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Home My WebLink About2002-03-04 City Council (10)City of Palo Alto City Manager’s Report TO: FROM: HONORABLE CITY COUNCIL CITY MANAGER DEPARTMENT: PLANNING AND COMMUNITY ENVIRONMENT DATE:MARCH 4, 2002 CMR:172:02 SUBJECT:2475 HANOVER STREET: SUPPLEMENT TO STAFF REPORT OF FEBRUARY 19, 2002 (CMR: 133:02) RECOMMENDATION Staff recommends that the City Council review the public comments received on the 2475 Hanover Project during the public review period for the Mitigated Negative Declaration, the responses to those comments, and: ¯Find that no further revisions of the Revised Mitigated Negative Declaration are required and no recirculation is necessary. ¯Approve the Revised Mitigated Negative Declaration (Attachment C of CMR: 133:02, attached to this report as Attachment B). ¯Approve the project application [01-ARB-100] based on the findings and subject to meeting the final conditions of approval set forth in Attachments A and B of CMR: 133:02. BACKGROUND The 2475 Hanover Street project appeared, as a Consent Calendar item on the February 19, 2002, City Council meeting agenda. Staff requested and the City Council voted (7-0, Mossar and Kleinberg not participating) to remove the item from the agenda and reschedule the item on a future Council meeting agenda. Public comments on the Revised Mitigated Negative Declaration were submitted between February 14 and February 19, 2002 from Dorothy Bender, John Abraham; Paul Collachi,. Joy Ogawa, John Baca, Aseem Das, and. Toni Stein. In responding to those comments (see Attachment A), staff reviewed additional information from the Regional Water Quality Control Board and Stanford University. CMR:172:02 Page 1 of 5 DISCUSSION The following is a list stating the general issues raised, who raised the issue and when, and a summary response to each issue. Detailed comments are provided in the attached Response to Comments, Attachment A. In summary, no revision of the Mitigated Negative Declaration, nor additional conditions of approval, are required for this project. Noise ¯Letter from John Abraham dated February 12, 2002 regarding noise conditions but not specifically addressing the MND. Summary Response This letter is being treated as a comment on the revised Mitigated Negative Declaration. Mr.Abraham requests a final check by the applicant and the City to ensurethe noise from mechanical units will meet the requirements of the City’s Noise Ordinance. Planning staff has added a condition (Condition No. 11.6) to the revised list of conditions in CMR:133:02 in response to Mr. Abraham’s concerns.This has been standard . condition on earlier projects and is acceptable to Stanford. Groundwater and Soil Contamination ¯Letter from Dorothy Bender dated February 13, 2002, regarding Groundwater and Soil Contamination. Comments regarding the MND from Antoinette Stein, Planning Commissioner, City of Menlo Park, are attached to Ms. Bender’s letter. Ms. Stein also critiques a memo staff prepared for her prior to the circulation of the Revised MND. ¯Letter (e-mail) from Toni Stein dated February 19, 20(~2, clarifying her comments. ¯Letters (e-mails) from Derek Whitworth, Regional Water Quality Control Board, San Francisco. Summary Response There is no potential-impact to air, water, soil, or persons from toxic or hazardous materials in this project and no mitigation measures are required. For the overall site, there is no chemical in the soil that exceeds clean-up standards or requires remediation. Therefore, the development :of this site does not pose any health risks to on site construction workers, residents across the street or future tenants. The existing Phase I and Phase II environmental assessments have established that levels of contamination are low enough to be acceptable for long term use of the site. Existing waste disposal regulations, provide for safe treatment of any material removed from the .site; existing healt~ and safety (OSHA) regulations provide, for protection of workers and others from any unsuspected contamination. The likelihood of finding contamination based on previously collected data is slim to none. CMR: 172:02 Page 2 of 5 The project site was originally used for agricultural purposes. Traces of agricultural chemicals remain in the soil at shallow levels. The site was then developed by Alza Corporation. Alza Corporation used chemicals regulated by the City as hazardous materials, and it was therefore subject to regular inspections by the Fire Department with respect to its handling of these materials. When Alza left the premises, additional inspections were performed and clean-up activities were supervised. Closure letters for Alza’s underground and above ground storage activities were completed by the Fire Department. During Alza’s occupancy of the site, a malfunction led to a chloroform contamination of the soil and water. Soil remediation of chloroform has been completed. Alza elected to have the Regional Water Quality Control Board supervise the remediation program. The groundwater.remediation is nearing completion under the Regional Water Quality Control Board’s review. The remaining chloroform affecting the groundwater is not near the garage footprint or proposed depth of grading of the project as finally proposed and approved. Because of the history of the use on site, there is no reason to believe there is any debris or contaminated soilunder the buildings, as there have been-regular monitoring, inspections and security on the site. The project includes soil sampling and classification for proper disposal so that soils leaving the site as a part of the grading will be handled safely. 3.~affic ¯Letter from Dorothy Bender dated February 14, 2002, regarding transportation and cumulative impacts. ¯Letters from Paul Collacchi, Council Member, City of Menlo Park, dated February 9, 2001 arid February 14, 2002, regarding traffic impacts. ¯Letter from Joy Ogawa dated February 18, 2002, regarding traffic impacts. Summary Response The project submittal ineluded a traffic study that enabled Menlo Park to perform its alternative analysis, in which it correctly utilized the Palo Alto standards for identifying a potentially significant traffic impact, but used an incorrect baseline figure. As a re.sult, Menlo Park greatly overstated the traffic impact. There is an existing 51,500 square foot building on the site. For CEQA purposes, that entire building must be assumed to be occupied with permitted uses to establish the baseline situation. The traffic impact is only the traffic attributable to the new square footage. Menlo Park only credited the project with that part of the building actually leased on a particular day. That is not the correct standard for CEQA analysis, though it is used for other kinds of studies. Comments also addressed the alleged inadequacy of the Council’s adopted program.for traffic impact mitigation through the Research Park impact fee program. However, at Council’s request, Stanford has agreed to implement an interim shuttle: This is a project condition rather than a mitigation measure because, under the City’s current criteria for significant traffic impact, there is no significant impact. CMR: 172:02 Page 3 of 5 o Cumulative Impacts: ¯Letter from Dorothy Bender dated February 14, 2002 ¯Letter (e-mail) from John Baca dated February 19, 2002. Summary Response The existence of cumulative impacts does not trigger the requirement for an Environmental Impact Report (EIR). An EIR is required only if there are cumulative impacts that are significant and the impacts of this project itself are "cumulatively considerable." Assuming that the commenting persons wish to indicate that an EIR should be prepared, they do not provide any factual basis for their assertion. The Council identified and addressed potential significant cumulative impacts with regard to community services funding and housing in the Revised Mitigated Negative Declaration and the applicant agreed to .project conditions which mitigate those impacts. The Council has decided to. undertake a review of its CEQA thresholds and update the environmental documentation for the Research Park area of the City. However, this project, which conforms to the Land Use element of the adopted Comprehensive Plan and to zoning which is consistent with that plan, does not, as conditioned by the Council and under the standards used by the City in evaluating this project and Others, have "cumulatively considerable" impacts which would require the preparation of an EIR. o Combination of issues ¯Letter (e-mail) from John Baca dated February 19, 2002, regarding building materials. ¯Letter (e-mail) from Aseem Das dated February 15, 2002, supporting Council’s conditions and vote for environmental impact report. Summary Response A concern was raised that exterior copper might be used on the building and cause damage to the environment. No copper is proposed or approved on the building exterior. Stanford’s and Regional Water Quality Control Board’s Responses to comments ¯Letter from William T. Phillips dated February 15, 2002. ¯Letter from Geomatrix dated February 15, 2002. ¯Letters from Derek Whitworth dated February 15 and February 26, 2002. These letters are referenced according to each issue discussed in staff’s detailed Response to Comments, attached. ATTACHMENTS Attachment A: Attachment B: Attachment C: Response to Comments on revised Mitigated Negative Declaration CMR:133:02 Letters from Public and Stanford from packet of 1/19/02 CMR: 172:02 Page 4 of 5 PREPARED BY: DEPARTMENT HEAD REVIEW: Amy French, Senior Planner LISA GROTE Chief Planning Official CITY MANAGER APPROVAL: Assistant City Manager co:Dorothy Bender, 591 Military Way, Palo, Alto, CA 94306 John Abraham, 736 Ellsworth Place, Palo Alto, CA 94306 Joy Ogawa, 2305 Yale Street; Palo Alto, CA 94306 John Baca, P.O. Box 18527, Stanford, CA 94309 . Aseem Das, 2211 Williams, Palo Alto, CA 94306 Paul Collachi, City Council Member, City of Menlo Park, 701 Laurel Street, Menlo Park, CA 94025-3483 Toni Stein, Planning Commissioner, City of Menlo Park, 701 Laurel Street, Menlo Park, CA 94025-3483 CMR:172:02 Page 5 of 5 ATTACHMENT A Response to Comments on Revised Mitigated Negative Declaration 2475 Hanover Street Comments Received: Letter from Dorothy Bender dated February 13, 2002, regarding Groundwater and ¯ Soil Contamination. It sets forth comments stated to be those of Antoinette Stein, alleging defects in the scientific studies submitted regarding soil and water pollution. Ms. Stein is described as holding a Ph.D. in Environmental Engineering in Air Quality Control, a Hearing Board Member of the Bay Area Air Quality Management District, and a Planning Commissioner of the City of Menlo Park. General Response: This document is not signed by Ms. Stein, though she has submitted comments in her own name. While the City does not apply formal evidentiary standards .to comments on environmental documents, this "double hearsay" of alleged expert testimony is inherently less reliable than a direct communication from Ms. Stein. Comment: The project site has been undergoing remediation for both groundwater and soil contamination; remediation is not yet complete and is ongoing. Groundwater still has concentrations of pollutants that exceed acceptable levels. Response: The site has been undergoing remediation, a fact that was mentioned in the MND. Page 14 of the original .MND notes operation of the remediation system is ongoing to further reduce chloroform levels in soil and groundwater. The revised MND reflects data staff received in January 2002 (listed as Source Reference # 14) that indicates (1) the soil remediation goal has been reached and the soil is considered clean of the chloroform release, and (2) the groundwater chloroform concentrations are close to the cleanup goal. Remediation began in June 2001 and had decreased concentration levels of chloroform in the groundwater by 90 percent before interruption of electrical service Ied to suspension of remediation on October 30th. (Aquifer Sciences Report; Regional Water Quality Control Board (RWQCB) memorandum of February 15, 2002.)Groundwater remediation resumed in February 2002. No revision or other response required. 020226 s)7 0091029 Comment: There is no mention [in the MND] that the site has had on-site underground storage tanks (UST) for hydrocarbon materials. The MND needs to incorporate discussion of this fact. Response: It is unclear from this comment to which tank Ms. Stein refers. The underground tank that existed at 1275 California Avenue and the above ground tank that existed at 2575 Hanover are discussed on page 14 of both the original and revised MNDs under Hazards and Hazardous materials. No revision or other response required. Co Comment: Additionally [to mentioning the presence of the underground storage tanks] the box under VIII(d) should be checked as "potentially significant unless mitigated." Response: There is no factual basis given fo) Ms. Stein’s assertion that the previous existence of an underground storage tank is potentially significant impact unless mitigated. No revision or other response required. Comment: The Lowney Associates report shows a heptachlor epoxide reading at a Concentration of 0.16ppb (sic) corresponding to.a cancer risk above the one in one million threshold for human safety set by EPA Region 9. The report also states that exceeding this level makes further evaluation of potential risk appropriate.. Response: Table 2 on Page 4 of the Lowney Associates report does show one heptachlor epoxide reading of 0.16 mg/kg (parts per million) but the site-wide statistical average is. 10 mg/kg. The Regional Water Quality Control Board, which is overseeing the remediation of this site, states that the appropriate standard for the proposed use (office) is the industrial PRG, 0.27 mg/kg. Current concentrations in the soil are below this value and do not require remediation. Toni Stein cited the residential Preliminary Remediation Goal (PRG) of 0.53 mg/kg. Residential PRGs are designed to evaluate risk to individuals living on a Site for a prolonged period of time; industrial PRGs are designed to evaluate risk to individuals who work at a .site. The appropriate standard for this project, and evaluating potential impacts for CEQA, is the industrial PRG. During redevelopment, the site will be graded using dust control measures as required under conditions of project, approval, and as required by BAAQMD. There is no potentially significant impact arising from heptachlor epoxide on the site or to the 020226 syn 0091029 2 eo adjacent neighborhood as confirmed by RWQCB. (See Derek Whitworth letters, Exhibit 2). Comment: Because (1.) buried debris may be .present under on-site structures and may be encountered during grading activities, (2) DDT was found on site near the corner of Hanover and California at a concentration higher than the California hazardous waste limit of 1 ppm, and (3) heptachlor epoxide exists at Boring B-1 at levels that exceed the EPA Region 9 cancer risk threshold and averaging this concentration with other boring concentrations is unsound engineering practice, the MND should provide that (a) excavation only take place when an organic vapor meter (OVM) is operating at the site and screening for chemically impacted soil; and (b) an environmental consultant should be on site at selected intervals during excavation and grading to observe soil management procedures and to be notified if impacted soils are identified and sampling of soil is needed. Response: Ms. Stein’s allegation about the averaging method used in the Lowney report is unfounded. The statistical evaluation was done based on the U.S. EPA, 1989, Risk Assessment Guidance for Superfund, Volume 1, Human Health Evaluation Manual, Part A, Interim Final, Office of Emergency and Remedial Response, Washington, D.C. (note that this is not a superfund site.) The mitigation proposed by Ms. Stein is not necessary or required.. There is no health risk from the contaminants, which are below the Risk Based Screening Levels. An organic vapor meter is used for volatile organic compounds and its use is not applicable for monitoring these non-volatile pesticides, which will not become airborne and migrate. If issues were to arise at the site, contractors are required to follow 29 CFR " 1910.120 which is the OSH_A reg for hazardous waste operations. The standard has the following requirements: training (40 hrs for all persons who may be exposed to health hazards and 8 hours for supervisors, 8 hour annual refresher); medical monitoring; health and safety plan; exposure monitoring and emergency planning within the health and safety plan. The applicant’s contractor will follow a Health and Safety Plan as required to meet OSHA requirements, and Aquifer Sciences is performing the monitoring functions on the site. (See Stanford’s responses.) Comment: The Department of Toxic Substance Control (DTSC) and the Regional Water Quality Control Board should be made aware of the MND because of the possibility of buried debris. Managing toxics is the statutory authority of the DTSC. 020226 s~n 0091029 No Response: The project site, known as the Alza Site, is the subject of a remediation agreement with the San Francisco Regional Water Quality Control Board. Therefore, the Board, rather than DTSC, is the lead agency for environmental oversight. The Board was given the opportunity to review the MND during the public review period. Comment: A "potentially significant unless mitigated’.’ impact should be described for air quality, because the professional reports provided to the City indicate that buried debris may be present. If it is dug up, the soil could be aerated and the pollutants volatilized and impact persons breathing in the vicinity. MND should require that any impacted soil be covered immediately upon encounter, and activity suspended until applicable BAAQMD permits are obtained. Response: Because of the history of the use on site, there is no reason to believe there is any debris or contaminated soil under the buildings, as there have been regular monitoring, inspections and security on the site. The levels of contaminants in the soil would not pose a health risk to people on site or off site. Again, the trace chemicals in the soil that are below clean- up standards are not volatile and are not airborne outside of the soil, and will not migrate. BAAQMD regulation 6-305 requires standard dust suppression measures to prevent emission of particles into the air. There is no impact because Condition of Approval No. 2.21 requires standard dust suppression practices during construction. In addition, Stanford has stated they have obtained a permit from the BAAQMD for demolition, and site grading will meet BAAQMD requirements. Therefore, there will be no impact upon public health. No revision of MND or conditions ofproiect approval required. Comment: The risk based on soil sampling must be assessed to assure that no known cancer risk exists during excavation. Response: Because no contaminants on the site exceed the appropriate Preliminary Remediation Goals set by EPA Region 9 on the site, no further risk assessment is needed. Heptachlor epoxide does exceed the residential PRG but is less than the industrial PRG. Ms. Stein provides no factual basis for her assertion that a residential PRG should be used for heptachlor epoxide instead of the industrial standard recommended by the RWQCB. The contaminant, resulting from earlier agricultural operation on the site, is not a volatile organic compound and will not migrate over the nearby residential neighborhood. 020226 syn 0091029 Table 2 on Page 4 of the Lowney Associates report does show a DDT reading of 1.17 mg/kg (parts per million) at one of five borings (B-l). The site-wide statistical average is 0.74 mg/kg. Mr. Whitworth of the Regional Water Quality Control Board agrees with the conservative risk assessment method used by the applicant, which applies this statistical average as allowed under EPA’s risk assessment guide referenced in Response to Comment le. Ms. Stein states that the California hazardous waste limit is 1 part per million. That is the standard used by the State of California when classifying waste that is to be moved off-site. It is not the standard used in evaluating the safety of a site. The DDT concentration on site does not present a safety hazard, using Region 9 PRGs, even for residential use. Again, Mr. Whitworth notes that the level of DDT on the site would not pose a risk to people on site or off site (see Exhibit 2). The remaining comments in Ms. Bender’s letter (page 3 of 3) do not pertain to the MND. In sulnmary, given standard conditions of approval that were applied to the project, the risks associated with excavation of soil are less than significant, and the project will not violate any air quality standard so there will be no ~mpact. No revision of MND or conditions of proiect approval required. Letter from Dorothy Bender dated February 14, 2002, regarding Transportation and Cumulative Impacts, received February 14, 2002. Comment: Traffic increase is understated because site is credited with traffic generated by existing buildings, even though a portion was not leased in 2001. Response: California law requires that theCity, when analyzing impacts under the California Environmental Quality Act, use as a baseline normal permitted activity on .the site, not the intensity at a particular time. Intensity of activity fluctuates, while the permitted level of activity is more stable. Therefore, the City overstated the traffic impact in its analysis, rather than understating it. Individuals commenting believe that the City has failed to ’identify a significant traffic impact of the Hanover project because it assumed at least partial occupancy of the existing buildings on site when calculating the increase in traffic that a new building would produce. 020226 syn 0091029 5 However, California law favors the use of a baseline that assumes occupancy of all space in the existing building(s), not just the portion actually rented in 2000, or on a particular day in 2000. See, for example, Fairview Neighbors v. County of Ventura (1999) 70 Cal. App. 4th 238. For most of their history, these buildings have been rented. While Stanford wishes to replace them with newer buildings, there is no evidence that they are unusable as they exist. Therefore, to the extent the City has used an incorrect baseline, it is by crediting the site with only 31,000 square feet of existing use, instead of the entire 5.1,500 square feet. This resulted in an overstatement of the impact, not an understatement. As discussed previously, the one hundred-trip threshold is not, under City standards, a threshold for environmental impact; it is a threshold for further studies. However, the point is moot in this case. The approach used by the City, which showed fewer than 100 trips, did not understate potential impacts. No revision of MND or conditions of project approval required. b.Comment: The shuttle is not included in mitigation measures. Response: This is correct. The shuttle is a project condition, agreed to by the applicant. It is not identified as a mitigation measure because, under the city’s criteria for significant traffic impact as they currently exist, there is no significant impact Furthermore, the City has adopted an across the board mitigation measure for impacts that do not approach the level of significant through its Research Park mitigation fees. In this case, there will also be a shuttle until planned intersection improvements are constructed. No revision of MND or conditions of project approval required. 020226syn 0091029 Comment: Cumulative impacts are not considered. Response: The net new, nonexempt floor area is 30,428 square feet, and does not exceed the maximum floor area ratio permitted by LM District regulations for development on the project site. On page 17 of the MND, staff included the statement, "The project will not create considerable cumulative impacts since it is located in an area that is largely developed, affording only a limited degree of additional redevelopment possibilities." On page 12 of the MND, the "no impact" box is checked, with a reference to the Comprehensive Plan. The Comprehensive Planwas adopted by the City Council after public review and comment of an Environmental Impact Report which contained Statements of Overriding Considerations for the growth within the City set forth in the Comprehensive Plan. The total, cumulative development within the Stanford Research Park has not exceeded the total floor area as described in the Comprehensive Plan, although the total development is nearer to the total than envisioned at this time. According to data from the Congestion Management Agency, the level of service at the applicable Stanford Research Park intersections may have improved in the recent past. In addition,, the City Council has stated that a supplemental Environmental Impact Report should, be prepared to address cumulative growth. Staff will address the issue of cumulative growth at a future City Council hearing on this topic. Letter The existence of cumulative impacts does not trigger the requirement for an Environmental Impact Report (EIR). An EIR is required only if there are cumulative impacts that are significant and the impacts of this project itself are "cum, ulatively considerable." The Council identified and addressed potential significant impacts with regard to community services funding and housing in the Revised Mitigated Negative Declaration and the applicant agreed to project conditions which mitigate those impacts. This project does not, as conditioned by the Council and under the standards used by the City in evaluating this project and others, have "cumulatively considerable" impacts which would require the preparation of an EIR. from John Abraham dated February 12, 2002. This letter is being treated as a comment on the revised Mitigated Negative Declaration. Mr. Abraham requests a final check by the applicant and the City to ensure the noise from mechanical units will meet the requirements of the City’s Noise Ordinance. (Palo Alto Municipal Code Chapter 9.10). Mr. Abraham does not identify a new impact or request a.new mitigation measure requested, but his suggesti~)n on administration is a good one. Planning staff has added a condition (Condition No. 11.6) to the revised list of conditions in CMR: 133:02 in response to Mr. Abraham’s concerns. This has been standard condition on earlier projects and is acceptable to Stanford. This action does not require further circulation of the Mitigated Negative Declaration. CEQA Guidelines 15073.5 (c) (2) and (3). Mr. Abraham also suggests certain changes in the conduct of acoustical studies. He does not suggest alteration in the City’s Comprehensive Plan and municipal code noise standards. No additional response or action is required. However, Stanford has contacted Mr. Abraham to discuss his concerns and is reviewing his suggestion with their acoustical engineering consultant. 020226 syn 0091029 No revision of MND or conditions of project approval required. Letters from Paul Collacchi, Council Member, City of Menlo Park, dated February 9, 2001 and addressed to City Council. A shorter’version of this letter, dated February 14, 2002, addressed to Amy French, Senior Planner, raises the same environmental issues and includes the same attachments as the letter of February 9th" Comment: When Menlo Park traffic engineers calculate the impacts of the project, they obtain an increase in critical delay at the Hanover/Page Mill intersection of 7.10 seconds and change in the volume over capacity ratio of .015. These figures exceed the Palo Alto standard of significance of 4.0 seconds and V/C change of .01. Therefore, the impact should be identified as "potentially significant unless mitigated." Response: The Menlo Park traffic engineers have correctly identified the Palo Alto standards for identifying a potentially significant traffic impact. However, the Menlo Park calculations are based on 51,000 square feet of new building, instead of 30,000. This results in figures showing a significant impact, but this is not the choice of baseline directed by California law. See Response to. Comments No. 2a. The City did, in fact, review a traffic study, and that information was included in the original MND as well as in the information presented to Council at its earlier hearing. It was that data that enabled Menlo Park to perform its alternative analysis. Comment: The time lag between collection of impact fees and the construction of improvements means there could be an unmitigated impact for some time. If it is disclosed as such, Council might be. able to require a shuttle, or if that proves inadequate, reject the MND. Response: The City’s analysis does not. show a significant traffic impact. However, Stanford has in fact, at Council’s request, agreed to implement an interim shuttle. See Condition of Approval No. 9.1 in Attachment B of CMR 133:02. Comment: Mr. Collachi could not, personally, accept fees as a mitigation measure for traffic impacts and councilmembers may reject this "embedded policy decision made by staff." Response: Mr. Collachi is in error as to the source of the policy decision to impose (and accept) impact fees in the Research Park. This was a decision 020226 syn 0091029 o o made by the City Council in 1989 after the Citywide Land Use and Transportation Study when it adopted Ordinance No. 3984 establishing the Transportaion Impact Fee. He is correct that the City Council can alter that decision. Mr. Collachi asks to see a description of the mitigations at Page Mill and Hanover Street and comment on the adequacy of these mitigations to address the potential impact of the project. As stated in the MND, the project includes payment of the City’s standard Stanford Research Park Traffic Mitigation fee for the additional floor area. Design is scheduled for FY03/04 and construction in FY04/05. No revision of MND or conditions of project approval required. Letter from Joy Ogawa dated February 18, 2002. Commeni: Traffic analysis should assume that site was vacant; prior use was research and development. Response: See Response to Comment 2a.. Comment: Traffic analysis should have compared Research and Development use with Office use. Response: See Response to Comment 2a. Comment: Impact fees calculated on new square footage, rather than total square footage, on the site, are inadequate because correct baseline was an empty building. Response: See Response to Comment 2a as to state law on inclusion of existing square footage in baseline. Because the City’s proposed impact fees are based upon the nexus between increased intensity of development, they cannot be charged against existing square footage and therefore must consider existing development. No revision of MND or conditions of project approval required. Letter (e-mail) from John Baca dated February 19, 2002. Comment: Will exterior copper be used at 2475 Hanover? If so, it should be identified as a "potentially significant unless mitigated" impact. The 020226 syn 0091029 City has yet to adopt an ordinance prohibiting the use of architectural copper. Response: The project as approved does not use exterior copper.. Any future change to exterior copper would require City review. Since none is proposed now, no action is needed. Comment: Antoinette Stein’s comments of February 13, 2002 are full of details and should be responded to fully; does council and staffhave time and expertise to respond to opposing expert opinions? If not, MND should not be approved. Response: See responses to Letter. #1, above. Comment: There is a real need for a supplemental EIR in the area of the Research Park to provide good data and good analysis to enable good decisions, in particular with regard to cumulative impacts. This is not just about 2475 Hanover. Response: As a matter of information, Council has voted that additional new development in the Research Park will require some form of environmental impact report. No revision of MND or conditions of project approval required. Letter (e-mail) from Aseem Das dated February 15, 2002. Comlnent: Assem Das supports conditions of project approval added by Councit at its meeting of January 14, 2002 and supports requirement of supplemental EIR before additional development in the Research Park. No revision of MND or conditions of project approval required. 8.Letter go (e-mail) from Toni Stein dated February 19, 2002. Comlnent: The Lowney report statement "buried debris may be present under on-site structures" would include areas under the existing buildings which have not to date been examined. . Response: See responses to letter #1. 020226 syn 0091029 No Comment: The footprint of the underground garage is directly where site remediation is ongoing for chloroform, as shown on Scheme D on sheet 7 of MBT Architecture drawings. Co Response: Scheme D was one of several alternative preliminary schemes reviewed by the City’s Architectural Review Board. This sheet was included in the plan set to show the architect’s design process. Scheme D does not reflect the proposal that was reviewed and recommended for approval by the Architectural Review Board. Comment: DDT and heptachlor epoxide exist on the property across from residences and the Geomatrix memo states residents may be potentially exposed via inhalation of dust and monitoring to verify management of windblown dust is proposed. Ms. Stein .restates her opinion that two checklist boxes under "potentially significant unless mitigated" should be checked for hazards and air quality. Response: Ms. Stein provides onlypartial information in her letter. Geomatrix notes that the development proposal includes dust monitoring, and there is no public health risk. Again, the standard dust suppression requirement is a condition of project approval, which will adequately , control airborne particulates. Als0, as previously noted, BAAQMD 6-305 requires any developer to control dust from project construction and Aquifer Sciences will be monitoring the construction site. There is no evidence, given the low concentrations and non-volatile nature of the pesticides detected in shallow soil, that thes~e constituents would cause an air quality impact during construction. Therefore, the "no impact" response under Air Quality in Section III (b) is correct and the "less than significant" response under Hazards VII (d) is correct. No revision of MND or conditions of proiect, approval required. 9.Letters from Stanford Management Corporation: Letter from William T. Phillips dated February 15, 2002 Attaching letter from Geomatrix Consultants to February 15, 2002 (Exhibit 1) Annette Walton, dated 10.Letters from Derek Whitworth of Regional Water Quality Control Board (RWQCB), Exhibit 2. 020226 syn 0091029 °Z/FEB, IS, 2002~ 2:57PMx ~°STANFORD MANAGEMENT 650 854 9268~"N0,8~91 P, 2 ~" Ms. Annette W~lton Starffor~k~.anagemen( Company 2770 8an I-till Road Menlo Park, Califomia 94025 (j~EOMATRIX Exhibit 1 (Letter 9 attachment) Data Review 1275 California Avenue and 2575 Hanovrr Sleet Palo Alto, California Dear Ms. Walton: As you requested, Oeomatrix Consultants, Inc. (Geomatrix), reviewed the analytical results for soil and grab groundwater sampling recently eoll~eted by Lowney Associates (Lowne)’) at the subject site. We did not review the sampling locations or data that may have been generated at the site by others. The put~s~ of our review was to evaluate whether constituents detected in soil at the sit~, posed a risk to human health during construction and long-term occupancy of the site. We understand that the proposed site use is commercial, and that the upI~r foot 1o two feet of soll across the site will be graded and likely exported. Bdow-grade parking and two 21,000 square-foot buildings will be built on the 4.7-acre site. The data generated by Lowney indicates that, in general, on-site soil is not impacted by volatile organic L’tmapounds (VOCs), semi-volatile organic compotmds (S¥OCs), or polychlorinated biphenyls (PCBs). One soil sample collected ~proximately 4.5 feet below ground surface contained bis(2-ethylhexy)phlhzlate at a low concentration. This eonstituertt is a plasticizer, and is oommonly detected as a result of the use of plastic gloves and other plastic equipment during environmentaI sanapling. Metals were detected within background conesfitrationm Based on th~ ¥OC, SVOC, PCB, and metals data generareA, we conclude that no adverse environmental impacts from these analytes are present at the locations evaluated. Surface soil contained low concentrations of organochlorine pesticides, incl, uding DDT, heptachlor epoxtde, alpha-chlordane, and gamma-chlordane. The residential preliminary r~m~diation goals (PRGs)1 used to evaluat~ the concentrations of the orgmaochlorine pesticides ar~ based on multiple.exposure pathways, including ingestion, direct oontap, t, and ir~halation and assume that a ~rson lives on ~he site for 365 days per year for 30 years, As the site is being developed for commercial/ind~.~trial use and the duration of construction is short relative to 30 years, residetatial PROs are highly consercative screening levels for this site. The maximtma concentrafio:as of each ot’the organochlorlne pestieldes detected ~ welt below their respeciive industrial. PROs, which are more appropriate screening concentrations given the chemicals detected, the proposed future site use, and the short duration over which a constrttetion worker will be working at the site. ~ United Stat~s Environmental Protection Agency. R~glon 9. Preliminary Rsm~diafion Ooaks, 2000. Engineers, GJaologis~s, and Environmental Sc~entiz~ Ms. Annette Walton Stauford Management Company Februa~! 15, 2002 Page 2 of 2 Pestidde DDT H~pta~h~.¢po~{de Alpha-chlordane G .am_ma~hlordane " "Concentrations in parta per million (ppm) Maximum Concemrafion in Soil ~.17 0.16 0.62 0,32 Industrial PRG (FPm) 12 0,27 11 _l! Off-slte residential receptors may be potentially exposed via inhalation of dust that migrates off site, which is the least significant of the pathways considered in devdoping the PRO. The off- site coacentrations would be significantly less than on sit~, and mo~toring to verify management of windblown dust is being proposed during the d~elopment. Therefore, for future development of the site, the concentrations of pesticides in soil at this sit~ do not po~e a public health risk. We appreciat~ ~he opportunity ~o provide consulting services to Staford Management Company. Please ¢alle~ther oft.he undersigned if you hav~ any fur~er questions. ,,~ Since~dy yours, GEOMATRIX CONSULTANTS, INC. Ann M:,~olbrow Senior Toxicologist Susan M. Gallardo, PE Principal Engi.ucer French, Am~/ From: Sent: To: Subject: Derek Whitworth [Dw@rb2.swrcb.ca.gov] Friday, FebruaQ/15, 2002 1:09 PM amy_french@city, palo-alto.ca, us Re: 2575 Hanover Street Palo Alto Exhibit 2 (Letter 10) Ms Amy French: I am responding to the email information attached to this response and the fax of the Memorandum from Dr. Antoinette Stein dated Feb 13, 2002. On March 20, 2001, ALZA signed an agreement with the San Francisco Regional Water Quality Control Board for Board oversight of remediation work on the Hanover St site. This effectively made the Board the lead agency for environmental oversight. Investigations completed in February 2001 had shown very localized soil and groundwater contamination by chloroform. Chloroform had been used by ALZA in its manufacturing operations and the contamination found in the soil was close to where it had been used. Thechloroform was at a depth in the soil that it could pose a potential threat to groundwater. After submission and review by the Board, remediation work, primarily soil vapor extraction, started in June 2001 and, based on subsequent reports prepared by Aquifer Sciences on behalf of ALZA, has been very effective in reducing the concentration of chloroform. An interruption in power supply had caused a change in the remediation operations to address thefinal traces of contamination. It is expected that the remaining spots with the highest contamination will remediated to non-health-risk levels using the criterium of drinking water. My understanding is that this property, formerly industrial, is being redeveloped for commercial uses and it will not be used for residences. I understand that for evaluating health risk on commercial and industrial sites then a one in one hundred thousand excess cancer risk would be appropriate. If one is usi.ng the Region 9 PRGs, use the industrial screening numbers. Similarly if using the SFRWQCB Risk Based Screening Levels look at industrial. For chloroform and drinking water other numbers apply. When we looked at the data our concern was for impact on groundwater. We did not review data for near surface soil samples so I cannot comment on the concentrations and associated risks in the original report. Reviewing the attached fax I can note that a DDT content of 1 ppm (or greater) would render such waste hazardous if moved off site but soil with less than 1.7 mg/kg does not pose a health risk even in a residential scenario. Clearly that soil should be left on site. One of those quirks of regulations. For heptachlor epoxide the PRG industrial soil is 330 pp.b and the PRG residential,soil is 49 ppb. A reading of 0.16 ppb is insignificant and I don’t understand why this is raised as an issue. If you want further information please contact me. Derek Whitworth, Ph.D., PE (Chemical) As I mentioned I worked for 13 years with the DTSC office in Berkeley and moved over to the Water Board on Feb 5, 2001. French, Am~/ From: Sent: To: Subject: Derek Whitworth [Dw@rb2.swrcb.ca.gov] Tuesday, February 26, 2002 3:56 PM Amy_french @city. palo-alto.ca, us test MemotoWalton.doc This is a follow up to my earlier email to Amy. My understanding is that tliis site is zoned commercial - industrial and you are not proposing to build housing on top of it. The appropriate look-up numbers would be those for soils on industrial sites. Using U.S. EPA Region 9 "PRGs" in its present use then ifDDT were on site in the soil 12 mg/kg or less then this would not pose a problem to people working on the site where they would have direct contact with the soil. For heptachlor epoxide, also detected, the corresponding level would be 0.27 mg/kg. The Lowney report has .corresponding 95%UCL numbers of 0.74 and 0. i0 mg/kg both below thresholds for risk. Since these levels would not pose a risk to people on site, it follows that they would not pose a risk to people off-site. The SFBRWQCB Risk Based Screening Level report (Dec 200 l) has numbers of 4 mg/kg for DDT and 0.014 mg/kg for heptachlor epoxide. I will have to talk to Roger Brewer of this office (he is reponsible for compiling the report) to see why there is such a deviation between the USEPA heptachlor number and the one t~om the Board. I will do that as soon as I see him and then let you know. I understand however that you are in fact removing the top two to three feet of soil from the site so the residual levels of contaminants will be insignificant and below the Risk Based Screening Levels and thus no issue of health risk from these contaminants. For off site disposal of the soils you will be collecting composite samples to classify the soil for proper disposa!. Based on the data provided in the Lowney report the composite concentrations can be expected to be below the levels that would classify the waste as hazardous. The hazardous waste thresholds are: TTLC for heptachlor of 4.7 mg/kg (the TCLP is 0.008 mg/L) TTLC for total DDT is 1.0 mg/kg I believe you can project that the soils leaving the site will be non-hazardous. I hope this is helpful. Please contact me again if you want further information. Derek Whitworth, PhD, PE Water Resources Control Engineer ATTACHMENT B City of Palo Alto City Manager’s Report TO: FROM:. DATE: SUBJECT: HONORABLE CITY COUNCIL CITY MANAGER DEPARTMENT: ’PLANNING AND COMMUNITY ENVIRONMENT FEBRUARY 19, 2002 CMR:133:02 2475 HANOVER STREET: CITY COUNCIL REVIEW AND ADOPTION OF REVISED MITIGATED . NEGATIVE DECLARATION AND APPROVAL OF CONDITIONS FOR THE DEMOLITION OF TWO BUILDINGS ON A 4.7-ACRE SITE IN THE LM ZONING DISTRICT AND THE CONSTRUCTION OF A TWO-STORY OFFICE BUILDING COMPRISING 81,928 SQUARE FEET. PARKING FACILITIES INCLUDE 146 UNDERGROUND PARKING SPACES AND 127 SURFACE PARKING SPACES. [FILES: 01-ARB-100, 01-EIA-15] REPORT IN BRIEF- This report responds to Council direction at the close of the public hearing on January 14, 2002 and discusses (1) the tree retention issue, (2) the shuttle issue, and (3) revisions made to the Mitigated Negative Declaration and conditions of project approval. The attachments include the ARB findings, Revised Mitigated Negative Declaration, revised conditions of project approval, additional/amended alternate conditions of approval, and the applicant’ s arborist’ s report. This report does not present the estimated resource impacts of the Council’s direction for staff to return to Council with a supplemental Environmental Impact Report for future Stanford Research Park development. This report does not discuss thresholds of significance for determining potential environmental impacts of development projects. Those items will be addressed in other reports to be presented to the City Council on a future action agenda. CMR:133:02 Page 1 of 8 RECOMMENDATION Staff recommends the Council adopt the revised Mitigated Negative Declaration (Attachment C) and approve the project application [file 01-ARB-100] based upon the ARB Findings (Attachment A) subject to meeting final conditions of approval (Attachment B)I reflecting modified versions of the C0uncil’s general conditions as stated at the January 14, 2002 Council meeting. BACKGROUND On January 14, 2002, the City Council conducted and closed the public hearing of the appeal filed by Joy Ogawa [file 01-AP-51 of the Director’s decision to approve redevelopment of the site known as 2475 Hanover Avenue. On a vote of 5-1-2-1 (5 yes, 1 no, 2 abstain and 1 absent), the City Council denied the appeal and directed staff to return with a revised Mitigated Negative Declaration [file 01-EIA-15] and revised conditions of approval reflecting Council discussion and direction. In a separate motion, the Council unanimously voted (7 yes, 0 no, 2 abstain and 1 absent) to direct staff to return to the City Council with (1) estimated impacts to the City’s resources to prepare a supplemental Environmental Impact Report prior to approval of future development in the. Stanford Research Park, and with (2) a report on the thresholds of significance for potential environmental impacts used by the City staff in evaluating development projects for Council review. That information will be provided at a fi~ture date. DISCUSSION The Council’s proposed additional conditions of approval were, generally: (1) to require extension of Stanford’s shuttle service to Hanover Street, (2) to require retention of the mature trees on the Hanover Street frontage, (3) to require payment of development impact fees for housing, parks and community facilities on the net new square footage (30,428) square feet at the fee level to be set by the City Council for development of this type, (4) to delete the provision of Condition of Approval 11.4 allowing Stanford to offset. its contribution to traffic calming by the cost of any EIR, and (5) to modify the proposed Mitigated Negative Declaration to address the project’s potential, but mitigated, impacts on housing and parks and community facilities. The Mayor requested that staff provide clarification regarding the tree retention issue and the shuttle condition. Each of these five issues is discussed below. Extension of shuttle to Hanover Street The City Council expressed concern that the payment of traffic impact fees and contribution towards traffic calming would not adequately address traffic concerns. Among the points made was that there will be a gap between the expected time of occupancy of the building and the time that the plaimed intersection improvements to Hanover Street (at Page Mill Road) are made. There was also discussion Of the general increase in traffic in the area over the past several years. Council directed addition of a CMR: 133:02 Page 2 of 8 condition requiring that Stanford extend the operations of its Marguerite Shuttle to the Hanover site. Staff has reviewed both the relationship of this condition to this project’s traffic impact and how most effectively to implement a shuttle expansion. This project’s floor area represents only four percent of the floor area on the "superblock" that would.be served by the shuttle. Using the City’s existing traffic analysis standards, the deterioration in traffic flow would only occur at peak-traffic hours and only in the "gap" period between building occupancy and improvements at the intersection of Hanover Street and Page Mill Road. The City’s five year proposed Capital Improvements Projects places the design and construction of these improvements in fiscal years 2003/04 and 2004/05, respectively. The City’s Comprehensive Plan makes clear that encouraging alternative transportation is preferred to street widenings. However, extending the route of the existing shuttle. program (the "A" line) to the Hanover block would increase the "A"-line’s interval between shuttles, arriving at CalTrain and decrease overall ridership. Staff has met with Stanford since the January 14 Council meeting to determine the best solution to meet Council’s expectations. Stanford proposed to operate a dedicated peak- hour only shuttle as a pilot project, to run between the site and the California Avenue CalTrain station and around the "superblock" bounded by E1 Camino Real, California Avenue, Hanover Street and Page Mill Road. The intent of the shuttle would be to mitigate traffic during the "gap" between the issuance of occupancy permit and the completion of the Hanover Street improvements, approximately three to four years. Stanford has estimated it could operate the shuttle for about $70,000 per year of operation; and data regarding shuttle ridership in that time period would be shared with City staff. Stanford would also-promote the peak-hour shuttle service to other "super- block" tenants, .(where peak hours would be a minimum of 2.5 hours each in the morning and afternoon.) Approximately six months after intersection improvements have been completed at Hanover Street, Stanford and the City staff would evaluate the project’s operational experience and determine whether the shuttle route should be terminated; modified or continued. New funding sources and necessary adjustments .would be identified and implemented in the event the shuttle service is modified or continued. Condition. NO. 9...1 in Attachment B has been amended to include this proposal. The City’s Transportation Division staff proposed, as an alternative, that the City establish a shuttle paid for by Stanford but operated by the City. The City staff would design the route to include an additional stop on California Avenue to serve College Terrace residents. The new shuttle route would be operated under contract with a private sector bus company, similar to the current arrangement for both the Stanford Marguerite and the City shuttle service. Incorporating this route into the City’s shuttle would CMR: 133:02 Page 3 of 8 implement a key recommendation of the Shuttle Feasibility Study: to extendCity shuttle bus services to the Stanford Research Park. Stanford has noted that a City operated shuttle would be acceptable under certain conditions: .(1) (2) (4) Stanford would agree to fund the shuttle at $70,000 per year for the time period between building occupancy and six months after the installation of intersection improvements at Hanover Street; If the. City wants to augment the program beyond the peak hours proposed by Stanford the City will need to seek additional funding; Stanford needs flexibility to allow other Stanford Research Park tenants to use and perhaps electively contribute to the shuttle. While the pilot project is running, Stanford would work with the City to explore funding sources .for the shuttle beyond the "gap"..period; If intersection improvements are not completed by the end of calendar year 2007, Stanford may discontinue its funding to the City at that time. Since this alternative, City operated shuttle program would require City resources (see Resource Impact), staff has placed the condition reflecting this proposal in Attachmen~ D (Condition No. 9.1), should the City Council prefer this program. Retention of mature trees along Hanover Street The .Council’s motion called for an amendment to the project approval requiring the retention of the trees along the Hanover frontage of the site. There are presently eight ash trees along Hanover Street. As noted in the arborist,s report (page 3, Attachment E), they are in "poor" to "very poor" condition. The ash trees are at the end of their useful lifespan and their canopies no longer provide the shade and streetscape functions that were originally intended. Palo Alto Street Tree Management Program policY is to replace old trees nearing the end of their lifespan with new trees, consistent with the concept of managing a sustainable urban forest.. The ash trees’ s~ate of decline is a result of se:~eral factors. The trees were dependent upon irrigation that was discontinued during the drought years. This water cutback resulted in significant die-back of the branches and roots. Several dead sections of the trees have been removed which explains their unbalanced, lop-sided appearance. Removal of the dead sections has also resulted in sun scald, bark damage, and decay in most of these trees. Further, several of these trees require extreme crown restoration pruning, which would significantly reduce the size and mass of the trees. For these reasons, staff recommends all of these trees be .removed and replaced. The ARB approval included a condition (condition 7.4) requiring the sixteen proposed replacement trees .to be 24-inch box ash trees of a different species than shown on the approved landscape plan. CMR: 133:02 Page 4 of 8 All but a few of the existing 122 inventoried trees on site have low to moderate suitability for preservation, including the Hanover Street trees (all street trees are included in the inventory count). The trees to be saved include an existing oak, which will be transplanted on site to a more prominent location at the entry plaza and three olive trees at the southeast corner of the site. Nine of the 11 gingko trees along California Avenue are in fair con~tition, while the other two are in ’°poor" condition. After considerable discussion, and with the support of the College Terrace Residents Association, Stanford will replace the gingkos with an allee (double row) of ash trees, 24 in total. Stanford proposes to extract and move these nine trees to designated locations to be approved by the City’s Parks Division staff. A suitable location for at least some of the trees has been identified at Robles Park on Park Avenue between Charleston Drive and East Meadow Drive. Additional locations will be identified in the coming weeks. Stanford has recently agreed to two additional conditions of approval (Conditions 7.7 "and 7.8) to ensure a successful relocation project. These conditions are included in Attachment B, Revised Conditions o~ Approval. Staff recommends that Council adopt these additional conditions instead of one calling for the preservation of the Hanover frontage street trees. There is one additional street tree, holly oak no. 1, on California Avenue at Hanover Street, that could be considered for retention. However, retention of this tree would mean that two ofthe allee ash trees could not be planted at the intersection. Holly oak no. 1 is a 40-foot-tall evergreen, tree in fair condition that provides moderate .screening during all seasons and would survive construction impacts. Should Council wish to require retention of this tree, an additional condition (Condition No. 7.9) in Attachment D can be adopted. If Council still prefers to require retention of the ash trees on.Hanover Street, an alternate Condition 7.4 is included in. Attachment D, in lieu of Condition 7.4 as stated in Attachment B. Payment of development impact fees ..... The Council has not yet completed its deliberations On the adoption of development impact fees for parks, libraries and community services and revising the level of housing impact fees. It received a report on October 16, 2001 which recommended setting fees at less than full-cost recovery. Council’s motion directed that this project, on its new square footage, include the payment of these fees at the level set by the Council when it completes its review this year. With respect to the housing }~ee, staff has modified condition 8.1 to reference new mitigation measure no. 6 of the Mitigated Negative Declaration and, to address the development impact fees for parks, libraries and community services, has added Condition of Approval No 11.5 (see Attachment B). CMR: 133:02 Page 5 of 8 Note that previous ARB condition 11.5 requiring return to ARB has been met and therefore was deleted from final conditions. Firm commitment of $150,000 for traffic calmin~ improvements Staff has replaced Condition No. 11.4 with the following, which Stanford has acceptedi "The applicant shall pay to the City the sum of $150,000 before commencement 0f new construction at 2475 Hanover Street to be used by the City to assist .with traffic cahning improvements in the College Terrace neighborhood." Revisions to Mitigated Negative Declaration Staff has prepared and circulated a revised Mitigated Negative Declaration, which is attached to this report as Attachment C. The revisions are underlined in the document. In summary: (1) The list of sources for checklist responses now includes the September 18, 2001 DMG-Maximus report and accompanying City Manager’s Report (CMR:381:01) that were reviewed by the City Council after the first initial study was prepared for this project; and the January 24, 2002 Aquifer Sciences report providing the latest update on progress of the ongoing soil and groundwater pollution remediation; (2) The checklist was modified in the housing/population, public services and recreation sections to indicate "signiticant impacts.unless mitigated" instead of no impact and three mitigation measures were added to address those impacts; (3) Revised text was added in the explanation of checklist responses for those sections; and (4) Text was added to the section on aesthetics regarding existing and replacement trees, and to the section on hazards to include recent information on the progress of the groundwater and soil pollution remediation program. These are the additional mitigation measures the applicant agreed to: Mitigation Measure No. 6: The property owner shall pay housing impact fees of general application at th~ fee level adopted by the City Council in the year 2002. Mitigation Measure No. 7: The property owner shall pay park impact fees of general application at the fee level adopted by the City Council in the year 2002. Mitigation Measure No. 8: The property owner shall pay libraries and community facilities impact fees of general application at the fee level adopted by the City Council in .the year 2002. As previously stated, the proposed revision to Condition of Approval 8.1 references Mitigation Measure 6. The City’s regulations currently allow half of the total housing CMR: 133:02 Page 6 of 8 impact fees to be paid before building permit and the remaining half at occupancy permit. New condition of approval 11.5 provides additional detail to specify payment timing issues beyond those set forth in Mitigation Measures 7 and 81 RESO.URCE IMPACT The City resources estimated to be used in operating a Stanford-funded, pilot program shuttle route would include staff time to design and market the new route, evaluate the shuttle contractor’s performance during the pilot program, evaluate the shuttle’s success at the end of the pilot program time period, and seek funding sources for the shuttle (such as VTA, CalTrain, Hewlett Packard or other Research Park tenants,) POLICY IMPLICATIONS The benefits of the City’s operating the shuttle include meeting Comprehensive Plan Goals %1 and T-2 by reducing trips and increasing services to COl~muters, as well as providing a public service to residents in College Terrace. ENVIRONMENTAL REVIEW The revised Mitigated Negative Declaration was circulated for a 20-day public review )eriod beginning January 30 and ending February 19, including the one-day extension due to the holiday on February 18. The notice for this review period included a statement that only written comments would be accepted in accordance with CEQA guidelines. Any written comments received prior to the end 0fthe review period will be forwarded to the City Council members. ATTACHMENTS Attachment A: Attachment B: Attachment C: Attachment D: Attachment E: Findings for Approval Revised/Final conditions of approval and mitigation measures Revised Mitigated Negative Declaration Additional/Amended alternate conditionsof approval Arborist’s report PREPARED BY: AMY FRENCH Senior Planner DEPARTMENT HEAD REVIEW: LISA GROTE Chief Planning Official CMR: 133:02 Page 7 of 8 CITY MANAOER APPROVAL: ~,v Assistant City Mana/ger COURTESY COPIES Joel Karr, 185 Berry Street, Suite 5700, San Francisco, CA 94107 Jean Snyder, Stanford Management Company, 2770 Sand Hill Road, Menlo Park, CA 94025 Joy Ogawa, 2305 Yale Street, Palo Alto, CA 94306 13 speakers at City Council meeting on J, anuary 14, 2002 CMR:133:02 Page 8 of 8 ATTACHMENT A FINDINGS FOR APPROVAL ARCHITECTURAL REVIEW BOARD STANDARDS FOR REVIEW SMC Project (Redevelopment of ALZA site) 2475 Hanover Street/File No. 01-ARB-100, 01-EIA-15 The proposed project, as conditioned, furthers the goals and purposes of the ARB Ordinance (Chapter 16.48 of the PAMC) as it complies with that ordinance’s Standards for Review as follows: The deszgn is consistent and compatible with applicable elements of the city’S comprehensive plan. The proposed project, as conditioned, is consistent with the Comprehensive Plan designation of Research!Office Park, in that the use would be compatible with the surrounding land uses. The design is compatible with the immediate environment of the site. The proposed project, as conditioned, is compatible with the immediate environment of the site with respect to the architectural character, scale and design of the nearby structures, will fit well onto its comer setting by the provision of a large number of trees, especially along California Avenue. The design is appropriate to the function of the project. The proposed project, as conditioned, is appropriately designed to the function of an administrative office building in the Stanford Research Park. The design promotes harmonious transitions in scale and character in areas between different designated land uses in that buildings, seating areas, landscaping and parking-areas are integrated in a unified design that allows for harmonious transitions. The design is compatible with approved improvements both on and off the site in that the modified driveways at the project site will not result in traffic conflicts between vehicular movements from the proje.c~ site and from the surrounding sites, and the driveways will not conflict with improvements to bicycle lanes and sidewalks. . The planning and siting of the various functions and buildings on the site create an internal sense of order and provide a desirable environment for occupants, visitors and the general community in that suitable amenities and vehicular circulation and parking are provided for employees and visitors, in an ordered and hanr~onious layout. The amount and arrangement of open space are appropriate to the design and the function of the structures in that the main parking area is located underneath and behind the building and the prominent open areas and visitor parking facilities in front of the building would receive plantings and special hardscaping. Sufficient ancilla~T functions are provided so support the main functions of the project and these functions are compatible with the project’s design concept in that the building Findings for Approval Architectural Review Board would have an employee amenity area and outdoor seating area that would support the primary use of the building. 10.Access to the property and circulation thereon are safe and convenient for pedestrians, cyclists and vehicles in that the two-way driveways on Hanover Street will be provide safe and convenient site access and the on site circulation will be safe due to pedestrian pathways and lighting.. 12.The materials, textures, colors and details of construction and plant material are appropriate expressions to the design and function and are compatible with the adjacent and neighboring structures, landscape elements and functions in that the materials and details will be compatible. 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 and the landscape concept depicts an appropriate unity with the various buildings on the site. 14.The 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. 15.The design is energy efficient and incorporates renewable energy design elements including, but not limited to." (A) Exterior energy design elements, recycling of demolishbd buildings, sun shading and recessed windows, spectrally sensitive glazing, dual pane glazing with low-E and additional insulation on the roof, (B) Internal lighting service and climatic control systems, which shall be shown in tenant improvement plans and (C) Building siting and landscape elements, such as the provision ofbio-swales and use of recycled materials in the landscape. ARB standards/findings #4 and #11 are not applicable to the project. Findings for Approval Architectural Review Board ATTACHMENT B *Revised Conditions of Approval and Mitigation Measures SMC Project, 2475 Hanover Street / File No. 01-ARB-100, 01-EIA-15 *(revised conditions and mitigation measures are underlined) The plans submitted for Building Permit shall be in substantial conformance with plans dated July 26, 2001, with additional plan sheets dated November 2001 as reviewed by the Architectural Review Board, except as modified to incorporate these conditions of approval. These mitigation ~ measures and conditions of approval shall be printed on the cover sheet of the plan set submitted with the Building Permit application. Mitigation Measure #1: Interior lighting systems shall by described in tenant improvement plans for staff architectural review, and shall address timing and shading issues, and include measures necessary to meet City requirements. Mitigation Measure #2: If cultural, paleontological, or historical resources are found during construction, all construction activities shall cease and the Director of Planning and Community Environment shall be notified and mitigation measures pursuant to Public Resources Code, Section 7050.5 and CEQA Guidelines shall be followed. Mitigation Measure #3: All proposed buildings and structures shall conform to Uniform Building Code, Zone 4 guidelines. New buildings and structures shall be designed in accordance with the recommendations of the Geotechnical Investigation report dated January 2, 2001. Mitigation Measure #4: The building permit plans shall include a sheet showing the location of all remediation wells on the site of the existing ALZA building D (2575 Hanover Street). Mitigation Measure #5: The project shall include, the installation and operation of equipment in accordance with noise analyses and recommendations prepared by Wilson, Ihrig & Associates, Inc. Mitigation Measure #6: The property owner shall p~y housing impact fees of general application at the fee level adopted by the City Council in the year 2002. Mitigation Measure #7: The property owner shall pay park impact fees of general application at the fee level adopted by the City Council in the year 2002. Mitigation Measure #8: The property owner shall pay libraries and community facilities impact fees of general application at the fee level adopted by the City Council in the v’ear 2002 Revised Conditions of Approval and Mitigation Measures PUBLIC WORKS CONDITIONS 1. WA~ER QUALITY 1.1 1.2 1.3 Palo Alto Municipal Code (PAMC) Section 16.09.032(b)(9) prohibits the use of copper or copper alloys in piping coming into contact with sewage, except for sink traps and associated connecting pipes. Project building plans must specify that non-copper wastewater piping will be used. Any drain plumbing for the underground parking garage must be connected to an oil/water separator with a minimum capacity of 100 gallons, and to the sanitary sewer system (PAMC 16.09o032(B)(17)). Any hard-plumbed water discharge to the sanitary sewer from the elevator sump pit must pass by gravity flow through an oil/water separator. If a sump pump is to be utilized, the pumped discharge must be contained in a tank, or the sump pump must be equipped with an oil sensor system to prevent hydraulic oil spills from being pumped to the sanitary sewer. ¯ 2.2 2.ENGINEERING Prior to Submittal for Building Permit: 2.1 Plan Revisions - The submitted Preliminary Grading Plan and tl~e "Storm Water Pollution Prevention Plan" (SWPPP) require further revision to meet Public Works Engineering ’ (PWE) grading, drainage and SWPPP requirements. The Applicant shall meet with PWE staffto obtain these additional SWPPP requirements. The revised plans shall incorporate these additional SWPPP requirements and shall be submitted for review by PWE within 10 days after final ARB approval. Approval of the revised preliminary plans by PWE must be obtained prior to commencing final design of the building permit plans or grading permit plans. General SWPPP Requirements - In order to address potential storm water quality impacts, the project plans shall identify the both the temporary and permanent Best Management Practices (BMP’s) that will be incorporated into the SWPPP for this project. The SWPPP temporary measurers are those implemented during construction to protect storm water quality. (Extraordinary SWPPP temporary measurers will apply to grading work performed during the wet season.) The SWPPP permanent measures are those BMP’s .to be incorporated into the project improvements for long term protection of storm water quality. The elements of the PWE-approved Preliminary Grading Plan and SWPPP plan shall be incorporated into the building and grading permit plans. The graded area of the project will be less than 5 acres therefore, a formal Notice of Intent (NOI) filing with the State will not be required for this project. Prior to Submittal for Building Permit: 2.3 ¯ Grading Permit - A Grading and Excavation Permit issued by the CPA Building Inspection Division is required for the proposed project. The grading permit submittal ¯shall at minimum address the issues of parking, truck routes and staging, materials storage, and the provision of pedestrian and vehicular traffic adjacent to the construction site. All truck routes shall conform with the City of Palo Alto’s Trucks and Truck Ronte Ordinance, Chapter 10.48, and the route map which outlines truck routes available throughout the City of Palo Alto. Any grading permit issued in conjunction with a phased project implementation plan will only authorize grading and storm drain improvements. Other site utilities may be shown on the grading plan for reference only, and should be so noted. No Revised Conditions of Approval and Mitigation Measures utility infrastructure should be shown inside the building footprint. Installation of these other utilities will be approved as part of a subsequent Building Permit application. 2.4 City Storm Drain System - The existing municipal storm drainage system in the area is unable to convey the peak runoff from the project site. A new storm drain line shall be installed in Hanover Street as part of this project. The new line shall provide drainage for this development and shall connect to the nearest adequate City storm drain system. The new line and connections shall be constructed to City Public Works Standards. 2.5 Impervious Area - The proposed development will result in a change in the impervious area of the property. The applicant shall provide calculations showing the adjusted impervious area with the building permit application. A Storm Drainage Fee adjustment on the applicant’s monthly City utility bill will take place in the month following the final approval of the construction by the Building Inspection Division. The impervious area calculation sheets and instructions are available from Public Works Engineering. Prior to Issuance of Building Permit: 2.6 Street Work Permit - The applicant shall obtain a Street Work Permit from Public Works Engineering for pedestrian protection on the public sidewalk and or construction proposed in the City right-of-way. Sec. 12.08.010. 2.7 Lease Line - An underlying lease line exists on the property. The developer/applicant shall take steeps to remove the lease line to the satisfaction of Planning and Public Works. The Building Permit associated with the application will not be issued until the required lease documents are recorded with the County Recorder’s office. 2.8 2.9 Soils Report - A detailed site-specific soil report prepared by a licensed soils or geo- technical engineer must be submitted which includes information on water table and basement construction issues. This report shall identify the curi-ent groundwater level, if encountered, and by .using this and other available information, as well as professional experience, the engineer shall estimate the highest projected ground-water level likely to be encountered in the future. If the proposed basement is reasonably.above the projected highest water level, then the basement cm~ be constructed in a conventional manner with a subsurface perimeter drainage system to relieve hydrostatic pressure. If not, measures must be undertaken to render the basement waterproof and able to withstand all projected hydrostatic and soil pressures. No external drawdown pumping of ground water is allowed. In general, however, Public Works Engineering recommends that structures be constructed in such a way that they do not penetrate existing or projected ground water levels. The soils report shall also include a discussion regarding possible hazardous material spills in the area of the site, the extent of any known Or discovered haz-mat plumes and remedies that must be undertaken as part of this project. Future submittals of these project plans will be subject to the review of the City Enviromnental Quality division of Public Works. 2.10 Dewatering Plan - Building permit applicants are required to prepare and submit a basement excavation dewatering plan whenever the project soils report indicates that Revised Conditions of Approval and Mitigation Measures 3 groundwater will be encountered during excavation. The plan should be reviewed and approved by Public Works engineering prior to the issuance of the building permit. Building permits that include a basement where groundwater is not expected to be encountered will be subject to a condition that a dewatering plan shall be submitted to Public Works Engineering for review and approval if groundwater is encountered during excavation. 2.11 2.12 Final Grading Plan - The applicant shall submit a final grading and drainage plan to Public Works Engineering. The final grading plan shall incorporate all required features of the PWE approved preliminary grading, drainage and SWPPP plan This plan shall show spot elevations or contours of the site and demonstrate the proper conveyance of storm water to the nearest adequate municipal storm drainage system. Existing drainage patterns, including accommodation of runoff from adjacent properties, shall be maintained. Storm Water Pollution Prevention Plan (SWPPP) - Although this proposed development will disturb less than five acres of land, it is located in an environmentally sensitive area and/or has potential for storm water pollution due to steep grades, paved parking areas or other site conditions. The applicant must prepare and implement a Storm Water Pollution Prevention Plan (SWPPP). The applicant is required to submit two copies of the final draft SWPPP to the Public Works Department for review and approval prior to issuance of the building permit. The SWPPP should include permanent, post development project design features as well as. temporary measures employed during construction to control storm water pollution. Specific Best Management Practices (BMP’s) which apply to the work should be incorporated into the design. 2.13 SWPPP Format The SWPPP shall be in the form of separate plan sheets titled as follows: 1) SWPPP Permanent Measures, 2) SWPPP Temporary Measures & Erosion Control, and 3) SWPPP Details. The SWPPP Details sheets should carry copies of standard BMP details and other custom designed BMP details that will be implemented on the project. If work is to occur in the wet season (from October 1 to April 15 of the following year) then the Temporary SWPPP & Erosion Control plan shall also include specific notes regarding winterization requirements for the site. Sec. 16.28.280. 2.14 Schedule - The applicant shall submit a master work schedule showing the proposed grading schedule, the proposed condition of the site on each July 15, August 15, September 15, October 1, and October 15 during which the permit is in effect. The master schedule shall also show the schedule for installation of all interim and permanent erosion and sediment control measures, and other project in-tprovements. Sec. 16.28.160. 2.15 Mechanical systems for equipment such as elevators, HVAC systems, etc which are located in the underground garage should have their hydraulic and electrical equipment set above the basement floor some reasonable freeboard distance. This will prevent damage to the equipment from ponded water entering the garage from vehicle ramps during a power outage. 2.16 Storm Drain Logo - The applicant is required to paint the "No Dumping/Flow~ to (insert name of creek) Creek" logo in blue color on a white background, adjacent to all storm drain inlets. Stencils of the logo are available from the Public Works Envirollmental Revised Conditions of Approval and Mitigation Measures 4 Compliance Division, which may be contacted at (650) 329-2598. A deposit may be required to secure the return of the stencil. Include the instruction to paint the logos on the construction grading and drainage plan. Include maintenance of these logos in the Hazardous Materials Management Plan, if such a plan is part of this project. 2.17 Vehicle Ramp. The vehicle ramp.should be designed to minimize the amount of drainage water directed toward the underground garage. The length of the ramp should be minimized. The top of the ramp should have a well-defined grade break to prevent entry of water from the outside parking lot. A slotted drain should be placed across the ramp to direct runoff water to the storm drain system. A roof should cover the unprotected portion of the ramp (below the slotted drain). The slotted drain near the base of the vehicle ramp must be connected to the storm drain system. If adverse grades exist then a sump and pump must be provided. This sump must be located inside the basement. 2.18 Vehicle Garage Drainage - The underground garage should have a drain, which is connected to the sanitary system. The drain must be protected by and approved interceptor device that filters the water prior to entry into the sanitary system. 2.19 Loading Docks - The plans include provision for future loading dock at two locations. Stoma runoff from a loading dock where chemicals or hazardous materials may. be handled shall not drain to a street gutter, or storm drain. Sec. 16.09.032(b)(4)(D). It is recommended that the loading dock be covered to preclude the need for a drain. If the loading docks will not be covered then a drain connected to the ’sanitary system will be necessary. In this event, the drainage area in front of the loading dock will be limited in size to minimize the entry of storm water into the sanitary system. A valve that is normally closed and requires attendance to be held in the open position shall protect the retention basin drain. A sign shall be posted near the valve with instructionsregarding valve operation and the need for inspection of collected water for spilled materials prior to release. Required wording for the sign will be provided during the building permit review of the loading dock design. During Construction: 2.20 SWPPP Monitoring - Daily monitoring of all extraordinary winter SWPPP measures shall be performed by an independent inspector throughout the wet season. Written monitoring reports shall be delivered weekly to PWE. The inspector shall advise the construction contractor of any measures BMPs found in noncompliance with ttie SWPPP. The construction contractor shall provide immediate corrective action to any after being so advised. The inspector and the monitoring report formal shall be subject to approval by PWE. 2.21 Dust Control - To reduce dust levels, it shall be required that exposed earth surfaces be watered as necessary. Spillage resulting from hauling operation along or across any public or private property shall be removed immediately and paid for by the contractor. Dust nuisances originating from the contractor’s operations, either inside or outside the right-of- way shall be controlled at the contractor’s expense. Revised Conditions of Approval and Mitigation Measures 2.22 The contractor must contact the CPA Public Works Inspector at (415) 496-6929 prior to any work performed in the public right-of-way. 2.23 No storage of construction materials is permitted in the street without prior approval of Public Works Engineering. 2.24 All construction within the City right-of-way, easements or other property under City jurisdiction shall conform to Standard Specifications of the Public Works and Utility Departments. Prior to Finalization: 2.25 Sidewalks, curbs and gutters bordering the project shall be repaired and/or removed and replaced in compliance with Public Works approved standards. S ec. 12.08.010. 2.26 The unused driveway located on California Avenue shall be removed and replaced with curb and gutter. Sec. 12.08.090. 2.27 A curb ramp for the disabled will be required at all driveway entrances to the property and at any street crosswalk entrances. 2.28 Public Works Inspector shall sign-off onthe building permit prior to the finalization of this permit. Construction activities that must be completed prior to this sign-off include: 1) all off-site improvements, 2) all on-site grading and storm drain improvements, 3) all post- construction storm water pollution control measures and 4) submittal of as-built record ¯drawings for improvements in the public right-of-way. FIRE DEPARTMENT CONDITIONS 3.1 Hydrants shall be spaced at intervals not to exceed 300 feet in both directions of travel around the buildings, following the route of travel of a fire .engine. (PAMC 15.04.140) 3.2 A fire sprinkler system shall be provided throughout the building, which meets the requirements of NFPA Standard No. 13-1996 Edition. Fire sprinkl(r system installations require separate submittal to the Fire Prevention Bureau. (PAMCl5.04.083), Note: Building plans will not be approved unless complete sprinkler coverage is provided, 3.3 3.4 An approved underground fire supply shall be provided for the sprinkler system(s), and shall meet the requirements of NFPA Standard No. 24,1996.Edition. Fire supply system installations require separate submittal to the Fire Prevention Bureau. (PAMC 15.04.083) NOTE: Fire Department approval will be withheld until Utilities Department and Public Works Department requirements have been met. An approved audible sprinkler flow alarm to alert the occupant shall be provided in the interior of the building in. an approved location. (98CBC904.3.2) Fire Alarm system installations require separate submittal to the Fire Prevention Bureau. (PAMC15.04.083) Revised Conditions of Approval and Mitigation Measures 6 3.5 Approved 2½-inch hose valves shall be provided at eachunderground floor level landing in every stairwell for the underground parking structure. (PAMC 15.04.178) 3.6 Elevator cars shall be sized for Fire Department gumey access requirements based on gumey dimensions of 24" x 82" plus a minimum of two emergency response personnel. (PAMC 15.04.120) 3.7 Clarify the source of water for the street hydrant in front of the current building at 2575 Hanover Street. Drawing C-1 currently shows the hydrant supplied by the underground line for the sprinkler risers (unacceptable). 3.8 Underground supply for the automatic sprinkler risers shall be configuSred such that there is no PIV or other shutoff valve downstream of the Fire Department Connection. UTILITIES DEPARTMENT CONDITIONS 4.UTILITIES ELECTRICAL ENGINEERING 4.1 The applicant shall be responsible for identification and location of all utilities, both public and private, within the work area. Prior to any excavation work at the site, the applicant shall contact Underground Service Alert (USA) at 1-800-227-2600, at least 48 hours prior to beginning work.. 4.2 The Applicant shall submit a request to disconnect all existing.utility services and/or ~neters including a signed affida’~it of vacancy, on the form provided by the Building Inspection Division. Utilities will be disconnected or removed within 10 working days after receipt of request. The demolition permit will be issued after all utility services and/or meters have been disconnected and removed. 4.3 A completed Electric Load Sheet and a full set of plansmust be included with all building permit applications involving electrical work. The load sheet must be included with the preliminary submittal. 4.4 Industrial and large commercial customers must allow sufficient lead-time for Electric Utility Engineering and Operations (typically 8-12 weeks after advance engineering feesr have been paid) to design and construct the electric service requested. Only one electric service lateral is permitted per parcel. Utilities Rule & Regulation #18. This project requires a padmount transformer unless otherwise approved in writing by the Electric Utility Engineering Department. The location of the padmount transformer shall be shown on the site plan and approved by the Utilities Department and the Architectural Review Board. Utilities Rule & Regulations #3 & #16. 4.7 The developer/owner shall provide space for installing padmount equipment (i.e. transformers, switches, and interrupters) and associated substructure as required by the City. In addition, the owner shall grant a Public Utilities Easement for facilities installed on private property as required by the City. Revised Conditions of Approval and Mitigation Measures 7 4.8 4.9 The customer shall install all electrical substructures (conduits, boxes and pads) required from the service point to the customer’s switchgear. All conduits must be sized according to National Electric Code.requirements and no ½-inch size conduits are permitted. Conduit runs over 500 feet in length require additional pull boxes. The design and installation shall also be according to the City standards. Utilities Rule & Regulations #16 & #18. Location of the electric panel/switchboard shall be shown on the site plan and approved by the Architectural Review Board and Utilities Department. 4.10 All utility meters, lines, transformers, backflow preventers, and any other required equipment shall be shown on the landscape and irrigation plans and shall show that no conflict will occur between the utilities and landscape materials. In addition, all aboveground equipment shall be screened in a manner that is consistent with the building design and setback requirements. 4.11 For services larger than 1600 amps, the customer will be required to provide a transition cabinet as the interconnection point between the utility’s padmount transformer and the customer’s main switchgear. The cabinet design drawings must be submitted to the Electric Utility Engineering Department for review and approval. 4.12 No more than four 750MCM conductors per phase can be connected to the transformer secondary terminals; otherwise, bus duct must be used for connections to padmount transformers. If customer installs a bus duct directly between the transformer secondary terminals and the main switchgear, the installation of transition cabinet will not be required. 4.13 The customer is responsible for sizing the service conductors and other required equipment according to the National Electric Code requirements and the City standards. Utilities Rule & Regulation #18. 4.14 If the customer’s total load exceeds 2500kVA, service shall be provided at the primary voltage of 12,470 volts and the customer shall provide the high voltage switchgear and transformers. Utilities Rule & Regulation #3. 4.15 For primary services, the standard service protection is a padmount fault interrupter owned and maintained by the City, installed at the customer’s expense. The customer must provide and install the pad and associated substructure required for the fault interrupter. 4.16 Projects that require the extension of high voltage primary distribution lines must be coordinated with the Electric Utility. Additional fees may be assessed for the reinforcement of offsite electric facilities. 4.17 Any additional facilities and services requested by the Applicant that are beyond what the utility deems standard facilities will be subject to Special Facilities charges. The Special Facilities charges include the cost of installing the additional facilities as well as the cost of ownership. Utilities Rule & Regulation #20. 4.18 The applicant shall comply with all the Electric Utility Engineering Department service requirements noted during plan review. Revised Conditions of Approval and Mitigation Measures 8 4,19 Contractors and developers shall obtain a street opening permit from the Department of Public Works before digging in the street right-of-way. This includes sidewalks, driveways and planter strips. ’ 4.20 At least 48 hours prior to starting any excavation, the customer must call Underground Service Alert (USA) at 1-800-227-2600 to have existing underground utilities located and marked. The areas to be checked by USA shall be delineated with white paint. All USA The customer is responsible for installing all on-site substructure (conduits, boxes and pads) required for the electric service. No more than 270 degrees of bends are allowed in a secondary conduit run. All conduits must be sized according to National Electric Code requirements and no ½-inch size conduits are permitted. All off-site substructure work will be constructed by the City at the customer’s expense. Where mutually agreed upon by the City and the Applicant, all or part of the off-site substructure work may be constructed by the Applicant. Utilities Rule & regulation #16.. 4.21 All primary electric conduits shall be concrete encased with the top of the encasement at a depth of 30 inches. No more than 180 degrees of bends are allowed in a primary conduit run. Conduit runs over 500 feet in length require additional pull boxes. 4.22 4.23 All new underground conduits and substructures shall be installed per City standards and . shall be inspected by the Electrical Underground Inspector before backfilling. Rule & Regulation #16. The customer is responsible for installing all underground electric service conductors, bus duct~ transition cabinets, and other required equipment. The installation shall meet the National Electric Code requirements and the City standards. 4.24 Prior to fabrication of electric switchboards and metering enclosures, the customer must submit switchboard drawings to the Electric Metering Department at 3201 East Bayshore Road, Palo Alto 94303 for approval. The City requires compliance with all applicable EUSERC standards for metering and switchgear. 4.25 All new underground electric services shall be inspected and approved by both the Building Inspection Division and the Electrical Underground Inspector before energizing. Utilities Rule & regulation #18. 4.26 The customer shall provide as-built drawings showing the location of all switchboards, conduits (number and size), conductors (number and size), splice boxes, vaults and switch!transformer pads. 4.27 The. applicant shall secure a Public Utilities Easernent for facilities installed on private property for City use. Utilities Rule & Regulations #16. 4.28 All required inspections have been completed and approved by both the Building Inspection Division and the Electrical Underground Inspector. 4.29 All fees must be paid. Revised Conditions of Approval and Mitigation Measures 4.30 All Special Facilities contracts or other agreements need to be signed by the City and applicant. 4.31 ADDITIONAL COMMENTS: Developer / Customer shall provide space and public utilities easements (PUE) for any substructure as required by the city. The city will provide detailed comments when plans along with load calculations are submitted to the building ’department for review and approval. Ref. DM#04 5.UTILITIES MARKETING Prior to issuance of either a Building Permit or Grading Permit, all common area landscaping shall be approved by the Utilities Marketing Servicesdivision of the Utilities Department. The landscape shall conform to the Landscape Water Efficiency Standards of the City of Palo Alto. A water budget shall be assigned to the project and a dedicated irrigation water meter shall be required. If each of the two buildings on this site is to have an individual domestic water meter, then each building shall be required to have an irrigation water meter. Call the Landscape Plan Review Specialist at 650.329.2549 for additional information. 6.UTILITIEs WATER, GAS & WASTEWATER ENGINEERING 6.1 The applicant shall submit improvement plans for all utility’construction. The plans must show the size and location of.all underground utilities within the development and the public right of way including meters, backflow preventers, fire service requirements, sewer cleanouts, and any other required utilities. Each unit or parcel shall have its own water, gas meters and sewer lateral connection. The applicant shall submit a completed WATER-GAS-WASTEWATER SERVICE CONNECTION APPLICATION - LOAD SHEET for City of Palo Alto Utilities. The applicant must provide all the information requested for utility service demands (water in G.P.M., gas in B.T.U.P.H, and sewer in G.P.D.). 6.4 The applicant must show on the site plan the existence of any water well, or auxiliary water supply. 6.5 The approved relocation and abandonment of water and sewer facilities including services, meters, hydrants, or other facilities will be performed at the cost of the applicant or developer. 6.6 The applicant shall pay the connection fees associated for the installation of the new services to be installed by the City of Palo Alto Utilities Department. Revised Conditions of Approval and Mitigation Measures 10 PLANNING AND COMMUNITY ENVIRONMENT CONDITIONS 7.MANAGING ARB ORIST 7.1 7.2 In conjunction with submittal of building permit plans, a detailed landscape plan without omissions and including an adjacent plant list on the same page shall be submitted. The annual color beds on each side of the entry drive shall each be enlarged to a quarter circle. A range of texture plants should be installed. 7.3 Additional plantings shall be added to the entrance and lobby area. Small planter areas, lobby/entry shade plants and large potted plants shall be included in plans. 7.4 ,7.5 The street trees along California and Hanover shall be Purple Autumn American Ash (Fraxinus americana ’Purple Autumn’) of 24-inch box size, planted per PW Detail #504 (please use the updated diagram). To prevent long term damage to hardscape by tree root~ and promote vigorous tree canopy, the sidewalk and paving on any side of a planter island shall be engineered structural soil base course material approved by the Planning Arborist. Specifications can be provided. 7.6 Tree protection and planting shall be consistent with the City Tree Technical Manual, Section 2.00 and 3.30 in all ways. The Manual shall prevail in the event a conflict in specification arises. 7.7 The relocation must be coordinated with Parks Department, Kate Rooney at 463-4977 or the above e-mail address. Stanford shall provide to the Parks Department .written instructions for care during the post-transplanting and recommended watering for the trees. This should be prepared by the contractor or the pr0iect arborist. 7.8 Before February 2002, the trees must be extracted professionally (a smaller tree spade should be sufficient) and moved to the new locations by Stanford. Receiving holes should have already been prepared by Stanford’s contractor. Parks Department should be geared up to provide the initial watering and care for the new trees. 8.HOUSING 8.1 Approximately 30,428 sq fl of net new space will be subject to the housing fee (81,928 non-exempt area minus 51,500 to be torn down). At the current rate of $4.21, the housing fee would be 128,101.88. Additional housing impact fees of general application adopted in 2002 shall be paid by the property owner pursuant to miti ~ation measure #6. 9.TRANSPORTATION 9.1 A traffic impact analysis is not required for the City or for the Congestion Management Program. The existing building square footage that was occupied at the time of the most recent traffic monitoring counts (April 2000) was 31,000 square feet according to Revised Conditions of Approval and Mitigation Measures 11 9.2 9.3 9.4 9.5 Stanford Management Company. Thus, foi determining the number of peak hour trips for CMP threshold purposes, the new square footage is 82,000 less the occupied area of 31,000 sf, or 51,000 sf. Using the Single Tenant Office land use category, the number of AM peak hour trips would be 91, not exceeding ~he 100-trip threshold, and thus not triggering a traffic study. This site is includedin the Comprehensive Plan EIR analysis, so no further traffic study for the City is required at this time. Mitigation is provided through th~ traffic impact fee. In addition to impact fees, Stanford shall provide a dedicated peak-hour shuttle between the proiect site and the California Avenue CalTrain upon issuance of the occupancy permit. The shuttle service shall be ineffect until the earlier of six months beyond the completion of intersection improvements at I-Ianover Street (at Page Mill Road) (estimated in City’s fiscal year 2004/2005) or 2007. If, at an’/ time following implementation of the service~ it is determined by the City and Stanford that the routing of the shuttle service to the proiect site is no longer desirable or required, the ioint oversight shuttle committee ma~/allow the service to be discontinued. A traffic impact fee is due for new square footage above the full square footage of the current buildings, at a rate of $3.03 per square foot (effective 7/i/01-6/30/02), payable before the building permit can be issued. Based on an approximate increase of 30,428 square feet, the fee would be $92,196.84. Unless there are other mitigating circumstances, we require that the sidewalk remain at sidewalk grade across project driveways, thus requiring driveway construction per Public Works Department standard drawing #120. iBicycle parking comments: A. Bicycle racks are not located acceptably because they are too far from the main public entrance. PAMC 18.83 requires ’bike parking to be located as conveniently as themost convenient auto parking (including handicapped stalls)i There appears to be ample space to place the bike racks in!on the plaza area surrounding the main entrance. B. The make and model of U-rack are acceptable. Since each "U" constitutes two bike parking spaces (one on each side), only three racks need to installed to meet the six-space requirement. However, it is desirable and acceptable to provide the extra racks if the applicant so desires. C. Approximately half of the lockers must be on ground level, somewhere near an employee entrance. The other half can remain in the garage. Dimensions are required for bike lockers showing that the required access aisles and clearances are provided for both sides of dual-sided lockers. Based on the garage layout, it appears that bicyclists will not be able to access all the lockers. In addition, lockers must be protected from being hit by automobiles, such as by placing lockers on raised islands.and/or providing bollards to prevent vehicle encroachment. Details are provided in PAMC 18.83. D. The make and model of bicycle lockers do not appear on the plans as near as we can determine. This is required. No fixed objects over three feet high, nor landscaping (except trees) over 2-1/2 feet high, all measured with respect to the driveway elevation, will be permitted in the vicinity of Revised Conditions of Approval and Mitigation Measures 12. driveways located 0n Hanover Street to avoid limiting the sight distance for exiting drivers. Refer to PAMC 18.83.110. 9.6 9.7 The preferred type of driveway curb cut is shown in the Department of Public Works standard drawing #120. This type of driveway crosses the sidewalk at the sidewalk grade, which is preferable from a pedestrian viewpoint. This is not the type of driveway that appear~ to be shown on the proposed plans. Consult Public Works for the correct type of driveway curb cut that is to be provided. Staff supports the proposed location of a possible future mid-block access in the Northeast Corner of the site. This access could be used in the future if ever a new roadway were developed between Page Mill Road and California Avenue. 10.BUILDING DIVISION THE FOLLOWING CONDITIONS APPLY PRIOR TO BUILDING AND GRADING pERMIT APPLICATION. 10.1 Address of the proposed new building shall be 2475 Hanover Street and the permit applications and plans shall reference this address. The address stated on the ARB application is 2575 Hanover Street, however, the majority of the site is currently addressed as 2475, which coincides better with the other properties and buildings along the street. 10.2 The plans submitted with the ARB application show the proposed building as a single large structure~ not two buildings as described in the ARB application. As such, the building shall be constructed under a single comprehensive building permit. 10.3 The building shall be served by a single electrical service in accordance with National Electric Code Art. 230-2 (not two services as shown on the submitted preliminary plans). 10.4 10.5 10.6 The electrical servicelocation shall require prior approval by the Inspection Services Division and shall be located at an exterior location or in a room or enclosure accessible directly, form the exterior. The building Shall be served by a single natural gas service, if multiple meters are required due to a future multi-tenant configuration, all gas meters shall be located at a single location on the site. The plans submitted fo~ the building permit shall include allowable floor area calculations that relate the proposed occupancies to type of construction. This includes possible future installation of assembly occupancies such as large conference rooms or cafeterias, for example. 10.7 Design of building components that are not included in the plans submitted for building permit and are to be "deferred" shall be limited to as few items as possible. The list of deferred items shall be reviewed and approved prior to permit application. Revised Conditions of Approval and Mitigation Measures 13 THE FOLLOWING CONDITIONS APPLY PRIOR TO ISSUANCE OF GRADING AND/OR BUILDING PERMITS 10.8 The project is currently comprised of two lots. Prior to issuance of grading and building permits the lots shall be merged to create a single parcel. 10.9 Demolition permits shall be required for the removal of the two existing buildings on the site. Issuance of the demolition permits is not dependent on completion of the lot merger required in condition 1 above. 11. PLANNING DIVISION/ARB 11.1 Timing devices and sensor lights shall be used wherever feasible, taking safety needs into consideration, for both interior and exterior lights-so that there is no. unnecessary continued illumination on the site. 11.2 11.3 11.4 11.5 11.6 In conjunction with Building Permit plans and/or tenant improvement plans, as may be applic.able, information regarding any proposed exterior building-lighting fixtures, interior lighting systems and interior shading systems shall be submitted. The shell building permit application plans must include detailed plans for the employee amenity area and proposed use(s) for planning staff evaluation, to determine whether the extra 2,005 square feet would be exempt. Otherwise, the building must not exceed the allowable floor area, pursuant to LM District regulations. The applicant shall pay to the City the sum of $150,000.00 before commencement of new construction at 2475 Hanover Street to be used by the City to assist with traffic calming improvements in the College Terrace neighborhood. The applicant shall pay fees to mitigate park, community center and library impacts. Such fees shall be paid before a building permit is issued at the rate recommended in CMR:381:01. If, prior to issuance of a final certificate of occupancy for this project, the City Council adopts a parks, community center and library impact fee of general application for similar proiects, at a higher rate, Stanford shall make an additional payment to increase its total payment to the new rate. No further Council action is required for imposition and collection of the fees at the rates specified in CMR:381:01 at building permit, or for collection of higher council-adopted fees before issuance of a certificate of occupancy. Prior to occupancy, the HVAC units must be tested by a qualified acoustical consultant to verify compliance with the Noise Ordinance, and results of the test must be provided to City Planning and Police staff. Revised Conditions of Approval and Mitigation Measures 14 Attachment C *RE VISED ENVIRONMENTAL CHECKLIST AND MITIGA TED NE GA TIVE DE CLARA TION City of Palo Alto Department .ofPlann!~g and Communi~ Environment 1.Project Title: 2.Lead Agency Name and Address: 3.Contact Person and Phone Number: Redevelopment of the ALZA Site City of Palo Alto, Planning Division 250 Hamilton Avenue Palo Alto, CA 94301 Amy French, Senior Planner (650) 329-2336 4.Project Location:2475 Hanover Street (comprised of parcels 142-20-004_and -005, formerly 2575 Hanover Street and 1275 California Avenue) 5.Application Numbers: 6.Project Sponsors’ Names and Addresses: 01-ARB-100; 01-EIA-15 MBT Architecture 185 Berry Street, Suite 500 San Francisco, CA 94107 Stanford Management Company 2770 Sand Hill Road Menlo Park, CA 94025 7.General Plan Designation:Research/Office Park 8.Zoning District(s):Limited Industrial]Research Park (LM) 9.Description of the.Project: Demolition of 51,500 square feet (2575 Hanover Street, ALZA Building D, and 1275 California Avenue, ALZA Building E and outbuilding) and construction of a two-story office building comprising 81,928 square feet (plus 2,005 square feet of area that is exempt from the FAR, parking, traffic fee and housing fee calculations). An underground parking facility comprising 59,133 square feet will provide 146 parking spaces, and 127 parking spaces will be provided at gade. The existing vegetation on the site will be removed and the site will be re-landscaped. 10. Surrounding Land Uses and Setting: The rectangular, 4.7 acre project site is within the LM Districtand £ located in tl~e Stanford Research Park. Development immediately to the north, south and east of the project site is characterized by office and industrial uses, which are also located on Stanford-owned land. Immediately to the west, across California Avenue, is the College Terrace single family residential district. The project site has relatively level topography (the grade level varies by 5 feet). The existing development.on the site includes two office/research and development buildings, an outbuilding, a surface parking lot and landscapiv_g which is mostly in poor condition: 11. Other public agencies whose approval is required (e.g. permits, financing approval, or participation agreement), none *Revisions appear in underlined text. ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED: The environmental factors checked below would be potentially affected by this project as indicated by the checklist on the following pages. X Aesthetics Agriculture Resources Air Quality . Hydrology/Water. Quality Land Use/Planning Mineral Resources Biological.Resources X Noise Cultural Resources X Pop’ulation/Housing Geology/Soils X I Public Services Hazards & Hazardous X Recreation Materials Transportation/Traffic Utilities/Service Systems Mandatory Eindings of Significance DETERMINATION: 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 ease 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 envir0nmenL but at least one effect: .1) has been adequately analyzed in an earlier document purs-uant to applicable legal standards, and 2) hasbeen addressed by mitigation measures based on the earlier analysis as deseribe.d 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 EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to ~hat earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required. X Director of Pla~ning &~Environment Date EVALUATION OF ENVIRONMENTAL IMPACTS: 1) 2) 3) A brief explanation is required for all answers except "No Impact" answers that are adequately supported by the information sources a lead agency cites in the parentheses following each question. A "No Impact" answer is adequately supported if the referenced information sources show that the impact simply does not apply to projects like the one involved(e, g. the project falls outside a fault rupture zone). A "No impact" answer should be explained where it is based on project-specific factors as well as general standards (e,g. the project will not expose sensitive receptors to pollutants, based on a project-specific screening analysis). All answers must take account of the whole action involved, including off-site as well as on-site, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts. Once the lead agency has determined that a partictilar physical impact may occur, then the checklist answers must indicate whether the impact is potentially significant, less than significant with mitigation, or less than significant. "Potentially Significant Impact" is appropriate if there is substantial evidence that an effect may be significant. If there are one or more "Potentially Significant Impact" entries when the determination is made, an EIR is required. 4) 5) "Negative Declaration: Less Than Significant With Mitigation Incorporated" applies where the incorporation of mitigation measures has reduced an effect from "Pote~ntially Significant Impact" to a "Less than Significant Impact." The lead agency must describe the mitigation measures, and briefly explain how theyreduce the effect to a less than significant level (mitigation measures from Section 17, "Earlier’Analysis," may be cross-referenced). Earlier analysis may be used where, pursuant to the tiering, program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration. Section 15063 © (3) (D). In this case, a brief discussion should identify the following: a) b) Earlier Analysis Used. Identify and state where they are available for review. Impacts Adequately Addressed. Identify which effects from the above checklist were within the sdope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measures based on the earlier analysis. c) Mitigation Measures. For effects that are "Less than Significant with Mitigation Measures Incorporated," describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the project. 6)Lead agencies are encouraged to incorporate into the checklist references to information sources for potential impacts (e.g. ^ --n! p~alL~, .......g ~,,4; ......)W~’r,r~noo ~-n ~ nrovinn~lv prepared org~n ....~t ......;~outside document should, where appropriate, include a reference to the page or pages where the statement is substantiated. 7)Supporting Information Sources: A source list should be attached, and other sources used or individuals contacted should be cited in the discussion. 8)This is only a suggested form, and lead agencies are free to use different formats; however, lead agencies should normally address the questions from this checklist that are relevant to a project’s environmental effects in whatever format is selected. 9) The explanation of each issue should identify: a)The significance criteria or threshold, if any, used to evaluate each question; and b)The mitigation measure identified, if any, to reduce the impact to less than significance 3 Sources Potentially,Potentially Less Than No Issues and Supporting Information Sources Significant " Significant Significant Impact Issues Unless Impact lVlitigated I.AESTHETICS. Would the project: a) Have a substantial adverse affect on a scenic vista?1, 2, 3 X b) Substantially damage scenic resources, including, but not 1, 2.3 X limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? c)Substantially degrade the existing visual character or 1 X quality of the site and its surroundings? d)Create a new source of substantial light or glare which 1, 2 X would adversely affect day or nighttime views in the area?’ II.AGRICULTURE RESOURCES. In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the Califot’nia AgricultUral Land Evaluation and Site Assessment Model (1997) prepared by ~he California Dept.of Conservation as an optional model to use in assessing impacts on agriculture and farmland. Would the project: . a) b) c) 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? ’ Conflict with existing zoning for agricultural use, or a Williamson Act contract? Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use? (map L-9), 4 N/A X X X III. AIR QUALITY. Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project: a) b) c) ¯ Conflict with or obstruct implementation of the applicable air quality plan? Violate any air quality standard or contribute substantially to an existing or projected air quality violation? 1,3 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)? 1,3 X X X d)Expose sensitivereceptors to substantial pollutant 1 concentrations? e) 1, 6 b) c) d) e) Wo b) c) Create objectionable odors affecting a substantial number of people? BIOLOGICAL RESOURCES. Would the project: 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? 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 US Fish and Wildlife Service? Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? 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 natiye wildlife nursery sites? Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional or state conservation plan? 1,3 1,3 1,3 1,3 1,3,5 1,3 X X X X X CULTURAL RESOURCES. Would the project: Cause a substantial adverse change in the significance of an historical resource pursuant to 15064.5? Cause a substantial adverse change in the significance of an arc.haeological resource pursuant to 15064.5? . Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? 1, 3 (map L-7) 1, 3 (map L-S), 6 1,3 (L-4, L-S), 6 X X X X 5 Issues and Supporting Information Sources d)Disturb any human remains, including those interred outside of forraal cemeteries? 1,3 (map L-8), 6 Potentially Significant Issues Potentially Significant Unless Mitigated X VI. GEOLOGY AND SOILS. Would the project: a)Expose people or structures to potential substantial see adverse effects, including the risk of loss, injury, or death,below involving: 7i)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 shaldng? iii)Seismic-related ground failure, including liquefaction? iv) La.ndslides ? b) c) d) e) Result in substantial soil erosion or the loss of topsoil? 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 on- or off- site landslide, lateral spreading, subsidence, liquefaction or collapse? 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? Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water? 3 (map N-IO) 3 (maP r -5) 3 (map N-S) 1 3 (map N-S), 8 3 (map N-S), 8 X X X X VII. HAZARDS AND HAZARDOUS MATERIALS. Would the project? a) Create a significant hazard to the public or the¯environment through the routing transport, use, or disposal of hazardous materials? 1,8 Less Than Significant Impact X No Impact I X X X Issues and Supporting Information Sources b) c) d) h) 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? Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances; or waste within one- quarter mile of an existing or proposed school? 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? 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? For a project within the vic.inity of a private airstrip, would the project resu!t in a safety hazard for people residing or working the project area? impair implementation of or pl~ysieally interfere with an adopted emergency respons~ plan or emergency evacuation plan? 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 wiidlands? Soul’ees 1,8 2, 8, 9 N/A N/A 1, 3 (map N-7) 1,3 ¯ (map N-7), 9 Potentially Significant Issues Potentially Significant Unless Mitigate~ Less Than Significant Impact X No Impact X X X X X VIII. HYDROLOGY AND WATER QUALITY. Would the project: a) Violate any waferquality standards or waste discharge 1, 3, 8,X requirements?10 b)X c) 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 g~anted)? 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 on- or off-site? 3 (map N,2) 1,2 X Issues and Supporting Information Sources 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 amoun~ of surface runoff in a manner which would result in flooding on-or off-site? ¯ Create or contribute runoff water which would exceed the capacity of existing or planned stormwater 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? SOtlrCes 10, 11 1, 2, 10 N/A h) Placewithin a 100-year flood hazard area structures which 3 (map would impede or redirect-flood flows?N-6) i) Expose people or structures to a significant risk of loss,3(maps injury or death involve flooding, including flooding as a N-8, N- result of the failure of a levee or dam?8) . j) Inundation by seiche, tsunami, or mudflow?3(maps N-6, N- 8) IX. LAND USE AND PLANNING. Would the project: a) Physically divide an established community?N/A b)1, 3 Potentially Significant Issues Potentially Significant Unless Mitigated Less Than Significant Impact Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but nol 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 X X X X X X 8 c) Conflict with any applicable habitat conservation plan or 1, 3 X natural community conservation plan? X. MINERAL RESOURCES. Would the project: a) Result in the loss of availability of a known mineral 1, 3 X resource that would be of value to the region and the residents of the state? Issues and Supporting Information Sources b)Result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, spegific plan or other land use plan? 1,3 Poten tinily Significant Issues Potentially Significant Unless Mitigated Less Than No Significant Impact Impact X XI. NOISE. Would the project result in: a) b) c) d) e) 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? Exposure of persons to or generation of excessive ground borne vibration or ground borne noise levels? A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project? A substantial temporary or periodic increase in ambient noise levels in the project vicihity above levels existing without the project? For a project located within an airport land use plan or, where such a plan has not been adopted, would the project expose people residing or working in the project area to excessive noise levels? 3,8 3,8 1,8 N/A .X X X X X f) For a project within the vicin.ity of a private airstrip, would N/A X the project expose people residing or working in the . project area to excessive noise levels? XII. POPULATION AND HOUSING. Would the project: [ a)1, 2, 3 X b) Induce substantial population growth in an area, either directly (for example, by proposingnew homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? Displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere? Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere? N/A N/A X Xc) Issues and Supporting Information Sources Potentially Significant Issues Potentially Significant Unless Mitigated Less Than Significant Impact XIII. PUBLIC SERVICES. a)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: Fire Protection? .Police protection? Schools? Parks? Other Public facilities? x v. R CREAT ON 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? see below 9 1 1 13 13 1, 13 N/A X X No Impact ~) X X X XV. TRANSPORTATION/TRAFFIC. Would the project: X3 (maps T-7, T- 8) 12 N/A Cause an increase in traffic which is substantial in relation to the existing traffic load and capacity of the street system (i.e., result in a substantial increase in either the number of vehicle trips, the volume to capacity ratio on roads, or congestion at intersections)? b) Exceed, either individually or cumulatively, a level of service standard established by the county congestion management agency for designated roads or highways? c)Result in change inair traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks? X X 10 Issues and Supporting Information Sources d) e) Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? Result in inadequate emergency access? f) Result in inadequate parking capacity? g) Conflict with adopted policies, plans, or programs supporting alternative transportation (e.g., bus turnouts, bicycle racks)? 1,9 1, 2, 4 1,3 Pot6ntially Significant Issues Potentially Significant Unless Mitigated Less Than Significant Impact b) e) d) e) UTILITIES AND SERVICE SYSTEMS. Would the project: Exceed wastewater treatment requirements of the applicable 1Regional Water Quality Control Board? 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? Require or result in the construction of new storm water drainage faciI!ties or expansion of existing facilities, the construction of which could cause significant environmental effects? Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed? Result in a determination by the wastewate~ 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? Be served by a landfill with sufficient permitted capacity to accommodate the project’s soIld waste disposal needs? 1, 3, 10 1, 3, 10 1, 10, 11 10 3, 11 g) Comply with federal, state, and local statutes and regulations related to solid waste? 11 ]No Impact X X X X X X X X X X X 11 XVIL MANDATORY FINDINGS OF SIGNIFICANCE. 1,3,5 Xa) b) c) 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 f~sh 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? 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)? Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly? 1,3 ~12 X SOURCE REFERENCES (Memoranda, analyses, reports, and assessments, noted below, pertain to project site): 5. 6. 7. 8. Project Planner’s knowledge of the site and the proposed project. Project Plans, entitled "SMC PROJECT" prepared by MBT Architecture, dated July 26, 2001. Palo Alto Comprehensive Plan, 1998-2010. Parenthetical references indicate maps found in the Comprehensive Plan. Palo Alto Municipal Code, Title 18 (Zoning Ordinance). Certified A_rborist’s Tree Inventory with Tree Appraisal, prepared by Ray Morneau, Arborist, dated August 16, 2001. City of Palo Alto, Planning Arborist memorandum Alquist-Priolo Earthquake Fault Zoning Map. Project Description (8/16/01), Environmental Assessment Worksheet and project-specific documentation (Acoustical Study dated 8/13/0 l, G eotechnical Investigation dated 112101, Installation of Wells and Remediation System prepared by Aquifer Sciences, Inc. dated 9/12/01, and Tree Inventory/Appraisal dated 8116/01submitted by applicant.) -. City of Palo Alto, Fire Department memorandum. City of Palo Alto, Utilities Engineering Division memorandum. City of Palo Alto, Public Works Department memorandum. City of Palo Alto, Transportation Division memorandum. Parks and Community Facilities Impact Fee Study by DMG-Maximus, dated September 18, 2001 Aquifer Sciences Monitoring Report for Fourth Quarter 2001 EXPLANATION FOR CHECKLIST RESPONSES: I. Aesthetics The site is developed with two two-and one-story industrial buildings. As designed, the new building will be two stories, which will have greater mass than the existing development, as seen from the residential neighborhood. The mass will be visually reduced sinc.e (1) a large setback (105 feet) will be provided on the residential facing side, (2) an earth berm will be created along California Avenue and landscaped with redwood trees in a dense grove, (3) 24" box size trees (Catalina Ironwood) wiiI be planted adjacent to the building, and (4) a double row of trees will be planted at the sidewalk on California Avenue. Of the 122 trees on the site. very few are in rood condition on the site and no trees in excellent condition, according m the arborist’s report. A mature, oak (tree 89) will be transplanted to a more prominent location at the entry plaza. Accordina to the arborist’s report, the "ash trees facina Hanover are all in poor to very poor condition and would not be expected m survive or recover under any pro-~ram" and I2 would be removed and replaced with ash trees. Plans show 15 ~al!on size Moraine Ash trees in a double row (alice) alon~ California Avenue and a single row aloha Hanover Street. a condition of approval requiresthe new street trees alon~ both California and Hanover to be Purple Autumn American Ash (Fraxinus americana ’Purpl~ Autumn’) of 24-inch box size. The building permit plans will include the correction. The transformers and trash enclosures will be screened as indicated in landscape plans. The project is subject to review by the Architectural Review Board, to ensure the building design will be aesthetically appropriate and compatible with the site and surrounding development, and the site improvements will be harmonious and appropriate to the building. The nearest exterior pole light fixtures to the residential neighborhood will be located approximately 60 feet from the westerly property line. These lights are low (pt;oposed at 13 feet in height) and the substantial redwood tree plantings on the west side of the lights will mitigate the potential glare offsite. Other lights on the site include 15-foot tall pole lights to illuminate the parking lot areas, and bollard lights in pedestrian walkway areas. The current proposal does not include lighting fixtures on the exterior of the building, but there will be a substantial amount of glass on the building, which may result in increased light from inside the offices at night, and glare reflected from the sun from outside duringthe day. The project is required to meet the provisions of Palo Alto Municipal Code Chapter 18.64, Additional Site Development and Design Regulations for Commercial and Industrial Districts. Section 18.64.030 (a)(2)(A) requires the elimination of glare and light spillover beyond the pertmeter of the development. Mitigation measure #1 requires submittal information- regarding interior lighting systems and interior shading systems in conjunction with tenant improvement plans, to ensure any light and glare impacts of the project will be reduced to a level of insignificance. Mitigation Measure #1: Interior lighting systems shall by described in tenant improvement plans for staff architectural review, and shall address timing and shading issues, and include measures necessary to meet City requirements. II.Agriculture Resources The site is not located in a "Prime Farmland," "Unique Farmland," or "Farmland of Statewide Importance" area, as shown on the maps prepared for the Farmland Mapping and Monitoring Program of the California Resources Agency. The site is not zoned for agricultural use, and is not regulated by the Williamson Act. Mitigation Measures: None required. III. Air Quality The redevelopment proposal will not have a significant effect on air quality. Even though more vehicle trips will be generated by the proposal than at present, the project will not, either individually or cumulatively, be of a scale to effect any regional ai~ quality plan or standards. Moreover, the project is proposing development consistent with the intensity (0.4:1.0 floor-area-ratio) contemplated by the Comprehensive Plan, for which an Environmental Impact Report (EIR) was adopted in 1998. A temporary increase in dust during demolition and construction, however, is likely but will be minimized through conditions of approva!, including the implementation of construction practices in accordance with BAAQMD regulations. Mitigation Measures: None required. IV. Biological Resources No endangered, threatened, or special gtatus animal or plant species have been identified at this site. The project includes the removal of existing on-site landscaping, including native species. The Planning ,M-borist has reviewed the proposal and determined that the proposed removal of landscaping is offset by the overall increase in landscape specimens. Mitigation Measures: None required. V. Cultural Resources The site is currently developed with two office buildings, parking facilities and landscaping. The site has been disturbed as a part of the existing development. No additional area will be disturbed and there are no "known cultural resources on the site. The 13 Comprehensive Plan indicates that the project site is located within an Archaeological Resource Area of moderate sensitivity.’ Mitigation Measure #2: !f cultural, paleontological, or historical resources are found during construction, all construction activities shall cease and the Director of Planning and Community Environment shall be notified and mitigation measures - pursuant to Public Resources Code, Section 70S0.5 and CEQA Guidelines shall be followed. Vll. Geology and Soils The entire state of California is in a seismically active area and the site located in a seismic risk area, subject to strong ground shaking in the event of an earthquake. Strong ground shaking can be expected at the site during moderate.to severe earthquakes. No known faults cross the project site. Map N-5 of the City’s Comprehensive Plan indicate the site has expansive soils and is located within an area having high potential for surface rupture along fault traces and potent!al for earthquake induced landslides where sloped (although the site is not sloped). A geotechnical investigation report prepared by Lowney Associates (dated January 2, 2001) has been submitted to the City for review. All new construction will be required to comply with to the provisions of the most current Uniform Building Code {UBC), portions of wlaich are directed at minimizing seismic risk and preventing loss of life and property in the event of an earthquake. The City’s required standard conditions of approyal ensure that potential impacts on erosion and soil will not be gignificant. Site soil modifications are not expected to result in significant adverse environmenta! impacts. The volume of soil to be removed has not been stated, but the depth of the cut would be approximately 10 to 14 feet for the underground parking area. project conditions of approval will require the applicant to submit a fi,nal grading and drainage plan subject to review by the Department of Public Works prior to issuance of any grading and building permits, Mitigation Measure #3: All proposed buildings and structures shall conform to Uniform Building Code, Zone 4 guidelines. New buildings and structures sha!! be designed in accordance wiih the recommendations of the Geotechnical Investigation report dated January 2, 2001, ’VII. Hazards and Hazardous Materials The site at 1275 California Avenue (Building E) was the location of a 1,500 gallon underground storage tank and industrial waste- water sump at 1275 California Avenue. The Polo Alto Fire Department Hazardous Materials Facility Closure requirements have been met (per March 23, 2000 letter on file). Final clean-up action was completed in January 2000. Hazardous materials (chloroform) were also stared at 2575 Hanover Street. The. California Regional Water Quality Control Board, Santa Clara Valley Water District (SCVWD) approved a work plan (dated April 26, 200,1) for environmental investigation and remedia~ion. "Ehe plan includes the implementation of monitoring wells, vapor extraction wells and air sparging. Permits have been obtained from SCVWD and the Bay Area Air Quality. Management District (BAAQMD) for well installation and system operations. A total of 21monitoring wells, vapor extraction wells, and air sparging wells were installed and operations of these wells began in June, 2001. Other remediation measures recently taken are described on pages 2 and 12 of the report prepared by Aquifer Sciences, Inc. The operation of the remediation system is ongoing, to further reduce chloroform levels in soil and ¯ groundwater. The chloroform impacted area of concern is localized and confined near the north east comer ofbuildin~ D. Based on data in the Januaw 2002 Aquifer Sciences report, the soil remediat0n ~oal has been reached in this area and the soil is considered clean. The groundwater chloroform concentrations are down to a maximum of 160 ppb and the cleanup goal is 80ppb. Groundwater at the site is at 25 feet below ground surface at the site. Overali site grading will be to a depth of 2 to 3 feet except for the under~round garage which will not do deeper than 16 feet below grade. The area where ~oundwater is impacted is not in the building or. garage footprint. Therefore, no additional safety measures are needed. Mitigation Mieasure #4: The building permit plans shall include a sheet showing the location of all remediation wells on the site of the existing ALZA building D (2575 Hanover Street). VIII. Hydrology and Water Quality The proposed redevelopment project will compiy with City, State and Federal standards pertaining to water quality and waste discharge, and storm water run-off. The project will not substantially deplete groundwater supplies, nor will it substantially alter the existing drainage pattern of the site. Mitigation Measures: None required. IX. Land Use and Planning The Comprehensive Plan designation for this site is Research/Office Park. Immediately surrounding land uses are office/research buildings and a low-density residential neighborhood. Given.the proposed design of the project, which minimizes potential effects to the most sensitive surrounding uses (residential), it is compatible with all adjacent development. The City’s zoning regulations do not specify law firms as being in a different category of use than professional offices, which .are allowed in the Stanford Research Park as a permitted use. The replacement of toxicologists with lawyers is not an environmental impact. The City’s environmental analysis of the use only deals with the potential physical impacts. The proposed law office use is at least as compatible with the nearby residential neighborh’ood as the previous R&D finn (ALZA), which generated groundwater pollution on the site. The project is consistent with Comprehensive Plan Policies and land use designation of Research/Office Park. The applicant laas met with the College Terrace Residence Association several ~imes and has modified their project plans to address their concerns. The new building’s setback from the California Avenue property line will be a significantly larger setback than that 0fthe existing building. In addition to the proposed building setback, a landscaped berrn and significant tree plantings are proposed between the building and California Avenue. This represents a substantial buffer from the neighborhood, and is an adequate method of achieving a gradual t~-ansition in the scale of development between residential and non-residential areas. Mitigation Measures: None required. X. Mineral Resources The project will not impact known mineral or locally-important mineral resources. Mitigation Mgasures~ None required. X[. Noise Rooftop HVAC units are proposed. The applicant is required to comply with the Polo Alto Noise Ordinance, Chapter 9.10 PAMC. Additionally, project-specific noise analyses and recommendations were completed by Wilson, Ihrig & Associates, Inc. in a report dated August 13,2001. All recommendations identified in the report regarding use of systems designed to minimize noise of roof-mounted equipment to meet City requirements sha!l be fol!owed. Mitigation Measure #5: The project shall include the installation and operation of equipment in accordance with noise analyses and recommendations prepared by Wilson, Ihrig & Associates, Inc. XII. Population and Housing The net new office area will be 30,428 square feet. This represents a potential increase of 121.6 jobs, or 1/10t~ of 1% (.001) of the total number of jobs in Palo Alto. This expansion is consistent with the Land Use Element of the City’s Comprehensive Plan and zoning regulations which anticipate some moderate job growth in Palo Alto. The City of Palo Alto has, on a regional basis, met our market-rate housing goals however it is deficient in below-market rate housing. The City’s below market rate housing impact fees are currently under Council review. In addition to paying $128,101.88 in housing impact feesas currently required for the net new floor area, the applicant will pay any inc,’eased housin~ fee of ~eneral application adopted by the City Council in the year 2002. See City Manager’s Repor(dated October 16, 2001 (referehcing the September 18, 2001 DMG-Maximus study) for range of possible fees. Mitigation in the form of increased fees is set forth in mitiaation measure #6. Mitigation Measure #6: The property owner shall pay housin~ impact fees of ~eneral application at the fee level adopted by the City Council in the year 2002. XIII. Public Services Fire The proposed project would not impact fire service to the existtng oNce/research park. The site is not located in a high fire hazard area. I5 Polic____~e The site is located within the jurisdiction of the Pulp Alto Police Department. for additional police officers, equipment, or facilities. The facility would not by itself result in the need Schools The project is subject to standard school impact fees, so that the project will have a less than significant impact upon schools. Park_____~s Recent studies have shown that office development does have an impact on park usage. Impact fees to address this impact aro. currently beinR studied by the City Council. The applicant will pay any park impact fees of general application adopted by the City Council in the year 2002. See City Manager’s Report dated October 16, 2001 (referenc.in~ the September 18, 2001 DMG- Maxtmus study)for range of.possible fees. Mitization in the form of increased fees is set forth in mitigation measure #7. Mitigation Measure #7: The property owner shall pay park impact fees of General application at the fee level adopted by the City Council in the year 2002. Other Public Facilitie~ Recent studies have shown that office devel.opment does have an impact on libraries and community facilities usage. Impact fees to address this impact are currently being studied by the City Council. The applicant will pay.any park impact fees of.zeneral application adopted by the C.ity Council in the year 2002. See City Manager’s .Report dated October ! ~i, 2001 (referencinR the September 18, 2001 DMG-Maximus study) for range of possible fees. Mitigation in the form of increased fees is set forth in mitigation measure #8. Mitigation Measure #8: The property owner shail pay library and community facilities impact fees of ~eneral application at the fee level adopted by the City Council in the year 2002. XIV. Recreation Recent studies have shown that office development does have an impact on parks, libraries-and community facilities usage. Impact fees to address this impact are currently bein.a studied by the City. Council. The applicant will pay any park impact fees of general application adopted by the Ci~ Council’.m the year 2002. See City Manager’s Report dated.October ! 6, 2001 (’referencing the September 18, 2001 DMG-Maximus study) for range of possible fees. Mitigation in the form of increased fees is set forth in mitigation measures #7 and #8. XV. Transpoctation/Traffic There are minor non-compliance issues related to placement and dimensions 0f bicycle parking spaces and vehicle gara.ge parking spaces, which will be addressed via conditions of project approval. City traffic counts of April 2000 occurred when only 31,Q00 square feet of the existing 51,500 square foot ALZA building was occupied. The City’s Transportation Planner assumed an addition of 51,000 square feet in the category of Single Tenant Office land use, with a corresponding increase of 91 AM peak hour trips, which does not exceed the 100-trip threshold. In addition, the build-outof this site was included in the Comprehensive Plan EIR analysis. Therefore a traffic study was not required. Nevertheless, the applicant has prepared and submitted a traffic study. The report Conforms with the Valley Transportation Authority’s (VTA) requirements. The report’s assumptions include an increase of 30, 500 Square feet, whereas the City assumed an increase of 5!, 000 square feet for the purpose of calculating potential trip increases. The City studied the project as an office use, which is the long-term use of the site. The City’s analysis was based on the square footage increase and appropriate engineering studies (ITE) of uses. Improvements at the intersection of Page Mill Koad and Hanover Street are currently budgeted and next in line for improvement by the City. A traffic impact fee based upon rates in effect at the time ofst~bmitta! will be collected from the building permit applicant. The project is subject to the City’s traffic mitigation fees, and the applicant will pay $92,196.84 for the project. The proiect also.includes $150.000 payment to the City toward implementation of traffic calming improvements in the College Terrace neighborhood. Mitigation Measures: None required. XVI. Utilities and Service Systems The proposed project would not significantly increase the demand on existing utilities and service systems or use resources in a 16 wasteful or inefficient manner. Mitigation Measures: None required. MANDATORY FINDINGS OF SIGNIFICANCE The proposed redevelopment of the project site is large-scale in nature, but will not substantially degrade the surrounding environment, impact wildlife species or their habitat, or el{minate important examples of cultural history or pre-history. Additionally, the project will not create considerable cumulative impacts since it is located in an area that is largely developed,affording only a limited degree of additional redevelopment possibilities. Additionally, the project will not cause substantial adverse effects on human beings. WE, THE UNDERSIGNED, HEREBY ATTEST THAT WE HAVE REVIEWED THIS REVISED MITIGATED NEGATIVE DECLNRATION DATED JANUARY 30, 2002, PREPARED FOR THE PROPOSED REDEVELOPMENT OF THE PROPERTY KNOWN AS 2575 HANOVER STREET AND 1275 CALIFORNIA AVENUE, PALO ALTO, CALIFORNIA, AND AGREE TO IMPLEMENT ALL MITIGATION MEASURES CONTAINED HEREIN, Date 17 ATTACHMENT D Additional/Alternate/Amended Conditions of Approval SMC Project, 2475 Hanover Street / File No. 01-ARB-100, 01-EIA-15 Additional Condition 7.9 Holly oak no. 1 shall be retained and protected through the course of construction in accordance with the City’s Tree Technical Manual, Section 2.00. The applicant’s landscape architect shall include this tree on the final landscape plan to be submitted for building permits. Alternate Amended Condition 7.4 (Unchanged portion): The street trees along California Avenue shall be Purple Autumn American Ash (Fraxinus americana ’Purple Autumn’) of 24-inch box size, planted per PW Detail No. 504 (please use the updated diagram). (Changed portion follows): The ash trees along Hanover Street shall be further evaluated by the project arborist, City arborists, and landscape architect to determine which trees must be removed, which trees can be reasonably retained, and the number .and location of new street trees that could be added to be consistent with the Hanover streetconcept. The project arborist would need to recommend measures to improve the health, and repair trunk damage and rotting root systems of any trees to be retained. These measures must include crown restoration, and selective removal of damaged and rotting roots. Alternate Amended Condition 9.1 (Unchanged portion): A traffic impact analysis is not required for the City or for the Congestion Management Program. The existing building square footage that was occupied at the time of the most recent traffic monitoring counts (April 2000) was 31,000 square feet according to Stanford Management Company. Thus, for determining the number of peak hour trips for CMP threshold purposes, the new square footage is 82,000 less the occupied area of 31,000 sf, or 51,000 sf. Using the Single Tenant Office land use category, the number of AM peak hour trips would be 91, not exceeding the 100-trip threshold, and thus not triggering a traffic study. This site is included in the Comprehensive Plan EIR analysis, so no further traffic study for the City is required at this time. Mitigation is provided through the traffic impact fee. (Changed portion follows): In addition to impact fees, Stanford shall pay $70,000 per year to fund a shuttle to be, operated by the City for the time period between building occupancy and six months after the installation of intersection improvements at Hanover Street (at Page Mill Road) (estimated in City’s fiscal 5,ear 2004/2005). Stanford will not be financially responsible for the additional hours of operation if the City wants to augment the program beyond the peak hours proposed by Stanford. Stanford may allow other Stanford Research Additional/Alternate/Amended Conditions of Approval 1 Park tenants to use and perhaps electively contribute to the shuttle. While the pilot project is running, Stanford shall work with the City to explore funding sources for the shuttle beyond the "gap" period. If intersection improvements are-not completed by the end of calendar year 2007, Stanford may discontinue its funding to the City at that time. If, at any time following implementation of the service, it is determined by the City and Stanford that the routing of the shuttle service to the project site is no logger desirable or required, the ioint oversight shuttle committee may allow the service to be discontinued. Additional/Alternate/Amended Conditions of Approval 2 RAY MORNEAU ¯ARBORIST ¯ 1354 Date A~/e. #8, Mountain View, CA 94040 ¯ Telephone: 650-964-7664 eMaih rmarborist@aol.como http://members.aol.com/RMArborist Attachment E Certified Arborist’s Tree Inventory with Tree Appraisal PROJECT LOCATION Stanford Commercial Site 2575 Hanover Avenue Palo Alto, California REPORT: Pre-construction Tree Inventory with Ti-ee Appraisal Values. REPORT FOR: Stanford Management Company Ramsey Shuayto 2770 Sand Hill Road Menlo Park, CA 94025 DATE OF REPORT: August 16, 2001. CONSULTATION & REPORT BY: Ray Momeau, Arborist ISA Certified Arborist #WC-0132 1354 Dale Avenue #8 Mountain View, CA 94040 (415-) 964-7664 Ray Morneau, Arborist ISA Certif. #WC-0132 650.96~.7664 Table of Contents 1.0 Scope and Purpose .............................................1. 2.0 Site Description. 2.1 General .............................................1. 2.2 Summaries 2 " 2.3 Outstanding Trees ...........................3 - 4. 3.0 Tree Inventory Methodg .....................................4 - 5. 4.0. Tree Appraisal Methods ....................................6. 5.0 Introduction to Tree Protection Measures ...........6 - 7. 6.0 Site-Specific Tree Protection Measures ..............7 - 12. 7.0 Appendices. 7.1 Assumptions & Limiting Conditions.. 13. 7.2 Literature and Authorities ................14. 7.3 Inventory Data ..................................14 - 27. 7.4 Appraisal Data (with Legend) ..........28 - 30. 7.5 Site Drawing (with tree numbers) ....31. 1.0 Scope-and Purpose This pre-construction certified arborist’s tree inventory results from my observation and inspection of the identified trees on the site around 2575 Hanover Street, Palo Alto, California. I have reviewed a copy of the Kier & Wright drawing titled "Topographic Survey", Sheet 1 of 1, dated October, 2000. This report provides data for this site’s 122 existing significant trees as identified by Palo Alto Municipal Code, §8.10 as data was gathered during August, 2001. 2.0 Site Description 2.1 General This is a commercial site in the area of Palo Alto known as the Stanford Industrial Park. The existing older buildings will be replaced. The project will include relandscaping. The current plant material on site is mostly over-mature, declining specimens. It would be a substantial benefit for the community’s urban forest to replant new trees and shrubs here. This site’s climate is in USDA plant hardiness zone 9 (USDA, 1949, p. 817). The micro-climate conforms to theSunset (1995, p. 28) zone 15. Au~st 16, 2001 Pre-Constmction: 2575 Hanover Street, Palo Alto.Page #1 of 31. Ray Morneau,1 Arborist- ~ISA Certifo #WC-O132 650.964.7664 2.2 Summaries As detailed in the "Tree Data" section of this report, the condition of this site’s 122 major identified trees can be summarized per the following table: CONDITION OVERALL Excellent 90- 100% 0 Good 70- 89%5 . Fair 50 - 69% Poor 26 - 49%42 Very Poor 25 - 2%26 Dead or Stumps 1 ~ 0%7 TOTAL 122 Pilqe, MontereyI 19 River Red Gum: 15 Sweetgum! 12 Maidenhair Tree 11 Ash, Moraine 8 Olive, Commor 7 Pittosl~_orurr 6 Plum, Commor 5 Birch, European White 4 Bottlebrush 4 Fern Pine 4 Eucalypt (???)3 Cedar, Deodar 2 Coffeeberry 2 Hawthorn, English 2 ¯ Mimosa; SilkTree 2 Acacia, Blackwood 1 Camphor 1 Cedar, Atlas 1 Cherry-laurel 1 Cotoneaster, Parney’s 1 Crabapple 1 Elm, Chinese 1 Horsechestnut, Red ;1 Juniper, Hollywood 1 Magnolia, Southern 1 Mulberry, Fruitless ! .Oak, Coast Live 1 Oak, Holly t Olive, Common 1 _ Pine,- Austrian Black~1 Privet, Japanesel 1 ~122 Sort Pinus radia{a Eucalyptus camaldulensis Liquidambar styraciflua Ginkgo biloba Fraxinus ’Moraine’ Olea europa Pittosporum.. tenuifolia Prunus species Betula pendula ~Callistemon citrinus IPodocarpus gracilior IEucalyptus species Cedrus deodara Rhamnus californica ~Crataegus laevigata :Albizzia julibrissin Acacia melanoxylon Cinnamomum camphora Cedrus atlantica Prunus laurocerasus Cotoneaster lacteus Malus floribunda Ulmus pavifolia Aesculus carnea Juniperus chinensis ’tortuosa’ Magnolia grandiflora Morus alba Quercus agrifolia Quercus ilex Olea europa Pinus nigra Li_gustrum lucidum August 16, 2001 Pre-Construction: 2575 Hanover Street, palo Alto.Page #2 of 31. Ray Morneau, Arborist Common Name Sod IBotanical Name Sort Acacia, Blackwooc 1 1 tAcacia mel.anoxylon Ash, Moraine 8 1 ~kesculus carnea Birch, European White 4 2 Albizziajulibrissin Bottlebrush 4 4 Betula pen.dula Camphor !4 Callistemon citrinus Cedar, Atlas 1 1 Cedrus atlantica Cedar, Deodar 2 2 Cedrus deodara Cherry-laurel 1 1 Cinnamomum camphora Coffeeberry 2 1 Cotoneaster lacteus Cotoneaster, Parney’s 1 2 Crataegus laevigata Crabapple 1 15 Eucalyptus camaldu~ensis Elm, Chinese 1 3 Eucaly.ptus species Eucalypt (???) 3 8 Fraxinus’Moraine’ Fern Pine 4 11 Ginkgo biloba Hawthorn, English 2 1 Juniperus chinensis ’tortuosa’ Horsechestnut, Red !1 Ligustrum !ucidum Juniper, Hollywood 1 12 Liquidambar styraciflua Ma~gnolia, Southern 1 1 Magnolia grandiflora Maidenhair Tree 11 1 Malus fioribunda Mimosa; SilkTree 2 1 Moi’us alba Mulberry, Fruitless 1 7 Olea europa Oak, Coast Live 1 1.Olea europa Oak, Holly 1 1 Pinus nigra Olive, Common 7 19 Pinus radiata . . Olive, Common 1 6 Pittosporum tenuifolia Pine, Austrian Blacl~ 1 4 Podocarpus gracili0r Pine, Monterey 19 1 Prunus laurocerasus Pittosporum 6 5 Prunus species Plum, Common 5 1 Quercus agrifolia Privet, Japanese 1 1 Quercus ilex River Red Gurr 15 2 Rhamnus californicaSweetgurr 11222 122 1 tUlmus pavif°lia 650.964.7664 2.3 Outstanding Trees Atlas Cedar (Cedrus atlantica) is a dead monstrosity at the front entrance to the existing building (California Avenue side). The only discernible causal agent is.root rot. Died before .project. Moraine Ash (Fraxinus ’Moraine’) facing Hanover are all in "Poor" to ~’Very Poor" condition and have been declining for some time. They would not be expected to survive (or recover) under any program. Monterey pines (~Pinus radiata) are very stressed. Most are substantially declining. Age and climate are probably the major factors. Fresh red turpentine beetle pitch tubes were found at the bases of most of these pines, indicating an active and maj or infestation. August 16, 2001 Pre-Construction: 2575 Hanover Street, Palo Alto.Page #3 of 31. Ray Morneau, Arborist 650.964.7664 River Red Gum (Eucalyptus camaldulensis), and other less-known Eucalypts, have been introduced from the Australian continent. An insect infestation has sprung up here -- a leaf-sucking bug named the lerp-forming psyllid which protects itself with a tiny sugary cone (lerp). And, effective controls have not yet been established. However, UC is working with a possible future control, importing another Australian native as a predator, but full-scale releases’ are not being made yet. Sweetgum trees (Liquidambar styraCiflua), though often planted for the fast growth and notable autumn color, here have the typical problems to the species, from surface roots to weak structure, from bleeding canker to dieback. 3.0 Tree Inv.entory Methods All significant trees on site were numbered, tagged, and inspected. Significant trees are those planted on site as part of a previous project and any self-seeded with a diameter of 4" or more. Observations were made and data gathered during my Autumn 2000 and August 2001 on-site inspections. Further conclusions and protection measures were refined from office research, seminar information, and past experience based on those observations and data. The gathered data was entered into a Microsoft® Works Database®. The data is encapsulized into the "Tree Data" section below. The categories are self-evident with only the following cnotes. # (Tree Number): I sequentially assigned tree numbers, commencing at the holly oak at the corner of California Avenue & Hanover Street. A 1" by 3" aluminum tag was stapled to each tree at about eye level. I add a prefix "2K" (for the year 2000) to identify each as linked with this inventory, thus differentiating it from any other numbering system. Names: We employ the initial common names from McMirm, if listed, otherwise from Sunset. Scientific/botanical names are included to minimize confusion. As applicable, we used McMinn’s key and/or Sunset’s descriptions Diameter(s) (dbh): This standard measuremem is the trunk "diameter breast high (4.5 feet above grade)", taken with a surveyor’s diameter-tape, recorded in inches and tenths. Alternatively, the measurement was taken beneath the lowest branch when the first branching or crotch swelling occurs at or below 4.5 feet. Span: Averaged canopy, spread is measured in feet. Rt (Height): Estimated distance foliage crown extends above grade, recorded in feet. August 16, 2001 Pre-Construction: 2575 Hanover Street, Palo Alto.Page #4 of 31. Ray Morneau, Arborist ~~ISA Cerfif. #V#C-0~32 650.964.7664 Crown Class: This helps visualize and assess tree form in the event stand might be altered. Both aesthetics and stability can be changed when adjacent trees are pruned or removed. Classifications: Dominant: tree canopy standing alone or over companions. Codominant: tree canopy blends with, but is crowded by, .companions. Intermediate: crowded canopy receiving some light from above but little, if any, from sides. Suppressed: tree’s foliage below surrounding trees’. Vigor: Rating for tree’s growth and vitality as a blend of elements like leaf or bud size and color, twig growth (elongation), accumulation of deadwood, cavities, woundwood development, trunk expansion (growth "cracks"), etc. % Form: Rating for tree’s architecture as a composite of factors like branch attachment, lean and balance, effects of prior breakage, crossing-tangled-twisted limbs, codominant trunks and]or branches, decay and cavities, anchorage (roots), etc. Overall Condition: Percentage rating assessing the tree’s overall vigor, recent growth, insects/diseases, and structural defects. Relative text rating included in the same ceil as: Excellent, Good, Fair, Poor, Very Poor. Thi; corresponds to the "Condition Percentage" factor in tree valuations per the Council of Tree and Landscape Appraisers (CTLA) system used by the International Society of Arboriculture. (CTLA, 1992.) It combines foliage, branches, limbs, trunk, and root ratings into a composite condition score. Suitability for Preservation: Considers tree’s condition (vigor and structure), longevity/age, adaptability, and aesthetics. This rating takes into account any announced intentions of changes in area’lot use. Degrees: High, Moderate, Low, Very Low. High: Tree in great condition and any existing defects or stresses are minor or can be easily mitigated. Modei’ate: Notable vigor and]or stability problems but which can be moderated with treatment and]or increased tree protection zone. Low: Significant problems, including shorter life expectancy. Difficult to retain but potential with much larger tree protection zone. Very Low: Substantial existing problems, defects, stresses. Unlikely to survive impact of any project. Comment: Notes; most obvious defects, insects, diseases or unique characteristics. August 16, 2001 Pre-Construction: 2575 Hanover Street, Palo Alto.Page #5 of 31. Ray Morneau, Arborist ~SA Certif. #WC-0132 650,964.7664 4.0 Tree Appraisal Methods Per the City of Pal o Alto Planning Arborist’s requirements, this report develops appraisal data and values for the existing trees on the project. The Council of Tree and Landscape Appraisers Ouid~e (CTLA, 1992,) and methods were followed. The Eighth Edition is current. It is complemented by three companion publications (CTLA, 1986, Manual for Plant Appraisers; I.S.A., 1993, W.orkbook, .Guide. for Plant Appraisal, 8th Edition.; Harris, R.W., 1992, Species Classification and Group Assignment). Each of the 122 trees are listed and calculated individually, one per spreadsheet line. A legend follows the spreadsheet data. The trunk formula method is practicable, fair, and appropriate for most of this site’s trees. The basis for the spreadsheet calculations are the trunk formula worksheets published in the _G_u_i~ (CTLA, 1992, p. 63) and the Workbook (ISA., 1993, pp. 10, 11). The spreadsheet cells contain the formulae as set out to work through those worksheets. My "Line #" headings corresponding to the line numbers of the items on those worksheets. 5.0 Introduction to Tree Protection Measures "’All trees, regardless of where they are growing, are genetically "forest’ trees ....The closer you can keep trees’ environment to that of a forest, the healthier the trees v,411 be." (Marx, 1995, p. 4.) No two trees react the same way to construction stress. Trees which are significantly impacted but appear to-continue to survive, maybe even thrive, are exceptions to the rule. Changes in the below ground environment are the most catastrophic for trees. (Koehler, 1988, p. 3.) Decline and!or death of trees might not become evident until many years later. Some authorities allow as short a time as one to three years (Britton, 1992, p. 10). Many are less specific (Dreistadt, 1994, p. 41; Harris, 1992, p. 467; Schoenweiss, 1982, p. 169). Shigo (1986, p. 553) extends it to ten to twelve years after construction injury. Coate (1983, p.26) notes that it may be fifteen years or more following changes beneath patriarch oaks. Construction projects in the vicinity of existing trees inevitably alter their environments. Some details of a project more or less directly than others. Examples of more directly as cutting the tree back so the project can have the space or severing roots with a trench for utility undergrounding. Less direct alterations, although no less important, include constructing surfaces which absorb heat or reflect heat back as well as umntentional soil compaction by traffic over the root zone. (Shigo, 1986, p. 552; Hams, 1992, p. 163) The more roots which can be left undisturbed, the greater a tree’s chances of survival five or ten years beyond project completion. Most authorities emphasize that the root zones may well be Aug-ust 16, 2001 Pre-Construction: 2575 Hanover Street, Palo Alto.Page #6 of 31. Ray Morneau, Arborist ~~sA Certil~.~wC-0132 650.964.7664 the most important part of our trees on construction sites. The root zones of most trees extend well beyond the spread of the branches, and 80% to90% of their absorbing root systems are in the top 6" to 12" of soil, maybe having some of the larger laterals down to a depth of 3’ (Hagen, 1991, p. 3; Harris; 1992, p. 309; Shigo, 1986, p. 197; Watson, Dec. 1985, p. 39; Willeke, 1992, p. 54). This is in contrast to the standard 6th-grade science book which has shown a 40’ tall tree with a mirror-image, 40’ deep, root system. In reality, root systems are much more pancake-shaped, and we must take this into consideration. Where measures cannot be taken to care for a tree, planning, for its early removal and replacement might be more prudent than needing unanticipated removal after its subsequent demise. In the interest of mitigating the impact of construction stresses to trees to remain after this project’s completion, the following Site-Specific Tree Protection Measures are proposed. These complement any tree-specific recommendations in the Data section (see appendix). As details of the project change or are refined, more individual measures canbe drawn up to address those variations with particularity. 6.0 Site-Specific Tree Protection Measures 2575 Hanover Street, Palo Alto. (corner of California Av.) With the CRy of Palo Alto’s publication of its Planning Arborist’s Tree Technical Manual, June 2001, many tree protection measures have been standardized. That 120+ page document governs tree care in Palo Alto. Salient parts are recapped and/or interpreted below. Pre-Construction FENCE: A tree protection zone is the area around the tree in which no grading or construction activity is to occur (HortScience, 1999, p. 5). Before other phases of the construction project begin, a continuous protective fence must usually be installed surrounding the trees to be saved. An ideal configuration positions the fence to maximize the exclusion of traffic over the root zones, preferably at the drip lines. Where the construction extends under a tree’s canopy, define as much of that root zone as possible with the protective fence. Modification of the fence line to the building eaves lines or project curb lines might be allowable, if other methods are employed to buffer the roots to be saved. Where modification is permitted, driven fence posts will not be acceptable within four feet (4’) of any trunk which has attained a diameter of at least six inches (6"); alternative supports might include pylons or concrete post bases set on grade. Acceptable fence material is 6’ high chain link fencing, framed or rolled, or approved equivalent. Typical fence support options for galvanized-frame fencing could include galvanized fence-frame pedestals or concrete pylons. Driven 2-inch diameter galvanized fence posts placed on 6’ to 10’ centers could be used for rolled fencing, all August 16, 2001 Pre-Construction: 2575 Hanover Street, Palo Alto Page #7 of 31 Ray Morneau, Arborist ~~ Certif. #WC-0132 650.964.7664 posts must be positioned to miss obvious major roots. When near tree trunks, spans are often centered on the tree’s trunk to maintain maximum distance between the posts and the larger roots. The fence shall be continuous with the exception of either a 18, to 24-inch opening or a gate for inspection purposes. A warning sign shall be prominently displayed on each TP fence section at intervals no greater than every 25’. The sign shall be a minimum of 18" square and shall state: "WARNING: This fence shall not be removed or relocated without prior written authorization from the City of Palo Alto Planning Arborist. Violators ,, will be prosecuted and are subject to fine pursuant to {}8.10.110 of the PAMC. 6.1.2 The fence shall remain in place, taut, standing, and continuous, until the final grading sage of the project. _BUFFER: When areas under trees’ foliage canopies cannot be fenced, yet access is necessary on top of their root zones during the project, to avoid extra stress to tree roots, the contractor must notify the Planning Arborist in writing to obtain prior permission. Then one typically installs and maintains a temporary buffer to absorb the load and reduce soil compact!on in the root zones. The buffer shall cover and remain in place Over any traffic area within tree protection zones. Acceptable alternatives usually include: ¯5" wood chips covered with 1/2" plywood sheets, ¯8" of wood chips, ¯6" crushed rock, or ¯1" plywood sheets nailed together. The buffer shall remain in place and be continuously maintained at the above specified thickness until the final grading stage of the project. If wood chips are used, it could ultimately be possible to incorporate them into the site soil as an organic amendment, since they will have begun to break down. Other buffer materials might need to be removed from the site after this time. 6.1.3 MOISTURE in ROOT ZONE: Root zone moisture for these trees is important. Even though seasonal precipitation is about normal, supplemental watering by soaker hose, watering wand, hose bubbler, or hydraulic tree rig could make appropriate ’applications. Quantity of water applied should be l0 to 20 gallons per trunk diameter inch per month. Additional supplemental water applications could be required as the soil becomes dry, as should be determined by periodic root-zone-soils inspections by the Project Arbofist. The contractor shall maintain a written watermg log on site to be presented to the City of Palo Alto Planning Arborist as needed and/or at the close of the project. August 16, 2001 Pre-Construction: 2575 Hanover Street, Palo Alto.Page #8 of 31. Ray Morneau, Arborist ISA Certif. #WC-0132 650.964.7664 6.1.4 6.1.5 6.1.6 6.1.7 6.1.8 6,1.9 PRUNING: Pre-construction trimming is often suggested to reduce requirements of extra care in vicinity of (or risk of damage to) new construction features as well as to improve tree vigor, vitality, and viability. Per ISA and ANSI published pruning standards, "Crown cleaning" as well as "Crown Raising" to accommodate the proposed work may be appropriate. The Project Arborist can provide pruning specifications and shall determine what pruning is necessary and!or allowable. .UT~ITIES, TEMP.: Any temporary construction site utilities (electric, water, communication, etc.) shall be placed so as not to affect foliage crowns or roots of trees to be retained. Infringement on any tree’s space requires Project Arborist consultation. CLEAN-UP AREA: If on-site cleaning of equipment is .required for cement forms and trucks, paint brushes, plastering tools, and such, then a location, must first be specified, posted with a sign, and noticed to all (sub)contractors. This area cannot be situated beneath any tree’s canopy nor in any (proposed) planting area. Runoff from a designated clean-up area can be avoided by providing a temporary base of wood chips or other absorbent material to be disposed of off site at the close of the project. PRE-PLAN: To pre-plan minimizing impact on the trees by factors not addressed above, the following areas need to be identified before construction begins: a. construction traffic: entrance, exit, on-site flow, b. staging sites for construction supplies, services, trailers, etc., c. construction equipment parking, d. construction worker parking, and e. any other potentially problem area (considering frequent use area and/or tree-stress activity). INSPECTION & SIGN-OFF, PRE-CONSTRUCTION: The Project Arborist shall verify that the above sections have been complied with by signing off after inspection (see {}6.2.10 below). PROJECT ARBORIST: The Project Arborist must be qualified arborist (§6.1110) who has sufficient access to reports, drawings/plans, and staff!team contacts such that he has developed a thorough understanding of the project. This requires a long-term relationship with the project in order to avoid the need to periodically re-train new arborists. Any necessary trimming, tree repair, and/or root pruning should be done to published standards under the supervision of the Project Arborist. August 16, 2001 Pre-Constmction: 2575 Hanover Street, Palo Alto.Page #9 of 31. Ray Morneau, Arborist ~~SA Certif.#WC-0132 650.964.7664 6.1 10 ARBORIST, QUAL1~’IED: Locally, a "’qualified arbofist" is either a Certified Arborist (by International Society of Arboriculture), or a member of the California Arborists’ Association, or a member of the American Society of Consulting Arborists. Of course the presumption stands that to be "qualified" any chosen arborist would have appropriate experience with comparable projects performing similar duties. 6.1.11 STANDARDS: 1. 2. U.S.A~ "published standards" include: Tree Pruning Guidelines (ISA, 1995), American National Standard for Tree Care Operations -- Tree, Shrub, and Oth. er Woody Plant Maintenanc~ -- Standard Practices (a.k.a.: ANSI A300-1995) (ANSI, 1995), and American National Standard for Tree Care Operations -- Pruning, Trimming, Repairing, Maintaining, and Removing Trees, and Cutting Brush -- Safety Requirements (a.k.a.: ANSI Z!33.1-1994) (ANSI, 1994). Workers may be unfamiliar with these standards, and the concepts contained there, or unwilling to abide by them. By de~nition, this would be sub-standard tree work and would put your trees at risk for untimely decline and death. Such workers must not be allowed to practice in the vicinity of trees important enough to be retained. During Construction: PRE-REQUIREMENTS: Applicable reqmrements from ’°Pre-Construction" Section above shall have been implemented and remain in place. 6.2.2 DEMOLITION: To preserve the important absorbing roots of trees to remain after constructmn, no unexpected cuts or fills should be al!owed beneath their canopies. The method for site preparation, of scraping the surface soil with a blade must not be allowed within the drip lines. Hand grubbing with a pick-mattocks can be sufficiently effective while saving tree roots. During any demolition stage of this project, care must be taken when portions of a discontinued utility system are near any tree to be retained, including, but not limited to, systems for irrigation, gas, electric, water. Rather than disturbing the root system, consider stubbing offthe pipe at the tree’s drip line and leaving it in place in the soil. Here, demolition requires the razing and hauling of existing hardscape. Equipment operators must remain aware of nearby trees to be preserved and avoid contacting them or their roots. As with other excavations, if/when exposed, roots should be protected from desiccation (see 1tern §6.2.6, below). Stump .removal can be a sensitive issue where a stump’s roots overlap with root systems from adjacent trees. Such stumps must not be extracted with tractors, bulldozers, or August 16, 2001 Pre-Construction: 2575 Hanover Street, Palo Alto.Page #10 of 31. ¯ Ray Morneau, Arborist ~~s~ Certif. #WC-0132 650 .9641766~ such power equipment lest intertwined roots tear up other roots tO be retained. One option is to grind up the stump in place. 6.2.3 TRENCHING: Intrusion beneath any tree’s canopy must be minimized for all trenches, including; electric, sewer, water, gas, decorative/security lighting, or irrigation. Where practicable (and approved), use common trenches for multiple utilities. Trenches must be routed to sever only a minimum of tree roots. Positioning trenches in driveways is often least intrusive. Trench plans within any existing dripline must be reviewed and approved by the Project Arborist before being implemented. 6,2.4 TUNNELING: Tunneling under roots is preferable to severing, especially for larger roots. Note "§6.2.5 Excavation", below. 6.2.5 EXCAVATION: Manual excavation and pruning methods will be used when encountering roots with a diameter exceeding 1.5" to avoid the extensive damage which heavy equipment does to roots. Roots which must be severed and measure over one and one-half inches (I .5") in diameter should be cut cleanly, smoothly without crushing, shattering, or tearing. If roughly cut by heavy equipment, re-cut to sound wood. Cuts should be made to lateral roots where possible. Cut & Fill Note: Avoid setting up a tractor, or other digging equipment~ on soil to remain undisturbed, uncompacted. Similarly, sideways sheering of roots shatters many of them back into tissue hoped to be saved. Alternatively, situate the tractor in the (to be) disturbed area and pull soil to be removed away from the tree. Another option could be to initially sever the roots at the line to be cut by using a stump grinder or root pruning wheel. Note "’ §6.2.6 Exposed Roots", below. 6.2.6 EXPOSED ROOTS: Curtail drying out of small roots. Within two hours of cut or opening, cover all exposed cuts in soil containing both root hairs and newly severed or exposed roots. To retain moisture, dampened wood chip mulch (4" deep), moist soil (3"), or wetted burlap (4 layers) placed against freshly cut and exposed soil are some choices; all must remain moist. When more than 10% of a tree’s absorbing root system is exposed or otherwise.stressed (as here for oak # 1), the application of an organic bio-stimulant, comparable to Roots’~, can reduce shock. Remedial Care must be assessed and prescribed by the Project Arborist during his (weekly) inspections. Such treatment might include, but not be limited to, aeration, soil amendment, mycorrhizal inoculation, and/or irrigation. 6.2.7 POWER EQU-DMENT: Equipment operators should be informed that machinery can cause great injury to standing trees. They must take unique care to operate with as August 16, 2001 Pre-Construction: 2575 Hanover Street, Polo Alto.Page#ll of 31. Ray Morneau, Arborizt ISA Certif, #WC-0132 650.964.7664 6.2.8 much distance as possible between machines and trees -, branches, trunks, and roots. Any accidental damage must be promptly repaired by a qualified arborist. CI-{EMICALS: No storage, pouring, or leaking of any fuel, oil, or chemical may be allowed beneath a tree’s canopy. Time is of the essence in the event of any size spill; prompt containment and proper clean-up is necessary. U__SE: No signs, wires, or other construction apparatus may be attached to any tree. INSPECTIONS & SIGN-OFFS: The Project Arborist shall be retained on-call to clarify tree issues and answer questions. The Arborist shall confirm project compliance with tree protection measures, including protection fencing, demolition, any root cutting or exposure, trenching or grading in root zones, and follow-up. Otherwise, the Project Arborist will verify observance of tree protection with weekly site inspections summarized in a monthly status report. - Follow-up: MONITOR for H~EALTH & VIGOR: These trees should be inspected upon project completion as well as at appropriate intervals to note changes and developing situations which could require action: foliage crown density, weight distribution, and/or breakage; pests; diseases; cables and supports; root zone moisture and oxygen; et alii. 6.3.2 MONITOR MOISTL!RE in ROOT ZONE: In conjunction with {}6.3.1, above, if the root zone soil is not moist at a depth of 6" below existing grade, then consider an application of supplemental watering similar to {}6.1.3, above. Irrigation water should never be applied in a way which allows it to wetthe base of any tree’s trunk at the soil line. Adjust any sprinkler head, bubbler, or hose to keep water at least 3’ from the base of trees. 6.3.3 6.3.4 6.3.5 FERTILIZER: Upon inspection, after new growth has been put out by the Fees following the close of the project, the qualified arborist inspecting can assess the advisability of making an application of fertilizer. ]’,rE.W. PLANTINGS: No planting or other intrusion shall be installed within 10 feet of the trunks of this site’s mature oak trees or within 5 feet of other species’ mature trunks. No litigation water should fall within 3 feet of mature-root flares. NEW OWNER: .The extent of care taken to minimize impact to these trees should be brought to the attention of any new .owner/tenant early in any negotiation process. August 16, 2001 Pre-Construction: 2575 Hanover Street, Palo Alto.Page #12 of 31. Ray Morneau, Arborist ~s~ Certif.#WC-0132 650.964.7664 7.0 Appendices 7.1 Assumptions and Limiting Conditions 7.1.1 The scope of this assignment includes no plant material other than the trees on this site. And, concerning these trees, any inspection was limited only to the cursory examination necessary to obtain the data for the pre-construction tree inventory. No climbing inspection, root crowri excavation/examination, tissue testing, soil samp~ling/evaluation, nor drilling-type testing was performed at this time. 7,1.2 This report is specific to this Unique site, these individual trees, and this particular situation. Although some of the principles herein discussed might appear to be applicable to another site, tree, or situation, it is not possible to effectively carry any of these ideas across to a different scenario. Uncategorically, further investigation of the different scene is required. 7.1.3 Due to the fact that trees are living organisms, the individual variability of each specimen in each situation renders guarantees and/or warranties for my services impracticable. However, following the codes of ethics endorsed by my peers and the professional organizations to which I belong, I offer my opinions relying on my best professional judgment and suggesting best management practices for my clients’ trees. 7.1.4 This report is not uwitten, offered, orintended as a legal opinion. Any and all references to ordinances, statutes, laws, legal words of art, and the province of jurisprudence are secondary to this work. Unequivocally, ’before they are to be interpreted or applied, any issues of law which might thus be mentioned herein must be researched and addressed by appropriate legal . counsel. 7.1.5 If the circumstances surrounding this situation turn to a legal forum, then this report’s consultant-author could be brought into legal testimony or court appearances only with a new assignment covered by additional consultant fees. 7.1.6 Alteration of this report, intentionally or unintentionally, voids the entire report. 7.1.7 Sketches, photographs, and any other graphics used in this report are intended solely as visual aids. Every attempt is made to limit distortions and to provide graphics realistic enough for the purposes of this report. Nevertheless, if engineering-accuracy is important to any user of this report, then other professionals must be retained to provide that level of detail. For instance, it may be necessary to survey actual tree trunk locations in order to be able to critically assess the specific impacts of construction activity in the vicinity of trees near proposed buildings, trenches, sidewalks, streets/curbs, and such. August 16, 2001 Pre-Construction: 2575 Hanover Street, Palo Alto.Page #13 of 31. Ray Morneau, Arborist ~sA certif. #wc-0132 650.964.7664 7.2 Literature & Authorities ANSI. t 995. A~nerican National Sta~dard for Tree Care Operations -- Tree, Shrub, ~w~d Other I4~oo~, Plant Maintenance - Stcmdard Practices (a.k.a.: ANSI A300-]995) American National Standards Institute, 11 West 42nd Street, New York, NY 10036. ANSI. 1994. American National Stc~dard for Tree Care Operations -- Pruning, Trimming, Repairing, Maintaining, a~d Rernoving Trees, artd Cutting Brush -- Safe~yl~equirements (a.k.a.: ANSI Z133.1-1994) Am. Nat’l Standards Inst., l I West 42rid Street, NY, NY 10036. Bfitton, Deniee F. and Gone P. Snyder. December, 1992. "Construction Damage: Correction Begins With Prevention." Arbor Age. 68-8960 Perez Road, Suite J, Cathedral City, CA 92234. CTLA. ! 992. Guide for Plant Appraisal (Sth. ed.) Prepared under contrac| by The Council of Tree and Landscape Appraisers Published by l.ntemafional Society ofArboriculture, P.O. Box G-G, Savoy, IL 61874-9902 CTLA. 1986. Manual for Plant Appraisers. Council of Tree and Landscape Appraisers, 1250 I Street, NW, Suite 504, Washington, DC 20005. Dookter, Dave¯ 2001. City of Polo Alto Tree TechnicaIManual - Standards and Specifications. City of Palo Alto, Department of Plarming and Community Development, 250 Hamilton Avenue, Polo Alto, CA 94301 650.329.2441 Hagen, Bruce W., Barrio D. Coale, and Keith Oldham. 1991. Compatible Plants Under andAround Oaks. California Oak Foundation, 909 Twelfth Street° Suite ]25, Sacramento, CA 95814. Houris, P,_.W. with’James R. Clark and Nelda P. Matheny. 1999. Arboriculture’: integrated management of landscape trees, shrubs and vJ’~es. (3rd. ed.) Prentice-Hall, Inc. Upper Saddle River, NJ 07458. Harris, R.W. 1992. Arboriculture: integrated management of landscape trees, shrubs and vines. (2rid. ed.) Prentice-Hall, Inc. Englewood Cliffs, NJ 07632. Harris, R.W. (Convener of the Northern California Regional Tree Appraisal Group) 1992. Species Classification and Group Assignment. International Society of Arborieulture, Western Chapter, P.O. Box 255155, Sacramento, CA 95865. lqortseienee. 1999. Trees and Development (Seminar Handout Notes). ISA Regiona Meeting, January 15, 1999, Santa Rosa, California. ©I-Iortscieeee, Inc. POB 754, Pleesanton, CA 94566 (Seminar presenters: Nelda Matheny and Jim Clark) 925.484.0211 I.S.A. 1995. Tree-Pruning Cruidelines. Intemation~ Society of Arborieulture, P.O. Box GG, Savoy, IL 61874-9902. I.S.A. 1993. Workbook. Guide for Plant Appraisal, 8th Edition. International Society of Arborieulture, P.O. Box C-G, Savoy, 1I, 61874-9902 Keehler, C. S., and R. H. Hunt, D. Freehlich, and J. Geiger. 1988. Protecting Trees when BuiMing on Forested Land. Leaflet #21348. Cooperative Extension, University of California, Division of Agriculture and Natural Resources, Berkeley, CA 94720. Marx, Donald. May, ] 995. "Roots and Myoorrhizae." Tree Care lndustry, National Arborist Association, P.O. Box 1094, Amherst, NJ 03031-1094. Matheny, Nelda and James R. Clark. 1998. Trees cotd Developmenl: a Technical Guide to Preservation of Trees During Land Development. Inlernation~l Societ~ of Arborieulture, P. O. Box 3129, Champaign, IL 61826-3129. McMinn, Howard E., and Evelyn Maino. 1974. An lllustratedManual of Pacific Coast Trees. (2rid. Edition) University of California Press, Berkeley, CA 94720. Sehoenweiss, Donald F. July, J982. "Prevention and Treatment of Construction Damage to Shade Trees." ~lourna! of Arboriculture. Volume 8; Number 7. International Society of Arborieultur~, P.O. Box GO, Savoy, 1I, 61874-9902. Shigo, Alex Lloyd. 1986. A New Tree Biology: Facts, Ahotos, and.Philosophies on trees and their problems and proper care. Shigo and Trees, Associates, Durham, Nt-! 03824. Sunset. 1995. Sunset gZestern Garden Book. Sunset Publishing Company, Menlo Park, CA 94025. U.S.D.A. 1949. Trees: The Yearbook of Agriculture, ~94~. Superintendent of Documents, U S Gov’t Printing Ollqee, Washington, DC 20025. Willeke, Donald C. April, 1992. "What Every Builder Should Know." Western Chapter News. Volume 18; Number 4. International Sooiety of Arboriculture, Western Chapter, P.O. Box 255155, Sacramento, CA 95865. 7.3 Inventory Data (printed to next 13 pages) .. August ! 6, 2001 Pro-Construction: 2575 Hanover Street, Polo Alto.Page #14 of 31. Ray Morneau, Arborist ~~sA Certif.#Wc-0132 650.964.7664 iCommon Name meterl ~iCondition Preservation iComment iOak~ Holl .y, Fair All branches originating at about the 6’ height; growing In curbside 4’ planter strip. Ash Moraine i i i ~Fair iAII branches originating at about the 6’ height; growing 3’ from sidewalk extensive surface roots....... !..n...!u.d....d.eca~." at .o..!d....p..r.,.u..n.!.n..g.,..w..£..u.,n...d.s......e...~.e...n.s!ye e.p.icormics.. .................................................. iAsh Moraine Poor All branches originating at about the 6’ height; surface roots in turf; extensive tip dieback. ...................... i~~~ i"i~~:~J~ ~ .........................................i i i ................i ......................[ ......................i ..................i Poor! .................................."i iAI branches originating at about the 6’ height; tip dieback; severe decline.~. ..-q-ip dieback; severe decline extensive surface roots. 6 ~Fraxinus ’Moraine’20.3 35’i 35’Dom. i 30%35%32%Very Low Ash Moraine ¯~~Poor IAII branches originating at about the 6’ height; tip dieback; sunscald (with decay behind)... ..........7. ..........iF...r_~!..n...u...s...i ,M.o.[.a.!..n..e.i ............................14.3 20, 30, Dora. 10% 20% 15% ...........V...e..~....L..o...w. ......... iAsh Moraine VeX Poor Rip dieback; sunscald (with decay behind).. i 8 iFraxinus ’Moraine’16.3 15’ 25’ Dom. i 10% i 20%15%i ....V..e..~..,.L..o...w. ........ iExtensive dieback; sunscald (with decay beneath it).i " ~9 Fraxlnus Moraine ~19.7 35 ~ 37 ~ Dom. ~ 10~ ~ 20% ~ 15Yo .:VeryLow iAsh Moraine -i }i Ve~ Poor iExtensive dieback; major deadwood to 8" diameter. !.s. . . .w. . . . .e. . .e. . ! ! u. . . .m. . . ................................................. i ................................... i ................ ~ .................................................................. i .......... .P. . . .o. . .o. . . r. . .....................................................iMajor deadwood; declining; extensive surface roots with decay; misshapen; embedded bark .... ..c..~.?.!..c.,.h....a..L£:..~..b....°.,.v..e...t.r.~..u.n...d.... ................................................................................................................................................................................................... August ]6, 2001 Pre-Construction: 2575 Hanover Street, Palo Alto.Page #15 of 3] Ray Morneau, Arborist~~IS~ ~ertif.#W~-0132 650.964.7664 iComment ~...w....e...e.!.!,.u..~ ............................................. i ....................... i .............................................................................. ! ............................ ..P..o...o..~ ..................................................... iMajor deadwood; declining; -7’ diameter root plate; embedded bark crotches at 5’. iMajor deadwood; poor structure; extensive root plate; breakage of secondary trunk at 3’ with deca.y, staring cavity. iDieback; declining; thin foliage crown; extensive root plate (scraped, with decay). iDieback; poor structure; embedded bark crotches; extensive root plate with scrapes/decay; LH....o..r...s...e....c...h...e....s..t....n...u...t.,.....R....e...d.. ...................... ! .................................................... ! ...................... t ......................................... ~ .......... ..F..,.a.!.r. ...................................................... :.:AI branches originating at about the 5’ height; extensive surface roots in turf. i ...................... i ...................... i .................. i Good i .......................................... iMinor deadwood accumulated; endweights. 17 iCedrus deodara i 18.6 40’ L...7...o.L...t.C..0...d.£..m.:.!.....5...5..°/,?. ..........6...6.~./.~ ....60% ..........M...o..d...e..r,.a...!..e. ........i ¯ hin foliage crown; surface roots. !Magnolia Southern i ! _ .. . ..F....a.![ . i~15’ diameter root plate; extensive decay; thin foliage crown. iFern P ne ................i ......................i ......................i ..................i Fair iFive stems averaging 5" diameter. i’"’"ii’ii........i~i"~’ii’~’"~i’£i’iii’ii .........................................i’"~’£’5 .........~’~’""i""Yii’"’iii’&i’~’ii"i’""~£’~’"’"i’"5"i;g"[ .........5Y’~)i .........’ ........9"~"i"ii~ ........ i.P...!..n...e..,...~..o....n..!.~r...e..~. ...................................i ....................................................i ......................i ......................................................P...?...o...r. ................................................... iCrowded; lop-sided; declining; thin foliage crown; extensive surface roots; fresh Red Turpentine !.......B...e.,.e..!.Le....P..!.t..c..h....t..u...b..~..s....a..L~..a..s...e..: ................................................................................................................................................................................................ August 16, 200]Pre-Construct~on: 2575 Hanover Street, Palo Alto.Page #16 of 31. Ray Morneau, Arborist ~ISA Certif. #WC-0132 650.964.7664 iCommon Name i meter i Condition Preservation i !Comment iCrowded; lop-sided; declining, thinning foliage crown; trunk lean 25" to east; fresh Red ..... ..................................................................................................................................................................................... iOrowded; lop-sided; declining, thinning foliage crown; trunk lean 20° to south; fresh Red - !Pine Monterey. ~ Poor !Crowded; lop-sided; declining; moderate deadwood; no Red Turpentine Beetle evidence (yet!). i.P...!..n..e..l...M....°..n..!..e.r.ey.. ................................ i .................................. i ............ i ............. t ......... ..V.e. ~...P .°..°.r i ......... : ................... iCrowded; lop-sided; declining; moderate deadwood; fresh Red Turpentine Beetle pitch tubes. iPine Monterey. Ve~ Poor ’ iCrowded; lop-sided; minor deadwood; fresh Red Turpentine Beetle pitch tubes at base. - 26 I}PinuS radiata 12.2 15’ 55’ Interm. 25% ! 25% i 25% i Ve~ Low !Crowded; lop-sided; minor deadwood; trunk lean 20° to northeast; fresh Red Turpentine Beetle tPine Monterey. ~ i i Ve~ Poor iCrowded; lop-sided; moderate deadwoodto 3" diameter; fresh Red Turpentine Beetle Sites. iPine Monterey. " i i i i Ve~ Poor Crowded; lop-sided; major deadwood to 3"; fresh Red Turpentine Beetle sites. ~Sweet!i!um } Poor iDieback; poor structure; embedded bark crotches; scraped root plate. iSweet~um i i i Poor iDieback; poor structure; endweights. August 16, 2001 Pre-Construction: 2575 Hanover Street, Palo Alto.Page #17 of 31. Ray Morneau, Arborist ~zs~ Certif.#WC-0132 650.964.7664 iCommon Name i meter~~Condition Preservation ~Comment iRiver Red Gum Fair !River Red Gum Good iReasonable structure for a eucalyptus; typical twisted grain. iRiver Red Gum Good~d~;:;~.~i~ii~i~;..;1~i~;j~i~fii~i~fi~[5~.fi5fi~.~‘~ ..........................................................................: .............................................................. iSweet~.um ~ . i Poor }Crowded; lop-sided; trunk lean 15° to south; dieback; declining; decay ~n cavity at 1’ level. -Sweet~.um PoorbT~i~~a~i~i;~iifi~i~~~;~i~~i~ ’: ....................................................................................................................................................................................... !Bottlebrush ~ Fair ¯ ;Four stems averaging 6" diameter. iBottlebrush Poor ,:q-wo s~ems averaging 7" diameter. I I (]0 0~15~........i#i~~;B~iS~;i;;~~ ........"" .............~6T~~i:~~ig[J~i~?;TSg~i~g~2;~ .........~g~; ...............’~;~~i;?~ .............................. ~ ..............................................................................i ~ ................; ....................;. ......................~ ..................;. ..........................................Lc....h.le..r.~:!...a...u..r...eJ .............................................. : .............. i ............... i .................... : .................. t ......................................... i.....v...e..~....P....°...?.,r. ........................................... IF ve stems averaging 3" diameter; poor vascular system. 39 iCedrus atlantica 24.0 i 30’ 50’ Dora. i 0% 0%0%N/A i..C..~.d.~r.:,.,,A...t.!,~.s. ...............................................................~ .......................................................~ .............................................:....O...e.,a...d. .................................................... iDEAD long before commencement of project. iCrowded; lop-sided by building; typical Hollywood Juniper attitude. August 16, 2001 Pre-Construction: 2575 Hanover Street, Palo Alto.Page #18 of 31. iHawthorn; En.g.lish Fair - iHas been nicely pruned and maintained -- not the tangle typical of E. Hawthorns. iB rch Europ.,ean White i ! Fair iTypically lanky; low vigor. IB rch EuroEean White i ]i Fair . . ~Typically lanky; low vigor. .........4..,4.. ........i.P...!,n...u..~..~!..g...r.a. ..............................................25.6 33’ 45’i Dom. 69% 50% 60%Moderate Pine Austrian Black ’.:Fair -! iMeasured at 12" height due to codominant trunks. ~Birch, Euro.p..ean White Dead !Dead before commencement of project; two codominant trunks at 4’. !Dead before commencement of project. iMaidenhair Tree Fair iDeclining. 48 iGink£~o biloba 1.0 2’6’Dom.70%66%68%Moderate iMaidenhair Tree Fair - i. ’ ....................................... i .......................................... Poor ............................................ ..’Very stressed-looking foliage crown. August 16, 2001 Pre-Constmction: 2575 HanoVer Street, Palo Alto.Page #19 of 3 I. Ray Morneau, Arborist ~~SA C~rtff.#WC-O13Z 650.904.7004 iCommon Name meteri ~i Condition Preservation ~Comment 51 iGink.g.,o biloba 1.0 2’ 7’ Dom. == 66% 66% i 66%Moderate !.M....a..!,.d..~..n..,.h..~.!.r....T...r...e...e,. ............................................................................................................~ ......................................................F....a..!r. ..................................................... {Maidenhair Tree Poor !Stressed-looking foliage. 53 !Ginkgo biloba .............................................................................................................................. iMa denhair Tree Fair iMaidenhair Tree =Fair.............................................................................. ~.......: ...........................~ .............................................................................................................................................................. iPotential structural problems -- large basal suckerlsprout and temporary branches on lower !......!.r..q.,,n...k.....h...a.v...e....b...e,.e.. n..,.~!.Lo..w..e.,g...f,9...a...t.t.a..!.,n.... ,s...u.,.b,..s.La, n,.t.!a,.L .s.!.z...e...,..ar~,.d....).m.p...o...rt .a..~..c..e.!.p..r.,.o..~!..n..,.e...n.,.c.~.: ................................................ .56 iGinkgo biloba ~ 2.4 5’8’ i Dom.66%66%66%Moderate iMaidenhair Tree ~Fair 57 iGinkgo biloba ~ .............................................................÷ ..................~ ..........................................~vlaidenhair Tree ~Fair ..P....o..?.r. .................................................... iFour stems averaging 6" diameter declining foliage crown with extensive twiggy deadwood. 60 iPnus radiata i 25.2 i 45’ 70’ iCodom.i 45% 40% 42% Ve~ Low i .................................................... iDec n ng; moderate deadwood; Ips beetles in foliage crown. August 16, 2001 " Pre-Construction: 2575 Hanover Street, Palo Alto.Page #20 of 31. ’ Ray Morneau, Arborist ~~sA Certif.#WC-O132 650.964.7664 iCommon Name i meteri ~Condition ~ Preservation !Comment iDeclining; moderate deadwood; Ips beetles in foliage crown. iMajor deadwood; Ips beetles in foliage crown. .......................iPine Monterey. i ~ i Poor i ........................................... iMajor deadwood; Ips beetles in foliage crown. iCrowded; lop-sided; em bedded bark crotch at 6’; oozing from Sweetgum canker. ~Sweetgum Poor iCrowded; lop-sided; major deadwood M mosa Silk Tree i Fair iTh tee codominant trunks at 6’. Silk Tree PooriM mosa } iDeclining; three codominant trunks at 6’; root.scrapes. iBottlebrush = Poor 69 ~Callistemon citrinus [ 15.0 23’25’Suppr.66%40%48%Low ~ iBotflebrush Poor ~ iFour stems averaging 6" diameter.~ : ..................................................................................Poori..R.!z.e.r....R...e...d.....G....u..~ ..................................., ...................................~ ................t .............~ ........i ......................! ..................i ................................! ...........................................iEmbedded bark crotches (three in lower 6’) (producing codominant stems prone to breakage). August 16, 2001 Pre-Constmction: 2575 Hanover Street, Palo Alto.Page #21 of 31. ~Young; with typical lankiness. Crowded; lop-sided; declining; trunk leans 30° to northeast. iGood pruning! (Not tangled as would be typical for E. Hawthorns.) .........7,..4.. ........!,.P...!,,n...u..s.....r..a.,.d..!.a...t.a.. ..........................................17.0 32’ 70’ i lnterm. 33%l ~30% 31% ........V..e..~...L...o...w.. ......... i.P...!~.~....,.M.. ,°...n.!..e..r..e.z ......................................................................................i ...............................i .......................P...o.o.r. ................................................. iMajor deadwood; declining; thinning foliage crown iOlive Common i !Fair iMajor deadwood; double leader: ~,~!.t.!..o.~...o..r.~...r,. ............................................~ ...................................i22.:i:21:iii1211111:iiiii121:2:1:i::::!12112111111; ............~,~.!~ ............11:11112111111111:11211111121! Augus~ 16, 2001 Pre-Construction: 2575 Hanover Street, Palo Alto.Page #22 of 31. Ray Morneau, ArborJst ~~SA Certif.#WC-O132 650.964.7664 iOommon Name meteri Condition i Preservationi ........................................................................................:..v....,~ ................................~ ......................L..o~ .....................................................................; ]Comment broken stump. p...!t.!..q,.s.p..o..r...u..~. ........................................................ : ....................... i,..: ............ ~ ............................................................................ ..F.,.a,.!r, ...................................................... iThree stems averaging 5" diameter. ........8...3. ........i.P...!t.!..o...s.p..o..r...u..,m..,t,..e,,.n,,u],f.o..[]a., .................i n/a n/a n/a n/a n/a n/a n/a ....................n.,!..a. ................. iPittos.p.orum i n/a !Old, broken stump.~ i..C..£.t.0..n.. ,e...a...s.!,.e..r....~..a,[..n...e..Y....s. ..................................................................... i ................. i .......... t .......... e~. P..o..o. r ~ .........................iTwo stems averaging 3" diameter; crooked, leaning trunk. iRoot flare defect; decay at old pruning wounds, iEIm, Chinese ~ : Poor !Two stems from ground level (5.5", 8.5"); declining, thinning foliage crown. ~Plum Common i i Ve~ Poor ¯ .q-wo stems from ground level (4.8", 7.9"); crowded; lop-sided; severely declining, thinning foliage ...... ,,c..r...o..w...n.....b..o.th ..s..t..e..m..s....v..e...~....§.p.!..a..y.#..d......o..u..t...a.!...a...n....e..xt..i.e.m..e..!y.....wide .a..ngle.: .............................................................. ~E...u..~...,..c,.,o,. ,m,, ,rn,°,.n. ................................. i .................................................... i .............. i ............... !...y..~...ry. P...q,.o.r. .......................................!Crowded; lop-sided; trunk leans 50° to north. i.0....a..k..,.....C...°....a...s.!...L..Lv...e.. ....................................................................................................................................i ..................~ ........~..?...o..~ .................................................... !Codominant trunks at 20’ above ground. 90 iPrunus sp.,ecies 8.0 25’ i 15’ i Su~pr 15% 10%12%Very Low iP..~...m......~..qrn.,,rn°,n. ...................................................................i .....................................................,..v. ,e...rz .P.p..p,r...:~ ............................... iTwo stems from ground level (5.2", 5.4"); crowded; lop-sided; misshapen; severely declining, L...~..o.!.h.,..~.Le...m....s.....v.e..~...s..P.!.~ .y..e.~....o.~L.~L.~n..~.~..e..,,.m..~..!)L..w..!..d. ,o...~.~!.e.: ................................................................................................................ August 16, 200]Pre-Construction: 2575 Hanover Street; Palo Alto.Page #23 of 31. Ray Morneau, Arborist ~sA Certif.#WC-0132 650.964.7664 ................................... .......................i~’~’~’~;’~’"~’~; ................................[meteri .......................................; ......................; ..................i Condition Preservation !Comment ~P um Common ~ ..................................................................................n/a fold, broken stump. iCoffeeber~ i i Poor . iBranches to multi-stemmed specimen at ’ above ground. 93 ~Ligustrum lucidum 11.2 15’18’Dom. i 25%25% i 25%YelLow ~Privet Jap..anese i Ve~ Poor iBranches to multi-stemmed specimen at ’. above ground, as typical for species; declining. 94.1 Acacia melanoxy..Ion 10.0 20’27’Dom. 80% 66%72%Moderate Good~Acacia Blackwood ’ iDense. " Crabap.p.le i i i ~ i Ve~ Poor iFour stems averaging 4" diameter; severely declining; internal decay; termite galleries noted. ..P....o...o.,r. .................................................... iExtensive major deadwood Ips beetles in branch wood branches low to three trunks at 3’. P ne Monterey i ’ i ! Ve..r.y. Poor iExtensive major deadwood Ips beetles in branch wood branches low at 2’. ..’Thinning foliage canopy; lerp psyllid. 99 ~Eucaly..p_tus camaldulensis 122.4 25’175’ !Codom. 40% 40%40%Low iRiver Red Gum :~Poor iThinning foliage canopy; extensive lerp psylid. August 16, 2001 Pre-Construction: 2575 Hanover Street, Pale Alto.Page #24 of 31. iRiver Red Gum Poor .:.,Thinning foliage canopy; extensive lerp psyllid. iRiver Red Gur~ ! ~ Poor ~Measured at 4’ due to branching to two codominant trunks at 4’ iRiver Red Gum Poor iPreviously topped; lanky regrowth; endweights. iRiver Red Gum ~i n/a : iBroken 10-foot-tall stump; formerly topped there (with decayed stub). 104 iEucaly..p.,tus camaldulensis =:17.0 18’ i 80’ Interm. 35% i 35%35%Low " iRiver Red Gum ~~:=Poor :....Very thin foliage crown; psyllid pressure. iEucal .y.p.t l???)i ,i Fair iEucal .y.p..t (777)Fair ~Measured at 1’ due to codominant trunks at 2’. ......!...o..,7........iE...u...c..a..!y.p..t..u...s...,s.p..e.,.c,!.e...s. .......................13.7 30’ 50’ iCodom. 45% 45% 45% ................L.,.o.w.. ..................................................... i ...................................i2ZZIZZZZiZZZZI{:IZZZ ..........Lo.o.s ..................................................... iMajor deadwood; central leader dead as if frost damage, plus sunscald, with decay. iRiver Red Gum Poor :--Thin foliage crown; psyllid pressure. ...... ‘1~.~...g..~i..E..‘u...c.‘‘.a.~!.y‘p.~!..u‘..s.~...c~...~..m..a.#.d...u.~..e.~.s.!~.s. ......19.4 i 30’ 50’ Dora.10%10%i 10% Ve Low iRiver Red Gum i i Ve~ Poor iMeasured at 1’ due to codominant trunks at 2’; very thin foliage canopy with psyllid pressure. August 16, 200]Pre-Construction: 2575 Hanover Street, Palo Alto.Page #25 of 31. Ray Morneau, Arborist ~zs~ ~. ~c-o~~so.~.7~ iCommon Name ~meteri ~~i Condition Preservation }Comment 110 iEucal.y,.p.,tus camaldulensis 15.8 40’ 30’ Dora. 25% 25% ~ 25% ! Very Low ~Olive, Common ¯ i ................ ! ............................................. i ................... Fair i ..................... i ................... iN ne trunks from ground leve( averaging 3" diameter. iOlive Common i Fair iFour trunks from ground level averaging 6" diameter..- ~!.!.v...e..,.....o....m..~..o...q ................................... i .................................................... t ................................................................ i ........... ..F...a..!r. .......... ~ ........................................... iEight trunks from ground level averaging 4" diameter. ~.s.,.w.,.e.e.f.g...u..m.. .......................................................................................................... : ...................................................................... F,.,a.!,r.: .................................................... iMeasured at 4’ due to branching at 4.5’ to codominant trunks. 115 iCedrus deodara 11.8 28’ i 40’ Dom. 55% i 50% i 52% i Moderate ...................... !~~i~’~i ~~ta~i: .....................................i .............................................................! ..................~ Fair i ......................................... !Lop-sided (a bit). i,.C....a..~p....h...o..r. ..............................................................................................................................................................................P.,..o...o..r. ...................... iCrowded; lop-sided; f~runk arches/sweeps to east over parking/driveway: iCam.p..hor i ~i !!i Fa r, iCrowded; lop-sided. iLanky. : iFern Pine ~" ’i ! Fair Moderate deadwood; endweights. August 16, 2001 Pre~Construction: 2575 Hanover Street, Palo Alto.Page #26 of 31. iFern Pine i i Ve~ Poor ¯ :.As typical for this species, has sometimes been sheared as a shrub. .......................[15i[~’~i~’~ ~~~;~’ ................................... i i ................ i ................................................................ VeT Poor i ............... ’ ....... iMeasured at 2.5’ due to branching to five codominat stems at 3.5’; major deadwood; severely ...... ~.~!)..n..,!.n...g....(.~ S..p~..e..c~.a.~x~.~.s..~.e..v~d.~.e..~.n.~.d..~..b..y....f.~L~~) ...................................................................................................................... August 16, 200]Pre-Constmction: 2575 Hanover Street, Palo Alto.Page #27 of 31. ATTACHMENT C 2475 HANOVER STREET [Files: 01’ARB:100, 01-EIA-15) Responses to Comments on Revised Mitigated Negative Declaration February 14 through February 19, 2002 1.Letter from Dorothy Bender. dated February 13, 2002 2.Letter from Dorothy Bender dated February 14, 2002 3.Letter from John Abraham dated February 12, 2002 4.Letters from Paul Collacchi dated February 9 and February 14, 2002 5.Letter from Joy Ogawa dated February 18, 2002 6..Letter (e-mail) from John Baca dated February 19, 2002 7.Letter (e-mail) from Aseem Das dated February 15, 2002 8.Letter from Toni Stein dated February 19, 2002 . 9.Letter from William T. Phillips dated February 15, 2002 10. Letter (e-mail) from Derek Whitworth dated February 15, 2002 To: Honorable Palo Alto City Council From: Dorothy Bender Letter 1 : Dorothy Bender CITY OF [~A[.O ALTO, CA CiTY OL.t-RK’S OFFICE Date: February 13, 2002 Subject: 2475 Hanover Street - Groundwater and Soil Contamination Drl Antoinette Stein reviewed the following three reports concerning the 2475 Hanover Street Project: ~Lowney.Associates Soil and Ground Water Quality Evaluation, January 23,2001 ~Aquifer Sciences, Inc September 12, 2001 ~Aquifer Sciences, Inc. January 24, 2002 and offers the attached comments and observations. Installation of Wells and Remediation System, Monitoring Report for Fourth Quarter, Dr. Stein has the following qualifications: ¯ Ph.D in Environmental Engineering in Air Quality Control ¯Hearing Board Member of the Bay Area Air Quality Management District’s Hearing Board ¯Planning Commissioner, City of Menlo Park ¯Voting Member of the San Mateo County Solid Waste Advisory Commission ¯ Voting Member of the San Mateo County Congestion Management and Air Quality Committee ¯ Materials and Process Engineer at General Electric - X-ray tube and Air Craft Engineering Divisions (7 years) Memorandum from Dr. Antoinette Stein, dated February 13, 2002 The Hanover Street project is situated on a site that has been undergoing remediation for both groundwater and s0il contamination. Remediation is not yet complete and is ongoing until concentration goals are met. Data to date shows that the concentrations in groundwater have not yet been met. 7 In the historical description of the site, there is no mention that the site has had on-site _~Dunderground storage tanks (UST) for hydrocarbon materials. The ~~v’Fg~ e c~F~ t i’o n-ff~ s-f "o~i’ff~fl~ o r-~t~’*dis cus s~-~’i~h~6~~Iii~°ffi~. -A~d~tio nally the box unde~ VII(d) for Hazards and Hazardous Materials is checked incorrectly. It is checked as a "less than significant impact" when it should be correctly checked as a "potentially significant unless mitigated". The Lowney Associates report that is on file with the City of Palo Alto dated January 23, 2001 very specifically states: "Please note that areas of buried debris may be present under on-site structures and may be encountered during grading activities. impacted soil is observed orsuspectedfollowing removal o,,f t~ bris, it must be characterized and appropriately handled. Page 6.) " Additionally the Lowney Associates report dated January 23, 2001 states that DDT was found on site to exceed the California hazardous waste limit of lppm in the area near the California and Hanover corner. (Page 6.) The Lowney Associates report dated January 23, 2001 shows that heptachlor epoxide exists on the site at boring B-1 at a concentration level of 0.16 ppb corresponding io a caficer risk above the one in one million threshold for human safety set by EPA Region 9. Lowney Assodates report states "..furtherevaluation of potential risks is appropriate "and ’further evaluation mayinclude additional sampling and or the reassessment of the assumptions and routes of e~72osure.. " (Page 4). Location B-1 is in a location near the California and Hanover corner. It is hnsound engineering practice to average this concentration with concentrations at other :boring locations that are unimpacted to try to minimize the statistical significance. This Concentration. value should be averaged with boring concentrations from the same location ~on the site for an assessment of statistical importance. (L~ ~-’ ~,~ ~(v~ M~mo fo Palo Alto City Council on 2476 Hanover, F~bru~ry ]3, 2002, ~rom Dr. Anfo~l~efte Sfe~ - Page 1 of 3 Based on stated findings from the environmental reports on file with the City of Palo Alto, there is a need to monitor_A[ordrnpac~ito~oL! i_n_. areas where buried debris may be encountered under on-site structures during grading activities. There is a need to properly characterize and handle any impacted soil encountered. It ihould_be stipulated in the Mitigated Negative Declaration and the construction ~ermits that excavatio_n a,~,~~ce_~o,,,nl__Z when an orgamc vapor ~t~eratmg,.atoT ~sxte,.andscreemng~t[or~. _c~.. ~ ~rmc0]Iy, impactei~ soft. X,,n~ sod[ ¢~ntammg measurable concentrauons of ~hxdrocarbons .,an~.d. tox~cs should be ~[" treated wxth appropriate risk management measures including notification to workers of the potential constituents that may be present, and on site soil management procedures and disposal procedures. It should be stipulated in the Mitigated Negative Declaration that an environmental consultant shall be on-site at selected intervals during excavation and grading to observe soil management procedures and to be notified if impacted soils are identified and sampling of soil is needed. The Lowney Associates report on file with the City of Palo Alto dated January 23. 2001 indicates that areas of buried debris may be present under on site structures and there is a potential that toxic substances may be encountered and may need to be managed appropriately. As a result the Department of Toxic Substance Control (DTSC) (Barbara Cook, (510-540-3828) and the Regional Water Board (RWQCB) should be made aware of this Mitigated Negative Declaration and should be given an opportunity to comment on it. Managing toxics is the statutory authority of the Department of Toxic Substance Control (DTSC). The Mitigated Negative Declaration Under Air Quality in Section III (b) is checked incorrectly~ The box for "no impact" is checked. Instead the box "Potentially Significant Unless Mitigated" should be checked. Section 1Ttb reads: "Would the project violate any air quality standard or contribute substantially to an existing or projected air quality violation?" the box should be checked as "Potentially Significant Unless Mitigated" because it has been established by the environmental professionals on this project that impacted soil may be encountered during grading and excavation. Hence there is potential that contaminated soil will be dug up and brought up and out to-the surface where it will be aerated and volatilize into the air where it will impact persons in the vicinity breathing the air. It must be stipulated that if impacted soil is encountered during excavation then the area will be immediately covered until proper risk assessment and measures for cancer risk are put in place and applicable excavation permits with the BAAQMD are obtained. During excavation of the site proper measures should be implemented to protect the heakh and welfare of workers, pedestrians, bicyclists and residents near the site. Additionally waste management of any impacted soil should be practiced. The risk based on soil sampling must be assessed to assure that no known cancer risk exists during excavation. Memo to Palo Alto City Council on 2475 Hanover, February 13, 2002, from Dr. Antoinette Stein - Page 2 of 3 In Amy French’s January 29, 2002 memo entitled Summary for Toni Stein, she writes: "In the Phase 2, a total of 9 soil samples were collected and analyzed for halogenated volatile organic compounds, semi-volatile organic compounds, PCBs, CAM17 metals and pH at depths ranging from 5,10 and 15 feet below ground surface. The soil had non-detectable concentrations of these constituents in these 9 sampling locations." After reading the Lowney Associates report that is on file with the City of Palo Alto dated January 23, 2001, Ms. French’s summary does not accurately reflect this report’s findings. The report very clearly states that soil samples were also taken at a zero to half foot depth for each of the 9 borings. At.this depth, DDT was found to exceed the California hazardous. waste limit of l ppm in-B~ring B-l’i~ th~’~a near the California and Hanover corner. Additionally the Lowney Associates report states that heptachlor epoxide was found at Boring B-1 at a concentration level of 0.16 ppb corresponding to a cancer risk above the one in one million threshold for human safety set by EPA Region 9 and exceeds the residential preliminary remediation goal (PRG) developed by EPA Region 9. Ms. French.writes in the January 29, 2002 memo entitled "Summary for Toni Stein:. "The site has no chemicals in the soil, the grading will not go deeper than 16 feet below grade, and the area where the groundwater is impacted is not in the building or garage footprint." Ms. French has no basis for the above blanket statement that the site has no chemicals in the soil. The Lowney Associates report that is on file with the City of Palo Alto dated January 23, 2001 very clearly states that: "areas of buried debris may be present under on-site structures and may be encountered during grading activities. If impacted soil is observed or suspected following removal of the debris, it must be characterized and appropriately handled." Memo to Palo Alto City Council on 2475 Hanover, February 13, 2002, from Dr. Antoinette Stein - Page 3 of 3 To: H6norable Palo Alto City Council From: Dorothy Bender Date: February 14, 2002 Letter 2: Dorothy Bender CITY OF P~LO AL’[’O, CA CITY CLER,~’S OFFICE 02 FEB Subject: Comments on the Revised Mitigated Negative Declaration for 2475 Hanover Street on Transportation and Cumulative Impacts I have reviewed the Revised Environmental Checklist and Mitigated Negative Declaration dated January 30% 2002 for 2475 Hanover Street and make the following comments: I.TRANSPOR TA TION The Revised Negative Declaration incorrectly indicates that there is "Less Than Significant Impact" for issue XV (a), which pertains to increase in traffic. Substantial evidence is on the record to support a finding of potentially significant traffic impacts unless mitigated. The Revised Mitigated Negative Declaration incorrectly indicates that there is "No Impact" for issue XV (b), which asks. whether a level of service standard established by a county congestion management agency is exceeded, either individually or cumulatively. The Hanover Street/Page Mill intersection is a Santa Clara County Congestion Management (CMP) intersection (see page 124, line 10, of the April 1998 Final Environmental Impact Report for the Palo Ako Comprehensive Plan Update: Transportation, Circulation & Parking; see also pages 1 and 2 of the July 9, 2001 Mayfield Site Development Traffic Impact Analysis prepared by Korve Engineering). Substantial evidence has been presented that an incorrect baseline was used by Fehr & Peers Associates, Inc. in their 2575 (2475) Hanover Street Traffic Analysis prepared for Stanford Management Company dated July 2001. Had the correct baseline been used, the thresholds used by the County to determine significant impacts at CMP intersections would be exceeded, thus a potentially significant impact exists unless mitigated. A Trafl% Study Is Required A traffic study is required and needs to be done because the 100-trip threshold is exceeded when an appropriate baseline is used. The record shows that the City had inappropriately used a baseline of 31,000 square feet of existing "office" use at the ~ite (based on the April 2000 date of the City’s most recent traffic counts)in order to generate i~s calculation of 91 new.AM peak hour trips. When a corrected baseline of 31,000 square feet of "Research and Development" use is applied, the number of new AM peak hour trips is 108 trips, which exceeds the 100-trip threshold, and thus requires that a traffic study be done, Substantial evidence is on the record that there ~will be a significant impact at the Hanover Street/Page Mill intersection resulting from this project, and that an incorrect baseline underestimated the impact at this intersection. ’Therefore, the City needs to do a traffic study that incorporates correct assumptions in order to accurately identify potential impacts at other intersections in addition to Hanover/Page Mill. (The traffic impact fee cannot be considered to be mitigation for a potentially significant impact at any intersection other than one of the eight intersections designated for capacity improvements using the traffic impact fee. See Section 16.45.060 of the Palo Alto Municipal Code which limits the use of the traffic impact fees collected such that the fees may only be used for capacity improvements at the eight designated intersections. One such intersection that may be significantly impacted by this project, but for which traffic impact Comments on Revised Mitigated Negative Declaration on 2475 Hanover Street February 14, 2002 Page 1 of 2 fee funds cannot be applied, is E1 Camino Real/Cambridge Avenue.) A traffic study needs to be don.e to identi~y potentially significant impacts on residential streets resulting from cut-through traffic. The Revised Mitigated Negative Declaration states "the build-out of this site was included in the Comprehensive Plan EIR Analysis". However both this site as well as the intersection at Page Mill/Hanover were NOT specific~llly mentioned or analyzed in the Comp Plan EIR. The Shuttle Is Not Included as a Mitgation The mitigation of a shuttle extension is missing from the Revised Mitigated Negative Declaration. The motion by Councilmember Morton, passed on a 5-1 vote, stated that the shuttle extension to the project was to be included as a mitigation. There is no such mitigation included in the Revised Mitigated Negative Declaration. There is also no data presented to show that the shuttle extension would adequately mitigate the impacts caused by the project. No Information on Intersection Improvements There is no information, schedule, or data showing that proposed intersection improvements at Page Mill/Hanover will adequately mitigate the potentially significant impacts to less than significant. II. CUMULATIVE IMPACTS The Revised Mitigated Negative Declaration has failed to address cumulative impacts. Cumulative impacts are required to be taken into account in all answers in the Environmental Checklist, yet cumulative impacts resulting from other past, current, and probable future projects in the Research Park have not been identified or addressed in the Checklist. Under Mandatory Findings of Signficance, XVII(b) the "No Impact" box is checked indicating that the project has no "impacts that are individually limited, but cumulatively considerable". Indeed, the record shows that there are cumulatively considerable impacts resulting from past, current and probable future projects. Although the Revised Mitigated Negative Declaration cites the Palo Alto Comprehensive Plan, 1998-2010. ("Comp Plan") as a basis for a finding of "No Impact," the record shows why the Comp Plan is not an adequate basis for such a finding. This evidence includes the following: (1) the Hanover Street/Page Mill intersection (and other potentially impacted intersections such as E1 Camino Real/Cambridge Avenue) was not studied in the 1998 Comp Plan EIR; (2) the Comp Plan did not anticipate this particular project; (3) the Comp Plan did not anticipate the intensification of use that has occurred in the Research Park; and (4) the Comp Plan assumed 800,00 square feet of growth in the Research Park under the Comp Plan EIR through the year 2010, but by 2002, approximately 700,000 square feet of new floor space has been added, which is a much higher rate of growth than anticipated by the Comp Han. (See remarks by Lisa Grote at the January 14th, 2002 hearing in which she stated (1) 170,000 s.f added to the Research Park between 1996 - 1998 and (2) 530,000 s.f. added’ from 1998 to the present.) III. CONCLUSION Based on the foregoing, it is respectfully requested that the Revised Mitigated Negative Declaration for 2475 Hanover Street be denied. Comments on Revised Mitigated Negative Declaration on 2475 Hanover Street Page 2 of 2 February 14, 2002 Council, Cit~ Several items pertainir same.subject are assert Letter 3: John Abraham this Dacka~ .... , From:John Abraham [ja133! @hotmail.com] Sent:Tuesday, February 12, 2002 8:54 PM ¯ To:city_cou ncil@city.palo-alto.ca.us Subject:2475 Hanover Street Dear Members of the City Council: I am concerned that neighborhood.protection against noise at this project may fall through the cracks, despite a commendable Acousitcal Engineering Report. The following are my comments to the Project Planner for this project. The Noise report was prepared by the firm of Wilson, lhrig & Associates, Inc, Acoustical Consultants with Mr. William A. Pritchard as Assistant Consultant.and Author. This report provides considerable data on the current ambient noise along California Street at this site including a frequency spectrum at two sites, one at the project corner and another further into the residential section on the.Stanford side of California Aenue. This data, while unrelated to the project, nevertheless forms the.basis of the consultant’s ~ecommendations. I believe that the consultant’s target level of 42 dBA, if actually attai=ned once the project is operatiing, will satisfy both the Comprehensive Plan and Palo Alto Municipal Code (PAMC) requirements. The problem is that there are no "after" ohecks to verify that the intended noise levels are being attained..There are, for example, several potential problems: The manufacturer’s specifications at the top of page 4 for intended equipment may be understated, the data does not necessarily apply .to subsequent production model changes or take into account unit to unit variation and there may be .midstream changes.in required equipment by the applicant. The report focuses on the mitigations required to bring the project into conformance with the Comprehensive Plan and there is nothing regarding the Noise Ordinance (PAtvlC), which must also be met for this or any such project. While the suggested mitigation is impressive there is no mechanism for delivery. It is all promises with no tests or guarantees. While residents can always phone in a noise complaint under the PAMC, there are will known problems with police priorities, gaps in training, unfamiliarity with the PAMC that make such complaints an unsatisfactory method of .achieving.pr0ject compliance. If it is possible to achieve 42 dBA in position 1, that would.likely satisfy the PAMC at the nearest residences across California Street, but there needs to be a final check by the applicant and the City before approval by the City is granted. I can find no such provision, certainly not in the mitigations. There is also a difference in viewpoint as to who might be responsible for a final noise check off. The Noise Consultant has indicated that it would be the Architect of the project who would require further noise analysis.. The City, from the Project Manager’s viewpoint, sees a buil.ding shell, with the tenants responsible for.any noise they might create. There is obvious potential for disagreement and misunderstanding about who if anyone is responsible for problems, despite the commendable suggested mitigation. It is not necessary to postulate malice or fraud to see how the project could quickly result in much higher than postulated noise levels. Neighbor protection could .fall between the cracks. Waiting until noise complaints-are called in is no protection at all for neighbors direclty across California Street, for example. In keeping with the cautious nature of the consultant’s recommendations, I suggest assuming that in regard to the PAMC, the base ambient noise level, particularly in the earlymorning hours about 3 a.m. should be set at the minimum level allowed by the PAMC, namely 40 dBA. The property is commercially zoned and the PAMC gives an 8 dBA cushion at the project property boundaries. If " after-construction noise tests Show compliance with the Comprehensive Plan and PAMC, that would ensure compliance at site 2 and should be sufficient to protect residents from PAMC violations. IF there are objections to using a 40 dBA ambient then I would like to see the data ofdiagrams 2 thru 11 supplemented with L99 data as well as L90, L50, etc at the site boundary. The PAMC requires L99.5 as ambient, not L90, although most acoustical engineers (including Mr. Pritchard) prefer Lg0,with the statement that there is only a slight difference between L90 and L99. No data has so far been presented to confirm this at the site, and unless the minimum 40-dBA is accepted, such data would be appropriate. Thee is still the possibility of excessive noise in the. low frequencies, which .while protected by law, could keep the residents awake late at night. The data of figure 12 suggests there is already considerable low frequency noise at site 1, peaking ataobut 74 dBA at 63 Hz. It is necessary that there be a similar diagram for data collected after operation begins for comparison. The suggested additions should not cause any problems with the project since the standards proposed by the consultant indicate compliance. It would help to dispel the fear that the noise mitigation is speculative and theoretical only and will not be enforced. Sincerely, John K. Abraham, 736 EIIsowrth Place, Palo Alto, CA 94306 Chat with friends online, try MSN Messenger: Click Here <http://.qo.msn.com/bql/hmta.ql etl EN.asp> FE£-13-2002 O8:37 CITY OF NENLO PARK, STEPHEN M. SCHMIDT MAYOR CHARLES M. KINNEY MAYOR PRO "I"EM MARY JO. BORAk PAUL(~OUNCILMEMBER NICHOLA~ P. "JELLINs coUNCILMEMBER ADMINISTRATION: ~’ry Man~gor’s OfficeTEL 550.858.3~80 FAX 651~ Chy ~lerX TEL.650:=sn.3381 FAX 650.37~,79115 TEL 650.85B FAX Per;sonm=l TEL FAX 650.327,53R2 COMMUNITY I~EVELOPMENT: Bullc!Ing TEL 65O.85B.339~ FAX 650.327.$41~3 Environm~’ntal TEL 650.858.3411 FAx 650.3Z7’,6497 Planning TEL tt20.858.0400 FAX 650.327,1i497 TEL 650.85~.33E=- FAX ~50.327,5497 HOU$1N~ &REPEVELOPMEIVT:- TEL ~5o.~5~.~ = FAX 650.327.~ ’/’59 LIBRAR~ TEL 650.651].3461 FAX B50.1158.3466 PARK3 & ¢OMMUN[I-YSF_.RVICES: TEL 650.1~66,3470 #A)~ 650.324,1721 POLICE DEPARTMENT’. T£L 550 ~158.3300 FAX 650.327.4314 PUBLIC WORKS: £nglnectin9 TEL 550.858,3420 FAX 650.327.~497 M~/nton=n¢e TEL 650,bs&~490 FAX 650.327. Letter 4: 701 LAUREL STREET, MENLO PARK, CA 94025-3483 www. menlo park. org Paul Collacchi February 9, 2002 The Honorable Mayor Victor Ojakian and Council Members] City of Polo Alto 250 Hamilton Avenue Polo Alto, CA 94301 RE: 247~ Hanover - Impacts at HanovedPage Mill Dear Mayor and Council Members: Thank you for this opportunity to comment on the re-circulated Mitigate Negative Declaration (RMND) for 2475 Hanover St. Menlo Park traffic engineers calculated the im pacts of the proposed Hanover project at the intersection of Hanover/Page Mill using Highway Capacity Manual procedures and Polo Alto counting rules and standards. The results are Summarized below and appear in detail in the appendix, Hour Impact Change Paio Alto Standard PM Critical Delay (seconds)7.10 4,0 PM Critical V/C .0~$04 The peak PM impacts at HanovedPage Mill exceed Palo Alto thresholds by 75% and 50% respectively and are significant. The RMND fails to disclose these impacts as "potentially significant unless i-n~tigated" In.the appropriate section XV(a) and possibly XV(b). I’m saddened to see that the next-door neighbors were offered financial incentivesto.resist CEQA, but the entire public, including Menlo Park, is entitled to substantive due process, The public.has a right to know about this impact and it stiould also be given the chance to review and comment upon explicit, written calculations showing the adequacy of any alleged mitigation. Currently the RMND makes no explicit calculations proving the adequacy of any mitigation. Jurisdictions routinely.supply such ~;al6ulations as part of a corn plete traffic study, No traffic study has been done for this project. I thought Council Member Kishimoto’s amendment to deny the previous "flawed" MND and to re-circulate a new one hinged on Council’s certain understanding that the Fehr & Peers study implied a significant impact would occur at Hanover FEB-13-2002 68:37 CITY OF MENLO PRRK.P.03/18 2475 Hanover Impacts at Hanover/Page Mill page /Page Mill if the cabulations were made assuming a 51KSF project rather than a 31KSF project. I fully expected the RMND to disclose this impact, and was surprised to see that it did not, This is.why I requesbd Menlo Park staff to make the ;alculation above. They did so easily with little effort. As a matter of formal process, Council Members who sincerely believe that the Fehr & Peers and Menlo Park calculations reveal significant impacts at Hanover/Page Mill cannot in good onscience ignore them and certify the RMND as It now stands. They should oppose the RMND and move for a proper traffb study to be prepared at the expense of the applicator. In Menlo Park, I would feel legally obligated to do so. This is perfectly normal and routine, In many jurisdi~ions, on behalf of the publb, traffic studies are routinely and immediately triggered to .confirm the reasonable suspicion of significant impels, In this particular case, ! do not believe the full individual and cumulative impacts of this project on California Avenue and the nearby neighborhood have been properly analyzed and disclosed, From discussion In the public headng, it seems that the proposed intersection improvements for Hanover and Page Mill, apparently, will not be built until after the project is built, As noted by Council Member Freeman, this time lag will leave a ~lgnificant Impact unmitigated for some period of time. The RMND does not estimate how long. This "significant unmitigated impact" could be legally important, If disclosed as such, it g~ves Council the power to impose an interim mitigation, such as a shuttle. If a shuttle proves inadequate and no other adequate interim mitigation can befound, then Council Members can deny the RMND because the unmitigated impact will remain unmitigated, Staff’s position regarding the interim impact is that the fee collected to offset eventual intersection construction adequately mitigates the temporary unmitigated impact. That is one view, but it cloaks an embedded policy decision, There are other views that are a~so valid. Council members have the discretionary authority to agree or disagree With embedded.policy decisions made by staff. Council Members are expected to make independent findings consistent with-their values and platforms so long as there is some evidence on the record to support their findings. The-time lag between fees being collected and mitigations being built is precisely why reasonable people ~n differ over whether fees oonsfJtute mitigations. For example,.it ]s my personal platform value that a transportation fee is not a mitigation until and unless it is built, Personally, I would not certify an impact as being mitigated, and I would not approve use of a project until and unless the mitigations are in place, Values differ, naturally - but conservative, protectlonist-values-are just as legal as developmentally permissive ones so long as they conform to CEQA’s logic. Council members who lean toward more restrictive land-use policies, and conservative, protective CEQA analysis can easily disagree with staff and make this finding in good faith. FEB-13-2002 08:3?CITY OF MENLO PARK,G5032899~5 P.04/18 2475 Hanover Impacts at Hanover/Page Mill page 3 Note also that if the Hanover/Page Mill intersection improvemel~t is budgeted but not programmed, then there is an added risk of financial and political uncertainty about Its beir~g built, This means there is a real risk that eventual construction might be further delayed. Delay wo~Jld extend public suffedng of an unmitigated significant Impact. A discussion of the risks and delays should appear in the RMND. If a majority finds that the Hanover/Page Mill impact is significant and will be unmitigated for some time, then 1. Suggest Council explore ways to impose interim conditions on the project.. If the. applicant doesn’t agree to Interim conditions it may withdraw its project, If staff cannot find ways to mitigate the interim impacts, tl~en they will remain unmitigate~l and a. Mitigated Negative Declaration is no longer the proper document to Use, The RMND should be denied, The applicant may still pursue the project by initiating an at its own expense. Council member’s ability to Impose temporary conditions (such as an interim shuttle) requires proper flndir~gs and documentation.in the RMND. These include: ,Documenting that there is a potentially significant impact at Hanover/Page Mi!l, o Documenting that the proposed mitigation will not be built within the timeframe of the project, ¯Determiningadequate Interim mitigations (e.g, resLdct use of the new building to 31 KSF until the intersection gets built, propose a temporary shuttle If it Is adequate, etc), Currently, this documentation is lacking, but there is evidence in the record to support the first two bullets, Council needs to work with staff to determine an adequate temporary mitigation. it is important to note that authority of Council to impose traffic mitigations, temporary or permanent, hinges on disclosing the significant impact at Hanover/Page Mill in the RMND. Impacts, once disclosed, trigger the legal authority to impo.se mitigations. But if =mpacts are ignored, sanitized, or denied then Council forfeits its authority to (repose mitigations on the applicant. Finally, the Mayfield study shows an increase in traffic volume of nearly 1700 trips per day on California Ave, These trips are the cumulative result of the proposed Mayfield project, a smaller version of the Hanover project, and background growth. This is a large increase for a residential street, and may reflect a cumulative significant impact on that street if Pale Alto has cumulative standards for .residential streets, About half of this increase is unaccounted for. Is it cut4hrough traffic or does it arise from the neighborhood or businesses ~n that area? FEB-13-2002 08=38 CITY OF MENLO PRRK~&503287935 P.05/18 247S Hanover Impacts at Harlover/Page Mill page 6 The neighbors are right to worry about these and other traffic impacts in their -neighborhood. And they have nothing to fear~rom CEQA. The real impacts of the Hanover project a~-e nearly twice those analyzed in any traffic study, AJl traffic studias-- Fehr & Peers and Mayfisld--understate the Hanover p~oject size. So the true impacts in the neighborhood have never been properly analyzed, The traffic study quite properly called-for by the significant impact listed above can truly serve the neighbors if it concentrates on traffic flows and impacts between El Camino and Page Mill on Califarnla/Hanover, .and exhaustively analyzes traffic im pacts on California Ave and ~ut-through traffic in the nearby residentlal neighborhood, Sincerely, Paul Gollacchi Council Member City of Menlo Park Wwdata~2475 Hanover & Page Mill FEB-13-2002 08:38 CITY OF MENLO PQRK.GS0328793S P.OG/IB DATE: TO: THROUGH: FROM: SUBJECT: TRANSPORTATION DIVISION 701 Laurel Street/Menlo Park, CA 940254483 1 (650) 858-3363 Fax (650) 327-5497 MEMORANDUM February 11, 2002 Council Member Paul Collachi David Boesch, City Manager Jamal Rah[mi, Transportation Manager Traffic Impact Calculations - 2475 Hanover Street Per your request, we made the calculations using standard Highway Capacity Manual (HCM) procedures and the City of Palo Alto rules and standards to determine the traffic impact of the project at 2475 Hanover Street on the intersection of Hanover Street and Page Mill Expressway. Our assumptions and calculations are attached as the appendix. As presented in our summary of calculations (Table 1), the project does not have a significant impact on the iatersection during the AM peak hour’, however, It does have a significant impact on the intersection during the PM peak hour, a~achments City Council i] ~EB-13-2@@2 88:38 CITY OF MENLO PRRK.~5@3~89935 Po@B/18 Assumptions & Methodology This mamorand,,m documents project hupaas at ~¢ Hanover Str~lIPag¢ Mill E~l~r~ssavay tnlersc.cfion prepared by the City of Menlo Park relath~g to fl~¢ proposal offi¢~ devolopm~nl at 2475 Hanover A~umptiOns: ¯N~w buildi~g is ~2KSF ¯New buildhlg generates trips @ ¯Cm~t i~ ~ven for ~cupi~ squwo foowge ofexS~tingbuil~ag (31 KS~ @1.78 ~p~ ~r KSF, ,Pr0j~t g~ts ¢1~ for a~ve ~ps but includ~s.mm~pied ~ion of e~sting building (51 KS~ ¯Trip g~emfion, a~i~ment, and ~sMbugon a~ as ~r ~uly 200~ F~I~ & P~rs Study Methyl. Standard FICM methodology, Palo Alto standards FEB-13-2002 88:~8 CITY OF MENLO PRRK.6503287935 P.89/18 MITIG8 ~ AM ~A!<’Mon Fe~ ii, 2002 10:31:32 Page i-I 2475 I~nover FLFfl!RE AM M/O MITI~TION W/0 P~OJECT bevel Of Service Computation Report 1985 ~CM 0pera~ions Method (Future Volume Alternative) Intersection ~i HANOV’~I~iPAGE MILL CyCle. (see):150 Critical vol./eap. (~):0.903 Loss.Time (see):12 (Y+R ~ 4 seo) Average Delay (sec/v~h):65,8 Optimal Cycle:135 Level Of Se.~vlce: Approach;North Bound Movemmnt:L T R Min. Green;7 I0 i0 Lines:0- Volume Module: AM PEA~< Base Vol:27 ~7 241 Growsh AdJ,1.08 1.08 1.08 Initial Bee:29 62 260 Added VoI:O 0 0 Added Vol;0 O 0 Initial ~u~29 ~25o User Adj~1,00 1,00 i.~0 PH~ Adji 1.00 1.00 l.o0 PH~ Volume;29 62 260 ~educt Vo~J:0 0 O. ~educ~d Vol~29 62 260 PCE Ad~:1,00 1,0O 1,00 MLF Adj:1.00 1.00 1,00 Final vol.:29 62 ~60 Saturation Flow Module~ Sat/Lane:1800 1800 1800 Adjustment:~.01 1,04 0,97 Lanes~0.g5 1.35 Final Sat.=1179 2520 1750 Capacity Analysis Module: Vol/8ah:0.02 0,02 0,15 crit Moves:**** Green Time:7.0 7.0 64.0 volu~e/Cap~0.53 0.53 0.35 Delay/Veh:55.5. 55.5 22.1 Delay Adj~i.oo 1.00 1.00P~ogAdj~ctr~1.00 1.00 1,00 AdjD~I/Veh:55,5 55.5 22.1 Desi~nOueue:~ 5 13 South Bound EeDt Bound L T R L T ~ ¯ SRli~ Phas~Protected Ovl Include 7 10 i0 7 10 i0 o 1 o I o i o 1 1 o West Bound T R Protected Include 7 Io 1o o 1 1 o ~6 108 154 465 157~73 %.08 1,08 1,08 1,08 1.08 1,08 39 117 166 502 1702 79 o o o 0 o o o o o 0 o o 3~~17 166 502 1702 .79 1.00 I..00 ~,.00 1.00 1.00 1,00 i.~0 1.00 1.00 1.00 1,00 ~,0o 39 117 166 502 1702 79 o o o o o o 39 i17 166 502 1702 79 1,00 1.00 1.00 1.00 1.00 1.00 i,oo i.oo i.oo I.OO i.o0 i,oo 39 117 166 502 1702 79 386 1219 1.08 1.08 1.08 417 1317 127 0 0 0 ~ 0 0 417 1317 127 1.00 1.00 1.00 l~O0 1.00 1.00 417 1317 i~7 .0 O 0 417 1317 127 1.00 1.00 1,0o 1,0o 1.00 1,DO "%17 1317 127 1800 IB00 IB00 iBO0 iB00 1800 1,00 i,OO l. OO 0.97 1,03 1,01 0,25 0,75 1,00 1.00 1.91 0.09 450 1350 1800 1750 3536 15~ i 1800 1800 IS00 0.97 1.03 1.00 1.00 1,82 0.18. 1750 3374 .325 0,09 O,OS 0.09 0,29 0,48 0,48 0.24 0.39 0.39 21,0 21.0 72.0 51-0 63.0 63.0 51.0 63.0 ~3.0 0.62 0,62 0,19 0.84 1.15 1.15 0.70’0.93 0,93 47.8 47.8 17.0 42.B 112 111,5 38,1 38.9 38.9 1,00 i.,00 1.00 1.00 1.00 1,00 1,00 1.00 1.00 1.00 1,00 1.00 1.00 1.00 1.00 1.00 1-00 1.00 47.8 47.8 17.0 42.3 112 iiI.~35.1 38-9 3 9 7 30 94 4 24 71 7 Trafflx 7.5.0615 (c) 2001 Dow!ing Assoc, Licensed to CITY OF MENLO PARK, CA FEB-13-2@02 @8:39 CITY OF MENLO PARK. ,. 65@3287935 P.I@/18 city of Palo Alto Fu~ AM W/O MITIGATION ~/o PROJECT Level Of Service Computation Report 198~ HCM Operations M~tbod (Fm~uTe Volume Alternmtive)~ IntersectiOn ~1 ~[;hNOVER/PAGE M~LL Cycle (~ec):i~0 Critical Vol./Cap, [x):0.903 LOSS Time (sec}|12 (Y÷R =4 sec) AvezaSe Crit Del (seo/v~h):89,5 optim~l Cycle:135 Level O£ Sei-vice: ApproaCh|North Bound Sou~h Bound Ea~ Bound Wes~ Bound Control~%plit Phase SpliK Phase Protected Pro~ected Rights:Ovl O~I Include Znclude Min, Green:7 .I0 I0’7 i0 !0 7 i0 IG 7 ID i0 Lanes:0 1 1 0 1 0 1 0 1 0 1 o I i 0 1 0 I 1 0............ I ........... "’II ...........Volume Module|. AM PEAK Base Vol,27 57 : 241 36 108 154 46B 1576 73 386 1219 i18 G~owth Ad~:1,08 1.08 1.O8 1.08 1,08 1,08 1,0~ 1.08 1.05 1,08 1.08 1,08 Initial B~e~2~62-260 39 117 166 ~0~ 1702 79 417 1317 127 Added ~01:0 0 0 o 0 0 0 0 0 o 0 0 Added ~oi:o 0 0 0 0 0 o 0 0 .0. 0 0 Initial Fur=29 62 ~60 59 117 165 502 1702 ?9 417 1317 127 U~r Adj~1.00 1.00 1.00 1.0O 1,00 1,00 1,00 1,00 1,00 1.00 1,00 1.00 PHF Adj:.1,00 1,00 1,00 1.00 1.00 1.0O ~,00 1,00 1,00 1,00 1.00 1,00 PH~ Yolume:29 62 260 39 iI~i~6 502 1702 7s ~17 1317 .127 Reduc~ Vol:0 0 0 0 0 0 0 O 0 0 -0 o RedUced ~oi:29 62 260 39 117 166 50~’1702 79 417 1317 127 PC~ Adj~1,00 1.00 1.0o 1,00 1,00 1,00 1.00 1.00 1,00 1.00 1,00 1,00 MLF Adj=1,00 1,00 1,00 .i.00 1.00 1.Do ~.00 1,00 1,00 1.00 1.00 1.0o Final ~oI,:29 62 260 39 117 ~66 502 1702 7~417 1317 127 Saturation Flow Mod~_le: Sat/Lane: 1800 1800 1800 1800 1800 1800 1800 IS0O 1800 1800’1800 1800 Ad~ustm~nn~1,01 1,04 0,97 1.00 i.o0 1,00 0.97 1,03 1,01 0.97 1.03 i~00 Lanes~ ¯0.65 1,35 1.00 o.2s 0,7S 1.00 1,00 i.~I 0.09 I.o0 1,82 0.18 Finil Sat.:1179 IS20 1750 %S0 I~5~ 1800 175o 35~6 164 1758 3374 325 C~paoityAnaly~i~ Module: Vol/sat:0.02 0,02 Cri~ Moves: Green Time~7,0 7.0 vo~ume/capz 0.53 0.53 Delay/Veh:55,5 55.5 Delay AdJ: ¯1,00 1.00 ProgAdjF~tr~ 1,0o AdjDel/veh: 55,5 55.5 DesignQueue: 2 5 0.15 0,09 0,09 0-09 0.29 0.48 0.48 0.24 0.39 .0,39 64.0 21.0 21.0 ?2.0 5~,0 ~3.0 63.0 51.0 63.0 63.0 0,35 0.62 0,6~0,19 0.84 1.15 1.15 0.70 0,93 0,93 ~2,1 47.~~.8 17.0 42.3 112 111,5 35.1 38.9 38.9 1,00.1.00 1,00 1,00 1,00 i~00 I Q0 1.00 1,0o 1,00 1,0o 1,00 1,00 1.00 I,O0 I.O0 1,00 l,oo 1,00 1,00 2~.i %7.8 47.8 17,0 ~2,3 ~12 111.5 35.1 3B.9 38,9 13 3 9 7 ~o 94 4 24 71 7 Tra~fix 7,’5.0615(c) 2001 Dowlipg Assoc. Licensed ~o CITY OF MENLO PARK, CA CITY OF MENLO .PARK.65@3289935 P.11/18 MITIaB - AM PEAK Mon Feb ii, 2002 10:38:39 Pa~e i-I 2475 E~nov~r S~reet City o~ Palo AI~o- FU~B AM W/O MITIGATION W/ P~OJECT Level O~ Servi~e Computation Repor~ 1985 HeM Operations Method (F~tu~ Volume Al~ern~tive) Int~rs~etio~ ~I H/%NOVER/PAGB MILL Cycle (sec)~.IBo Criti=al Vol./Cap. (x) :0,905 Loss Time (see):12 (Y+~ =4 sec) Ave~aSe Delay (see/vet):6~,5 optim~l Cycle:136 Level Of service:F A~proach:North Bound South Bot~n~East Bound West Bound Movement:L T ~L T R L T ~L ~ T -. Control:Split Phase Split Phase Pro~ecLed Protected RiShts:Ovl ~l Include ~nclude Man, Green:7 i0 10 7 10 I0 7 .I0 I0 7 10 Lanes:O i 1 O 1 0 1 0 1 0 i 0 1 I O I 0 1 I 0 ............ I ................II ...............II ...............II ...............I Volume Module: ~_M PEAK Base Vol~27 57 241 36 108 154 465 1576 73 386 12~9 Growth Adj:1.08 1,08 1,08 1,08 1.08 1,08 1,08 1.08 1,08 1,08 1.08 1,08 Initial Bse~29 62 260 39 117 166 502 1702 79 417 1317 127 Added Vol~.0 0 0 ’ 0 0 0 o 0 O 0 0 0 Added Vol:0 0 0 3 0 4 25 O 0 0 0 25 Initial FII~:29 62 2~0 ~2.117 170 527 1702 79 417 1317 152 User Adj~1.00 1.00 1,00 1.00 1.00 1,00 1,00 1.00 1,00 1,00 1.00 1,00 PHF Adj:1.00 1.00 1,00 1.00 1.00 1,00 1,00 1,00 1,00 1,00 1.00 1,00 PEF Volume:29 62 260 42 117 170 527 1702 79 417 13~7 ~educt Vol~0 0 0 0 O 0 0 0 0 0 0 ~edu~ed vol:29 52 260 42 117 170 527 1702 79 4~7 1317 PCE Adj:1.00 1.00 ~.00 1.00 l,D0 i.00 1.00 1,00 1,00 1,00 1.00 1,00 MLF AdJ:1.00 1.00 1-00 I100 1,00 .~,00 1,00 1,00 1,00 1.00 i,D0 Final Vol.:29 62 260 42 117 170 527 17o2 79 427. 1317 152. Saturatio~ Flow Modulm: Sat/Lane:1~00 1800 ~800 1800 1800 2800 1800. 1800 1800 1800 ~800 1800 Adjus~enE:l. Ol 1,04 0,97 1_00 1.00 1,00 0,97 1.03 1,01 0,97 1.0~1,00 Lanes:0,65 1.35 1.00 0.26 0.74 1,00 ~,00 1.91 0,09 1,00 1.79 0,21 Finll Sat,:1179 2520 1750 475 1325 1800 1750 3536 164 1750 33~5 383 Capacity~hnalysie Module: Vol/Sat: 0.0~ 0,02 0.1S 0,09 0,09 0.09 0-,30 0,48 D,48 0,24 0,40 0,40 Green Time:7-0 7.0 64,0 21.0 21,0 72,0 5%.0 63.0 63,0 51.0 63,0 63.0 Volume/Cap:0.53 0,53 0,35 0~6~ 0,63 0.,SO 0.89 IJl5 1.25 0.V0 0,95 Delay/Veh:55.5 S5,5 22,1 48.0 48.0 17.0 46.1 112 lll,S 35.1 40,9 40,9 Delay Ad~:1,00 1,00 1;00 1,00 1,00 Z,00 1.00 1.00 1,00 1.00 1,00 ~,00 ProsAd~F~nr:1.00 1.00 1.00 i.o0 1,00 1,00 1.00 1,00 1,00 1.00 1.00 AdjDel/Veh;55-5 55,5 2~,1 48.0 48,0 27,0 A6.1 112 ~i1,5 35,1 40.9 40~9 DesignQueue~2 5 13 3 9 8 31 94 4 2~ 71 T~affix 7,5.0615 (c) 2001 Dowling Assoc. License~ to CITY 00 MEhTLO PA!EK, CA ¯ FEB-13-2002 08:39 CITY OF MENLO PARK. 650328T935 P,$2/18 MITIG8 - AM PEAK Mon Feb ii, 2002 10:38:52 Pa~e 1-1 2475 Hanover Street City of Palo Alto FUTURE AM W/O MITIGATION W/ PROJECT Level Of servi=e Computation Report 1985 MCM Operations Method (Future Volume Alterna~iv~) Int~rsec~io~ #I ~L~NOVER!PAGE MILL Cycle (sec) ~150 Critical VOl./Cap. (X):0.905 Loss Time~(See):i~ (Y+R ~4 ~c) Average ~r£~ Del (sec/veh) :89.4 Optimal Cycle:13~Level Of Servieei F Approach:NorSh Bound South Bound Ba~t BOund -West Bound Movement:L T R L -T -R L T R L T Control:Split Phase spli~ Phase Protected Pro~ectad Rights:Ovl Ovl Include Include Man. Green~7 i0 1O 7 i0 i0 7 i0 i0 7 i0 I0 Lanes:0 1 1 0 1 0 ~ 0 1 0 1 0 1 1 0 1 0 1 1 0 Volume Module: ~M PEAK Bas~ Vol:~7 57 241 36 108 154 465 1576 73 386 1219 118 Growth Adj:1.08 1.08 1.0~1.08 1.08 1.08 I,OB 1.08 1.08 1.08 1,08 ~.08 Initi~l Bse;29 62 260 39 117 166 502 1702 79 417 1317 127 Added Vol:0 0 0 0 0 0 0 o 0 0 0 0 0 Added ~oi:0 0 0 3 0 .4 25 0 0 0 0 25 Initial Fur:29 62 260 42 117 170 527 1702 79 417 131~152 USer Adj:1.00 1.00 1.00 1,00 1.00 1.00 1.00 1.00 1.00 1.00 1,00 1.00 PHF Adj:i.~0 1.00 1.00 1.00 1.00 i~O0 1.00 1.0o 1.00 1,00 1,00 1.00 PHF ~olum~:29 62 260 42 117 170 527 1702 79 417 1317 152 ~educ~ Vol:0 0 0 0 0 0 0 0 0 0 0,0 Reduced vol~29 62 260 ’ 42 117 170 527 1702 79 417 13~7 152 PCE Adj:1,00 1.00 1.00 1.00 1.00 1,00 1.00 1,00 1.00 1.00 1.00 1.00 MLF Adj:1,00 1.00 1,00 1.00 1.00 1.00 1.00 1.00 1,00 1,00 1,00 1.00 Final Vol.~29 62 26~4~117 170 527 1702 79 417 1317 152 ............ I ...............II ...............II ...............II ................8aturation Flow Module: Sat/Lane:1800 1800 1800 1800 IS00 1800 1800 1800 1800 1800 1800 1800 Adjustment:1.0! 1.04 0.97 1.DO 1.00 1.00 0.97 1,03 1-01 0.97 1,03 1.00 5anes:0.65 1,35 1.00 0,2~ 0.74 1.00 l,O0 1.91 0.09 1.00 1.79 0.21 Final sat.:1179 2520 1750 475 1325 la00 1750 3536 164 1750 3315 Capacity ~alysis Module: Vo~/Ba~:0.02 0.02 0.15 0,09 0.09 0.09 0,30 0.48 0.48 0.24 0,40 0.40 Crit Moves:*~*~******** Green Time:7.0 7.0 64.0 21.0 21,0 72.0 51.0 63.0 63.0 51.0 65.0 63.0 Volume/Cap:0.53 0.53 ~.35 0,63 ~.63 0.20 0,89 1-15 I~5 0.70 0.95 0.95 Delay/Veh:55.5,55.5 22.1 48,0 45.0 17.0 46,1 112 111.5 35.1 40.9 40,.9 Delay Adj:1.00 1.00 1,00 1.00 1.00 1.00 1.00 1.00 1.00 1,00 1.00 ~rogAdjFc~r:1,00 1.oo 1,oo 1.00 1.00 1.oo 1.oo 1.~o 1.o0 i,oo 1.00 1.o0 AdJD~i/Veh:55,5 55.5 22.1 48.0 48.0 17.0 46.1 112 111.5 35.1%0,9 D~slg~Queu~:2 ~13 3 9 8 31 94 4 24 71 8 Traffix 7.5.0615 (c) ~001 Dowlin9 ASSoc, Licensed to CITY OF MENLO P~K, CA FEB-13-2082 08:40 CITY OF MENLO PRRK,6503287935 P.13/18 MITIG5 - PM PEAK Mom Feb ii, 2002 10:16:29 Page 2475 Hanover Street City of FU~ PM W/O MITIGATION W/O PROJECT Level Of Se~vic~ Computation Report 1985 HCM Operation= Method (~%l~ure Volume Alt~rnati~e) Intersection ~i KANOVE~/~A~E MILL Cycle (see) :180 Critical Vol,/Cap. (X) ;0.960 Loss Time (sec);12 (Y+R =- 4 sec) Average Cri~ Del (sec/veh):79.3 opti~l Cycle;190 Leve~ Of Se~-vice~ Approaoh~Norah Bound South Bound Movemsn~"L -T K, L T R Control:SpliD, Phase Ri~hts:Ovl Min. G;een~7 I0 i0 Lanes:0 1 l’. 0 1 Volume Module~>> Count Da~e: Base Vol:~7 94 446erowth Adj:1,08 1.08 1,08 Initial B~e~7~i0~482 Added ~oi:o 0 0 Added Vol: ¯0 0 0 ~nitial Fur:72 102 482 User AdJ~~.00 1,00 1.00 P~ Adj~1.00 l.O0 1,00 P~ Volume~7~i0~402 Reducu VoI:0 O O ~ed’~c~d Vol:72 i0~48~ 9CE Adj:1.00 1.00 1.00MLP Adj~1.0O 1,00 1,00 East Bound W~s~ Bound L T R L T R Spllc Phase P~otec~d Protecued Ovl Include Include 7 i0 i0 7 I0 i0 7 i0 i0 0 1 0 1 0 1 0. 1 1 0 I 0 1 1 0 i Jan 2000 << PM PEAK 122 98 394 I~3 I~45 ii IB~ 1665 70 1.08 1.08 1.08 1,08 1.0B 1.08 1.08 1,08 1,08 132 10~4~6 133 1453 12 208 1798 78 o o o o o o o o o o o o o o o,o o o 132 i0~426 133 1453 12 208 1798 7~ i,.00 1,00 1.00 1.00 1.00 1,00 1,00 1.00 1,00 ~.00 1,00 1.00 1,00 1,00 1.00 1,00 1,00 1.00 %32 106 426 133 1453 12 ~08 1798 76 o o o o o o o o -o 132 10G 426 133 1453 12 208 1798 7~ 1,00 1.00 1.00 1,0o i.o0 1.00 1,00 1.00 1,00 1.00 I,oo 1.00 1,00 i.oo 1.00 1.00 1.00 1.00 ~inal ~ol.~ 72 102 482 13~ 1.06 426 133 1453 12 208 1798 76 saturation slow Module% Smt/LaDs~1800 1800 IB00 1800 1800 1800 Adjustment:1,0~ 1.04 0.97 ~,01 0,99 1.00 Lnnes:0.84 ~-16 1,00 0.55 0.45 1,00 Final Sa~,~1530 2168 1750 998 802 ISO0 Capacity Analysis Module~ Vol/Sat:0,05 0.05 0.20 o~s 0,13 0,24 Crit Moves~*~ Green Time:24.4 24.4 43.0 ~5.0 ~5,0 41.8 Volume/Cap:0.~7 0.~7 1,2~ 1.0~ ~.00 1.08Delay/Veh~57,8 07.8 194,8 .90.9.90,9 109.4 Delay Adj:1,48 1.48 i,i~ ,l.lS 1-15 1.12 ProsAdJFctr:1,00 1,00 1.00 1,00 1.00 1,00 AdjD~i/Veh:85.5 85,S 218,1 D~signOueue:7 io 42 13 I0 37 .1800 1800 1800 1800 1800 1800 0.97 1.03 0.83 0.97 1.03 1.04 1.00 1.98 0.02 1.00 1.92 0.08 1750 3~69 30 1750 3550 150 0.08 0,~0 0.40 0,12 0.51 0,51 16,8 Ii0 Ii0,0 18.6 112 111.8 0.86 0.68 0.68 1,21 D.86 89,1 21,8 2~.8 223,1 27.3 27.5 1.00 1.00 l,OO 1.00 1.00 1.00 1.00 1,00 i.o0.1,00 1.00 1.00 89.~21,8 21,8 223.1 27,3 27.5 13 72 1 20 90 4 Traffix 9.5.0615 (c) 2001 Dowlins A~Boc, Licensed uo CITY OF MENLO PARK,.C-A ¯ FEB-13~2002. 08:40 CITY OF MENLO PARK.6503289935 P.14/18 MIT~G8 - PM ~EAK Mort Feb ll, 2002 I0~18:40 pa~e i-i 2475 Eanover Street City of Palo Alto FLYIqJRE PM W/O MITIGATION W/ PROJECT Level Of Service Computation Report 1985 HCM Operations Method (Future Volume Alterna~ive) Intersection #I KANOVEK/PAGE MILL Cyc!e (eec) :190 Critical vol./Cap, (X) :0.975 Lose Time{see)=12 (¥+~ =4 .see) AveraSe Delay (sec/veh) z 73.3 Optimal Cycle:$90.Level Of Service:F Approach;North Bound South Bound East Bound West Bound Movement;L T -R L T R L -T ~L T R ............ I ...............II ............---II ....1 I Con~rol:split Phase Split Phase Protected Protected Rishte:OvI Ovl Include IDclude Min- ~reen:7 I0 i0 7 I0 i0 7 i0 i0 ~ l0 i0 Lanes:0 1 .i 0 1 0 1 0 1 0 1 0 1 1 0 1 0 1 1 0 ¯ ............ I .......... .....II ...............I I .... .......I Volume Module: >> Coun~ Date: 3. Jan 2000 <~ PM PEAK Base ~oi:67 94 446 122 98 394 123 1345 ii 193 1665 Growth AdJ:1,08 1.08 1,08 1.08 1.08 1.08 1,08 1,08 1.08 1,08 1,08 1.08 ~nitial Bse:72 102 482 132 106 426 133 I%53 12 208 1798 76 Added V01~0 0 0 0 0 0 0 0 0 ’ 0 0 0 Added Vol:0 0 0 24 0 22,3 0 0 0 0 5 I~itial Fut~72 102 482 156 106 448 136 1453 12 208 1798 81 User Adj:1.00 1.00 1.00 1,00 1.00 1.00 1.00 1,00 1.00 1.00 ~,00 1.00 PHF Adj~1,00 1.00 1.00 1.00 1.00 1,00 1.00 I,00 1,00 ~..00 1.00.1.00 PKY Volu~e:72 102 482 156 106 448 136 i~55 12 208 1798 81 Reduct Vol~0 . 0 0 0 0 .0 0 0 0 0 0 0 Reduced Vol:72 102 48~156 106 448 136 1453 12 208 1798 81 PCE Adj:1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1,00 1.00. MLF Adjr 1,00 1,00 1,00 ~.00 I..00 1.00-1,00 1,00 1.00.1.00 1.00 1,00 Fi~K1 Vol : 72 102 482 ~56 106 448 136 1453 12 ~08 1798 81 Saturation Flow Module~ SatiL~ne:1800 1800 1800 1800 1800 1800 1800 1800 1800 1800 1800 1800 A~justment:1~i 1-.04 0,97 1.01 0.99 1,00 0.97 1.03 0.83 0.97 1.03 1.04 LKnes:0.84 1.16 i~00 0.59 0.41 1,00 1.00 1.98 0.0~1.00 1.91 0.09 F~nal Sate=1530 2168 1750 1073 729 1800 1750 3669 30 1750 3541 160 Cap~cityAnalysis Module, ~ol/Sat:0.05 0.05 0,28 0-150.15 0.25 0-08 0.40 0.40 0.12 0.51 0,51 criL Moves:************ Green Time:24,4 24,4 ~3’.0 25.0 25.0 ~1.8 15.8 110 ii0.0 18.5 . 112 ii1o8 ~olume/Cap:0,37 0.37 1.22 1.11 1.11 1.13 0.88 0.68 0.68 1.21 0.86 0.86 Delay/Veh;57,8 57.8 194.8 127.6 128135.1 92.3 21.8 21.8 223.1 27,4 27,~ Delay Adj:1.48 &L48 1.12 1.15 1.15 1.12 1.00 1.00 1.00 1.00 1.00 1,00 ~rogAdjFcsr~1.00 1.00 1_00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 AdjDel/Veh:85,5 85,5 218.1 ~6.7 %4? &5~.3 92.3 21.8 ~1.8 22B.& 27.4 27.6 DesisnQueue~7 i0 42 15 i0 39 13 72 1 20 90 4 Traffix 7,5,0615 (c) 2001 Dowling Assoc, Licensed ~o CITY OF MENLO PARK, CA FEB-13-2802 08:40 CITY OF MENLO P~RK.650~287~3S P,15/18 MITIG8 - PM PEAK Mon Feb ii, 2002 .i0:19:16 Page i-i 2475 Hanover Street city ~ Palo Alto PUTURX PM W/O MITIGATION’W/ PROJRCT Level Of Service Computation Report 1985 HCM Opera[ions Mehhod (Future Volume Alternative) Inhersec~ion #1 HANOVer/PAGE MILL Cycle (see):190 c~itical Vol./C£p. (X)~0,975 Los~ Time (see}:i~ (Y+R =4 sec) Average Crit De~ (sec/veh)~ Optimal Cycle:190 Devel Of service:F Approach:North Bound.South Bound East B~und West Bound Movement:L T R L T -~L Control:Split Phase Split Phase Protected Protected ~ights:Ovl Ovl Include Include Min. Green:7 l0 ~0 7 I0 i0 b~nes:D 1 1 0 1 0 1 0 1 0 1 0 1 X 0 1 0 1 1 V~ume Module: >> Count DaCe: i Jan 2000 << PM P~AK Base Vol: Gzowth Adj: In%cial Bse: Added Added Vol: Initial ~u=: ¯ Uaer Adj~ PHF Adj= PHF Volume: ~eduot Vol: Reduoed PCE Adj: MLF Adj: Final Vol.: 67 94 446 1.08 1,0B 1,08 72 102 ~82 0 0 0 0 0 0 72 102 482 1.00 1.00 1,00 ~22 98 3~%123 1345 Ii 193 1665 70 %.08 1.08 1.08 ~,08 1,0B 1.08 ~,08 1,08 1.08 13~I0~426 133 1453 ~2 208 1798 76 o o o o o o o o o 2~o 22 s o 0 o o 5 156 i0~448 136 1453 I~208 1798 81 l. O0 1,00 1.00 1,00 1,00 1.00 1,00 1.00 1,00 1.00 1,00 1.00 1,00 72 102 482 156 I0~ 0 0 0 O 0 Y2 102 "482 156 106 1,00 1.00 1.00 I~00 1.00 1.00 1,00"l~O0 1,00 1.00 7~102 482 156 106 1.00 1.00 I..~0 1.00 1.00 1.00 1.00 1.00 4%8 136 1453 12 208 1798 81 o o o o o o o 448 136 1453 12 208 I’19~~i l,OD 1.00 1,00 1.00 1,00 1,00 1.00 1,00 1,00 1.00 1.00 1.00 1,00 1.00 ~48.136 1453 12 208 1798 81 Saturation Flow Module: Sat/Lane:1800 IBO0 IB00 IS00 1800 1800 1800 1800 IB00 1800 1800 1800 Adjustment:1.01 1,04 0.97 1.01 0-99 1.00 0.97 1,03 0.83 0.97 1,03 1.04 Lanes:0.84 i.i~1.00 0,59 0.~i 1.00 1.00 1,98 0.02 1,00 1,91 0.09 Final Sat,:1530 216~1750 I07~ 729 1800 1750 5669 ¯50 1750 3541 160 Capac~y~lalys~e Modul~: Vol/Sat~ 0.05 0.05 0.28 0.15 0.15 0.25 0.08 0.40 0.40 0,12 0.51 0.LA Green Time:24.4 24,4 43.0 25.0 25.0 41.8 16.8 ii0 ii0.0 18,6 112 I~1.8 Volume/Cap:0.37 0,37 1.22 I.Ii i.ii 1.13 0.88 0,~8 0.68 1,21 0,86 0-8’6 Delay/Veh:57.8 57.8 194.8 127,6 128 135,1 92.3 21.8 21.8 ~23,1 27,4 27.6 Delay Adj:1.48 1.48 1,12 1,15 1.15 1,12 1.00 1.00 1.00 1.00. 1,00 1.00 Pro~A~jPc~r:1,00 1.00 1,00 1.00 1,00 1.00 1.0O 1.00 l. O0 1.00 1,00 1,00 AdjDel/Veh:85.5 85.5 21%.i 146,7 147 151,~9~.3 21.8 ~1.8 2~3,i 2V.4 27.6DesignQu4ue;7 i0 42 ;[5 I0 39 13 72 i 20 90 4 Traffix 7.5,0615 (c) 2001 Dowllng Assoc. Licensed to CITY OF MEArLO PARK, CA FEB~i~-2002 08:41 CITY.OF MENLO P~K.G50328T935 P.IG/I8 I KEY.___~ ! .~.~, O -= Study lnt~rsectior xx rn’l = AM (PM) Peak Hour Traffic Volumes N Not to Scale 5~<.2575 Hanover Street Traffic Impact Analysis PROJECT TRIP ASSIGNMENT (NET.NEW TRIPS) FIGURE 8 -FEB-13-2002 88:41 CITY OF. MENLO PARK.650328?935 P.17/18 , Transportation .Con.~Itants Te~ (925) 284-3200 F~,: (925) 294-2691 J.anuary 7, 2002 To:Bill Phillips From:.lorry WaIte, r.s 2475 HanovetOfficc Trip Gga~rdtion C~icul~tiong .This m~mc~randum docun~i~ts trip, gene~tion c~ilculatiom prepared by Fehr & P~s Associatez (FPA) relating to tho pmposexl officodev¢lopn~nt at 2475 Hanover Street. This analysis d~t~rmined that the’project.would generate less thai 100 trips durifig the morning and ove, nlng periods. The~fom, a traffic study is not required for this site.. Supporting data is provided in Attar. ~ A. Scenario Pchr & Peers ¯ Approach City of Pals Alto (Mayfield) -.Ko~m Study City of P~o Alto-. Carl "’ stoffd H~otheti¢~l Worst ¯ Approach¯ . Credit for Oc~p.i~d . . Po~on of Existing Building at .Lowsr Trip Rm (31 KSl9 and Accurate Sp~e Utiliza6on 97 ~ps i.Represents highest AM or PM volumes 2.Does project cxceM I00 AM or PM trip thieshold? CITY COUNCIL: TEL 650.858.3380 FAX 650.328.7935 STEPHEN M. SCHMIDT MAYOR CHARLES M. KINNEY MAYOR PRO TEM MARY JO BORAK COUNCILMEMBER PAULJ. COLLACCHI COUNCILMEMBER NICHOLASP. JELLINS COUNClLMEMBER ADMINISTRATION: City Manager’s Office TEL 650.858.3360 FAX 650.328.7935 City Clerk TEL 650.858.3381 FAX 650.328.7935 Finance TEL 650.858.3443 FAX 650,327.5391 Personnel TEL 650.858.3370 FAX 650.327.5382 COMMUNITY DEVEL OPMENT: Building TEL 650.858.3390 FAX 65C ,327.5403 Environmental TEL 650.858.3411 FAX 650.327.5497 Planning TEL 650.858.3400 FAX 650.327.5497 Transportation TEL 650.858.3363 FAX 650.327.5497 HOUSING & REDEVELOPMENT: TEL 650.858.3414 FAX 650.327.1759 LIBRARY." TEL 650.858.3461 FAX 650.858.3466 PARKS & COMMUNITY SER VICES: TEL 650.858.3470 FAX 650.324.1721 POLICE DEPARTMENT," TEL 650.858.3300 FAX 650.327.4314 PUBLIC WORKS: Engineering TEL 650.858.3420 FAX 650.327.5497 Maintenance TEL 650.858.3490 FAX 650.327.1953 CITY OF MENLO \PARKj 701 LAUREL STREET, MENLO PARK, CA 94025-3483 www.menlopark.org February l4,2002 Amy French Senior Planner, City of Palo Alto 250 Hamilton Ave Palo Alto California RE: 2475 Hanover- Impacts at Hanover/Page Mill Thank you for the oppo(tunity to comment on the re-circulated Mitigated Negative Declaration (RMND) for 2475 Hanover Street. Menlo Park calculated the impacts of the proposed 2475 Hanover Street project at the intersection of Hanover/Page Mill using Highway Capacity Manual procedures and Palo Alto counting rules and standards. Those calculations appear in the attached memorandum fi’om Menlo Park City Transportation M.anager, Jamal Rahimi, dated February 11, 2002. PM peak hour results are summarized below. Hour Impact Change Palo Alt0 Standard PM Critical Delay (seconds)7.10 4.0 PM Critical V/C .015 .01 The peak PM impacts at Hanover/Page Mill exceed Palo Alto thresholds by 75% and 50% respectively and are stgnificant. The RMND fails to disclose these impacts as "potentially significant unless mitigated" in the appropriate section XV(a) and possibly XV(b). This impact was indicated by the Fehr & Peers study. Several citizens asked Palo Alto to independently calculate it using the correct project size, 51KSF project. Palo Alto ignored those requests. They are now confirmed. Palo Alto conducted no traffic study for 2475 Hanover Street. The "100-trip traffic study rule" is an administrative rule imposed by the County Congestion Management Agency (CMA) on Palo Alto telling it when to perform traffic studies required by the CMA. It answers the question, "Should Palo Alto submit a traffic study for the CMA?" It does not respond to the question, "Does the 2475 Hanover project create significant traffic impacts using Palo Alto’s standards of significance?" This administrate rule is not relevant to Palo Alto’s responsibility to discover and disclose significant impacts under CEQA. Neither the Fehr & Peers study or the Mayfield study serves as a valid estimate for the 2475 Hanover Project. Both analyze a 31KSF project instead ofa 5 IKSF project. Mayfield analyzes 2475 Hanover in the backgound of a cumulative scenario. It does not analyze Hanover individually. Letter to Amy French February 14, 2002 Page Two The impact at Hanover/Page Mill cited above is not specifically mitigated in the RMND. No calculations were made showing that intersection improvements cited in the Comprehensive Plan for Hanover/Page Mill will mitigate the significant impacts to less than significance. Citizens are entitled to see a description of the mitigations and comment on their adequacy. The intersection improvements for Hanover/Page Mill, apparently, will not be complete within the timeframe of the project. Therefore the impact will remain significant and unmitigated for some period of time. The RMND proposes no interim mitigations that would reduce the impact to less than significant..These intersection improvements are budgeted but apparently not programmed. There is some budgetary and political uncertainty about their eventual construction and there is some likelihood of further delay. None of this is discussed in the RMND. Build-out of the Comprehensive Plan is apparently well ahead of the pace assumed in the Comprehensive Plan EIR. Mitigations scheduled in the Comprehensive Plan should not be expected to keep pace. This would subject citizens to impacts not analyzed in the Comp Plan EIR. For a 31KSF project, the Mayfield study shows a cumulative volume increase ori California Ave in excess of 1500 vpd. This may constitute a significant cumulative impact for both the Hanover and Mayfield projects. Nearly 50% of this cumulative increase Is unexplained. No attempt has been made to analyze the cut-through traffic generated by this project on California or the nearby neighborhood. It may greatly benefit the neighbors to analyze this traffic in detail. Sincerely, Paul Collacchi City Councihnember Collacchi Letter 2-02 TRANSPORTATION DIVISION. 701 Laurel Street / Menlo Park, CA 94025-3483 / (650) 858-3363 / Fax (650) 327-5497 MEMORANDUM DATE: TO: THROUGH: FROM: SUBJECT: February 11, 2002 Council Member Paul Collachi David Boesch, City Manager Jamal Rahimi, Transportation Manager Traffic Impact Calculations - 2475 Hanover Street Per your request, we made the calculations using standard Highway Capacity Manual (HCM) procedures and the City of Palo Alto rules and standards to determine the traffic impact of the project at 2475 Hanover Street on the intersection of Hanover Street and Page Mill Expressway. Our assumptions and calculations are attached as the appendix. As presented in our summary of calculations (Table 1), the project does not have a significant impact on the intersection during the AM peak hour; however, it does have a significant impact on the intersection during the PM peak hour. attachments cc: City Council u:\rene b\traffic signal pro.~ectk24"/5 hanover street.doc To: Honorable Palo Alto City Council From: Joy Ogawa, 2305 Yale Street, Palo Alto, CA Date: RE: Letter 5: Joy Ogawa RECEIVED. FEB i’~ 2002 Department of ~annlng ano94306Community Environmenl February 18, 2002 Comments on the Revised Mitigated Negative Declaration for 2475 Hanover Street These comments to the Revised Mitigated Negative Declaration for 2475 Hanover Street are being submitted to the City of Palo Alto before 5:30 PM on February 19, 2002, which is the next business day following February 18, 2002, an official City of Paio Alto holiday during which City offices were closed. BASELINE IS INCORRECT There is substantial evidence on the record that shows the inaccuracy of the baseline used in the Mitigated Negative Declaration. The Revised Mitigated Negative Declaration fails to correct the baseline. The Site Was Vacant On The Baseline Date Under CEQA, the baseline should be the existing physical conditions at the project site at the time the environmental analysis was commenced, which, in this case is August 16, 2001, the date the application was filed. At the January 14, 2002 public hearing, staff (Lisa Grote), in response to a question from Council Member Lytle, indicated that on August 16, 2001, the site was "partially occupied." However, at least one document on file with the City contradicts Ms. Grote’s statement, and indicates that the site was vacant on August 16, 2001. The Monitoring Report For Fourth Quarter 2001 for 2575 Hanover Street, Palo Alto California, prepared for Alza Corporation by Aquifer Sciences, Inc. and dated’January 24, 2002 (hereinafter, ".Aquifer Sciences Report") includes the following description of the site on page 1 of the report: ALZA Corporation occupied the site from the early 1970s until 2001. ALZA developed and manufactured pharmaceutical products. ¯.. In early 2001, ownership of the site transferred from ALZA to Stanford Management Company, and ALZA vacated the facility. (Emphasis added) The fact that permits were obtained and a remediation system was installed in May and June of 2001 (see page 2 of Aquifer Sciences Report) is consistent with conclusion that Page 1 the buildings were vacated prior to this time. Thus, the Aquifer Sciences Report indicates that the project site was vacant on August 16, 2001. Prior Use Was Research & Development The report entitled "Soil and Ground Water Quality Evaluation, 1275 California Avenue and 2575 Hanover Street, Palo Alto, California," prepared for Stanford Management Company by Lowney Associates, and dated January 23, 2001 (hereinafter, "Lowney Associates Report") includes the following description of the site on page 1 of the report: The site appeared to have been used as agricultural land for row crops from at least 1955 until the construction of the two existing commercial buildings (1275 California Avenue and 2575 Hanover Street) in the early 1960’s. Alza Corporation reportedly used the site for pharmaceutical research and development and manufacture of pharmaceutical products since the early 1970’s. The 1275 California Avenue building was leased for 1 to 2 years by Caliper Technologies for microbiology research during the late 1990’s. The 1275 California Avenue building has been vacant for approximately two years. The 2575 Hanover Street building has been used for research and development purposes since late 1998 to early 1999. Both the Aquifer Sciences Report and the Lowney Associates Report state that the prior use of both of the buildings was for Research and Development purposes. There is no mention of either of the two buildings being used for Office purposes. XlI. POPULATION AND HOUSING, XIH. PUBLIC SERVICES, XIV. RECREATION and XV. TRANPORTATION/TRAFFIC - Mitigations areInadequate The impact fees mitigations described in the Revised Mitigated Negative Declaration only address the impacts of 30,428 square feet of the proposed development. The appropriate baseline under CEQA is a vacant property, which means that, under CEQA, the potentially significant impacts of 81,928 square feet of new office plus 2005 square feet of employee amenity area must be mitigated. Thus, the Revised Mitigated Negative Declaration has failed to mitigate the impacts of at least 206 new jobs. City staff admitted at the January 14, 2002 public hearing that the baseline is less than 51,000 square feet of occupied space, but City staff claims that 31,000 square feet of building was occupied on August 16, 2001 (a claim which has been refuted above). Even if City staff’s asserted baseline is used, the impacts of 20,500 plus 2005 square feet of Page 2 new development are left unmitigated by impact fees under the Revised Mitigated Negative Declaration. Note that, while the City continues to ignore the employee amenity area as being a potential source of environmental impact, additional workers may be needed to staffor service that employee amenity area, which means additional jobs whose impacts need to be included. Any trip reduction anticipated as a result of an employee amenity area will come during work hours, especially during the ltmeh hour, not during the AM or PM peak commute hours. Indeed, the workers who staff or service the employee amenity area are likely to add trips during the peak commute hours. TRANSPORTATION/TRAFFIC A Traffic Study Is Required Substantial evidence is on the record that the 100-new trip threshold is exceeded ira correct baseline is used. The Revised Mitigated Negative Declaration continues to apply an incorrect baseline of 3.1,000 square feet of"Offlee" use for the April 2000 date of the City’s most recent traffic counts, when the correct use, as verified bythe Aquifer Sciences Report and the Lowney Associates Report, was "Research and Development." Evidence is on the record that, if the multiplier for a correct prior use of"Research and Development" instead of"Office" were applied in the calculation, a total of 108 new trips would be calculated to result from the proposed project. Because the 100-trip threshold is exceeded, a traffic study must be done. CONCLUSION The Revised Mitigated Negative. Declaration is deficient and inaccurate and should NOT be approved. Page 3 Letter 6: John BacaFrench, Am~/ From: Sent: To: Cc: Subject: john baca [verdosa@hotmail.com] Tuesday, February 19, 2002 7:56 AM amy_french@city.palo-alto.ca.us; city-cou ncil@city.palo-alto.ca city_clerk@city, palo-alto.ca 2475 Hanover (01-EIA-15), Council Agenda Item 8 Feb. 19,2002 Palo Alto City Councilmembers Amy French, Senior Planner, City of Palo Alto Re: 2475 Hanover (01-EIA-.15), Council Agenda Item 8 Amy and Councilmembers, First I have a technical question, and, second, objections to approval of the revised Mitigated Negative Declaration. Is there planned, or possible, use of exterior copper at 2475 Hanover? If so, then this should be included as "Potentially Significant Unless Mitigated" environmental impacts in the checklist and discussion should be included. The obvious mitigation is a prohibition on exterior use of copper in the Conditions for Approval. The City of Palo Alto currently has no ordinance prohibiting use of exterior copper, but such an ordinance was due to be submitted to the city council within six months according to an email to me on Oct. 15, 2001 from Phil Bobel, Manager, Department of Public Works/Environmental Compliance. Stormwater runoff to the bay containing copper is a serious environmental issue and has been for many years. Comprehensive Plan Element N-33 addresses the copper problem, but the city has been slow to act. There is very real, very valid, reason notto approve the revised Mitigated Negative Declaration if CEQA law is to be followed. The February 15, 2002 comment about mitigations from William T. Phillips, Stanford Management Company, does not directly address CEQA requirements, while Dr. Antoinette Stein’s comments, dated February 13, 2002, address CEQA law, as well as assessing mitigations and requirements. Both comments are full of details. If the checklist is not proper, as seems this case with "potentially significant impacts" being ignored, and there is not discussion of impacts or possible mitigations in the revised document, then the revised Mitigated Negative Declaration is not to be approved. It would not be legal. For this project, the City Council has multiple comments referring in depth as to studies and mitigations, but does council or staff have sufficient specific knowledge, as well as have had time, to differentiate between opposing expert opinions? I think not. Prove it in your deliberations, if you please. There is a real need for a supplemental EIR in the area of the Research Park. I am sorry that such a study has been put off and may not even occur. There are cumulative impacts that need analysis. This is not about just 2475 Hanover. People need good analysis and good data to make good decisions. Sincerely, John Baca P.O. Box 18527, Stanford, CA 94309 650/473,0996 verdosa@hotmail.com Council,,Cit] Letter 7: Aseem Das From: Sent: To: Co: Subject: Aseem Das[aseerndas@hotnLf~.~ofr~]ER~ S 8FFI-~E Friday, Februa~ 15, 2002 1:3~ ci~_council@ci~.palo-alto.ca~ FEB ! 9 ~N 9:19 ci~lerk@ci~.palo-alto.ca,us 2475 Hanover Street Dear City Council I am a College Terrace resident and am writing to you in support of the additional required conditions to be met by Stanford for the 2475 Hanover Street development. ~iso, I fully support the council’s intention that future new development in the Research Park should not be approved until a supplemental EIR is prepared. With thanks Aseem Das 2211 Williams Palo Alto, CA Send and receive Hotmail on your mobile device: http://mobile.msn.com 46 To: Honorable Mayor and City Council of Palo Alto From: Toni Stein Date: February 19, 2002 Subject: 2475 Hanover Street CMR: 133:02 Letter 8: Toni Stein I previously commented to you in a memo dated Feb. 13th, 2002 regarding the Revised Mitigated Negative Declaration dated Jan. 30th 2002 for the 2475 Hanover Street project as proposed by Stanford Management Company. Since that date, Mr. William T. Phillips has written a response to statements and comments regarding traffic and environmental issues surrounding the project. I would like to formally object to a number of Mr. Phillips comments. Mr. Phillips has provided misleading and false information. I would like to clarify a number of important points: 1)The Lowney Associates report on file with the City of Palo Alto dated January 23, 2001 states: "... areas of buried debris may be present under on-site structures and may be encountered during grading activities. If impacted soil is observed or suspected following removal of the debris, it must be characterized and appropriately handled." (Page 6) "Under on-site smlctures" includes under the existing buildings which have not to date been examined. 2)The footprint of the underground garage is directly where site remediation is ongoing for chloroform. From the site maps on file Scheme D on sheet 7 of MBT Architecture Drawings shows the location of the underground parking garage. This proposed location is precisely at the same location as the chloroIbrm contamination reported by Aquifer Sciences in there June 13th, 2001 Exhibit B. 3)The Lowney Associates report dated January 23, 2001 on page 6 states that pesticides, DDT and heptachlor epoxide exist on the property directly across the street from residences. Geomatrix Consultants, Inc. in their memo dated Feb. t5th’ 2002 states: ~ " Off-site residential receptors may be potentially exposed via inhalation of dust that migrates off site..." "...and monitoring to verify management of windblown dust is bei.ng proposed during the development..." "Off-site residential receptors" includes residences across the street. The Revised Mitigated Negative Declaration for 2475 Hanover Street is incorrectly checked for Air Quality (Section III (b)) and for Hazards and Hazardous Materials (VII(d)). Both of these boxes should be checked as "potentially significant unless mitigated". Respectfully submitted, Toni Stein Letter 9: William T. Phillips STANFORD MANAGEMENT COMPANY Memorandum To: From: Date: Subject: Honorable Mayor and City Council of Palo Alto William T. Phillips February 15, 2002 2475 .Hanover CMR: 133:02 Addressed below are responses to statements and comments made regarding traffic and environmental issues in two items of correspondence that were included in the subject Council package. TRAFFIC ISSUES FROM FEBRUARY 9, 2002 LETTER OF MENLO PARK COUNCILMEMBER PAUL COLLACHI AND FEBRUARY 14, 2002 MEMO OF DOROTHY BENDER Paul Collachi Comments: Comment 1 (Page l, Paragraph 2)." "....the peak PM impacts at Hanover/Page Mill exceed Palo Alto thresholds... " Mr. Collacchi’s comment is not valid for the following reasons: The Project does not generate 100 or more peak hour trips mad, therefore, is not subject to analysis of intersection volume/capacity changes or delay. (Palo Alto City Manager’s .Report CMR: 466:01, January 14, 2002, page 3) Mr. Collacchi’s impact calculation does-not address "Project" impacts as defined by Palo Alto or Santa Clara County CMA. His calculation includes the effects of background traffic growth (the reuse of existing building space for its entitled Use) combined with the effects of the Project (the additional 31,000 square feet of building space). Therefore, his conclusions on changes in traffic delay and volume/capacity are not relevant to the Project alone. Subject: 2475 Hanover CMR:133:02 Page 2 of 6 Comment 2 (Page 3, paragraph 2): ... City should impose interim mitigation measures until intersection improvements a~e constructed ... Operation of shuttle bus service condition is an interim mitigation. Comment 3 (Page 3, last pm~agraph) : "...Mayfield study shows an increase in traffic of nearly 1700 trips per day on California Avenue. " The Mayfield Study estimated that such traffic would increase by over 1,400 trips over a day. This study estimated that over half of the trips would result from the "project". This study defined the project to include both the propoSed Hanover Project and the much larger proposed JCC facility. The remainder of the traffic was assumed to be growth in background. This background growth would include other projects in the area and was derived from historical counts. The Korve study concluded that the proj ect-related trips (Hanover and JCC) did not exceed the City thresholds for noticeable traffic impacts for residential streets. Dorothy Bender Comments: Comment 1 (Page 1, Paragraph 3): "Had the correct baseline been used, the thresholds used by the-County to determine significant impacts at CMP intersections would be exceeded ... " This comment was submitted prior to the January-14, 2002 City Council meeting, was responded to by Palo Alto Staff in the January 14 City Manager’s Report (CMR:466:01), and discussed thoroughly at the January Council Hearing. The Staff Report concluded correctly that the Project does not exceed the threshold that would trigger CMA concerns about the intersection. Comment 2 (Page 1, Paragraph 4): "... the number of new trips ... exceeds the l O0-trip threshold... " This comment was submitted prior to the January 14, 2002 City Council meeting, was responded to by Palo Alto Staff in the January 14 City Manager’s Report (CMR:466:01), and discussed at the January Council Hearing.. The Staff Report concluded correctly that the Project would not generate over 100 trips; and furthermore, that even the combined effects of the Project and background growth related to re-occupancy of the existing vacant space in the building would only represent 91 trips. 2770 SAND HILL ROAD MENLO PARK, CA 94025 PHONE: " 6501 926-0200 Subje.ct: 2475 Hanover CMR: 133:02 Page 3 of 6 Comment 3 (Page 2, first line): ",.. other intersections may also be impacted by the project, one such ... is El Camino Real/Cambridge." The traffic study addressed all of the intersections identified as potentially significantly impacted. E1 Camino Real/Cambridge Avenue is farther from the Project site than several other studied intersections that were found to have no significant impact, such as E1 Camino/California. Comment 4 (Page 2, second paragraph): "the site ... was not mentioned or analyzed in the Comp Plan EIR" The square footage added by the proposed Project, taken together will all other expansions to the Stanford Research Park to date, is within the cumulative additional square footage in the Research Park analyzed in the Comp Plan EIR. Comment 5 (Page 2 fourth paragraph): "There is no information ... showing that the proposed intersection improvement at Page Mill/Hanover will adequately mitigate ... " There are at least two published transportation studies that address improvements at this intersection. The first study is the TIBCO Campus Transportation Impact Analysis (July 2000) that was prepared by Fehr & Peers. The second study is the Korve Mayfield Study. Both of these .studies identified and evaluated various improvements at this intersection. The first improvement option, which is a restriping of the intersection, was evaluated in the Mayfield study. This study concluded that the intersection operation would improve the average delay by nearly 20 seconds in the AM and PM. The second improvement option that requires adding westbound and eastbound left turn lanes at the intersection was evaluated in both the TIBCO and Mayfield study. Both the Fehr & Peers study and the Korve study indicated that this improvement would improve the operation of the intersection to LOS E. II.ENVIRONMENTAL ISSUES FROM COMMENTS OF ANTOINETTE STEIN FORWARDED IN FEBRUARY 13, 2002 MEMO OF DOROTHY BENDER Ms. Stein’ s assessment of site conditions appears inaccurate and based on incomplete information. The following information is documented and currently on file at the City of Palo Alto’s Planning Office; Regional Water Quality Control Plant; Regional Water 2770 SAND IqlLL ROAD MENLO PARK, CA 94025 PHONE: " 650/ 926-0200 Subject: 2475 Hanover CMR: 133:02 Page 4 of 6 Quality Control Board, San Francisco Bay Region (RWQCB); and at the City of Palo Alto Fire Department. Historical Information As part of initial due diligence, Stanford hired Lowney Associates to conduct a Phase 2 investigation to identify potential, areas that could impact the environment. Lowney conducted the investigation on December 1, 2000, at locations where chemicals were used and stored on site. A total of 9 borings at 9 different locations were collected and analyzed for volatile organic compounds (VOCs), semi-v01atile compounds (SVOCs), polychlorinated biphenyl (PCBs), metals and pH. In addition, a total of 5 groundWater samples were collected and analyzed for VOCs. Soil samples collected in the native soil had concentrations below preliminary remediation goals (PRGs) for residential use, except for one sample for DDT. Concentrations of DDT were below PRGs for industrial/commercial site use (the proposed use for this site.). No VOCs were detected in groundwater beneath the site with the exception of low levels (1.2 to 2.6ppb) of chloroform detected in 3 samples at thenortheast corner of the property, near building. D. The report also mentioned the possibility of buried structures beneath the site. Stanford forwarded the report to Alza to review. (report on file with the city) In March 2000 Alza received closure from the City of Palo Alto for the industrial wastewater discrimination ~ank. In January and February of 2001, Alza conducted the remaining site facility closure with the City of Palo Alto Fire Department providing oversight. During closure, Alza removed all remaining buried sumps, tanks and piping from the property. Sampling beneath these items was conducted and the sampling results showed no impact to the environment above regulatory thresholds, except for the northeast corner of building D where chlorofonr~ was detected near the former vapor recovery unit. Once the ¯ chloroform was detected, Alza immediately notified Stanfordand the RWQCB. All sumps, tanks and piping were considered non-hazardous and were sent to either a recycling facility or a non-hazardous landfill for disposal. On March 8, 2001, the City of Palo Alto Fire Department granted closure, of building E (1275 California). On April 20, 2001, the fire department granted closure of building D, with. the following statement--"Since contamination has been found a Hazardous Materials Unauthorized Release Report has been generated and sent to the San Francisco Regional Water Quality Control Board." The noted release only applies to chloroform. All reports are currently on file at the Fire Department (closure letters and reports on file at the city) The RWQCB is providing regulatory oversight for the chloroform release. The chloroform contamination is limited in extent to an area of approximately 2500 square feet (that is, an area of approximately 50 feet by 50 feet) and is only located at the northeast corner of building D. The groundwater elevation is 25 2770 SAND HILL ROAD MENLO PARK, CA 94025 PHONE: " 650/ 926-0200 Subject: 2475 Hanover CMR: 133:02 Page 5 of 6 feet below the existing ground surface. Aquifer Science began operating a.vapor extraction and air sparging system at the site in June 2001. Prior to remediation, chloroform was detected in soil samples at concentrations up to 1600 ppb. After remediation began, 35 soil samples were collected from seven borings drilled in August and November 2001: Up to 17 ppb Of chloroform remains in soil in isolated areas. These concentrations are significantly less than the residential PRG of 79 ppb for chloroform in shallow soil. The analytical data demonstrate that operation of the remediation system has successfully remediated chloroform in soil. Prior to remediatio.n, the highest concentration chloroform detected in ¯ groundwater was 1,100 ppb. After remediation began, groundwater samples were collected from the air sparging and monitoring wells in July, August, September, and November 2001. The analytical data show that the extent of chloroform contamination in groundwater is limited to the immediate vicinity of the former vapor recovery unit. As of November 2001, the highest concentration in groundwater for chloroform in this limited area of the site is 160 ppb. Industry and StanfordStandards Stanford is required by law to notify future tenants and all contractors regarding site conditions. Stanford has made the notifications. The contractor must prepare Health and Safety Plans to meet site conditions and have trained personnel. Stanford’s policy requires that any soil imported or exported from its land be chemically.tested. Potential buyers of the soil or landfill will not accept the soil without analytical information. Sampling is planned for the exported soil. We do not anticipate finding any impacted soil based on the data previously collected. Dust mitigation measures are. required by Stanford’s air permit, which has been obtained for demolition and site grading. The entire site will be graded, and the top 2 to 3 feet of soil will be removed. In the location of the underground garage, the excavation will extend to appropriately 14 to 16 feet below ground surface. Risks and Risk Management Alza has agreed to monitor the excavation of the site and has hired Aquifer Science to perform the work. Aquifer Sciences has provided to Stanford the surveyed location of the Chloroform groundwater in relationship to the footprint of the new buildings and 2770 SAND HILL ROAD MENLO PARK, CA 94025 PHONE: " 650/ 926-0200 Subject:’ 2475 Hanover CMR: 133:02 Page 6 of 6 underground garage. The area of impacted groundwater is not beneath the building or garage footprint. (on file .at the city) Health risk-Geomatrix independently reviewed the data generated by Lowney with respect to the potential for human health risks as a result of the presence of pesticides in shallow, on-site soil. Geomatrix concluded that the screening analysis used in the Lowney report is conservative, and, under the future use scenario for the site, concentrations of pesticides in soil, if left in place, do not pose a risk to human health. Geomatrix’s letter summarizing its review is attached separately. The pesticides detected in shallow soil at the one location will be removed during site grading and properly disposed. These pesticides are non-volatile and, using standard dust suppression practices as required by permit, will not present a public health risk to persons on, or in the vicinity of, the site. 2770 SAND H1LL ROAD MENLO PARK, CA 94025 PHONE; " 650/ 926-0200 1 ~h Fl~or February 15, 2002 Project 1909 !~.OMATi:IIX Ms. Annette Walton Stattfotd~.anagcmeat Company 2770 San Hill Koad Menlo Park, California 94025 Subject:Data Review 1275 California Avenue and 2575 Hanover Street Palo Alto, California De~ Ms. Waltor~: As you requested, Oeomatrix Consultants, Inc. (Geomatrix), reviewed the analytical results for soil and grab groundwater sampling recently collected by Lowney Associates (Lowney) at the s~bjeet site, We did not review the sampling locations or data that may have been generated at the site by others. The purposb of our ~¢view wan to evaluate whether eonsfituen~ detected in soil at the site posed a risk to human health during construction artd long:term occupmcy of the site. We understand that the proposed site use is commercial, md that the upi~r foot lo two feet of soL1 across the site will be graded and likdy exported. Bdow-gtade parking and v,vo 2] ,000 square-foot buildings will be built on the 4.7-acre site. The data generated by Lowney indicates that, in general, on-site soil is not i~pactcd by.volatile organic L~mpounds (VOCs), semi-volatile orgmaic compo~tud~ ($’VOCs), or polychlorinated biphcnyls (PCBs). One soil sample collected ~pmximately 4.5 feet below ground surface contdned bis(2-ethylhexy)phtl~late at a low concentration, This constituent is a plasticizer, and is commonly detected as a ~zult oft.he use of plastic gloves and other plastic equipment during environmental sampling. Metals were detected within background eot~e~tradons. Based on the ¥OC, SVOC, PCB, and metals data gen~rarzd, we conclude that no adverse environmental impacts frorrt these analytes are present at the locations evaluated. Surface soil contained low co[tcentrations of o~ganochlorine pesticides, including DDT, heptachlo, r epoxide, alpha-ehlordane~ and gamma-ohlordar~e. The residenfiW preliminaryr~m~diat~on goals (PRGs)1 used ~o evaluate ~b,e concentrations of the organochlor~e p~ticides are based on multiple.exposure pathways, including ingestion, direct conta9% and Lrdaalation and assume that a person lives on .txhe site for 365 days per year for 30 years, As the site is being developed for cornraercial/ind~£al use and the duration of eo~astruetion is short relative to 30 years, ~esideutial PKGs are highly conservative screen.hag levels-for this site. The maximum concentrat~o:as of each of’the orga~oehlorine pesticides detected are well below t~ir respecfiw iadustda~ PKGs, whMa ate more appropriate screening eoneen!.rations gNen the chemicals dew.cted, the proposed future eke use, and the short duration over whida a constrtt~on worker will be work[n~ at the site. ~ United Sta~s Envkonmenta[ ~rotection Agenw!. Keglon 9, PrdiminaW l~m~di~on Ooal~, 20~0. t, J Ms. Annette.Walton Stanford Managemeat Company February 15, 2002 Page 2 of 2 ,.~ laL’~A’rletlX., Maximum Concentration in Soil 1.17 0.16 0.62 0,32 Indu~rial PRO il~1on~) DDT Alpha-chlordane Gamma-chlordane * Conc~n~ation~ in part~ p~r million (ppm) 0,27 Off-rite residential receptors may be potentially exposed via inhalation of dust tha~ migrat~ off site, which is the ][east significant of the pathways considered in developing the PK(3. The off- site concentrations would be significantly l~s than on site, and morftoring to verify management of windblown dust is being proposed during the development. Therefore, for future development of ~e site, the concentrations of pesticides in soil at this si~ do not pose a public health, ri~k. We appreciate the opportunity to pmvido consulting serv~ee~ to Stanford Manage:dent Company. Please call either of fla~ undersigned if you have any further questions..,~ Sinc~rdy yours~ GEOMATRIX CONSULTANTS, INC. Ann M:~Iolbmw S~ior Toxicologist Susan M. Gallardo, PE Principal Engkw.er French, Amy From: Sent: To: ’ Subject: Derek Whitworth [Dw@rb2.swrcb.ca.gov] Friday, February 15, 2002 1:09 PM amy_french @city. palo-alto, ca. us Re: 2575 Hanover Street Palo Alto Letter 10: Derek Whitworth Ms Amy French: I am responding to the email information attached to this response and the fax of the Memorandum from Dr. Antoinette Stein dated Feb 13, 2002. On March 20, 2001, ALZA signed an agreemen(with the San Francisco Regional Water Quality Control Board for Board oversight of remediation work on the Hanover St site. This effectively made the Board the lead agency for environmental oversight. Investigations completed in February 2001 had shown very localized soil and groundwater contamination by chloroform. Chloroform had been used by ALZA in its manufacturing operations and the contamination found in the soil was close to where it had been used. The chloroform was at a depth in the soil that it could pose a potential threat to groundwater. After submission and review by the Board, remediation work, primarily soil vapor extraction, started in June 2001 and, based on subsequent reports prepared by Aquifer Sciences on behalf of ALZA, has been very effective in reducing the concentration.of chloroform. ~n interruption in power supply had caused a change in the remediation operations to address the final traces of contamination. It is expected that the remaining spots with the highest contamination will remediated to non-health-risk levels using the criterium of drinking water. My understanding is that this property, formerly industrial, is being redeveloped for commercial uses and it will not be used for residences. I understand that for evaluating health risk on commercial and industrial sites then a one in one hundred thousand excess cancer risk would be appropriate. If one is using the Region 9PRGs, use the industrial screening numbers. Similarly if using the SFRWQCB Risk Based Screening Levels look at industrial. For chloroform and drinking water other numbers apply. When we looked at the data our concern was for impact on groundwater. We did not review data for near surface soil samples so I cannot comment On the concentrations and associated risks in the original report. Reviewing the attached fax I can note that a DDT content of 1 ppm (or greater) would render such was~te hazardous if moved off site but soil with less than 1.7 mg/kg does not pose a health risk even in a residential scenario. Clearly that soil should be left on site. One of those quirks of regulations. For heptachlor epoxide the PRG industrial soil is 330 ppb and the PRG residential soil is 49 ppb. A reading of 0.16 ppb is insignificant and I don’t understand why this is raised as an issue. If you want further information please contact me. Derek Whitworth, Ph.D., PE (Chemical) ...... As I mentioned I worked for 13 years with the DTSC office in Berkeley and moved over to the Water Board on Feb 5, 2001. French, Am~/ From: Sent: To: Subject: Derek Whitworth [Dw@rb2.swrcb.ca.govl Tuesday, February 26, 2002 3:56 PM Amy_french@city. palo-alto.ca, us test MemotoWaltot~doc This is a follow up to my earlier email to Amy. My understanding is that this site is zoned commercial - industrial and you are not proposing to build housing on top of it. The appropriate look-up numbers would be those for soils on industrial sites. Using U.S. EPA Region 9 "PRGs" in its present use then ifDDT were on site in the soil 12 mg/kg or less then this would not pose a problem to people working on the site where they would have direct contact with the soil. For heptachlor epoxide, also detected, the corresponding level would be 0.27 mg/kg. The Lowney report has corresponding 95%UCL numbers of 0.74 and 0.10 mg/kg both below thresholds for risk. Since these levels would not pose a risk to people on site, it follows that they would not pose a risk to people off-site. " The SFBRWQCB Risk Based Screening L.evel report (Dec 2001.) has numbers of 4 mg/kg for DDT and 0.014 mg/kg for heptachlor epoxide. I will have to talk to Roger Brewer of this office (he is reponsible for compiling the report) to see why there is such a deviation between the USEPA heptachlor number and the one t~om the Board. I will do that’as soon as I see him and then let you know. I understand however that you are in fact removing the top two to three feet of soil from the site so the residual levels of contaminants will .be insignificant and below the Risk Based Screening Levels and thus no issue of health risk from these contaminants. For off site disposal of the soils you will be collecting composite samples to classify the soil for proper disposal. Based on the data provided in the Lowney report the composite concentrations can be expected to be below the levels that would classify the waste as hazardous. The hazardous waste thresholds are: TTLC for heptachlor of 4.7 mg/kg (the TCLP is 0.008 mg/L) TTLC for total DDT is 1.0 mg/kg I believe you can project that the soils leaving the site will be non-hazardous. I hope this is helpful. Please contact me again if you want further information. Derek Whitworth, PhD, PE Water Resources Control Engineer