HomeMy WebLinkAboutStaff Report 2554City of Palo Alto (ID # 2554)
City Council Informational Report
Report Type: Informational Report Meeting Date: 3/5/2012
March 05, 2012 Page 1 of 5
(ID # 2554)
Title: Discussion of Value of Composting Permit
Subject: Response to Council Request for Additional Information on the Value of
the City's Composting Permit
From:City Manager
Lead Department: Public Works
Recommendation
This is an informational report and requires no Council action.
Executive Summary
Staff has evaluated the value of the City of Palo Alto’s (City) current composting
permit relative to permitting a new Energy/Compost Facility and has
determined that, although there would be some value to having a current
permit at the time that a future new facility underwent permitting, it can not be
concluded that this would be a significant value.As a result of this conclusion,
staff will close the composting facility when enough compost has been produced
to meet the landfill closure vegetative soil requirements as directed by Council at
the Council meeting on February 6, 2012. Council approved closure of the
composting operation once enough compost had been generated for closure,
dependent upon staff determination that maintenance of the existent permit
did not have significant future value. Staff estimates that the composting facility
will stop accepting yard trimmings by March 31, 2012, and that the composting
operation will be closed by June 15, 2012.
Background
Energy/Compost Facility
On April 5, 2010, Council directed staff to initiate a feasibility study for an
Energy/Compost Facility in Palo Alto. On August 2, 2010, Council approved a
contract with ARI to conduct the study (CMR:333:10). In October 2011, a Final
Feasibility Report was presented to Council (staff report ID#2037). The Final
Feasibility Report recommended that if a site at Byxbee Park becomes available
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through the passage of Measure E, the City should take further actions to
consider anaerobic digestion and other technologies for managing the City’s food
scraps, yard trimmings, and biosolids at the site. In November 2011, Palo Alto
voters passed Measure E, which undedicated from parkland a 10-acre parcel
(mostly on the landfill)for the City to consider an Energy/Compost Facility on the
10-acre parcel or some portion thereof. On February 6, 2012, a contract
amendment with ARI was approved by Council to assist the City with developing a
plan and timeline for consideration of an Energy/Compost Facility (staff report ID#
2361). This plan and timeline is scheduled to be presented to Council in early June
2012 for further consideration.
Landfill Closure
The Palo Alto Landfill is comprised of 126-acres and is divided into four Phases: I,
IIA, IIB, and IIC. Phase I (known as Byxbee Park)was capped and opened to park
users in 1991. Phase IIA was capped in 1992 and Phase IIB was capped in 2000.
In July 2011,the landfill reached final capacity and closed. Also in the summer of
2011, all of Phase IIA and a large portion of Phase IIB were opened to park users
after the environmental control systems were buried and additional clean soil was
brought in to bring these settled areas to final design grades.In November 2011,
an additional 7 acres of Phase IIB was opened to park users. Approximately 3
acres of Phase IIB is currently being used to stockpile a vegetative soil mixture
that will be used to construct the Phase IIC vegetative layer. Phase IIC is 51 acres
in size and is the final phase of the landfill to be capped. The City’s open windrow
composting operation occupies a 7.5 acre section of Phase IIC.The City has been
completing closure preparation activities including: 1)importing, placing and
compacting clean soil necessary to build the final cover foundation layer;
2)importing clean soil, mixing with compost, screening and stockpiling for the
vegetative soil layer; and 3)completing facility closures of the former cogen area
and the Recycling Center (now closed).
Capping of Phase IIC was originally scheduled to begin during the 2012
construction season in accordance with the landfill’s Closure and Postclosure
Maintenance Plan. On February 6, 2012, Council approved deferring capping of
Phase IIC to the 2013 construction season. Once capped, all areas of Phase IIB
and IIC will be opened to park users with the possible exception of the 10-acre
parcel described in Measure E.
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Composting Operation
As mentioned above,the landfill reached capacity and stopped accepting refuse
in July 2011. The City’s open windrow composting facility located on the landfill
has continued to accept yard trimmings from the contract hauler (GreenWaste),
City crews and City tree trimming contractors so that compost could be produced
and mixed with clean soil in order to produce a high quality vegetative soil
material. The vegetative soil layer will be used during capping and is being
stockpiled on a small portion of Phase IIB and on Phase IIC. Staff is estimating
that the quantity of compost needed for closure will be delivered to the site by
March 31, 2012.
Discussion
On February 6, Council directed staff to determine whether the existing
composting permit has a significant value.The Council discussion indicated that
the determination of significant value was to be with respect to the process of
obtaining a new permit for a potential future Energy/Compost Facility. Council
direction specified that if staff did not determine that the composting permit had
significant value,then staff would inform Council of this in an informational CMR
and close the composting operation once enough compost has been generated
for closure. Council further directed that if staff determined that the existing
permit does have a significant value then staff would return to Council with an
agendized item for further consideration.
City staff contacted staff from: 1) the Local Enforcement Agency “LEA” (County of
Santa Clara, Department of Environmental Health); 2) CalRecycle; 3) The San
Francisco Bay Regional Water Quality Control Board (RWQCB); and 4) The Bay
Area Air Quality Management District (BAAQMD). Staff at these agencies were
asked to render opinions on the advantages and value of keeping the existing
composting facility permit active relative to permitting a new Energy/Compost
Facility. The LEA and the RWQCB stated that from a permitting perspective, there
is no advantage in trying to keep the permit for the composting facility active for
the new Energy/Compost Facility permit application. They further indicated that
they thought it would neither help nor hinder the permitting of an
Energy/Compost Facility.The LEA stated that their response was for both the LEA
and CalRecycle since both agencies would approve the same solid waste facility
permit application.
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Staff from the BAAQMD indicated that there would likely be some benefit in
having an existing composting facility permit at the time that a future
Energy/Compost Facility is developed.The BAAQMD staff indicated that the City
would likely need Precursor Organic Compounds (POC) emission reduction credits
in order to obtain a permit for a new Energy/Compost Facility operation.The
BAAQMD staff said that the City could obtain credits from the shutdown of the
compost operation and transfer them to the Energy/Compost Facility. The credits
are based on the last three years before the banking application is submitted,and
the price per credit is market driven.The BAAQMD could not estimate the likely
value of these credits, but SCS Engineers (the City’s consultant)very roughly
estimated that this one-time value could be approximately $160,000.
From a local land use or California Environmental Quality Act (CEQA)process
perspective there is likely some convenience value in continuing to compost at
the City’s facility until permitting of a new Energy/Compost Facility would be
completed. This value is largely tied to what baseline to use for the final CEQA
analysis. As it is likely that the City would prepare a comprehensive
environmental analysis for a new facility, regardless of the selected baseline, this
value is also minimal. Therefore,staff is unable to conclude that the convenience
value with respect to the CEQA process is a significant one.
In Staff Report ID# 2361 (February 6, 2012 Council Meeting), staff estimated that
the short term cost to compost at the City’s facility was approximately equal to
the cost to transport these materials to the Sunnyvale Materials Recovery and
Transfer Station (SMaRT Station)for ultimate composting. In an email to Council
(http://www.cityofpaloalto.org/council/) on February 6, 2012, staff also
estimated that when vehicle and equipment replacement costs are added for a
longer term operation, then the City’s composting operation would cost at least
$17,000 per month ($204,000 per year) more than sending the yard trimmings to
the SMaRT Station (not including rent or major repairs).
Therefore,staff has concluded that the estimated $160,000 one-time value of
POC credits would be exceeded by expenses ($204,000/ year)and would
therefore not have a positive (or “significant”) value. Further, staff is not able to
conclude that the value of the existing composting permit from a land use or
CEQA perspective is significant.In accordance with Council direction, staff will
close the City’s composting operation when enough yard trimmings have been
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received and processed to meet the closure vegetative soil needs. Staff estimates
that the composting facility will stop accepting yard trimmings by March 31, 2012,
and that the composting operation will be closed by June 15, 2012. The closure
was scheduled to occur in December 2011 and the June 15, 2012 closure date
requires no new Council approval or action.
Prepared By:Ron Arp, Manager, Environmental Control Programs
Department Head:J. Michael Sartor, Director
City Manager Approval: James Keene, City Manager