRFP, allowing solids processing
recommendations in the BFP to move forward in concert with other planned improvements at the RWQCP (as
defined in the LRFP). Together, the two documents provide a comprehensive long-term plan for the RWQCP.
The proposed project analyzed in this document is the dewatering and loadout facility, also known as
Component 1 of the BFP. The dewatering and loadout facility would have independent utility as a backup
sludge dewatering and haul off facility that can be used long-term even if additional BFP components are not
built.
The proposed project includes the construction of a new building to accommodate the installation of four belt
filter presses. The project also includes mechanisms to convey the resulting cake from the belt filter presses to
three storage bins, and to load the cake from the bins into trucks. These activities would occur within the new
ATTACHMENT G
dewatering and truck loadout facility building. The new building would be a two story, cast‐in‐place concrete
structure that would contain space for the belt filter presses, truck loadout, and other miscellaneous support
areas. The facility would have a building footprint of approximately 7,500 square feet and a building height of
50 feet. The facility would include a robust system for odor control. The roof would include removable
skylights over the BFPs for the purpose of facilitating future removal/replacement. These skylights would also
provide light into the room, reducing the need for electric lights during the daytime. Various minor
modifications to the yard piping system would be needed in order to accommodate the new facility. In addition
to the dewatering and truck loadout facility itself, a standby diesel engine generator will be installed to provide
backup. The generator is sized to handle the load for the facility as well as other nearby facilities. Fuel storage
will be provided by means of a sub‐base fuel tank.
II. DETERMINATION
In accordance with the City of Palo Alto’s procedures for compliance with the California Environmental
Quality Act (CEQA), the City has conducted an Initial Study to determine whether the proposed project could
have a significant effect on the environment. On the basis of that study, the City makes the following
determination:
________
The proposed project COULD NOT have a significant effect on the environment, and a
NEGATIVE DECLARATION is hereby adopted.
___X____
Although the project, as proposed, could have a significant effect on the environment,
there will not be a significant effect on the environment in this case because mitigation
measures have been added to the project and, therefore, a MITIGATED NEGATIVE
DECLARATION is hereby adopted.
The initial study prepared for this project described above incorporates all relevant information
regarding the potential environmental effects of the project and confirms the determination that an EIR
is not required for the project. The following describes the areas of analysis and any mitigation measures
incorporated into the proposed project in accordance with CEQA:
A. AESTHETICS. The project will not have a significant impact on aesthetics or visual resources, therefore no
mitigation is required.
B. AGRICULTURAL RESOURCES. The project will not have a significant impact on agricultural resources,
therefore no mitigation is required.
C. AIR QUALITY. The project will not have a significant impact on air quality, therefore no mitigation is
required.
D. BIOLOGICAL RESOURCES.
Impact BIO (a): The proposed project may have a substantial adverse effect, either directly or through
habitat modifications, on any species identified as candidate, sensitive, or special-status species.
Avoidance Measures for Special-Status Wildlife Species. The proposed project includes the following
avoidance and minimization measures to reduce impacts on species covered by the MBTA during construction
to a less-than-significant level:
Pre-construction nesting surveys will be conducted before undertaking work during the nesting season
(February through August). Any nest found within 50 feet for songbirds and 300 feet for raptors will be
avoided, and a designated construction-free buffer zone will be established until the nests are no longer
active.
Biological monitoring of work activities for active bird nests found during the nesting season will be
conducted by a qualified biologist.
A qualified biologist will conduct onsite informational meetings with all construction personnel before
construction begins. The purpose of these training sessions will be to familiarize construction personnel
with the procedures regarding nesting birds they are to follow if they are encountered.
E. CULTURAL RESOURCES. The project will not have a significant impact on cultural resources, therefore
no mitigation is required.
F. GEOLOGY, SOILS, AND SEISMICITY. The project will not have a significant impact on geology, soils,
and seismicity, therefore no mitigation is required.
G. GREENHOUSE GAS EMISSIONS. The project will not have a significant impact on greenhouse gas
emissions, therefore no mitigation is required.
H. HAZARDS AND HAZARDOUS MATERIALS. The project will not have a significant impact on hazards
and hazardous materials, therefore no mitigation is required.
I. HYDROLOGY AND WATER QUALITY. The project will not have a significant impact on hydrology and
water quality, therefore no mitigation is required.
J. LAND USE AND PLANNING. The project will not have a significant impact on land use and planning,
therefore no mitigation is required.
K. MINERAL RESOURCES. The project will not have a significant impact on mineral resources, therefore
no mitigation is required.
L. NOISE. The project will not have a significant impact on noise, therefore no mitigation is required.
M. POPULATION AND HOUSING. The project will not have a significant impact on population and
housing, therefore no mitigation is required.
N. PUBLIC SERVICES. The project will not have a significant impact on public services, therefore no
mitigation is required.
O. RECREATION. The project will not have a significant impact on recreation, therefore no mitigation is
required.
P. TRANSPORTATION AND TRAFFIC. The project will not have a significant impact on transportation
and traffic, therefore no mitigation is required.
Q. UTILITIES AND SERVICE SYSTEMS. The project will not have a significant impact on utilities and
service systems, therefore no mitigation is required.
R. MANDATORY FINDINGS OF SIGNIFICANCE. As indicated throughout this Initial Study, impacts on
all environmental resources were deemed to result in either ‘no impact,’ a ‘less-than-significant impact,’ or ‘less
than significant with mitigation incorporation.’ As a result, the project with proposed mitigation measures
would not create environmental effects that would degrade the quality of the environment, substantially reduce
the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels,
threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or
endangered plant or animal community, or eliminate important examples of major periods of California history
or prehistory.
PUBLIC REVIEW PERIOD
The public review period begins on December 15, 2015 and ends on January 13, 2016. Comments on the Draft
Mitigated Negative Declaration may be submitted to:
Amy French, Chief Planning Official
City of Palo Alto
250 Hamilton Avenue, 5th Floor
Palo Alto, CA 94301
_______________________________ _________________________
Project Planner Date
INITIAL STUDY
Palo Alto Regional Water Quality
Control Plant Sludge Dewatering and
Loadout Facility Project
Prepared for
City of Palo Alto
250 Hamilton Ave, 5th Floor
Palo Alto, CA 94301
December 2015
2485 Natomas Park Drive
Suite 600
Sacramento, CA 95833
Contents
Section Page
Acronyms and Abbreviations .............................................................................................................. v
1. Background Information ..................................................................................................... 1-1
1.1 Project Title ...................................................................................................................... 1-1
1.2 Lead Agency Name and Address ...................................................................................... 1-1
1.3 Lead Agency Contact Person and Phone Number ........................................................... 1-1
1.4 Project Location ............................................................................................................... 1-1
1.5 Project Sponsor’s Name and Address .............................................................................. 1-1
1.6 General Plan Designation ................................................................................................. 1-1
1.7 Zoning .............................................................................................................................. 1-1
1.8 Background and Description of the Project ..................................................................... 1-1
1.8.1 Project Features .................................................................................................. 1-2
1.8.2 Project Construction ........................................................................................... 1-2
1.8.3 Operations and Maintenance ............................................................................. 1-3
1.8.4 Permits and Approvals ........................................................................................ 1-3
2. Environmental Determination ............................................................................................. 2-1
2.1 Environmental Factors Potentially Affected .................................................................... 2-1
2.2 Determination .................................................................................................................. 2-1
3. Evaluation of Environmental Impacts .................................................................................. 3-1
3.1 Aesthetics ......................................................................................................................... 3-1
3.1.1 Setting ................................................................................................................. 3-1
3.1.2 Impact Analysis ................................................................................................... 3-1
3.2 Agriculture and Forest Resources .................................................................................... 3-2
3.2.1 Setting ................................................................................................................. 3-2
3.2.2 Impact Analysis ................................................................................................... 3-3
3.3 Air Quality ........................................................................................................................ 3-3
3.3.1 Setting ................................................................................................................. 3-4
3.3.2 Impact Analysis ................................................................................................... 3-4
3.4 Biological Resources ........................................................................................................ 3-7
3.4.1 Setting ................................................................................................................. 3-8
3.4.2 Impact Analysis ................................................................................................... 3-9
3.5 Cultural Resources ......................................................................................................... 3-11
3.5.1 Setting ............................................................................................................... 3-11
3.5.2 Impact Analysis ................................................................................................. 3-12
3.6 Geology and Soils ........................................................................................................... 3-13
3.6.1 Setting ............................................................................................................... 3-13
3.6.2 Impact Analysis ................................................................................................. 3-13
3.7 Greenhouse Gas Emissions ............................................................................................ 3-15
3.7.1 Setting ............................................................................................................... 3-15
3.7.2 Impact Analysis ................................................................................................. 3-16
3.8 Hazards and Hazardous Materials ................................................................................. 3-17
3.8.1 Setting ............................................................................................................... 3-17
3.8.2 Impact Analysis ................................................................................................. 3-18
3.9 Hydrology and Water Quality ........................................................................................ 3-19
3.9.1 Setting ............................................................................................................... 3-20
EN0717151040SAC/658394 (ISMND_ADMINDRAFT) iii
CONTENTS
Section Page
3.9.2 Impact Analysis ................................................................................................. 3-20
3.10 Land Use and Planning ................................................................................................... 3-22
3.10.1 Setting ............................................................................................................... 3-22
3.10.2 Impact Analysis ................................................................................................. 3-22
3.11 Mineral Resources ......................................................................................................... 3-23
3.11.1 Setting ............................................................................................................... 3-23
3.11.2 Impact Analysis ................................................................................................. 3-23
3.12 Noise .............................................................................................................................. 3-24
3.12.1 Setting ............................................................................................................... 3-24
3.12.2 Impact Analysis ................................................................................................. 3-24
3.13 Population and Housing ................................................................................................. 3-25
3.13.1 Setting ............................................................................................................... 3-26
3.13.2 Impact Analysis ................................................................................................. 3-26
3.14 Public Services................................................................................................................ 3-26
3.14.1 Setting ............................................................................................................... 3-26
3.14.2 Impact Analysis ................................................................................................. 3-27
3.15 Recreation ...................................................................................................................... 3-27
3.15.1 Setting ............................................................................................................... 3-27
3.15.2 Impact Analysis ................................................................................................. 3-28
3.16 Transportation/Traffic ................................................................................................... 3-28
3.16.1 Setting ............................................................................................................... 3-28
3.16.2 Impact Analysis ................................................................................................. 3-29
3.17 Utilities and Service Systems ......................................................................................... 3-30
3.17.1 Setting ............................................................................................................... 3-30
3.17.2 Impact Analysis ................................................................................................. 3-30
3.18 Mandatory Findings of Significance ............................................................................... 3-32
4. List of Preparers .................................................................................................................. 4-1
4.1 CH2M HILL ........................................................................................................................ 4-1
5. References .......................................................................................................................... 5-1
Appendix
A Air Quality and Greenhouse Gas Emissions Output Files
Tables
1 Project Construction Emissions and Comparisons to 2010 Baaqmd CEQA Thresholds
2 Project Construction Greenhouse Gas Emissions
Figure
1 Project Location
2 Site Plan
3 Architectural Elevations
iv EN0717151040SAC/658394 (ISMND_ADMINDRAFT)
Acronyms and Abbreviations
ADC alternative daily cover
BAAQMD Bay Area Air Quality Management District
BFP Biosolids Facility Plan
BMP best management practice
CalEEMod California Emissions Estimator Model
CalRecycle California Department of Resources Recycling and Recovery
CAPCOA California Air Pollution Control Officers Association
CDFW California Department of Fish and Wildlife
CEQA California Environmental Quality Act
CFC California Fire Code
CFR Code of Federal Regulations
CGP Construction General Permit
CH4 methane
City City of Palo Alto
CO carbon monoxide
CO2 carbon dioxide
CWA Clean Water Act
dBA a-weighted decibels
DMG Division of Mines and Geology
DOC California Department of Conservation
FEMA Federal Emergency Management Agency
GHG greenhouse gas
IS Initial Study
LRFP City of Palo Alto Long Range Facilities Plan for the Regional Water Quality
Control Plant Final Report
MGD million gallons per day
MBTA Migratory Bird Treaty Act
N2O nitrous oxide
NOx oxides of nitrogen
NPDES National Pollutant Discharge Elimination System
O3 ozone
OHWM ordinary high water mark
PC Planned Community
EN0717151040SAC/658394 (ISMND_ADMINDRAFT) v
ACRONYMS AND ABBREVIATIONS
PF Public Facilities
PM2.5 particulate matter with aerodynamic diameter equal to or less than 2.5 microns
PM10 particulate matter with aerodynamic diameter equal to or less than 10 microns
proposed project sludge dewatering and loadout facility project
PRC Public Resources Code
ROG reactive organic gases
ROLM(E) Research, Office and Limited Manufacturing Subdistrict - Embarcadero
RWQCP Regional Water Quality Control Plant
SFBRWQCB San Francisco Bay Regional Water Quality Control Board
SOx sulfur oxide
SRA Shaded Riverine Aquatic (type of habitat)
SWPPP stormwater pollution prevention plan
USACE U.S. Army Corps of Engineers
USEPA U.S. Environmental Protection Agency
USFWS U.S. Fish and Wildlife Service
WDR waste discharge requirements
vi EN0717151040SAC/658394 (ISMND_ADMINDRAFT)
SECTION 1
Background Information
1.1 Project Title
Palo Alto Regional Water Quality Control Plant Sludge Dewatering and Loadout Facility Project
1.2 Lead Agency Name and Address
City of Palo Alto
250 Hamilton Avenue, 5th Floor
Palo Alto, CA 94301
1.3 Lead Agency Contact Person and Phone Number
Amy French, AICP
Chief Planning Official
City of Palo Alto
(650) 329-2336
1.4 Project Location
The project is located within the existing Regional Water Quality Control Plant (RWQCP), which is
located in Palo Alto at the southern end of the San Francisco Bay in Santa Clara County, California.
Access to the site is via U.S. Highway 101, and Embarcadero Rd, approximate latitude/longitude
37°27’8.39”N/ 122° 6’40.47”W. See Figure 1.
1.5 Project Sponsor’s Name and Address
Mr. Padmakar M. Chaobal, P.E.
City of Palo Alto Regional Water Quality Control Plant
2501 Embarcadero Way
Palo Alto, CA 94303
1.6 General Plan Designation
The Palo Alto Comprehensive Plan 1998-2010 (updated June 2014) designates the project site as Major
Institution/Special Facilities. This land use designation allows for institutional, academic, governmental,
and community service uses and lands that are either publicly owned or operated as non-profit
organizations.
1.7 Zoning
The project site is zoned as Public Facilities with a site and design review overlay, PF (D).
1.8 Background and Description of the Project
This Initial Study (IS) is being prepared by the City of Palo Alto (City) to identify and analyze the
anticipated environmental impacts of the proposed sludge dewatering and loadout facility project
(proposed project) in Palo Alto, California. The proposed project would include the construction and
EN0717151040SAC/658394 (ISMND_ADMINDRAFT) 1-1
SECTION 1 – BACKGROUND INFORMATION
operation of a sludge dewatering and truck loadout facility at the Palo Alto Regional Water Quality
Control Plant (RWQCP). The City has prepared this IS as lead agency to comply with the California
Environmental Quality Act (CEQA). This document also identifies Standard Project Conditions and
mitigation measures that would be implemented to reduce project impacts to a less than significant
level.
The City of Palo Alto has operated the RWQCP for more than 80 years. Originally constructed in 1934,
the RWQCP is an advanced treatment facility that provides treatment and disposal of wastewater for
the cities of Palo Alto, Mountain View, and Los Altos; the Town of Los Altos Hills; the East Palo Alto
Sanitary District; and Stanford University. The RWQCP has undergone several expansions and upgrades
throughout the years and currently has a designed average dry weather flow capacity of 39 million
gallons per day (MGD) and a current average flow of about 18 MGD. The RWQCP effluent is partly
discharged to the San Francisco Bay, and partly diverted to the RWQCP recycled water facility for reuse.
The City’s vision for future biosolids management encompasses the need to address the RWQCP’s aging
solids handling infrastructure, to proactively comply with changing and uncertain regulations affecting
biosolids, and to respond to community goals to increase the beneficial use of recovered organic
resources city-wide. To respond to this, the City developed a Biosolids Facility Plan (BFP) that provides a
long-term roadmap to enable the City to reliably and sustainably manage and beneficially reuse the
wastewater solids produced at the RWQCP through year 2045. The BFP was developed as a companion
document to the City of Palo Alto Long Range Facilities Plan for the Regional Water Quality Control Plant
Final Report (LRFP) (Carollo Engineers, 2012). The BFP builds on the LRFP, allowing solids processing
recommendations in the BFP to move forward in concert with other planned improvements at the
RWQCP (as defined in the LRFP). Together, the two documents provide a comprehensive long-term plan
for the RWQCP. The project analyzed in this is the dewatering and loadout facility, also known as
Component 1 of the BFP. The dewatering and loadout facility would have independent utility as a
backup sludge dewatering and haul off facility that can be used long-term even if additional BFP
components are not built.
1.8.1 Project Features
The proposed project includes the construction of a new building to accommodate the installation of
four belt filter presses. The project also includes mechanisms to convey the resulting cake from the belt
filter presses to three storage bins, and to load the cake from the bins into trucks. These activities would
occur within the new dewatering and truck loadout facility building. The new building would be a two
story, cast-in-place concrete structure that would contain space for the belt filter presses, truck loadout,
and other miscellaneous support areas. The facility would have a building footprint of approximately
7,500 square feet and a building height of 50 feet. The facility would include a robust system for odor
control. The roof would include removable skylights over the belt filter presses for the purpose of
facilitating future removal/ replacement. These skylights would also provide light into the room, reducing
the need for electric lights during the daytime. Various minor modifications to the yard piping system
would be needed in order to accommodate the new facility. The location of the new dewatering and
loadout facility within the existing RWQCP is shown on Figure 2. Building elevation drawings are shown
on Figure 3.
In addition to the dewatering and truck loadout facility itself, a standby diesel engine generator will be
installed to provide backup. The generator is sized to handle the load for the facility as well as other
nearby facilities. Fuel storage will be provided by means of a sub-base fuel tank.
1.8.2 Project Construction
The sludge dewatering and loadout facility would be constructed over a period of approximately
24 months, beginning in April 2016 and continuing through Spring 2018. Project construction would
1-2 EN0717151040SAC/658394 (ISMND_ADMINDRAFT)
SECTION 1 – BACKGROUND INFORMATION
consist of site preparation and minor demolition activities; building construction; and equipment
installation, startup, and testing. Most of the construction activities would occur during building
construction, which would include modifications to nearby yard piping. Construction access would be
from Embarcadero Way, and is expected to average 10 vehicles per day (counted as 20 trips per day)
over the construction period.
1.8.3 Operations and Maintenance
The dewatering and truck loadout facility is part of the RWQCP solids processing system. The belt filter
presses are large machines that use physical pressure to separate solids from the liquid waste stream
(i.e., dewatering). All dewatering activities will occur within the new building, effectively isolating the
continuous machinery operations from the environment. Compressed solids produced by the belt filter
presses – the “cake” – would be conveyed to the bins for offsite disposal. Trucks would enter the
building through a roll-up door on the southwest side, and would receive the waste load from the
overhead bins. Up to five trucks per day (counted as ten trips per day) are expected to fully meet the
waste load generated by the dewatering operations. The BFP provides several options for beneficial
reuse within the Bay Area and surrounding counties.
The project does not require specialized maintenance, and all facilities would undergo routine
maintenance as part of overall RWQCP operations.
1.8.4 Permits and Approvals
Construction of the proposed project would require permits and approvals from the following agencies.
• Bay Area Air Quality Management District (BAAQMD) – Authority to Construct/Permit to Operate
• State Water Resources Control Board (SWRCB) – Clean Water State Revolving Fund grant funding
EN0717151040SAC/658394 (ISMND_ADMINDRAFT) 1-3
WT0508151059SAC Figure_1_V2.ai tdaus 07.15.2015
FIGURE 1Project Location
Sludge Dewatering and Loadout FacilityCity of Palo AltoPalo Alto, CA
North
0 1,000500
Approximate scale in feet
LEGEND
Project Location
101
Project Location
San Jose
Palo Alto
San Francisco
Hayward
Emba
r
c
a
d
e
r
o
R
o
a
d
Palo Alto WWTPPalo Alto WWTP
WT0508151059SAC Figure_2.ai tdaus 05.26.2015
FIGURE 2Site PlanSludge Dewatering and Loadout FacilityCity of Palo AltoPalo Alto, CA
WT0508151059SAC Figure_3.ai tdaus 05.26.2015
FIGURE 3aArchitectural Elevations Sludge Dewatering and Loadout FacilityCity of Palo AltoPalo Alto, CA
WT0508151059SAC Figure_3.ai tdaus 05.26.2015
FIGURE 3bArchitectural Elevations Sludge Dewatering and Loadout FacilityCity of Palo AltoPalo Alto, CA
SECTION 2
Environmental Determination
2.1 Environmental Factors Potentially Affected
The environmental factors checked below would be potentially affected by this project, i.e. involve at
least one impact that is a “Potentially Significant Impact” as indicated by the checklist on the following
pages.
Aesthetics Agriculture Resources Air Quality
Biological Resources Cultural Resources Geology/Soils
Greenhouse Gas Emissions Hazards & Hazardous Materials Hydrology/Water Quality
Land Use/Planning Mineral Resources Noise
Population/Housing Public Services Recreation
Transportation/Traffic Utilities/Service Systems Mandatory Findings of
Significance
2.2 Determination
Determination: (To be completed by the Lead Agency)
On the basis of this initial evaluation:
I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE
DECLARATION will be prepared.
I find that although the proposed project could have a significant effect on the environment, there will not be a
significant effect in this case because revisions in the project have been made by or agreed to by the project
proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.
I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL
IMPACT REPORT is required.
I find that the proposed project MAY have a “potentially significant impact” or “potentially significant unless
mitigated” impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier
document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on
the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it
must analyze only the effects that remain to be addressed.
I find that although the proposed project could have a significant effect on the environment, because all
potentially significant effects (a) have been analyzed adequately in an earlier ENVIRONMENTAL IMPACT REPORT
or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant
to that earlier ENVIRONMENTAL IMPACT REPORT or NEGATIVE DECLARATION, including revisions or mitigation
measures that are imposed upon the proposed project, nothing further is required.
Signature Date
Title Agency
EN0717151040SAC/658394 (ISMND_ADMINDRAFT) 2-1
SECTION 3
Evaluation of Environmental Impacts
3.1 Aesthetics
Would the project:
Potentially
Significant
Impact
Less-Than-
Significant with
Mitigation
Incorporation
Less-Than-Si
gnificant
Impact
No
Impact
a. Have a substantial adverse effect on a scenic vista?
b. Substantially damage scenic resources, including, but not
limited to, trees, rock outcroppings, and historic buildings
within a state scenic highway?
c. Substantially degrade the existing visual character or
quality of the site and its surroundings?
d. Create a new source of substantial light or glare which
would adversely affect day or nighttime views in the area?
3.1.1 Setting
The RWQCP is within an urbanized area of the City of Palo Alto, and the sludge dewatering and loadout
facility would be located approximately in the middle of the existing plant. Adjacent land uses are a
commercial/light industrial business park to the west, the Palo Alto Airport to the north, and Baylands
and park uses to the east and south. Distances from the closest edge of the sludge dewatering and
loadout facility site are as follows:
• California Self Storage adjacent to RWQCP, at nearest building – 195 feet.
• Business park office building across from RWQCP entrance, at building frontage – 475 feet.
• Palo Alto Airport, at entrance road – 850 feet.
• Palo Alto Baylands east of the site, at closest point of the trail – 500 feet.
• Palo Alto Baylands/Byxbee Park south of the site, at Embarcadero road entrance – 600 feet.
3.1.2 Impact Analysis
a. Would the project have a substantial adverse effect on a scenic vista?
NO IMPACT. The project is not located in an area that contains scenic vistas.
b. Would the project substantially damage scenic resources, including, but not limited to, trees, rock
outcroppings, and historic buildings within a state scenic highway?
NO IMPACT. The proposed project is not located within a state scenic highway and does not contain
scenic resources.
c. Would the project substantially degrade the existing visual character or quality of the site and its
surroundings?
LESS-THAN-SIGNIFICANT IMPACT. The project site is located on RWQCP site. Views toward the site
from most nearby uses (e.g., mini-storage, office buildings, airport) have low visual character and
quality consistent with the low-density urban setting. High-quality views from the adjacent Palo Alto
EN0717151040SAC/658394 (ISMND_ADMINDRAFT) 3-1
SECTION 3 – EVALUATION OF ENVIRONMENTAL IMPACTS
Baylands, including an unpaved trail, are toward the bay itself. Inland views from the Baylands are
dominated by Embarcadero Road, and by two prominent tank features on the RWQCP site – the
north and south fixed film reactors. The new sludge dewatering and loadout facility may be visible
from portions of the Baylands, most likely from due north at the trail access from Embarcadero
Road. However, the scale of the building would be consistent with other visible RWQCP features
such as the solids incineration building. Additionally, the project is required to obtain site and design
review approval from the City of Palo Alto. Meeting the City’s approval findings would ensure the
project’s aesthetic compatibility with the surrounding area. Because the project would be located on
an existing RWQCP, would be similar in scale to existing features, and would meet the City’s
approval findings, the visual character and quality of views from the Palo Alto Baylands would not be
substantially degraded. Impacts would be less than significant.
d. Would the project create a new source of substantial light or glare which would adversely affect
day or nighttime views in the area?
NO IMPACT. The project is located within the existing RWQCP site, and does not include any
additional lighting other than incidental, downward-facing safety lighting. Therefore there would be
no impact.
3.2 Agriculture and Forest Resources
Would the project:
Potentially
Significant
Impact
Less-Than-
Significant with
Mitigation
Incorporation
Less-Than-
Significant
Impact No Impact
a. Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland), as shown on
the maps prepared pursuant to the Farmland Mapping and
Monitoring Program of the California Resources Agency, to
non-agricultural use?
b. Conflict with existing zoning for agricultural use, or a
Williamson Act contract?
c. Conflict with existing zoning for, or cause rezoning
of, forest land (as defined in Public Resources Code (PRC)
Section 12220(g) or timberland (as defined in PRC
Section 4526), or timberland zoned Timberland Production (as
defined by Government Code section 51104(g))?
d. Result in the loss of forest land or conversion of
forest land to non-forest use?
e. Involve other changes in the existing environment
which, due to their location or nature, could result in
conversion of Farmland, to non-agricultural use or conversion
of forest land to non-forest use?
3.2.1 Setting
The dewatering and loadout facility would be constructed on the already existing Palo Alto RWQCP. The
RWQCP location is designated as Major Institution/Special Facilities by the City of Palo Alto.
3-2 EN0717151040SAC/658394 (ISMND_ADMINDRAFT)
SECTION 3 – EVALUATION OF ENVIRONMENTAL IMPACTS
3.2.2 Impact Analysis
a. Would the project convert Prime Farmland, Unique Farmland, or Farmland of Statewide
Importance, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring
Program of the California Resources Agency, to non-agricultural use?
NO IMPACT. The project is not located on or near land designated for agricultural use as defined by
the Farmland Mapping and Monitoring Program or the Williamson Act. The project is located on an
existing wastewater treatment plant site in a commercial/industrial zoned area. No farmlands are
present nor would any agricultural lands be converted to non-agricultural use; therefore there
would be no impact.
b. Would the project conflict with existing zoning for agricultural use, or a Williamson Act contract?
NO IMPACT. The proposed project is not located on land zoned for agriculture or under a Williamson
Act contract.
c. Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in
PRC section 1220(g)) or timberland (as defined in PRC section 4526)?
NO IMPACT. No forest or timber land is present at the project site or in the project vicinity nor
would be affected by the project.
d. Would the project result in the loss of forest land or conversion of forest land to non-forest use?
NO IMPACT. No forest land is present at the project site or in the project vicinity nor would be
affected by the project.
e. Would the project involve other changes in the existing environment which, due to their location
or nature, could result in the conversion of Farmland, to non-agricultural use?
NO IMPACT. The project would not involve other changes that could result in the conversion of
farmland to non-agricultural use.
3.3 Air Quality
Would the project:
Potentially
Significant
Impact
Less-Than-
Significant with
Mitigation
Incorporation
Less-Than-
Significant
Impact
No
Impact
a. Conflict with or obstruct implementation of the
applicable air quality plan?
b. Violate any air quality standard or contribute
substantially to an existing or projected air quality violation?
c. Result in a cumulatively considerable net increase of
any criteria pollutant for which the project region is non-
attainment under an applicable federal or state ambient air
quality standard (including releasing emissions which exceed
quantitative thresholds for ozone (O3) precursors)?
d. Expose sensitive receptors to substantial pollutant
concentrations?
e. Create objectionable odors affecting a substantial
number of people?
EN0717151040SAC/658394 (ISMND_ADMINDRAFT) 3-3
SECTION 3 – EVALUATION OF ENVIRONMENTAL IMPACTS
3.3.1 Setting
The proposed project is located in Santa Clara County within the San Francisco Bay Area air basin. Santa
Clara County is currently designated as nonattainment for the federal standards for ozone and
particulate matter with aerodynamic diameter equal to or less than 2.5 microns (PM 2.5,), and
maintenance for carbon monoxide (CO). Under state standards, the project area is designated as
nonattainment for ozone, particulate matter with aerodynamic diameter equal to or less than
10 microns (PM10), and PM2.5. The project area is designated as attainment/unclassified for all other
pollutants.
Construction activities have the potential to generate air pollutants that degrade air quality and increase
local human exposure to air contaminants. The Bay Area Air Quality Management District (BAAQMD)
has published guidelines for evaluating, measuring, and mitigating a project’s air quality impacts,
including impacts associated with criteria air pollutants (such as ozone and particulate matter) and toxic
air contaminants (BAAQMD, 2012).
3.3.2 Impact Analysis
a. Would the project conflict with or obstruct implementation of the applicable air quality plan?
NO IMPACT. The most recent air quality plan prepared by BAAQMD in response to federal planning
requirements is the San Francisco Bay Area 2001 Ozone Attainment Plan for the 1-hour National
Ozone Standard (BAAQMD, 2001). BAAQMD also adopted the Bay Area 2010 Clean Air Plan in
September 2010, which provides an integrated, multi-pollutant control strategy to reduce emissions
of ozone, particulates, air toxics, and greenhouse gases (GHGs) (BAAQMD, 2010a). The project
would be constructed in compliance with the applicable BAAQMD regulations and policies and best
management practices (BMPs), and would be implemented to reduce criteria pollutant emissions.
Therefore, project activities would be consistent with the regional and local air quality planning
strategy, with no impact to air quality.
b. Would the project violate any air quality standard or contribute substantially to an existing or
projected air quality violation?
LESS-THAN-SIGNIFICANT IMPACT. Construction of the proposed project would cause temporary
minor increases in ambient air pollutant concentrations. BAAQMD adopted new CEQA thresholds of
significance in June 2010 (BAAQMD, 2010b). Although the adoption of the new thresholds are the
subject of recent judicial actions (BAAQMD, 2012), the Lead Agency concluded that Appendix D of
the BAAQMD CEQA Air Quality Guidelines (BAAQMD, 2010b), in combination with BAAQMD’s
Revised Draft Options and Justification Report (BAAQMD, 2009), provide substantial evidence to
support the BAAQMD-recommended thresholds. Therefore, the BAAQMD 2010 thresholds were
used in this analysis to evaluate the significance of the project’s impacts.
Short-term construction emissions of ozone precursors (oxides of nitrogen [NOx] and reactive
organic gases [ROG]), CO, oxides of sulfur (SOx), PM10, and PM2.5 were evaluated. Construction
emissions were estimated using methodology consistent with the California Emissions Estimator
Model (CalEEMod) (California Air Pollution Control Officers’ Association [CAPCOA], 2013). Emissions
from onroad vehicles (delivery trucks, material haul trucks, pickup trucks, and worker commute
vehicles) and offroad vehicles (fuel and water trucks) were calculated using emission factors from
EMFAC2014 for the year 2016 vehicle fleet in Santa Clara County and default trip distances from the
CalEEMod User’s Guide (ENVIRON, 2013). Fugitive dust emissions (PM10 and PM2.5) from on- and
offroad vehicle travel were estimated using methodology from AP-42 (U.S. Environmental
Protection Agency [EPA], 2011; EPA, 2006). Emissions from construction equipment were calculated
using default horsepower ratings, load factors, and emission factors from the CalEEMod User’s
Guide (ENVIRON, 2013). Fugitive dust emissions (PM10 and PM2.5) from disturbed surfaces and
3-4 EN0717151040SAC/658394 (ISMND_ADMINDRAFT)
SECTION 3 – EVALUATION OF ENVIRONMENTAL IMPACTS
material handling, as either cut/fill or aggregates, were estimated using methodology from the
Software User’s Guide: URBEMIS2007 for Windows (Jones & Stokes Associates, 2007) and/or the
CalEEMod User’s Guide (ENVIRON, 2013). Off-gassing emissions (ROG) from paving activities were
estimated using emission factors from the CalEEMod User’s Guide (ENVIRON, 2013). Project-specific
construction schedules and equipment/vehicle usage were used to determine the sequence of
activities and potential overlap in resulting construction emissions. Appendix A contains the
complete construction emission calculations and assumptions used. Estimated construction
emissions would be below BAAQMD thresholds, as shown in Table 1.
table 1 Project Construction Emissions and Comparisons to 2010 BAAQMD CEQA Thresholds
ROG
(lb/day)
CO
(lb/day)
NOx
(lb/day)
SOx
(lb/day)
PM10
Exhaust
(lb/day)
PM2.5
Exhaust
(lb/day)
PM10
Fugitive
Dust
(lb/day)
PM2.5
Fugitive
Dust
(lb/day)
2016 (Average Daily) 4 25 47 0.1 2 2 80 15
BAAQMD 2010
Threshold
(Daily Average
Emissions, lb/day)
54 N/A 54 N/A 82 54 N/A N/A
Exceed BAAQMD CEQA
Threshold?
No N/A No N/A No No N/A N/A
Notes:
Thresholds are from BAAQMD CEQA Guidelines (BAAQMD, 2010b)
N/A = not applicable
Construction emissions would be below the BAAQMD CEQA thresholds. During construction, the
project would not violate any air quality standard or contribute substantially to an existing or
projected air quality violation. In addition, the proposed project would implement applicable criteria
pollutant control measures identified by the BAAQMD in its latest CEQA guidelines (BAAQMD,
2012). Applicable construction emission control measures may include, but are not limited to, the
following:
• All exposed surfaces (for example, parking areas, staging areas, soil piles, graded areas, and
unpaved access roads) shall be watered twice per day.
• All haul trucks transporting soil, sand, or other loose material offsite shall be covered.
• All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power
vacuum street sweepers at least once a day. The use of dry power sweeping is prohibited.
• All vehicle speeds on unpaved roads shall be limited to 15 miles per hour.
• All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible.
Building pads shall be laid as soon as possible after grading unless seeding or soil binders are
used.
• Idling times shall be minimized either by shutting equipment off when not in use or reducing the
maximum idling time to 5 minutes (as required by the California airborne toxics control measure
Title 13, Section 2485 of California Code of Regulations). Clear signage shall be provided for
construction workers at all access points.
EN0717151040SAC/658394 (ISMND_ADMINDRAFT) 3-5
SECTION 3 – EVALUATION OF ENVIRONMENTAL IMPACTS
• All construction equipment shall be maintained and properly tuned in accordance with
manufacturer’s specifications. All equipment shall be checked by a certified visible emissions
evaluator.
• A publicly visible sign shall be posted with the telephone number and person to contact at the
Lead Agency regarding dust complaints. This person shall respond and take corrective action
within 48 hours. The BAAQMD’s phone number shall also be visible to ensure compliance with
applicable regulations.
Once the few facility is operational, all equipment would be powered by electricity with the
exception of the diesel-powered emergency backup generator. The generator would be permitted
by the BAAQMD to operate on an emergency basis, with limited periodic testing, consistent with Air
Resources Board emissions standards. In addition, there would be negligible emissions from the five
trucks per day used to haul the dewatered solids for offsite reuse.
Construction and operation of the project would not violate any air quality standard or contribute
substantially to an existing or projected air quality violation and therefore would have
less-than-significant impacts.
c. Would the project result in a cumulatively considerable net increase of any criteria pollutant for
which the project region is non-attainment under an applicable federal or state ambient air
quality standard (including releasing emissions which exceed quantitative thresholds for ozone
precursors)?
LESS-THAN-SIGNIFICANT IMPACT. In developing thresholds of significance for air pollutants,
BAAQMD considered the emission levels for which a project’s individual emissions would be
cumulatively considerable (BAAQMD, 2010c). Projects that do not exceed the significance
thresholds are not considered to be cumulatively significant. As described above, project
construction emissions would be lower than the BAAQMD significance thresholds. Additionally, the
construction emissions would be temporary, and the maximum daily emissions would occur for only
a portion of the construction period. Because the project would emit pollutants below the
thresholds of significance for an individual project, it would not result in a cumulative considerable
emission increase of nonattainment pollutants (PM10, PM2.5, and the ozone precursors NOx and
ROG), and the air quality impact on nonattainment criteria pollutants would be less than significant.
d. Would the project expose sensitive receptors to substantial pollutant concentrations?
LESS-THAN-SIGNIFICANT IMPACT. As discussed in previous sections, project construction emissions
would be temporary and below the BAAQMD CEQA thresholds and therefore would not expose
nearby receptors to a substantial amount of criteria pollutants. Exhaust emissions from construction
equipment contain toxic air contaminants, such as diesel particulate matter, that have potential
cancer and non-cancer chronic health effects.
The project site is bounded by office/commercial land use on the west side, and otherwise by open
space. The closest residential receptor is approximately 3,275 feet to the northwest, and the closest
school is more than 1 mile from the site. Given the distance, short-term construction emissions
would not expose sensitive receptors to substantial pollutant concentrations. In addition, the
project construction is required to implement the BMPs and follow emission control measures,
including minimizing idling times and maintaining equipment in good condition. These measures will
help minimize any potential exposure to construction-related pollutants. Therefore, impacts would
be less than significant.
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e. Would the project create objectionable odors affecting a substantial number of people?
LESS-THAN-SIGNIFICANT IMPACT. The sludge dewatering and loadout facility would be a new source
of odor at the RWQCP. In addition, changes to overall RWQCP sludge handling processes may affect
odor generation from other units that feed sludge to the new dewatering facility. Existing RWQCP
operations include odor-control treatments such as adding sodium hypochlorite to sludge prior to
storage. These practices would continue under the proposed project. The project also includes the
addition of an odor-control system, likely a two-stage system consisting of a biotrickling filter
followed by a mixed media adsorber. This type of system is proven to be effective in sharply
reducing the concentration of odorous substances in wastewater treatment facilities.
Odor is regulated by the BAAQMD (Regulation 7 – Odorous Substances) as a two-part process. First,
thresholds are triggered only if the BAAQMD receives odor complaints from at least 10 individuals in
a 90-day period. If sufficient complaints are received, then the generator must demonstrate that
odors at the property line are not odorous after dilution with four parts of odor-free air. In other
words, a dilution-to-threshold ratio (D/T) of no greater than 5 must be met. Air dispersion modeling
conducted for the project indicates that odors at the property line would be substantially less than
the 5 D/T threshold. Based on the expected performance of the odor-control system and the results
of dispersion modeling, odor impacts would be less than significant.
3.4 Biological Resources
Would the project:
Potentially
Significant
Impact
Less-Than-
Significant with
Mitigation
Incorporation
Less-Than-
Significant
Impact
No
Impact
a. Have a substantial adverse effect, either directly or
through habitat modifications, on any species identified as
a candidate, sensitive, or special status species in local or
regional plans, policies, or regulations, or by the California
Department of Fish and Game or U.S. Fish and Wildlife
Service?
b. Have a substantial adverse effect on any riparian habitat
or other sensitive natural community identified in local or
regional plans, policies, regulations or by the California
Department of Fish and Game or U.S. Fish and Wildlife
Service?
c. Have a substantial adverse effect on federally protected
wetlands as defined by Section 404 of the Clean Water Act
(CWA) (including, but not limited to, marsh, vernal pool,
coastal, etc.) through direct removal, filling, hydrological
interruption, or other means?
d. Interfere substantially with the movement of any native
resident or migratory fish or wildlife species or with
established native resident or migratory wildlife corridors,
or impede the use of native wildlife nursery sites?
e. Conflict with any local policies or ordinances protecting
biological resources, such as a tree preservation policy or
ordinance?
f. Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation Plan,
or other approved local or regional habitat conservation
plan?
EN0717151040SAC/658394 (ISMND_ADMINDRAFT) 3-7
SECTION 3 – EVALUATION OF ENVIRONMENTAL IMPACTS
3.4.1 Setting
The project site is within a highly developed area in Palo Alto, within the middle of the existing RWQCP.
One biotic habitat was identified within the project area: developed/ruderal lands.
Vegetation. The lands within the RWQCP including the project footprint are developed and accented by
patches of ornamental shrubs and trees such as privet (Ligustrum vulgare), myoporum (Myoporum
laetum), and blue gum (Eucalyptus globulus). Ruderal vegetation includes invasive forbs and nonnative
annual grasses including Italian thistle (Carduus pycnocephalus), black mustard (Brassica nigra) and wild
oats (Avena fatua). Native natural communities do not occur on the site. The boundaries of the Palo Alto
Baylands nature preserve occur approximately 500 feet to the east and 800 feet to the south of the site.
A tall, dense thicket of privet trees line the eastern boundary of the site creating a natural barrier
between the site, the adjacent roadway (Embarcadero Road), and the preserve lands to the east. The
southern portion of the RWQCP developed lands is lined with coast live oak trees (Quercus agrifolia) and
Embarcadero Road separate the project site and the preserve lands to the south. To the north and
northwest is the Palo Alto Airport of Santa Clara County and the Palo Alto Golf Course. Additional
commercial properties occur to the west.
Wildlife. Developed areas can support certain wildlife species adapted to the unique nesting and
foraging opportunities found there, but wildlife abundance and diversity is generally low in these areas.
Striped skunk (Mephitis mephitis), raccoon (Procyon lotor), and Virginia opossum (Didelphis virginiana)
occur regularly in urban habitats. Bird species adapted to urban landscapes include house finch
(Carpodacus mexicanus), northern mockingbird (Mimus polyglottos), mourning dove (Zenaida
macroura), house sparrow (Passer domesticus), and rock dove (Columba livia).
The Palo Alto Baylands preserve is home to a variety of native resident wildlife species. Common birds
include great and snowy egrets (Ardea alba and Egretta thula), great blue heron (Ardea herodias), black-
crowned night heron (Nycticorax nycticorax), green-winged teal (Anas crecca), mallard (Anas
platyrhnchos), northern pintail (Anas acuta), American coot (Fulica americana), killdeer (Charadrius
vociferus), black-necked stilt (Himantopus mexicanus), and American avocet (Recurvirostra americana).
Small mammals such as red fox (Vulpes vulpes), deer mouse, and California vole are also known to
occur. Populations of two federally-and state endangered wildlife species, the California clapper rail
(Rallus longirostris obsoletus) and saltmarsh harvest mouse (Reithrodontomys raviventris), occur in the
tidal salt marsh habitats within the region. The aquatic habitat is also known to be nursery grounds for
several special-status salmonid species including Central California Coast steelhead (Oncorhynchus
mykiss). Although the project site is within 500 feet of the preserve, native marshland and aquatic
habitats are absent from the site.
Special-Status Species. The developed/ruderal lands identified on the project site are limited in size and
generally disturbed characterized by compact gravel surfaces, thereby precluding occurrence of most
special-status species in the region, which typically occur in open grassland, marshlands, and woodlands.
Furthermore, the sparely vegetated areas onsite are dominated by nonnative and invasive plant species,
which significantly reduces their capacity to support special-status wildlife species. Therefore, special-
status species known from the region including the California clapper rail and saltmarsh harvest mouse,
are not expected to occur at the project site. Special-status bird species known from the region may fly
over the site when migrating from the southern end to the north end of the preserve. However, these
sensitive birds are not expected to stop and forage within the project site due to the lack of suitable
foraging habitat and increased human activity.
The California Natural Diversity Database was queried for special-status species records within a 5-mile
radius of the project site (CDFW, 2015). None of the plant species known from the region are expected
to occur as suitable habitat conditions including alkaline and clay soils within the project site do not
3-8 EN0717151040SAC/658394 (ISMND_ADMINDRAFT)
SECTION 3 – EVALUATION OF ENVIRONMENTAL IMPACTS
exist. In addition, special-status wildlife species, including the federally- and state-endangered California
clapper rail and saltmarsh harvest mouse, are not expected to occur onsite as suitable native habitats
including coastal salt marshlands, are not present. The closest known occurrences for both the California
clapper rail and saltmarsh harvest mouse are approximately 1 mile northeast of the project site within
salt marsh habitats just south of the Dumbarton Bridge.
Common bird species adapted to urban lands may nest in the ornamental vegetation onsite during the
nesting season (February to August). Nesting birds are covered under the Migratory Bird Treaty Act
(MBTA) and would be considered a sensitive resource if active nests occur onsite during construction.
Ordinance-Size Trees. The City of Palo Alto Tree Ordinance defines trees in three categories according to
the Palo Alto Municipal Code, Title 8, Trees and Vegetation: 1) protected trees; 2) street trees; and 3)
designated trees. Each category is defined below.
• Category 1: All coast live oak, valley oak (Quercus lobata) trees that are 11.5-inches or greater in
diameter (36-inches in circumference measured at 54-inches above natural grade) and coast
redwood (Sequoia sempervirens) trees that are 18-inches or greater in diameter (57-inches in
circumference measured at 54-inches above natural grade) and Heritage Trees, individual trees of
any size or species designated as such by City Council.
• Category 2: All trees growing within the street right-of-way (publicly-owned), outside of private
property.
• Category 3: All trees, when associated with a development project, that are specifically designated
by the City to be saved and protected on a public or private property which is subject to a
discretionary development review (such as a variance, home improvement exception, architectural
review, site and design, subdivision, etc.). Tree removal is considered a minor change to the existing
site plan—and requires review approval from the Planning Division.
Three blue gum trees ranging from 30-35 inches in circumference and six coast redwood plantings
ranging from 15 to 18 inches in circumference measured at 54-inches above natural grade were
observed onsite. The six coast redwood trees were planted by the RQWCP as part of a tree experiment
using recycled water. The nine trees onsite would not fall under Categories 1 or 2 of the tree ordinance,
and would not likely fall under Category 3.
3.4.2 Impact Analysis
a. Would the project have a substantial adverse effect, either directly or through habitat
modifications, on any species identified as candidate, sensitive, or special-status species in local or
regional plans, policies, or regulations, or by the California Department of Fish and Game or
U.S. Fish and Wildlife Service?
LESS-THAN-SIGNIFICANT IMPACT WITH MITIGATION INCORPORATED.
Impacts on Special-Status Plant Species. The project area does not contain suitable habitat for
special-status plants as suitable habitat conditions including alkaline and clay soils do not exist
onsite. The reconnaissance survey was conducted during the blooming periods for most species, and
none were observed within or adjacent to the project site. In addition, none of these species are
known from past occurrences to be within or adjacent to the project site (CDFW, 2015). Therefore,
special-status plant species are presumed to be absent and no further surveys are warranted.
Impacts on these species are considered to be negligible.
Impacts on Wildlife, Including Special-Status Species. Several special-status wildlife species have
the potential to occur in the eastern and southern areas of the project region within the Palo Alto
Baylands preserve; however none of these species are expected to occur onsite due to the
developed nature of the site, lack of suitable marshland habitat, and the increased human activity
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associated with the existing RWQCP operations. Special-status birds may occur as occasional
flyovers during the spring and fall migration periods, but because these special-status bird species
are not likely to forage or nest in the project area, the project construction activities would not
result in significant impacts. In addition, avoidance measures, including preconstruction nesting
surveys, biological monitoring, and establishing construction-free buffer zones as described below
would be implemented during the nesting season (February through August) to protect birds
covered under the MBTA that may nest within the project area. Therefore, impacts on resident and
migratory birds in the area would be reduced to a less-than-significant level.
Wildlife currently found in and around the project site is likely tolerant to levels of disturbance
typically associated with ongoing operations of the RWQCP, air traffic from the existing airport to
the north, and surrounding industrial and commercial development. The visual and acoustic
disturbance to wildlife associated with the proposed project is not expected to be significantly
higher than what currently exists, and wildlife in the adjacent areas are expected to habituate to
these new levels of disturbance. The RWQCP is closed at 5pm; therefore, impacts on nocturnal
wildlife would not be expected.
Avoidance Measures for Special-Status Wildlife Species. The proposed project includes the
following avoidance and minimization measures to reduce impacts on species covered by the MBTA
during construction to a less-than-significant level:
• Pre-construction nesting surveys will be conducted before undertaking work during the nesting
season (February through August). Any nest found within 50 feet for songbirds and 300 feet for
raptors will be avoided, and a designated construction-free buffer zone will be established until
the nests are no longer active.
• Biological monitoring of work activities for active bird nests found during the nesting season will
be conducted by a qualified biologist.
• A qualified biologist will conduct onsite informational meetings with all construction personnel
before construction begins. The purpose of these training sessions will be to familiarize
construction personnel with the procedures regarding nesting birds they are to follow if they are
encountered.
b. Would the project have a substantial adverse effect on any riparian habitat or other sensitive
natural community identified in local or regional plans, policies, or regulations, or by the California
Department of Fish and Game or U.S. Fish and Wildlife Service?
NO IMPACT. Because all construction activities associated with the proposed project would occur
within graveled surfaces, paved roads, and other previously disturbed areas, no temporary or
permanent construction impacts or ongoing operations impacts are anticipated to sensitive habitats
identified by CDFW or USFWS.
c. Would the project have a substantial adverse effect on federally protected wetlands as defined by
Section 404 of the CWA (including, but not limited to, marsh, vernal pool, coastal, etc.) through
direct removal, filling, hydrological interruption, or other means?
NO IMPACT. Federally protected wetlands, as defined by Section 404 of the Clean Water Act, do not
occur within the project area; therefore, no permanent or temporary impacts would occur as a
result of construction. In addition, natural water features do not occur within the project area.
Therefore, no permanent or temporary impacts on wetland or other aquatic resources are expected.
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d. Would the project interfere substantially with the movement of any native resident or migratory
fish or wildlife species or with established native resident or migratory wildlife corridors, or
impede the use of native wildlife nursery sites?
NO IMPACT. Because all construction activities associated with the proposed project would occur
within the existing developed RWQCP site, the project would not disturb any natural habitats
including riparian, wetland, or aquatic habitats used by local wildlife species. Therefore, the
proposed construction and operation activities would not interfere with the movement of native
resident or migratory fish, wildlife species, native resident or migratory wildlife corridors, or impede
the use of native wildlife nursery sites because these are not currently onsite. Changes in vegetation
from removal of nonnative, invasive herbaceous species would not present significant barriers to
movement of fish or wildlife.
e. Would the project conflict with any local policies or ordinances protecting biological resources,
such as a tree preservation policy or ordinance?
LESS-THAN-SIGNIFICANT IMPACT. The project would not conflict with any local policies or
ordinances protecting biological resources. Tree pruning may be required for construction access
and up to nine non-ordinance-sized trees may be removed including three blue gum trees and six
coast redwood plantings previously planted as part of a recycled water use experiment conducted
by the RWQCP. Tree removal would not conflict with the City of Palo Alto Tree Ordinance.
f. Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural
Community Conservation Plan, or other approved local, regional, or state habitat conservation
plan?
NO IMPACT. The project would not conflict with the provisions of a Habitat Conservation Plan or
Natural Community Conservation Plan, or other governmental habitat conservation plan. The site is
outside of the boundaries of the nearest Habitat Conservation Plan (Santa Clara Valley Habitat Plan);
therefore, there would be no impact.
3.5 Cultural Resources
Would the project:
Potentially
Significant
Impact
Less-Than-
Significant with
Mitigation
Incorporation
Less-Than-
Significant
Impact
No
Impact
a. Cause a substantial adverse change in the significance
of a historical resource as defined in §15064.5?
b. Cause a substantial adverse change in the significance
of an archaeological resource pursuant to §15064.5?
c. Directly or indirectly destroy a unique paleontological
resource or site or unique geologic feature?
d. Disturb any human remains, including those interred
outside of formal cemeteries?
3.5.1 Setting
The proposed project site is within the existing City of Palo Alto RWQCP, which is completely developed
and paved. The original ground surface is not visible. Prior to human settlement, the project area
consisted of coastal littoral land cover characterized by a series of microenvironments including
estuaries, bays, marshes, and grassy terraces. Although it was originally salt marsh, the RWQCP property
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is situated entirely on imported fill that was placed from the early 1930s to the 1950s for the
development of the RWQCP and other nearby uses including the airport and golf course (William Self
Associates, 2007). Although the site has been used for wastewater treatment purposes since 1934, no
pre-1950s buildings remain on the site.
3.5.2 Impact Analysis
a. Would the project cause a substantial adverse change in the significance of a historical resource as
defined in §15064.5?
NO IMPACT. A records and information search was conducted at the Northwest Information Center
at Sonoma State University. The results from this search indicated that there were no recorded
historical sites within the project area or within 0.25 mile of the project. Additionally, the record
search showed that three cultural resources were conducted within 0.25 mile of the project area;
however, no cultural materials were identified in any of the three studies (William Self Associates,
2007). Additionally, a field study of the project area did not identify any historical resources within
or around the project site. There would be no impact to historical resources as a result of this
project.
b. Would the project cause a substantial adverse change in the significance of an archaeological
resource pursuant to §15064.5?
LESS THAN SIGNIFICANT IMPACT. The project site and its surrounding area was prehistorically open
marshland, but is now completely paved and developed. Given the location of the project area and
its relation to its original (native) context along the marshy bank of the Palo Alto Baylands, it is
possible that the prehistoric people utilized the project area for hunting and raw material
procurement, but it’s less likely that it would have been a suitable location for permanent habitation
(William Self Associates, 2007). A records and information search conducted at the Northwest
Information Center at Sonoma State University indicated that no previously recorded archaeological
resources have been identified in the project area or within 0.25 mile of the surrounding area
(William Self Associates, 2007). As such, there is a low potential for exposing significant
archaeological resources during construction. Additionally, the record search showed that three
cultural resources were conducted within 0.25 mile of the project area; however, no cultural
materials were identified in any of the three studies (William Self Associates, 2007). If archeological
resources are exposed during construction, work would stop in accordance with applicable local,
state, and federal regulations until such time that the resources can be evaluated by a qualified
archaeologist and appropriate mitigation actions can be implemented. Based on these standard
requirements, impacts would be less than significant.
c. Would the project directly or indirectly destroy a unique paleontological resource or site or
unique geologic feature?
NO IMPACT. No impacts to paleontological resources are expected because the project site is
already highly disturbed as a result of past activities. Work would be done either in an existing
roadway or in areas previously disturbed. Since the project site and much of the surrounding area
has been previously graded and developed, these deposits are likely to have a low potential to
contain fossil resources, and are thus, considered to have little to no paleontological sensitivity.
d. Would the project disturb any human remains, including those interred outside of formal
cemeteries?
LESS THAN SIGNIFICANT IMPACT. No recorded instances of prehistoric or historic human remains are
known to be within or adjacent to the project area. In the event of an unexpected discovery of human
remains, California Health and Safety Code (Section 7050.5[b]) would be followed and the County
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Coroner would be notified. Based on these standard requirements, impacts would be less than
significant.
3.6 Geology and Soils
Would the project:
Potentially
Significant
Impact
Less-Than-
Significant with
Mitigation
Incorporation
Less-Than-
Significant
Impact
No
Impact
a. Expose people or structures to potential substantial
adverse effects, including the risk of loss, injury, or death
involving:
i) Rupture of a known earthquake fault, as delineated on
the most recent Alquist-Priolo Earthquake Fault
Zoning Map issued by the State Geologist for the area
or based on other substantial evidence of a known
fault? Refer to Division of Mines and Geology Special
Publication 42.
ii) Strong seismic ground shaking?
iii) Seismic-related ground failure, including liquefaction?
iv) Landslides?
b. Result in substantial soil erosion or the loss of topsoil?
c. Be located on a geologic unit or soil that is unstable, or
that would become unstable as a result of the project, and
potentially result in onsite or offsite landslide, lateral
spreading, subsidence, liquefaction, or collapse?
d. Be located on expansive soil, as defined in Table 18-1-B of
the Uniform Building Code (1994), creating substantial
risks to life or property?
e. Have soils incapable of adequately supporting the use of
septic tanks or alternative wastewater disposal systems
where sewers are not available for the disposal of
wastewater?
3.6.1 Setting
A geotechnical analysis was conducted for the project area (CH2M HILL, 2015). The project site is located
in Palo Alto, which is a relatively flat portion of the Santa Clara Valley. The project site has an elevation
of approximately 10 feet. The geotechnical analysis described the subsurface conditions as consisting of
medium dense to very dense sand and soft to stiff lean clay. While the entire state is a seismically active
area, the project site is not located within any California-designated Alquist-Priolo Zone.
3.6.2 Impact Analysis
a. Would the project expose people or structures to potential substantial adverse effects, including
the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other
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3‐14 EN0717151040SAC/658394 (ISMND_ADMINDRAFT)
substantial evidence of a known fault? Refer to Division of Mines and Geology Special
Publication 42.
NO IMPACT. There are no Alquist‐Priolo Earthquake Fault Zones that have been designated at
the Palo Alto RWQCP. Additionally, the project site is not identified by the County of Santa Clara
as being in a County Fault Rupture Hazard Zone. Therefore there would be no impact as a result
of this project.
ii) Strong seismic ground shaking?
LESS‐THAN‐SIGNIFICANT IMPACT. It is expected that the site would be subject to seismic events
over the life of the project. The project is designed to incorporate standard construction
specifications and recommendations consistent with the 2013 California Building Code (CBC,
2013) and as recommended by the American Society of Civil Engineers’ ASCE‐7 – Minimum
Design Loads for Buildings and Other Structures (ASCE, 2010). Compliance with these standards
would ensure that the project could withstand these types of events; therefore, impacts
resulting from seismic events would be less than significant.
iii) Seismic‐related ground failure, including liquefaction?
LESS‐THAN‐SIGNIFICANT IMPACT. The project location consists of subsurface soils that are not
susceptible to liquefaction (CH2M HILL, 2015). While it is possible that some of the soils
identified in the geotechnical memorandum have the possibility to liquefy during an earthquake,
the overall potential for liquefaction is low. Additionally, the project is designed to incorporate
standard construction specifications and recommendations consistent with the 2013 California
Building Code (CBC, 2013) and as recommended by the American Society of Civil Engineers’
ASCE‐7 – Minimum Design Loads for Buildings and Other Structures (ASCE, 2010). Therefore,
there would be a less‐than‐significant impact as a result of this project.
iv) Landslides?
NO IMPACT. The project location is flat with no potential for landslides or mudflows.
b. Would the project result in substantial soil erosion or the loss of topsoil?
LESS‐THAN‐SIGNIFICANT IMPACT. The project site is flat, with little potential for soil erosion. As
described in Section 3.9.2(a), erosion and water quality impacts would be minimized during
construction by following standard practices for erosion control. Therefore, impacts would be less
than significant.
c. Would the project be located on a geologic unit or soils that is unstable, or that would become
unstable as a result of the project, and potentially result in an onsite or offsite landslide, lateral
spreading, subsidence, liquefaction, or collapse?
LESS‐THAN‐SIGNIFICANT IMPACT. The project would not be located on a geologic unit or soils that
are unstable or that would become unstable as a result of the project, potentially resulting in an
onsite or offsite landslide, lateral spreading, subsidence, liquefaction, or collapse. The project is
designed to incorporate standard construction specifications and recommendations consistent with
the 2013 California Building Code (CBC, 2013) and as recommended by the American Society of Civil
Engineers’ ASCE‐7 – Minimum Design Loads for Buildings and Other Structures (ASCE, 2010).
Additionally, the project would be completed using the most up‐to‐date construction and
engineering techniques to ensure safe construction; therefore, there would be a less‐than‐
significant impact.
SECTION 3 – EVALUATION OF ENVIRONMENTAL IMPACTS
d. Would the project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building
Code (1994), creating substantial risks to life or property?
LESS-THAN-SIGNIFICANT IMPACT. The project would be designed and constructed to avoid or
minimize potential damage from expansive soils. As stated in the geotechnical analysis (CH2MHILL,
2015), the project would incorporate standard construction specifications and recommendations
consistent with the 2013 California Building Code (CBC, 2013) and as recommended by the American
Society of Civil Engineers’ ASCE-7 – Minimum Design Loads for Buildings and Other Structures (ASCE,
2010). Based on complying with these requirements, impacts would be less-than-significant.
e. Would the project have soils incapable of adequately supporting the use of septic tanks or
alternative wastewater disposal systems where sewers are not available for the disposal of
wastewater?
NO IMPACT. The project does not include the use of septic tanks for alternative wastewater disposal
systems. Therefore, there would be no impact.
3.7 Greenhouse Gas Emissions
Would the project:
Potentially
Significant
Impact
Less-Than-
Significant with
Mitigation
Incorporation
Less-Than-
Significant
Impact
No
Impact
a. Generate greenhouse gas (GHG) emissions, either
directly or indirectly, that may have a significant
impact on the environment?
b. Conflict with any applicable plan, policy, or regulation
of an agency adopted for the purpose of reducing the
emissions of GHGs?
3.7.1 Setting
Various gases in the earth’s atmosphere play an important role in moderating the earth’s surface
temperature. Solar radiation enters earth’s atmosphere from space and a portion of the radiation is
absorbed by the earth’s surface. The earth emits this radiation back toward space, but the properties of
the radiation change from high-frequency solar radiation to lower-frequency infrared radiation. GHGs
are transparent to solar radiation, but are effective in absorbing infrared radiation. Consequently,
radiation that would otherwise escape back into space is retained, resulting in a warming of the earth’s
atmosphere. This phenomenon is known as the greenhouse effect.
GHGs include both naturally occurring and anthropogenic gases that trap heat in the earth’s
atmosphere. GHGs include, but are not limited to, carbon dioxide (CO2), methane, nitrous oxide,
hydrochlorofluorocarbons, perfluorocarbons, and sulfur hexafluoride. Although there is disagreement as
to the speed of global warming and the extent of the impacts attributable to human activities, the
majority of the scientific community now agrees that there is a direct link between increased emission
of GHGs and long-term global temperature.
In the United States, the main source of GHG emissions is electricity generation, followed by
transportation. In California, however, transportation sources (passenger cars, light-duty trucks, other
trucks, buses, and motorcycles) make up the largest category of GHG-emitting sources (CARB, 2013). In
2011, the annual California statewide GHG emissions were 448.11 million metric tons of CO2-equivalent
(CARB, 2013). The transportation sector accounts for about 38 percent of the statewide GHG emissions
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inventory. The electric power sector accounts for about 19 percent of the total statewide GHG emissions
inventory. The dominant GHG emitted is CO2, primarily from fossil fuel combustion.
3.7.2 Impact Analysis
a. Would the project generate GHG emissions, either directly or indirectly, that may have a
significant impact on the environment?
LESS-THAN-SIGNIFICANT IMPACT. There are no GHG emission thresholds for construction activities
in BAAQMD’s 2010 thresholds of significance. Rather, the guidelines suggest evaluating impact
significance in relation to meeting GHG reduction strategies. The operational threshold for GHGs
from stationary source operations is 10,000 metric tons per year. The threshold for other non-
stationary source projects is 1,100 metric tons per year (BAAQMD, 2010c).
GHG impacts from the proposed project were based on the GHG emissions from offroad
construction equipment and on- and offroad vehicle usage during the construction period. CO2
emissions from offroad construction equipment and on- and offroad vehicles were estimated using
methodology described in Section 3.3.2. The project is not expected to result in measurable
emissions of other GHGs. Appendix A contains the complete construction calculations used to assess
GHG impacts.
Table 2 Project Construction Greenhouse Gas Emissions
CO2
(Million Metric Tons/Year)
2016 through 2018 Emissions 0.001
2007 BAAQMD Inventory 95.8
2010 State Inventory 448.11
State GHG Goal 2020 (Assembly Bill 32) 427
The GHG emissions from project construction would be temporary and would occur only during the
approximately 24 months of construction from April 2016 through Spring 2018. GHG emissions from
construction would be temporary and negligible compared to the local and State GHG inventory.
Once the few facility is operational, all equipment would be powered by electricity with the
exception of the diesel-powered emergency backup generator. The generator would be permitted
by the BAAQMD to operate on an emergency basis, with limited periodic testing, consistent with Air
Resources Board emissions standards. In addition, there would be negligible emissions from the five
trucks per day used to haul the dewatered solids for offsite reuse.
The minimal GHG emissions during construction and operation are not expected to contribute
substantially to the regional GHG emissions inventory, or contribute to global climate change.
Therefore, the project would result in a less-than-significant impact from GHG emissions.
b. Would the project conflict with any applicable plan, policy, or regulation of an agency adopted for
the purpose of reducing the emissions of GHGs?
NO IMPACT. The BAAQMD established a climate protection program in 2005 to explicitly
acknowledge the link between climate change and air quality, and has prepared a GHG emissions
inventory to support its climate protection activities. Based on the BAAQMD inventory, total GHG
emissions within the San Francisco Bay Area air basin were 95.8 million metric tons in 2007
(BAAQMD, 2010d).
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As shown in Table 2, the short-term construction GHG emissions would be negligible compared to the
State or BAAQMD GHG inventories and GHG emissions goal for 2020. The project would not interfere
with the Assembly Bill 32 Scoping Plan and the long-term goal of Assembly Bill 32 to reduce GHG
emissions to 1990 levels by 2020. The proposed project would not conflict with applicable plans,
policies, or regulations intended to reduce GHG emissions and would, therefore, have no impact on
climate change.
3.8 Hazards and Hazardous Materials
Would the project:
Potentially
Significant
Impact
Less-Than-
Significant with
Mitigation
Incorporation
Less-Than-
Significant
Impact
No
Impact
a. Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
b. Create a significant hazard to the public or the
environment through reasonably foreseeable upset and
accident conditions involving the release of hazardous
materials into the environment?
c. Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste within
one-quarter mile of an existing or proposed school?
d. Be located on a site, which is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a result,
would it create a significant hazard to the public or
the environment?
e. For a project located within an airport land use plan, or
where such a plan has not been adopted, within two
miles of a public airport or public use airport, would the
project result in a safety hazard for people residing or
working in the project area?
f. For a project within the vicinity of a private airstrip,
would the project result in a safety hazard for people
residing or working in the project area?
g. Impair implementation of or physically interfere with an
adopted emergency response plan or emergency
evacuation plan?
h. Expose people or structures to a significant risk of loss,
injury, or death involving wildland fires, including where
wildlands are adjacent to urbanized areas or where
residences are intermixed with wildlands?
3.8.1 Setting
The project is located at the existing RWQCP, a publicly owned treatment works managed by the City of
Palo Alto. The RWQCP uses various chemicals as part of its normal operations. The project involves
changes in the solids dewatering and handling processes, and would not affect other wastewater
treatment operations including most of the existing chemical uses.
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3.8.2 Impact Analysis
a. Create a significant hazard to the public or the environment through the routine transport, use, or
disposal of hazardous materials?
LESS-THAN-SIGNIFICANT IMPACT. Project construction will involve the use of construction
equipment at the site for approximately 17 months. The type of equipment used would be typical
for industrial building construction, and could result in some potential for release of hazardous
materials such as fuel, oil, and similar pollutants derived from vehicle use. Given the small size of the
construction project and the limited number of vehicles expected to be required for construction,
the potential for impacts is small. In addition, the job site would be maintained consistent with
standard construction requirements for pollution and water quality control. For these reasons,
impacts would be less than significant. Any residual pollution from construction equipment could be
transported by stormwater runoff, but all onsite drainage is captured and treated as part of the
wastewater treatment system - this would be effective for pollutant removal.
Project operations would involve the transport of biosolids from the project site for offsite beneficial
reuse. Potential impact would be limited as biosolids would be treated consistent with applicable
federal regulations. California’s biosolids program is regulated by USEPA Region IX pursuant to
40 Code of Federal Regulations (CFR) 503, “Standards for the Use and Disposal of Sewage Sludge”
(i.e., the 503 Rule). The 503 Rule establishes standards such as pollutant limits, pathogen reduction
requirements, and vector attraction reduction requirements. Therefore, impacts would be less than
significant.
b. Create a significant hazard to the public or the environment through reasonably foreseeable upset
and accident conditions involving the release of hazardous materials into the environment?
LESS-THAN-SIGNIFICANT IMPACT. See response to “a” above.
c. Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials,
substances, or waste within one-quarter mile of an existing or proposed school?
NO IMPACT. The proposed project is not within one-quarter mile of any existing or proposed school,
therefore, there would be no impacts.
d. Would the project be located on a site which is included on a list of hazardous materials sites
compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a
significant hazard to the public or the environment?
NO IMPACT. The project is not located on a site that is included on a list of hazardous materials sites
compiled pursuant to Government Code Section 65962.5, and is not expected to create a significant
hazard to the public or environment. An investigation of the Envirostor database, also known as the
Cortese List, did not identify any contaminated sites within the project area (California Department
of Toxic Substances Control, 2015).
e. For a project located within an airport land use plan or, where such a plan has not been adopted,
within two miles of a public airport or public use airport, would the project result in a safety
hazard for people residing or working in the project area?
LESS-THAN-SIGNIFICANT IMPACT. The RWQCP is 750 feet south of the Palo Alto Airport. Based on
Santa Clara County General Plan requirements for land uses adjacent to the airport, all structures on
the RWQCP are restricted to heights of less than 150 feet. Because the new sludge dewatering and
loadout facility would be less than 150 feet in height, impacts would be less than significant.
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f. For a project within the vicinity of a private airstrip, would the project result in a safety hazard for
people residing or working in the project area?
NO IMPACT. The project is not located near a private airstrip; therefore, impacts would be less than
significant.
g. Would the project impair implementation of or physically interfere with an adopted emergency
response plan or emergency evacuation plan?
NO IMPACT. The project would be constructed within the existing RWQCP, and does not include
design features that would impede emergency access. City of Palo Alto Ordinance 1111 was passed
in November 2007 and lists adoption of the California Fire Code (CFC) and changes required for the
City. In Sections 15.04.150 and 15.04.160, the ordinance states that the fire access road should be
20 feet wide, comply with the requirements of Section 503.1.1 of the CFC, and extend within
150 feet of all portions of the facility and all portions of the exterior walls of the first story of the
building. The existing access road along the north side of the new building is 25 feet wide and the
furthest point on the building is approximately 143 feet away. Therefore, the existing road meets
the requirements for fire access and additional roads are not required. There would be no impacts
as a result of this project.
h. Would the project expose people or structures to a significant risk of loss, injury, or death
involving wildland fires, including where wildlands are adjacent to urbanized areas or where
residences are intermixed with wildlands?
NO IMPACT. The project would be constructed within the property of the existing RWQCP, and is
500 feet away from the nearest open space region. Therefore, there would be no impact to
wildlands as a result of this project.
3.9 Hydrology and Water Quality
Would the project:
Potentially
Significant
Impact
Less-Than-
Significant with
Mitigation
Incorporation
Less-Than-
Significant
Impact
No
Impact
a. Violate any water quality standards or waste discharge
requirements (WDR)?
b. Substantially deplete groundwater supplies or interfere
substantially with groundwater recharge such that there
would be a net deficit in aquifer volume or a lowering of
the local groundwater table level (e.g., the production
rate of pre-existing nearby wells would drop to a level
which would not support existing land uses or planned
uses for which permits have been granted)?
c. Substantially alter the existing drainage pattern of the site
or area, including through the alteration of the course of a
stream or river, in a manner which would result in
substantial erosion or siltation onsite or offsite?
d. Substantially alter the existing drainage pattern of the site
or area, including through the alteration of the course of a
stream or river, or substantially increase the rate or
amount of surface runoff in a manner which would result
in flooding onsite or offsite?
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e. Create or contribute runoff water, which would exceed
the capacity of existing or planned storm water drainage
systems, or provide substantial additional sources of
polluted runoff?
f. Otherwise substantially degrade water quality?
g. Place housing within a 100-year flood hazard area as
mapped on a federal Flood Hazard Boundary or Flood
Insurance Rate Map or other flood hazard delineation
map?
h. Place within a 100-year flood hazard area structures,
which would impede or redirect flood flows?
i. Expose people or structures to a significant risk of loss,
injury, or death involving flooding, including flooding as a
result of the failure of a levee or dam?
j. Inundation by seiche, tsunami, or mudflow?
3.9.1 Setting
The project is located at the existing RWQCP site near the Palo Alto Baylands and the Mayfield Slough,
which both connect to the San Francisco Bay.
3.9.2 Impact Analysis
a. Would the project violate any water quality standards or waste discharge requirements, or
otherwise substantially degrade water quality?
LESS-THAN-SIGNIFICANT IMPACT. The RWQCP is heavily regulated by the San Francisco Bay Regional
Water Quality Control Board (RWQCB) under Order No. R2-2014-0024 (NPDES Permit No.
CA0037834), which establishes waste discharge requirements for disposal of treated wastewater
into San Francisco Bay. The onsite storm drainage system discharges into the wastewater treatment
system, and therefore site stormwater also is regulated under Order No. R2-2014-0024. The
proposed project would add a minor amount of impervious surface to the overall RWQCP with the
addition of the new building and the loss of the undeveloped land. Because stormwater is included
in Order No. R2-2014-0024, the proposed project would be consistent with applicable water quality
standards and waste discharge requirements.
Under both the construction and operation phases, the proposed project would not substantially
degrade water quality due to the plant’s available capacity to handle the small increase in
stormwater runoff. All stormwater runoff at the site is directed into the wastewater treatment
system, which is highly effective in removing pollutants from onsite storm drainage. Therefore,
impacts to water quality would be less than significant.
b. Would the project substantially deplete groundwater supplies or interfere substantially with
groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of
the local groundwater table level (e.g., the production rate of pre-existing nearby wells would
drop to a level which would not support existing land uses or planned uses for which permits have
been granted?
NO IMPACT. The project would not deplete groundwater supplies or interfere with recharge.
Groundwater in this area is not beneficially used; therefore, there would be no impacts as a result of
this project.
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c. Would the project substantially alter the existing drainage pattern of the site or area, including
through the alteration of the course of a stream or river, in a manner which would result in
substantial erosion or siltation onsite or offsite?
LESS-THAN-SIGNIFICANT IMPACT. The project site consists of several solar panels on undeveloped
land, where stormwater permeates into the ground. Under the proposed project, the site would
become impervious due to the new dewatering and truck loadout facility. The facility has designed
to direct rain water away from buildings in the direction of the existing stormwater collection
system, which conveys storm runoff to the 72-inch joint sewer that ultimately discharges to the
plant pump station. Roof drainage will discharge to ground on splash blocks or will be hard piped to
an existing storm drain. Where storm drainage is required, all components of the system will be
designed to convey the 10-year storm, and 100-year storm runoff will be conveyed away from the
building without creating or contributing to the downstream or upstream flooding conditions per
the Santa Clara County, California, Drainage Manual. Because surface flow is treated in the plant,
none is leaving the site requiring detention/ retention.
No streams or rivers would be affected by project construction or operation, nor would alterations
of existing drainage patterns on the site area be affected, other than the minor change in
impervious surfaces. The RWQCP has adequate capacity to handle the additional inflow of
stormwater runoff from the project site; therefore, these minimal changes would result in
less-than-significant impacts.
d. Would the project substantially alter the existing drainage pattern of the site or area, including
through the alteration of the course of a stream or river, or substantially increase the rate or
amount of surface runoff in a manner which would result in flooding onsite or offsite?
LESS-THAN-SIGNIFICANT IMPACT. The proposed project would not alter the existing drainage
pattern of the site or area and would result in less-than-significant impacts; see answer (c) for more
information, above.
e. Would the project create or contribute runoff water which would exceed the capacity of existing
or planned storm water drainage systems or provide substantial additional sources of polluted
runoff?
LESS-THAN-SIGNIFICANT IMPACT. The proposed project would not create or contribute runoff water
and would result in less-than-significant impacts; see answers (a) and (c) for more information,
above.
f. Would the project otherwise substantially degrade water quality?
LESS-THAN-SIGNIFICANT IMPACT. The proposed project would not substantially degrade water
quality; all potential water quality impacts are discussed in (a), (c), and (d) above.
g. Would the project place housing within a 100-year flood hazard area as mapped on a federal
Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map?
NO IMPACT. No housing construction is proposed as a part of the project. Therefore, construction
and operation of the project would result in no flood hazard impacts to housing.
h. Would the project place within a 100-year flood hazard area structures which would impede or
redirect flood flows?
LESS-THAN-SIGNIFICANT IMPACT. The RQWCP is located in an area designated a high risk flood zone
(Zone AE) with a base flood elevation of 11 feet by the Federal Emergency Management Agency
(FEMA). While the proposed project would be within a 100-year floodplain, the facility will have a
finished floor elevation of 11.5 feet. Because the finished floor would be above the base flood
elevation, project impacts would be less than significant.
EN0717151040SAC/658394 (ISMND_ADMINDRAFT) 3-21
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i. Would the project expose people or structures to a significant risk of loss, injury, or death
involving flooding, including flooding as a result of the failure of a levee or dam?
LESS-THAN-SIGNIFICANT IMPACT. While the proposed project is located in an area that is designated
a high risk food zone (Zone AE), the proposed building will be above the base flood elevation of
11 feet and would not expose people or structures to a significant risk of loss, injury, or death as a
result of flooding. Additionally, there are no levees or dams near the project area; therefore,
impacts would be less than significant.
j. Would the project result in inundation by seiche, tsunami, or mudflow?
NO IMPACT. The project area is not subject to inundation by seiche, tsunami, or mudflow, therefore
there are no impacts anticipated as a result of the proposed project.
3.10 Land Use and Planning
Would the project:
Potentially
Significant
Impact
Less-Than-
Significant with
Mitigation
Incorporation
Less-Than-
Significant
Impact
No
Impact
a. Physically divide an established community?
b. Conflict with any applicable land use plan, policy, or
regulation of an agency with jurisdiction over the
project (including, but not limited to the general plan,
specific plan, local coastal program, or zoning
ordinance) adopted for the purpose of avoiding or
mitigating an environmental effect?
c. Conflict with any applicable habitat conservation plan
or natural community conservation plan?
3.10.1 Setting
The project is within the existing RWQCP property in the City of Palo Alto in Santa Clara County, CA.
Land use designation at the project site is Public Facilities, with a site and design review overlay, PF (D).
Surrounding zoning districts and land uses include Public Facilities (PF), Planned Community (PC), and
Research, Office and Limited Manufacturing Subdistrict – Embarcadero [ROLM(E)].
3.10.2 Impact Analysis
a. Would the project physically divide an established community?
NO IMPACT. The project is located within the existing RWQCP and would involve the installation of
three BFPs with room to install a future unit for filtration purposes. Construction and operation
would occur on site, with trucks transporting waste away from the facility via City roads. It would
not divide an established community.
b. Would the project conflict with any applicable land use plan, policy, or regulation of an agency
with jurisdiction over the project (including, but not limited to, the general plan, specific plan,
local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an
environmental effect?
NO IMPACT. The project would not conflict with any applicable land use plan, policy, or regulation, it
is consistent with its general plan and zoning designations.
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c. Would the project conflict with any applicable habitat conservation plan or natural community
conservation plan?
NO IMPACT. The project area is not located within a Habitat Conservation Plan or Natural
Community Conservation Plan.
3.11 Mineral Resources
Would the project:
Potentially
Significant
Impact
Less-Than-
Significant with
Mitigation
Incorporation
Less-Than-
Significant
Impact
No
Impact
a. Result in the loss of availability of a known mineral
resource that would be of value to the region and the
residents of the state?
b. Result in the loss of availability of a locally-important
mineral resource recovery site delineated on a local
general plan, specific plan or other land use plan?
3.11.1 Setting
The project is not located in an area of known mineral resources. According to the Natural Environment
Element of the City of Palo Alto’s Comprehensive Plan, the City of Palo Alto does not contain any mineral
deposits of regional significance and therefore does not include any policies relating to mineral
resources (City of Palo Alto, 2007).
3.11.2 Impact Analysis
a. Would the project result in the loss of availability of a known mineral resource that would be of
value to the region and the residents of the state or result in the loss of availability of a
locally-important mineral resource recovery site delineated on a local general plan, specific plan,
or other land use plan?
NO IMPACT. The project area is within Mineral Resource Zone MRZ-1, as classified by the California
Department of Conservation (DOC), Division of Mines and Geology (DMG). MRZ-1 is defined as
“Areas where available geologic information indicates that little likelihood exists for the presence of
significant mineral resources.” (DMG, 1996). Additionally, the City of Palo Alto’s Comprehensive Plan
has noted that it does not contain any mineral deposits of regional significance (City of Palo Alto,
2007). Therefore, there would be no change associated with the proposed project.
b. Would the project result in the loss of availability of a locally-important mineral resource recovery
site delineated on a local general plan, specific plan, or other land use plan?
NO IMPACT. The proposed project would not result in the loss of availability of a mineral resource
recovery site as described in “a.” above.
EN0717151040SAC/658394 (ISMND_ADMINDRAFT) 3-23
SECTION 3 – EVALUATION OF ENVIRONMENTAL IMPACTS
3.12 Noise
Would the project:
Potentially
Significant
Impact
Less-Than-
Significant with
Mitigation
Incorporation
Less-Than-
Significant
Impact
No
Impact
a. Exposure of persons to or generation of noise levels in
excess of standards established in the local general plan
or noise ordinance, or applicable standards of other
agencies?
b. Exposure of persons to or generation of excessive
groundborne vibration or groundborne noise levels?
c. A substantial permanent increase in ambient noise levels
in the project vicinity above levels existing without the
project?
d. A substantial temporary or periodic increase in ambient
noise levels in the project vicinity above levels existing
without the project?
e. For a project located within an airport land use plan or,
where such a plan has not been adopted, within two
miles of a public airport or public use airport, would the
project expose people residing or working in the project
area to excessive noise levels?
f. For a project within the vicinity of a private airstrip,
would the project expose people residing or working in
the project area to excessive noise levels?
3.12.1 Setting
The project site is located east of U.S. Highway 101, near the Palo Alto Baylands and commercial/office
uses. The nearest residence is located approximately 0.7 mile from the project site.
3.12.2 Impact Analysis
a. Exposure of persons to or generation of noise levels in excess of standards established in the local
general plan or noise ordinance, or applicable standards of other agencies?
LESS-THAN-SIGNIFICANT IMPACT. Noise generated by project construction is expected to vary
depending on construction activities. Project construction would occur on weekdays, typically from
8:00 a.m. to 6:00 p.m., Monday through Friday, and from 9:00 a.m. to 6:00 p.m. on Saturdays in
accordance with the City of Palo Alto municipal code. Project construction would generate noise
from the heavy equipment used. Individual pieces of construction equipment are likely to generate
noise levels of 80 to 85 a-weighted decibels (dBA) at 50 feet from the source. Pilings would be
installed to support the sludge dewatering building; however, the piles would be installed using an
auger and no pile driving would occur. The nearest sensitive receptors would be users of the
recreational trails on the adjacent Palo Alto Baylands, approximately 500 feet away. Given the lack
of nearby sensitive receptors, and by following City of Palo Alto noise standards, construction noise
impacts would be less than significant.
Project operations would generate noise from equipment (e.g., belt filter presses and conveyor) and
from haul truck trips. Equipment noise would be contained within the building, and would not
contribute to an increase in exterior ambient noise levels. Truck trips would be limited to
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approximately five truckloads per day. Trucks would enter the RWQCP via Embarcadero Way and
would exit via Embarcadero Road. These roads run through a commercial and industrial area, and
would not drive near sensitive land uses like the Palo Alto Baylands. For these reasons, truck trips
would not contribute to a substantial increase in noise levels that would affect sensitive receptors;
impacts, therefore, would be less than significant.
b. Exposure of persons to or generation of excessive groundborne vibration or groundborne noise
levels?
LESS-THAN-SIGNIFICANT IMPACT. The project construction may temporarily expose persons to ground
vibrations above ambient levels but due to the short duration of the construction project they would
remain less than significant.
c. A substantial permanent increase in ambient noise levels in the project vicinity above levels
existing without the project?
LESS-THAN-SIGNIFICANT IMPACT. See the response to “a” above.
d. A substantial temporary or periodic increase in ambient noise levels in the project vicinity above
levels existing without the project?
LESS-THAN-SIGNIFICANT IMPACT. See the response to “a” above.
e. For a project located within an airport land use plan or, where such a plan has not been adopted,
within two miles of a public airport or public use airport, would the project expose people residing
or working in the project area to excessive noise levels?
NO IMPACT. While the project is 0.5 miles away from the Palo Alto Airport, the project would not
expose people to excessive noise levels from the airport. No impact would occur as a result of the
project.
f. For a project within the vicinity of a private airstrip, would the project expose people residing or
working in the project area to excessive noise levels?
NO IMPACT. The project is not within the vicinity of a private airstrip.
3.13 Population and Housing
Would the project:
Potentially
Significant
Impact
Less-Than-
Significant with
Mitigation
Incorporation
Less-Than-
Significant
Impact
No
Impact
a. Induce substantial population growth in an area, either
directly (for example, by proposing new homes and
businesses) or indirectly (for example, through extension
of roads or other infrastructure)?
b. Displace substantial numbers of existing housing,
necessitating the construction of replacement housing
elsewhere?
c. Displace substantial numbers of people, necessitating the
construction of replacement housing elsewhere?
EN0717151040SAC/658394 (ISMND_ADMINDRAFT) 3-25
SECTION 3 – EVALUATION OF ENVIRONMENTAL IMPACTS
3.13.1 Setting
The proposed project would be constructed within the existing RWQCP, is surrounded by
office/commercial and public facilities land uses, and would not conflict with populations or housing
resources.
3.13.2 Impact Analysis
a. Would the project induce substantial population growth in an area, either directly (for example,
by proposing new homes and businesses) or indirectly (for example, through extension of roads or
other infrastructure)?
NO IMPACT. The proposed project does not expand the capacity of the RWQCP. For this reason, the
project is not expected to induce population growth; therefore there would be no growth inducing
impacts.
b. Would the project displace substantial numbers of existing housing, necessitating the construction
of replacement housing elsewhere?
NO IMPACT. The project would be constructed at the existing RWQCP along developed city streets,
within already developed areas of the City of Palo Alto. Therefore, the project would not displace
any existing housing.
c. Would the project displace substantial numbers of people, necessitating the construction of
replacement housing elsewhere?
NO IMPACT. The project would be constructed at the existing RWQCP along developed city streets,
within already developed areas of the City of Palo Alto. Therefore, the project would not displace
any people and would not necessitate the construction of replacement housing elsewhere.
3.14 Public Services
Would the project result in substantial adverse physical
impacts associated with the provision of new or
physically altered governmental facilities, need for new
or physically altered governmental facilities, the
construction of which could cause significant
environmental impacts, in order to maintain acceptable
service ratios, response times, or other performance
objectives for any of the public services:
Potentially
Significant
Impact
Less-Than-
Significant with
Mitigation
Incorporation
Less-Than-
Significant
Impact No Impact
a. Fire protection?
b. Police protection?
c. Schools?
d. Parks?
e. Other public facilities?
3.14.1 Setting
Public services and facilities are provided and maintained by local municipalities, including fire, police,
and public works.
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3.14.2 Impact Analysis
a. Fire protection?
LESS-THAN-SIGNIFICANT IMPACT. Construction and operation of the project is not expected to
increase the demand for fire protection services in the project area. During construction of the
project, emergencies could occur at the project site; however, appropriate notification to local
emergency service providers prior to construction would address impacts that could affect
emergency response times such as lane closures.
b. Police protection?
NO IMPACT. The project would not increase population and is not anticipated to affect crime rates
in the vicinity. Therefore, additional police protection is not needed.
c. Schools?
NO IMPACT. This is a non-residential project, therefore there would not be a secondary impact
associated with increased demand for schools. The project would not generate additional
population or students during construction or operation.
d. Parks?
NO IMPACT. This is a non-residential project, therefore there would not be a secondary impact
associated with increased demand for parks. The project would not increase the use of existing
neighborhood and regional parks or other recreational facilities.
e. Other public facilities?
NO IMPACT. This is a non-residential project, therefore there would not be a secondary impact
associated with increased demand for public facilities. The project would not result in an increase in
population during project construction or operation; therefore, the project would not affect other
government services or public facilities.
3.15 Recreation
Potentially
Significant
Impact
Less-Than-
Significant with
Mitigation
Incorporation
Less-Than-
Significant
Impact
No
Impact
a. Would the project increase the use of existing
neighborhood and regional parks or other recreational
facilities such that substantial physical deterioration of
the facility would occur or be accelerated?
b. Does the project include recreational facilities or
require the construction or expansion of recreational
facilities which might have an adverse physical effect
on the environment?
3.15.1 Setting
The proposed project is located in a non-residential area of the City of Palo Alto, north of the Palo Alto
Baylands and less than 0.5 miles away from the Palo Alto Golf Course.
EN0717151040SAC/658394 (ISMND_ADMINDRAFT) 3-27
SECTION 3 – EVALUATION OF ENVIRONMENTAL IMPACTS
3.15.2 Impact Analysis
a. Would the project increase the use of existing neighborhood and regional parks or other
recreational facilities such that substantial physical deterioration of the facility would occur or be
accelerated?
NO IMPACT. This is a non-residential project, therefore there would not be a secondary impact
associated with increased demand for recreational facilities. Therefore, there would be no impacts
as a result of this project.
b. Does the project include recreational facilities or require the construction or expansion of
recreational facilities which might have an adverse physical effect on the environment?
NO IMPACT. The project would not increase population, and therefore does not include or require
the construction or expansion of recreational facilities.
3.16 Transportation/Traffic
Would the Project:
Potentially
Significant
Impact
Less-Than-
Significant with
Mitigation
Incorporation
Less-Than-
Significant
Impact
No
Impact
a. Conflict with an applicable plan, ordinance or policy
establishing measures of effectiveness for the
performance of the circulation system, taking into
account all modes of transportation including mass
transit and non-motorized travel and relevant
components of the circulation system, including but not
limited to intersections, streets, highways and
freeways, pedestrian and bicycle paths, and mass
transit?
b. Conflict with an applicable congestion management
program, including, but not limited to level of service
standards and travel demand measures, or other
standards established by the county congestion
management agency for designated roads or highways?
c. Result in a change in air traffic patterns, including
either an increase in traffic levels or a change in
location that results in substantial safety risks?
d. Substantially increase hazards due to a design feature
(e.g., sharp curves or dangerous intersections) or
incompatible uses (e.g., farm equipment)?
e. Result in inadequate emergency access?
f. Conflict with adopted policies, plans, or programs
regarding public transit, bicycle, or pedestrian facilities,
or otherwise decrease the performance or safety of
such facilities?
3.16.1 Setting
The project area is located east of U.S. Highway 101, off of Embarcadero Road and Embarcadero Way in
the City of Palo Alto. The project would involve the use of existing public and private roadways by
construction equipment and crews, and for the operation of transporting the waste load generated by
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the dewatering operations. During construction, approximately 10 vehicles per day are expected to
access the job site. When the facility is operational, an estimated five trucks per day are expected to
access the site for sludge loadout and hauling. All traffic would use Embarcadero Road and Embarcadero
Way to access the truck loadout facility building.
3.16.2 Impact Analysis
a. Conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the
performance of the circulation system, taking into account all modes of transportation including
mass transit and non-motorized travel and relevant components of the circulation system,
including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle
paths, and mass transit?
LESS-THAN-SIGNIFICANT IMPACT. Project operations would require the use of Embarcadero Road and
Embarcadero Way for waste hauling. As identified in the City of Palo Alto Comprehensive Plan,
Embarcadero Road is classified as an arterial roadway that connects business parks and other uses
and channels traffic to U.S. Highway 101. Embarcadero Road is a four-lane arterial with a designated
bike lane and street parking traffic. This portion of Embarcadero Road is not used for public transit.
Applicable plans include Plan Bay Area: Strategy for a Sustainable Region, but nothing in the
applicable plans address the low levels of traffic generated by the project. Therefore, impacts would
be less than significant.
As described in Section 1.8.2, up to 10 trucks would use Embarcadero Road and Embarcadero Way
to access the site during the construction period. Construction activities would temporarily generate
a negligible amount of additional traffic, and local street capacity would not be affected. Therefore,
impacts would be less than significant.
b. Conflict with an applicable congestion management program, including, but not limited to level of
service standards and travel demand measures, or other standards established by the county
congestion management agency for designated roads or highways?
LESS THAN SIGNIFICANT IMPACT. See response to “a” above.
c. Result in a change in air traffic patterns, including either an increase in traffic levels or a change in
location that results in substantial safety risks?
NO IMPACT. The project would have no impact on air traffic patterns.
d. Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm equipment)?
NO IMPACT. The project would be constructed within the existing RWQCP, and does not include
design features that would affect local roadways.
e. Result in inadequate emergency access?
NO IMPACT. The project would be constructed within the existing RWQCP, and does not include
design features that would impede emergency access. Internal circulation around the new building
would exceed the minimum requirements of the California Fire Code.
f. Conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian
facilities, or otherwise decrease the performance or safety of such facilities?
NO IMPACT. The project would be constructed within the existing RWQCP, and does not include
design features that would impede public transit, bicycle, or pedestrian facilities.
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SECTION 3 – EVALUATION OF ENVIRONMENTAL IMPACTS
3.17 Utilities and Service Systems
Would the Project:
Potentially
Significant
Impact
Less-Than-
Significant with
Mitigation
Incorporation
Less-Than-
Significant
Impact
No
Impact
a. Exceed wastewater treatment requirements of the
applicable RWQCB?
b. Require or result in the construction of new water or
wastewater treatment facilities or expansion of
existing facilities, the construction of which could
cause significant environmental effects?
c. Require or result in the construction of new storm
water drainage facilities or expansion of existing
facilities, the construction of which could cause
significant environmental effects?
d. Have sufficient water supplies available to serve the
project from existing entitlements and resources, or
are new or expanded entitlements needed?
e. Result in a determination by the wastewater treatment
provider which serves or may serve the project that it
has adequate capacity to serve the project’s projected
demand in addition to the provider’s existing
commitments?
f. Be served by a landfill with sufficient permitted
capacity to accommodate the project’s solid waste
disposal needs?
g. Comply with federal, state, and local statutes and
regulations related to solid waste?
3.17.1 Setting
The proposed project is located within an urbanized environment within the City of Palo Alto where
utility infrastructure is in place. The proposed project would not include any elements that would
expand or adversely affect most utility services, but would require the offsite disposal of the biosolids
generated by the sludge dewatering facility. The project is being designed based on a need to handle
approximately 32 dry tons per day of biosolids, which is expected to require five trucks (i.e. ten truck
trips) per day to haul offsite for beneficial reuse. At this time, the City may choose one of several options
for disposal.
3.17.2 Impact Analysis
a. Exceed wastewater treatment requirements of the applicable RWQCB?
NO IMPACT. The proposed project site is within an existing RWQCP. The project would introduce a
change in the solids handling process at the plant, but the liquids processing facilities would not be
changed. Therefore, there would be no change in discharges to the San Francisco Bay.
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b. Require or result in the construction of new water or wastewater treatment facilities or expansion
of existing facilities, the construction of which could cause significant environmental effects?
NO IMPACT. The proposed project includes the construction of a new dewatering and truck loadout
facility building, a two story cast-in-place concrete structure that would contain space for the belt
filter presses, truck loadout, and other support areas. These features are new components of an
existing wastewater treatment plant, and would not result in the need for new water or wastewater
treatment services.
c. Require or result in the construction of new storm water drainage facilities or expansion of
existing facilities, the construction of which could cause significant environmental effects?
NO IMPACT. The proposed project would construct the new dewatering and truck loadout facility
building on an existing water quality control plant on property that is already paved with existing
drainage infrastructure. The project would not result or require the construction of new stormwater
drainage facilities or expand an existing one; therefore there would be no impact.
d. Have sufficient water supplies available to serve the project from existing entitlements and
resources, or are new or expanded entitlements needed?
NO IMPACT. There would be no water use from the proposed project, other than minor dust control
during site preparation.
e. Result in a determination by the wastewater treatment provider which serves or may serve the
project that it has adequate capacity to serve the project’s projected demand in addition to the
provider’s existing commitments?
NO IMPACT. The project features are new components of an existing wastewater treatment plant,
and would not result in the need new wastewater treatment services.
f. Be served by a landfill with sufficient permitted capacity to accommodate the project’s solid
waste disposal needs?
LESS-THAN-SIGNIFICANT IMPACT. The proposed project would generate up to approximately 32 dry
tons per day of material for offsite beneficial reuse, requiring up to five haul trucks (ten trips total)
per day. Although the final destination is not known, one option is for biosolids reuse as alternative
daily cover (ADC) at the Potrero Hills or Hay Road landfills in Solano County.1 Both facilities accept
biosolids for beneficial use. Capacity at landfills located closer to Palo Alto where biosolids are
accepted for ADC is unlikely; for example, ADC needs at the Newby Island Landfill are already being
fully met by biosolids from the San José-Santa Clara Regional Wastewater Facility. Because of the
willingness of the Solano County landfills to accept biosolids as ADC, impacts would be less than
significant.
g. Comply with federal, state, and local statutes and regulations related to solid waste?
LESS-THAN-SIGNIFICANT IMPACT. The project includes beneficial reuse of biosolids, consistent with
state regulations. The regulation of biosolids in California involves multiple agencies at the federal,
state, and local levels. The extent to which biosolids are regulated is greatly dependent on the
treatment technology used, as well as the end use of the biosolids. California’s biosolids program is
regulated by USEPA Region IX pursuant to 40 Code of Federal Regulations (CFR) 503, “Standards for
the Use and Disposal of Sewage Sludge” (i.e., the 503 Rule). The 503 Rule establishes standards such
as pollutant limits, pathogen reduction requirements, and vector attraction reduction requirements.
1 Alternative daily cover means cover material other than earthen material placed on the surface of the active face of a municipal solid waste
landfill at the end of each operating day to control vectors, fires, odors, blowing litter, and scavenging. Federal regulations require landfill
operators to use six inches of earth material as daily cover unless other materials are allowed as alternatives. CalRecycle has approved 11 ADC
material types, including biosolids from municipal wastewater treatment plants.
EN0717151040SAC/658394 (ISMND_ADMINDRAFT) 3-31
SECTION 3 – EVALUATION OF ENVIRONMENTAL IMPACTS
In addition, the California Department of Resources Recycling and Recovery (CalRecycle) has
approved the use of biosolids from municipal wastewater treatment facilities as ADC. ADC is not
considered landfill disposal because it provides beneficial use as landfill cover. With compliance with
existing regulations for biosolids reuse, impacts would be less than significant.
3.18 Mandatory Findings of Significance
Potentially
Significant
Impact
Less-Than-
Significant with
Mitigation
Incorporation
Less-Than-
Significant
Impact
No
Impact
a. Does the project have the potential to degrade the
quality of the environment, substantially reduce the
habitat of a fish or wildlife species, cause a fish or
wildlife population to drop below self-sustaining levels,
threaten to eliminate a plant or animal community,
reduce the number or restrict the range of a rare or
endangered plant or animal or eliminate important
examples of the major periods of California history or
prehistory?
b. Does the project have impacts that are individually
limited, but cumulatively considerable? (“Cumulatively
considerable” means that the incremental effects of a
project are considerable when viewed in connection
with the effects of past projects, the effects of other
current projects, and the effects of probable future
projects?
c. Does the project have environmental effects which will
cause substantial adverse effects on human beings,
either directly or indirectly?
a. Does the project have the potential to degrade the quality of the environment, substantially
reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below
self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or
restrict the range of a rare or endangered plant or animal or eliminate important examples of the
major periods of California history or prehistory?
LESS-THAN-SIGNIFICANT IMPACT WITH MITIGATION INCORPORATED. As indicated throughout this
Initial Study, impacts on all environmental resources were deemed to result in either ‘no impact,’ a
‘less-than-significant impact,’ or ‘less than significant with mitigation incorporation.’ As a result, the
project with proposed mitigation measures would not create environmental effects that would
degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species,
cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant
or animal community, reduce the number or restrict the range of a rare or endangered plant or
animal community, or eliminate important examples of major periods of California history or
prehistory.
b. Does the project have impacts that are individually limited, but cumulatively considerable?
“Cumulatively considerable” means that the incremental effects of a project are considerable
when viewed in connection with the effects of past projects, the effects of other current projects,
and the effects of probable future projects?
LESS-THAN-SIGNIFICANT IMPACT. As indicated throughout this Initial Study, impacts on all
environmental resources were deemed to result in either ‘no impact,’ a ‘less-than-significant
3-32 EN0717151040SAC/658394 (ISMND_ADMINDRAFT)
SECTION 3 – EVALUATION OF ENVIRONMENTAL IMPACTS
impact,’ or ‘less than significant with mitigation incorporation.’ As a result, the project with
proposed mitigation measures would not create environmental effects that would have impacts that
are individually limited but cumulatively considerable.
c. Does the project have environmental effects which will cause substantial adverse effects on
human beings, either directly or indirectly?
LESS-THAN-SIGNIFICANT IMPACT. As indicated throughout this Initial Study, impacts on all
environmental resources were deemed to result in either ‘no impact,’ a ‘less-than-significant
impact,’ or ‘less than significant with mitigation incorporation.’ As a result, the project with
proposed mitigation measures would not create environmental effects that would cause substantial
adverse effects on human beings, either directly or indirectly.
EN0717151040SAC/658394 (ISMND_ADMINDRAFT) 3-33
SECTION 4
List of Preparers
4.1 CH2M HILL
Danielle Tannourji, Biologist
Elyse Engel, Environmental Engineer
Matt Franck, Environmental Planner – Task Manager
Yassaman Sarvian, Environmental Planner
Heather Waldrop, Environmental Planner
EN0717151040SAC/658394 (ISMND_ADMINDRAFT) 4-1
SECTION 5
References
American Society of Civil Engineers (ASCE). 2010. Minimum Design Loads for Buildings and Other
Structures. ASCE/SEI 07-10.
Bay Area Air Quality Management District (BAAQMD). 2012. California Environmental Quality Act Air
Quality Guidelines. http://www.baaqmd.gov/Divisions/Planning-and-Research/CEQA-
GUIDELINES/Updated-CEQA-Guidelines.aspx. Updated May 2012.
Bay Area Air Quality Management District (BAAQMD). 2010a. Bay Area 2010 Clean Air Plan. September.
Bay Area Air Quality Management District (BAAQMD). 2010b. California Environmental Quality Act
(CEQA) Air Quality Guidelines.
http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/CEQA/Draft_BAAQMD_CEQA_G
uidelines_May_2010_Final.ashx?la=en. May. Accessed August 30, 2013.
Bay Area Air Quality Management District (BAAQMD). 2010c. Source Inventory of Bay Area Greenhouse
Gas Emissions. February.
Bay Area Air Quality Management District (BAAQMD). 2010d. Source Inventory of Bay Area Greenhouse
Gas Emissions. February.
Bay Area Air Quality Management District (BAAQMD). 2009. Revised Draft Options and Justification
Report. October.
Bay Area Air Quality Management District (BAAQMD). 2001. San Francisco Bay Area 2001 Ozone
Attainment Plan for the 1-hour National Ozone Standard. October.
California Air Pollution Control Officers Association (CAPCOA). 2013. California Emission Estimator Model
User’s Guide Version 2013.2. July.
California Air Resources Board (CARB). 2013.
http://www.arb.ca.gov/cc/inventory/data/tables/ghg_inventory_scopingplan_00-11_2013-08-01.pdf.
Accessed September 6, 2013.
California Air Resources Board (CARB). 2011. EMFAC2011. http://www.arb.ca.gov/msei/modeling.htm/.
California Building Standards Commission (CBC). 2013. 2013 California Building Code (CBC).
California Department of Fish and Wildlife (CDFW). 2015. Rarefind. California Natural Diversity Database
(CNDDB). Accessed on May 5, 2015.
California Department of Toxic Substances Control. 2013. EnviroStor Database.
http://www.envirostor.dtsc.ca.gov/public/. Accessed May 2015.
Carollo Engineers. 2012. Long Range Facilities Plan Final Report. October.
CH2M HILL. 2015. Technical Memorandum 3 – Geotechnical Draft. May.
City of Palo Alto. 2007. City of Palo Alto Comprehensive Plan. July.
California Department of Conservation, Division of Mines and Geology. 1996. Update of Mineral Land
Classification: Aggregate Materials in the South San Francisco Bay Production-Consumption Region.
Accessed on May 12, 2015.
ENVIRON. 2013. CalEEMod User’s Guide. September.
Jones & Stokes Associates. 2007. Software User’s Guide: URBEMIS2007 for Windows. November.
EN0717151040SAC/658394 (ISMND_ADMINDRAFT) 5-1
SECTION 5 – REFERENCES
U.S. Environmental Protection Agency. 2006. AP-42, Fifth Edition, Volume I. Chapter 13: Miscellaneous
Sources. Section 13.2.2, Unpaved Roads. November.
U.S. Environmental Protection Agency. 2011. AP-42, Fifth Edition, Volume I. Chapter 13: Miscellaneous
Sources. Section 13.2.1, Paved Roads. January.
William Self Associates, INC. 2007. Cultural Resource Assessment Palo Alto Regional Water Quality
Control Plant UV Disinfection Project. October.
5-2 EN0717151040SAC/658394 (ISMND_ADMINDRAFT)
Appendix A
Air Quality and Greenhouse Gas
Emissions Output Files
TABLE A‐1
Construction Emissions Summary
Palo Alto Dewatering Building Project
Construction Emissions
VOC CO NOx SOx PM10_Exhaust PM2.5_Exhaust PM10_Fugitive PM2.5_Fugitive
Max Daily Emissions (lbs/day) 3.96 25.27 47.41 0.07 2.14 1.94 80.14 14.83
Project Emissions (tons/project) 0.31 1.94 3.67 0.01 0.16 0.14 0.30 0.06
BAAQMD Thresholds of Significance (lbs/day) b 54 N/A 54 N/A 82 54 N/A N/A
Exceeds Threshold (Y/N)? N N N N N N N N
CO2 CO2e c
Max Daily Emissions (lbs/day) 6,921 7,267
Project Emissions (metric tons/project) 554 581.95
CARB Thresholds of Significance (metric tons/year) d N/A 7,000
Exceeds Threshold (Y/N)? N N
Notes:
b BAAQMD Thresholds of Significance taken from Table 2‐1 of the Draft CEQA Air Quality Guidelines (BAAQMD, 2010).
d CARB Thresholds of Significance taken as the statewide interim thresholds of significance for GHGs (CARB, 2008).
Construction Activities
Construction Activities
GHG Emissions a
Criteria Pollutant Emissions a
c Only CO2 emission factors were available for all types of construction equipment utilized for this project. According to the EPA, emissions of CH4 and N2O from passenger vehicles are
expected to be much lower than emissions of CO2, contributing in the range of 5 to 6 percent of the total CO2e emissions (EPA, 2005). Therefore, assuming the passenger vehicle research is
applicable to all mobile emission sources, the CO2 emissions were conservatively increased by 5 percent to calculate CO2e emissions, accounting for the potential CH4 and N2O emissions
associated with construction activities.
a It was assumed that the four construction phases would occur sequentially and that, within each phase, some equipment/vehicles may operate concurrently but that sub‐tasks would
largely occur sequentially. Refer to Table 1.A‐1 for clarification on what sub‐tasks may occur concurrently.
EN0717151040SAC Page 1 of 1
TABLE A‐2
Construction Emissions
Palo Alto Dewatering Building Project
VOC CO NOx SOx PM10_Exhaust PM2.5_Exhaust PM10_Fugitive PM2.5_Fugitive CO2
Sitework
Earthwork (Test Pits and Survey)
Cat 420 E Construction Equipment 1 ‐‐210‐‐0.430 3.047 4.111 0.004 0.316 0.291 ‐‐ ‐‐408.761
Pickup e Offsite Light‐duty Truck 4 ‐‐2 ‐‐14.6 0.005 0.198 0.020 0.000 0.005 0.002 0.034 0.008 37.958
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐2 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
Earthwork (Rough Grading and Survey)
Cat D 6 Construction Equipment 1 ‐‐210‐‐0.885 3.555 11.924 0.010 0.460 0.423 ‐‐ ‐‐1,000.393
Pickup e Offsite Light‐duty Truck 4 ‐‐2 ‐‐14.6 0.005 0.198 0.020 0.000 0.005 0.002 0.034 0.008 37.958
Grader Cat 140M 17 Construction Equipment 1 ‐‐210‐‐1.281 6.195 13.049 0.008 0.733 0.674 ‐‐ ‐‐816.410
Fugitive Dust g Disturbed Surface 0.70 acres 2 ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐3.512 0.731 ‐‐
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐2 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
Earthwork (Mass Excavation and Survey)
Cat D 6 Construction Equipment 1 ‐‐110‐‐0.885 3.555 11.924 0.010 0.460 0.423 ‐‐ ‐‐1,000.393
Pickup e Offsite Light‐duty Truck 3 ‐‐1 ‐‐14.6 0.004 0.170 0.017 0.000 0.005 0.002 0.029 0.007 32.536
Water Truck Onsite Heavy‐duty Diesel 1 ‐‐1 ‐‐5 0.022 0.055 0.228 0.000 0.003 0.003 9.961 0.996 37.572
Grader Cat 140M 17 Construction Equipment 1 ‐‐110‐‐1.281 6.195 13.049 0.008 0.733 0.674 ‐‐ ‐‐816.410
Scraper Cat 621 G Construction Equipment 1 ‐‐110‐‐1.733 13.815 22.055 0.019 0.889 0.818 ‐‐ ‐‐1,939.670
Fugitive Dust h Onsite Cut/Fill 560 yd3 1 ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐66.080 13.745 ‐‐
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐1 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
AC Paving (Fine Grade Roadway) and Concrete Paving
Grader 30000 lbs Construction Equipment 1 ‐‐110‐‐1.281 6.195 13.049 0.008 0.733 0.674 ‐‐ ‐‐816.410
2 Ton Flatbed Crew Truck e Offsite Heavy‐duty Diesel 4 ‐‐1 ‐‐14.6 0.025 0.100 0.759 0.002 0.020 0.012 0.039 0.010 218.619
Concrete Material Loads e Offsite Heavy‐duty Diesel 1 ‐‐1 ‐‐40 0.017 0.068 0.520 0.001 0.014 0.008 0.026 0.007 149.739
Fugitive Dust g Disturbed Surface 0.17 acres 1 ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐0.000 0.000 ‐‐
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐1 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
AC Paving (Sidewalk/Drive Concrete) and Concrete Paving
Vibraplate Construction Equipment 1 ‐‐110‐‐0.050 0.263 0.314 0.001 0.012 0.012 ‐‐ ‐‐43.099
2 Ton Flatbed Crew Truck e Offsite Heavy‐duty Diesel 4 ‐‐1 ‐‐14.6 0.025 0.100 0.759 0.002 0.020 0.012 0.039 0.010 218.619
Concrete Material Loads e Offsite Heavy‐duty Diesel 1 ‐‐1 ‐‐40 0.017 0.068 0.520 0.001 0.014 0.008 0.026 0.007 149.739
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐1 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
AC Paving (Base Course) and Concrete Paving
Grader 30000 lbs Construction Equipment 1 ‐‐110‐‐1.281 6.195 13.049 0.008 0.733 0.674 ‐‐ ‐‐816.410
25 Ton Vibrating Roller Construction Equipment 1 ‐‐110‐‐0.426 2.548 3.940 0.003 0.290 0.267 ‐‐ ‐‐344.849
Dozer 300 hp Construction Equipment 1 ‐‐110‐‐1.132 7.804 15.013 0.014 0.582 0.535 ‐‐ ‐‐1,451.359
1.5 CY Loader Construction Equipment 1 ‐‐110‐‐0.624 2.305 8.119 0.008 0.277 0.255 ‐‐ ‐‐799.451
Water Truck Onsite Heavy‐duty Diesel 1 ‐‐1 ‐‐5 0.022 0.055 0.228 0.000 0.003 0.003 9.961 0.996 37.572
2 Ton Flatbed Crew Truck e Offsite Heavy‐duty Diesel 4 ‐‐1 ‐‐14.6 0.025 0.100 0.759 0.002 0.020 0.012 0.039 0.010 218.619
Concrete Material Loads e Offsite Heavy‐duty Diesel 3 ‐‐1 ‐‐40 0.051 0.204 1.559 0.004 0.042 0.025 0.079 0.020 449.218
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐1 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
AC Paving (Sub Base) and Concrete Paving
Grader 30000 lbs Construction Equipment 1 ‐‐110‐‐1.281 6.195 13.049 0.008 0.733 0.674 ‐‐ ‐‐816.410
25 Ton Vibrating Roller Construction Equipment 1 ‐‐110‐‐0.426 2.548 3.940 0.003 0.290 0.267 ‐‐ ‐‐344.849
2 Ton Flatbed Crew Truck e Offsite Heavy‐duty Diesel 4 ‐‐1 ‐‐14.6 0.025 0.100 0.759 0.002 0.020 0.012 0.039 0.010 218.619
Concrete Material Loads e Offsite Heavy‐duty Diesel 3 ‐‐1 ‐‐40 0.051 0.204 1.559 0.004 0.042 0.025 0.079 0.020 449.218
Fugitive Dust i Aggregates 146 tons 1 ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐2.958 0.448 ‐‐
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐1 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
AC Paving (Bituminous Stabilizer) and Concrete Paving
3000 Gal Tanker Onsite Heavy‐duty Diesel 1 ‐‐1 ‐‐40 0.179 0.441 1.826 0.003 0.028 0.021 79.685 7.968 300.573
Tractor Truck 380 hp Offsite Heavy‐duty Diesel 1 ‐‐1 ‐‐14.6 0.006 0.025 0.190 0.001 0.005 0.003 0.010 0.002 54.655
2 Ton Flatbed Crew Truck e Offsite Heavy‐duty Diesel 4 ‐‐1 ‐‐14.6 0.025 0.100 0.759 0.002 0.020 0.012 0.039 0.010 218.619
Concrete Material Loads e Offsite Heavy‐duty Diesel 3 ‐‐1 ‐‐40 0.051 0.204 1.559 0.004 0.042 0.025 0.079 0.020 449.218
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐1 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
AC Paving (Plant Mix AC Paving) and Concrete Paving
Paving Machine 130 hp Construction Equipment 1 ‐‐110‐‐0.387 3.203 4.493 0.005 0.223 0.205 ‐‐ ‐‐524.853
10 Ton Steel Roller Construction Equipment 1 ‐‐110‐‐0.426 2.548 3.940 0.003 0.290 0.267 ‐‐ ‐‐344.849
12 Ton Pneumatic Roller Construction Equipment 1 ‐‐110‐‐0.426 2.548 3.940 0.003 0.290 0.267 ‐‐ ‐‐344.849
2 Ton Flatbed Crew Truck e Offsite Heavy‐duty Diesel 4 ‐‐1 ‐‐14.6 0.025 0.100 0.759 0.002 0.020 0.012 0.039 0.010 218.619
Concrete Material Loads e Offsite Heavy‐duty Diesel 1 ‐‐1 ‐‐40 0.017 0.068 0.520 0.001 0.014 0.008 0.026 0.007 149.739
Fugitive Dust i Aggregates 61 tons 1 ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐0.000 0.000 ‐‐
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐1 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
AC Paving (Place Concrete) and Concrete Paving
2 Ton Flatbed Crew Truck e Offsite Heavy‐duty Diesel 5 ‐‐1 ‐‐14.6 0.031 0.124 0.949 0.003 0.025 0.015 0.048 0.012 273.274
Concrete Material Loads e Offsite Heavy‐duty Diesel 1 ‐‐1 ‐‐40 0.017 0.068 0.520 0.001 0.014 0.008 0.026 0.007 149.739
Fugitive Dust j Paving 0.0376 acres 1 ‐‐ ‐‐0.099 ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐1 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
Miles per Day c
Emissions (lbs/day) d
Equipment / Vehicle List a Quantity a Hours per Day b
Number of Days
Used aEquipment / Vehicle Type
Quantity
Units
EN0717151040SAC Page 1 of 7
TABLE A‐2
Construction Emissions
Palo Alto Dewatering Building Project
Sitework
Earthwork (Test Pits and Survey)
Cat 420 E
Pickup e
Worker Commute f
Earthwork (Rough Grading and Survey)
Cat D 6
Pickup e
Grader Cat 140M 17
Fugitive Dust g
Worker Commute f
Earthwork (Mass Excavation and Survey)
Cat D 6
Pickup e
Water Truck
Grader Cat 140M 17
Scraper Cat 621 G
Fugitive Dust h
Worker Commute f
AC Paving (Fine Grade Roadway) and Concrete Paving
Grader 30000 lbs
2 Ton Flatbed Crew Truck e
Concrete Material Loads e
Fugitive Dust g
Worker Commute f
AC Paving (Sidewalk/Drive Concrete) and Concrete Paving
Vibraplate
2 Ton Flatbed Crew Truck e
Concrete Material Loads e
Worker Commute f
AC Paving (Base Course) and Concrete Paving
Grader 30000 lbs
25 Ton Vibrating Roller
Dozer 300 hp
1.5 CY Loader
Water Truck
2 Ton Flatbed Crew Truck e
Concrete Material Loads e
Worker Commute f
AC Paving (Sub Base) and Concrete Paving
Grader 30000 lbs
25 Ton Vibrating Roller
2 Ton Flatbed Crew Truck e
Concrete Material Loads e
Fugitive Dust i
Worker Commute f
AC Paving (Bituminous Stabilizer) and Concrete Paving
3000 Gal Tanker
Tractor Truck 380 hp
2 Ton Flatbed Crew Truck e
Concrete Material Loads e
Worker Commute f
AC Paving (Plant Mix AC Paving) and Concrete Paving
Paving Machine 130 hp
10 Ton Steel Roller
12 Ton Pneumatic Roller
2 Ton Flatbed Crew Truck e
Concrete Material Loads e
Fugitive Dust i
Worker Commute f
AC Paving (Place Concrete) and Concrete Paving
2 Ton Flatbed Crew Truck e
Concrete Material Loads e
Fugitive Dust j
Worker Commute f
Equipment / Vehicle List a VOC CO NOx SOx PM10_Exhaust PM2.5_Exhaust PM10_Fugitive PM2.5_Fugitive
0.000 0.003 0.004 0.000 0.000 0.000 ‐‐ ‐‐0.371
0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.034
0.000 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.300
0.001 0.004 0.012 0.000 0.000 0.000 ‐‐ ‐‐0.908
0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.034
0.001 0.006 0.013 0.000 0.001 0.001 ‐‐ ‐‐0.741
‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐0.004 0.001 ‐‐
0.000 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.300
0.000 0.002 0.006 0.000 0.000 0.000 ‐‐ ‐‐0.454
0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.015
0.000 0.000 0.000 0.000 0.000 0.000 0.005 0.000 0.017
0.001 0.003 0.007 0.000 0.000 0.000 ‐‐ ‐‐0.370
0.001 0.007 0.011 0.000 0.000 0.000 ‐‐ ‐‐0.880
‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐0.033 0.007 ‐‐
0.000 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.150
0.001 0.003 0.007 0.000 0.000 0.000 ‐‐ ‐‐0.370
0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.099
0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.068
‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐0.000 0.000 ‐‐
0.000 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.150
0.000 0.000 0.000 0.000 0.000 0.000 ‐‐ ‐‐0.020
0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.099
0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.068
0.000 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.150
0.001 0.003 0.007 0.000 0.000 0.000 ‐‐ ‐‐0.370
0.000 0.001 0.002 0.000 0.000 0.000 ‐‐ ‐‐0.156
0.001 0.004 0.008 0.000 0.000 0.000 ‐‐ ‐‐0.658
0.000 0.001 0.004 0.000 0.000 0.000 ‐‐ ‐‐0.363
0.000 0.000 0.000 0.000 0.000 0.000 0.005 0.000 0.017
0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.099
0.000 0.000 0.001 0.000 0.000 0.000 0.000 0.000 0.204
0.000 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.150
0.001 0.003 0.007 0.000 0.000 0.000 ‐‐ ‐‐0.370
0.000 0.001 0.002 0.000 0.000 0.000 ‐‐ ‐‐0.156
0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.099
0.000 0.000 0.001 0.000 0.000 0.000 0.000 0.000 0.204
‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐0.001 0.000 ‐‐
0.000 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.150
0.000 0.000 0.001 0.000 0.000 0.000 0.040 0.004 0.136
0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.025
0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.099
0.000 0.000 0.001 0.000 0.000 0.000 0.000 0.000 0.204
0.000 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.150
0.000 0.002 0.002 0.000 0.000 0.000 ‐‐ ‐‐0.238
0.000 0.001 0.002 0.000 0.000 0.000 ‐‐ ‐‐0.156
0.000 0.001 0.002 0.000 0.000 0.000 ‐‐ ‐‐0.156
0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.099
0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.068
‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐0.000 0.000 ‐‐
0.000 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.150
0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.124
0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.068
0.000 ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐
0.000 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.150
Emissions (tons/project) d CO2 Emissions (metric
tons/project) d
EN0717151040SAC Page 2 of 7
TABLE A‐2
Construction Emissions
Palo Alto Dewatering Building Project
VOC CO NOx SOx PM10_Exhaust PM2.5_Exhaust PM10_Fugitive PM2.5_Fugitive CO2Miles per Day c
Emissions (lbs/day) d
Equipment / Vehicle List a Quantity a Hours per Day b
Number of Days
Used aEquipment / Vehicle Type
Quantity
Units
Buried 4" DIP (Excavation), Buried 6" DIP (Excavation), Buried 6" PVC
(Excavation), Copper Pipe (Excavation), and Buried HDPE 2" (Excavation)
Cat 320 DL Construction Equipment 1 ‐‐310‐‐0.488 4.312 5.573 0.007 0.274 0.252 ‐‐ ‐‐691.629
Cat 416E Construction Equipment 1 ‐‐210‐‐0.430 3.047 4.111 0.004 0.316 0.291 ‐‐ ‐‐408.761
Fugitive Dust h Onsite Cut/Fill 930 yd3 3 ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐36.584 7.609 ‐‐
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐3 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
Buried 4" DIP (Backfill Pipe Zone), Buried 6" DIP (Backfill Pipe Zone), Buried 6"
PVC (Backfill Pipe Zone), Copper Pipe (Backfill Pipe Zone), and Buried HDPE 2"
(Backfill Pipe Zone)
Cat 320 DL Construction Equipment 1 ‐‐310‐‐0.488 4.312 5.573 0.007 0.274 0.252 ‐‐ ‐‐691.629
Loader Cat 938 H Construction Equipment 1 ‐‐310‐‐0.624 2.305 8.119 0.008 0.277 0.255 ‐‐ ‐‐799.451
Roller Bomag BW65H e Construction Equipment 2 ‐‐310‐‐0.710 4.247 6.566 0.006 0.483 0.445 ‐‐ ‐‐574.749
Pipe Bedding Material Loads e Offsite Heavy‐duty Diesel 2 ‐‐2 ‐‐40 0.034 0.136 1.040 0.003 0.028 0.016 0.053 0.013 299.478
Offhaul Loads Offsite Heavy‐duty Diesel 1 ‐‐1 ‐‐40 0.017 0.068 0.520 0.001 0.014 0.008 0.026 0.007 149.739
Cat 416E Construction Equipment 1 ‐‐210‐‐0.430 3.047 4.111 0.004 0.316 0.291 ‐‐ ‐‐408.761
Fugitive Dust h Offsite Cut/Fill 88 yd3 3 ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐12.962 2.696 ‐‐
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐3 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
Buried 4" DIP (Backfill Above Pipe Zone) and Buried 6" DIP (Backfill Above Pipe
Zone)
Loader 950H Construction Equipment 1 ‐‐210‐‐0.624 2.305 8.119 0.008 0.277 0.255 ‐‐ ‐‐799.451
Water Truck Onsite Heavy‐duty Diesel 1 ‐‐2 ‐‐5 0.022 0.055 0.228 0.000 0.003 0.003 9.961 0.996 37.572
50" Vibratory Roller Construction Equipment 1 ‐‐210‐‐0.426 2.548 3.940 0.003 0.290 0.267 ‐‐ ‐‐344.849
Pipe Bedding Material Loads e Offsite Heavy‐duty Diesel 15 ‐‐2 ‐‐40 0.255 1.022 7.797 0.021 0.209 0.123 0.397 0.099 2,246.089
Offhaul Loads e Offsite Heavy‐duty Diesel 6 ‐‐2 ‐‐40 0.094 0.375 2.859 0.008 0.077 0.045 0.146 0.036 823.566
Fugitive Dust h Offsite Cut/Fill 41 yd3 2 ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐0.000 0.000 ‐‐
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐2 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
Buried 4" DIP (Pipe Installations), Buried 6" DIP (Pipe Installations), Buried 6"
PVC (Pipe Installations), Copper Pipe (Pipe Installations), and Buried HDPE 2"
(Pipe Installations)
Cat 416E Construction Equipment 1 ‐‐810‐‐0.430 3.047 4.111 0.004 0.316 0.291 ‐‐ ‐‐408.761
2 Ton Flatbed Crew Truck e Offsite Heavy‐duty Diesel 2 ‐‐13 ‐‐14.6 0.011 0.042 0.321 0.001 0.009 0.005 0.016 0.004 92.493
Rammax Construction Equipment 1 ‐‐810‐‐0.426 2.548 3.940 0.003 0.290 0.267 ‐‐ ‐‐344.849
Cat 320 DL Construction Equipment 1 ‐‐13 10 ‐‐0.488 4.312 5.573 0.007 0.274 0.252 ‐‐ ‐‐691.629
Loader Cat 938 H Construction Equipment 1 ‐‐13 10 ‐‐0.624 2.305 8.119 0.008 0.277 0.255 ‐‐ ‐‐799.451
Pickup e Offsite Light‐duty Truck 1 ‐‐13 ‐‐14.6 0.002 0.061 0.006 0.000 0.002 0.001 0.010 0.003 11.679
66" Vibratory Roller e Construction Equipment 1 ‐‐13 10 ‐‐0.459 2.744 4.243 0.004 0.312 0.287 ‐‐ ‐‐371.376
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐13 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
Buried 4" DIP (Tie in Existing) and 48" Manholes
Cat 416E Construction Equipment 1 ‐‐110‐‐0.430 3.047 4.111 0.004 0.316 0.291 ‐‐ ‐‐408.761
2 Ton Flatbed Crew Truck e Offsite Heavy‐duty Diesel 2 ‐‐1 ‐‐14.6 0.012 0.050 0.379 0.001 0.010 0.006 0.019 0.005 109.310
Rammax Construction Equipment 1 ‐‐110‐‐0.426 2.548 3.940 0.003 0.290 0.267 ‐‐ ‐‐344.849
Crane 30 Ton Construction Equipment 1 ‐‐110‐‐0.900 3.731 10.664 0.007 0.484 0.445 ‐‐ ‐‐732.781
Cat 320 DL Construction Equipment 1 ‐‐110‐‐0.488 4.312 5.573 0.007 0.274 0.252 ‐‐ ‐‐691.629
Loader Cat 938 H Construction Equipment 1 ‐‐110‐‐0.624 2.305 8.119 0.008 0.277 0.255 ‐‐ ‐‐799.451
Pickup Offsite Light‐duty Truck 1 ‐‐1 ‐‐14.6 0.001 0.057 0.006 0.000 0.002 0.001 0.010 0.002 10.845
66" Vibratory Roller Construction Equipment 1 ‐‐110‐‐0.426 2.548 3.940 0.003 0.290 0.267 ‐‐ ‐‐344.849
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐1 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
Sitework Maximum 3.960 25.267 47.414 0.044 2.141 1.941 80.141 14.830 4,582.487
Dewatering Building
Crane and 24" Thick Slab
150 Ton Crane e Construction Equipment 1 ‐‐40 10 ‐‐0.900 3.731 10.664 0.007 0.484 0.445 ‐‐ ‐‐732.781
2 Ton Flatbed Crew Truck e Offsite Heavy‐duty Diesel 3 ‐‐67 ‐‐14.6 0.021 0.083 0.634 0.002 0.017 0.010 0.032 0.008 182.727
Concrete Pump Construction Equipment 1 ‐‐510‐‐0.836 4.828 6.137 0.008 0.445 0.445 ‐‐ ‐‐778.780
Concrete Material Loads Offsite Heavy‐duty Diesel 1 ‐‐67 ‐‐40 0.017 0.068 0.520 0.001 0.014 0.008 0.026 0.007 149.739
Fugitive Dust g Disturbed Surface 0.18 acres 67 ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐0.026 0.005 ‐‐
Fugitive Dust i Aggregates 513 tons 67 ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐0.156 0.024 ‐‐
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐67 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
Crane, 12" Straight Walls, 24" Straight Walls, Concrete Stairs, and Masonry 8"
Walls
150 Ton Crane e Construction Equipment 1 ‐‐30 10 ‐‐0.900 3.731 10.664 0.007 0.484 0.445 ‐‐ ‐‐732.781
2 Ton Flatbed Crew Truck e Offsite Heavy‐duty Diesel 18 ‐‐46 ‐‐14.6 0.109 0.436 3.328 0.009 0.089 0.053 0.170 0.042 958.836
Concrete Pump e Construction Equipment 2 ‐‐610‐‐1.533 8.851 11.250 0.015 0.817 0.817 ‐‐ ‐‐1,427.764
Concrete Material Loads e Offsite Heavy‐duty Diesel 2 ‐‐46 ‐‐40 0.034 0.136 1.040 0.003 0.028 0.016 0.053 0.013 299.478
Fugitive Dust i Aggregates 421 tons 46 ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐0.186 0.028 ‐‐
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐46 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
Crane and 12" Elevated Slab
150 Ton Crane e Construction Equipment 1 ‐‐30 10 ‐‐0.900 3.731 10.664 0.007 0.484 0.445 ‐‐ ‐‐732.781
EN0717151040SAC Page 3 of 7
TABLE A‐2
Construction Emissions
Palo Alto Dewatering Building Project
Equipment / Vehicle List a
Buried 4" DIP (Excavation), Buried 6" DIP (Excavation), Buried 6" PVC
(Excavation), Copper Pipe (Excavation), and Buried HDPE 2" (Excavation)
Cat 320 DL
Cat 416E
Fugitive Dust h
Worker Commute f
Buried 4" DIP (Backfill Pipe Zone), Buried 6" DIP (Backfill Pipe Zone), Buried 6"
PVC (Backfill Pipe Zone), Copper Pipe (Backfill Pipe Zone), and Buried HDPE 2"
(Backfill Pipe Zone)
Cat 320 DL
Loader Cat 938 H
Roller Bomag BW65H e
Pipe Bedding Material Loads e
Offhaul Loads
Cat 416E
Fugitive Dust h
Worker Commute f
Buried 4" DIP (Backfill Above Pipe Zone) and Buried 6" DIP (Backfill Above Pipe
Zone)
Loader 950H
Water Truck
50" Vibratory Roller
Pipe Bedding Material Loads e
Offhaul Loads e
Fugitive Dust h
Worker Commute f
Buried 4" DIP (Pipe Installations), Buried 6" DIP (Pipe Installations), Buried 6"
PVC (Pipe Installations), Copper Pipe (Pipe Installations), and Buried HDPE 2"
(Pipe Installations)
Cat 416E
2 Ton Flatbed Crew Truck e
Rammax
Cat 320 DL
Loader Cat 938 H
Pickup e
66" Vibratory Roller e
Worker Commute f
Buried 4" DIP (Tie in Existing) and 48" Manholes
Cat 416E
2 Ton Flatbed Crew Truck e
Rammax
Crane 30 Ton
Cat 320 DL
Loader Cat 938 H
Pickup
66" Vibratory Roller
Worker Commute f
Sitework Maximum
Dewatering Building
Crane and 24" Thick Slab
150 Ton Crane e
2 Ton Flatbed Crew Truck e
Concrete Pump
Concrete Material Loads
Fugitive Dust g
Fugitive Dust i
Worker Commute f
Crane, 12" Straight Walls, 24" Straight Walls, Concrete Stairs, and Masonry 8"
Walls
150 Ton Crane e
2 Ton Flatbed Crew Truck e
Concrete Pump e
Concrete Material Loads e
Fugitive Dust i
Worker Commute f
Crane and 12" Elevated Slab
150 Ton Crane e
VOC CO NOx SOx PM10_Exhaust PM2.5_Exhaust PM10_Fugitive PM2.5_Fugitive
Emissions (tons/project) d CO2 Emissions (metric
tons/project) d
0.001 0.006 0.008 0.000 0.000 0.000 ‐‐ ‐‐0.941
0.000 0.003 0.004 0.000 0.000 0.000 ‐‐ ‐‐0.371
‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐0.055 0.011 ‐‐
0.000 0.002 0.000 0.000 0.000 0.000 0.000 0.000 0.450
0.001 0.006 0.008 0.000 0.000 0.000 ‐‐ ‐‐0.941
0.001 0.003 0.012 0.000 0.000 0.000 ‐‐ ‐‐1.088
0.001 0.006 0.010 0.000 0.001 0.001 ‐‐ ‐‐0.782
0.000 0.000 0.001 0.000 0.000 0.000 0.000 0.000 0.272
0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.068
0.000 0.003 0.004 0.000 0.000 0.000 ‐‐ ‐‐0.371
‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐0.019 0.004 ‐‐
0.000 0.002 0.000 0.000 0.000 0.000 0.000 0.000 0.450
0.001 0.002 0.008 0.000 0.000 0.000 ‐‐ ‐‐0.725
0.000 0.000 0.000 0.000 0.000 0.000 0.010 0.001 0.034
0.000 0.003 0.004 0.000 0.000 0.000 ‐‐ ‐‐0.313
0.000 0.001 0.008 0.000 0.000 0.000 0.000 0.000 2.038
0.000 0.000 0.003 0.000 0.000 0.000 0.000 0.000 0.747
‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐0.000 0.000 ‐‐
0.000 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.300
0.002 0.012 0.016 0.000 0.001 0.001 ‐‐ ‐‐1.483
0.000 0.000 0.002 0.000 0.000 0.000 0.000 0.000 0.545
0.002 0.010 0.016 0.000 0.001 0.001 ‐‐ ‐‐1.251
0.003 0.028 0.036 0.000 0.002 0.002 ‐‐ ‐‐4.078
0.004 0.015 0.053 0.000 0.002 0.002 ‐‐ ‐‐4.714
0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.069
0.003 0.018 0.028 0.000 0.002 0.002 ‐‐ ‐‐2.190
0.000 0.010 0.001 0.000 0.000 0.000 0.002 0.001 1.952
0.000 0.002 0.002 0.000 0.000 0.000 ‐‐ ‐‐0.185
0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.050
0.000 0.001 0.002 0.000 0.000 0.000 ‐‐ ‐‐0.156
0.000 0.002 0.005 0.000 0.000 0.000 ‐‐ ‐‐0.332
0.000 0.002 0.003 0.000 0.000 0.000 ‐‐ ‐‐0.314
0.000 0.001 0.004 0.000 0.000 0.000 ‐‐ ‐‐0.363
0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.005
0.000 0.001 0.002 0.000 0.000 0.000 ‐‐ ‐‐0.156
0.000 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.150
0.031 0.201 0.344 0.000 0.018 0.016 0.179 0.031 38.306
0.018 0.075 0.213 0.000 0.010 0.009 ‐‐ ‐‐13.295
0.001 0.003 0.021 0.000 0.001 0.000 0.001 0.000 5.553
0.002 0.012 0.015 0.000 0.001 0.001 ‐‐ ‐‐1.766
0.001 0.002 0.017 0.000 0.000 0.000 0.001 0.000 4.551
‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐0.001 0.000 ‐‐
‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐0.005 0.001 ‐‐
0.001 0.049 0.005 0.000 0.002 0.001 0.011 0.003 10.058
0.014 0.056 0.160 0.000 0.007 0.007 ‐‐ ‐‐9.972
0.003 0.010 0.077 0.000 0.002 0.001 0.004 0.001 20.006
0.005 0.027 0.034 0.000 0.002 0.002 ‐‐ ‐‐3.886
0.001 0.003 0.024 0.000 0.001 0.000 0.001 0.000 6.249
‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐0.004 0.001 ‐‐
0.001 0.034 0.003 0.000 0.001 0.000 0.008 0.002 6.906
0.014 0.056 0.160 0.000 0.007 0.007 ‐‐ ‐‐9.972
EN0717151040SAC Page 4 of 7
TABLE A‐2
Construction Emissions
Palo Alto Dewatering Building Project
VOC CO NOx SOx PM10_Exhaust PM2.5_Exhaust PM10_Fugitive PM2.5_Fugitive CO2Miles per Day c
Emissions (lbs/day) d
Equipment / Vehicle List a Quantity a Hours per Day b
Number of Days
Used aEquipment / Vehicle Type
Quantity
Units
2 Ton Flatbed Crew Truck e Offsite Heavy‐duty Diesel 14 ‐‐45 ‐‐14.6 0.086 0.344 2.627 0.007 0.071 0.042 0.134 0.033 756.666
Concrete Pump Construction Equipment 1 ‐‐510‐‐0.836 4.828 6.137 0.008 0.445 0.445 ‐‐ ‐‐778.780
Concrete Material Loads Offsite Heavy‐duty Diesel 1 ‐‐45 ‐‐40 0.017 0.068 0.520 0.001 0.014 0.008 0.026 0.007 149.739
Fugitive Dust i Aggregates 203 tons 45 ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐0.092 0.014 ‐‐
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐45 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
Crane and Elevated 12" Walls
150 Ton Crane e Construction Equipment 1 ‐‐12 10 ‐‐0.900 3.731 10.664 0.007 0.484 0.445 ‐‐ ‐‐732.781
2 Ton Flatbed Crew Truck e Offsite Heavy‐duty Diesel 15 ‐‐22 ‐‐14.6 0.095 0.380 2.898 0.008 0.078 0.046 0.148 0.037 834.728
Concrete Pump Construction Equipment 1 ‐‐310‐‐0.836 4.828 6.137 0.008 0.445 0.445 ‐‐ ‐‐778.780
Concrete Material Loads Offsite Heavy‐duty Diesel 1 ‐‐22 ‐‐40 0.017 0.068 0.520 0.001 0.014 0.008 0.026 0.007 149.739
Fugitive Dust i Aggregates 98 tons 22 ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐0.090 0.014 ‐‐
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐22 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
Structural Steel, Metal Decking, Metal Screens, and Metal Stairs
2 Ton Flatbed Crew Truck e Offsite Heavy‐duty Diesel 2 ‐‐52 ‐‐14.6 0.014 0.057 0.434 0.001 0.012 0.007 0.022 0.006 125.075
Welder e Construction Equipment 1 ‐‐52 10 ‐‐1.000 3.504 3.206 0.005 0.253 0.253 ‐‐ ‐‐369.065
90 Ton Crane Construction Equipment 1 ‐‐710‐‐0.900 3.731 10.664 0.007 0.484 0.445 ‐‐ ‐‐732.781
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐52 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
Steel Trusses
90 Ton Crane Construction Equipment 1 ‐‐53 10 ‐‐0.900 3.731 10.664 0.007 0.484 0.445 ‐‐ ‐‐732.781
Welder Construction Equipment 1 ‐‐53 10 ‐‐0.703 2.462 2.253 0.003 0.178 0.178 ‐‐ ‐‐259.343
2 Ton Flatbed Crew Truck e Offsite Heavy‐duty Diesel 1 ‐‐53 ‐‐14.6 0.007 0.026 0.200 0.001 0.005 0.003 0.010 0.003 57.748
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐53 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
Waterproofing
2 Ton Flatbed Crew Truck Offsite Heavy‐duty Diesel 1 ‐‐14 ‐‐14.6 0.006 0.025 0.190 0.001 0.005 0.003 0.010 0.002 54.655
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐14 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
BUR Roofing and Skylights
2 Ton Flatbed Crew Truck e Offsite Heavy‐duty Diesel 2 ‐‐5 ‐‐14.6 0.011 0.045 0.342 0.001 0.009 0.005 0.017 0.004 98.379
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐5 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
Doors and Windows
2 Ton Flatbed Crew Truck Offsite Heavy‐duty Diesel 1 ‐‐45 ‐‐14.6 0.006 0.025 0.190 0.001 0.005 0.003 0.010 0.002 54.655
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐45 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
Finishes Painting
Pickup Offsite Light‐duty Truck 1 ‐‐10 ‐‐14.6 0.001 0.057 0.006 0.000 0.002 0.001 0.010 0.002 10.845
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐10 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
Bridge Cranes
2 Ton Flatbed Crew Truck Offsite Heavy‐duty Diesel 1 ‐‐10 ‐‐14.6 0.006 0.025 0.190 0.001 0.005 0.003 0.010 0.002 54.655
Forklift Construction Equipment 1 ‐‐10 10 ‐‐0.286 1.579 2.442 0.002 0.204 0.188 ‐‐ ‐‐198.399
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐10 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
HVAC
2 Ton Flatbed Crew Truck e Offsite Heavy‐duty Diesel 6 ‐‐10 ‐‐14.6 0.035 0.142 1.081 0.003 0.029 0.017 0.055 0.014 311.532
Boom Truck Construction Equipment 1 ‐‐10 10 ‐‐0.900 3.731 10.664 0.007 0.484 0.445 ‐‐ ‐‐732.781
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐10 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
Cassions
40 Ton Crane Construction Equipment 1 ‐‐10 10 ‐‐0.900 3.731 10.664 0.007 0.484 0.445 ‐‐ ‐‐732.781
Hammer 22k ft‐lb Construction Equipment 1 ‐‐10 10 ‐‐0.472 2.668 4.053 0.003 0.342 0.314 ‐‐ ‐‐332.408
Drill Rig Truck Mount e Construction Equipment 5 ‐‐98 10 ‐‐2.061 12.128 31.067 0.051 0.912 0.839 ‐‐ ‐‐5,375.199
Offhaul Loads Offsite Heavy‐duty Diesel 1 ‐‐49 ‐‐40 0.017 0.068 0.520 0.001 0.014 0.008 0.026 0.007 149.739
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐98 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
Dewatering Building Maximum 3.484 20.073 46.443 0.066 1.802 1.628 0.737 0.166 6,921.087
Process Equipment
Elevated Platform, Piping, Belt Conveyor, Cake Bins, Polymer Pumps and
Equipment, Belt Filter Press, Scum Concentrator, and Hot Water Systems
2 Ton Flatbed Crew Truck e Offsite Heavy‐duty Diesel 7 ‐‐60 ‐‐14.6 0.041 0.165 1.259 0.003 0.034 0.020 0.064 0.016 362.544
Forklift Construction Equipment 1 ‐‐60 10 ‐‐0.286 1.579 2.442 0.002 0.204 0.188 ‐‐ ‐‐198.399
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐60 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
Process Equipment Maximum 0.362 3.221 3.840 0.009 0.289 0.229 0.393 0.098 891.903
Electrical
Electrical Allowances (Lighting and Power), Transformer, MCC 2500 A, Electrical
Panels, Transformer 2000 kVA, Generator, and I & C Allowance
2 Ton Flatbed Crew Truck e Offsite Heavy‐duty Diesel 9 ‐‐30 ‐‐14.6 0.056 0.224 1.708 0.005 0.046 0.027 0.087 0.022 491.893
Wire and Conduit Construction Equipment 1 ‐‐30 10 ‐‐0.472 2.668 4.053 0.003 0.342 0.314 ‐‐ ‐‐332.408
Worker Commute f Offsite Light‐duty Auto/Truck 20 ‐‐30 ‐‐24.8 0.035 1.477 0.140 0.003 0.051 0.021 0.329 0.082 330.961
Electrical Maximum 0.563 4.369 5.900 0.011 0.438 0.362 0.416 0.104 1,155.262
EN0717151040SAC Page 5 of 7
TABLE A‐2
Construction Emissions
Palo Alto Dewatering Building Project
Equipment / Vehicle List a
2 Ton Flatbed Crew Truck e
Concrete Pump
Concrete Material Loads
Fugitive Dust i
Worker Commute f
Crane and Elevated 12" Walls
150 Ton Crane e
2 Ton Flatbed Crew Truck e
Concrete Pump
Concrete Material Loads
Fugitive Dust i
Worker Commute f
Structural Steel, Metal Decking, Metal Screens, and Metal Stairs
2 Ton Flatbed Crew Truck e
Welder e
90 Ton Crane
Worker Commute f
Steel Trusses
90 Ton Crane
Welder
2 Ton Flatbed Crew Truck e
Worker Commute f
Waterproofing
2 Ton Flatbed Crew Truck
Worker Commute f
BUR Roofing and Skylights
2 Ton Flatbed Crew Truck e
Worker Commute f
Doors and Windows
2 Ton Flatbed Crew Truck
Worker Commute f
Finishes Painting
Pickup
Worker Commute f
Bridge Cranes
2 Ton Flatbed Crew Truck
Forklift
Worker Commute f
HVAC
2 Ton Flatbed Crew Truck e
Boom Truck
Worker Commute f
Cassions
40 Ton Crane
Hammer 22k ft‐lb
Drill Rig Truck Mount e
Offhaul Loads
Worker Commute f
Dewatering Building Maximum
Process Equipment
Elevated Platform, Piping, Belt Conveyor, Cake Bins, Polymer Pumps and
Equipment, Belt Filter Press, Scum Concentrator, and Hot Water Systems
2 Ton Flatbed Crew Truck e
Forklift
Worker Commute f
Process Equipment Maximum
Electrical
Electrical Allowances (Lighting and Power), Transformer, MCC 2500 A, Electrical
Panels, Transformer 2000 kVA, Generator, and I & C Allowance
2 Ton Flatbed Crew Truck e
Wire and Conduit
Worker Commute f
Electrical Maximum
VOC CO NOx SOx PM10_Exhaust PM2.5_Exhaust PM10_Fugitive PM2.5_Fugitive
Emissions (tons/project) d CO2 Emissions (metric
tons/project) d
0.002 0.008 0.059 0.000 0.002 0.001 0.003 0.001 15.445
0.002 0.012 0.015 0.000 0.001 0.001 ‐‐ ‐‐1.766
0.000 0.002 0.012 0.000 0.000 0.000 0.001 0.000 3.056
‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐0.002 0.000 ‐‐
0.001 0.033 0.003 0.000 0.001 0.000 0.007 0.002 6.755
0.005 0.022 0.064 0.000 0.003 0.003 ‐‐ ‐‐3.989
0.001 0.004 0.032 0.000 0.001 0.001 0.002 0.000 8.330
0.001 0.007 0.009 0.000 0.001 0.001 ‐‐ ‐‐1.060
0.000 0.001 0.006 0.000 0.000 0.000 0.000 0.000 1.494
‐‐ ‐‐ ‐‐ ‐‐ ‐‐ ‐‐0.001 0.000 ‐‐
0.000 0.016 0.002 0.000 0.001 0.000 0.004 0.001 3.303
0.000 0.001 0.011 0.000 0.000 0.000 0.001 0.000 2.950
0.026 0.091 0.083 0.000 0.007 0.007 ‐‐ ‐‐8.705
0.003 0.013 0.037 0.000 0.002 0.002 ‐‐ ‐‐2.327
0.001 0.038 0.004 0.000 0.001 0.001 0.009 0.002 7.806
0.024 0.099 0.283 0.000 0.013 0.012 ‐‐ ‐‐17.616
0.019 0.065 0.060 0.000 0.005 0.005 ‐‐ ‐‐6.235
0.000 0.001 0.005 0.000 0.000 0.000 0.000 0.000 1.388
0.001 0.039 0.004 0.000 0.001 0.001 0.009 0.002 7.956
0.000 0.000 0.001 0.000 0.000 0.000 0.000 0.000 0.347
0.000 0.010 0.001 0.000 0.000 0.000 0.002 0.001 2.102
0.000 0.000 0.001 0.000 0.000 0.000 0.000 0.000 0.223
0.000 0.004 0.000 0.000 0.000 0.000 0.001 0.000 0.751
0.000 0.001 0.004 0.000 0.000 0.000 0.000 0.000 1.116
0.001 0.033 0.003 0.000 0.001 0.000 0.007 0.002 6.755
0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.049
0.000 0.007 0.001 0.000 0.000 0.000 0.002 0.000 1.501
0.000 0.000 0.001 0.000 0.000 0.000 0.000 0.000 0.248
0.001 0.008 0.012 0.000 0.001 0.001 ‐‐ ‐‐0.900
0.000 0.007 0.001 0.000 0.000 0.000 0.002 0.000 1.501
0.000 0.001 0.005 0.000 0.000 0.000 0.000 0.000 1.413
0.005 0.019 0.053 0.000 0.002 0.002 ‐‐ ‐‐3.324
0.000 0.007 0.001 0.000 0.000 0.000 0.002 0.000 1.501
0.005 0.019 0.053 0.000 0.002 0.002 ‐‐ ‐‐3.324
0.002 0.013 0.020 0.000 0.002 0.002 ‐‐ ‐‐1.508
0.101 0.594 1.522 0.003 0.045 0.041 ‐‐ ‐‐238.939
0.000 0.002 0.013 0.000 0.000 0.000 0.001 0.000 3.328
0.002 0.072 0.007 0.000 0.002 0.001 0.016 0.004 14.712
0.264 1.579 3.118 0.005 0.130 0.113 0.107 0.025 475.937
0.001 0.005 0.038 0.000 0.001 0.001 0.002 0.000 9.867
0.009 0.047 0.073 0.000 0.006 0.006 ‐‐ ‐‐5.400
0.001 0.044 0.004 0.000 0.002 0.001 0.010 0.002 9.007
0.011 0.097 0.115 0.000 0.009 0.007 0.012 0.003 24.274
0.001 0.003 0.026 0.000 0.001 0.000 0.001 0.000 6.694
0.007 0.040 0.061 0.000 0.005 0.005 ‐‐ ‐‐4.523
0.001 0.022 0.002 0.000 0.001 0.000 0.005 0.001 4.504
0.008 0.066 0.089 0.000 0.007 0.005 0.006 0.002 15.721
EN0717151040SAC Page 6 of 7
TABLE A‐2
Construction Emissions
Palo Alto Dewatering Building Project
Notes:
‐‐ = Parameter not required for computing emissions.
a Unless otherwise noted, Equipment / Vehicle List provided by J. DeWolf in 'Palo Alto Dewatering Building Equipment 6‐3‐15.xlsx' and it was conservatively assumed that one piece of each equipment / vehicle type would be used for multiple days during the subsequent phases of construction, as applicable.
b The Hours per Day were assumed based on the anticipated construction schedule.
c Miles per Day for vehicles were calculated as follows:
‐ For hauling type vehicles: 40 miles (20 x 2) per Section 4.5 of Appendix A of the CalEEMod User’s Guide (ENVIRON, 2013).
‐ For delivery type vehicles: 14.6 miles (7.3 x 2) per Table 4‐2 of Appendix D of the CalEEMod User’s Guide (ENVIRON, 2013); C‐NW value for an urban setting in the San Francisco Bay Area.
‐ For worker commutes: 24.8 miles (12.4 x 2) per Table 4‐2 of Appendix D of the CalEEMod User’s Guide (ENVIRON, 2013); H‐W value for an urban setting in the San Francisco Bay Area.
‐ For onsite vehicles: estimated to be 5 miles per day based on the size of the project site.
d The following conversion factors were used to estimate emissions:
e Quantities were adjusted to accommodate potential overlapping activities, using engineering judgment and the proposed schedule of construction activities.
f The quantity of Worker Commutes assumes a maximum of 10 vehicles accessing the site per day (for 20 vehicle trips per day), as provided in Section 1.8.2 of the Initial Study. Number of Days Used generally set equal to the longest duration for other equipment or vehicles used during the same construction activity.
g The areas disturbed were estimated based on data provided by J. DeWolf in '658394 Palo Alto Sludge Dewatering Detail 5‐21‐15.pdf', specifically looking at areas to be graded. Estimates were converted from ft2 and yd2 to acres using the above conversion factors.
h The cut/fill quantities were estimated based on data provided by J. DeWolf in '658394 Palo Alto Sludge Dewatering Detail 5‐21‐15.pdf', specifically looking at materials associated with backfill/compact and excavation activities. Quantities were assumed to be offsite when associated with a 'Haul spoils, offsite' activity.
i The aggregate quantities were estimated based on data provided by J. DeWolf in '658394 Palo Alto Sludge Dewatering Detail 5‐21‐15.pdf', specifically looking at materials associated with concrete and subbase activities. Estimates were converted from yd3 to tons using the above conversion factor.
j The paving area was estimated based on data provided by J. DeWolf in '658394 Palo Alto Sludge Dewatering Detail 5‐21‐15.pdf'. Estimate was converted from ft2to acres using the above conversion factor.
EN0717151040SAC Page 7 of 7
TABLE A‐3
Construction Equipment Emission Factors
Palo Alto Dewatering Building Project
Emission Factors from OFFROAD2011
VOC CO NOx SOx PM10 PM2.5 CO2
1.5 CY Loader Rubber Tired Loader 200 0.36 0.393 1.452 5.115 0.005 0.175 0.161 503.654
10 Ton Steel Roller Roller 81 0.38 0.628 3.755 5.806 0.005 0.428 0.393 508.199
12 Ton Pneumatic Roller Roller 81 0.38 0.628 3.755 5.806 0.005 0.428 0.393 508.199
25 Ton Vibrating Roller Roller 81 0.38 0.628 3.755 5.806 0.005 0.428 0.393 508.199
50" Vibratory Roller Roller 81 0.38 0.628 3.755 5.806 0.005 0.428 0.393 508.199
66" Vibratory Roller Roller 81 0.38 0.628 3.755 5.806 0.005 0.428 0.393 508.199
Cat 320 DL Excavator 163 0.38 0.358 3.158 4.081 0.005 0.201 0.185 506.495
Cat 416E Tractor/Loader/Backhoe 98 0.37 0.538 3.811 5.142 0.005 0.396 0.364 511.346
Cat 420 E Tractor/Loader/Backhoe 98 0.37 0.538 3.811 5.142 0.005 0.396 0.364 511.346
Cat D 6 Crawler Tractor 208 0.43 0.449 1.803 6.047 0.005 0.233 0.215 507.355
Crane 30 Ton Crane 226 0.29 0.623 2.582 7.381 0.005 0.335 0.308 507.155
Dozer 300 hp Crawler Tractor 300 0.43 0.398 2.744 5.279 0.005 0.205 0.188 510.339
Grader 30000 lbs Grader 175 0.41 0.810 3.916 8.250 0.005 0.464 0.426 516.131
Grader Cat 140M 17 Grader 175 0.41 0.810 3.916 8.250 0.005 0.464 0.426 516.131
Loader 950H Rubber Tired Loader 200 0.36 0.393 1.452 5.115 0.005 0.175 0.161 503.654
Loader Cat 938 H Rubber Tired Loader 200 0.36 0.393 1.452 5.115 0.005 0.175 0.161 503.654
Paving Machine 130 hp Paving Equipment 131 0.36 0.372 3.081 4.322 0.005 0.215 0.197 504.820
Rammax Roller 81 0.38 0.628 3.755 5.806 0.005 0.428 0.393 508.199
Roller Bomag BW65H Roller 81 0.38 0.628 3.755 5.806 0.005 0.428 0.393 508.199
Scraper Cat 621 G Scraper 362 0.48 0.452 3.606 5.757 0.005 0.232 0.214 506.350
Vibraplate Plate Compactor 8 0.43 0.661 3.469 4.142 0.008 0.161 0.161 568.299
150 Ton Crane Crane 226 0.29 0.623 2.582 7.381 0.005 0.335 0.308 507.155
40 Ton Crane Crane 226 0.29 0.623 2.582 7.381 0.005 0.335 0.308 507.155
90 Ton Crane Crane 226 0.29 0.623 2.582 7.381 0.005 0.335 0.308 507.155
Boom Truck Crane 226 0.29 0.623 2.582 7.381 0.005 0.335 0.308 507.155
Concrete Pump Pump 84 0.74 0.610 3.523 4.478 0.006 0.325 0.325 568.299
Drill Rig Truck Mount Bore/Drill Rig 206 0.50 0.193 1.133 2.902 0.005 0.085 0.078 502.128
Forklift Forklift 89 0.20 0.730 4.023 6.222 0.005 0.520 0.479 505.583
Hammer 22k ft‐lb Other General Industrial Equipment 88 0.34 0.716 4.045 6.144 0.005 0.518 0.476 503.944
Welder Welder 46 0.45 1.540 5.395 4.936 0.007 0.389 0.389 568.299
Wire and Conduit Other General Industrial Equipment 88 0.34 0.716 4.045 6.144 0.005 0.518 0.476 503.944
Notes:
a Equipment List provided by J. DeWolf in 'Palo Alto Dewatering Building Equipment 6‐3‐15.xlsx'.
b Equipment Categories selected to best align the CalEEMod default equipment types with the equipment expected for this project.
d Emission Factors taken as the default values for the year 2016 provided in Table 3.4 of Appendix D of the CalEEMod User's Guide (ENVIRON, 2013).
c Unless specifically noted in the Equipment List, Horsepower and Load Factors taken as the default, average values provided in Table 3.3 of Appendix D of the CalEEMod User's Guide (ENVIRON, 2013).
Emission Factors (g/bhp‐hr) d
Equipment List a Horsepower c
Load Factor
cEquipment Category b
EN0717151040SAC Page 1 of 1
TABLE A‐4
Construction Vehicle Emission Factors
Palo Alto Dewatering Building Project
Emission Factors from EMFAC2014 and AP‐42
VOC CO NOx SOx PM10 d PM2.5 d CO2 PM10 PM2.5
2 Ton Flatbed Crew Truck Offsite Heavy‐duty Diesel 0.193 0.773 5.895 0.016 0.158 0.093 1,698.043 0.300 0.075
3000 Gal Tanker Onsite Heavy‐duty Diesel 2.028 4.999 20.707 0.033 0.313 0.241 3,408.501 903.622 90.362
Concrete Material Loads Offsite Heavy‐duty Diesel 0.193 0.773 5.895 0.016 0.158 0.093 1,698.043 0.300 0.075
Offhaul Loads Offsite Heavy‐duty Diesel 0.193 0.773 5.895 0.016 0.158 0.093 1,698.043 0.300 0.075
Pipe Bedding Material Loads Offsite Heavy‐duty Diesel 0.193 0.773 5.895 0.016 0.158 0.093 1,698.043 0.300 0.075
Water Truck Onsite Heavy‐duty Diesel 2.028 4.999 20.707 0.033 0.313 0.241 3,408.501 903.622 90.362
Tractor Truck 380 hp Offsite Heavy‐duty Diesel 0.193 0.773 5.895 0.016 0.158 0.093 1,698.043 0.300 0.075
Worker Commute Offsite Light‐duty Auto/Truck 0.032 1.351 0.128 0.003 0.046 0.019 302.669 0.300 0.075
Pickup Offsite Light‐duty Truck 0.045 1.762 0.175 0.003 0.047 0.020 336.945 0.300 0.075
Vehicle Vehicle Class a
Exhaust Emission Factors (g/mile) b Road Emission Factors (g/mile) c
EN0717151040SAC Page 1 of 2
TABLE A‐4
Construction Vehicle Emission Factors
Palo Alto Dewatering Building Project
Notes:
a The vehicle classes are represented as follows:
Heavy‐duty Diesel:Assumed to be 100% HHDT, DSL values, per Section 4.5 of Appendix A of the CalEEMod User's Guide (Environ, 2013).
Light‐duty Truck:Assumed to be an average of LDT1, GAS and LDT2, GAS values.
Light‐duty Auto/Truck:Assumed to be 50% LDA, GAS; 25% LDT1, GAS; and 25% LDT2, GAS values, per Section 4.5 of Appendix A of the CalEEMod User's Guide (ENVIRON, 2013).
d The PM10 and PM2.5 emission factors include tire and brake wear.
Derivation of Paved Road Emission Factors
Parameter PM10 PM2.5
Average Weight a 2.4 2.4
k b 1 0.25
sL a 0.1 0.1
Emission Factor (g/mile) c 0.300 0.075
Notes:
a Average Weight and sL taken as the default value from CalEEMod for Santa Clara County.
b k taken from Table 13.2.1‐1 of Section 13.2.1 of AP‐42 (EPA, 2011).
c Emission factor calculated using Equation 1 from Section 13.2.1 of AP‐42 (EPA, 2011):
Emission Factor (g/mile) = k (g/mile) x [sL (g/m2)]0.91 x [Average Weight (tons)]1.02
Derivation of Unpaved Road Emission Factors
Parameter PM10 PM2.5
Mean Vehicle Weight a 16.5 16.5
Silt Content b 8.5 8.5
k c 1.5 0.15
a c 0.9 0.9
b c 0.45 0.45
P d 58 58
Emission Factor (g/mile) e 903.62 90.36
Notes:
a Mean vehicle weight assumes that heavy‐ and light‐duty trucks weigh an average of 16.5 tons.
b Silt content taken from Table 13.2.2‐1 of Section 13.2.2 of AP‐42 (EPA, 2006) for a Construction Site, Scraper Route; this value is consistent with the CalEEMod defaults.
c k, a, and b taken from Table 13.2.2‐2 of Section 13.2.2 of AP‐42 (EPA, 2006) for industrial roads.
d P taken as the CalEEMod default for the climate region of Santa Clara County
e Emission factor calculated using Equations 1a and 2 from Section 13.2.2 of AP‐42 (EPA, 2006):
Emission Factor (g/mile) = {k (lbs/mile) x [Silt Content (%) / 12]a x [Mean Vehicle Weight (tons) / 3]b} x [(365‐P) / 365] x 453.6 (g/lb)
c Paved and unpaved road emission factors were calculated using CalEEMod methodology, as described below.
b Exhaust Emission Factors from EMFAC2014 for Santa Clara County, calendar year 2016. EMFAC2007 Vehicle Categories were used. A speed of 40 mph was assumed for offsite, onroad vehicles, which is consistent with the CalEEMod
default. A speed of 5 mph was assumed for onsite, offroad vehicles. An average temperature of 64°F and humidity of 62% were used per Table B‐1 of CT‐EMFAC: A Computer Model to Estimate Transportation Project Emissions (UC Davis,
2007).
EN0717151040SAC Page 2 of 2
TABLE A‐5
Fugitive Dust Emission Factors
Palo Alto Dewatering Building Project
Emission Factors from WRAP Fugitive Dust Handbook
PM10 a PM2.5 b Units
0.110 0.023 ton/acre‐month
0.005 0.001 ton/acre‐day c
Onsite Cut/Fill d 0.059 0.012 ton/1,000 yd3
Offsite Cut/Fill d 0.220 0.046 ton/1,000 yd3
Aggregates e 0.020 0.003 lbs/ton
Notes:
d All cut/fill quantities were assumed to be handled and remain onsite, except those specifically labeled as "Haul spoils, offsite" in '658394 Palo Alto
Sludge Dewatering Detail 5‐21‐15.pdf', which was provided by J. DeWolf.
c Emission factor converted to units of ton/acre‐day assuming 22 construction days per month.
e Aggregate emission factors were calculated per the Debris Loading Equation of Section 4.4 of Appendix A of the CalEEMod User's Guide (ENVIRON,
2013).
Disturbed Surface
Activity
Emission Factors
a Unless otherwise noted, PM10 emission factors taken from Table A‐4 of Appendix A of the Software User's Guide: URBEMIS2007 for Windows (JSA,
2007).
b Unless otherwise noted, PM2.5 emissions assumed to be 20.8% of the PM10 emissions for construction fugitive dust sources per the Final ‐
Methodology to Calculate Particulate Matter (PM) 2.5 and PM 2.5 Significance Thresholds (SCAQMD, 2006).
EN0717151040SAC Page 1 of 1
TABLE A‐6
Paving Emission Factor
Palo Alto Dewatering Building Project
Emission Factors from CalEEMod
VOC Units
Paving a 2.620 lb/acre
Notes:
Emission Factor
Activity
a Emission factor from Section 4.8 of Appendix A of the CalEEMod User's Guide (ENVIRON, 2013).
EN0717151040SAC Page 1 of 1
Addendum Addressing Comments on the Proposed Mitigated Negative Declaration for the Palo Alto Regional Water Quality Control Plant Sludge Dewatering and Loadout Facility
This document has been prepared to address comments submitted on the proposed CEQA Mitigated
Negative Declaration for the Palo Alto RWQCP Sludge Dewatering and Loadout Facility. The proposed
Mitigated Negative Declaration and Initial Study were circulated for agency and public review for a 30-day
period beginning December 15, 2015, and a public hearing was conducted by the City of Palo Alto Planning
Commission on January 27, 2016, and the Mitigated Negative Declaration is being considered for adoption
by the City Council on March 21, 2016.
During this period, three comment letters were received (Attachment 1)
•January 13, 2016 from Herb Borock
•January 27, 2016 from Herb Borock
•February 20, 2016 from Herb Borock
Most of the comments provided in these three letters addressed similar topics, and for clarity the responses
below are grouped by topic. In some cases, text changes to the Initial Study are proposed in response to the
comments. Text changes are presented in this document using strikeout and underline format. The
proposed text changes add clarity to the discussion, but do not add new information of substantial
importance.
Odors
In his letter dated January 13, 2016, the commenter states that no objective information is provided in the
proposed Mitigated Negative Declaration demonstrating that odor impacts would be less than significant.
Additional detail is provided in both the January 27, 2016 and February 20, 2016 letters asking additional
questions about regulatory compliance in terms of dilution-to-threshold ratios and meeting California
Ambient Air Quality for hydrogen sulfide.
These questions were partially addressed for the January 27, 2016 Planning Commission meeting, in which
the following response was provided:
The potential for odor impacts was fully assessed in the Initial Study, with the conclusion that odor
levels would be “substantially less” than the Bay Area AQMD’s dilution-to-threshold (D/T) ratio of 5.
The exact D/T ratio was unquantified in the Initial Study because of some potential variations in the
exact control technology to be used. Notwithstanding this unquantified conclusion in the Initial
Study text, appropriate calculations were prepared as part of our record, and further refined in an
updated version of the odor control memo referenced by the commenter (dated August 4, 2015). As
reported in the memo, and in calculations performed at the time the Initial Study was prepared, the
proposed odor control technology would result in an expected D/T ratio of approximately 0.9 at the
property line. In addition, a more conservative model run was performed to assess a potential worst
case, which showed a maximum D/T ratio of approximately 1.5 at the property line. All calculations
were performed using the AERMOD dispersion model. These numbers support the Initial Study
conclusion that impacts would be less than significant.
This response addressed odors in general, but did not specifically address individual odor-causing
compounds such as hydrogen sulfide. Aggregate odors were determined to be below the applicable
threshold as described above – in other words, including the contributions of all odorous compounds. The
commenter requested information about the specific compounds that would generate odors – based on
sampling, odorous compounds are expected to include hydrogen sulfide, methyl mercaptan, carbonyl
ATTACHMENT H
sulfide, and dimethyl sulfide. In addition, the commenter asked specifically about hydrogen sulfide
emissions relative to the California Ambient Air Quality Standard of 0.03 parts per million. As part of the
odor control analysis, hydrogen sulfide concentrations were measured at the existing belt filter presses in
order to determine expected levels for the proposed project.1 Two samples were taken, with measurements
of 0.024 ppm and 0.021 ppm. Additional samples were taken at the sludge blending tank to form the basis
of the odor control system design. This odor control system is provided to treat high concentration odors
(from cake storage and sludge blend tank). Dispersion of the exhaust from the odor control facility and the
building exhaust (0.024 ppm) was modeled using AERMOD. The model results demonstrate that the
hydrogen sulfide concentration at the property line would be below the 0.03 ppm threshold and that odor
D/T would be below the 5 D/T requirement.
In order to provide clarification in response to these comments, the following text changes are proposed for
the Initial Study document in Section 3.3.2(e) – Would the project create objectionable odors affecting a
substantial number of people?
LESS-THAN-SIGNIFICANT IMPACT. The sludge dewatering and loadout facility would be a new source
of odor at the RWQCP. Odors would be generated at the proposed sludge dewatering and loadout
facility. Odorous compounds would include hydrogen sulfide, methyl mercaptan, carbonyl sulfide,
and dimethyl sulfide. In addition, changes to overall RWQCP sludge handling processes may affect
odor generation from other units that feed sludge to the new dewatering facility. Existing RWQCP
operations include odor-control treatments such as adding sodium hypochlorite to sludge prior to
storage. These practices would continue under the proposed project. The project also includes the
addition of an odor-control system, likely a two-stage system consisting of a biotrickling filter
followed by a mixed media adsorber. This type of system is proven to be effective in sharply
reducing the concentration of odorous substances in wastewater treatment facilities.
Odor is regulated by the BAAQMD (Regulation 7 – Odorous Substances) as a two-part process. First,
thresholds are triggered only if the BAAQMD receives odor complaints from at least 10 individuals in
a 90-day period. If sufficient complaints are received, then the generator must demonstrate that
odors at the property line are not odorous after dilution with four parts of odor-free air. In other
words, a dilution-to-threshold ratio (D/T) of no greater than 5 must be met. Air dispersion modeling
conducted for the project indicates that odors at the property line would be 0.9 D/T, which is
substantially less than the 5 D/T threshold. In addition, hydrogen sulfide concentrations at the
property line would be less than the California Ambient Air Quality Standards for hydrogen sulfide of
0.03 parts per million. Based on the expected performance of the odor-control system and the
results of dispersion modeling, odor impacts would be less than significant.
Greenhouse Gases
In his letters dated January 13, 2016, and January 27, 2016, the commenter states that the Mitigated
Negative Declaration omits greenhouse gas emissions from project operations. This question was addressed
for the January 27, 2016 Planning Commission meeting, in which the following response was provided:
The Initial Study discusses impacts from both project construction and operation in Section 3.7.2.
Given the extent of construction activities, impacts are quantified and compared to regional
greenhouse gas reduction strategies. Impacts from operation are negligible, and potential emission
sources – periodic testing of the backup generator and a nominal five truck trips per day – are
addressed qualitatively. Because the new facility would be powered by electricity, there is limited
onsite potential for greenhouse gas generation from equipment operations. In response to the
comment, we further examined the potential for impacts from equipment operations, focusing on
the potential for methane emissions from the new sludge handling process, and determined that
1 It should be noted that existing belt filter presses are in use at the Regional Water Quality Control Plant – in other words, the use of sludge
watering is not a “new” process at the plant although the proposed dewatering and loadout facility itself would be a new plant feature.
the biosolids residence time is so short that generation of biogenic methane is not expected. No
changes to the Initial Study are required. Also, it should be noted that this project is a significant
step in replacing the existing multiple hearth incinerators, which will substantially reduce overall
greenhouse gas emission from wastewater treatment operations.
This response also referenced a Greenhouse Gas Emissions Fact Sheet, dated August 2015, which described
overall greenhouse gas emissions at the Regional Water Quality Control Plant and recent efforts to decrease
emissions. In his letter dated February 20, 2016, the commenter asked several questions about the Fact
Sheet including missing data and future estimates. In response to these comments, the Fact Sheet has been
updated and is attached to this addendum (Attachment 2) for informational purposes. It should be noted
that the Fact Sheet presents general background information about the City’s efforts to reduce greenhouse
gas emissions at the plant, and was not used as reference material for the Mitigated Negative Declaration.
Future Components of the Biosolids Facility Plan/Cumulative Impacts
In all three of his comment letters, the commenter addresses future components of the City’s Biosolids
Facility Plan, including the potential for the City to treat biosolids using technologies such as gasification and
pyrolysis, and states that it is necessary to include a statement for each of these alternatives as to whether
those processes produce odor-causing pollutants or emit greenhouse gases. In addition, the commenter
discussed the Bay Area Biosolids-to-Energy (B2E) Coalition and its potential interests in a consolidated B2E
facility in one location. The City is a member of the Bay Area B2E Coalition, and is actively exploring
partnerships as well as onsite options. However, City staff are still in the process of developing future
components of the Biosolids Facility Master Plan, and at this time no additional components are ready for
detailed engineering or environmental consideration. Because future components of the Biosolids Facility
Plan are speculative, they do not need to be considered in the Mitigated Negative Declaration.
Landscaping and Visual Quality
In his comment letter dated January 13, 2016, the commenter requested additional information about views
from the adjacent former landfill site, southeast of the Regional Water Quality Control Plant. In response to
this comment, the City prepared a new visual simulation from the location requested by the commenter – a
high point in the adjacent landfill site – and shared this new simulation with the commenter and with the
Planning Commission at its January 27, 2016 meeting.
In his comment letter dated February 20, 2016, the commenter asked several additional questions about
landscaping and visual screening. These questions referenced prior landscaping on both the south and east
sides of the plant, and the potential for future landscaping to be successful consistent with the visual
simulations. It is important to note that it is not the City’s goal to completely screen all aspects of the plant
from all sides. In some cases, this would be undesirable. For example, area south of the plant, located next
to the future Byxbee Park, is currently reserved for a compost facility consistent with Measure E (2011) – the
City is not planning to augment landscaping to screening views from this area given the potential future use.
In addition, it is important to note that the environmental analysis must focus on the project at hand – the
proposed Sludge Dewatering and Loadout Facility. With regard to this project, the proposed new
landscaping has been selected by a licensed landscape architect to provide screening using native and non-
native plants that are known to thrive in the local climate. The proposed Mitigated Negative Declaration
does not need to address unrelated questions about Regional Water Pollution Control Plant landscaping.
Dewatered Sludge Storage Bins Capacity
In his letter dated February 20, 2016, the commenter noted the potential for emergencies to disrupt the
transport of solids for offsite disposal, and asked about the capacity of the proposed dewatered sludge
storage bins. The bins have a capacity sufficient for 2 days of storage, based on the engineering design
calculations. This comment on the design of the project does not affect the environmental impact
assessment.
Attachment 1
Attachment 2
GREENHOUSE GAS EMISSION PROJECTIONS
February 2016
RWQCP GHG Emission Components:
RWQCP Partner Cities = Mountain View, East Palo Alto Sanitary District, Los Altos, Los Altos Hills, and Stanford
Calculated using the Local Government Operations Protocol, version 1.1 & include both anthropogenic & biogenic emissions
Sewage sludge incinerator auxiliary gas & sludge combustion
Gas usage for office building comfort heating
Electricity usage (green electricity has no GHG emissions)
Wastewater treatment process fugitive GHG emissions
Baylands conversion of effluent total nitrogen
Landfill flare and fleet are not included in RWQCP GHG emissions as they are reported by other City Divisions
2018
Assumptions
2019 ‐ 2024
Assumptions
2025a
Assumptions
2025b
Assumptions
Emissions are
comparable
to 2015
Comfort heating gas usage is
approximately the same as 2014
Wastewater treatment process is the
same as in 2014
o Projected increases in population
& effluent nitrogen load
Sewage sludge incinerators
decommissioned; hauling dewatered
sewage sludge to Central Valley (closer
locations will be evaluated)
o Emissions from sludge
transportation included
o Emissions from disposal of sludge
after transport not included
o Emission estimates for sludge
disposal taken from the Biosolids
Facility Plan (CH2MHill, 2012)
Comfort heating gas usage is approximately the same as 2014
Sewage sludge treated onsite via mesophilic anaerobic
digestion with thermal hydrolysis and biogas‐fueled
combined heat & power with sidestream nutrient removal
treatment
o Emission estimates for sludge disposal taken from
the Biosolids Facility Plan (CH2MHill, 2012)
Wastewater treatment
process is the same as in
2015
o Projected
increases in
population &
effluent nitrogen
load
Wastewater treatment
expanded to total nitrogen
removal of 90% through
the RWQCP
o Projected
increases in
population &
effluent nitrogen
load
GREENHOUSE GAS EMISSIONS
FACTSHEET
February 2016
*GHG emissions are calculated using the Local Government Operations Protocol, version 1.1 & include both anthropogenic and biogenic emissions.
GHG emissions associated with electrical usage and the switch to green electricity are included in the above totals. Excluding the purchase of green
electricity, the RWQCP decreased its GHG emissions by 16% between 2005 and 2015.
The Regional Water Quality Control Plant (RWQCP) is one of the City of Palo Alto’s major greenhouse gas
(GHG) emitting facilities. Since 2005, the RWQCP has undertaken numerous initiatives to decrease GHG
emissions. These initiatives include purchasing green electricity, routinely tuning the sewage sludge
incinerators to decrease natural gas consumption, and utilizing landfill gas to further decrease natural gas
used in the sewage sludge incinerators. Since 2005, the RWQCP has reduced its GHG emissions by more than
40 percent. The RWQCP is dedicated to reducing its GHG footprint and has incorporated GHG emissions as a
key decision‐making factor as it plans for a new biosolids treatment process and anticipated nutrient removal
requirements.
ENERGY USE FACTSHEET
February 2016
The Regional Water Quality Control Plant (RWQCP) is the City of Palo Alto’s major energy consuming facility.
Since 2005, the RWQCP has undertaken numerous initiatives to decrease and switch to greener energy
options. These initiatives include purchasing green electricity, routinely tuning the sewage sludge incinerators
to decrease natural gas consumption, and utilizing landfill gas to further decrease natural gas used in the
sewage sludge incinerators. The RWQCP is dedicated to reducing its energy footprint and is planning
numerous projects and evaluations to do so (Table 1). The RWQCP has incorporated energy usage as a key
decision‐making factor as it prepares for expanded recycled water demand and anticipated nutrient removal
requirements.
Table 1: Summary of Future Energy Projects & Evaluations Anticipated to Occur Between 2016 & 2020
Energy Reduction Projects Energy Reduction Evaluations Future Energy Increase Projects
Decommission sewage sludge incinerator
Replace aeration basin diffuser
Install new controls (VFD) on motors
Trickling filter rehabilitation
New Pumping Plant rehabilitation
Install electrical meters and
load evaluations by process
area
Emerging technologies for
trickling filter and nitrification
optimization
New nutrient removal
treatment processes
Increased recycled water
production
Increased incoming
wastewater strength
ARCHITECTURAL REVIEW BOARD 1
February 18, 2016 2
3
VERBATIM MINUTES 4
5
6
DRAFT EXCERPT 7
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9
Item No: 3: 2501 Embarcadero Way [File 15-PLN-00371]: Request by Public Works for Site 10
and Design Review of a New Two-Story, 7,500 Square Foot, 50-Foot Tall Building Designed to Handle 11
Sludge De-watering and Truck Load-outs, with Adjacent Stand-by Generator, Outdoor Equipment Area 12
and Landscaping Improvements to be Centrally Located on the Regional Water Quality Control Plant Site. 13
Environmental Assessment: A Draft Mitigated Negative Declaration Has Been Published and Circulated 14
for a 30-day Public Review and Comment Period. For more information contact, Project Planner Amy 15
French at amy.french@cityofpaloalto.org 16
17
Amy French: Good morning. Nice to be back. This application — I assume you already read the 18
description of it - this is the second public hearing on the project. It's proposed on a 25-acre site, the 19
Regional Water Quality Control Plant. I have on the screen an image that shows that it will be centrally 20
located. The Planning and Transportation Commission reviewed and recommended the project and the 21
Mitigated Negative Declaration on January 27th of this year. The ARB offered some guidance at a study 22
session in December and offered guidance on areas to focus on for the formal ARB. Here we are now. 23
Changes to the project since December are noted on the report on page 9, and they'll be covered by 24
Public Works staff in their presentation. This staff report provides draft architectural review approval 25
findings which are, of course, open to your review and edits. The ARB comments on the Mitigated 26
Negative Declaration, particularly the aesthetics section, are also welcome. Department approval 27
conditions are not yet finalized; they will be finalized prior to sending the report to the City Council. The 28
tentative date is March 21st. There is an error in the report that says February 22nd, and that is an 29
error. This report also outlines the Baylands Design Guidelines on report pages 10 and 11. The focus for 30
sites adjacent to the Baylands, which is the case for this site, is compatibility with Baylands aesthetics 31
and environment. Finally, this report contains sections on the project with respect to the Palo Alto 32
airport. This is on page 12, and this is mainly for the benefit of the public following concerns that were 33
brought up just prior to the Planning and Transportation Commission review. Also, there's a note about 34
the CEQA process regarding the adjustments that will be made to the Mitigated Negative Declaration, 35
clarifications basically for the Council review and action. I'll turn it over to Phil. 36
37
Phil Bobel: Thank you, Amy. Phil Bobel, Public Works Assistant Engineer. We've got some other people 38
with us today to answer questions and to help out. Jamie Allen is our Plant Manager. He's with us. 39
Padham [phonetic] is our Senior Engineer with us. Greg is our architect, and David is our design 40
engineer from CH2M. They're all here to help answer questions. Since we did have a study session on 41
this, I wasn't going to belabor sort of the project itself. Just a quick reminder, we need this dewatering 42
and truck off-haul facility so that we can phase out, eliminate the incinerator. That's the goal. For 43
several years, we'll be hauling this dewatered sludge probably to another sewage treatment plant while 44
we get our own digesters in place, which is the hoped for ultimate process for Palo Alto. I'll not go back 45
through what we did at the study session. A picture of our incinerator. This was the Long Term Facilities 46
Plan we did where we showed that brown area as the site for the replacement facilities for the 47
incinerator. That's exactly what we're doing now. You can see that there's kind of an open area right in 48
the upper center of the plant. That's where this facility is going. Here's the slide that Amy showed. It 49
has the building that we're talking about, our dewatering building, right with that big arrow as slightly 50
yellow. I'm going to just focus on the comments we got from you at the study session and how we've 51
responded to them, and then remind you of how it looks from the various sides. Some of those sides you 52
didn't have too comments on, but I'll go back through all of the looks, the four sides of the building. This 53
was our drawing showing the building from different perspectives. We didn't change that drawing. This 1
is in your packet. It points out where we did do new things in response to your comments. I'll go over 2
those, showing you the actual elevations now. First, I wanted to—we didn't do a good job, I don't think, 3
of explaining that just last year in 2015 we spent about $1 million on landscaping at the sewage 4
treatment plant. We didn't show you last time the outline of what was done there. Here's not a detailed 5
drawing obviously, but the work that we did and completed in 2015. A lot of new plantings, a new path 6
around the plant on the northeast side, and then a lot of internal work on the southwestern side. We'll 7
be talking more about that, because that's the entrance to our plant. That shows the details of the new 8
plants that were installed and the new features. There's the new sign that we put in front at the western 9
side of the facility, and the new artwork that's next to it on the right. That was part of the public art for 10
that project. There's some more of the public art that matched it with vines. We'll be talking more about 11
this vine. I personally like it and hope we incorporate some more of it, but we haven't chosen the plant 12
types. This is the elevation that you guys had most of the thoughts about last time. It's our west 13
elevation. As you enter the plant from the main entrance, this is the side of the building you see, the 14
western elevation. The main changes we've made since last time to try to add more interest to the 15
building are that second window, which is the upper window on the second story in the middle. That's 16
new, and it matches one that was in the original design on the right-hand side. That window is new. 17
These demarcation, those two lines, grooves in the concrete demarking the first and second stories is 18
new. The major new feature are the green screens. That's a product you've probably seen before that's 19
a green mesh and then vines. Whatever plants you choose can grow up that. I think that's a major 20
response to your concern that we do something more interesting with that side of the building. We're 21
excited about that. We agreed with you that something more was needed. Let's show you what—we 22
also had discussion about the concrete itself, what would that look like. This is what we'll be trying to 23
sort of match, because most of the existing concrete at the sewage treatment plant looks like this. This 24
is a shot of one of our existing buildings at the sewage treatment plant, and you can see we've used 25
those grooves. The 4 by 8 sheets weren't grooved, but they show an outline. The holes from the ties 26
are visible. They were filled but visible. This is kind of the look that the rest of the buildings have at the 27
sewage treatment plant and what we tried to achieve with the new building. Here's a shot looking from 28
the entrance. We're just inside the fence, looking east at the west elevation. There's some existing trees 29
which are in the middle and block part of the view of the building, so you don't see when you're this far 30
away quite as well those green screens. Of course, with actual plants on them, they'd be a darker green, 31
and they'd be more visible. That's what it looks like. The other thing last time when we were here, our 32
photos weren't as up-to-date as they should have been and didn't include our new landscaping in all 33
cases. This shows what it actually looks like now with the newer landscaping in front and some of our 34
new plantings. Again, this is new plantings that we would do, not the previous project but plants that we 35
would add with this project. You can see that there are three larger trees out in front, some other plants 36
on the western side, the down side of this building. Outside of our fence, there's another row of plants, 37
and we'll talk about that in a minute. Plants and trees that we'll be adding to the screening from the 38
eastern side of the plant. We'll see that in a minute. Here's the east elevation. That elevation didn't 39
change, and we didn't have any comments from you on the elevation itself. This shows, looking at that 40
east elevation from outside the plant, this shows photo shopped in what it would look like now. Where 41
that arrow points down and in front of the building is where these new plants would go that I showed 42
you on the other drawing. There they are again. It's that upper row of plants. They would be screening 43
better the building from the east side. Here's a picture on the right. This is a photo shopped rendering 44
of what we think it will look like in ten years after those plants achieve full height and grow up and would 45
hide the building sort of. This also shows—on the left-hand side, it's showing you the plants that we 46
added last year. On the right-hand side, the diagram is showing you the plants that we would add with 47
this project. It's been on three different slides, but those are those same plants on the right-hand side 48
that we would add this year. There's just a blown-up photo, again, photo shopped in showing after 10 49
years what we think that growth would look like and basically hide the east elevation of the building. The 50
north elevation changed. We had some vines shown, but we've now shown this green screen effect. 51
The west and the north elevation, it's the only place where you can kind of be in the plant and see two 52
elevations at once. You can be at that corner, and you can see the north and the west. We made an 53
effort here to tie those two together and to use that same green screen material and use the same either 1
vine or mixture of vines. We haven't chosen the plant types yet. Comments welcome on that. I didn't 2
show you from the north, from offsite the plant, because you can't see the north side from outside the 3
plant. There's another building blocking it. Our UV building blocks it. The south elevation we'll talk 4
about for a minute. Didn't get any comments from you on the elevation itself. I wanted to show you 5
what it looks like from the Baylands again. Here's looking from our Byxbee Park, the old landfill, which is 6
the open area on the eastern or right-hand side of this aerial. Those very small photos show you what it 7
would look like from those. Here they are blown up a bit. Our new building is visible; you see it best in 8
that central photo where the new building is photo shopped in the arrow on the left. These are shots 9
from various points at Byxbee Park. One of our commenters, Herb, raised—that's it again from that 10
lower elevation. Herb raised the point of what would it look like, though, from the very top of the park. 11
Those were taken down the hill closer to the building but not at a high elevation. Point E is the highest 12
point, 65 feet in elevation, at Byxbee Park. We went back and took a photo from there and photo 13
shopped our building in. On the left-hand side is the current look without our new building. On the 14
right-hand side, our new building is photo shopped in. Again, this is from 65 feet, and you're much 15
further from the sewage treatment plant now. You can see the Cor-Ten in the new building right here. 16
This is the new building here sticking up above our existing building. This is one of our existing buildings, 17
and then you see our new building sticking up where I've got the arrow right now. You get up higher, 18
and you do see more of the new building. That's all I was going to show you. We can come back to any 19
of those drawing needless to say as you have questions. 20
21
Chair Gooyer: I think we've got a pretty good handle on it. Thank you very much. I'll open it up to the 22
public. We have one card right at the moment, and that's for Herb Borock. Herb. 23
24
Herb Borock: How much time do I have, Chair? How much time do I have to speak? What's my—how 25
much time? 26
27
Chair Gooyer: That's fine. 28
29
Herb Borock: No, tell me. I don't have a number here. I need to know how much time I have to speak. 30
31
Chair Gooyer: Traditionally, you have 3 minutes. 32
33
Herb Borock: Okay, that's what I need to know. Thank you, Chair Gooyer. Just briefly on the 34
environmental in terms of greenhouse gases, the PowerPoint slide seemed to have gaps in years. I 35
would request that be filled in on missing years on 2006 and '07 and moving the explanatory text up in 36
years 2015 to 2018 so that you have a complete bar chart for the greenhouse gases. In terms of the 37
landscaping, even without the views that I requested, you can see from the south side views that that 38
landscaping that was installed a long time ago does not provide protection from existing parts of the 39
plant. Although we have nice simulations and a condition to maintain it, I don't know whether it's the 40
type of landscaping that's planted or the soil that it's in or what, but how can we get assurance that it will 41
do what we said it was going to do? I feel that recently there was an experiment planting some 42
evergreen, some eucalyptus and others, that didn't work out. Normally when you have a project just as 43
in the previous ones, you're willing to consider changing what it looks like in terms of bulk and mass to 44
meet your guidelines. Here, what's inside is really a given. You're looking at just a box to make look 45
better from the outside. When it goes to Council, I think that we need more explanation. Of course, this 46
is supposed to be the first component of a multi-component process. My first request in my mind was 47
why is the building so big. The existing filter presses I don't think are even labeled on the plans. I think 48
it's where the sludge dewatering and odor control equipment is, which would be next to where the public 49
will assemble for tours of the plant. Basically you're taking what's part of a continuous process and 50
making it a batch process for loading the trucks with the cake of the sludge. My question would be how 51
many truckloads of storage you would have on the roof considering possible disruptions either in the fact 52
that there's a movement away from having sludge being moved from one county to the other and that 53
the price of all the alternative places to use it keeps on going up. For the natural disaster like an 1
earthquake, if the transportation network isn't available, how much can you store in it? Right now it 2
would be two to three truckloads a day. At maximum capacity for the plant, it would be five truckloads a 3
day. How many truckloads can you put up there, and do you need more space? Thank you. 4
5
Chair Gooyer: Thank you. Could staff ... 6
7
Phil Bobel: I'll ask maybe Jamie to address how much storage we have. In the case of an emergency, 8
how long could we not truck the material? 9
10
Jamie Allen: Depending on if the bins were completely empty, we have 3 days of storage, and that 11
would get us through labor strikes, holidays when the hauler is not hauling and things like that. That 12
was the design we picked for how much storage. Three days of sludge storage. 13
14
Chair Gooyer: Any other questions? I'll bring it back to the Board. 15
16
Board Member Baltay: I do have a question, not about the sludge though. What is the proposed new 17
green screen? In more detail, what plant grows on it and how is it maintained? I see just the words 18
modular trellis system on the drawings, and it seems an important aesthetic feature. 19
20
Phil Bobel: I'm sorry. We were conferring. 21
22
Board Member Baltay: I'd like to know what the green screen feature is in more detail. What I see here 23
is the words trellis system, and I see a detail of the mechanical part of it, the green metal. What plant 24
grows on that? 25
26
Phil Bobel: One of the main ones that we're considering is that honeysuckle that I showed the picture of, 27
that we have on a different trellis. The plant folks want to consider this further. Here's the one that's 28
doing well right adjacent. It's this honeysuckle. It's got a red flower, really almost all of the year. 29
30
Chair Gooyer: Wynne, you had a comment or question? 31
32
Board Member Furth: I had a couple of questions. One was I read with interest the discussion about 33
odor control and ammonia formation and whatnot. I was looking at page 3-7 of the evaluation of 34
environmental impacts. It describes what the Air Quality Management District does, which is if you 35
complain enough times, it investigates. What's our own onsite protocol for dealing with possible error? I 36
realize people who work there, their noses become desensitized, but what's our process for making sure 37
this is not a source of objectionable odors? 38
39
Phil Bobel: We definitely test for H2S; that's the main thing you worry about, hydrogen sulfide gas. We 40
test to make sure it meets OSHA requirements regardless of the level of smell. There's two issues: 41
there's smell and there's actual harm. The OSHA requirement is based on harm. We test to make sure 42
that we're meeting the OSHA requirements for H2S onsite. We've been fortunate. We have sewage 43
sludge onsite that's undigested, that we're moving around currently. Having sewage sludge that's 44
undigested is not a new thing for us. We've been very fortunate we have very few complaints. I can't 45
even think when the last time we had a complaint was from the public, from somebody outside the 46
facility or our own people. Jamie, do you have any? 47
48
Jamie Allen: It's been years. 49
50
Phil Bobel: I shouldn't say we've been fortunate. I think we've done a good job. Therefore, we just 51
don't get complaints. 52
53
Board Member Furth: Do you have feasible options if odor problems do arise? The objection was you 1
can't just say it in an EIR or a Negative Dec rather that we'll figure that out if the time arises. Are you 2
confident there's adequate technology? 3
4
Phil Bobel: No, no. There's two systems that are designed to prevent an odor problem. Who's best to 5
describe that? Jamie, do you want to? 6
7
Jamie Allen: We have a bio-trickling filter to take the foul air and run it through like a wet media filter, 8
and the microorganisms break down, the hydrogen sulfide and any odorous compounds. Then it's 9
polished off with an activated carbon to bring down 99 percent in each unit to meet Air District 10
requirements. This is a tested design that the Air District will approve. 11
12
Board Member Furth: You're confident this isn't going to smell bad? 13
14
Jamie Allen: Right. 15
16
Board Member Furth: Thank you. 17
18
Chair Gooyer: Wynne, why don't you go ahead and start then? 19
20
Board Member Furth: Thank you for the new drawings and points of view. I wanted to talk about 21
landscaping. My colleagues are all trained to read drawings; I'm trained to read text. People who deal in 22
design often drive me berserk with their use of text. Just to start out, it says here that we're going to 23
have a use of drought-tolerant native and nonnative California plant materials. I didn't know if that 24
meant California plant materials that are native and not native to California or the more accurate 25
description would be you're going to use drought-tolerant materials. It has nothing to do with whether 26
they're native or nonnative. When I go on and read this, what you have is a little island of the South 27
Pacific here, or the big island. You've got New Zealand and Australia as your principal contributors, 28
generously assisted by South Africa and a little bit from the Mediterranean. Clearly this is not—we've just 29
had an interesting—which is lovely. I'm not arguing that you should undo the work you already did at 30
great expense, but it does seem to me that the way this is being presented to us is a little confusing. 31
Basically the plan here is what? It's not about California natives. As far as I can tell, it's not about great 32
habitat for local beetles and butterflies and moths. What is our philosophy here? Try and put it into the 33
Baylands plan. 34
35
Phil Bobel: I'd say there's a couple of main objectives. One main objective is to have something that's 36
going to be visually pleasing for a large percentage of the year, and it's going to be of a size that is going 37
to hide, frankly, as much of the facility as we can. That's a goal. To be drought-tolerant is a goal. When 38
you ... 39
40
Board Member Furth: To survive in the Baylands is a goal. 41
42
Phil Bobel: Yep. Those are our main objectives, and they don't always add up to—we don't always find 43
a native, that's why it says ... 44
45
Board Member Furth: I don't expect you to. I'm all in favor of that. Just I would prefer you didn't 46
reference it in the document as a goal. 47
48
Phil Bobel: I guess I'd call it a sub-goal. We want to try to maximize natives, but we've got these other 49
objectives, the size of the plant, looking good all year. We have to balance those objectives. 50
51
Board Member Furth: I think I understand that the landscape is described as open, serene and treeless, 52
clearly that's not going to do for screening of water treatment facilities. Clearly you have a well-53
established pattern there which involves the great California tradition of importing stuff from elsewhere. 1
I had two concerns. One was—I'm interested to hear from my colleagues on this—the shape of the 2
trellises or the screens that would hold up vines on the building itself didn't make a lot of sense to me. 3
When I was looking at the design, it seems to me that one of the more important views that's going to 4
be affected by this project is the one down the driveway. You've got a good picture of it; you showed it 5
to us. I forget which one it is. It focuses on rampant weeds in the front. Looking down the drive. 6
7
Phil Bobel: You mean the one looking down the driveway? 8
9
Board Member Furth: Yeah, exactly. That's identified in the description of the landscaping plan as one 10
of the areas of landscaping, but I didn't see any description of what was going to go there. It does seem 11
like an important—can you help me relate that picture to this drawing? 12
13
Phil Bobel: These are the new plants. 14
15
Jamie Allen: Phil, if you go back, those are not weeds. That's part of the $1 million landscaping. That's 16
a groundcover. That's all new groundcover. Those aren't weeds. 17
18
Board Member Furth: What is it? 19
20
Jamie Allen: I don't know the name of it. I'm not a plant person. It's not weeds; that's part of our new 21
landscaping. It's maintained by the city's ... 22
23
Phil Bobel: All of that is ... 24
25
Board Member Furth: Is this outside of the scope of this project, because your drawings start beyond 26
that? 27
28
Phil Bobel: Yes, they do. Our drawings start—I'll try to ... 29
30
Board Member Furth: What I'm getting at is it did not seem terribly well integrated. 31
32
Phil Bobel: The new ones are the ones that Amy's showing. They're right in front of the building. If you 33
want to go back, Amy, to the photo. All of that stuff is actually just beyond that very large, roundish tree 34
that's blocking the building, that tree. All that is ... 35
36
Board Member Furth: They won't be particularly visible from the street? 37
38
Phil Bobel: It won't be very visible from the street except for the green screen itself. You can see the 39
green screen is surrounding that one doorway. That'll be the most visible thing from the street. The 40
new plants won't be very visible at all from the street. Of course, remember this is a dead-end street. 41
The only people that will be here will be people coming into the sewage treatment plant. 42
43
Board Member Furth: This is the entry? 44
45
Phil Bobel: Yes. 46
47
Board Member Furth: You're planting Arbutus unedo, and you're planting a lot of other—I guess you're 48
planting ... 49
50
Phil Bobel: The planting that you see in front ... 51
52
Board Member Furth: That's picking up on the plants you already have on the site elsewhere. Is that 1
right? 2
3
Phil Bobel: Yes. It's integrated in. It's done by the same landscape architect, Siegfried. It was planned 4
in conjunction with one another. The green that you see here, except for the tall eucalyptus trees, is all 5
new. It was all part of the $1 million project that went through ARB about 2 years ago and was finished 6
last year. 7
8
Board Member Furth: My comment was going to be that it would be good if the new landscaping 9
integrated with this, and you had a sense of the whole thing fitting together. I can't tell that from the 10
plans that we have. It's hard ... 11
12
Phil Bobel: I don't know how to make you feel better about that, except ... 13
14
Board Member Furth: That's okay. It's the way it is. You're thinking of putting bright orange on the 15
building itself, right? 16
17
Phil Bobel: You mean the Cor-Ten? 18
19
Board Member Furth: Yeah. No, no, bright orange plants, the cape honeysuckle. 20
21
Phil Bobel: The flowers are, I would call it reddish. 22
23
Board Member Furth: It's a beautiful plant. It has pulled down more than one of my fences. My 24
comments, I have nothing to say that would recommend that we change this. It seems to be an 25
approach which isn't particularly anticipated by the Baylands documents, but clearly one that's already 26
well established on this site. 27
28
Chair Gooyer: Peter. 29
30
Board Member Baltay: Thank you. I can support the project as it is. I'd like to make a couple of quick 31
notes. One is that I had been concerned—I think several Board Members were—about the Cor-Ten steel 32
possibly staining the concrete. I appreciate your detail. I'm going to read the number of the detail, it's 33
tricky, so staff can be sure that that's incorporated in the future. It's Detail 1080024. It shows the Cor-34
Ten screening set back behind a small concrete parapet which would keep water from draining down the 35
face of the building. I'm just trying to emphasize to planners when they review the drawings it's very 36
important that it be kept that way. There was a similar detail not shown in the drawings, but I'll assume 37
it's going to be designed in the same way. That's 1080023. It's referenced on the plans, but I don't see 38
it in the plan set. I'll take it on faith that it will be done that way. The elevations show the Cor-Ten—39
that's the parapet at the very top of the building. Again, it's imperative that that be set back from the 40
edge of the concrete. We'll, otherwise, just have a very unattractive thing. 41
42
Phil Bobel: We're tuned into that principle. Greg can speak to that if you'd like. 43
44
Board Member Baltay: No, I think we've done plenty of talking. I just want to be sure it's in the record, 45
so Amy and her staff have a chance at just catching it. There's a lot of paper here, and it's hard to find 46
that detail. I'm not in favor of the green trellis. I think that in concept it's a good idea, but I'm afraid in 47
execution it may end up being a dead plant. I think the building is fine looking for what it is without that 48
additional feature. If I can just as a means of comment say, I think it was my comment originally that 49
you have an opportunity. You have this big truck gate down the end of this long road driving in. You 50
can architecturally do something with it like a trellis or a canopy over the door. You could be playful, 51
make a mouth out of it. Any number of things that will just sort of say what you're doing here, be fun 52
about it. It wasn't intended to be something that is in any way you have to do. I think the building is 53
cleaner without the green trellis on it, but I can support it either way. That's all my comments. Thank 1
you. 2
3
Chair Gooyer: Kyu. 4
5
Board Member Kim: My only comment would be regarding the green screen. It just looks too slapped 6
on. I think the way that it's drawn in the drawings, there doesn't seem to be a rhyme or reason for 7
things like the shape of the curve and the distances that they are from one another as well as the 8
amount that it's held off from the ground. I agree that the building would probably look a lot cleaner 9
without it or possibly reverting back to some of the cable vine systems. I think with the new landscaping, 10
I don't think we're going to see a lot of that. Maybe the building can do without it. Even with it, I would 11
be okay with it as far as the approval process. Just wanted to also reiterate the thanks for the details, 12
especially the Cor-Ten steel and some of the areas and components where there was a little bit of clarity 13
lacking, but I think it's been clarified now. Thank you. 14
15
Vice Chair Lew: Thank you for the revisions to the project. Also I did want to give you kudos for all the 16
photo simulations. Those were some of the best that I've seen in a long, long time. They're very high 17
quality, and it's very important out in the Baylands. I want to say too I do also like all the landscaping 18
improvements on the Bay side of the project. I do go running and stuff back there, and that all looks 19
great. I'm not so crazy about the entrance view of your landscaping. I think other Board Members have 20
mentioned that. Again, as Wynne was saying, it's missing a big design idea. I understand you've got 21
native plants, and that's fine. I think what I'm missing is the entry statement, the big idea for the 22
entrance, and it shows. At the end of the cul de sac there, when you look there, there's a mess of 23
different signs. There's the artwork. You've got two different gates. There's an old light fixture there. 24
There's just a lot of clutter. I think that was the point that we were trying to get at last time. My only 25
real main objection to the project is the green screen as you have it presented. I'm not opposed to 26
green screen. It can get really cluttered. It can get ugly really quickly. If you start doing it in all sorts of 27
funny shapes and different sizes, it's actually really ugly. The cleaner installations I've seen of it are not 28
the green or the black, just the silver color, no edge—what do they call it? There's some sort of like side 29
panels to work with the architecture of the building which is the 4-foot concrete panel, the 4-foot 30
concrete module. I can't support the green and the curves and all of that as it's proposed, but I'm not 31
opposed to it. It depends on the vine. Some vines are okay with wires, but other vines need more 32
support. Whether you go with wire or a green screen, it's going to vary depending on the plant. It 33
seems to me you're doing two different things here. Most of the time when we use a green screen it's to 34
push something in the background. Cover it with green and let it just sort of fade into the background. 35
If you put a plant that has orange or red-orange vines on it, then it's actually popping it into the 36
foreground. It seems like this is not resolved aesthetically. I'm sure it's workable, but the big idea is lost 37
on me at the moment. I would like that to come back to the Board or subcommittee at some point. I 38
don't have any other objections to the project. 39
40
Chair Gooyer: Can I make a suggestion then? Seeing as how I think we're all sort of in that same 41
agreement, I think the green screen was taken a little bit too literally. Can I suggest—I agree that the 42
arch really has no relationship to anything. I'd be willing to approve it without that, and put the money 43
towards landscaping that's already there. I mean, is everybody willing to ... 44
45
Vice Chair Lew: You're saying just on the west? It's also on the north. 46
47
Chair Gooyer: No, just get rid of the screens altogether. 48
49
Vice Chair Lew: On both sides? 50
51
Chair Gooyer: Yeah, on both sides. 52
53
Board Member Baltay: is the applicant okay with that? 1
2
Phil Bobel: Sure. We need to move forward with this. I'm shocked, frankly, and personally disappointed 3
as we were looking forward to it at the plant. We need to move forward. If that's what you're going to 4
do ... 5
6
Chair Gooyer: I agree basically the same sort of thing is that Alex's interpretation is exactly right. 7
Usually you do that to sort of make something disappear. You're making it punch out. 8
9
Phil Bobel: I'm sorry to interrupt. I said we hadn't selected the plant type. If that's the comment, we 10
can select the plant type without ... 11
12
Chair Gooyer: No, no, that's just—hang on. The gist of it being just that I think it's an interesting 13
approach, but the building I think looks cleaner with just the Cor-Ten and the concrete rather than just 14
trying to impose another element. Also because of the fact that it's somewhat random with the curve the 15
way you have it and the problem is that if this was out in the middle of nowhere as you have the fern, as 16
you said—I should say the planting—this is right up against the building where people are going to be 17
walking, everything else, that I have a feeling it's going to end up, at least the lower 10 feet of it or so, 18
being a mess pretty soon rather than anything else. If I could get a motion from someone, I think we'd 19
all like to approve the building. My approach would be just to remove the green screen on the two sides, 20
but I'll leave that up to someone. Can I get a motion from someone? 21
22
MOTION 23
24
Board Member Baltay: Sure. I'll move that we approve the building as submitted with the exception that 25
the entire green screen feature is removed. 26
27
Chair Gooyer: Can I get a second? 28
29
Board Member Kim: I'll second that. 30
31
Chair Gooyer: All those in favor. Opposed. 32
33
Amy French: Sorry. Could you make reference to the architectural review findings in your motion? 34
35
Board Member Baltay: I thought I did when I said that we'll—they're all in the staff report, and I support 36
the findings the way they're worded in the staff report. 37
38
Chair Gooyer: It's 3-2. 39
40
Vice Chair Lew: I'm opposed. 41
42
Chair Gooyer: 3-2 or 4-1? Wynne? 43
44
Board Member Furth: 4-1. 45
46
MOTION PASSED: 4-1-0-0 47
48
Mail Processing Center
Federal Aviation Administration
Southwest Regional Office
Obstruction Evaluation Group
10101 Hillwood Parkway
Fort Worth, TX 76177
Aeronautical Study No.
2016-AWP-456-OE
Page 1 of 7
Issued Date: 02/18/2016
Tom Kapushinski
City of Palo Alto
Water Quality Control Plant
2501 Embarcadero Way
Palo Alto, CA 94303
** DETERMINATION OF NO HAZARD TO AIR NAVIGATION **
The Federal Aviation Administration has conducted an aeronautical study under the provisions of 49 U.S.C.,
Section 44718 and if applicable Title 14 of the Code of Federal Regulations, part 77, concerning:
Structure:Building Sludge Dewatering Bld.
Location:Palo Alto, CA
Latitude:37-27-08.00N NAD 83
Longitude:122-06-39.00W
Heights:12 feet site elevation (SE)
77 feet above ground level (AGL)
89 feet above mean sea level (AMSL)
This aeronautical study revealed that the structure would have no substantial adverse effect on the safe
and efficient utilization of the navigable airspace by aircraft or on the operation of air navigation facilities.
Therefore, pursuant to the authority delegated to me, it is hereby determined that the structure would not be a
hazard to air navigation provided the following condition(s) is(are) met:
As a condition to this Determination, the structure is marked/lighted in accordance with FAA Advisory circular
70/7460-1 L, Obstruction Marking and Lighting, red lights - Chapters 4,5(Red),&12.
It is required that FAA Form 7460-2, Notice of Actual Construction or Alteration, be e-filed any time the
project is abandoned or:
__X__ At least 10 days prior to start of construction (7460-2, Part 1)
__X__ Within 5 days after the construction reaches its greatest height (7460-2, Part 2)
See attachment for additional condition(s) or information.
The structure considered under this study lies in proximity to an airport and occupants may be subjected to
noise from aircraft operating to and from the airport.
Any height exceeding 77 feet above ground level (89 feet above mean sea level), will result in a substantial
adverse effect and would warrant a Determination of Hazard to Air Navigation.
ATTACHMENT J
Page 2 of 7
This determination expires on 08/18/2017 unless:
(a)the construction is started (not necessarily completed) and FAA Form 7460-2, Notice of Actual
Construction or Alteration, is received by this office.
(b)extended, revised, or terminated by the issuing office.
(c)the construction is subject to the licensing authority of the Federal Communications Commission
(FCC) and an application for a construction permit has been filed, as required by the FCC, within
6 months of the date of this determination. In such case, the determination expires on the date
prescribed by the FCC for completion of construction, or the date the FCC denies the application.
NOTE: REQUEST FOR EXTENSION OF THE EFFECTIVE PERIOD OF THIS DETERMINATION MUST
BE E-FILED AT LEAST 15 DAYS PRIOR TO THE EXPIRATION DATE. AFTER RE-EVALUATION
OF CURRENT OPERATIONS IN THE AREA OF THE STRUCTURE TO DETERMINE THAT NO
SIGNIFICANT AERONAUTICAL CHANGES HAVE OCCURRED, YOUR DETERMINATION MAY BE
ELIGIBLE FOR ONE EXTENSION OF THE EFFECTIVE PERIOD.
This determination is subject to review if an interested party files a petition that is received by the FAA on
or before March 19, 2016. In the event a petition for review is filed, it must contain a full statement of the
basis upon which it is made and be submitted to the Manager, Airspace Policy & Regulation, Federal Aviation
Administration, 800 Independence Ave, SW, Room 423, Washington, DC 20591.
This determination becomes final on March 29, 2016 unless a petition is timely filed. In which case, this
determination will not become final pending disposition of the petition. Interested parties will be notified of the
grant of any review. For any questions regarding your petition, please contact Airspace Regulations & ATC
Procedures Group via telephone -- 202-267-8783 - or facsimile 202-267-9328.
This determination is based, in part, on the foregoing description which includes specific coordinates, heights,
frequency(ies) and power. Any changes in coordinates, heights, and frequencies or use of greater power will
void this determination. Any future construction or alteration, including increase to heights, power, or the
addition of other transmitters, requires separate notice to the FAA.
This determination does include temporary construction equipment such as cranes, derricks, etc., which may be
used during actual construction of the structure. However, this equipment shall not exceed the overall heights as
indicated above. Equipment which has a height greater than the studied structure requires separate notice to the
FAA.
This determination concerns the effect of this structure on the safe and efficient use of navigable airspace
by aircraft and does not relieve the sponsor of compliance responsibilities relating to any law, ordinance, or
regulation of any Federal, State, or local government body.
Any failure or malfunction that lasts more than thirty (30) minutes and affects a top light or flashing obstruction
light, regardless of its position, should be reported immediately to (877) 487-6867 so a Notice to Airmen
(NOTAM) can be issued. As soon as the normal operation is restored, notify the same number.
This aeronautical study considered and analyzed the impact on existing and proposed arrival, departure, and
en route procedures for aircraft operating under both visual flight rules and instrument flight rules; the impact
on all existing and planned public-use airports, military airports and aeronautical facilities; and the cumulative
impact resulting from the studied structure when combined with the impact of other existing or proposed
Page 3 of 7
structures. The study disclosed that the described structure would have no substantial adverse effect on air
navigation.
An account of the study findings, aeronautical objections received by the FAA during the study (if any), and the
basis for the FAA's decision in this matter can be found on the following page(s).
If we can be of further assistance, please contact Karen McDonald, at (310) 725-6557. On any future
correspondence concerning this matter, please refer to Aeronautical Study Number 2016-AWP-456-OE.
Signature Control No: 278720416-282045534 ( DNH )
Mike Helvey
Manager, Obstruction Evaluation Group
Attachment(s)
Additional Information
Map(s)
Page 4 of 7
Additional information for ASN 2016-AWP-456-OE
The proposal, submitted by the City of Palo Alto, will construct a two-story building with stack to 77-ft above
ground level (agl)/89-ft above mean sea level (amsl) at the Regional Water Quality Control Plant, in Palo Alto,
California.
This site point is approximately 0.57 nautical miles southeast of the Palo Alto (PAO) airport reference point;
2,328 feet direct distance from the Runway 31 physical approach end, at this closest civilian public-use landing
area.
The PAO Field Elevation (FE) is 6 feet above mean sea level (amsl); Runway 31 physical approach end
elevation is 7 feet amsl. The site elevation of this proposed structure point is 12 feet amsl.
The structure height exceeds the obstruction standards of Title 14 Code of Federal Regulations (CFR) Part 77,
as follows:
Section 77.17(a)(3) - (TERPS criteria); would penetrate the PAO RWY 13 40:1 departure obstacle clearance
surface (OCS) in the Initial Climb Area (ICA) by 29 feet (less than 35 feet). Mitigation: The proposed
structure height would not require an increase in the existing published departure climb gradient (cg), nor
would it require an increase in departure weather minimums. It qualifies as a 'low close-in' obstacle penetration
with climb gradient termination altitude 200 feet or less above DER, and upon receipt from the sponsor of the
7460-2 Part 1, a note will be added to the 'Take-off Minimums and (Obstacle) Departure Procedures in the U.S.
Terminal Procedures publication.
Details of this proposal were not distributed for public aeronautical comment because current internal FAA
Obstruction Evaluation policy exempts structures that would exceed only the above-cited Section 77.17(a)(3)
standard by 35 feet or less.
FAA airspace evaluation has found that the adverse effect of this structure is known. The structure height does
not require a change to any existing instrument published climb gradient or departure weather minimums and
would not have a significant adverse effect on the TERPS criteria. FAA evaluation finds that the proposal
would not create substantial adverse effect on visual aeronautical operations or lessen the utility of the
navigable airspace overlying the site.
Existing obstacles and terrain control the development of future approach and departure Terminal Instrument
Procedures for PAO landing area. Therefore, no further attempt to negotiate the structure to a lower height was
considered necessary.
This does not affect the right to petition for review determinations regarding structures which exceed the subject
obstruction standards.
AERONAUTICAL STUDY FOR POSSIBLE EFFECT UPON THE OPERATION OF AN AIR
NAVIGATION AID:
- None.
AERONAUTICAL STUDY FOR POSSIBLE INSTRUMENT FLIGHT RULES (IFR) EFFECT DISCLOSED
THE FOLLOWING:
Page 5 of 7
- The proposal would have no effect on any existing or proposed IFR arrival/departure routes, operations, or
procedures.
- The proposal would have no effect on any existing or proposed IFR en route routes, operations, or procedures.
- The proposal would have no effect on any existing or proposed IFR minimum flight altitudes.
AERONAUTICAL STUDY FOR POSSIBLE VISUAL FLIGHT RULES (VFR) EFFECT DISCLOSED THE
FOLLOWING:
- The proposal would have no effect on any existing or proposed VFR arrival or departure routes, operations or
procedures.
- The proposal would not conflict with airspace required to conduct normal VFR traffic pattern operations
at any known civilian public use or military airports, including PAO. The proposal does not penetrate the
maneuvering area associated with VFR Traffic Pattern operations at PAO. Aircraft at normal Traffic Pattern
altitudes and standard rates of descent have reasonable clearance above this structure.
- The proposal would not penetrate those altitudes normally considered available to airmen for VFR en route
flight.
The cumulative impact of the proposed structure, when combined with other existing structures is not
considered significant. Study did not disclose any adverse effect on existing or proposed civilian public-use or
military airports or navigational facilities. Nor would the proposal affect the capacity of any known existing or
planned civilian public-use or military airport.
Therefore, it is determined that the proposed construction would not have a substantial adverse effect on the
safe and efficient utilization of the navigable airspace by aircraft or on any air navigation facility and would not
be a hazard to air navigation.
This determination, issued in accordance with Part 77, concerns the effect of the proposal on the safe and
efficient use of the navigable airspace by aircraft and does not relieve the sponsor of any compliance
responsibilities relating to laws, ordinances, or regulations of any Federal, state, or local governmental bodies.
Determinations, which are issued in accordance with Part 77, do not supersede or override any state, county, or
local laws, avigation easements, or ordinances, or local zoning maximum heights.
Page 6 of 7
TOPO Map for ASN 2016-AWP-456-OE
Page 7 of 7
Sectional Map for ASN 2016-AWP-456-OE
ATTACHMENT K
ATTACHMENT L
Attachment M
Project Plans
(Hard copies for City Council Only)
http://www.cityofpaloalto.org/civicax/filebank/documents/50224