HomeMy WebLinkAboutStaff Report 10148
City of Palo Alto (ID # 10148)
City Council Staff Report
Report Type: Action Items Meeting Date: 6/10/2019
City of Palo Alto Page 1
Council Priority: Climate/Sustainability and Climate Action Plan
Summary Title: Zero Waste – New Deconstruction and Foodware Reduction
Requirements
Title: PUBLIC HEARING: Adoption of Three Ordinances Amending Title 5
(Health and Sanitation) of the Palo A lto Municipal Code to: 1) Establish New
Disposable Foodware Requirements, Including Restrictions on the use of
Plastic Straws, Cutlery, Stirrers and Related Items, and Provision of Printed
Receipts at Food Service Establishments; 2) Establish Regulations R elated to
Produce Bags at Retail Service Establishments; and 3) Require Deconstruction
and Source Separation of Construction and Demolition Related Materials to
Maximize Salvage and Reuse of Building Materials, and Increase Recycling
and Diversion from Lan dfills; Adoption of a Negative Declaration for New
Deconstruction Program Activities; and Finding the Disposable Foodware and
Refuse Collection Ordinance to be Exempt Under California Environmental
Quality Act (CEQA)
From: City Manager
Lead Department: Pub lic Works
Recommendations
Staff recommends that Council:
1. With respect to a proposed Ordinance for Disposable Foodware and Produce Bags
(Disposable Foodware Ordinance):
a. Find the Ordinance is exempt from California Environmental Quality Act (CEQA)
in accordance with CEQA Guidelines Sections 15061(b)(3), 15307 and 15308; and
b. Adopt an Ordinance (Attachment A) amending Chapters 5.30 and 5.35 of Title 5
of the Palo Alto Municipal Code, to: (1) regulate the use of disposable foodware,
including restricting the use of plastic straws, cutlery, beverage plugs, stirrers
CITY OF
PALO
ALTO
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and other accoutrements, and the provision of printed receipts at food service
establishments, and (2) restrict the use of plastic produce and meat bags at retail
service establishments including grocery stores and farmers markets; and
2. With respect to a proposed Ordinance for Refuse Collection (Refuse Collection
Ordinance):
a. Find the Ordinance is exempt from California Environmental Quality Act (CEQA)
in accordance with CEQA Guidelines Sections 15307 and 15308; and
b. Adopt an Ordinance (Attachment B) amending Chapter 5.20 of Title 5 of the Palo
Alto Municipal Code, to restrict refuse collection bags to particular types and
colors, and other clarifications to make waste sorting more effective and
facilitate monitoring; and
3. With respect to a proposed Ordinance for Deconstruction and Construction Materials
Management (Deconstruction Ordinance):
a. Adopt a Resolution (Attachment C) adopting the Negative Declaration
(Attachment D) for the Ordinance for Deconstruction and Construction Materials
Management as adequate and complete under the CEQA; and
b. Adopt an Ordinance (Attachment E) replacing Chapter 5.24 with a new Chapter
5.24 to Title 5 of the Palo Alto Municipal Code, to establish deconstruction and
construction materials management requirements for demolition projects.
Executive Summary
In August 2018, Council accepted the 2018 Zero Waste Plan containing 48 initiatives that will
help the City meet its sustainability and climate action goals. The proposed Disposable
Foodware, Deconstruction, and Refuse Collection Ordinances implement key provisions of that
the Zero Waste Plan.
Background
The 2018 Zero Waste Plan was developed in response to Palo Alto’s Sustainability/Climate
Action Plan (S/CAP) Framework adopted by Council in 2016. The S/CAP set a new goal of 95
percent of waste generated in Palo Alto to be diverted from landfills by 2030. The City’s most
recent Zero Waste Plan was accepted by Council in August 2018 after approximately 10 months
of staff and consultant work and stakeholder engagement includ ing community workshops, an
online survey and individual feedback from community leaders. The plan contains 48 initiatives
that could help the City meet its zero waste objectives. According to the Zero Waste Plan
estimates, the adoption and execution of the Disposable Foodware and Deconstruction
Ordinances and related actions will result in the implementation of five key short term
initiatives.
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Disposable Foodware Ordinance - Background
Disposable foodware items and single-use non-recyclable produce bags are intended to be used
once and then discarded. Although most plastics are recyclable in Palo Alto, small plastic items
are generally not recoverable at the sorting facility because they fall through the sort screens
and end up as residuals that are landfilled. These items pose waste management challenges
and can persist in the environment for many years, causing harm to wildlife and blight to
waterways. Plastic discards are being found in rivers, bays, oceans, and are a litter nuisance and
an environmental hazard to marine animals who often mistake pieces of plastic for food. In
2018, Girl Scout Troop #60016 teamed with the City to create a Straw Awareness Campaign to
end plastic straw pollution and waste in Palo Alto. The scouts highlighted that 500 million
straws are used each day in the United States and that plastic straws and stirrers are among the
top 10 marine debris items found on beaches. Plastics are hard to break down and stay a long
time in the environment. The United Nations Educational, Scientific and Cultural Organization
(UNESCO) Intergovernmental Commission website facts and figures on marine pollution
identified that more than 1 million seabirds and more than 100,000 marine animals die each
year from plastic pollution. A Proceedings of the National Academy of Sciences of the United
States of America (PNAS) study titled “Threat of plastic pollution to seabirds is global, pervasive,
and increasing” estimates that by 2050 99 percent of all seabirds will have plastic in their
digestive system.
Deconstruction Ordinance - Background
Over 40 percent of the waste from Palo Alto disposed in landfills, about 19,000 tons, is from
construction and demolition related projects (see Chart 1). This waste is produced during the
process of demolition, construction, renovation, or remodels of stru ctures, when materials are
typically combined and mixed into a large debris box or self-haul truck and then transported to
a processing facility and at times directly to a landfill. This material is often referred to as mixed
construction and demolition debris (C&D). Mixed C&D typically includes a comingled mix of
concrete, asphalt, wood, metals, gypsum wallboard, roofing material, glass, carpet, bricks,
rocks, dirt, trees, stumps, vegetation, rocks, and dirt. It also includes cardboard, which is
typically generated in the final stages of construction as products, such as kitchen cabinets, are
delivered and installed.
Chart 1: Breakdown on the Source of Landfilled Materials
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Additionally, according to the 2017 Waste Characterization Study of Palo Alto’s waste stream
and the profile analysis on loads of mixed C&D debris delivered to the Zanker Material
Processing Facility, about 92 percent of Palo Alto’s mixed C&D materials are recyclable or
compostable through current programs serving the community and would yield a higher
recovery if the materials could be source separated. Table 1 shows the top six material types
found in mixed C&D that can be recycled to nearly 100 percent when source separated,
compared to at best 80 percent recovery when processed as mixed C&D. Further, while
recycling is beneficial and important, it is not necessarily the highest and best use of all
materials, especially for old growth lumber and unique architectural features that can be
reused.
Table 1: Top six materials found in mixed construction and demolition waste - comparing
recycling percentage (recovery) of mixed C&D to source separated materials
Material
Estimated
Percent in
Mixed C&D
Mixed C&D
Recycling
Recovery
Recovery if
Source
Separated
Gypsum 54%
Recovery ranges
from 71% to
80%
93%
Clean wood 23% 95%
Clean engineered wood 14% 95%
Inerts - concrete 5% 98%
Clean, flattened cardboard 4% 99%
Currently, construction and demolition projects are required to meet the City’s Green Building
requirements to achieve an 80 percent diversion rate with material taken to local C&D recycling
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facilities. The recovery rate of these materials ranges from 71 percent to 80 percent depending
on whether the loads have higher volumes of concrete, which is a material that is easily
recyclable but skews overall project recovery rates due to its heavier weight . In addition, all
single‐family residential projects obtaining a whole house demolition permit ar e required to
complete a deconstruction/salvage survey provided by a third‐party entity approved by the
Chief Building Official. The City requires all permittees with projects valued over $25,000 to
track the weights of materials removed from project sites into Green Halo, a web-based service
for waste diversion and recycling tracking. Overall, compliance with existing Green Building
requirements is high, but there are still projects sending C&D materials directly for landfill
disposal and there is little salvage or reuse occurring.
Discussion
Five of the key short term initiatives included in the 2018 Zero Waste Plan are being
incorporated into the following actions:
1. Development of a new Disposable Foodware Ordinance to reduce and restrict the usage
of foodware items (mainly plastics) at food service locations with a goal of reducing
plastic waste in the environment.
2. Development of a new Deconstruction and Construction Materials Management
Ordinance (Deconstruction Ordinance) that would require demolition projects to use
deconstruction methods (instead of demolition) and materials to be source separated to
maximize the salvage of materials for reuse, to increase diversion of recycl able
materials, to reduce the amount of landfilled waste, and to reduce greenhouse gases.
A scope of work to provide a new ongoing deconstruction collection program was added to the
amended and restated GreenWaste agreement, approved by Council in January 2019. In
addition to the GreenWaste related annual ongoing expenses of $567,000 and $243,000 in one-
time expenses, staff estimates $118,000 of additional one-time expenses for consultant
services at the Development Center to assist in outreach and education to the community and
stakeholders on the new deconstruction requirements in the initial year. Staff will request
Council approval for these expenses separately as part of the budget development process.
Staff does not anticipate the City incurring additional expenses to implement the Disposable
Foodware Ordinance; implementation will be accomplished with existing staff resources.
The adoption and implementation of both the Disposable Foodware and the Deconstruction
Ordinances would have a significant effect on increasing the City’s waste diversion. In the Zero
Waste Plan, it is estimated that these ordinances, when fully implemented in accordance to the
Zero Waste Plan, will decrease disposal in landfills by more than 8,220 tons and reduce
greenhouse gas emissions (GHG) by 22,770 metric tons of carbon dioxide equivalent (MTCO2e),
see Table 2. These changes begin to reduce the use of disposable foodware and to become
substantially more sustainable. Both ordinances will aid in achieving the City’s Zero Waste and
S/CAP goals.
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Table 2: Annual Waste Diversion and GHG Emission Benefits of Ordinances When Fully
Implemented in Accordance to the Zero Waste Plan
Ordinance
Diversion
Potential
(Tons)
GHG Reduction
(MTCO2e)
Disposable Foodware Ordinance 290 470
Deconstruction Ordinance 7,930 22,300
Total Reduction 8,220 22,770
Disposable Foodware Ordinance - Chapters 5.30 and 5.35
This Disposable Foodware Ordinance would restrict the use of plastic straws, utensils, stirrers,
drink plugs, and other small plastic food accoutrements and require these items to be
compostable or reusable, and only provided to customers upon request or via a self-serve
station. The Disposable Foodware Ordinance would also ban plastic produce and meat bags
from grocery stores and farmers markets. If grocery stores and farmers markets provide
disposable bags for meat/produce, the bags would be required to be compostable.
The above group of restrictions are Phase I of a larger Foodware Items Reduction Plan
developed by Staff, which contains a Phase II and a Phase III (Attachment F). These later two
Phases also implement the 2018 Zero Waste Plan accepted by Council. Phases II and III would
be proposed for adoption as an Ordinance in approximately one year, after further verification
and stakeholder engagement work is completed by staff.
As of March 2019, numerous cities in California have passed their own requirements limiting
the use of certain plastic foodware items (see Table 3). The City and County of San Francisco,
City of Berkeley, the City of Alameda, and the City of Malibu have banned the use of plastic
straws and require compostable straws be provided only upon request. As of January 2019,
Assembly Bill 1884, requires full-service restaurants in California to only provide straws upon
request, but it exempts fast-food restaurants.
Table 3: Summary of Other Jurisdictions’ Disposable Foodware Ordinance Requirements
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Requirement/Jurisdiction San
Francisco Berkeley Alameda Oakland Santa
Cruz Malibu Palo
Alto
Prohibits single-use plastic
foodware items. X X X
Requires foodware items
including straws to be
compostable.
X X X1 X2
Requires single-use
foodware items only upon
request or in a self-serve
area.
X X X X X X
Requires disposable
foodware to be
acceptable in the City’s
composting or recycling
collection program.
X X X X
Single-use straws allowed
only upon request. X X X X X X X
Requires produce/meat
bags to be compostable
or reusable.
X
1 If "affordable" – purchased by food vendors for same or less purchase cost than non-
biodegradable alternative.
2 Includes only straws, utensils, stirrers, drink plugs, food picks, and drink accoutrements.
Based on research of publicly available bulk product pricing, staff estimates that compostable
foodware costs between $0.01 to $0.02 more per item on average. Compostable produce bags
in grocery stores are estimated to cost between $0.09 to $0.15 per bag more than regular
plastic produce bags. These costs are expected to be passed on to the consumer.
The small plastic items that would be restricted are subject to being moved by wind and
rainwater and therefore are more prone to get into the environment as litter. This ordinance
would reduce the amount of these small plastic items and therefore protect the City’s
waterways and environment. It would reduce the number of single-use plastics along roadways,
keep these items out of storm drains, and it would reduce the amount of plastic waste going to
the landfill. The Disposable Foodware Ordinance would also reduce the amount of
contaminants in the City’s green compost containers and reduce the confusion on what to do
with these items by requiring them to be compostable. Requiring produce/meat bags to be
compostable keeps plastic bags out of the creeks and streets, allows the produce bag to be
composted, and allows the compostable produce bag to be beneficially reused at home as a
compost bucket liner. Another key change proposed for Chapter 5.30 includes requiring food
service establishments to provide a printed receipt only upon request.
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Disposable Foodware Ordinance - Stakeholder Engagement and Feedback
In December 2018, the City contacted stakeholders, mainly food services establishments (FSEs),
located in Palo Alto for feedback on concepts for a draft ordinance. A postcard notifying FSEs of
the proposed change to the ordinance with a link to an online survey were sent out to all 439
FSEs within the City. Approximately 300 in-person surveys were conducted by the Girl Scouts
(Troop #60016), Gunn High School marine biology class students, a volunteer Zero Waste Block
Leader, as well as GreenWaste and City staff. An additional 12 in-person surveys were
conducted at grocery stores specifically to get feedback from store owners and managers
regarding produce bags. For Food Service Establishments that could not be surveyed in -person,
183 emails and phone calls were made to reach out and gather feedback. Stakeholders
reported they were concerned about the additional costs of switching to compostables, that it
would be difficult finding compostable foodware items, and that compostable foodware items
could still result in litter. The stakeholder survey findings include that about 1/3 of food service
establishments already use some compostable foodware and 52 percent of respondents said it
would be easy to switch to using compostable foodware. T o assist FSEs in finding compostable
foodware products, staff will conduct outreach and provide compostable foodware vendor
information and make that information available online on the Zero Waste website.
Compostable foodware can be placed in the existing City’s green compost containers for
collection and processing as compost. Current petroleum-based foodware products do not
easily breakdown and can persist for years in the environment and are harmful to wildlife.
Requiring compostable foodware is the first step in transitioning FSEs from using single-use
plastic (petroleum based) foodware to compostable foodware, and ultimately to reusable
foodware.
On May 14, 2019, Council received input from a group of plastic use reduction advocates
requesting that Council adopt, as an Ordinance, not just Phase I but Phase II as well. Staff
intends to propose Phases II and III for adoption as Ordinances approximately one year from
now, following feasibility verification for much of Phase II and III.
The Disposable Foodware Ordinance would go into effect January 1, 2020, to all Food Service
Establishments. The produce bag requirement would go into effect July 1, 2020, to all grocery
stores and farmers markets.
Deconstruction Ordinance - Chapter 5.24
Since construction and demolition materials represent more than 40 percent of the total
materials from Palo Alto that are disposed in landfills, their management plays a critical role in
achieving the City’s diversion goals. While some of this waste cannot be recycled or reused (e.g.
insulation, painted or treated wood), much more of it could be reused, recycled , or composted.
As a result, this waste represents a significant opportunity for diversion and recovery of
materials from landfill disposal, which led to staff developing a draft deconstruction ordinance.
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Deconstruction and source separation of construction and demolition related waste focuses on
handling discards as resources rather than waste. It leads to highest and best use of materials
(reuse), higher recovery levels, and greater recyclability of materials. Deconstruction also
follows preferable waste management and zero waste hierarchy of reduce, reuse, recycle and
compost, and reduces the volume and toxicity of waste in landfills.
Deconstruction involves buildings or structures being systematically taken apart thereby
allowing materials to be kept unbroken and separated, making it easier to reuse and recycle.
This differs from traditional demolition, where an excavator knocks down a whole building with
all the materials within the structure being smashed and combined into a container. Complete
demolition costs less than deconstruction primarily because it takes less time to demolish an
entire building and fill containers with the mixed waste. The demolition portion of a residential
project is estimated to cost in the range of $8 to $12 per square foot and would take a couple
of days to complete the work using an excavator and a crew size of two to three people.
Alternatively, the same phase of the project if deconstructed is estimated to cost in the range
of $22 to $34 per square foot (based on two recent pilot projects that the City has performed),
and would take about 10 to 15 working days to deconstruct manually utilizing a crew size of
four to eight people depending on the project complexity and percentage of salvageable
materials. Project costs vary widely based on factors such as building age, size, material type,
presence of asbestos or lead, and location of the project. Commercial projects typically have a
much wider range of possible costs and schedule needed to deconstruct a building depending
on the size and the type of construction material composing the structure. It should be noted
that large commercial sites have already been doing a significant amount of deconstruction and
source separating the recovered materials as it saves disposal costs. Further, some of the
deconstruction costs can be offset by the tax incentive of donating reusable materials and
items, which could allow some projects to experience reduced disposal costs. There are also
points available to deconstructed projects pursuing certification under the Leadership in Energy
and Environmental Design (LEED) Rating System.
The deconstruction of a building takes several days longer than a standard demolition and
would cost more for the “demolition” portion of projects, but the environmental benefits
would be significant. According to the Environmental Protection Agency and the City of
Portland, one of the leaders in deconstruction, up to 25 percent of materials can be reused in
some residential buildings and up to 70 percent of materials can be recycled (equivalent to 95
percent diversion potential). Some recoverable materials and items that can be salvaged for
reuse include the following:
• Appliances
• Cabinets
• Lumber
• Windows and doors
• Electric and plumbing fixtures
• Hardwood floors
• Architecture antiques
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The Deconstruction Ordinance would require the following:
• Deconstruction of buildings and structures (instead of demolition) and source
separation of materials for reuse, recycling, and reduction of disposal in landfills.
• A salvage survey listing reusable materials and items to be completed and submitted
prior to demolition or building permit issuance.
• Source separation of building materials to increase recovery and recycling.
• The City’s contractor, GreenWaste of Palo Alto (GreenWaste), would be the only
container provider (for bins or debris boxes) at project sites. This will ensure higher
recyclability and diversion and increase compliance with facilities that have higher
recovery rates.
• Self-haul of materials in trucks would still be allowed, but materials would be source
separated in accordance with ordinance requirements and City regulations, and
materials would be taken to City approved processing facilities .
• All projects would be required to utilize the standard containers for collection of
traditional recyclables in a blue recycling container (e.g., cardboard, metals, plastics),
and collection of compostables in a green compostable container (e.g., trees, brush,
vegetation, leftover lunches from workers).
• All materials would be delivered to City-approved recovery and processing facilities.
• Documentation to be submitted to the City showing the materials/items identified in
the salvage survey were received by an approved reuse organization.
The Deconstruction Ordinance would apply, effective July 1, 2020, to all residential and
commercial projects undergoing a whole structure demolition (unless the project is comprised
solely of an Accessory Dwelling Unit demolition). Staff estimates that the ordinance would
affect approximately 114 projects annually.
After implementation of this initial phase applicable only to whole structure demolitions, staff
anticipates returning to Council to propose a phased expansion of the program to include
construction, partial demolition, and remodel/renovation projects. The Ordinance does not
address these later phases, and an amendment to the Ordinance would be required to
implement them.
To facilitate source separation of materials from smaller projects, the GreenWaste agreement
(approved by Council in January 2019) includes provisions for a new collection service with
smaller bins to collect source separated deconstruction materials to accommodate smaller
projects or sites with small footprints. GreenWaste will use their operations yard at the City-
owned old Los Altos Treatment Plant (LATP) to consolidate source separated materials for
transfer to the Zanker Material Processing Facility in San Jose.
Compliance with the Deconstruction Ordinance would be verified by City Zero Waste staff,
GreenWaste drivers, supervisors, and outreach staff who are in the field already checking on
other Zero Waste requirements.
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Deconstruction Ordinance - Stakeholder Engagement and Feedback
The draft concepts for the Deconstruction Ordinance and related Zero Waste Plan initiatives
were presented to stakeholders between January and November 2018. The concepts shared
involved a broader scope, not limited to whole building demolition projects as now proposed,
and included application to construction and remodel projects that staff anticipates
recommending for ordinance adoption in two later phases. The three phases are described in
attachment G.
Staff advertised and conducted four public workshops and an online survey to solicit feedback
from the community and stakeholders. Two of the workshops were focused specifically on the
draft concepts for the Deconstruction Ordinance and were offered exclusively to approximately
1,200 contractors, developers and architects who regularly work on projects in Palo Alto. These
stakeholders were also sent the initial draft ordinance concepts through direct e-mail. Overall,
residents were overwhelmingly in support of initiatives and concepts, and contractors said it
could be done but had concerns. A few themes emerged from the contr actor stakeholders’
feedback:
• A $25,000 value threshold of projects was too low for the deconstruction, salvage and
source separation requirement;
• Education and outreach on new requirements and on proper materials sorting would be
critical to success;
• Standards should be created for salvage surveys and reuse organizations;
• Concern of limited space in some construction sites for source separation activities.
As a result of feedback from stakeholders, Staff modified the proposed concepts for the
deconstruction ordinance, removed the later phases that would apply the ordinance to
construction and renovation projects, and focusing on whole building demolitions in this initial
ordinance.
Deconstruction Ordinance - Other Jurisdictions
Deconstruction and source separation of materials for reuse and recycling is the key to
achieving zero waste goals for most jurisdictions and some have begun implementing
deconstruction requirements. These requirements range from simply encouraging salvage and
reuse, to others that have specific deconstruction requirements. The most well-known
deconstruction ordinance is from the City of Portland . It went into effect in 2016 and it applies
to houses built before 1916, which represent about one-third of all their residential
demolitions. Portland staff reports that the ordinance has been successful in diverting more
materials to salvage and reuse, and they will be expanding their ordinance to include a greater
inventory of projects. Portland also reports that the ordinance has gene rated employment
opportunities, and deconstruction sites tend to produce less dust and noise compared to
traditional demolition locations. Other cities that have followed with similar requirements
include Seattle, Milwaukee, and most recently Vancouver in British Colombia. Local cities
including San Francisco, Oakland, Alameda, Redwood City, and San Mateo County are also
considering similar policies; however, the City’s proposed Deconstruction Ordinance would
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apply to the largest percentage of the cities’ b uildings and would achieve the highest diversion
of materials from landfill disposal.
Deconstruction Ordinance - Technical Assistance & Outreach
Staff plans to provide extensive outreach, training, and technical assistance to both internal and
external stakeholders announcing the Deconstruction Ordinance requirements to ensure all
projects affected are provided with information well ahead of schedule. Outreach would be
provided in the form of “how to” guides, best management practices, pamphlets, direct
mailings, online documents, and training videos. Staff will also explore creating case studies of
deconstruction projects to document and demonstrate the benefits to contractors, builders and
property owners.
Refuse Collection Ordinance - Chapter 5.20
Staff is also recommending updates to Chapter 5.20, Collection, Removal and Disposal of
Refuse, not specifically related to the two ordinances described above. Specifically, for bags
containing refuse being put out for the City’s refuse collection program by c ommercial facilities
(not including residential dwelling units that are part of a mixed-use development or
multifamily properties), blue-tinted bags must be used for recyclable materials and clear bags
must be used for garbage (landfill). If bags are used for compost by either commercial or
residential facilities, they must be green compostable bags. These changes will make sorting
more effective and monitoring easier. The compostable bag requirement will also reduce the
amount of plastic in the City generated compost. Other updates to this ordinance include the
following:
• Adding new or modified definitions including a new definition for “Refuse Room” to
clarify that refuse may also be stored inside a building, and modifying the definition for
“Multifamily property” to three or more attached units from five or more units to
conform to Planning Department's definition of “Multifamily property”.
• To address the issue of cardboard boxes not being broken down, causing recycling
containers to overflow and collection trucks from filling up too fast, a new requirement
to break down cardboard boxes was added to Section 5.20.090.
• Section 5.20.109 was modified to ensure new container covers for public refuse
containers are used during special events and returned to the City.
• Clarified self-haul exemption to restrict the use of containers to only those from the
City’s contracted hauler for collecting, removing and disposing of refuse so that the City
can ensure refuse is properly managed and processed.
• Two new requirements in Section 5.20.120 include allowing the City or its collector
access to internal and external refuse containers for inspection as well as ensuring
refuse containers serviced by the City contracted hauler are accessible, easy to service,
safe to service, and clear of obstructions.
• Due to increased instances of refuse containers being left out in the public right-of-way
after collection service, a new requirement allowing refuse containers to stay in the
public right-of-way 24 hours before or after being serviced was added to Section
5.20.130.
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Updates to the Collection Ordinance would go into effect with in 30 days of the second reading
of the ordinance with the exception of the colored refuse bag requirement. The colored refuse
bag requirement would go into effect on July 1, 2020.
Timeline
Disposable Foodware Ordinance – Timeline
The estimated schedule for the new Disposable Foodware Ordinance implementation is as
follows:
• First reading (Public Hearing) - June 10, 2019
• Second reading – June 24, 2019
• Implement outreach and education – July through December 2019
• Implement new foodware requirements – January 1, 2020
Deconstruction Ordinance – Timeline
The estimated schedule for the implementation of the new Deconstruction Ordinance is as
follows:
• First reading (Public Hearing) – June 10, 2019
• Second reading – June 24, 2019
• Implement outreach, education, training of stakeholders, and conduct a soft launch (on
a voluntary basis) on new requirements - July 2019 through June 2020
• Ordinance effective July 1, 2020
• Staff contemplates adoption and implementation of the Deconstruction Ordinance
requirements in 3 phases. Only the first phase is included in the proposed ordinance.
The next two phases will be proposed for adoption after sufficient experience with the
first phase can inform the City’s draft concepts for Phase II and Phase III.
Refuse Collection Ordinance – Timeline
The estimated schedule for the Refuse Collection Ordinance implementation is as follows:
• First reading (Public Hearing) - June 10, 2019
• Second reading – June 24, 2019
• Implement outreach and education on the colored refuse bag requirements – July 2019
through June 2020
• Implement the colored refuse bag requirements – July 1, 2020
Resource Impact
Disposable Foodware Ordinance
The new ordinance would require outreach and education to commercial customers but no
additional budget requests are expected as the planned outreach and education expenditures
would be funded within the existing budget by reprioritizing current outreach activities.
Deconstruction Ordinance
To implement the Deconstruction Ordinance, an increase in annual ongoing expenses of
$567,000 for additional GreenWaste personnel and processing costs would be required. Staff is
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proposing this budget change as part of the FY 2020 budget development process. Utilizing
existing funds within the GreenWaste contract budget, a one-time expense of $243,000 would
be incurred for the startup of the new service in FY 2020 for the purchase of new containers,
signs, and a small scale. Additionally, existing funds would be used to cover a one-time
estimated expense of $118,000 to be allocated for consultant services to provide support at the
Development Center in the development and execution of an education and outreach
campaign to the community and stakeholders. Outreach would include on-site education and
training, guides, videos, monitoring, and support for contractors.
Policy Implications
The recommended ordinance changes advance the initiatives of the Zero Waste Plan accepted
by Council in August 2018, support the City’s goals of 95 percent diversion by 2030 in the
S/CAP, and help reduce greenhouse gases.
Environmental Review
These ordinances were assessed in accordance with the authority and criteria contained in the
California Environmental Quality Act (CEQA), the State CEQA Guidelines, and the environmental
regulations of the City. The subject ordinances and the Inert Debris Transfer Facility Site
Permitting have been assessed in accordance with the authority and criteria contained in the
California Environmental Quality Act (CEQA), the State CEQA Guidelines, and the environmental
regulations of the City.
Disposable Foodware Ordinance
Under Section 15061(b)(3) of the State CEQA Guidelines, this Ordinance is exempt from the
requirements of CEQA because it can be seen with certainty that reducing disposable plastic
foodware items such as straws, utensils, and stirrer sticks and having compostable alternatives
offered only upon request, reducing plastic bags, and other provisions of the Ordinance would
not have the potential for causing a significant effect on the environme nt. The Ordinance is
exempt from the requirements of CEQA pursuant Guidelines Section 15061(b)(3) because it can
be seen with certainty that reducing the use of disposable plastic produce bags in retail service
establishments in Palo Alto would not have the potential for causing a significant effect on the
environment. The Ordinance is also exempt from the requirements of CEQA pursuant to CEQA
Guidelines Sections 15307 and 15308 as actions taken by regulatory agencies to assure the
maintenance, restoration or enhancement of natural resources. This Ordinance is intended to
achieve the environmental protection initiatives of the City’s code and policies, as well as state
mandates for waste reduction, recycling, and composting.
Deconstruction Ordinance
Pursuant to Section 21092 and 21092.3 of the Public Resources Code and CEQA Guidelines
Section 15072, as amended, the City prepared an Initial Study for the Deconstruction and
Construction Materials Management Ordinance and Inert Debris Transfer Facility Site
Permitting to evaluate the environmental impacts. The Initial Study concludes that the project
would not have a significant effect on the environment. Therefore, an Initial Study/Negative
City of Palo Alto Page 15
Declaration (IS/ND) was circulated on March 22, 2019 for a twenty -day review period. No
comments were received during the circulation period. The final IS/ND (Attachment D) is
provided for Council’s review and adoption.
Refuse Collection Ordinance
The Ordinance is exempt under CEQA Guidelines Sections 15307 and 15308, actions taken by
regulatory agencies to assure the maintenance, restoration or enhancement of natural
resources.
Attachments:
• Attachment A - Disposable Foodware Ordinance (Chapter 5.30 and 5.35)
• Attachment B - Refuse Collection Ordinance (Chapter 5.20)
• Attachment C - Resolution Adopting Negative Declaration for Deconstruction
• Attachment D - Negative Declaration for Deconstruction
• Attachment E - Deconstruction Ordinance (Chapter 5.24)
• Attachment F - Disposable Foodware Reduction Plan
• Attachment G - Deconstruction Ordinance Summary
• Attachment H: Exemption Request Disposable Foodware Reduction Ordinance SHC
LPCH.vf
• Attachment I: Foodware Reduction- Sign on Letter to Palo Alto City Council (1) (3)
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2019053002
Ordinance No. _____
Ordinance of the Council of the City of Palo Alto Amending Title 5 of the Palo
Alto Municipal Code to Establish Regulations Related to Disposable Foodware
Items and Other Disposable Products at Food Service Establishments (Chapter
5.30) and to Require the Use of Compostable Produce Bags at Retail Service
Establishments and Farmers Markets (Chapter 5.35)
The Council of the City of Palo Alto ORDAINS as follows:
SECTION 1. Findings and Declarations. The City Council finds and declares as follows:
A. Disposable foodware items and single-use non-recyclable produce bags are
intended to be used once then discarded. These items pose waste management challenges and
can persist in the environment for many years, causing harm to wildlife and blight to
waterways. The production, use and disposal of these items have substantial environmental
impacts, including environmental contamination; consumption of energy, water, and non-
renewable, polluting fossil fuels; emissions of greenhouse gases; release of air and water
pollutants; depletion of natural resources; litter on streets and in waterways; plastic pollution;
and increased waste clean-up and management costs.
B. Plastics in waterways and oceans break down into smaller pieces that are not
biodegradable. Among other hazards, plastic debris attracts and concentrates ambient
pollutants in seawater and freshwater, which can transfer to fish, other seafood and salt that is
eventually sold for human consumption. Disposable foodware can also contain harmful
fluorinated chemicals that are linked to serious health conditions.
C. The practice of freely giving customers disposable foodware and single-use, non-
recyclable produce bags encourages customers, retailers, and food vendors to pay little
attention to the quantity of disposable packaging products they consume and the associated
environmental impact.
D. The City of Palo Alto updated its Zero Waste Plan in 2018, with new provisions
designed to help the City reach its goal of 95% diversion of materials from landfills by 2030, and
80% reduction of greenhouse gases by the same year. Disposable foodware and single-use,
non-recyclable produce bags pose difficulties for composting or recycling, hampering Palo Alto
from achieving zero waste.
E. Policies that promote reusable and/or compostable foodware and produce bags
encourage both reuse of materials and reduction of pollutants. These twin strategies are crucial
for conserving resources and protecting the environment, and integral to Palo Alto’s goal of
zero waste.
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SECTION 2. Chapter 5.30 of Title 5 (Health and Sanitation) is hereby amended to read as
follows:
Chapter 5.30
Plastic Foam and Non-Recyclable Food Service Containers and Packaging Items
Disposable Foodware Items and Other Disposable Products
5.30.010 Definitions.
(a) "ASTM Standard" means meeting the standards of the American Society for Testing and
Materials (ASTM) International Standards D6400 or D6868 for biodegradable and compostable
plastics and any amendments or successor standards thereto.
(a)(b) "City Facilities" refers to any real property, building, structure or vehicle owned or
operated by the City of Palo Alto, its agents, departments and franchises.;
(b) “Compostable” means items deemed acceptable within the City’s compost collection
program as determined by the Director of Public Works and identified on the City’s website.
(c) “Disposable” means items designed to be used once or a limited number of times and then
discarded, whether the item is non-recyclable, Recyclable or Compostable.
(c)(d) “Disposable Food Service Container” means single-use disposable a product used by
Food Service Establishments for serving or transporting prepared and ready-to-consume food
or beverages. This includes but is not limited to plates, cups, bowls, lids, trays and hinged or
lidded containers. This does not include single-use disposable straws, utensils, or hot cup lids;
(d)(e) “Food Service Establishment” means any establishment, located or providing food
within the City of Palo Alto, which provides prepared and ready to consume food or beverages,
for public consumption including but not limited to any Retail Service Establishment, eating and
drinking service (as defined in Title 18), takeout service (as defined in Title 18), supermarket,
delicatessen, restaurant, food vendor, sales outlet, shop, cafeteria, catering truck or vehicle,
cart or other sidewalk or outdoor vendor or caterer which provides prepared and ready-to-
consume food or beverages, for public consumption, whether open to the general public or
limited to certain members of the public (i.e., company cafeteria for employees).;
(e) "Non-Recyclable Plastic" means all plastics that do not meet the definition of Recyclable
Plastic;
(f) “Foodware Item” means any item used or provided by Food Service Establishments to serve
or consume food or beverages. Foodware Items include Food Service Containers, condiment
cups and packets, straws, utensils (forks, spoons, sporks, knives, chopsticks), drink stirrers,
beverage spill plugs, napkins, and other drink or food accoutrements.
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(f)(g) “Plastic Foam” shall means blown expanded and extruded plastic foams made from
polystyrene or other resins which are processed by any number of techniques including, but not
limited to, fusion of monomer spheres (expanded bead plastic), injection molding, foam
molding and extrusion-blown molding (extruded foam plastic). Expanded polystyrene and other
plastic foam resins are generally used to make disposable cups, bowls, plates, trays, egg
cartons, clamshell containers, ice chests, shipping boxes and packing materials.;
(g)(h) “Plastic Foam Products” shall means Ddisposable Plastic Foam ice chests, cups, bowls,
plates, clamshells, shipping boxes containers, egg cartons, packaging peanuts, packing blocks or
other packaging materials that are not wholly encapsulated or encased by a more durable
material. Additional Plastic Foam Products may be added by administrative regulation
promulgated by the Director of Public Works or his/her designee.;
(h)(i) “Prepared Food’ means any food or beverage prepared for consumption using any
cooking, packaging, or food preparation technique, including but not limited to cooking,
chopping, slicing, mixing, freezing, squeezing, or brewing, and which requires no further
preparation to be consumed. Prepared Food includes uncooked fruits or vegetables, “take-out”
food, or food prepared to be consumed off the Food Service Establishment premises. Prepared
Food does not include any uncooked meat, fish or poultry.;
(j) “Recyclable” means items deemed acceptable within the City’s recycling collection program
as determined by the Director of Public Works and identified on the City’s website.
(i) "Recyclable Plastics" include any plastic which can be accepted for recycling or composting
by the City's municipal recycling program. For purposes of this Chapter, Recyclable Plastic does
not include any expanded Plastic Foam labeled with recycling symbol #6, or any other Plastic
Foam made with other plastic resins;
(j)(k) “Retail Service Establishment” shall have the same meaning as Retail Service as defined in
Title 18 of this Code.
(l) “Reusable Foodware” means a Foodware Item made of durable materials and designed to
be used repeatedly with a useful life greater than one year.
5.30.020 Prohibition on the use of expanded plastic foam products and non-recyclable
plastic.
(a) Except as provided by Section 5.30.030, Food Service Establishments are prohibited
from providing Prepared Food in Disposable Food Service Containers made from Plastic Foam
or other Nnon-Rrecyclable Pplastic.;
(b) Except as provided by Ssection 5.30.030, Retail Service Establishments are prohibited
from selling, leasing or otherwise providing Plastic Foam Products.;
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(c) Except as provided by section 5.30.030, all City facilities and vendors at City sponsored
events or City owned facilities are prohibited from using Disposable Food Service Containers,
packaging or other products made from Plastic Foam or Non-Recyclable Plastic.;
(d) Nothing in this Ordinance Section shall be interpreted to restrict the use or sale of any form
of fiber or paper disposable food service container, or the use of any form of biodegradable or
plastic food service container meeting ASTM Standards or other products authorized by
Administrative Regulation.
5.30.025 Limitation on the use of Disposable Foodware Items and other Disposable
products.
Effective January 1, 2020:
(a) Food Service Establishments are prohibited from providing the following Disposable
Foodware Items:
1. Plastic straws
2. Plastic utensils (e.g., forks, knives, spoons, sporks, chopsticks)
3. Plastic drink stirrers, drink plugs, and other drink accoutrements such as novelty
cocktail accessories
4. Plastic food picks and toothpicks
(b) Food Service Establishments, City Facilities, and vendors at City-sponsored events shall
provide the following Foodware Items only if they are Reusable or Compostable:
1. Straws
2. Utensils (e.g., forks, knives, spoons, sporks, chopsticks)
3. Drink stirrers, drink plugs, and other drink accoutrements such as novelty
cocktail accessories
4. Food picks and toothpicks
(c) Food Service Establishments shall provide permitted Disposable Foodware Items, other
than Food Service Containers, only upon customer request or at a self-serve station.
(d) Food Service Establishments shall provide a printed receipt only at the request of the
customer.
5.30.030 Exemptions.
(a) The following exemptions shall apply:
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(i) Foods prepared or packaged outside the City of Palo Alto are exempt from the
provisions of this Chapter. Purveyors of food prepared or packaged outside the City of
Palo Alto are encouraged to follow the provisions of this Chapter.
(ii) The Director of Public Works, or his/her designee, may exempt a Food Service
Establishment, Retail Service Establishment or City Ffacility/vendor from the requirements
of this Chapter for a period of up to one year, if the applicant for such exemption can
demonstrate that the conditions of this Chapter would cause an undue hardship. An
"undue hardship" includes, but is not limited to situations unique to the applicant where
there are no reasonable alternatives to Plastic Foam Products or Nnon-recyclable Pplastic
Disposable Food Service Containers and compliance with this Chapter would cause
significant economic hardship to that applicant, or cause them to be deprived of a legally
protected right.
(iii) A Food Service Establishment, Retail Service Establishment or City Facility/vendor
seeking an exemption application shall include all information necessary for the City to
make its decision, including but not limited to documentation showing the factual support
for the claimed exemption. The Director may require the applicant to provide additional
information to permit the Director to determine facts regarding the exemption
application.
(iv) Emergency Supplies and Service Procurement. City Facilities, Food Service
Establishments, Retail Service Establishments, City contractors and vendors doing
business with the City shall be exempt from the provisions of this Chapter, in a situation
deemed by the City Manager to be an emergency for the immediate preservation of the
public peace, health or safety.
5.30.040 Reserved Operative dates.
All Food Service Establishment, Retail Service Establishments and City facilities and vendors
must comply with the requirements of this Chapter by March 1, 2016.
5.30.050 Severability.
If any provision or clause of this Chapter is held to be unconstitutional or otherwise invalid by
any court of competent jurisdiction, such invalidity shall not affect other provisions of this
Chapter, and clauses of this Chapter are declared to be severable.
5.30.060 Enforcement and penalties.
(a) The Director of Public Works or his or/ her designee shall have primary responsibility for
enforcement of this Chapter. The Director of Public Works or his or her designee is authorized
to promulgate regulations and to take any and all other actions reasonable and necessary to
enforce this Cchapter, including, but not limited to, entering the premises of any Food Provider
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Service Establishment to verify compliance and the types of Recyclable and cCompostable
Ffoodware Iitems acceptable in the City’s collection program.
(b) Anyone violating or failing to comply with any of the requirements of this Chapter shall be
guilty of an infraction as set forth in Chapter 1.08 of the Palo Alto Municipal Code.
(c) Anyone violating or failing to comply with any of the requirements of this Chapter shall be
subject to an administrative penalty or administrative compliance order as set forth in Chapters
1.12 and 1.16 of the Palo Alto Municipal Code.
(d) The remedies and penalties provided in this Section are cumulative and not exclusive.
5.30.070 Construction.
This Chapter is intended to be a proper exercise of the City's police power, to operate only
upon its own officers, agents, employees and facilities and other persons acting within its
boundaries, and not to regulate inter-city or interstate commerce. It shall be construed in
accordance with that intent.
SECTION 3. Section 5.35.010 of Chapter 5.35 (Retail and Food Service Establishment Checkout
Bag Requirements) of Title 5 (Health and Sanitation) of the Palo Alto Municipal Code is hereby
amended to read as follows:
5.35.010 Definitions.
The following words and phrases, whenever used in this Chapter, shall be construed as defined
in this Section:
(a) “Checkout Bag” means a bag that is provided by a Retail Service Establishment at the
checkstand, cash register, point of sale or other point of departure for the purpose of
transporting food or merchandise out of the establishment. Checkout Bags do not include
Produce Bags or Product Bags as defined in this Chapter.
(b) “Compostable Produce Bags” means paper bags and bags made of plastic-like material if
the material meets the ASTM Standard Specifications for compostability D6400 or D6868, or
the product is Biodegradable Products Institute (BPI) certified, or is considered acceptable
within the City’s compost collection program.
(b)(c) "Food Service Establishment" means any establishment, located or providing food within
the City of Palo Alto, which provides prepared and ready-to-consume food or beverages, for
public consumption including but not limited to any Retail Service Establishment, eating and
drinking service (as defined in Chapter Title 18), takeout service (as defined in Chapter Title 18),
supermarket, delicatessen, restaurant, food vendor, sales outlet, shop, cafeteria, catering truck
or vehicle, cart or other sidewalk or outdoor vendor or caterer which provides prepared and
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ready-to-consume food or beverages, for public consumption, whether open to the general
public or limited to certain members of the public (i.e., company cafeteria for employees).
(c)(d) "Produce or product Bag" means: any bag without handles provided to a customer to
carry produce, meats, bulk food, or other food items to the point of sale inside a store and
protects food or merchandise from being damaged or contaminated by other food or
merchandise when items are placed together in a Reusable bag or Recyclable Paper Checkout
Bag.
i. Any bag without handles provided to a customer to carry produce meats, bulk food, or
other food items to the point of sale inside a store;
ii. To hold prescription medication dispensed from a pharmacy;
iii. To protects food or merchandise from being damaged or contaminated by other food
or merchandise when items are placed together in a reusable bag or recyclable paper
checkout bag;
iv. A bag without handles that is designed to be placed over articles of clothing on a
hanger.
(e) "Product Bag” means a bag provided to a customer to protect merchandise from being
damaged or contaminated by other merchandise when items are placed together in a Reusable
Bag or Recyclable Paper Checkout Bag; a bag to hold prescription medication dispensed from a
pharmacy; or a bag without handles that is designed to be placed over articles of clothing on a
hanger.
(d)(f) "Recyclable Paper Checkout Bag" means a paper bag that meets one of the following
criteria:
i. Pre-approved standard. A paper bag that meets all of the following requirements:
1. Contains no old growth fiber;
2. Is 100% recyclable overall and contains a minimum of 40% post-consumer
recycled content;
3. Displays the word "Recyclable" on the outside of the bag; and
4. The manufacturer, the location (country) where manufactured and the
percentage of post-consumer recycled content in an easy-to-read size font.
ii. Alternative materials. The Director of Public Works or his or her designee is authorized
to approve alternate materials or testing methods meeting this Section's requirements
provided that the Director or designee finds that the proposed materials or testing
standards satisfactorily comply with the intent, quality and effectiveness in order to meet
the purposes of this Cchapter. The particulars of any approval made by the director of
public works or his or her designeeDirector under this subsection shall be entered upon
the records of the Public Works Department and a signed copy shall be furnished to the
applicant.
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iii. Alternative standard. Any other published uniform recyclable paper bag standard as
approved by the Director of Public Works or his or her designee.
(e)(g) "Retail Service Establishment" means any establishment providing retail sale, rental,
service, processing, or repair of items primarily intended for consumer or household use,
including but not limited to the following: groceries, meat, vegetables, dairy products, baked
goods, candy, and other food products; liquor and bottled goods, household cleaning and
maintenance products; drugs, cards, and stationery, notions, books, tobacco products,
cosmetics, and specialty items; flowers, plants, hobby materials, toys, household pets and
supplies, and handcrafted items; apparel, jewelry, fabrics, and like items; cameras, photography
services, household electronic equipment, records, sporting equipment, kitchen utensils, home
furnishing and appliances, art supplies and framing, arts and antiques, paint and wallpaper,
carpeting and floor covering, interior decorating services, office supplies, musical instruments,
hardware and homeware, and garden supplies; bicycles; mopeds and automotive parts and
accessories (excluding service and installation); cookie shops, ice cream stores and
delicatessens.
(f)(h) "Reusable Checkout Bag" shall mean a bag with handles that is specifically designed and
manufactured for multiple reuse which can be washed or wiped clean and meets all of the
following criteria:
i. Bags with a capacity of 15 liters or greater must meet all of the following
requirements:
1. To confirm durability, bags must meet EcoLogo ATP-001 standards (including
future amendments or any successor legislation):
a. Capacity test - minimum of 15 liters.
b. Dynamic test - minimum of 5 sets of 300 cycles (1,500 cycles total).
2. To confirm bag thickness of 2.25 mils thick or greater, bags will be measured
according to ASTM D6988-08 or ISO 4593:1993 or ISO 4591:1992 standards
(for embossed film) (including future amendments or any successor
legislation).
3. To confirm the absence of heavy metals causing environmental hazards upon
entering the solid waste stream, state methods are to be used for preparing
and for testing samples of each unique bag component following the Model
Toxics in Packaging Legislation; and
4. Is either:
a. Labeled in an easy-to-read sized font with the name of the manufacturer,
the country of origin where manufactured, the material from which it is
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manufactured, the percentage of post-consumer recycled content, and a
statement that the bag does not contain heavy metals; or
b. As an alternative, information about the manufacturer, the country of
origin where manufactured, the material from which the bag is
manufactured, the percentage of post-consumer recycled content, and a
statement that the bag does not contain heavy metals can be provided
through the reporting requirements set forth under Section 5.35.030(d).
ii. Reusable Bags that with a capacity of less than 15 liters must meet all of the following
requirements:
1. Is 2.25 mils thick or greater as measured according to ASTM D6988-08 or ISO
4593:1993 or ISO 4591:1992 standards (for embossed film) (including future
amendments or any successor legislation).
2. To confirm the absence of heavy metals causing environmental hazards upon
entering the solid waste stream, state methods are to be used for preparing and for
testing samples of each unique bag component following the Model Toxics in
Packaging Legislation; and
3. Is either:
a. Labeled in an easy-to-read sized font with the name of the manufacturer,
the country of origin where manufactured, the material from which it is
manufactured, the percentage of post-consumer recycled content, and a
statement that the bag does not contain heavy metals; or
b. As an alternative, information about the manufacturer, the country of
origin where manufactured, the material from which the bag is
manufactured, the percentage of post-consumer recycled content, and a
statement that the bag does not contain heavy metals can be provided
through the reporting requirements set forth under Section 5.35.030(d).
iii. Alternative materials. The Director of Public Works or his or her designee is authorized
to approve alternate materials or testing methods meeting this section's requirements
provided that the Director or the designee finds that the proposed materials or testing
standards satisfactorily complies with the intent, quality and effectiveness in order to
meet the purposes of this Chapter. The particulars of any approval made by the Director
under this subsection shall be entered upon the records of the public works
departmentPublic Works Department and a signed copy shall be furnished to the
applicant.
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iv. Alternative standard. Any other published uniform bag standard as approved by the
Director of Public Worksor his or her designee.
(g)(i) "Single-use Plastic Checkout Bag" means any bag made predominately of plastic derived
from natural gas, petroleum or a biologically-based source, such as corn or other plant sources,
which is provided to a customer at the point of sale which does not meet the definition of a
Reusable Checkout Bag.
SECTION 4. Section 5.35.020 of Chapter 5.35 (Retail and Food Service Establishment Checkout
Bag Requirements) of Title 5 (Health and Sanitation) of the Palo Alto Municipal Code is hereby
amended to read as follows:
5.35.020 Types of checkout bags permitted at retail service and food service establishments.
(a) Retail Service Establishments within the city of Palo Alto shall provide or make available to
a customer only Reusable Bags or Recyclable Paper Checkout Bags for the purpose of carrying
away goods or other materials from the point of sale, subject to the terms of this Chapter.
i. Single-use Plastic Bags exempt from the Chapter include those integral to the
packaging of the product, produce or Product Bags, newspaper bags, door-hanger bags, or
bags sold in packages containing multiple bags intended for use as garbage, pet waste or
yard waste bags.
ii. Food Service Establishments within retail stores must comply with those requirements
listed under Section 5.35.020(b) below.;
iii. Effective January 1, 2020, Ffarmers markets shall only may provide Compostable
Produce or product Bags to hold produce, meats, bulk food or bulk other food items.
Single-use Plastic Checkout Bags, Produce Bags or Product Bags shall not be provided by
farmers markets for produce or meats. charges for these bags are not required at farmers
markets unless checkout bags used to hold produce or product bags are provided.
(b) Effective November 1, 2013, Food Service Establishments shall provide or make available to
a customer only Recyclable Paper Checkout Bags or Reusable Bags, at their discretion, for the
purpose of carrying away goods or other materials from the point of sale, subject to the terms
of this Chapter.
i. Produce or Product Bags without handles may be used at Food Service Establishments
to hold containers of food items that are free liquids such as soups or stews that might be
susceptible to spilling.
(c) The City of Palo Alto encourages, but does not require in-store public education and
encouragement to customers about the use of Reusable Bags. In-store education for Retail
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Service Establishments and Food Service Establishments is available at
www.cityofpaloalto.org/plastics.
(d) Nothing in this Chapter prohibits customers from using bags of any type that they bring to
the establishment themselves or from carrying away goods that are not placed in a bag at point
of sale, in lieu of using bags provided by the establishment.
(e) A Retail Service or Food Service Establishment may provide a Reusable Bag at no charge if it
is distributed as part of an infrequent and limited time promotion. Infrequent and limited time
promotions shall not exceed a total of 14 days in any consecutive 12 month period.
SECTION 5. Chapter 5.35 (Retail and Food Service Establishment Checkout Bag Requirements)
of Title 5 (Health and Sanitation) of the Palo Alto Municipal Code is hereby amended to add a
new Section 5.35.035 to read as follows:
5.35.035 Use of Compostable Produce Bags at Retail Service Establishments.
Effective January 1, 2020, Retail Service Establishments shall only provide Compostable Produce
Bags to carry produce, meats, bulk food, or other food items to point-of-sale within the store.
SECTION 6. Chapter 5.35 (Retail and Food Service Establishment Checkout Bag Requirements)
of Title 5 (Health and Sanitation) of the Palo Alto Municipal Code is hereby amended to delete
Section 5.35.040 as follows:
5.35.040 Reserved Delayed implementation for food service establishments.
All food service establishments shall comply with the requirements of Section 5.35.020 of this
Chapter beginning November 1, 2013.
SECTION 7. If any section, subsection, clause or phrase of this Ordinance is for any reason held
to be invalid, such decision shall not affect the validity of the remaining portion or sections of
the Ordinance. The Council hereby declares that it should have adopted the Ordinance and
each section, subsection, sentence, clause or phrase thereof irrespective of the fact that any
one or more sections, subsections, sentences, clauses or phrases be declared invalid.
SECTION 8. The Council finds that this Ordinance is exempt from the provisions of the
California Environmental Quality Act (“CEQA”), pursuant to CEQA Guidelines Section 15308,
Actions by Regulatory Agencies for Protection of the Environment. This exemption applies to
actions taken by regulatory agencies, as authorized by state or local ordinance, to assure the
maintenance, restoration, enhancement, or protection of the environment where the
regulatory process involves procedures for protection of the environment. The Ordinance is
also exempt from CEQA pursuant to Guidelines Section 15061(b)(3) because it can be seen with
certainty that there is no possibility that the Ordinance will have a significant effect on the
environment.
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SECTION 9. This Ordinance shall be effective on the thirty-first day after the date of its
adoption.
INTRODUCED:
PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
____________________________ ____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
____________________________ ____________________________
Assistant City Attorney City Manager
____________________________
Director of Public Works
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2019052201
Ordinance No. _____
Ordinance of the Council of the City of Palo Alto Amending Sections 5.20.010
(Definitions), 5.20.020 (Declaration of Policy), 5.20.030 (Discarding of Refuse),
5.20.090 (Collection and Ownership of Recycled Materials), 5.20.100 (Collection
and Ownership of Compostable Materials), 5.20.105 (Contamination of
Containers), 5.20.109 (Requirements for Special Events), 5.20.110 (Exclusions),
5.20.120 (Refuse Containers), 5.20.130 (Maintenance and Placement of
Containers) of Chapter 5.20 (Collection, Removal and Disposal of Refuse) of Title
5 (Health and Sanitation) of the Palo Alto Municipal Code
The Council of the City of Palo Alto does ORDAIN as follows:
SECTION 1. Section 5.20.010 (Definitions) of Chapter 5.20 (Collection, Removal and Disposal of
Refuse) of Title 5 (Health and Sanitation) is hereby amended to read as follows:
5.20.010 Definitions.
Within and limited to this Chapter, the following words and phrases shall be construed
as defined in this section, unless the context indicates otherwise.
(1) "Bin" means a detachable refuse container used in connection with commercial
premises with a 1 to 8 cubic yard capacity, equipped with a lid, and designed for mechanical
pick-up by collection vehicles.
(2) "Box" means a wheeled or sledded container or compactor, generally 7 to 50 cubic
yards in size, suitable for the storage and collection of commercial solid waste or recyclable
materials.
(3) "Cart" means a wheeled receptacle equipped with a lid, and designed for
mechanical pick-up by collection vehicles.
(4) "City" means the government of the City of Palo Alto, defined in Section 1.04.050(1)
of the municipal code, with a principal place of business at 250 Hamilton Avenue, Palo Alto,
County of Santa Clara.
(5) "City manager" means the person referred to in Section 2.08.140 of the municipal
code, or designee.
(6) "Collection agreement" means a contract with the City for the collection of refuse
pursuant to Section 5.20.040.
(7) "Collector" means one or more persons authorized by Section 5.20.040 to provide
the collection, processing and disposal of refuse pursuant to one or more written contracts with
the City.
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(8) "Commercial business owner" means any person holding or occupying, alone or
with others, commercial premises, whether or not the person holds the title or is the record
owner of the commercial premise.
(9) "Commercial premises" means any occupied real property in Palo Alto, except
property occupied by federal, state or local government agencies which do not consent to their
inclusion, and except residential premises as defined in subsection (3331) hereof, and shall
include, without limitation, any wholesale or retail establishments, restaurant and food service
establishment, bar, store, shop, shopping center, office, industrial establishment,
manufacturing establishment, service station, repair, research and development establishment,
professional, services, sports or recreational facility, any place or premise where an animal is
maintained or sheltered, construction or demolition site, a multiple dwelling that is not a
residential premise, and any other commercial or industrial business facility, structure, site, or
other establishment in Palo Alto.
(10) "Compostable materials" means organic materials designated by the City as
approved for collection and processing, including, without limitation, yard trimmings, food
scraps, soiled paper and compostable plastics, but excluding animal manure, sewage sludge,
and human biological wastes.
(11) "Composting" means the controlled, biological decomposition of organic materials
into humus for use as a soil amendment, conditioner or fertilizer or for any other similar use or
purpose.
(12) "Construction and/or demolition site" means any real property in Palo Alto, at
which a building or structure, or any portion thereof, is being constructed, assembled, erected
or demolished, and during which construction or demolition waste which must be removed
from the property.
(13) "Construction and/or demolition waste" means any waste generated as the result
of construction or demolition work, including, without limitation, discarded packaging or
containers and waste construction materials, whether brought on-site for fabrication or used in
construction or resulting from demolition, excluding liquid waste and hazardous waste.
(14) "Container" means any bin, box, cart, compactor, drop box, roll-off box, or
receptacle, used for the storage of solid waste, recyclable materials, compostable materials or
other materials designated by the City for collection by the collector.
(15) "Director" means the person referred to in Section 2.08.190 of the Municipal
Code, or the director's designee.
(16) "Disposal or processing facility" means a landfill facility, a recycling facility, a
composting facility or a solid waste transfer or processing station.
(17) "EPA" means the federal Environmental Protection Agency or successor agency.
(18) "Food service establishment" means any establishment, located or providing food
within Palo Alto, which provides prepared and ready-to-consume food or beverages, for public
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consumption, including, but not limited to, any retail service establishment, eating and drinking
service (as defined in Chapter 18.23), takeout service (as defined in Chapter 18.23),
supermarket, delicatessen, restaurant, food vendor, sales outlet, shop, cafeteria, catering truck
or vehicle, cart or other sidewalk or outdoor vendor or caterer which provides prepared and
ready-to-consume food or beverages, for public consumption.
(19) "Hazardous waste" means waste defined as hazardous by Public Resources Code
section 40141, as it now exists or may be amended, namely, a waste or combination of wastes,
which due to its quantity, concentration, or physical, chemical or infectious characteristics, may
do either of the following: (i) cause or significantly contribute to, an increase in mortality or an
increase in serious irreversible, or incapacitating reversible, illness; (ii) pose a substantial
present or potential hazard to human health or environment when improperly treated, stored,
transported, or disposed of, or otherwise managed. "Hazardous waste" includes extremely
hazardous waste and acutely hazardous waste, and any other waste as may hereafter from
time to time be designated as hazardous by the EPA or other agency of the United States
Government, or by the California Legislature or any agency of the State of California
empowered by law to classify or designate waste as hazardous, extremely hazardous or acutely
hazardous.
(20) "Home composting" means the controlled decomposition of organic material,
including, without limitation, yard trimmings and kitchen scraps, into humus by any person
owning or occupying any place or premises in Palo Alto.
(21) "Manure" means the waste droppings of any animal.
(22) "Multifamily property" means any residential premise with threefive or more
attached units with shared service.
(23) "Organic wastes" means "compostable materials."
(24) "Person" means any individual, or entity referred to in Section 1.04.050(5) of the
Municipal Code and including any general partnership, limited partnership, limited liability
partnership, or limited liability company.
(25) "Place or premises" means every residential premises and commercial premises,
including any structure, apparatus, or portion thereof occupied or operated by any person and
situated on an integral parcel of land undivided by a public street, highway, or railway.
(26) "Public solid waste or recycling receptacles" means any container for the
collection of solid waste, recyclable materials or compostable materials that are both located
on public property and intended for use by the general public.
(27) "Recyclable materials" means materials designated by the City as suitable for
collection and transport to a material recovery facility for processing into a recycled content
product, including, without limitation, newspaper, paper, cans, corrugated cardboard, glass and
certain types of plastic, and metals.
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(28) "Recycling" means the process of collecting, sorting, cleansing, treating, and
reconstituting materials that would otherwise become solid waste, and returning them to the
economic mainstream in the form of raw material for new, reused, or reconstituted products
which meet the quality standards necessary to be used in the marketplace. This term does not
include transformation as that term is defined in Public Resources Code section 40180.
(29) "Refuse" means and includes compostable materials, recyclable materials and
solid waste.
(30) “Refuse Room” means a room(s) located inside a building in which refuse
containers are maintained and refuse is collected. Refuse rooms are typically located at the
end of a hallway or on the ground level, but may be in other locations.
(310) "Refuse service" means the weekly or other periodic collection, processing and
disposal of materials properly deposited in the collector-provided containers for solid waste, as
well as weekly collection and processing of recyclable materials and weekly collection and
processing of compostable materials.
(321) "Residential householder" means any person owning or occupying residential
premises in Palo Alto.
(332) "Residential premises" means any residential dwelling unit in Palo Alto, including,
without limitation, a multiple unit residential complex, such as a rental housing project,
condominium, apartment house, mixed condominium and rental housing, and a mobile home
park, except any multiple dwelling which, with the prior written approval of the Director,
receives commercial bin service.
(343) "Salvage" means the controlled removal of construction or demolition
debris/material from a permitted building, construction, or demolition site for the purpose of
recycling, reuse, or storage for later recycling or reuse. Examples include air conditioning and
heating systems, columns, balustrades, fountains, gazebos, molding, mantels, pavers, planters,
quoins, stair treads, trim, wall caps, bath tubs, bricks, cabinetry, carpet, doors, ceiling fans,
lighting fixtures, electrical panel boxes, fencing, fireplaces, flooring materials of wood, marble,
stone or tile, furnaces, plate glass, wall mirrors, door knobs, door brackets, door hinges, marble,
iron work, metal balconies, structural steel, plumbing fixtures, refrigerators, rock, roofing
materials, siding materials, sinks, stairs, stone, stoves, toilets, windows, wood fencing, lumber
and plywood.
(354) "Solid waste" means solid and semisolid wastes, generated in or upon, related to
the occupancy of, remaining in or emanating from residential premises or commercial
premises, including garbage, trash, rubbish, ashes, industrial wastes, manure, animal carcasses,
solid or semisolid wastes, and other solid and semisolid wastes. "Solid waste" shall not include
liquid wastes or sewage, abandoned vehicles, hazardous waste, recyclable materials or
compostable materials.
(365) "Solid waste enterprise" shall mean any person regularly engaged in the business
of providing solid waste, recyclable materials or compostable materials handling services.
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(376) "Source separated single recyclable materials" means recyclable materials that
are separated from other recyclable materials or solid waste and placed in separate containers
according to type or category of materials and directly marketed as a single commodity.
(387) "Yard trimmings" means plant trimmings generated from the maintenance or
alteration of public, commercial premises or residential premises landscapes, including, without
limitation, grass cuttings, yard clippings, leaves, tree trimmings, pruning, brush and weeds,
excepting those materials which are prohibited under written rules and regulations
promulgated by the Director.
SECTION 2. Section 5.20.020 (Declaration of Policy) of Chapter 5.20 (Collection, Removal and
Disposal of Refuse) of Title 5 (Health and Sanitation) is hereby amended to read as follows:
5.20.020 Declaration of policy.
(a) The accumulation, collection, removal and disposal of refuse must be controlled by
the City for the protection of the public health, safety and welfare. The Council finds that to
give practical effect to this policy a comprehensive system for the periodic collection, removal
and disposal of refuse from all places or premises is essential and benefits all occupants of
places or premises. All occupants of places or premises shall be liable for refuse collection
charges established by the Council for the collection, removal and disposal of refuse.
(b) The City complies with the applicable provisions of the California Integrated Waste
Management Act, as amended, codified in the Public Resources Code section 40000 et seq. The
law requires that, by and after January 1, 2000, fifty percent (50%) of the solid waste generated
must be diverted through some source reduction, recycling, and composting activities.
(c) The City also complies with the 75 percent recycling goal included as part of AB 341
Mandatory Commercial Recycling Law, adopted on October 6, 2011, which includes
modifications to the Public Resources Code.
(d) In addition, the City complies with AB 1826, which amended the law in 2014,
imposesthe organic waste recycling requirements under AB 1826, with a mandate that will
beginwhich became effective on April 1, 2016.
(e) In 2016, SB 1383 established methane emissions reduction targets to reduce
statewide emissions of short-lived climate pollutants including, establishing a 50 percent
reduction of disposed organic waste from 2014 levels by 2020 and a 75 percent reduction by
2025; and the target to reduce 20 percent of disposed edible food by 2025. Further, inAlso in
2016, the Ccity established sustainability and climate action goals of an 80 percent% reduction
in greenhouse gases and 95 percent% diversion of materials from landfills by 2030.
(fe) The City may adopt, implement, and enforce requirements, rules and regulations
for local compostable materials and local recyclable materials that are more stringent or
comprehensive than California law.
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SECTION 3. Section 5.20.030 (Discarding of Refuse) of Chapter 5.20 (Collection, Removal and
Disposal of Refuse) of Title 5 (Health and Sanitation) is hereby amended to read as follows
5.20.030 Discarding of refuse.
(a) No person shall throw, drop, leave, place, keep, accumulate, or otherwise dispose
of any refuse upon private property either with or without the intent to later remove the same
from that place or premises, or upon any street, public right-of-way, sidewalk, gutter, stream,
or creek, or the banks thereof, or any public place or public property.
(b) All persons shall separate their refuse according to its characterization as solid
waste, compostable materials, or recyclable materials, and place each type of refuse in a
separate container designated for disposal of that type of refuse. No person may mix any type
of refuse, or deposit refuse of one type in a collection container designated for refuse of
another type, except as otherwise provided in this Chapter. This does not prohibit the
placement of refuse in public solid waste or recycling receptacles, or in containers for collection
in accordance with the provisions of this Chapter. This section does not prohibit any person
from engaging in home composting. Administrative citations or any other enforcement actions
will not apply to this paragraph for a person occupying a residential premise.
(c) Effective July 1, 2020, any person occupying a commercial premises, not including
multiple dwellings, who uses bags to collect and discard refuse, whether placed for collection
inside or outside a container, shall ensure that the refuse contents of the bags are clearly
visible. When bags are used, garbage shall be collected in clear plastic bags and recyclable
materials shall be collected in blue-tinted plastic bags.
(d) Effective July 1, 2020, all persons who use bags to collect compostable materials,
whether placed for collection inside or outside a container, shall use green-tinted compostable
bags such that the contents are clearly visible.
SECTION 4. Section 5.20.090 (Collection and Ownership of Recyclable Materials) of Chapter
5.20 (Collection, Removal and Disposal of Refuse) of Title 5 (Health and Sanitation) is hereby
amended to read as follows:
5.20.090 Collection and ownership of recyclable materials.
(a) All persons owning or occupying any place or premises where recyclable materials
are created, produced or accumulated shall subscribe and pay for this type of refuse services
and shall subscribe and pay for a number of containers sufficient to hold all recyclable materials
created, produced or accumulated at the place or premises during a one-week period, unless a
different frequency collection schedule has been approved or directed pursuant to this
Chapter.
(b) Recyclable materials placed for curbside collection in or outside of a container shall
become the property of the collector at the time of placement at the curb or other designated
location for collection in or outside of the container. The collector shall have the exclusive right
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to collect the recyclable materials, unless the collection agreement specifies a different
arrangement.
(c) The disposal of solid waste and compostable materials in containers designated for
the collection of recyclable materials is prohibited. Recyclable materials that are placed in a
recyclable materials container for collection by the collector must be free of solid waste and
compostable materials.
(d) Cardboard boxes shall be broken down flat before being placed into recyclables
containers to allow for adequate space to contain the recyclable materials.
SECTION 5. Section 5.20.100 (Collection and Ownership of Compostable Materials) of Chapter
5.20 (Collection, Removal and Disposal of Refuse) of Title 5 (Health and Sanitation) is hereby
amended to read as follows:
5.20.100 Collection and ownership of compostable materials.
(a) All persons owning or occupying any place or premises where compostable
materials are created, produced or accumulated shall subscribe and pay for this type of refuse
services and shall subscribe and pay for a number of containers sufficient to hold all
compostable materials created, produced or accumulated at the place or premises during a
one-week period, unless a different frequency collection schedule has been approved or
directed pursuant to this Chapter.
(b) Compostable materials placed for curbside collection in a container shall become
the property of the collector at the time of placement at the curb or other designated location
for collection of the container.
(c) On or after April 1, 2016, all commercial premises at which 8 cubic yards or more of
solid waste refuse service is subscribed per week, multifamily properties, and food service
establishments shall subscribe and pay for a number of containers sufficient to hold
compostable materials created, produced or accumulated at or on the places or premises
during a one-week period, unless a different frequency collection schedule has been approved
or directed pursuant to this chapter.
(d) On or after January 1, 2017, all commercial premises where 2 cubic yards or more
of solid waste refuse service is subscribed per week, shall subscribe and pay for a number of
containers sufficient to hold compostable materials created, produced or accumulated at or on
the place or premises during a one-week period, unless a different frequency collection
schedule has been approved or directed pursuant to this chapter.
(ce) On or after January 1, 2018, Aall commercial premises at which solid waste refuse
service is subscribed, shall subscribe and pay for a number of containers sufficient to hold
compostable materials created, produced or accumulated at or on the place or premises during
a one-week period, unless a different frequency collection schedule has been approved or
directed pursuant to this Chapter.
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(df) The City may direct the collector to audit individual solid waste streams generated
at commercial premises to determine the owner, occupant or tenant's compliance with this
section.
SECTION 6. Section 5.20.105 (Contamination of Containers) of Chapter 5.20 (Collection,
Removal and Disposal of Refuse) of Title 5 (Health and Sanitation) is hereby amended to read as
follows:
5.20.105 Contamination of containers.
(a) No person subscribing to refuse service shall dispose or permit the disposal of solid
waste in a container designated for the collection of recyclable materials or compostable
materials. The person shall remove any solid waste deposited in the recyclable materials and
compostable materials containers before the collection of the recyclable materials and
compostable containers occurring that week.
(1) The collector will notify any person who occupies commercial premises
whenever the City or the collector determines the recyclable materials or compostable
materials container of that person is contaminated with solid waste and the waste must
be removed. After the person removes the solid waste from the recyclable materials
and compostable materials container, the collector will return to the commercial
premises to service the container or containers and the person occupying the
commercial premises will be charged a "return trip" fee specified in the refuse rate
schedules.
(2) If the person occupying the commercial premises does not remove the
waste from the recyclable materials and compostable materials containers by the
scheduled pick-up date, the containers will be serviced at the next business day and the
person occupying the commercial premises will be charged both an "extra solid waste
pick-up" fee and a "return trip" fee in addition to the refuse charges that apply to the
level of service subscribed by the person occupying the commercial premises. The extra
solid waste pick-up fee shall be determined according to the size of the contaminated
recyclable materials or compostable materials container and the established rates
approved by the City.
(3) The fees outlined in Section 5.20.105 (a)(1) - (2) will also apply if a person
occupying a commercial premises places recyclable materials in containers designated
for compostable materials or compostable materials in containers designated for
recyclable materials.
(4) On or after July 1, 2021, iIf a person occupying a commercial premises places
recyclable materials and/or compostable materials in containers designated for solid
waste, the person will be subject to a "contamination" fee.
(5) A person occupying residential premises will not be subject to a "return trip"
fee, an "extra solid waste pick-up" fee, a "contamination" fee, an administrative citation
or any other enforcement action. A multifamily property will not be subject to a "return
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trip" fee or an "extra solid waste pick-up" fee if owners or managers of the multifamily
property can demonstrate compliance with Section 5.20.108 to the satisfaction of the
Director.
(b) No person shall dispose of commercial grease or cooking oil in a compostable
materials container.
SECTION 7. Section 5.20.109 (Requirements for Special Events) of Chapter 5.20 (Collection,
Removal and Disposal of Refuse) of Title 5 (Health and Sanitation) is hereby amended to read as
follows:
5.20.109 Requirements for special events.
(a) The promoter or coordinator of a special event held in Palo Alto must provide a
level of refuse service sufficient to contain the refuse generated at the special event.
(b) The promoter or coordinator shall provide containers at appropriate locations at
the special event to facilitate the source separation of solid waste, compostable materials, and
recyclable materials by event employees, vendors, and attendees.
(c) The three types of containers shall:
(1) Be appropriate in number and size with respect to the quantity of solid
waste, compostable materials, and recyclable materials anticipated to be
generated at the property or premises;
(2) Bear appropriate signage and be color-coded – blue containers for
recyclable materials, green containers for compostable materials, and black
containers for solid waste – to identify the type of refuse to be contained and
meet any additional design criteria established by the City; and
(3) Be placed together as a waste station to provide equally convenient access
to users.
(d) If the promoter or coordinator determines that vendor booths at the special event
will require refuse containers, the vendors shall receive from the promoter or coordinator a set
of refuse containers that bear appropriate signage and are color-coded to identify the type of
waste to be contained.
(e) The use of public solid waste, recycling or composting receptacles at special events
is prohibited. The promoter or coordinator shall remove or cover all public solid waste,
recycling or composting receptacles to prevent their use during the special event. If covers for
receptacles are utilized, the promoter or coordinator shall return them to the City after the
special event.
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SECTION 8. Section 5.20.110 (Exclusions) of Chapter 5.20 (Collection, Removal and Disposal of
Refuse) of Title 5 (Health and Sanitation) is hereby amended to read as follows:
5.20.110 Exclusions.
(a) Residential Householder Exclusion. No provision of this Chapter shall prevent a
residential householder from collecting and disposing of occasional loads of solid waste
generated at the residential premise, composting at home, or selling, donating or disposing of
recyclable or compostable materials generated at the residential premise. The containers
provided by the collector may not be used for activities authorized by this
paragraph. Notwithstanding the foregoing, no residential householder shall employ or engage
any solid waste enterprise, other than the collector to haul or transport solid waste, recyclable
materials, or compostable materials to a disposal or processing facility. No residential
householder may collect or dispose of solid waste generated at a location that is not the
residential premise.
(b) Gardener's Exclusion. No provision of this Chapter shall bar a gardener, tree
trimmer or other person engaged in a similar trade from collecting and disposing of yard
trimmings not containing other solid waste whenever the collection and disposal are incidental
to providing the gardening, tree trimming or similar services.
(c) Commercial Source Separated Recyclable Materials and Compostable Materials.
(1) Commercial business owners shall retain the right to donate or sell
recyclable materials and compostable materials, or to pay fees for services to
solid waste enterprises other than the collector for the collection of particular
recyclable materials and compostable materials, so long as all recyclable
materials and compostable materials collected are source separated single
recyclable materials and compostable materials. Recyclable materials and
compostable materials collected pursuant to this paragraph (c) shall be
transported to a recyclable materials and compostable materials facility
achieving a diversion rate of 90 percent and where not more than 10 percent of
the materials are disposed of in a landfill.
(2) Commercial business owners shall demonstrate compliance with the
provisions of this paragraph (c) at the request of the Director.
(3) The City may require any recycler, junk dealer or other enterprise
engaged in the business of buying and marketing recyclable materials and
compostable materials to provide the City with information pertaining to the
collection and the amount of recyclable materials and compostable materials
collected from within Palo Alto's territorial limits.
(d) Collection of Source Separated Single Recyclable Materials. No provision of this
Chapter shall prevent a recycler, junk dealer or other enterprise engaged in the business of
buying and marketing source separated single recyclable materials in the stream of commerce
and which buys such materials for marketing and not for disposition in a landfill or transfer
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station (as defined in Public Resources Code Section 40200), from buying recyclable materials
for monetary or other valuable consideration. A recycler, junk dealer or enterprise which buys
recyclable materials shall not be prohibited from removing and transporting those materials to
a destination for marketing in the stream of commerce.
(e) Renovation, Rebuilding, Repairs. No provision of this Chapter shall prevent a
commercial business owner from arranging for any worn, spent, or defective equipment, or
part thereof, used in the commercial business and requiring renovation, rebuilding, recharging,
regeneration or repair, to be picked up, renovated, rebuilt, recharged, regenerated or
otherwise restored and repaired and returned to that commercial business owner. Any person
engaged in the business of renovating, rebuilding, recharging, regenerating, or otherwise
restoring or repairing the equipment or part thereof, is not prohibited from transporting the
same from or returning it to the commercial business, or from removing, transporting or
disposing of the equipment, or part thereof, replaced in connection with an equipment repair
or service contract.
(f) Contractors' Exclusions. In addition to the authority granted by paragraph (c) of this
Section 5.20.110, no provision of this Chapter shall prevent a licensed contractor under
contract for the deconstruction, demolition or reconstruction of a building, structure,
pavement, or concrete installation from marketing any saleable or donation items salvaged
from the deconstruction, demolition or reconstruction, or from causing the salvageable items
or construction or demolition waste to be removed and transported from the place or premises
at which such waste is generated, pursuant to the provisions of the demolition or construction
contract, subject to the following:
(1) The collection, removal and disposal activity shall be performed only by the
licensed contractor under contract for the construction, deconstruction or demolition
work that generated the salvageable items or by regularly employed personnel carried
on the licensed contractor's payroll records as an employee.
(2) All vehicles used to facilitate the collection, removal and disposal activities
shall be owned by or under the exclusive control of the licensed contractor and shall
meet all of the requirements of this Chapter and all other laws, statutes, rules,
regulations and ordinances of the state of California and the City. All vehicles shall be
subject to inspection by and the approval of the Director from time to time.
(3) The placement and use of a container, other than a container provided by
the collector, shall be prohibited, whether placed on the ground, on a vehicle, or any
other place.
(g) Reinforced Concrete Exclusion. In addition to the authority granted by paragraph (f)
of this Section 5.20.110, nothing in this Chapter shall prevent a commercial/industrial business
owner, residential householder, or licensed contractor from using a solid waste enterprise
other than the collector to dispose of reinforced concrete.
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(h) Document Destruction Service. No provision of this Chapter shall prevent any
person engaged in the business of destroying or disposing of secret, confidential or sensitive
documents from transporting or disposing of those documents, provided the transport and
disposal of the documents are incidental to the document destruction or disposal service.
(i) Self-Haul Exclusion. In addition to the authority granted by paragraph (a) of this
Section 5.20.110, nothing in this Chapter shall prevent a commercial business owner or
residential householder from, on a regular basis, collecting, transporting and disposing of solid
waste generated at the place or premise, in lieu of availing themselves of the services of the
collector. No residential householder or commercial business owner shall employ or engage
any solid waste enterprise, other than the collector, to haul or transport the solid waste to a
disposal or processing facility. Any residential householder or commercial business owner who
pursuant to this paragraph (ih) seeks to on a regular basis collect, transport and dispose of solid
waste generated at the place or premise, shall first obtain approval of the Director, and must
comply with any written rules and regulations established by the Directorthe procedures
applicable to self-hauling that are adopted by resolution.
(j) General Requirement. In all cases where the right to an exclusion pursuant to this
Section 5.20.110 is exercised, disposal shall be made at a disposal or processing facility that
meets all applicable regulatory requirements. Any disposal by a person exempted under this
section shall not be relieved of any obligation or liability imposed by this Chapter or any other
ordinance, resolution, rule or regulation for the payment of the minimum solid waste and
recyclable materials disposal rates imposed pursuant to this Chapter or any other applicable
rates or fees. Notwithstanding the foregoing, any person with a valid self-haul permit obtained
pursuant to paragraph (h), and who does not use the solid waste collection services offered by
the collector, shall be exempt from the payment of the solid waste collection rates imposed for
use of the services provided by the collector.
(k) Backhauling Compostable Materials. A commercial business may opt out of the
compostable materials service levels required by this Chapter, provided that business verifies to
the satisfaction of the Director that all compostable materials generated on-site will be
transported to a central facility to be later composted or otherwise recycled at a 90 percent
rate and not placed in a landfill.
(l) Space Limitations for Existing Structures. The Director may grant a written
exemption for any existing commercial business structure that lacks sufficient storage space for
compostable materials or recyclable materials from all or portions of this section in accordance
with the written rules and regulations established by the Director. The Director, in cases where
space constraints are determined to exist, shall also evaluate the feasibility of shared container
usage by contiguous businesses or multifamily property structures.
(m) De Minimus Exception. The Director may waive any of the requirements of this
section if documentation satisfactory to the Director, based upon rules and regulations, is
provided to establish that the materials in any type of container, on an on-going basis is
incidental to any other materials originating from that collection location.
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SECTION 9. Section 5.20.120 (Refuse Containers) of Chapter 5.20 (Collection, Removal and
Disposal of Refuse) of Title 5 (Health and Sanitation) is hereby amended to read as follows:
5.20.120 Refuse containers.
(a) All types of refuse containers shall be kept in a sanitary condition with the lids
closed except whenever they are being loaded or unloaded.
(b) Refuse containers suitable for residential places or premises shall be provided by
the collector or the City. Any container shall be of a size based upon the subscription service
level requested by the person responsible for the payment of charges therefor or as may be
required by this Chapter. Any container shall not be loaded with more than the quantity of
materials that either can fit in the container with its lid closed or is in excess of the weight limit
marked on the container, when the lid is closed. All containers for use at commercial premises
shall be provided by or approved by the collector, except for industry-approved grease or
cooking oil tallow containers that shall be provided by a designated tallow hauler.
(c) Refuse containers shall be collected by the collector whenever the containers are
placed in a refuse solid waste enclosure or at the authorized collection area. Collection may be
made at another location upon approval of the Director, based upon the subscription service
level requested.
(d) All commercial property owners and commercial business owners shall provide
access to the City or the collector for the inspection of internal and external refuse containers
and enclosures. The Director shall be authorized to conduct inspections of commercial
premises, as permitted by law, to ensure compliance with this Chapter, including this Section.
(e) Commercial property owners and commercial business owners shall ensure that all
refuse containers and refuse enclosures are accessible and easily serviceable by the collector.
Service vehicles shall have a safe and clear passage and access to refuse enclosures to provide
for the efficient service to customers.
SECTION 10. Section 5.20.130 (Maintenance and Placement of Containers) of Chapter 5.20
(Collection, Removal and Disposal of Refuse) of Title 5 (Health and Sanitation) is hereby
amended to read as follows:
5.20.130 Maintenance and placement of containers.
(a) The commercial business owners and residential householder shall maintain their
containers at their places and premises and the areas where the containers are located in good,
usable, clean and sanitary condition, and shall ensure that the lids on the container are kept
closed and shall ensure that there is no litter underneath or surrounding the containers. No
refuse shall be placed outside of the container. Containers shall be maintained by the
commercial business owners and residential householders in a manner that will prevent
leakage, spillage and the emission of odors. Commercial premises sharing receptacles placed
outside of retail areas, must also share equally in the responsibility of emptying the receptacles
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so that they do not overflow and maintaining the area around the receptacles so that it is free
of loose litter.
(b) The location or placement of containers at any place or premise shall be subject to
the approval of the Director. Every commercial business owner shall provide a location at the
commercial premises for the containers they use.
(c) Any collection agreement may provide for the rental of containers approved by the
collector to customers. The collector shall be responsible for maintenance of the rental
containers by keeping the containers in good and sanitary condition (ordinary wear and tear
excepted) and shall repaint the containers at a frequency as determined by the Director. The
collector and the renter shall determine and agree upon the placement of the containers to
minimize traffic, aesthetics and other potential effects that may be associated with their
placement.
(d) Where a container is not rented from the collector but is rented from another solid
waste enterprise and approved by the City, the renter shall ensure that the container meets the
standards of quality and maintenance applicable to the containers supplied by the collector.
The renter shall procure the written standards or rules and regulations of the collector prior to
renting from another solid waste enterprise.
(e) Any containers of a one cubic yard or greater size shall be identified with the name
and telephone number of the collector or other solid waste enterprise servicing the container.
The container shall be identified by the type of materials that can be deposited in the container.
(f) Containers shall remain on private property and not in the public right-of-way
except as necessary to accommodate scheduled collection. Containers are permitted in the
public right-of-way only during the day preceding the day of scheduled collection and
terminating the day following such collection.
SECTION 11. If any section, subsection, clause or phrase of this Ordinance is for any reason
held to be invalid, such decision shall not affect the validity of the remaining portion or sections
of the Ordinance. The Council hereby declares that it should have adopted the Ordinance and
each section, subsection, sentence, clause or phrase thereof irrespective of the fact that any
one or more sections, subsections, sentences, clauses or phrases be declared invalid.
SECTION 12. The Council finds that this project is exempt from the provisions of the California
Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA Guidelines,
because it can be seen with certainty that there is no possibility that the ordinance will have a
significant effect on the environment.
//
//
//
Attachment B
Not Yet Approved
2019052201 15
SECTION 13. This Ordinance shall be effective on the thirty-first day after the date of its
adoption.
INTRODUCED:
PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
____________________________ ____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
____________________________ ____________________________
Assistant City Attorney City Manager
____________________________
Director of Public Works
2019042301 1
Attachment C
Not Yet Adopted
Resolution No. _________
Resolution of the Council of the City of Palo Alto Adopting the Negative Declaration
for the Deconstruction/Construction Materials Management Ordinance and Inert
Debris Transfer Facility Site Permitting Project, in Accordance with CEQA
R E C I T A L S
A. Prior to the adoption of this Resolution, the City of Palo Alto prepared an Initial Study
and approved for circulation a Negative Declaration for the Deconstruction/Construction Materials
Management Ordinance and Inert Debris Transfer Facility Site Permitting Project (the “Initial Study/
Negative Declaration”) all in accordance with the requirements of the California Environmental Quality
Act of 1970, together with state and local guidelines implementing said Act, all as amended to date
(collectively “CEQA”).
B. The Initial Study/Negative Declaration evaluated potential environmental impacts
associated with the adoption of an ordinance and implementation of a program that would require
construction and demolition projects to use deconstruction methods and source separate construction
materials to maximize the salvage of materials for reuse and increase the diversion of recyclable
materials, reducing the amount of landfilled waste. The program would also include the use of an inert
debris transfer facility to consolidate materials generated in Palo Alto for offsite transfer. A more
detailed description is set forth in the Negative Declaration.
C. The draft Initial Study/ Negative Declaration was made available for public comment
from March 22, 2019 through April 11, 2019.
D. The City of Palo Alto considered the comments received during the public review period
and prepared a final Initial Study/ Negative Declaration.
E. The Initial Study/ Negative Declaration concluded that implementation of the Project
could not have a significant effect on the environment.
F. The City of Palo Alto is the lead agency on the Project, and the City Council is the
decision-making body for the proposed approval of the Project.
G. The City Council has reviewed and considered the Initial Study/ Negative Declaration for
the Project, together with comments received on the Initial Study/ Negative Declaration, and intends
to take actions on the Project in compliance with CEQA and state and local guidelines implementing
CEQA.
2019042301 2
Attachment C
Not Yet Adopted
H. The Initial Study/ Negative Declaration for the Project are on file in the Department of
Public Works, located at 250 Hamilton Avenue, 6th Floor, Palo Alto, CA 94301 are available for
inspection by any interested person at that location and are, by this reference, incorporated into this
Resolution as if fully set forth herein.
NOW, THEREFORE, THE COUNCIL OF THE CITY OF PALO ALTO HEREBY RESOLVES:
SECTION 1. THE CITY COUNCIL does hereby make the following findings: (1) it has
independently reviewed and analyzed the Initial Study/ Negative Declaration and other information in
the record and has considered the information contained therein, prior to acting upon or approving
the Project, (2) the Initial Study/ Negative Declaration prepared for the Project has been completed in
compliance with CEQA and is consistent with state and local guidelines implementing CEQA, and (3)
the Initial Study/ Negative Declaration represents the independent judgment and analysis of the City of
Palo Alto, as lead agency for the Project. The City Council designates the Director of Public Works, at
250 Hamilton Avenue, 6th Floor, Palo Alto, CA 94301, as the custodian of documents and records of
proceedings on which this decision is based.
//
//
//
//
//
//
//
//
//
//
//
//
2019042301 3
Attachment C
Not Yet Adopted
SECTION 2. THE CITY COUNCIL does hereby find that based upon the entire record of
proceedings before it and all information received that there is no substantial evidence that the Project
will or could have a significant effect on the environment and does hereby adopt the Negative
Declaration. The Initial Study/ Negative Declaration is available for viewing at City of Palo Alto City
Hall, 6th Floor – Public Works Department, 250 Hamilton Avenue, Palo Alto, CA 94301.
INTRODUCED AND PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
________________________________ ______________________________
City Clerk Mayor
APPROVED AS TO FORM:
________________________________ _______________________________
Assistant City Attorney City Manager
________________________________
Director of Planning and Community
Environment
_________________________________
Director of Public Works
FINAL INITIAL STUDY ♦♦♦♦ NEGATIVE DECLARATION
Deconstruction/Construction Materials Management Ordinance
and Inert Debris Transfer Facility Site Permitting
PREPARED BY
City of Palo Alto
250 Hamilton Avenue
Palo Alto, California 94301
Contact: Claire Hodgkins, AICP, Planner
PREPARED WITH THE
ASSISTANCE OF
Sophia Mitchell & Associates, LLC
P.O. Box 1700
Gualala, CA 95445
REPORT DATE April 2019
Attachment D
This report printed on 100% post‐consumer recycled content and process chlorine‐free paper.
CITY OF PALO ALTO P a g e | 3
TABLE OF CONTENTS
Initial Study ............................................................................................................................................................ 5
Environmental Factors Potentially Affected ..................................................................................................... 13
Environmental Checklist ..................................................................................................................................... 14
1 Aesthetics ......................................................................................................................... 14
2 Agriculture and Forestry Resources .................................................................................. 18
3 Air Quality ......................................................................................................................... 20
4 Biological Resources ......................................................................................................... 25
5 Cultural Resources ............................................................................................................ 28
6 Geology and Soils .............................................................................................................. 30
7 Greenhouse Gas Emissions ............................................................................................... 34
8 Hazards and Hazardous Materials .................................................................................... 37
9 Hydrology and Water Quality ........................................................................................... 41
10 Land Use and Planning ...................................................................................................... 44
11 Mineral Resources ............................................................................................................ 46
12 Noise ................................................................................................................................. 47
13 Population and Housing .................................................................................................... 52
14 Public Services .................................................................................................................. 54
15 Recreation ......................................................................................................................... 56
16 Transportation .................................................................................................................. 57
17 Utilities and Service Systems ............................................................................................ 63
18 Energy Conservation ......................................................................................................... 65
19 Wildfire ............................................................................................................................. 66
20 Mandatory Findings of Significance .................................................................................. 68
References .................................................................................................................................................... 70
TABLES
Table 1. LATP Throughput under Proposed Ordinance ................................................................. 10
Table 2. Comparison of Current and Proposed Construction‐Related Waste Transport .............. 11
Table 3 BAAQMD Air Quality Thresholds of Significance .............................................................. 22
Table 4 Expected Daily Operational Air Quality Emissions ............................................................ 23
Table 5 Expected Yearly Operational Air Quality Emissions .......................................................... 23
Table 6 Palo Alto Land Use Compatibility for Community Noise Environments ........................... 49
FIGURES
Figure 1 Proposed Materials Consolidation Site ............................................................................... 6
APPENDICES
Appendix A. Air Quality Memorandum
TABLE OF CONTENTS
4 | P a g e Initial Study Mitigated Negative Declaration
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CITY OF PALO ALTO P a g e | 5
INITIAL STUDY
PROJECT TITLE
Deconstruction/Construction Materials Management Ordinance and Inert Debris
Transfer Facility Site Permitting
LEAD AGENCY NAME AND ADDRESS
City of Palo Alto
250 Hamilton Avenue
Palo Alto, California 94301
CONTACT PERSON AND PHONE NUMBER
Claire Hodgkins, AICP, Planner
(650) 329‐2116
PROJECT LOCATION
The Deconstruction/Construction Materials Management would apply to the entire City
of Palo Alto (City), which is located in Santa Clara County. The inert debris facility
permitting is for a portion of the former Los Altos Treatment Plant (LATP) which is
located at 1237 San Antonio Road in the City (APN # 116‐01‐013 and 116‐01‐047).
PROJECT SPONSOR’S NAME AND ADDRESS
City of Palo Alto
250 Hamilton Avenue
Palo Alto, California 94301
EXISTING SETTING
The proposed inert debris facility (LATP consolidation site) is 1.16 acres of a larger
13.26‐acre site. The area proposed for use is paved. The area of the larger site directly
north of the LATP consolidation site is used as a contractor rental area where
contractors can stage their equipment and construction materials for City projects. The
northern most acreage of the LATP consists of open space, dilapidated buildings and old
sewage ponds – now considered wetlands. The properties adjacent to the LATP site are
commercial businesses. On the east, there are two roads, one that leads into the
contractor rental area of the larger site and the other is San Antonio Road. Commercial
businesses are on the far side of San Antonio Road. Figure 1 shows the proposed LATP
consolidation site.
INITIAL STUDY
6 | P a g e Initial Study Mitigated Negative Declaration
Figure 1 Proposed Materials Consolidation Site
COMPREHENSIVE PLAN DESIGNATION
The proposed LATP consolidation site has a land use designation of Major
Institution/Special Facility according to the City of Palo Alto’s Comprehensive Plan.
As described in the Comprehensive Plan, the Major Institution/Special Facility land use
designation describes areas that are for institutional, academic, governmental and
community service uses and lands that are either publicly owned or operated as non‐
profit organizations.
ZONING
The proposed LATP consolidation site has a zoning designation of PF(D), Public Facilities
District. This designation is designed to accommodate governmental, public utility,
educational, community service, or recreational facilities. Within the PF District,
Public/Quasi‐Public Facility uses are permitted, which includes all facilities owned or
leased, and operated or used, by the City of Palo Alto, the County of Santa Clara, the
State of California, the government of the United States, the Palo Alto Unified School
CITY OF PALO ALTO P a g e | 7
District, or any other governmental agency, or leased by any such agency to another
party.
DESCRIPTION OF PROJECT
The proposed project is the adoption of a new Deconstruction/Construction Materials
Management Ordinance (Ordinance) and the approval of an inert debris transfer facility
to consolidate materials for offsite transfer for the City of Palo Alto (City). The Ordinance
will result in changes to Chapter 5.24 of the City’s Municipal Code.
Deconstruction/Construction Materials Management Ordinance
The proposed Deconstruction/Construction Materials Management Ordinance
(Ordinance) addresses construction materials management, with the primary goals of
increasing: 1) salvage of materials for reuse; 2) recovery of more materials (higher
diversion from landfill disposal); and 3) the quality of recyclable materials for all
construction related projects. The Ordinance would require construction projects to use
deconstruction methods of structure removal (instead of demolition) and the
construction‐related waste would be required to be source separated into categories in
separate bins, boxes or truck trailers1.
Existing C&D Materials Management
Over the last several years, construction related waste constituted approximately 40
percent of all of the waste that was disposed in landfills by all entities from the City. The
City has approved waste diversion goals of 90 percent diversion of solid waste from the
landfill by 2021 and 95 percent diversion by 2030.
Currently, Construction and Demolition (C&D) projects are required to meet the City’s
Green Building requirements to achieve an 80 percent diversion rate with material
currently taken to local C&D recycling facilities, including the Zanker Materials
Processing Facility (Zanker) in San Jose. All single‐family residential projects obtaining a
whole house demolition permit are required to complete a deconstruction/salvage
survey provided by a third‐party entity approved by the Chief Building Official.
Additionally, the City requires that all permittees with projects valued over $25,000 are
required to track the weights of materials removed from project sites in Green Halo.2
1 Source separated materials means recyclable materials that are separated from other recyclable materials or
solid waste and placed in separate containers according to type or category of materials and directly marketed
as a single commodity.
2 Green Halo is a web-based service for waste diversion and recycling tracking.
INITIAL STUDY
8 | P a g e Initial Study Mitigated Negative Declaration
Proposed Construction‐Related Material Management
Under the proposed Ordinance, the following initial conceptual changes and/or
expansion related to construction materials management would occur within a phased
implementation plan:
All single family residential dwelling units and commercial applicants shall obtain
salvage surveys on construction projects valued at $50,000 or more.
Contractors shall ensure that all items indicated on the salvage survey are
properly salvaged and certified by City‐approved salvage facilities.
All projects where structures are being partially or fully removed and where
materials are generated shall be deconstructed (not demolished, except for
concrete and pavement).
Materials generated during deconstruction activities shall be source separated
by contractors (as approved by City) and delivered to City‐approved materials
recovery facilities.
During construction, contractors shall sort and separate all materials in
accordance with the City’s Zero Waste program requirements and sort materials
in appropriate containers.
Contractor shall utilize the City’s contractor, GreenWaste of Palo Alto
(GreenWaste), to haul all materials if using containers/debris boxes. Contractors
can continue to self‐haul material by using trucks but must still source separate
materials in accordance with City ‘s new requirements (above) and deliver
materials to City‐approved materials recovery facilities.
Contractors for all projects over $25,000 shall ensure that the following data is
inputted in Green Halo: 1) the salvaged and reused inventory and their ultimate
disposition and 2) the weights and types of all source separated materials
generated at their site and where these materials were delivered.
The source separated construction related material would be collected by GreenWaste
of Palo Alto (GreenWaste) from the generation site in large debris boxes (7, 15, 20, 30
and 40 cubic yards) as is the current practice, or in smaller bins (2, 3 or 4 cubic yards) on
an on‐call basis. The recycle, compost, and landfill drop boxes/bins would be
differentiated from each other with unique, color‐coded signage identifying the material
type they are meant to contain. Materials to be source separated include, but are not
limited to steel, glass, brick, concrete, asphalt, roofing material, pipe, gypsum,
CITY OF PALO ALTO P a g e | 9
sheetrock, lumber, wood, pallets, rocks, sand, soil, clean cardboard, paper, plastic,
carpet, wood scrap, and metal scrap. It is expected that up to 7,500 tons of material
could be diverted from the landfill each year through implementation of the Ordinance.
Transfer Operation and LATP Transfer Location Description
GreenWaste would deliver the smaller bins of source separated material from the
generation site directly to the LATP transfer location at 1237 San Antonio Road.
Currently materials from the generation sites go directly to the Zanker facility. The
project adds an interim consolidation point at the LATP prior to transfer to the Zanker
facility for the material from generators that are generating smaller amounts of debris
that do not warrant larger debris boxes. Generators that utilize the larger debris boxes
will continue to have their material taken directly to the Zanker facility.
The smaller bins would be weighed on a portable scale and emptied into typically 40
cubic yard sized boxes staged at the LATP site. Once the debris boxes are full, they
would be hauled to the Zanker or related facility. The LATP consolidation site would not
receive putrescible (likely to decay), hazardous, or liquid wastes.
The LATP consolidation site is owned by the City and would be considered as a
Construction and Demolition/Inert Debris Recycling Center. It would be the
southernmost 1.16 acres of a larger 13.26‐acre site (Figure 1).
The area of the larger (13.26 acre) site directly north of the LATP consolidation site is
currently used as a contractor rental area where contractors can stage their equipment
and construction materials for City projects. The northern most acreage of the LATP
consists of open space, dilapidated buildings and old sewage ponds – now considered
wetlands. The properties adjacent to the LATP site are commercial businesses. On the
east, there are two roads, one that leads into the contractor rental area of the larger
site and the other is San Antonio Road. Commercial businesses are on the far side of San
Antonio Road.
No chipping, grinding or other processing would be completed at the LATP. The
maximum timeframe the inert materials would be stored would be a maximum of 30
days. Public access to the LATP site will not be allowed. The 1.16 acre consolidation site
is currently used as the GreenWaste storage yard and is already completely secured by
fencing and locked gates.
GreenWaste would operate the LATP transfer site. As stated above, debris boxes will be
staged at the site to consolidate the materials. GreenWaste will collect the smaller sized
bins full of material from construction sites, bring them to the LATP consolidation site,
weigh the material, and transfer the material in them into the larger debris boxes. The
INITIAL STUDY
1 0 | P a g e Initial Study Mitigated Negative Declaration
LATP consolidation site would operate Monday through Friday from 6:00 AM to 3:00
PM.
Table 1 summarizes the anticipated amount of throughput at the LATP consolidation
site and the associated number of truck trips with implementation of the Ordinance.
Table 1. LATP Throughput under Proposed Ordinance
Item Tons Cubic Yards Trips
Incoming: Construction Related Waste to LATP
Per Year 7,000 tons 48,500 cys
6,063 trips(1)
Average Per Day (260 days) 27 tons 187 cys
23 trips(2)
Outgoing: Consolidated Boxes to Zanker Facility
Per Year 7,000 tons 48,500 cys
1,617 trips
Average Per Day (260 days) 27 tons 187 cys
6 trips(3)
Notes:
(1) The scat truck can take two bins at a time.
(2) Assume 4 cubic yard sized. During busy season four bins at a time could be delivered on flatbed trucks.
(3) Assume 30 cubic yard sized boxes.
As shown in Table 1, incoming trips of bins from the generation sites to LATP would be
6,063 trips/year or 23 trip/day. Outgoing trips of the consolidated boxes to the Zanker
facility would be 1,617 trips /year or 6 trips/day. It is important to note that not all of
these would be new trips since materials are currently being collected from the
generation sites and taken to Zanker facility. Current trips and the net change with
implementation of the Ordinance are discussed in the Trip Generation section of this
project description.
Trip Generation
Implementation of the Ordinance would result in an increase in trip generation for both
vehicles and trucks.
Trip Generation from Materials Salvage ‐ For each individual deconstruction project the
following number of trips would be generated for salvage of reusable materials:
One vehicular trip for a salvage inspector and
One truck trip for taking materials to the salvage yard located at The Reuse
People in Oakland, CA or another not yet specified facility.
CITY OF PALO ALTO P a g e | 1 1
It is expected that an average of 926 construction and/or demolition projects per year
would have to comply with the Ordinance. This number was determined based upon the
three‐year average of permit applications received from 2015 through 2017. When
applying the deconstruction trip generation assumptions for each project, as noted
above, this would result in 926 vehicular trips per year for salvage inspectors, 926 truck
trips per year for taking materials to salvage yards. A one‐way trip length of 28 miles
from the City to the salve yard (Reuse People) in Oakland is assumed for this analysis.
Trip Generation from Source Separated Materials ‐ Table 1 presented the anticipated
number of trips generated by implementation of the Deconstruction/Construction
Materials Management Ordinance as it relates to the transport of bins from the
generation sites to the LATP consolidation site and then to the Zanker facility. It is
estimated that half of the material generated will be in large debris boxes not requiring
consolidation and therefore will go directly to an approved processing facility.
It is important to note that not all of these would be new trips since materials are
currently being collected from the generation sites and taken to the Zanker facility.
Implementation of the Ordinance would 1) result in additional trips from the delivery
and collection of more bins for source separation to and from the generation sites, and
2) result in the interim rerouting of some of the collected C&D material to the LATP for
consolidation before being taken to the Zanker facility. Table 2 provides information on
the number of trips under the current operations and the number of trips under the
proposed Ordinance.
As shown in Table 2, the current handling of construction generated waste results in
approximately 12 trips/day for a total of 168 miles. Implementation of the Ordinance is
expected to generate 35 trips/day for a total of 225 miles. Therefore, the net increase
between current and proposed operations would be 23 trips and approximately 57
additional miles of truck travel.
Table 2. Comparison of Current and Proposed Construction‐Related Waste Transport
Item Distance(1) Trips/Year
Trips/Day
CURRENT OPERATIONS
Construction Related Waste to Zanker Facility 14 miles 3,233 trips/year
12 trips/day
Total Miles Current Operations 45,262 miles per year
168 miles/day
OPERATIONS UNDER PROPOSED ORDINANCE
Construction Related Waste to LATP 3 miles 6,063 trips/year
INITIAL STUDY
1 2 | P a g e Initial Study Mitigated Negative Declaration
23 trips/day
Consolidated Boxes from LATP to Zanker Facility 12 miles 1,617 trips/year
6 trips/day
Construction Related Waste Direct from Generator to Zanker
Facility 14 miles 1,617 trips/year
6 trips/day
Total Trips Per Day Under Proposed Ordinance 35 trips/day
Net Change in Trips Per Day 23 trips/day
Total Miles Per Day Under Proposed Ordinance 225 miles/day
Net Change in Miles Per Day 57 miles/day
Note: (1) Average miles derived from the approximate center of the City at Oregon Expressway and
Middlefield Road to LATP facility or Zanker Facility except those from the LATP facility to the Zanker
facility.
SURROUNDING LAND USES
The area of the larger site directly north of the LATP consolidation site is used as a
contractor rental area where contractors can stage their equipment and construction
materials for City projects. The northern most acreage of the LATP consists of open
space, dilapidated buildings and old sewage ponds – now considered wetlands. The
properties adjacent to the LATP site are developed. To the south are light
industrial/office buildings. To the west and northwest, on the opposite side of San
Antonio Road are additional light industrial/office buildings.
OTHER PUBLIC AGENCIES WHOSE APPROVAL IS REQUIRED
The LATP consolidation site would be considered as a Construction and Demolition/Inert
Debris Recycling Center. Approval for this designation has come from the County of
Santa Clara Department of Environmental Health (DEH) Solid Waste Program which is
certified as the Local Enforcement Agency (LEA) by the California Department of
Resources, Recycling and Recovery (CalRecycle). The LEA regulates solid waste facilities
to ensure compliance with state minimum standards. The LEA would be a Responsible
Agency under the California Environmental Quality Act (CEQA) for the project.
ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED
This project would potentially affect the environmental factors checked below, involving at
least one impact that is "Potentially Significant" or "Less than Significant with Mitigation
Incorporated" as indicated by the checklist on the following pages.
D Aesthetics Agriculture and Forest Air Quality
Resources
D Biological Resources Cultural and Tribal Geology and Soils .
Resources
D Greenhouse Gas Emissions Hazards and Hazardous Hydrology/ Water Quality
Materials
D Land Use and Planning Mineral Resources Noise
D Population and Housing Public Services Recreation
D Transportation Tribal Cultural Energy
Resources
D Wildfire Mandatory Findings
of Significance
DETERMINATION
Based on this initial evaluation:
I find that the proposed project COULD NOT have a significant effect on the environment, and a
NEGATIVE DECLARATION will be prepared .
I find that although the proposed project could have a significant effect on the environment,
there will not be a significant effect in this case because revisions to the project have been made
by or agreed to by the project proponent . A MITIGATED NEGATIVE DECLARATION will be
prepared.
I find that the proposed project MAY have a significant effect on the environment, and an
ENVIRONMENTAL IMPACT REPORT is required.
I find that the proposed project MAY have a "potentially significant impact" or "potentially
significant unless mitigated" impact on the environment, but at least one effect (1) has been
adequately analyzed in an earlier document pursuant to applicable legal standards, and (2) has
been addressed by mitigation measures based on the earlier analysis as described on attached
sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects
that remain to be addressed.
I find that although the proposed project could have a significant effect on the environment,
because all potential 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 that earlier EIR or NEGATIVE DECLARATION, including revisions or
mitigation measures that are imposed upon the proposed project, nothing further is required.
?--/
Signature Date
&t.Ac,r.c HiJIJll:.DJJ I AttP
Printed Name Title
CITY OF PALO AL TO Page I 13
ENVIRONMENTAL CHECKLIST
AESTHETICS
1 4 | P a g e Initial Study Negative Declaration
ENVIRONMENTAL CHECKLIST
1 Aesthetics
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project have any of the following impacts:
a. Have a substantial adverse effect on a
scenic vista? □ □ ■ □
b. Substantially damage scenic resources,
including, but not limited to, trees, rock
outcroppings, and historic buildings within
a state scenic highway? □ □ ■ □
c. In non‐urbanized areas, substantially
degrade the existing visual character or
quality of public views of the site and its
surroundings? (Public views are those that
are experienced from publicly accessible
vantage points). If the project is in an
urbanized area, would the project conflict
with the applicable zoning and other
regulations governing scenic quality? □ □ □ ■
d. Create a new source of substantial light or
glare that would adversely affect daytime
or nighttime views in the area? □ □ □ ■
e. Substantially shadow public open space
(other than public streets and adjacent
sidewalks) between 9:00 a.m. and 3:00
p.m. from September 21 to March 21? □ □ □ ■
a. Have a substantial adverse effect on a scenic vista?
Proposed Ordinance
The proposed Ordinance will require additional materials separation at construction and
deconstruction sites. This could result in the placement of additional materials collection
bins at construction sites and some of these sites could be located along scenic routes, view
corridors or near primary gateways in the City. Since these additional bins would be placed
within active construction/deconstruction zones, and for a short duration, it is not
ENVIRONMENTAL CHECKLIST
AESTHETICS
CITY OF PALO ALTO P a g e | 1 5
anticipated they would result in a noticeable visual change compared to the concurrent
construction/ deconstruction activities. Impacts would be less than significant.
LATP Consolidation Site
The area of the larger site directly north of the proposed LATP consolidation site is used as a
contractor rental area where contractors can stage their equipment and construction
materials for City projects. The northern most acreage of the proposed LATP consolidation
site consists of open space, dilapidated buildings and old sewage ponds – now considered
wetlands.
The properties adjacent to the LATP site are developed. To the south are light industrial/
office buildings. To the west and northwest, on the opposite side of San Antonio Road are
additional light industrial/office buildings.
The site is not identified as being along a major view corridor, scenic route, or near a
primary gateway, as shown on Map L‐4 of the adopted Comprehensive Plan. Proposed
consolidation and temporary storage activities at the proposed LATP site would occur
behind a fenced area in an existing storage yard that is already fenced, and would not be
visible from a public street. There would be no visible change from offsite locations. Impacts
would be less than significant.
LESS THAN SIGNIFICANT IMPACT
b. Substantially damage scenic resources, including, but not limited to, trees, rock
outcroppings, and historic buildings within a state scenic highway?
There are no Officially Designated State Scenic Highways in Palo Alto. A very small segment
of Interstate 280 passes through the City (north of Page Mill Road), and that segment is
eligible for listing as a State Scenic Highway but is not officially designated.
Proposed Ordinance
The proposed Ordinance will require additional materials separation at construction and
deconstruction sites. This could result in the placement of additional materials collection
bins at construction sites and some of these sites could be located along scenic routes, view
corridors or near primary gateways in the City. Since these additional bins would be placed
within active construction/deconstruction zones, it is not anticipated they would result in a
noticeable visual change compared to the concurrent construction/ deconstruction
activities. However, all construction sites are required to have perimeter fencing for safety.
Though the fencing may be of any type, fencing with visual screening is used on most sites
for increased site security. Therefore, bins on construction sites would not typically be
visible from the public right‐of‐way. Impacts would be less than significant.
LATP Consolidation Site
The proposed LATP consolidation site is not identified as being adjacent to a scenic corridor
in the adopted Comprehensive Plan. The closest state highway to the project site is US
Highway 101, which is located approximately 0.2 miles south of the project site. US Highway
101 in Santa Clara is not identified as an Officially Designated State Scenic Highway or an
eligible State Scenic Highway by Caltrans. Proposed materials consolidation and temporary
storage activities will occur within already paved areas at the site and would not result in
ENVIRONMENTAL CHECKLIST
AESTHETICS
1 6 | P a g e Initial Study Negative Declaration
any impact to trees rock outcroppings or historic buildings. No impact is identified for this
issue area.
LESS THAN SIGNIFICANT IMPACT
c. In non‐urbanized areas, substantially degrade the existing visual character or quality of
public views of the site and its surroundings? (Public views are those that are
experienced from publicly accessible vantage points). If the project is in an urbanized
area, would the project conflict with the applicable zoning and other regulations
governing scenic quality?
Proposed Ordinance
The proposed Ordinance would apply to all areas within the City, both urbanized and non‐
urbanized. The proposed Ordinance will require additional materials separation at
construction and deconstruction sites. This could result in the temporary placement of
additional materials collection bins at active construction site throughout the City. Since
these additional bins would be placed within active construction/ deconstruction zones and
for a short duration, it is not anticipated they would result in a substantial degradation to
the visual character or quality of the sites. Impacts would be less than significant.
LATP Consolidation Site
The proposed LATP Consolidation site is located in an urbanized portion of the City. The site
is not identified as being along a major view corridor, scenic route or near a primary
gateway, as shown on Map L‐4 of the adopted Comprehensive Plan. The proposed use of
construction/deconstruction materials consolidation and temporary storage would be
consistent with the uses allowed under the Public Facilities District designation. No conflict
with zoning or other regulations governing scenic quality would occur.
LESS THAN SIGNIFICANT IMPACT
d. Create a new source of substantial light or glare that would adversely affect daytime or
nighttime views in the area?
Proposed Ordinance
The proposed Ordinance would not create any new sources of substantial light or glare. The
proposed Ordinance addresses the management of deconstruction and construction
materials. Implementation of the proposed Ordinance would not create a new source of
substantial light or glare that would adversely affect daytime or nighttime views and no
impact is identified.
LATP Consolidation Site
The proposed LATP consolidation site already has lighting for safety and security. No new
lighting is proposed. Additionally, no new structures or other equipment is proposed at the
LATP consolidation site which would create a new source of lighting or glare. No impact is
identified for this issue area.
NO IMPACT
ENVIRONMENTAL CHECKLIST
AESTHETICS
CITY OF PALO ALTO P a g e | 1 7
e. Substantially shadow public open space (other than public streets and adjacent
sidewalks) between 9:00 a.m. and 3:00 p.m. from September 21 to March 21?
Proposed Ordinance
The proposed Ordinance would not result in any conditions which would result in
substantial shadow to public open spaces. No impact is identified for this issue area.
LATP Consolidation Site
The proposed LATP consolidation site will not result in the building of any structures, so
there would not be any potential to shadow public spaces. No impact is identified for this
issue area.
NO IMPACT
ENVIRONMENTAL CHECKLIST
AGRICULTURE AND FORESTRY RESOURCES
1 8 | P a g e Initial Study Negative Declaration
2 Agriculture and Forestry Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project have any of the following impacts:
a. Convert Prime Farmland, Unique Farmland,
Farmland of Statewide Importance
(Farmland), as shown on maps prepared
pursuant to the Farmland Mapping and
Monitoring Program of the California
Resources Agency, to non‐agricultural use? □ □ □ ■
b. Conflict with existing zoning for agricultural
use or a Williamson Act contract? □ □ □ ■
c. Conflict with existing zoning for or cause
rezoning of forest land (as defined in Public
Resources Code Section 12220(g));
timberland (as defined by Public Resources
Code Section 4526); or timberland zoned
Timberland Production (as defined by
Government Code Section 51104(g))? □ □ □ ■
d. Result in the loss of forest land or
conversion of forest land to non‐forest use? □ □ □ ■
e. Involve other changes in the existing
environment which, due to their location or
nature, could result in conversion of
Farmland to non‐agricultural use or
conversion of forest land to non‐forest use? □ □ □ ■
a. Would the project convert Prime Farmland, Unique Farmland, Farmland of Statewide
Importance (Farmland), as shown on the maps prepared pursuant to the Farmland
Mapping and Monitoring Program of the California Resources Agency, to non‐
agricultural use?
b. Would the project conflict with existing zoning for agricultural use, or a Williamson Act
contract?
c. Would the project conflict with existing zoning for, or cause rezoning of, forest land (as
defined in Public Resources Code Section 12220(g)), timberland (as defined by Public
ENVIRONMENTAL CHECKLIST
AGRICULTURE AND FORESTRY RESOURCES
CITY OF PALO ALTO P a g e | 1 9
Resources Code Section 4526), or timberland zoned Timberland Production (as defined
by Government Code Section 51104(g))?
d. Would the project result in the loss of forest land or conversion of forest land to non‐
forest use?
e. Would the project involve other changes in the existing environment, which, due to their
location or nature, could result in conversion of Farmland to non‐agricultural use?
Proposed Ordinance
The proposed Ordinance addresses the management of deconstruction and construction
materials to reduce the amount of materials that go to the landfill. As such, the proposed
Ordinance would have no impact with respect to conversion of Prime Farmland, Unique
Farmland, or Farmland of Statewide Importance (Farmland) to non‐agricultural use; conflict
with existing agricultural zoning or Williamson Act contracts; result in the loss of forest land
or conversion of forest land to non‐forest use; or other conversion of farmland to non‐
agricultural use.
LATP Consolidation Site
The proposed LATP consolidation site is located on Urban and Built‐Up Land, per the
Department of Conservation’s Important Farmland Finder (DOC 2016). The site is not
identified as any farmland type, it is not enrolled in Williamson Act contracts, and it does
not support forest land or resources. The site is not located on or adjacent to agricultural
land or forest land and the proposed project would not involve any development that could
result in the conversion of farmland to non‐agricultural uses. The proposed LATP
consolidation site is currently used for storage and staging of construction materials for
contractors for City projects. For these reasons, the project would have no impact with
respect to conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide
Importance (Farmland) to non‐agricultural use; conflict with existing agricultural zoning or
Williamson Act contracts; result in the loss of forest land or conversion of forest land to
non‐forest use; or other conversion of farmland to non‐agricultural use.
NO IMPACT
ENVIRONMENTAL CHECKLIST
AIR QUALITY
2 0 | P a g e Initial Study Negative Declaration
3 Air Quality
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project have any of the following impacts:
a. Conflict with or obstruct implementation of
the applicable air quality plan? □ □ ■ □
b. 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? □ □ ■ □
c. Expose sensitive receptors to substantial
pollutant concentrations? □ □ ■ □
d. Result in other emission (such as those
leading to odors) adversely affecting a
substantial number of people? □ □ ■ □
AIR QUALITY STANDARDS AND ATTAINMENT
The proposed Ordinance would apply to the entire City. The proposed LATP consolidation
site is located at 1237 San Antonio Road. The Bay Area Air Quality Management District
(BAAQMD) regulates air quality emissions within the City.
AIR QUALITY MANAGEMENT
The Bay Area 2017 Clean Air Plan (CAP) provides a plan to improve Bay Area air quality and
protect public health as well as the climate. The legal impetus for the CAP was to update the
most recent ozone plan, the 2010 Clean Air Plan, to comply with state air quality planning
requirements as codified in the California Health & Safety Code. Although steady progress in
reducing ozone levels in the Bay Area has been made, the region continues to be designated
as non-attainment for both the one-hour and eight-hour state ozone standards. In addition,
emissions of ozone precursors in the Bay Area contribute to air quality problems in
neighboring air basins. Under these circumstances, state law requires the CAP to include all
feasible measures to reduce emissions of ozone precursors and reduce transport of ozone
precursors to neighboring air basins (BAAQMD 2017).
In 2006, the U.S. Environmental Protection Agency (EPA) tightened the national 24‐hour
PM2.5 standard regarding short‐term exposure to fine particulate matter from 65 µg/m3
(micro‐grams per cubic meter) to 35 µg/m3. Based on air quality monitoring data for years
2006‐2008 showing that the region was slightly above the standard, U.S. EPA designated the
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AIR QUALITY
CITY OF PALO ALTO P a g e | 2 1
Bay Area as non‐attainment for the 24‐hour national standard in December 2008. This
triggered the requirement for the Bay Area to prepare a State Implementation Plan (SIP)
submittal to demonstrate how the region would attain the standard. However, data for
both the 2008‐2010 and the 2009‐2011 cycles showed that Bay Area PM2.5 levels currently
meet the standard. On October 29, 2012, the U.S. EPA issued a proposed rule‐making to
determine that the Bay Area now attains the 24‐hour PM2.5 national standard. Based on
this, the Bay Area is required to prepare an abbreviated SIP submittal which includes an
emission inventory for primary (directly‐emitted) PM2.5, as well as precursor pollutants that
contribute to formation of secondary PM in the atmosphere; and amendments to the
BAAQMD New Source Review (NSR) to address PM2.5 (adopted December 2012).3 However,
key SIP requirements to demonstrate how a region will achieve the standard (i.e. the
requirement to develop a plan to attain the standard) will be suspended as long as
monitoring data continues to show that the Bay Area attains the standard.
In addition to preparing the “abbreviated” SIP submittal, the BAAQMD has prepared a
report entitled “Understanding Particulate Matter: Protecting Public Health in the San
Francisco Bay Area” (2012). The report will help to guide the BAAQMD’s on‐going efforts to
analyze and reduce PM in the Bay Area in order to better protect public health. The Bay
Area will continue to be designated as “non‐attainment” for the national 24‐hour PM2.5
standard until such time as the Air District elects to submit a “redesignation request” and a
“maintenance plan” to the U.S. EPA, and the U.S. EPA approves the proposed redesignation.
AIR EMISSION THRESHOLDS
The BAAQMD May 2017 CEQA Air Quality Guidelines include revisions made to the 2010
Guidelines, addressing the California Supreme Court’s 2015 opinion in the Cal. Bldg. Indus.
Ass’n vs. Bay Area Air Quality Mgmt. Dist., 62 Cal. 4th 369 (BAAQMD 2017a). For this Initial
Study, the City of Palo Alto has determined that the BAAQMD’s significance thresholds in
the updated May 2017 BAAQMD CEQA Guidelines for project operations in the Basin are
the most appropriate thresholds for use in determining air quality impacts of the proposed
project. Table 1 presents the significance thresholds for construction and operational‐
related criteria air pollutant and precursor emissions being used for the purposes of this
analysis. These represent the levels at which a project‘s individual emissions of criteria air
pollutants or precursors would result in a cumulatively considerable contribution to the
Basin‘s existing air quality conditions. For the purposes of this analysis, the proposed project
would result in a significant impact if construction or operational emissions would exceed
any of the thresholds shown inTable 1.4
3 PM is made up of particles that are emitted directly, such as soot and fugitive dust, as well as secondary particles that
are formed in the atmosphere from chemical reactions involving precursor pollutants such as oxides of nitrogen (NOx),
sulfur oxides (SOx), volatile organic compounds (VOC), and ammonia (NH3).
4 Note the thresholds for PM10 and PM2.5 apply to construction exhaust emissions only.
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AIR QUALITY
2 2 | P a g e Initial Study Negative Declaration
Table 1 BAAQMD Air Quality Thresholds of Significance
Pollutant/
Precursor
Construction‐Related Thresholds Operation‐Related Thresholds
Average
Daily Emissions
(pounds per day)
Average
Daily Emissions
(pounds per day)
Maximum
Annual Emissions
(tons per year)
ROG 54 54 10
NOX 54 54 10
PM10 82
(exhaust)
82 15
PM2.5 54
(exhaust)
54 10
Notes: ROG = reactive organic gases; NOX = oxides of nitrogen; PM2.5 = fine particulate matter with an aerodynamic resistance
diameter of 2.5 micrometers or less; PM10 = respirable particulate matter with an aerodynamic resistance diameter of 10
micrometers or less.
Source: Table 2‐1, BAAQMD 2017b.
In addition, a significant air quality impact would occur if the project design or project
construction does not incorporate control measures recommended by the BAAQMD to
control emissions during construction (as listed in Table 8‐1 of the BAAQMD CEQA
Guidelines).
IMPACT ANALYSIS
a. Would the project conflict with or obstruct implementation of the applicable air quality
plan?
b. Would the project result in a cumulatively considerable net increase of any criteria
pollutant for which the project region is non‐attainment under an applicable federal or
state ambient air quality standard?
Construction Emissions
The project will not result in any construction emissions since no construction is proposed
at the LATP consolidation site. Construction and/or deconstruction activities that would
occur at the generator sites would have already been analyzed for potential environmental
impacts, including any air quality impact. The proposed Ordinance addresses the debris
generated by construction and deconstruction projects that would have already been
approved.
Operational Emissions
Operational emissions from the project would be primarily from vehicular emissions. Some
dust emissions may be created when bins are consolidated into larger boxes at the LATP
site.
Emissions were modeled via CalEEMod and the model was modified by manually adjusting
vehicular trips to 100 percent trucks. The calculated operational daily emissions are
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AIR QUALITY
CITY OF PALO ALTO P a g e | 2 3
identified in Table 4 and yearly emissions are shown in Table 5 and shown in Appendix A to
the air quality technical memorandum (LDN 2019).
Table 4 Expected Daily Operational Air Quality Emissions
ROG NOx PM2.5 PM10
Summer Scenario
Operational Emission Estimates (Lb/Day)
0.081
1.815
0.023
0.062
BAAQMD Thresholds 54 54 54 82
Significant? No No No No
Winter Scenario
Operational Estimates (Lb/Day) 0.088 1.840 0.023 0.062
Significant? No No No No
Source: LDN 2019
Table 5 Expected Yearly Operational Air Quality Emissions
ROG NOx PM2.5 PM10
Annual Scenario
Operational Emission Estimates (Ton/Year)
0.011
0.238
0.003
0.008
BAAQMD Thresholds (Ton/Year) 10 10 10 15
Significant? No No No No
Source: LDN 2019
Based upon the conclusions presented in Tables 4 and 5, the daily and annual operations of
the deconstruction/construction materials management and inert debris transfer facility
activities are anticipated to produce air quality emissions well below BAAQMD thresholds.
Impacts would be less than significant.
The project would not 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. All daily and annual operational emission would be well
below BAAQMD screening thresholds.
CALIFORNIA AMBIENT AIR QUALITY STANDARDS FOR CARBON MONOXIDE
To ensure safe levels of local CO emissions, CAAQS sets the following thresholds for CO:
9.0 ppm (8‐hour average)
20.0 ppm (1‐hour average)
BAAQMD provides a preliminary screening methodology to conservatively determine
whether a proposed project would exceed CO thresholds. If the following criteria are met, a
project would result in a less than significant impact related to local CO concentrations:
ENVIRONMENTAL CHECKLIST
AIR QUALITY
2 4 | P a g e Initial Study Negative Declaration
1. Project is consistent with an applicable congestion management program established by
the county congestion management agency for designated roads or highways, regional
transportation plan, and local congestion management agency plans.
2. The project traffic would not increase traffic volumes at affected intersections to more
than 44,000 vehicles per hour.
3. The project traffic would not increase traffic volumes at affected intersections to more
than 24,000 vehicles per hour where vertical and/or horizontal mixing is substantially
limited (e.g., tunnel, parking garage, bridge underpass, natural or urban street canyon,
below‐grade roadway).
Analysis of the proposed project’s traffic impacts (Section 16) indicates that the proposed
project meets all three criteria listed above. As a result, the project would have a less than
significant impact related to local CO concentrations.
As the project would be in compliance with BAAQMD criteria pollutant thresholds, and
CAAQS CO thresholds, the project would not result in individually or cumulatively significant
impacts to air quality.
LESS THAN SIGNIFICANT IMPACT
c. Would the project expose sensitive receptors to substantial pollutant concentrations?
Sensitive receptors, such as hospitals, schools, daycare facilities, elderly housing and
convalescent facilities, could be located near proposes construction and deconstruction
sites, since these projects could occur in all areas of the City. The sorting of construction
materials at generator sites and the pick‐up and delivery of sorting bins would not result in
the generation of substantial pollutant concentrations. There are no sensitive receptors
adjacent to the proposed LATP consolidation site. Further the activities proposed at the
LATP site (consolidation and temporary storage of inert construction debris) are not a type
to generate substantial pollutant concentrations. Impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
d. Would the project result in other emission (such as those leading to odors) adversely affecting a
substantial number of people?
Odors are typically associated with industrial projects involving the use of chemicals,
solvents, petroleum products, and other strong‐smelling elements used in manufacturing
processes. The proposed project, which includes implementation of a construction
materials management program and a consolidation site at the former LATP site for inert
materials consolidation and storage, would not result in activities which could result in
other emissions, such as those leading to odors, that would adversely affect a substantial
number of people. The LATP consolidation site would not receive putrescible (likely to
decay), hazardous, or liquid wastes. No impact is identified for this issue area.
NO IMPACT
ENVIRONMENTAL CHECKLIST
BIOLOGICAL RESOURCES
CITY OF PALO ALTO P a g e | 2 5
4 Biological Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project have any of the following impacts:
a. Have a substantial adverse effect, either
directly or through habitat modifications, on
any species identified as a candidate,
sensitive, or special status species in local or
regional plans, policies, or regulations, or by
the California Department of Fish and
Wildlife or U.S. Fish and Wildlife Service? □ □ □ ■
b. Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional
plans, policies, or regulations, or by the
California Department of Fish and Wildlife or
U.S. Fish and Wildlife Service? □ □ □ ■
c. Have a substantial adverse effect on state or
federally protected wetlands (including, but
not limited to, marsh, vernal pool, coastal,
etc.) through direct removal, filling,
hydrological interruption, or other means? □ □ □ ■
d. Interfere substantially with the movement of
any native resident or migratory fish or
wildlife species or with established native
resident or migratory wildlife corridors, or
impede the use of native wildlife nursery
sites? □ □ □ ■
e. Conflict with any local policies or ordinances
protecting biological resources, such as a
tree preservation policy or as defined by the
City of Palo Alto’s Tree Preservation
Ordinance (Municipal Code Section 8.10)? □ □ □ ■
f. Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural
Community Conservation Plan, or other
approved local, regional, or state habitat
conservation plan? □ □ □ ■
ENVIRONMENTAL CHECKLIST
BIOLOGICAL RESOURCES
2 6 | P a g e Initial Study Negative Declaration
a. Would the project have a substantial adverse effect, either directly or through habitat
modifications, on any species identified as candidate, sensitive, or special status in local
or regional plans, policies, or regulations, or by the California Department of Fish and
Wildlife or the U.S. Fish and Wildlife Service?
b. Would the project have a substantial adverse effect on any riparian habitat or other
sensitive natural community identified in local or regional plans, policies, or regulations,
or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
c. Would the project have a substantial adverse effect on state on federally protected
wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct
removal, filling, hydrological interruption, or other means?
d. Would the project interfere substantially with the movement of any native resident or
migratory fish or wildlife species or with established native resident or migratory wildlife
corridors, or impede the use of native wildlife nursery sites?
Proposed Ordinance
The proposed Ordinance applies to the entire City and within the City there are sensitive
biological resources including sensitive habitats, sensitive species, riparian areas, state and
federally protected wetlands, and/or wildlife corridors or nursery sites.
The proposed Ordinance addresses materials separation for construction/deconstruction
projects. While there is a possibility that future construction/deconstruction activities could
impact sensitive biological resources, such projects would be subject to review and approval
by City staff and would be subject to their own environmental review and mitigation (if
sensitive biological resources are present). The proposed Ordinance does not directly or
indirectly impact sensitive biological resources, rather it addresses the management and
disposition of materials from debris generated by construction/deconstruction activities.
Therefore, no impact is identified for this issue area.
LATP Consolidation Site
The proposed LATP consolidation site is located in an urbanized area of Palo Alto, and has
been graded and paved for the existing construction staging and equipment storage uses
that already occur on the site. There are no sensitive resources on the proposed
consolidation site.
The addition of construction and deconstruction debris consolidation and temporary
storage of these materials would not result in any impacts to habitat or species protected
by CDFW or USFWS, riparian habitat or other sensitive natural communities, state or
federally protected wetlands, nor would it interfere substantially with the movement of any
native resident or migratory fish or wildlife species, wildlife corridors, or wildlife nursery
site. No impact is identified.
NO IMPACT
ENVIRONMENTAL CHECKLIST
BIOLOGICAL RESOURCES
CITY OF PALO ALTO P a g e | 2 7
e. Would the project conflict with any local policies or ordinances protecting biological
resources, such as a tree preservation policy or as defined by the City of Palo Alto’s Tree
Preservation Ordinance (Municipal Code Section 8.10)?
According to the City’s CEQA thresholds, a significant impact would occur if the project
would conflict with the City’s Tree Preservation Ordinance. The purpose of the City of Palo
Alto Tree Preservation Ordinance (PAMC Chapter 8.10) is to promote the health, safety,
welfare, and quality property within the city, and the establishment of standards for
removal, maintenance, and planting of trees. In establishing these procedures and
standards, it is the City's intent to encourage the preservation of trees.
Proposed Ordinance
The proposed Ordinance addresses materials separation for construction/deconstruction
projects. While there is a possibility that future construction/deconstruction activities could
impact trees, such projects would be subject to review and approval by City staff and would
be subject to their own environmental review. The proposed Ordinance does not directly or
indirectly impact trees, rather it addresses the management and disposition of debris
materials generated from construction/deconstruction activities. Therefore, no impact is
identified for this issue area.
LATP Consolidation Site
The activities proposed at the LATP consolidation site would occur within already
developed/paved areas and would not result in any impact to trees.
NO IMPACT
f. Would the project conflict with the provisions of an adopted Habitat Conservation Plan,
Natural Community Conservation Plan, or other approved local, regional, or state
habitat conservation plan?
The proposed project would not occur within an approved Habitat Conservation Plan,
Natural Community Conservation Plan, or other approved local, regional, or state habitat
conservation plan (CDFW 2017). No impact would occur.
NO IMPACT
ENVIRONMENTAL CHECKLIST
CULTURAL RESOURCES
2 8 | P a g e Initial Study Negative Declaration
5 Cultural Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project have any of the following impacts:
a. Cause a substantial adverse change in the
significance of a historical resource as
defined in§15064.5? □ □ □ ■
b. Cause a substantial adverse change in the
significance of an archaeological resource
as defined in §15064.5? □ □ □ ■
c. Disturb any human remains, including those
interred outside of formal cemeteries? □ □ □ ■
d. Cause a substantial adverse change in the
significance of a tribal cultural resource,
defined in Public Resources Code section
21074 as either:
1. A site, feature, place, cultural landscape
that is geographically defined in terms
of the size and scope of the landscape,
sacred place, or object with cultural
value to a California Native American
Tribe, that is listed or eligible for listing
on the California Register of Historical
Resources, or on a local register of
historical resources as defined in Public
Resources Code section 5020.1(k), or □ □ □ ■
2. A resource determined by a lead
agency, in its discretion and supported
by substantial evidence, to be significant
according to the historical register
criteria in Public Resources Code section
5024.1 (c), and considering the
significance of the resource to a
California Native American tribe? □ □ □ ■
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CULTURAL RESOURCES
CITY OF PALO ALTO P a g e | 2 9
a. Cause a substantial adverse change in the significance of a historical resource as defined
in§15064.5?
b. Cause a substantial adverse change in the significance of an archaeological resource as
defined in §15064.5?
c. Would the project disturb any human remains, including those interred outside of formal
cemeteries?
d.1. Would the project cause a substantial adverse change in the significance of a tribal
cultural resource as defined in Public Resources Code 21074 that is listed or eligible for
listing in the California Register of Historical Resources, or in a local register of historical
resources as defined in Public Resources Code section 5020.1(k)?
d.2. Would the project cause a substantial adverse change in the significance of a tribal
cultural resource as defined in Public Resources Code 21074 that is a resource
determined by the lead agency, in its discretion and supported by substantial evidence,
to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code
Section 2024.1?
Proposed Ordinance
The proposed Ordinance addresses materials separation for construction/deconstruction
projects. While there is a possibility that future construction/deconstruction activities could
be located on sites that contain historical resources, archaeological resources, tribal cultural
resources or could encounter human remains interred outside of formal cemeteries, such
projects would be subject to review and approval by City staff and would be subject to their
own environmental review. The implementation of the Ordinance does not increase the
potential for impacting these types of resources. Any inadvertent finds of human remains
would be handled in a manner consistent with California Health and Safety Code Section
7050.5.
The proposed Ordinance does not directly or indirectly impact historical resources,
archaeological resources, or tribal cultural resources, rather it addresses the management
and disposition of debris materials from construction/deconstruction activities.
LATP Consolidation Site
The proposed LATP consolidation site is already developed and paved. The proposed site is
not identified as containing any cultural or historic resources in Map L‐5 in the City’s
adopted Comprehensive Plan. The consolidation and temporary storage of
construction/deconstruction debris would occur within paved areas and would not result in
any impact to historical resources, archaeological resources, or tribal cultural resources.
NO IMPACT
ENVIRONMENTAL CHECKLIST
GEOLOGY AND SOILS
3 0 | P a g e Initial Study Negative Declaration
6 Geology and Soils
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project have any of the following impacts:
a. Expose people or structures to potentially
substantial adverse effects, including the
risk of loss, injury, or death involving:
1. 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. □ □ □ ■
2. Strong seismic ground shaking? □ □ □ ■
3. Seismic‐related ground failure,
including liquefaction? □ □ ■ □
4. Landslides? □ □ □ ■
5. Expansive Soils? □ □ □ ■
b. Result in substantial soil erosion or loss of
topsoil? □ □ □ ■
c. Be located on a geologic unit or that would
become unstable as a result of the project,
and potentially result in on or offsite
landslide, lateral spreading, subsidence,
liquefaction, or collapse? □ □ ■ ■
d. Have soils incapable of adequately
supporting the use of septic tanks or
alternative wastewater disposal systems
where sewers are not available for the
disposal of wastewater? □ □ □ ■
ENVIRONMENTAL CHECKLIST
GEOLOGY AND SOILS
CITY OF PALO ALTO P a g e | 3 1
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
e. Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature? □ □ □ ■
a1. Would the project expose people or structures to potential substantial adverse effects, including
the risk of loss, injury, or death involving 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?
The proposed LATP consolidation site is not located in an area that has been identified as
having a known earthquake fault as delineated on the most recent Alquist‐Priolo
Earthquake Fault Zoning Map (Santa Clara County 2019). The nearest known active fault is
the San Andreas Fault, which is approximately eight miles west of the site. As a result, the
proposed consolidation site would not be subject to ground rupture. No impact would
occur.
NO IMPACT
a2. Would the project expose people or structures to potential substantial adverse effects, including
the risk of loss, injury, or death involving strong seismic ground shaking?
As with much of the Bay Area region, the City is susceptible to strong seismic ground
shaking in the event of a major earthquake. Nearby active faults include the San Andreas
Fault. The project, which includes the implementation of an Ordinance addressing
construction and deconstruction materials management and the use of a portion of the
LATP site to consolidate and temporarily store these materials, would not expose people or
structures to substantial adverse effects from seismic ground shaking. No development or
construction of structures is proposed to be built as part of the project.
NO IMPACT
a3. Would the project expose people or structures to potential substantial adverse effects, including
the risk of loss, injury, or death involving seismic‐related ground failure, including liquefaction?
Liquefaction is a condition that occurs when unconsolidated, saturated soils change to a
near‐liquid state during groundshaking.
According to Map S‐3 (Liquefaction Risk) in the Comprehensive Plan, the proposed LATP
consolidation site is located in an area with a very high risk for liquefaction. No construction
or development is proposed at the site. Proposed activities at the LATP site would be the
consolidation and short‐term storage of construction and deconstruction debris. This would
not be characterized as a use that would expose people or structures to potential
ENVIRONMENTAL CHECKLIST
GEOLOGY AND SOILS
3 2 | P a g e Initial Study Negative Declaration
substantial adverse effects, including the risk of loss, injury, or death involving seismic‐
related ground failure, including liquefaction. Impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
a4. Would the project expose people or structures to potential substantial adverse effects, including
the risk of loss, injury, or death involving landslides?
Earthquakes can trigger landslides that may cause injuries and damage. The proposed LATP
consolidation site is located on a level piece of property in a lower‐elevation portion of the
City. No construction or development is proposed at the LATP consolidation site. The
proposed use includes the consolidation and short‐term storage of construction and
deconstruction debris. This would not be characterized as a use that would expose people
or structure to potential substantial adverse effects from landslides. The project would not
increase the risk of exposure of people or structures to adverse effects involving landslides.
NO IMPACT
a.5 Would the project expose people or structures to potential substantial adverse effects, including
the risk of loss, injury, or death involving expansive soils?
Per Map S‐4 (Geotechnical Hazards) in the City’s Comprehensive Plan, the LATP
consolidation site is not identified as being located in an area with expansive soils. The
consolidation and temporary storage of construction/deconstruction debris would not
result in the exposure of people or structure to adverse effects due to expansive soils. No
impact is identified for this issue area.
NO IMPACT
b. Would the project result in substantial soil erosion or loss of topsoil?
The proposed LATP consolidation site would not require any ground disturbance or other
activities which could result in a substantial erosion or loss of top soil. The consolidation of
construction/deconstruction debris materials and temporary storage of the bins and boxes
would occur within paved areas. No impact is identified for this issue area.
NO IMPACT
c. Would the project 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?
The project does not propose any construction or activities that could result in disturbance
of unstable soils thereby causing on‐ or off‐site landslide, lateral spread, subsidence,
liquefaction or collapse. The proposed use at the LATP site includes the consolidation and
short‐term storage of construction and deconstruction debris materials.
NO IMPACT
ENVIRONMENTAL CHECKLIST
GEOLOGY AND SOILS
CITY OF PALO ALTO P a g e | 3 3
d. Would the project have soils incapable of adequately supporting the use of septic tanks or
alternative wastewater disposal systems where sewers are not available for the disposal of
wastewater?
The proposed project would not require the use of septic tanks or alternative wastewater
disposal systems. No impact would occur.
NO IMPACT
e. Would the project directly or indirectly destroy a unique paleontological resource or unique
geologic feature?
The proposed Ordinance addresses materials separation for construction/deconstruction
debris. While there is a possibility that future construction/deconstruction activities could
be located on sites that contain unique paleontological or geologic features, such projects
would be subject to review and approval by City staff and would be subject to their own
environmental review. The proposed Ordinance does not directly or indirectly destroy a
unique paleontological resources or unique geologic feature, rather it addresses the
management and disposition of materials from construction/deconstruction activities.
The proposed LATP consolidation site is developed and paved. There would not be any
ground disturbing activities at the site. Consolidation and temporary storage facilities would
occur within paved areas and would not have the potential to directly or indirectly destroy
unique paleontological resources or unique geologic features. No impact would occur.
NO IMPACT
ENVIRONMENTAL CHECKLIST
GREENHOUSE GAS EMISSIONS
3 4 | P a g e Initial Study Negative Declaration
7 Greenhouse Gas Emissions
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project have any of the following impacts:
a. Generate greenhouse gas emissions, either
directly or indirectly, that may have a
significant impact on the environment? □ □ □ ■
b. Conflict with any applicable plan, policy,
or regulation adopted to reduce the
emissions of greenhouse gases? □ □ □ ■
Climate change is the observed increase in the average temperature of the Earth’s
atmosphere and oceans along with other substantial changes in climate (such as wind
patterns, precipitation, and storms) over an extended period of time. Climate change is the
result of numerous, cumulative sources of greenhouse gases (GHGs), gases that trap heat in
the atmosphere, analogous to the way in which a greenhouse retains heat. Common GHGs
include water vapor, carbon dioxide (CO2), methane (CH4), nitrous oxides (N2O), fluorinated
gases, and ozone. GHGs are emitted by both natural processes and human activities. Of
these gases, CO2 and CH4 are emitted in the greatest quantities from human activities.
Emissions of CO2 are largely by‐products of fossil fuel combustion, whereas CH4 results from
off‐gassing associated with agricultural practices and landfills. Man‐made GHGs, many of
which have greater heat‐absorption potential than CO2, include fluorinated gases, such as
hydrofluorocarbons (HFCs), perfluorocarbons (PFC), and sulfur hexafluoride (SF6) (Cal EPA
2015).
The accumulation of GHGs in the atmosphere regulates the earth’s temperature. Without
the natural heat trapping effect of GHGs, Earth’s surface would be about 34° C cooler (Cal
EPA 2015). However, it is believed that emissions from human activities, particularly the
consumption of fossil fuels for electricity production and transportation, have elevated the
concentration of these gases in the atmosphere beyond the level of naturally occurring
concentrations.
Pursuant to the requirements of SB 97, the Resources Agency adopted amendments to the
CEQA Guidelines for the feasible mitigation of GHG emissions and analysis of the effects of
GHG emissions. The adopted CEQA Guidelines provide regulatory guidance on the analysis
and mitigation of GHG emissions in CEQA documents, while giving lead agencies the
discretion to set quantitative or qualitative thresholds for the assessment and mitigation of
GHGs and climate change impacts.
The vast majority of individual projects do not generate sufficient GHG emissions to directly
influence climate change. However, physical changes caused by a project can contribute
ENVIRONMENTAL CHECKLIST
GREENHOUSE GAS EMISSIONS
CITY OF PALO ALTO P a g e | 3 5
incrementally to cumulative effects that are significant, even if individual changes resulting
from a project are limited. The issue of climate change typically involves an analysis of
whether a project’s contribution towards an impact would be cumulatively considerable.
“Cumulatively considerable” means that the incremental effects of an individual project are
significant when viewed in connection with the effects of past projects, other current
projects, and probable future projects (CEQA Guidelines, Section 15064[h][1]).
In late 2015, the California Supreme Court’s Newhall Ranch decision confirmed that there
are multiple potential pathways for evaluating GHG emissions consistent with CEQA,
depending on the circumstances of a given project (Center for Biological Diversity v.
Department of Fish and Wildlife (2015) 62 Cal. 4th 204). The decision also identified the
need to analyze both near term and post‐2020 emissions, as applicable, stating that an “EIR
taking a goal‐consistency approach to CEQA significance may in the near future need to
consider the project’s effects on meeting longer term emissions reduction targets.” While
not legally binding on local land use agencies, SB 32 extends the statewide AB 32 reduction
goal, requiring the State to further reduce GHGs to 40 percent below 1990 levels by 2030,
and Executive Order S‐03‐05 has set forth a long‐term reduction target to reduce GHG
emissions in California by 80 percent below 1990 levels by the year 2050.
While the State has adopted the AB 32 Scoping Plan and multiple regulations to achieve the
AB 32 year 2020 target, there is no currently adopted State plan to meet post‐2020 GHG
reduction goals. ARB is currently working to update the Scoping Plan to provide a
framework for achieving the 2030 target set forth by SB 32 (ARB 2015). As a result, State
reduction strategies cannot be applied to the project to achieve long‐term reductions.
Achieving these long‐term GHG reduction policies will require State and federal plans and
policies for achieving post‐2020 reduction goals. Placing the entire burden of meeting long‐
term reduction targets on local government or individual new development projects would
be disproportionate and likely ineffective.
Given the recent legislative attention and judicial action regarding post‐2020 goals and the
scientific evidence that additional GHG reductions are needed through the year 2050, the
Association of Environmental Professionals’ (AEP) Climate Change Committee published a
white paper in 2015 recommending that CEQA analyses for most land use development
projects may continue to rely on current adopted thresholds for the immediate future (AEP
2015). As such, for project GHG impacts, this analysis evaluates future conditions based on
consistency with the BAAQMD recommended threshold of 1,100 MT CO2e.
ZEROWASTE PLANNING
The proposed Ordinance is one of several initiatives that are included in the City’s Zero
Waste Plan update. In November 2016, the City Council approved the Sustainability and
Climate Action Plan Framework, Principles & Guidelines which identified a goal of 90
percent diversion of solid waste from landfills by 2021 and a 95 percent waste diversion
rate by 2030. Diversion includes all waste prevention, reuse, recycling and composting
activities that “divert” materials from landfills.
Based upon City calculations included in the Zero Waste Plan update, implementation of an
ordinance that emphasizes deconstruction instead of demolition and source separation of
ENVIRONMENTAL CHECKLIST
GREENHOUSE GAS EMISSIONS
3 6 | P a g e Initial Study Negative Declaration
construction (the proposed Ordinance), is expected to result in a GHG reduction of 8,580
MTCO2e per year.
CONSTRUCTION EMISSIONS
No construction emissions are anticipated for the project. Construction and deconstruction
materials, and their associated emissions would already be generated at project sites. The
proposed Ordinance addresses the source separation and management of the generated
debris. The proposed Ordinance would not result in any new construction or demolition
activities. No construction would be required to implement the Ordinance or the proposed
LATP consolidation site. Therefore, the GHG analysis focuses on operational emissions.
OPERATIONAL EMISSIONS
Operational emissions for the project would be associated with vehicle and truck trips. This
includes trips associated with materials salvage, delivery of bins to the generator sites, pick
up and transport of bins to the LATP site for consolidation, and then transport of
consolidated materials to the Zanker facility. In some instances, separated materials may go
directly from the generator sites to the Zanker facility. Trip generation and trip distance
assumptions are detailed in the Table 2 of the project description section of this document.
IMPACT ANALYSIS
a. Would the project generate GHG emissions, either directly or indirectly, that may have a
significant impact on the environment?
b. Would the project conflict with any applicable plan, policy, or regulation adopted for the
purpose of reducing the emissions of greenhouse gases?
GHG emissions associated with operational emissions from the proposed project were
estimated using CalEEMod. To be conservative, CalEEMod was modified to manually adjust
vehicular trip to 100 percent trucks. Modeling output is included as Attachment A of the air
quality memorandum prepared for the project (LDN 2019).
The expected emissions will be 67.3519 MTCO2e per year (LDN 2019). This is below the
1,100 MT MTCO2e per year threshold recommended by BAAQMD. Additionally, this
calculation does not consider the GHG emissions reductions that would be realized by
decreasing the amount of construction and deconstruction debris material going to the
landfill. As previous stated, implementation of the proposed Ordinance could reduce GHG
emissions up to 8,580 MTCO2e per year. Thus, the project would result in a net benefit with
regard to GHG emissions. The project would result in an overall reduction of GHG emissions
by achieving higher landfill diversion rates as contemplated in the City’s Sustainability and
Climate Action Plan Framework, Principles & Guidelines, which sets a goal of 90 percent
diversion of solid waste from the landfill by 2021 and 95 percent diversion rate by 2030. No
impact is identified for this issue area.
NO IMPACT
ENVIRONMENTAL CHECKLIST
HAZARDS AND HAZARDOUS MATERIALS
CITY OF PALO ALTO P a g e | 3 7
8 Hazards and Hazardous Materials
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project have any of the following impacts:
a. Create a significant hazard to the public or
the environment through the routine
transport, use, or disposal of hazardous
materials? □ □ ■ □
b. Create a significant hazard to the public or
the environment through reasonably
foreseeable upset and accident conditions
involving the release of hazardous
materials into the environment? □ □ ■ □
c. Emit hazardous emissions or handle
hazardous or acutely hazardous materials,
substances, or waste within 0.25 mile of an
existing or proposed school? □ □ ■ □
d. Be located on a site which is included on a
list of hazardous materials sites compiled
pursuant to Government Code Section
65962.5 and, as a result, would it create a
significant hazard to the public or the
environment? □ □ ■ □
e. For a project within and airport land use
plan or, where such a plan has not been
adopted, within two miles or a public
airport or public use airport, would the
project result in a safety hazard for people
residing or working the project area? □ □ □ ■
f. Impair implementation of or physically
interfere with an adopted emergency
response plan or emergency evacuation
plan? □ □ □ ■
ENVIRONMENTAL CHECKLIST
HAZARDS AND HAZARDOUS MATERIALS
3 8 | P a g e Initial Study Negative Declaration
a. Would the project create a significant hazard to the public or the environment through
the routine transport, use, or disposal of hazardous materials?
b. Would the project 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?
Proposed Ordinance
The project addresses the collection and handling of construction and deconstruction
project debris. These are inert, non‐hazardous materials. While some of the deconstruction
projects could generate hazardous materials (e.g., lead‐based paint, asbestos‐containing
materials), these materials would be handled in accordance with existing regulations and
would not be included in the materials sorted and collected under the proposed Ordinance.
GreenWaste, the firm that currently handles waste collection in the City, has procedures in
place regarding the collection of waste and materials and they would also be used for the
construction/deconstruction debris collection. This includes outreach, signage and driver
load checks.
Implementation of the proposed Ordinance would not create a significant hazard to the
public or environment through the routine transport, use or disposal of hazardous materials
or through reasonably foreseeable upset and accident conditions involving the release of
hazardous materials into the environment. Impacts would be less than significant.
LATP Consolidation Site
As noted above, the materials that would be collected from construction/deconstruction
sites would be non‐hazardous. In the event that hazardous materials inadvertently come to
the LATP site from the construction/deconstruction site, materials would be stored in a
secure location until they could be properly disposed using a hazardous waste disposal
contractor. There will not be any consolidation or temporary storage of hazardous materials
at the LATP consolidation site. Impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
c. Would the project emit hazardous emissions or handle hazardous or acutely hazardous
materials, substances, or waste within 0.25 mile of an existing or proposed school?
Proposed Ordinance
The project addresses the collection and handling of construction and deconstruction
project debris. These are inert, non‐hazardous materials. While some of the
construction/deconstruction projects could be located within 0.25 mile of an existing or
proposed school, the project does not result in any increased risk associated with hazardous
materials. Deconstruction projects would be required to adhere to existing regulations
regarding the handling of hazardous materials (e.g., lead‐based paint, asbestos‐containing
material) and impacts would be less than significant.
LATP Consolidation Site
ENVIRONMENTAL CHECKLIST
HAZARDS AND HAZARDOUS MATERIALS
CITY OF PALO ALTO P a g e | 3 9
The closest school to the proposed LATP consolidation site is Palo Verde Elementary school,
which is located approximately one mile to the west. As noted above, the materials that
would be collected from construction/deconstruction sites would be non‐hazardous. There
will not be any consolidation or temporary storage of hazardous materials at the LATP
consolidation site.
LESS THAN SIGNIFICANT IMPACT
d. Would the project create a significant hazard to the public or the environment from
existing hazardous materials contamination by exposing future occupants or users of the
site or from location on listed hazardous material sites compiled pursuant to
Government Code Section 65962.5?
The proposed consolidation site is a smaller portion of a larger site that was associated with
the former Los Altos Treatment Plant. A search on the Department of Toxic Substance
Control’s (DTSC) EnviroStor database identified the former Los Altos Treatment Plant as a
Clean Up Program site. Per DTSC’s information, a case was opened in 1990 and site
assessments were conducted in 2008 and 2013. The site investigation history from the
EnviroStor site is as follows:
“Several investigations have taken place, most recently in 2007. Soluble lead (17
mg/l), reactive sulfide (1200 mg/kg), chromium (540 mg/kg), cobalt (220 mg/kg),
copper (610 mg/kg), nickel (500 mg/kg), zinc (860 mg/kg) and arsenic (6.4 mg/kg)
have been detected above PRGs/CHHSLs. Reactive sulfide is currently "trapped" in
the sludge below the water in the former wastewater treatment ponds. When
disturbed, this sludge releases hydrogen sulfide gas that has been detected at levels
immediately dangerous to life and health (IDLH). Water in Pond 5 has been found to
contain values of arsenic, cobalt, copper, nickel selenium, vanadium and zinc above
Estuary Habitat environmental screening level (ESL) concentration limits. No
exceedances were found in groundwater sampled at the Site.”
Proposed consolidation and storage activities would occur on paved surfaces that are
already used for storage (see Figure 1). This area is located in the southwest corner of the
larger LATP site. There would not be any disturbance to the areas of concern noted in the
DTSC database description. Impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
e. For a project within and airport land use plan or, where such a plan has not been
adopted, within two miles or a public airport or public use airport, would the project
result in a safety hazard for people residing or working the project area?
The Palo Alto Airport of Santa Clara County (PAO) is located approximately two miles north
of the proposed LATP consolidation site. The proposed consolidation site is located just
outside of the airport influence area (SCALUC 2016). The use of the site to consolidate and
store construction and deconstruction debris would not result in any increase in safety
hazards for people working on the site.
NO IMPACT
ENVIRONMENTAL CHECKLIST
HAZARDS AND HAZARDOUS MATERIALS
4 0 | P a g e Initial Study Negative Declaration
f. Would the project impair implementation of or physically interfere with an adopted
emergency response plan or emergency evacuation plan?
The proposed Ordinance addresses the handling of construction and deconstruction debris.
It would not result in any condition that would impair implementation of or physically
interfere with an adopted emergency response plan or emergency evacuation plan.
Similarly, the consolidation and temporary storage of construction and deconstruction
debris at the LATP site would not result in an impact to emergency response or evacuation
plans. No impact is identified for this issue area.
NO IMPACT
ENVIRONMENTAL CHECKLIST
HYDROLOGY AND WATER QUALITY
CITY OF PALO ALTO P a g e | 4 1
9 Hydrology and Water Quality
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project have any of the following impacts:
a. Substantially decrease groundwater supplies
or interfere substantially with groundwater
recharge such that the project may impede
sustainable groundwater management of
the basin? □ □ □ ■
b. Violate any water quality standards or
waste discharge requirements or otherwise
substantially degrade surface or
groundwater quality? □ □ ■ □
c. Substantially alter the existing drainage
pattern of the site or area, including through
the alteration of the course of a stream or
river, or through the addition of impervious
surfaces, in a manner which would result in
substantial erosion or siltation on‐ or off‐
site? □ □ ■ □
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 through the addition of impervious
surfaces, in a manner which would
substantially increase the rate of surface
runoff in a manner which would result in
flooding on‐ or offsite? □ □ ■ □
e. Substantially alter the existing drainage
pattern of the site or area, including through
the alteration of the course of a stream or
river, or through the addition of impervious
surfaces, in a manner which would 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? □ □ ■ □
ENVIRONMENTAL CHECKLIST
HYDROLOGY AND WATER QUALITY
4 2 | P a g e Initial Study Negative Declaration
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
f. Substantially alter the existing drainage
pattern of the site or area, including through
the alteration of the course of a stream or
river, or through the addition of impervious
surfaces, in a manner which would impede
or redirect flood flows? □ □ ■ □
g. In flood hazard, tsunami, or seiche zones,
risk release or pollutants due to project
inundation? □ □ □ ■
h. Conflict with or obstruct implementation of
a water quality control plan or sustainable
groundwater management plan? □ □ □ ■
a. Would the project substantially deplete groundwater supplies or interfere substantially
with groundwater recharge such that the project may impede sustainable groundwater
management of the basin?
The proposed project would not introduce any uses which would result in an increase in
demand of groundwater supplies or interfere with groundwater recharge. The project is the
implementation of an ordinance addressing construction/deconstruction debris
management and the consolidation and storing of the materials at the LATP site prior to
transport to the Zanker facility. No impact is identified for this issue area.
NO IMPACT
b. Would the project violate any water quality standards or waste discharge requirements?
c. Would the project substantially alter the existing drainage pattern of the site or area,
including through the alteration of the course of a stream or river, or through the
addition of impervious surfaces, in a manner which would result in substantial erosion or
siltation on‐ or off‐site?
d. Would the project substantially alter the existing drainage pattern of the site or area,
including through the alteration of the course of a stream or river, or through the
addition of impervious surfaces, in a manner which would substantially increase the rate
of surface runoff in a manner which would result in flooding on‐ or off‐site?
e. Would the project substantially alter the existing drainage pattern of the site or area,
including through the alteration of the course of a stream or river, or through the
addition of impervious surfaces, in a manner which would create or contribute runoff
ENVIRONMENTAL CHECKLIST
HYDROLOGY AND WATER QUALITY
CITY OF PALO ALTO P a g e | 4 3
water which would exceed the capacity of existing or planned stormwater drainage
systems or provide substantial additional sources of polluted runoff?
f. Would the project substantially alter the existing drainage pattern of the site or area,
including through the alteration of the course of a stream or river, or through the
addition of impervious surfaces, in a manner which would impede or redirect flood
flows?
The proposed project does not introduce any activities or uses that would result in an
increased water quality or hydrology impact. Proposed storage and consolidation activities
at the LATP site would be on an existing paved area. Storage bins and boxes that contain
materials waiting to be transferred to the Zanker facility would be covered when there is
rain so that there is not a potential for runoff from the stored materials.
The proposed Ordinance does not result in any new paving or placement of impervious
surfaces, nor would there be any alteration of drainage patterns. Impacts would be less
than significant.
LESS THAN SIGNIFICANT IMPACT
g. In flood hazards, tsunami, or seiche zones, would the project release of pollutants due to
project inundation?
Proposed Ordinance
The proposed Ordinance applies to the entire City and within the City there are areas within
regulated floodways or areas that could be subject to flood hazards, including inundation
areas. The proposed Ordinance addresses materials separation for construction/
deconstruction projects. This would not result in any increase in the potential for release of
pollutants due to inundation. Construction and deconstruction debris would already be
generated at sites, the Ordinance addresses how those materials are sorted and stored.
LATP Consolidation Site
According to Map S‐5 (100 Year Flood Zones) of the Comprehensive Plan, the proposed
LATP consolidation site is identified as being subject to a 100‐year flood. Temporary storage
of construction/deconstruction materials would be in metal bins and boxes. In the event of
significant rain events where there is a potential for flooding, the materials would be
transferred to the Zanker facility in advance of any flooding. The project does not result in
any increase in potential for release of pollutants due to site inundation.
NO IMPACT
h. Would the project conflict with or obstruct implementation of a water quality control
plan or sustainable groundwater management plan?
The project does not propose any uses or activities that would result in the potential for
conflict with or obstruction of implementation of a water quality control plan or sustainable
groundwater management plan. There would not be any use of groundwater for the
project. No impact is identified for this issue area.
NO IMPACT
ENVIRONMENTAL CHECKLIST
LAND USE AND PLANNING
4 4 | P a g e Initial Study Negative Declaration
10 Land Use and Planning
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project have any of the following impacts:
a. Physically divide an established
community? □ □ □ ■
b. Cause a significant environmental impact
due to a conflict with any applicable land
use plan, policy, or regulation adopted for
the purpose of avoiding or mitigating an
environmental effect? □ □ □ ■
a. Would the project physically divide an established community?
Proposed Ordinance
The proposed Ordinance would address the handling of construction/deconstruction debris;
it would not result in any development or activities which could divide an established
community. No impact is identified for this issue area.
LATP Consolidation Site
The proposed LATP consolidation site would occur on City‐owned property that is already
used for storage. The LATP site is located in a developed portion of the City in the vicinity of
light industrial/office uses. Activities at the consolidation site, which consist of
construction/deconstruction materials consolidation and temporary storage, would not
physically divide an established community. No impact is identified for this issue area.
NO IMPACT
b. Would the project conflict with any applicable land use plan, policy, or regulation of an
agency with jurisdiction over the project (including but not limited to the general plan,
specific plan, local coastal program, or zoning ordinance) adopted for the purpose of
avoiding or mitigating an environmental effect?
Proposed Ordinance
The proposed Ordinance would introduce new requirements for some construction or
deconstruction projects. No conflicts with existing land use plans, policies or regulations
adopted for the purpose of avoiding or mitigating environmental effects would occur.
Implementation of the Ordinance helps the City get closer to achieving their landfill
diversion rates and also reducing GHG emissions, as contemplated in the City’s
Sustainability and Climate Action Plan Framework, Principles & Guidelines.
ENVIRONMENTAL CHECKLIST
LAND USE AND PLANNING
CITY OF PALO ALTO P a g e | 4 5
LATP Consolidation Site
The proposed LATP consolidation site has a land use designation of Major
Institution/Special Facility according to the City’s Comprehensive Plan. As described in the
Comprehensive Plan, the Major Institution/Special Facility describes areas that are for
institutional, academic, governmental and community service uses and lands that are either
publicly owned or operated as non‐profit organizations. The City owns the site and it is
currently used for storage of equipment and supplies for contractors working on City
projects. The proposed use would be similar to what is already occurring on the site and is
an allowable use under the Comprehensive Plan designation.
The proposed LATP consolidation site has a zoning designation of PF(D), Public Facilities
District. This designation is designed to accommodate governmental, public utility,
educational, community service or recreational facilities. As mentioned above, the City
owns the site and it is currently used for storage of equipment and supplies for contractors
working on City projects. The proposed use would be similar to what is already occurring on
the site and is an allowable use under the current zoning designation.
The project would not conflict with any applicable land use plan, policy, or regulation of an
agency with jurisdiction over the project (including but not limited to the general plan,
specific plan, local coastal program, or zoning ordinance) adopted for the purpose of
avoiding or mitigating an environmental effect.
NO IMPACT
c. Would the project conflict with an applicable habitat conservation plan or natural
community conservation plan?
The proposed project would not occur within an approved Habitat Conservation Plan,
Natural Community Conservation Plan, or other approved local, regional, or state habitat
conservation plan (CDFW 2017). No impact would occur.
NO IMPACT
ENVIRONMENTAL CHECKLIST
MINERAL RESOURCES
4 6 | P a g e Initial Study Negative Declaration
11 Mineral Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project have any of the following impacts:
a. Result in the loss of availability of a known
mineral resource that would be of value to
the region and the residents of the state? □ □ □ ■
b. Result in the loss of availability of a locally
important mineral resource recovery site
delineated on a local general plan, specific
plan, or other land use plan? □ □ □ ■
a. Would the project result in the loss of availability of a known mineral resource that
would be of value to the region and the residents of the state?
b. Would the project result in the loss of availability of a locally important mineral resource
recovery site delineated on a local general plan, specific plan, or other land use plan?
LATP Consolidation Site
The proposed LATP consolidation site and surrounding properties are part of an urbanized
area with no current oil or gas extraction. According to the Natural Environment Element of
the City’s Comprehensive Plan, there are no policies relating to mineral resources because
Palo Alto does not contain any mineral deposits of regional significance (City of Palo Alto
Comprehensive Plan, 2007). No mineral resource activities would be altered or displaced by
the proposed project. No impact would occur.
NO IMPACT
ENVIRONMENTAL CHECKLIST
NOISE
CITY OF PALO ALTO P a g e | 4 7
12 Noise
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project result in any of the following impacts:
a. Generate a substantial temporary or
permanent increase in ambient noise
levels in the vicinity of the project in
excess of standards established by the
local general plan or noise ordinance,
or applicable standards of other
agencies? □ □ ■ □
b. Generate excessive groundborne
vibration or groundborne noise levels? □ □ ■ □
c. For a project located within the vicinity
of a private airstrip or an airport land
use plan or, where such a plan has not
been adopted, within two miles of a
public airport or public use airport,
would the project expose people
residing or working in the project area
to excessive noise levels? □ □ □ ■
Noise is unwanted sound that disturbs human activity. Environmental noise levels typically
fluctuate over time, and different types of noise descriptors are used to account for this
variability. Noise level measurements include intensity, frequency, and duration, as well as
time of occurrence. Noise level (or volume) is generally measured in decibels (dB) using the
A‐weighted sound pressure level (dBA). The A‐weighting scale is an adjustment to the actual
sound power levels to be consistent with that of human hearing response, which is most
sensitive to frequencies around 4,000 Hertz (about the highest note on a piano) and less
sensitive to low frequencies (below 100 Hertz).
Because of the logarithmic scale of the decibel unit, sound levels cannot be added or
subtracted arithmetically. If the physical intensity of a sound is doubled, the sound level
increases by 3 dBA, regardless of the initial sound level. For example, 60 dBA plus 60 dBA
equals 63 dBA. Where ambient noise levels are high in comparison to a new noise source,
the change in noise level would be less than 3 dBA. For example, when 70 dBA ambient
noise levels are combined with a 60 dBA noise source the resulting noise level equals 70.4
dBA.
ENVIRONMENTAL CHECKLIST
NOISE
4 8 | P a g e Initial Study Negative Declaration
Noise that is experienced at any receptor can be attenuated by distance or the presence of
noise barriers or intervening terrain. Sound from a single source (i.e., a point source)
radiates uniformly outward as it travels away from the source in a spherical pattern. The
sound level attenuates (or drops off) at a rate of 6 dBA for each doubling of distance. For
acoustically absorptive, or soft, sites (i.e., sites with an absorptive ground surface, such as
soft dirt, grass, or scattered bushes and trees), ground attenuation of about 1.5 dBA per
doubling of distance normally occurs. A large object or barrier in the path between a noise
source and a receiver can substantially attenuate noise levels at the receiver. The amount of
attenuation provided by this shielding depends on the size of the object, proximity to the
noise source and receiver, surface weight, solidity, and the frequency content of the noise
source. Natural terrain features (such as hills and dense woods) and human‐made features
(such as buildings and walls) can substantially reduce noise levels. Walls are often
constructed between a source and a receiver specifically to reduce noise. A barrier that
breaks the line of sight between a source and a receiver will typically result in at least 5 dBA
of noise reduction.
Vibration is a unique form of noise because its energy is carried through buildings,
structures, and the ground, whereas noise is simply carried through the air. Thus, vibration
is generally felt rather than heard. Some vibration effects can be caused by noise; e.g., the
rattling of windows from passing trucks. This phenomenon is caused by the coupling of the
acoustic energy at frequencies that are close to the resonant frequency of the material
being vibrated. Typically, groundborne vibration generated by manmade activities
attenuates rapidly as distance from the source of the vibration increases. The ground
motion caused by vibration is measured as particle velocity in inches per second and is
referenced as vibration decibels (VdB) in the U.S.
The vibration velocity level threshold of perception for humans is approximately 65 VdB. A
vibration velocity of 75 VdB is the approximate dividing line between barely perceptible and
distinctly perceptible levels for many people. Most perceptible indoor vibration is caused by
sources within buildings such as operation of mechanical equipment, movement of people,
or the slamming of doors. Typical outdoor sources of perceptible groundborne vibration are
construction equipment, steel wheeled trains, and traffic on rough roads.
REGULATORY SETTING
The City’s Comprehensive Plan Natural Environment Element includes goals and policies
related to noise. This element establishes land use compatibility categories for community
noise exposure (see Table ). For schools, noise levels up to 60 dBA Ldn are identified as
normally acceptable and noise levels between 60 and 75 dBA Ldn are identified as
conditionally acceptable.
ENVIRONMENTAL CHECKLIST
NOISE
CITY OF PALO ALTO P a g e | 4 9
Table 6 Palo Alto Land Use Compatibility for Community Noise Environments
Exterior Noise Exposure Ldn or CNEL or dB
Land Use Category Normally Acceptable Conditionally Acceptable Unacceptable
Residential, Hotel and
Motels 50‐60 60‐75 75+
Outdoor Sports and
Recreation,
Neighborhood Parks and
Playgrounds 50‐65 65‐80 80+
Schools, Libraries,
Museums, Hospitals,
Personal Care, Meeting
Halls, Churches 50‐60 60‐75 75+
Office Buildings, Business
Commercial, and
Professional 50‐70 70‐80 80+
Auditoriums, Concert
Halls, and Amphitheaters N/A 50‐75 75+
Industrial, Manufacturing,
Utilities, and Agriculture 50‐70 75+ N/A
Source: City of Palo Alto Comprehensive Plan Update Noise Draft Existing Conditions Report, August 29, 2014
The PAMC regulates noise primarily through the Noise Ordinance, which comprises Chapter
9.10 of the Code, under Title 9, Public Peace, Morals and Safety. The Municipal Code
contains additional specific and general provisions relating to noise. Per PAMC Section
9.10.030 noise can be generated by any land use that is more than 6 dBA above the local
ambient noise level at a residential property.
The Municipal Code also addresses construction‐related noise in Section 9.10.060(b) for
non‐residential property and 9.10.060(c) for residential property. Construction, alteration
and repair activities are allowed Monday through Friday from 8 AM to 6 PM and on
Saturday from 9 AM to 6 PM. No construction activities are permitted on Sundays and
holidays.
IMPACT ANALYSIS
a. Would the project generate a substantial temporary or permanent increase in ambient
noise levels in the vicinity of the project in excess of standards established by the local
general plan or noise ordinance, or applicable standards of other agencies?
Proposed Ordinance
The proposed Ordinance addresses construction/deconstruction materials management
and would apply to projects throughout the City that meet a certain project value threshold
($25,000). With implementation of the Ordinance, construction and deconstruction debris
sorting would be required at more sites throughout the City. The site type and the
ENVIRONMENTAL CHECKLIST
NOISE
5 0 | P a g e Initial Study Negative Declaration
neighboring property type would vary from construction project to construction project, as
would the existing ambient noise condition at each site.
Debris handling would be a part of any construction/deconstruction project, but under the
Ordinance, debris would need to be systematically sorted into specific bins on site to better
facilitate recycling and landfill diversion. The increased sorting requirements are not
expected to result in any significant noise increase at the project site. This is because debris
handling activities would already be occurring at construction/deconstruction sites, the only
difference is how the debris materials are sorted and stored.
Since these activities would be construction‐related, they would be required to comply with
the City’s Municipal Code, Section 9.10.060, as it relates to construction noise. Construction,
alteration and repair activities are allowed Monday through Friday from 8 AM to 6 PM and
on Saturday from 9 AM to 6 PM. No construction activities are permitted on Sundays and
holidays. Compliance with the Municipal Code would reduce potential conflicts between
construction/deconstruction activities and adjacent properties. Bin delivery and pick up
would occur on an as‐needed basis and would be during typical business hours, Monday
through Saturday.
The current handling of construction‐generated waste results in approximately 12 trips/day
for GreenWaste. Implementation of the Ordinance is expected to generate 35 trips/day, for
a net increase of 23 trips/day. These trips would be to and from the LATP consolidation site
and would be dispersed throughout the City, depending on the location of the construction
site. This small number of trips would not be enough to represent a doubling of traffic on
any roadways in the City and would not result in a significant vehicle/truck‐related noise
impact. Impacts would be less than significant.
LATP Consolidation Site
Bins and boxes would be stored at the LATP consolidation site. This includes empty bins and
boxes waiting to be delivered to construction/deconstruction sites and also filled bins and
boxes that are being consolidated before being taken to the Zanker facility in San Jose.
The LATP site is located in an urbanized portion of the City adjacent to lands zoned as light
industrial. For these areas, 50 to 70 dB Ldn is normally acceptable, up to 85 dB Ldn is
conditionally acceptable. The LATP site is also influenced from noise from US Highway 101
(Bayshore Freeway), which is located approximately 0.2 miles away.
Consolidation activities would be intermittent and are not expected to result in sounds
levels that would not exceed the threshold for acceptable noise levels on and off the project
site. Impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
b. Would the project generate excessive groundborne vibration or groundborne noise
levels?
ENVIRONMENTAL CHECKLIST
NOISE
CITY OF PALO ALTO P a g e | 5 1
Proposed Ordinance
The proposed Ordinance addresses construction/deconstruction materials management
and would apply to projects throughout the City that meet a certain project value threshold
($25,000). With implementation of the Ordinance, construction and demolition debris
sorting would be required at more sites throughout the City. The site type and the
neighboring property type would vary from construction project to construction project.
Construction and deconstruction activities have the potential to generate groundborne
vibration and groundborne noise. Debris handling would be a part of any
construction/deconstruction project, but under the Ordinance, debris would need to be
systematically sorted into specific bins on site to better facilitate salvage, recycling and
landfill diversion. The increase in debris sorting requirements is not expected to result in
any significant increase related to groundborne vibration and groundborne noise. This is
because debris handling activities would already be occurring at construction/
deconstruction sites, the only difference is how the debris materials are sorted and stored.
LATP Consolidation Site
There are already existing storage and construction staging activities occurring on the LATP
site by contractors and City staff that are working on City projects. Activities proposed at
the LATP consolidation site would consist of bin and box storage, preparing bins and boxes
for delivery to construction/deconstruction sites, and consolidating materials in the bins
and boxes once they are returned to the LATP site. There will also be temporary storage of
consolidated materials for up to 30 days before materials are transferred to the Zanker
facility in San Jose. None of these activities would be of a type that would generate
excessive groundborne vibration or groundborne noise levels. Impacts would be less than
significant.
LESS THAN SIGNIFICANT IMPACT
c. For a project located within the vicinity of a private airstrip or an airport land use plan
or, where such a plan has not been adopted, within two miles of a public airport or
public use airport, would the project expose people residing or working in the project
area to excessive noise levels?
The Palo Alto Airport of Santa Clara County (PAO) is located approximately two miles north
of the proposed LATP consolidation site. The proposed consolidation site is located just
outside of the airport influence area (SCALUC 2016). Additionally, as shown on Map N‐5
(Existing Noise Contours), the proposed LATP consolidation site is more influenced by noise
from Highway 101 (Bayshore Freeway) than from the airport. The airport’s noise contours
do not extend to the proposed consolidation site. Employees at the consolidation site would
not be exposed to excessive noise levels and no impact is identified for this issue area.
NO IMPACT
ENVIRONMENTAL CHECKLIST
POPULATION AND HOUSING
5 2 | P a g e Initial Study Negative Declaration
13 Population and Housing
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project result in any of the following impacts:
a. Induce substantial unplanned population
growth in an area, either directly (e.g., by
proposing new homes and businesses) or
indirectly (e.g., through extension of roads
or other infrastructure)? □ □ □ ■
b. Displace substantial amounts of existing
people or housing, necessitating the
construction of replacement housing
elsewhere? □ □ □ ■
c. Create a substantial imbalance between
employed residents and jobs? □ □ □ ■
a. Would the project induce substantial unplanned population growth in an area, either
directly (for example, by proposing new homes and businesses) or indirectly (for
example, through extension of roads or other infrastructure)?
The proposed project would not induce substantial unplanned growth either directly or
indirectly. The proposed Ordinance addresses construction/deconstruction debris material
management in the City. The proposed LATP consolidation site would be located within an
existing City‐owned area that is adequately serviced by infrastructure. No new homes or
businesses would be constructed due to the project. No impact is identified for this issue
area.
NO IMPACT
b. Would the project displace substantial numbers of existing people or housing,
necessitating the construction of replacement housing elsewhere?
The proposed project would not displace any people or housing. The proposed Ordinance
addresses construction/deconstruction materials management in the City. The proposed
LATP consolidation site would be located within an existing City‐owned area and would not
result in any displacement of people or housing. No impact is identified for this issue area.
NO IMPACT
c. Would the project create a substantial imbalance between employed residents and jobs?
The proposed project would not result in a substantial imbalance between employed
residents and jobs. The proposed Ordinance addresses construction/deconstruction
ENVIRONMENTAL CHECKLIST
POPULATION AND HOUSING
CITY OF PALO ALTO P a g e | 5 3
material management in the City. The proposed LATP consolidation site activities would
consolidate materials and temporarily store them before transport to the Zanker facility.
The project could generate up to two jobs, however this would not be an amount that
would result in a substantial imbalance. No impact is identified for this issue area.
NO IMPACT
ENVIRONMENTAL CHECKLIST
PUBLIC SERVICES
5 4 | P a g e Initial Study Negative Declaration
14 Public Services
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project result in any of the following impacts:
a. Result in an adverse physical impact from
the construction of additional school
facilities in order to maintain acceptable
performance standards? □ □ □ ■
b. Result in an adverse physical impact from
the construction of additional fire
protection facilities in order to maintain
acceptable performance standards? □ □ □ ■
c. Result in an adverse physical impact from
the construction of additional police
protection facilities in order to maintain
acceptable performance standards? □ □ □ ■
d. Result in an adverse physical impact from
the construction of additional parks and
recreation facilities in order to maintain
acceptable performance standards? □ □ □ ■
e. Result in an adverse physical impact from
the construction of additional library
facilities in order to maintain acceptable
performance standards? □ □ □ ■
a. Would the project result in an adverse physical impact from the construction of
additional school facilities in order to maintain acceptable performance standards?
The proposed Ordinance and LATP consolidation site are not activities which would result in
the generation of student. The project would not require the construction of schools and
would not result in any adverse physical impact from the construction of additional school
facilities. No impact is identified for this issue area.
NO IMPACT
ENVIRONMENTAL CHECKLIST
PUBLIC SERVICES
CITY OF PALO ALTO P a g e | 5 5
b. Would the project result in an adverse physical impact from the construction of
additional fire protection facilities in order to maintain acceptable performance
standards?
The City of Palo Alto Fire Department (PAFD) provides fire protection, fire suppression,
paramedic ambulance service, search and rescue, fire prevention inspections/permits,
public fire education programs, emergency preparedness planning, and other services
based on community needs. The closest fire station to the proposed LATP consolidation site
is Fire Station 4 (Mitchell Park) at 3600 Middlefield Road. The proposed Ordinance and
proposed LATP consolidation site are not activities which would result in an increase in
demand for fire protection services. The project would not result in any adverse physical
impact due to the construction of fire protection facilities. No impact is identified for this
issue area.
NO IMPACT
d. Would the project result in an adverse physical impact from the construction of additional police
protection facilities in order to maintain acceptable performance standards?
The Palo Alto Police Department (PAPD) provides police protection. The closest police
station to the proposed LATP consolidation site is located at 275 Forest Avenue. The
proposed Ordinance and proposed LATP consolidation site are not activities which would
result in an increase in demand for police services. The LATP site is secured behind a fence
and gate. The project would not result in any adverse physical impact due to the
construction of police protection facilities. No impact is identified for this issue area.
NO IMPACT
e. Would the project result in an adverse physical impact from the construction of additional parks
and recreation facilities in order to maintain acceptable performance standards?
Refer to Section 14, Recreation.
NO IMPACT
f. Would the project result in an adverse physical impact from the construction of additional library
facilities in order to maintain acceptable performance standards?
The Palo Alto City Library (PACL) provides library services. The closest library branch to the
proposed LATP consolidation site is Mitchell Park Library located at 3700 Middlefield Road.
The proposed Ordinance and proposed LATP consolidation site are not activities which
would result in an increase in library service, nor would they result in any adverse physical
impact due to the construction of additional library facilities. No impact is identified for this
issue area.
NO IMPACT
ENVIRONMENTAL CHECKLIST
RECREATION
5 6 | P a g e Initial Study Negative Declaration
15 Recreation
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project result in any of the following impacts:
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? □ □ □ ■
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?
The City of Palo Alto owns and operates approximately 36 parks and preserves, comprising
about 162 acres of urban parks and 4,000 acres of open space (City of Palo Alto, 2015). The
recreation area closest to the proposed LATP consolidation site is the Baylands Nature
Preserve. This is a 1,940‐acre area of undisturbed marshland with 15 miles of multi‐use
trails. One of the trail access points is at the end of terminus of San Antonio Road.
The proposed Ordinance and the proposed LATP consolidation site activities would not
result in the increase in use of existing neighborhood, regional parks or other facilities as it
does not increase demand for these facilities. The project would not require the
construction or expanding recreational facilities which could have an adverse physical effect
on the environment. No impact is identified for this issue area.
NO IMPACT
ENVIRONMENTAL CHECKLIST
TRANSPORTATION
CITY OF PALO ALTO P a g e | 5 7
16 Transportation
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project result in any of the following impacts:
a. Conflict with a program plan, ordinance or
policy addressing the circulation system,
including transit, roadway, bicycle and
pedestrian facilities? □ □ □ ■
b. Conflict or be inconsistent with CEQA
Guidelines section 15064.3, subdivision (b)? □ □ ■ □
c. Cause an intersection to drop below its
level of service standard, or if it is already
substandard level of service, deteriorate by
more than a specified amount? □ □ ■ □
d. Substantially increase hazards due to a
geometric design feature (e.g. sharp curves
or dangerous intersections) or incompatible
uses (e.g., farm equipment)? □ □ □ ■
e. Result in inadequate emergency access? □ □ □ ■
Neither a traffic impact assessment nor a focused traffic analysis was prepared for the
project since the project will generate led than 50net new weekday (AM or PM Peak hour)
or weekend peak hour trips. The Santa Clara Valley Transit Authority’s Transportation
Impact Guidelines require an analysis if a project is anticipated to generate 100 or more net
new weekday (AM or PM Peak hour trips). To be conservative, the City of Palo Alto requires
a focused traffic analysis that quantifies potential project impacts for projects generating
more than 50 trips per peak hour.
ROADWAY NETWORK
The proposed Ordinance would apply citywide; therefore, truck traffic associated with
debris bin or box delivery to construction/deconstruction sites, and trips associated with
salvage assessments and salvage materials collection, could be on any street in the City.
Trucks delivering bins would originate from the LATP consolidation site located at 1237 San
Antonio Road. The trucks with smaller debris bins would return to the LATP consolidation
site. The trucks with larger boxes would proceed directly to the Zanker facility in San Jose.
ENVIRONMENTAL CHECKLIST
TRANSPORTATION
5 8 | P a g e Initial Study Negative Declaration
The following provides a description of the circulation network in the vicinity of the LATP
consolidation site.
San Antonio Road ‐ Within the City, San Antonio Road runs between Alma Road/Central
Expressway in the south and terminates at the Baylands Nature Preserve trailhead
parking area in the north. San Antonio Road also provides access to northbound US
Route 101 (Bayshore Freeway) via ramps.
East Bayshore Road ‐ Within the City, East Bayshore Road runs between San Antonio
Road in the south and the point at which it crosses San Francisquito Creek in the north.
East Bayshore Road continues into the City of East Palo Alto.
Bayshore Parkway – Bayshore Parkway runs from the City boundary at San Antonio
Road in the north to Rengstorff Avenue in the City of Mountain View south.
STUDY METHODOLOGY AND THRESHOLDS
LEVEL‐OF‐SERVICE METHODOLOGY
Level of service (LOS) is a qualitative index of the performance of an element of the
transportation system. LOS is a rating scale running from A to F, with LOS A indicating no
congestion, and LOS F indicating unacceptable congestion and delay. For this study, LOS
describes the operating conditions for signalized and unsignalized intersections.
The Highway Capacity Manual (HCM) is a standard reference published by the
Transportation Research Board (TRB) and contains specific criteria and methods for
assessing LOS.
SIGNALIZED INTERSECTIONS
Per City of Palo Alto standards, a project generating increased motor vehicle traffic is
considered to have a significant impact:
If intersection operations degrade from an acceptable level (LOS D or better) to an
unacceptable level (LOS E or F); or
If the critical delay increases by more than four seconds and the volume‐to‐capacity
(V/C) ratio increases by 0.01 or more at intersections with unacceptable operations (LOS
E or F).
UNSIGNALIZED INTERSECTIONS
LOS D is used as the minimum acceptable operation level at unsignalized intersections.
Project‐generated increases in traffic are considered to have a significant impact if
intersection operations degrade to LOS E or F from acceptable operations and the
intersection satisfies a peak hour signal warrant from the California Manual on Uniform
Traffic Control Devices.
The City of Palo Alto considers a significant impact to be satisfactorily mitigated when an
implemented measure would restore LOS to baseline conditions or better.
ENVIRONMENTAL CHECKLIST
TRANSPORTATION
CITY OF PALO ALTO P a g e | 5 9
CMP INTERSECTIONS
A project‐generated increase in traffic is considered to have a significant impact on
Congestion Management Plan (CMP) intersections:
If intersection operations degrade from an acceptable level (LOS E or better) to an
unacceptable level (LOS F)
If the critical delay increases by more than four seconds and the V/C ratio increases by
0.01 or more at intersection with unacceptable operations (LOS F)
PEDESTRIAN AND BICYCLE IMPACT CRITERIA
The City of Palo Alto Comprehensive Plan describes related policies necessary to ensure that
pedestrian and bicycle facilities are safe and effective for City residents. Based on the
Comprehensive Plan, significant impacts to these facilities would occur when a project or an
element of a project:
Creates a hazardous condition that currently does not exist for pedestrians and
bicyclists, or otherwise interferes with pedestrian or bicycle accessibility to the site and
adjoining areas
Conflicts with an existing or planned pedestrian or bicycle facility
Conflicts with policies related to bicycle and pedestrian activity adopted by the City of
Palo Alto, Santa Clara County, Valley Transportation Authority (VTA), or California
Department of Transportation (Caltrans) for their respective facilities in the study area
TRANSIT IMPACT CRITERIA
Significant impacts to transit service would occur if the project or any part of the project:
Creates demand for public transit services above the capacity which is provided or
planned
Disrupts existing transit services or facilities including disruptions caused by proposed
project driveways on transit streets, impacts to transits stops/shelters, and impacts to
transit operations from traffic improvements proposed or resulting from a project
Conflicts with an existing or planned transit facility
Conflicts with transit policies adopted by the City of Palo Alto, Santa Clara County, VTA,
or Caltrans for their respective facilities in the study area
EXISTING INTERSECTION CONDITIONS
The closest intersection to the LATP consolidation is the signalized intersection at San Antonio
Road/Bayshore Parkway – East Bayshore Road, located approximately 400 feet south of the site
entrance. Recent observations of the intersection during peak periods show that the intersection
generally operates at acceptable conditions (LOS D or better).
TRIP GENERATION
Construction/Deconstruction Material Hauling ‐ Table 2 in the project description
presented the existing and proposed trips as it relates to the hauling of
ENVIRONMENTAL CHECKLIST
TRANSPORTATION
6 0 | P a g e Initial Study Negative Declaration
construction/deconstruction materials. Under the proposed Ordinance, it is expected that
there would be 23 new truck trips/day to bring construction and deconstruction waste to
the LATP site for consolidation. Assuming an 8‐hour workday, this represents approximately
three additional trips per hour.
Salvage Activities ‐ Implementation of the Ordinance will also generate an additional six
trips per day associated with salvage inspection and salvage materials transport (three trips
for the salvage inspector and three trips for the salvage material haul trucks). The three
salvage inspector trips would be dispersed throughout the City, depending on the location
of the specific construction/deconstruction project. Salvaged materials suitable for reuse
would be transported to Reuse People in Oakland. In total this represents less than one
additional trip per hour.
IMPACT ANALYSIS
a. Would the project conflict with an applicable plan, ordinance or policy addressing the
circulation system including transit, roadway, bicycle and pedestrian facilities?
Pedestrian and Bicycle Facilities ‐ The project does not create any hazardous condition that
currently does not exist for pedestrians and bicyclists, or otherwise interfere with
pedestrian or bicycle accessibility to the site and adjoining areas. The project does not
conflict with an existing or planned pedestrian or bicycle facility, nor does it conflict with
policies related to bicycle and pedestrian activity adopted by the City of Palo Alto, Santa
Clara County, Valley Transportation Authority (VTA), or California Department of
Transportation (Caltrans) for their respective facilities in the study area.
Transit Facilities ‐ The project would not create a demand for public transit services above
the capacity which is provided or planned, would not disrupt existing transit services or
facilities including disruptions caused by proposed project driveways on transit streets,
impacts to transits stops/shelters, would not conflict with an existing or planned transit
facility, nor would it conflict with transit policies adopted by the City of Palo Alto, Santa
Clara County, VTA, or Caltrans for their respective facilities in the study area
Roadway Facilities ‐ For roadway and intersections, analysis is provided in transportation
threshold “c”, below. The analysis concluded that the project would not result in a
significant increase in delay at the studied intersection. Impacts would be less than
significant.
LESS THAN SIGNIFICANT IMPACT
b. Would the project conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision
(b)?
Section 15064.3(b) of the CEQA Guidelines provide criteria for analyzing transportation
impacts for land use projects and transportation projects. The proposed Ordinance does not
fit specifically within either of these categories. The proposed siting of a debris transfer
facility (the LATP consolidation site) could be considered a land use project, though it is not
resulting in any physical development.
ENVIRONMENTAL CHECKLIST
TRANSPORTATION
CITY OF PALO ALTO P a g e | 6 1
The Governor’s Office of Planning and Research released a Technical Advisory on Evaluating
Transportation Impact in CEQA in December 2018 to provide recommendations regarding
assessment of vehicle miles traveled (VMT), threshold of significance, and mitigation
measures.
Page 12 of the Technical Advisory (OPR 2018) provides screening thresholds for small
projects and states that “… projects that generate or attract fewer than 110 trips per day
generally may be assumed to cause a less‐than‐significant transportation impact.”
The project is anticipated to generate 29 new trips per day. This is due to an increase of 23
trips per day associated with hauling of sorted construction/deconstruction debris materials
and the addition of six trips per day associated with salvage inspection and transport (three
trips for inspection, three trips for transport). The total addition of 29 trips per day is well
below the 110 trip per day screening threshold identified in OPR’s technical advisory.
Impacts would be less than significant.
With regard to VMT increase, the addition of interim trips to consolidate materials at the
LATP site is anticipated to result in a 57‐mile (one‐way)/ 114‐mile (round trip) increase per
day (Table 2). Salvage inspector trips and salvage material haul trucks are expected to be 28
miles (one‐way, Palo Alto to Oakland)/ 56 miles (round trip). Assuming three inspector trips
and three haul truck trips per day, this represents 336 additional miles per day. When
combined with the trips to consolidate materials at the LATP, the project would result in a
total VMT increase of 450 miles per day.
LESS THAN SIGNIFICANT IMPACT
c. Would the project cause an intersection to drop below its level of service standard, or if it
is already substandard level of service, deteriorate by more than a specified amount?
The proposed project is anticipated to generate approximately three peak hour trips, or less
than one additional one trip every 20 minutes at the San Antonio Road/Bayshore Parkway‐
East Bayshore Road intersection. This is less than the threshold to warrant a formal analysis
(10 trips per lane per hour), and is not anticipated to trigger a potentially significant
operational impact. Recent observations of the intersection during peak periods show that
the intersection generally operates at acceptable conditions (LOS D or better), and would
not degrade to LOS E or F with the proposed project. Impacts would be less than significant.
Other trips associated with implementation of the Ordinance would be scattered
throughout the City and would not bring a consistent number of trips to a specific location
on a regular basis, such as those that will be coming to and leaving the LATP consolidation
site. Therefore, no additional analysis of other intersections in the City was conducted.
LESS THAN SIGNIFICANT IMPACT
d. Would the project substantially increase hazards due to a geometric design feature (e.g. sharp
curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
The project does not propose any changes to the geometric design of roadways and
intersection, nor does it propose uses that would be incompatible. No impact is identified
for this issue area.
NO IMPACT
ENVIRONMENTAL CHECKLIST
TRANSPORTATION
6 2 | P a g e Initial Study Negative Declaration
e. Would the project result in inadequate emergency access?
The proposed project would not result in inadequate emergency access. There would not be
any changes to the existing access at the proposed LATP consolidation site. Bin and boxes
for consolidation materials, both at the individual construction sites and at the LATP site,
would be in located a manner so as to still allow adequate movement for emergency
vehicles. No impact is identified for this issue area.
NO IMPACT
ENVIRONMENTAL CHECKLIST
UTILITIES AND SERVICE SYSTEMS
CITY OF PALO ALTO P a g e | 6 3
17 Utilities and Service Systems
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project result in any of the following impacts:
a. Require or result in the relocation or
construction of new or expanded water,
wastewater treatment or stormwater
drainage, electric power, natural gas, or
telecommunications facilities, the
construction or relocation of which could
cause significant environmental effects? □ □ □ ■
b. Have sufficient water supplies available to
serve the project and reasonably foreseeable
future development during normal, dry and
multiple dry years? □ □ □ ■
c. Result in a determination by the wastewater
treatment provider that it has inadequate
capacity to serve the project’s projected
demand in addition to the provider’s existing
commitments? □ □ □ ■
d. Generate solid waste in excess of State or
local standards, or in excess of the capacity
of local infrastructure, other otherwise
impair the attainment of solid waste
reduction goals? □ □ □ ■
a. Require or result in the relocation or construction of new or expanded water, wastewater
treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities,
the construction or relocation of which could cause significant environmental effects?
The proposed project would not introduce any uses which would result in the relocation or
construction of new or expanded water, wastewater treatment or stormwater drainage,
electric power, natural gas, or telecommunications facilities. The project is the
implementation of an Ordinance addressing construction/deconstruction debris
management and the consolidation and storing of the materials at the LATP site prior to
transport to the Zanker facility. No impact is identified for this issue area.
NO IMPACT
ENVIRONMENTAL CHECKLIST
UTILITIES AND SERVICE SYSTEMS
6 4 | P a g e Initial Study Negative Declaration
b. Have sufficient water supplies available to serve the project and reasonably foreseeable
future development during normal, dry and multiple dry years?
The proposed project would not introduce any uses which would result in an increase in
demand on water supplies or water service. The project is the implementation of an
Ordinance addressing construction/deconstruction debris management and the
consolidation and storing of the materials at the LATP site prior to transport to the Zanker
facility. No impact is identified for this issue area.
NO IMPACT
c. Result in a determination by the wastewater treatment provider that it has inadequate
capacity to serve the project’s projected demand in addition to the provider’s existing
commitments?
The proposed project would not introduce any uses which would result in an increase in
demand on wastewater treatment services. The project is the implementation of an
Ordinance addressing construction/deconstruction debris management and the
consolidation and storing of the materials at the LATP site prior to transport to the Zanker
facility. No impact is identified for this issue area.
NO IMPACT
d. Generate solid waste in excess of State or local standards, or in excess of the capacity of
local infrastructure, other otherwise impair the attainment of solid waste reduction
goals?
Currently, the City contracts with GreenWaste of Palo Alto for collection of garbage,
recycling, and composting services in the City and with Waste Management Inc. to use the
Kirby Canyon Landfill for waste disposal. As of July 31, 2015, the Kirby Canyon Landfill has a
remaining capacity of roughly 36,400,000 cubic yards. The daily permitted capacity of Kirby
Canyon Landfill is up to 2,600 tons per day (CalRecycle, 2015).
Through implementation of the proposed Ordinance, a greater amount of construction and
deconstruction materials would be diverted from the landfill. There would also be a greater
emphasis on salvaging materials for reuse. It is expected that up to 7,500 tons of material
could be diverted from the landfill each year through implementation of the Ordinance. This
has the benefit of decreasing the overall amount of material going to the Kirby Canyon
Landfill and also assists the City in achieving higher diversion rates as contemplated in the
City’s Sustainability and Climate Action Plan Framework, Principles & Guidelines, which sets
a goal of 90 percent diversion of solid waste from the landfill by 2021 and 95 percent
diversion by 2030.
NO IMPACT
ENVIRONMENTAL CHECKLIST
ENERGY CONSERVATION
CITY OF PALO ALTO P a g e | 6 5
18 Energy Conservation
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project result in any of the following impacts?
a. Result in potentially significant
environmental impacts due to wasteful,
inefficient, or unnecessary consumption
or energy resources, during project
construction or operation? □ □ ■ □
b. Conflict with or obstruct a state or local
plan for renewable energy or energy
efficiency? □ □ □ ■
a. Result in potentially significant environmental impacts due to wasteful, inefficient, or
unnecessary consumption of energy resources, during project construction or operation?
The project does not propose any uses of activities that would result in environmental
impacts due to wasteful, inefficient, or unnecessary consumption of energy resources.
Implementation of the proposed Ordinance would capture more items for salvage/reuse
and for recycling. Increase the amount of materials for salvage has the potential to reduce
energy consumption since there may be a reduction in the amount of new materials that
are proposed.
LESS THAN SIGNIFICANT IMPACT
b. Would the project conflict with or obstruct a state or local plan for renewable energy or
energy efficiency?
The project does not propose any uses or activities that would conflict with or obstruct with
state or local plans for renewable energy or energy efficiency.
NO IMPACT
ENVIRONMENTAL CHECKLIST
WILDFIRE
6 6 | P a g e Initial Study Negative Declaration
19 Wildfire
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
If located in or near state responsibility areas or lands classified as very high fire hazard severity
zone, would the project:
a. Substantially impair an adopted
emergency response plan or emergency
evacuation plan? □ □ □ ■
b. Due to slope, prevailing winds, or other
factors, exacerbate wildfire risks, and
thereby expose project occupants to,
pollutant concentrations from a wildfire or
uncontrolled spread of wildfire? □ □ □ ■
c. Require the installation or maintenance of
associated infrastructure (such as roads,
fuel breaks, emergency water sources,
power lines or other utilities) that may
exacerbate fire risk or that may result in
temporary or ongoing impacts to the
environment? □ □ □ ■
d. Expose people or structure to significant
risks, including downslope or downstream
flooding or landslides, as a result of runoff,
post‐fire slope instability, or drainage
changes? □ □ □ ■
a. Substantially impair an adopted emergency response plan or evacuation plan?
The proposed project does not result in any use or activity which would substantially impair
an adopted emergency response plan or evacuation plan. Bins and boxes at the
construction/deconstruction site would be located in a way so as to not block any traffic or
impede access for emergency responds vehicles. No impact is identified for this issue area.
NO IMPACT
b. Due to slope, prevailing winds, or other factors, exacerbate wildfire risks, and thereby
expose project occupants to, pollutant concentrations from a wildfire or uncontrolled
spread of wildfire?
ENVIRONMENTAL CHECKLIST
WILDFIRE
CITY OF PALO ALTO P a g e | 6 7
Proposed Ordinance
According to Map S‐8 (Wildfire Hazard Zones) of the Comprehensive Plan, wildfire risk in the
City ranges from low to extreme, depending on the level of development and the level of
vegetation cover. The proposed Ordinance would apply to the entire City. However, the
Ordinance, which addresses the management of construction and deconstruction debris
would not result in any increase in risk related to wildfire.
LATP Consolidation Site
According to Map S‐8 (Wildfire Hazard Zones) of the Comprehensive Plan, the LATP
consolidation site has a low risk for wildlfire. The consolidation and temporary storage of
construction and deconstruction debris is not expected to significantly increase risks related
to wildfire, as the site is located in a developed area and materials would be stored in non‐
combustible bins on paved areas.
NO IMPACT
c. Require the installation or maintenance of associated infrastructure (such as roads, fuel
breaks, emergency water sources, power lines or other utilities) that may exacerbate fire
risk or that may result in temporary or ongoing impacts to the environment?
Implementation of the project will not require the installation or maintenance of any
infrastructure that may exacerbate fire risk or result in temporary or ongoing impacts to the
environment. The only equipment to be installed will be a portable scale at the proposed
LATP consolidation site. There would not be any increase in fire risk associated with the
installation and operation of the scale. No impact is identified for this issue area.
NO IMPACT
d. Expose people or structures to significant risks, including downslope or downstream
flooding or landslides, as a result of runoff, post‐fire slope instability or drainage
changes?
The proposed Ordinance addresses the management of construction and deconstruction
debris. Proposed activities at the LATP consolidation site include construction and
deconstruction debris materials consolidation and temporary storage. These would not be
characterized as activities which would result in an increase for exposure of people or
structure to significant risk as a result of runoff, post‐fire slope instability or drainage
changes.
NO IMPACT
ENVIRONMENTAL CHECKLIST
MANDATORY FINDINGS OF SIGNIFICANCE
6 8 | P a g e Initial Study Negative Declaration
20 Mandatory Findings of Significance
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Have the potential to substantially reduce
the habitat of a fish or wildlife species,
cause a fish or wildlife population to drop
below self‐ sustaining levels, eliminate a
plant or animal community, reduce the
number or restrict the range of a rare or
endangered plant or animal or eliminate
important examples of the major periods
of California history or prehistory? □ □ ■ □
b. Does the project have impacts that are
individually limited, but cumulatively
considerable? (“Cumulatively considerable”
means that the incremental effects of a
project are considerable when viewed in
connection with the effects of past
projects, the effects of other current
projects, and the effects of probable future
projects)? □ □ ■ □
c. Does the project have environmental
effects which will cause substantial
adverse effects on human beings, either
directly or indirectly? □ □ ■ □
a. Does the project have the potential to substantially reduce the habitat of a fish or
wildlife species, cause a fish or wildlife population to drop below self‐ sustaining levels,
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?
The project’s potential to impact biological, cultural and historical resources was analyzed in
this document. The analysis concluded that there would either be no impact or that impacts
would be less than significant. The project does not result in any vegetation or habitat
removal, nor does it require any ground disturbing activities. Impact would be less than
significant.
LESS THAN SIGNIFICANT IMPACT
CITY OF PALO ALTO P a g e | 6 9
b. Does the project have impacts that are individually limited, but cumulatively considerable?
(“Cumulatively considerable” means that the incremental effects of a project are considerable
when viewed in connection with the effects of past projects, the effects of other current
projects, and the effects of probable future projects)?
Based upon the analysis presented in Sections 1 through 18 of this document,
implementation of the proposed Ordinance would not result in any significant impacts and
no mitigation would be required. Given the dispersed nature of the future construction and
deconstruction sites and the temporary nature of the consolidation activities at a given site,
it is unlikely that the project would contribute to a significant cumulative impact.
LESS THAN SIGNIFICANT IMPACT
c. Does the project have environmental effects which will cause substantial adverse effects on
human beings, either directly or indirectly?
The project’s potential to impact human beings was analyzed within several of the
environmental topics, including air quality, greenhouse gas, hazards/hazardous materials,
noise, and public/services and utilities. The analysis concluded that there would either be
no impact or that impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
7 0 | P a g e Initial Study Negative Declaration
REFERENCES
BIBLIOGRAPHY
Bay Area Air Quality Management District (BAAQMD), 2017. California Environmental
Quality Act ‐ Air Quality Guidelines. May.
California Department of Conservation (DOC). 2016. California Important Farmland Finder
https://maps.conservation.ca.gov/DLRP/CIFF/
Viewed February 5, 2019.
California Department of Fish and Wildlife (CDFW). 2017.
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=68626&inline
Viewed February 5, 2019
Caltrans. 2019. California Scenic Highway Mapping System – Santa Clara County.
http://www.dot.ca.gov/hq/LandArch/16_livability/scenic_highways/
Viewed February 5, 2019
City of Palo Alto. 2017. Comprehensive Plan 2030.
https://www.cityofpaloalto.org/civicax/filebank/documents/62915
Governor’s Office of Planning and Research (OPR). 2018. Technical Advisory on Evaluating
Transportation impact in CEQA. December.
http://opr.ca.gov/docs/20190122‐743_Technical_Advisory.pdf
Ldn Consulting, Inc (LDN). 2019. Palo Alto Zero Waste Deconstruction/Construction
Materials Management Ordinance and Inert Debris Transfer Facility Air Quality Screening
Letter. February 28.
Santa Clara County Airport Land Use Commission (SCALUC). 2016. Comprehensive Land Use
Plan Santa Clara County ‐ Palo Alto Airport. November 19.
https://www.sccgov.org/sites/dpd/DocsForms/Documents/ALUC_PAO_CLUP.pdf
Santa Clara County. Alquist Priolo Earthquake Fault Zone Map via the Open Data Portal.
https://data.sccgov.org/Environment/AlquistPrioloEarthquakeFaultZone/jg2y‐nftn
Santa Clara Valley Transportation Authority (SCVTA). 2014. Congestion Management
Program Transportation Impact Analysis Guidelines. October.
CITY OF PALO ALTO P a g e | 7 1
APPENDIX A
Air Quality Memorandum
7 2 | P a g e Initial Study Negative Declaration
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42428 Chisolm Trail, Murrieta CA 92562 phone 760-473-1253
www.ldnconsulting.net fax 760-689-4943
2/28/19 19-14 Palo Alto Zero Waste AQ 1
February 28, 2019
Sophia Habl Mitchell
Sophia Mitchell & Associates
PO BOX 1700
Gualala, CA 95445
RE: Palo Alto Zero Waste Deconstruction/Construction Materials Management
Ordinance and Inert Debris Transfer Facility Air Quality Screening Letter
The purpose of this air quality screening letter is to identify potential impacts, if any, from the
adoption of a new Deconstruction/Construction Materials Management Ordinance (Ordinance)
and the approval of an inert debris transfer facility to process construction and demolition (C&D)
materials at the former Los Altos Treatment Plant (LATP) in the City of Palo Alto (City). The
proposed project is located in The Bay Area Air Quality Management District (BAAQMD)
regulates air quality emissions within the City of Palo Alto.
Deconstruction/Construction Materials Management Ordinance
The proposed ordinance addresses construction materials management, with the primary goals
of increasing: 1) salvage of materials for reuse; 2) recovery of more materials (higher diversion
from landfill disposal); and 3) increasing the quality of recyclable materials for all construction
related projects. The Ordinance would require construction projects to use deconstruction
methods of structure removal (instead of demolition) and the construction-related waste would
be required to be source separated into categories in separate bins, boxes or truck trailers.
Existing C&D Materials Management
Over the last several years, construction related waste constituted approximately 40 percent of
all of the waste that was disposed in landfills by all entities from the City. The City has approved
waste diversion goals of 90 percent diversion of solid waste from the landfill by 2021 and 95
percent diversion by 2030.
Currently, C&D projects are required to meet the City’s Green Building requirements to achieve
an 80 percent diversion rate with material currently taken to local C&D recycling facilities,
including the Zanker Materials Processing Facility located in San Jose. All single-family residential
projects obtaining a whole house demolition permit are required to complete a
deconstruction/salvage survey provided by a third-party entity approved by the Chief Building
Sophia Habl Mitchell
Sophia Mitchell & Associates
PO BOX 1700
Gualala, CA 95445
42428 Chisolm Trail
Murrieta CA 92562
phone 760-473-1253
2/28/19 19-14 Palo Alto Zero Waste AQ 2
Official. Additionally, the City requires that all permittees with projects valued over $25,000 are
required to track the weights of materials removed from project sites in Green Halo.1
Proposed Construction-Related Material Management
Under the proposed Ordinance, the following initial conceptual changes and/or expansion
related to construction materials management would occur within a phased implementation
plan:
• Contractors shall obtain salvage surveys on all construction projects valued at $50,000 or
more (both residential and commercial).
• Contractors shall ensure that all items indicated on the salvage survey are properly salvaged
and certified by City-approved salvage facilities.
• All projects where structures are being partially or fully removed and where materials are
generated shall be deconstructed (not demolished, except for concrete and pavement).
• Materials generated during deconstruction activities shall be source separated by contractors
(as approved by City), and delivered to City-approved materials recovery facilities.
• During construction, contractors shall sort and separate all materials in accordance with the
City’s Zero Waste program requirements and sort materials in appropriate containers.
• Contractor shall utilize the City’s contractor, GreenWaste of Palo Alto (GreenWaste), to haul
all materials if using containers/debris boxes. Contractors can continue to self-haul material
by using trucks, but must still source separate materials in accordance with City’s new
requirements (above) and deliver materials to City-approved materials recovery facilities.
• Contractors for all projects over $25,000 shall ensure that the following data is inputted in
Green Halo: 1) the salvaged and reused inventory and their ultimate disposition and 2) the
weights and types of all source separated materials generated at their site and where these
materials were delivered.
The source separated construction related material would be collected by GreenWaste of Palo
Alto (GreenWaste) from the generation site in large debris boxes (7, 15, 20, 30 and 40 cubic
yards) as is the current practice, or in smaller bins (2, 3 or 4 cubic yards) on an on-call basis.
The recycle, compost, and landfill drop boxes/bins would be differentiated from each other with
unique, color-coded signage identifying the material type they are meant to contain. Up to seven
different material type categories could be utilized to separate the following: concrete, wood
waste, sheetrock, asphalt shingles, carpet, ceiling tiles, and other demolition materials. It is
expected that up to 7,500 tons of material could be diverted from the landfill each year through
implementation of the Ordinance.
1 Green Halo is a web-based service for waste diversion and recycling tracking.
Sophia Habl Mitchell
Sophia Mitchell & Associates
PO BOX 1700
Gualala, CA 95445
42428 Chisolm Trail
Murrieta CA 92562
phone 760-473-1253
2/28/19 19-14 Palo Alto Zero Waste AQ 3
Transfer Operation and LATP Transfer Location Description
GreenWaste would deliver the smaller bins of source separated material from the generation
site directly to the LATP transfer location at 1237 San Antonio Road which is shown in the project
vicinity map in Figure 1. Currently materials from the generation sites go directly to the Zanker
facility. The project adds an interim consolidation point at the LATP prior to transfer to the
Zanker facility for the material from generators that cannot accommodate the larger debris
boxes. Generators that utilize the larger debris boxes will continue to have their material taken
directly to the Zanker facility.
The smaller bins would be weighed on a portable scale and emptied into typically 40 cubic yard
sized boxes staged at the LATP site. Once the debris boxes are full, they would be hauled to
the Zanker or related facility. The LATP consolidation site would not receive putrescible (likely
to decay), hazardous, or liquid wastes.
No chipping, grinding or other processing would be completed at the LATP. The maximum
timeframe the inert materials would be stored would be a maximum of 30 days. Public access
to the LATP site will not be allowed. The site is the GreenWaste storage yard and is completely
secured by fencing and locked gates.
GreenWaste would operate the LATP transfer site. As stated above, debris boxes will be staged
at the site to consolidate the materials and GreenWaste will collect the smaller sized bins full of
material from construction sites, bring them to the LATP consolidation site, weigh the material
and transfer the material in them into the debris boxes. The LATP consolidation site would
operate Monday through Friday, 6 AM to 3 PM. An aerial site showing the source separation
location is shown in Figure 2.
Trip Generation Assumptions – Materials Salvage
Trip generation from materials salvage for each individual deconstruction project is expected to
generate 926 vehicle trips per year (3.56 trips per day) associated with the salvage inspector
and 926 truck trips per year (3.56 trips per day) associated with the hauling of the salvage
materials to a reuse center. Vehicle miles traveled associated with the salvage activities are
assumed 28 miles one-way (Palo Alto to Oakland) for both the salvage inspector and the salvage
material haul truck.
Trip Generation Assumptions – Materials Consolidation
Trips generated by implementation of the Deconstruction/ Construction Materials Management
Ordinance relates to the transport of bins from the generation sites to the LATP consolidation
site and then to the Zanker facility. It is estimated that half of the material generated will be in
Sophia Habl Mitchell
Sophia Mitchell & Associates
PO BOX 1700
Gualala, CA 95445
42428 Chisolm Trail
Murrieta CA 92562
phone 760-473-1253
2/28/19 19-14 Palo Alto Zero Waste AQ 4
large debris boxes not requiring consolidation and therefore will go directly to an approved
processing facility.
Implementation of the Ordinance would 1) result in additional trips from the delivery and
collection of more bins for source separation to and from the generation sites, and 2) result in
the interim rerouting of some of the collected C&D material to the LATP for consolidation before
being taken to the Zanker facility.
The current handling of construction generated waste results in approximately 12 trips/day for
a total of 168 miles. Implementation of the Ordinance is expected to generate 35 trips/day for
a total of 225 miles.
Therefore, the net increase between current and proposed operations would be 23 trips/day
and approximately 57 additional miles of truck travel per day. Based on discussions with the
project applicant operations would be expected 260 days per year. Given this, the project action
would generate 14,820 additional truck miles traveled per year.
Air quality impacts related to daily operations were calculated using the latest CalEEMod
2016.3.2 air quality and GHG model, which was developed by BREEZE Software in collaboration
with South Coast Air Quality Management District (SCAQMD) in 2018. The City of Palo Alto
recognizes the CalEEMod Version 2016.3.2 as an acceptable model for projects of this nature.
Sophia Habl Mitchell
Sophia Mitchell & Associates
PO BOX 1700
Gualala, CA 95445
42428 Chisolm Trail
Murrieta CA 92562
phone 760-473-1253
2/28/19 19-14 Palo Alto Zero Waste AQ 5
Figure 1: Project Vicinity Map
LATP Site
Source: (Google, 2018)
Sophia Habl Mitchell
Sophia Mitchell & Associates
PO BOX 1700
Gualala, CA 95445
42428 Chisolm Trail
Murrieta CA 92562
phone 760-473-1253
2/28/19 19-14 Palo Alto Zero Waste AQ 6
Figure 2: Source Separation Location – LATP site
Source: (Google Earth, 2019)
Sophia Habl Mitchell
Sophia Mitchell & Associates
PO BOX 1700
Gualala, CA 95445
42428 Chisolm Trail
Murrieta CA 92562
phone 760-473-1253
2/28/19 19-14 Palo Alto Zero Waste AQ 7
Air quality screening criteria for the City of Palo Alto utilize BAAQMD Air Quality Thresholds
(BAAQMD, 2017). The screening thresholds for construction and daily operations are shown in
Table 1.
Table 1: Operational Screening Thresholds for Criteria Pollutants BAAQMD
Pollutant Total Emissions
(Pounds per Day) Tons/Year
Respirable Particulate Matter (PM 10) 82 15
Respirable Particulate Matter (PM 2.5) 54 10
Nitrogen Oxide (NOx) 54 10
Reactive Organic Gases (ROG) 54 10
Project Related Operational Emissions
As previously discussed, operational emissions are primarily from vehicular emissions. Additional
emissions may be generated in the form of particulate matter dust as materials are consolidated
from the smaller bins to the larger boxes. These emissions would be minimal since the City will
utilize best available dust control measures such as wetting the materials or minimizing work
whenever wind speeds exceed 15 mile per hour. CalEEMod was modified manually adjusting
vehicular trips to 100 percent trucks using a 2020 operational year. The calculated operational
daily emissions are identified in Table 2 and yearly emissions are shown in Table 3 and shown
in Attachment A to this report.
Table 2: Expected Daily Operational Air Quality Emissions
ROG NOx PM2.5 PM10
Summer Scenario
Operational Emission Estimates (Lb/Day) 0.081 1.815 0.023 0.062
BAAQMD Thresholds 54 54 54 82
Significant? No No No No
Winter Scenario
Operational Estimates (Lb/Day) 0.088 1.840 0.023 0.062
Significant? No No No No
Daily pollutant generation calculated within CalEEMod 2016.3.2
Sophia Habl Mitchell
Sophia Mitchell & Associates
PO BOX 1700
Gualala, CA 95445
42428 Chisolm Trail
Murrieta CA 92562
phone 760-473-1253
2/28/19 19-14 Palo Alto Zero Waste AQ 8
Table 3: Expected Yearly Operational Air Quality Emissions
ROG NOx PM2.5 PM10
Annual Scenario
Operational Emission Estimates (Ton/Year) 0.011 0.238 0.003 0.008
BAAQMD Thresholds (Ton/Year) 10 10 10 15
Significant? No No No No
Winter Scenario
Daily pollutant generation calculated within CalEEMod 2016.3.2
Based upon the findings for the proposed Project, the daily and annual operations of the
deconstruction/construction materials management ordinance and inert debris transfer facility
activities are anticipated to produce air quality emissions well below BAAQMD thresholds.
Therefore, less than significant impacts are expected and no further analysis is required. If you
have any questions, please do not hesitate to contact me directly at (760) 473-1253.
Sincerely,
Ldn Consulting, Inc.
Jeremy Louden
Attachments: Attachment A: CalEEMod Output
Sources:
BAAQMD. (2017). Bay Area Air Quality Management Distrcit California Environmental Quality
Act - Air Qulatiy Guidelines. Retrieved from
http://www.baaqmd.gov/~/media/files/planning-and-
research/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en
Google. (2018). Retrieved from www.maps.google.com
Google Earth. (2019).
Project Characteristics -
Land Use - Project Site Acreage 13.26 acres
Construction Phase - Truck trips only no construction
Off-road Equipment - zero'd out so that construction emissions are zero
Trips and VMT - zero'd out... no construction emissons
Vehicle Trips - 100 percent trucks assumed
Construction Off-road Equipment Mitigation -
Fleet Mix - 100 percent trucks
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population
User Defined Industrial 1.00 User Defined Unit 13.26 0.00 0
1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
5
Wind Speed (m/s)Precipitation Freq (Days)2.2 64
1.3 User Entered Comments & Non-Default Data
1.0 Project Characteristics
Utility Company City of Palo Alto Public Utilities
2020Operational Year
CO2 Intensity
(lb/MWhr)
354.26 0.029CH4 Intensity
(lb/MWhr)
0.006N2O Intensity
(lb/MWhr)
Palo Alto - Deconstruction/Construction Materials Management Ordinance and Inert Debris Transfer Fac
Bay Area AQMD Air District, Summer
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Table Name Column Name Default Value New Value
tblAreaCoating Area_EF_Parking 150 0
tblConstructionPhase NumDays 20.00 1.00
tblFleetMix HHD 0.02 0.00
tblFleetMix LDA 0.57 0.00
tblFleetMix LDT1 0.04 0.00
tblFleetMix LDT2 0.19 0.00
tblFleetMix LHD1 0.02 0.00
tblFleetMix LHD2 5.3710e-003 0.00
tblFleetMix MCY 5.9420e-003 0.00
tblFleetMix MDV 0.11 0.00
tblFleetMix MH 8.1200e-004 0.00
tblFleetMix MHD 0.02 1.00
tblFleetMix OBUS 2.5450e-003 0.00
tblFleetMix SBUS 8.7700e-004 0.00
tblFleetMix UBUS 2.4420e-003 0.00
tblLandUse LotAcreage 0.00 13.26
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 1.00
tblOffRoadEquipment UsageHours 8.00 0.00
tblTripsAndVMT WorkerTripNumber 3.00 0.00
tblVehicleTrips CC_TL 7.30 1.00
tblVehicleTrips CC_TTP 0.00 100.00
tblVehicleTrips CNW_TL 7.30 0.00
tblVehicleTrips CW_TL 9.50 0.00
tblVehicleTrips PR_TP 0.00 100.00
tblVehicleTrips WD_TR 0.00 57.00
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2.0 Emissions Summary
2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2020 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2020 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
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2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 1.0000e-
005
0.0000 1.0000e-
004
0.0000 0.0000 0.0000 0.0000 0.0000 2.2000e-
004
2.2000e-
004
0.0000 2.3000e-
004
Energy 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mobile 0.0813 1.8152 0.9732 1.7400e-
003
0.0556 6.1300e-
003
0.0617 0.0167 5.8600e-
003
0.0225 179.1024 179.1024 0.0109 179.3753
Total 0.0813 1.8152 0.9733 1.7400e-
003
0.0556 6.1300e-
003
0.0617 0.0167 5.8600e-
003
0.0225 179.1026 179.1026 0.0109 0.0000 179.3756
Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 1.0000e-
005
0.0000 1.0000e-
004
0.0000 0.0000 0.0000 0.0000 0.0000 2.2000e-
004
2.2000e-
004
0.0000 2.3000e-
004
Energy 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mobile 0.0813 1.8152 0.9732 1.7400e-
003
0.0556 6.1300e-
003
0.0617 0.0167 5.8600e-
003
0.0225 179.1024 179.1024 0.0109 179.3753
Total 0.0813 1.8152 0.9733 1.7400e-
003
0.0556 6.1300e-
003
0.0617 0.0167 5.8600e-
003
0.0225 179.1026 179.1026 0.0109 0.0000 179.3756
Mitigated Operational
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3.0 Construction Detail
3.1 Mitigation Measures Construction
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Paving Paving 1/1/2020 1/1/2020 5 1
OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor
Paving Rollers 1 0.00 80 0.38
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Paving 1 0.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural
Coating – sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 0
Acres of Paving: 0
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3.2 Paving - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction Off-Site
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4.0 Operational Detail - Mobile
3.2 Paving - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction Off-Site
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 0.0813 1.8152 0.9732 1.7400e-
003
0.0556 6.1300e-
003
0.0617 0.0167 5.8600e-
003
0.0225 179.1024 179.1024 0.0109 179.3753
Unmitigated 0.0813 1.8152 0.9732 1.7400e-
003
0.0556 6.1300e-
003
0.0617 0.0167 5.8600e-
003
0.0225 179.1024 179.1024 0.0109 179.3753
4.1 Mitigation Measures Mobile
4.2 Trip Summary Information
4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
User Defined Industrial 57.00 0.00 0.00 14,820 14,820
Total 57.00 0.00 0.00 14,820 14,820
Miles Trip %Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by
User Defined Industrial 0.00 1.00 0.00 0.00 100.00 0.00 100 0 0
4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH
User Defined Industrial 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 1.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000
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5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
NaturalGas
Unmitigated
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
5.1 Mitigation Measures Energy
Historical Energy Use: N
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6.1 Mitigation Measures Area
6.0 Area Detail
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
User Defined
Industrial
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
User Defined
Industrial
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 1.0000e-
005
0.0000 1.0000e-
004
0.0000 0.0000 0.0000 0.0000 0.0000 2.2000e-
004
2.2000e-
004
0.0000 2.3000e-
004
Unmitigated 1.0000e-
005
0.0000 1.0000e-
004
0.0000 0.0000 0.0000 0.0000 0.0000 2.2000e-
004
2.2000e-
004
0.0000 2.3000e-
004
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 1.0000e-
005
0.0000 1.0000e-
004
0.0000 0.0000 0.0000 0.0000 0.0000 2.2000e-
004
2.2000e-
004
0.0000 2.3000e-
004
Total 1.0000e-
005
0.0000 1.0000e-
004
0.0000 0.0000 0.0000 0.0000 0.0000 2.2000e-
004
2.2000e-
004
0.0000 2.3000e-
004
Unmitigated
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8.1 Mitigation Measures Waste
7.1 Mitigation Measures Water
7.0 Water Detail
8.0 Waste Detail
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 1.0000e-
005
0.0000 1.0000e-
004
0.0000 0.0000 0.0000 0.0000 0.0000 2.2000e-
004
2.2000e-
004
0.0000 2.3000e-
004
Total 1.0000e-
005
0.0000 1.0000e-
004
0.0000 0.0000 0.0000 0.0000 0.0000 2.2000e-
004
2.2000e-
004
0.0000 2.3000e-
004
Mitigated
9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type
10.0 Stationary Equipment
Fire Pumps and Emergency Generators
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11.0 Vegetation
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type
User Defined Equipment
Equipment Type Number
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Project Characteristics -
Land Use - Project Site Acreage 13.26 acres
Construction Phase - Truck trips only no construction
Off-road Equipment - zero'd out so that construction emissions are zero
Trips and VMT - zero'd out... no construction emissons
Vehicle Trips - 100 percent trucks assumed
Construction Off-road Equipment Mitigation -
Fleet Mix - 100 percent trucks
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population
User Defined Industrial 1.00 User Defined Unit 13.26 0.00 0
1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
5
Wind Speed (m/s)Precipitation Freq (Days)2.2 64
1.3 User Entered Comments & Non-Default Data
1.0 Project Characteristics
Utility Company City of Palo Alto Public Utilities
2020Operational Year
CO2 Intensity
(lb/MWhr)
354.26 0.029CH4 Intensity
(lb/MWhr)
0.006N2O Intensity
(lb/MWhr)
Palo Alto - Deconstruction/Construction Materials Management Ordinance and Inert Debris Transfer Fac
Bay Area AQMD Air District, Winter
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Table Name Column Name Default Value New Value
tblAreaCoating Area_EF_Parking 150 0
tblConstructionPhase NumDays 20.00 1.00
tblFleetMix HHD 0.02 0.00
tblFleetMix LDA 0.57 0.00
tblFleetMix LDT1 0.04 0.00
tblFleetMix LDT2 0.19 0.00
tblFleetMix LHD1 0.02 0.00
tblFleetMix LHD2 5.3710e-003 0.00
tblFleetMix MCY 5.9420e-003 0.00
tblFleetMix MDV 0.11 0.00
tblFleetMix MH 8.1200e-004 0.00
tblFleetMix MHD 0.02 1.00
tblFleetMix OBUS 2.5450e-003 0.00
tblFleetMix SBUS 8.7700e-004 0.00
tblFleetMix UBUS 2.4420e-003 0.00
tblLandUse LotAcreage 0.00 13.26
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 1.00
tblOffRoadEquipment UsageHours 8.00 0.00
tblTripsAndVMT WorkerTripNumber 3.00 0.00
tblVehicleTrips CC_TL 7.30 1.00
tblVehicleTrips CC_TTP 0.00 100.00
tblVehicleTrips CNW_TL 7.30 0.00
tblVehicleTrips CW_TL 9.50 0.00
tblVehicleTrips PR_TP 0.00 100.00
tblVehicleTrips WD_TR 0.00 57.00
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2.0 Emissions Summary
2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2020 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2020 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
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2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 1.0000e-
005
0.0000 1.0000e-
004
0.0000 0.0000 0.0000 0.0000 0.0000 2.2000e-
004
2.2000e-
004
0.0000 2.3000e-
004
Energy 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mobile 0.0883 1.8400 1.1591 1.7100e-
003
0.0556 6.2700e-
003
0.0618 0.0167 6.0000e-
003
0.0226 176.4140 176.4140 0.0122 176.7184
Total 0.0883 1.8400 1.1592 1.7100e-
003
0.0556 6.2700e-
003
0.0618 0.0167 6.0000e-
003
0.0226 176.4142 176.4142 0.0122 0.0000 176.7186
Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 1.0000e-
005
0.0000 1.0000e-
004
0.0000 0.0000 0.0000 0.0000 0.0000 2.2000e-
004
2.2000e-
004
0.0000 2.3000e-
004
Energy 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mobile 0.0883 1.8400 1.1591 1.7100e-
003
0.0556 6.2700e-
003
0.0618 0.0167 6.0000e-
003
0.0226 176.4140 176.4140 0.0122 176.7184
Total 0.0883 1.8400 1.1592 1.7100e-
003
0.0556 6.2700e-
003
0.0618 0.0167 6.0000e-
003
0.0226 176.4142 176.4142 0.0122 0.0000 176.7186
Mitigated Operational
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3.0 Construction Detail
3.1 Mitigation Measures Construction
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Paving Paving 1/1/2020 1/1/2020 5 1
OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor
Paving Rollers 1 0.00 80 0.38
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Paving 1 0.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural
Coating – sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 0
Acres of Paving: 0
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3.2 Paving - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction Off-Site
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4.0 Operational Detail - Mobile
3.2 Paving - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction Off-Site
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 0.0883 1.8400 1.1591 1.7100e-
003
0.0556 6.2700e-
003
0.0618 0.0167 6.0000e-
003
0.0226 176.4140 176.4140 0.0122 176.7184
Unmitigated 0.0883 1.8400 1.1591 1.7100e-
003
0.0556 6.2700e-
003
0.0618 0.0167 6.0000e-
003
0.0226 176.4140 176.4140 0.0122 176.7184
4.1 Mitigation Measures Mobile
4.2 Trip Summary Information
4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
User Defined Industrial 57.00 0.00 0.00 14,820 14,820
Total 57.00 0.00 0.00 14,820 14,820
Miles Trip %Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by
User Defined Industrial 0.00 1.00 0.00 0.00 100.00 0.00 100 0 0
4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH
User Defined Industrial 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 1.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000
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5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
NaturalGas
Unmitigated
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
5.1 Mitigation Measures Energy
Historical Energy Use: N
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6.1 Mitigation Measures Area
6.0 Area Detail
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
User Defined
Industrial
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
User Defined
Industrial
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 1.0000e-
005
0.0000 1.0000e-
004
0.0000 0.0000 0.0000 0.0000 0.0000 2.2000e-
004
2.2000e-
004
0.0000 2.3000e-
004
Unmitigated 1.0000e-
005
0.0000 1.0000e-
004
0.0000 0.0000 0.0000 0.0000 0.0000 2.2000e-
004
2.2000e-
004
0.0000 2.3000e-
004
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 1.0000e-
005
0.0000 1.0000e-
004
0.0000 0.0000 0.0000 0.0000 0.0000 2.2000e-
004
2.2000e-
004
0.0000 2.3000e-
004
Total 1.0000e-
005
0.0000 1.0000e-
004
0.0000 0.0000 0.0000 0.0000 0.0000 2.2000e-
004
2.2000e-
004
0.0000 2.3000e-
004
Unmitigated
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8.1 Mitigation Measures Waste
7.1 Mitigation Measures Water
7.0 Water Detail
8.0 Waste Detail
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 1.0000e-
005
0.0000 1.0000e-
004
0.0000 0.0000 0.0000 0.0000 0.0000 2.2000e-
004
2.2000e-
004
0.0000 2.3000e-
004
Total 1.0000e-
005
0.0000 1.0000e-
004
0.0000 0.0000 0.0000 0.0000 0.0000 2.2000e-
004
2.2000e-
004
0.0000 2.3000e-
004
Mitigated
9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type
10.0 Stationary Equipment
Fire Pumps and Emergency Generators
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11.0 Vegetation
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type
User Defined Equipment
Equipment Type Number
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Project Characteristics -
Land Use - Project Site Acreage 13.26 acres
Construction Phase - Truck trips only no construction
Off-road Equipment - zero'd out so that construction emissions are zero
Trips and VMT - zero'd out... no construction emissons
Vehicle Trips - 100 percent trucks assumed
Construction Off-road Equipment Mitigation -
Fleet Mix - 100 percent trucks
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population
User Defined Industrial 1.00 User Defined Unit 13.26 0.00 0
1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
5
Wind Speed (m/s)Precipitation Freq (Days)2.2 64
1.3 User Entered Comments & Non-Default Data
1.0 Project Characteristics
Utility Company City of Palo Alto Public Utilities
2020Operational Year
CO2 Intensity
(lb/MWhr)
354.26 0.029CH4 Intensity
(lb/MWhr)
0.006N2O Intensity
(lb/MWhr)
Palo Alto - Deconstruction/Construction Materials Management Ordinance and Inert Debris Transfer Fac
Bay Area AQMD Air District, Annual
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Table Name Column Name Default Value New Value
tblAreaCoating Area_EF_Parking 150 0
tblConstructionPhase NumDays 20.00 1.00
tblFleetMix HHD 0.02 0.00
tblFleetMix LDA 0.57 0.00
tblFleetMix LDT1 0.04 0.00
tblFleetMix LDT2 0.19 0.00
tblFleetMix LHD1 0.02 0.00
tblFleetMix LHD2 5.3710e-003 0.00
tblFleetMix MCY 5.9420e-003 0.00
tblFleetMix MDV 0.11 0.00
tblFleetMix MH 8.1200e-004 0.00
tblFleetMix MHD 0.02 1.00
tblFleetMix OBUS 2.5450e-003 0.00
tblFleetMix SBUS 8.7700e-004 0.00
tblFleetMix UBUS 2.4420e-003 0.00
tblLandUse LotAcreage 0.00 13.26
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 1.00
tblOffRoadEquipment UsageHours 8.00 0.00
tblTripsAndVMT WorkerTripNumber 3.00 0.00
tblVehicleTrips CC_TL 7.30 1.00
tblVehicleTrips CC_TTP 0.00 100.00
tblVehicleTrips CNW_TL 7.30 0.00
tblVehicleTrips CW_TL 9.50 0.00
tblVehicleTrips PR_TP 0.00 100.00
tblVehicleTrips WD_TR 0.00 57.00
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2.0 Emissions Summary
2.1 Overall Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2020 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2020 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction
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2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 0.0000 0.0000 1.0000e-
005
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e-
005
2.0000e-
005
0.0000 0.0000 2.0000e-
005
Energy 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mobile 0.0110 0.2380 0.1389 2.2000e-
004
7.0100e-
003
8.0000e-
004
7.8100e-
003
2.1100e-
003
7.7000e-
004
2.8800e-
003
0.0000 20.9620 20.9620 1.3700e-
003
0.0000 20.9961
Waste 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Water 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0110 0.2380 0.1389 2.2000e-
004
7.0100e-
003
8.0000e-
004
7.8100e-
003
2.1100e-
003
7.7000e-
004
2.8800e-
003
0.0000 20.9620 20.9620 1.3700e-
003
0.0000 20.9962
Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quarter Start Date End Date Maximum Unmitigated ROG + NOX (tons/quarter)Maximum Mitigated ROG + NOX (tons/quarter)
Highest
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2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 0.0000 0.0000 1.0000e-
005
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e-
005
2.0000e-
005
0.0000 0.0000 2.0000e-
005
Energy 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mobile 0.0110 0.2380 0.1389 2.2000e-
004
7.0100e-
003
8.0000e-
004
7.8100e-
003
2.1100e-
003
7.7000e-
004
2.8800e-
003
0.0000 20.9620 20.9620 1.3700e-
003
0.0000 20.9961
Waste 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Water 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0110 0.2380 0.1389 2.2000e-
004
7.0100e-
003
8.0000e-
004
7.8100e-
003
2.1100e-
003
7.7000e-
004
2.8800e-
003
0.0000 20.9620 20.9620 1.3700e-
003
0.0000 20.9962
Mitigated Operational
3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Paving Paving 1/1/2020 1/1/2020 5 1
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Acres of Grading (Site Preparation Phase): 0
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3.1 Mitigation Measures Construction
OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor
Paving Rollers 1 0.00 80 0.38
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Paving 1 0.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural
Coating – sqft)
Acres of Grading (Grading Phase): 0
Acres of Paving: 0
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3.2 Paving - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/28/2019 12:43 PMPage 7 of 18
Palo Alto - Deconstruction/Construction Materials Management Ordinance and Inert Debris Transfer Fac - Bay Area AQMD Air District, Annual
4.0 Operational Detail - Mobile
3.2 Paving - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/28/2019 12:43 PMPage 8 of 18
Palo Alto - Deconstruction/Construction Materials Management Ordinance and Inert Debris Transfer Fac - Bay Area AQMD Air District, Annual
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 0.0110 0.2380 0.1389 2.2000e-
004
7.0100e-
003
8.0000e-
004
7.8100e-
003
2.1100e-
003
7.7000e-
004
2.8800e-
003
0.0000 20.9620 20.9620 1.3700e-
003
0.0000 20.9961
Unmitigated 0.0110 0.2380 0.1389 2.2000e-
004
7.0100e-
003
8.0000e-
004
7.8100e-
003
2.1100e-
003
7.7000e-
004
2.8800e-
003
0.0000 20.9620 20.9620 1.3700e-
003
0.0000 20.9961
4.1 Mitigation Measures Mobile
4.2 Trip Summary Information
4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
User Defined Industrial 57.00 0.00 0.00 14,820 14,820
Total 57.00 0.00 0.00 14,820 14,820
Miles Trip %Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by
User Defined Industrial 0.00 1.00 0.00 0.00 100.00 0.00 100 0 0
4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH
User Defined Industrial 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 1.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/28/2019 12:43 PMPage 9 of 18
Palo Alto - Deconstruction/Construction Materials Management Ordinance and Inert Debris Transfer Fac - Bay Area AQMD Air District, Annual
5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Electricity
Mitigated
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Electricity
Unmitigated
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
NaturalGas
Mitigated
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
NaturalGas
Unmitigated
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
5.1 Mitigation Measures Energy
Historical Energy Use: N
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/28/2019 12:43 PMPage 10 of 18
Palo Alto - Deconstruction/Construction Materials Management Ordinance and Inert Debris Transfer Fac - Bay Area AQMD Air District, Annual
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
User Defined
Industrial
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
User Defined
Industrial
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/28/2019 12:43 PMPage 11 of 18
Palo Alto - Deconstruction/Construction Materials Management Ordinance and Inert Debris Transfer Fac - Bay Area AQMD Air District, Annual
6.1 Mitigation Measures Area
6.0 Area Detail
5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
User Defined
Industrial
0 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000
Unmitigated
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
User Defined
Industrial
0 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/28/2019 12:43 PMPage 12 of 18
Palo Alto - Deconstruction/Construction Materials Management Ordinance and Inert Debris Transfer Fac - Bay Area AQMD Air District, Annual
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 0.0000 0.0000 1.0000e-
005
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e-
005
2.0000e-
005
0.0000 0.0000 2.0000e-
005
Unmitigated 0.0000 0.0000 1.0000e-
005
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e-
005
2.0000e-
005
0.0000 0.0000 2.0000e-
005
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 0.0000 0.0000 1.0000e-
005
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e-
005
2.0000e-
005
0.0000 0.0000 2.0000e-
005
Total 0.0000 0.0000 1.0000e-
005
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e-
005
2.0000e-
005
0.0000 0.0000 2.0000e-
005
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/28/2019 12:43 PMPage 13 of 18
Palo Alto - Deconstruction/Construction Materials Management Ordinance and Inert Debris Transfer Fac - Bay Area AQMD Air District, Annual
7.1 Mitigation Measures Water
7.0 Water Detail
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 0.0000 0.0000 1.0000e-
005
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e-
005
2.0000e-
005
0.0000 0.0000 2.0000e-
005
Total 0.0000 0.0000 1.0000e-
005
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e-
005
2.0000e-
005
0.0000 0.0000 2.0000e-
005
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/28/2019 12:43 PMPage 14 of 18
Palo Alto - Deconstruction/Construction Materials Management Ordinance and Inert Debris Transfer Fac - Bay Area AQMD Air District, Annual
Total CO2 CH4 N2O CO2e
Category MT/yr
Mitigated 0.0000 0.0000 0.0000 0.0000
Unmitigated 0.0000 0.0000 0.0000 0.0000
7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
User Defined
Industrial
0 / 0 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/28/2019 12:43 PMPage 15 of 18
Palo Alto - Deconstruction/Construction Materials Management Ordinance and Inert Debris Transfer Fac - Bay Area AQMD Air District, Annual
8.1 Mitigation Measures Waste
7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
User Defined
Industrial
0 / 0 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000
Mitigated
8.0 Waste Detail
Total CO2 CH4 N2O CO2e
MT/yr
Mitigated 0.0000 0.0000 0.0000 0.0000
Unmitigated 0.0000 0.0000 0.0000 0.0000
Category/Year
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/28/2019 12:43 PMPage 16 of 18
Palo Alto - Deconstruction/Construction Materials Management Ordinance and Inert Debris Transfer Fac - Bay Area AQMD Air District, Annual
8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
User Defined
Industrial
0 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000
Unmitigated
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
User Defined
Industrial
0 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000
Mitigated
9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/28/2019 12:43 PMPage 17 of 18
Palo Alto - Deconstruction/Construction Materials Management Ordinance and Inert Debris Transfer Fac - Bay Area AQMD Air District, Annual
11.0 Vegetation
10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type
User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/28/2019 12:43 PMPage 18 of 18
Palo Alto - Deconstruction/Construction Materials Management Ordinance and Inert Debris Transfer Fac - Bay Area AQMD Air District, Annual
NEGATIVE DECLARATION
CIRCULATION PERIOD
3/22/2019 to 4/11/2019
PROJECT NAME Deconstruction/Construction Materials Management Ordinance
and Inert Debris Transfer Facility Site Permitting
PROJECT LOCATION The Deconstruction/Construction Materials Management would
apply to the entire City of Palo Alto (City), which is located in
Santa Clara County. The inert debris transfer facility is located at
1237 San Antonio Road, Palo Alto, California 94303 (APN # 116-
01-013 and 116-01-047).
PROJECT PROPONENT City of Palo Alto
250 Hamilton Avenue
Palo Alto, California 94301
CITY CONTACT Claire Hodgkins, AICP, Planner
City of Palo Alto, 250 Hamilton Avenue, Ground Floor
Palo Alto, CA 94301
Phone: 650-329-2116
Fax: 650-329-2240
Email: Claire.Hodgkins@cityofpaloalto.org
PROJECT DESCRIPTION The proposed project is the adoption of a new
Deconstruction/Construction Materials Management Ordinance
(Ordinance) and the approval of an inert debris transfer facility
to consolidate materials for offsite transfer for the City of Palo
Alto (City). The Ordinance will result in changes to Chapter 5.24
of the City’s Municipal Code.
DETERMINATION
In accordance with the City of Palo Alto's procedures for compliance with the California
Environmental Quality Act {CEQA}, the City has conducted an Initial Study to determine
whether the proposed project could have a significant effect on the environment. On the
basis of that study, the City makes the following determination:
181 The proposed project COULD NOT have a significant effect on the environment, and
a NEGATIVE DECLARATION is hereby adopted.
Although the project, as proposed, could have a significant effect on the
environment, there will not be a significant effect on the environment in this case
because mitigation measures have been added to the project and, therefore, a
MITIGATED NEGATIVE DECLARATION is hereby adopted.
The attached initial study incorporates an relevant information regarding the potential
environmental effects of the project and confirms the determination that an Ef R is not
required for the project.
~~~~~~~~~~~~VLM2--~~~'-I-Lj
Signature (Project Planner} ntte Dote
Adopted by City Council, Attested by
Director of Planning + Community Environment
(signed after ND has been approved}
Title Date
City of Pa!<> Alto • ~iti{i;at1:d Ne.gative ~e~lara~ion P_ a _g .': I 2
NOTICE OF INTENT TO ADOPT A NEGATIVE DECLARATION
Pursuant to Section 21092 and 21092.3 of the Public Resources Code and CEQA Guidelines
Section 15072, as amended to date, this notice is to advise you that the City of Palo Alto has
prepared an Initial Study on the following project to evaluate the environmental impacts of
the project identified below. The Initial Study concludes that the project described below
would not have a significant effect on the environment, and therefore, the City proposes to
adopt a Negative Declaration (ND). The purpose of this notice is to inform the public of the
City’s intent to adopt a ND for the project, and to provide an opportunity for public
comments on the draft ND/Initial Study.
TO: AGENCIES,
ORGANIZATION, +
INTERESTED PARTIES
The City of Palo Alto requests comments and concerns from
agencies, organizations and interested parties regarding the
environmental issues associated with construction and
operation of the proposed project.
PROJECT TITLE Deconstruction/Construction Materials Management Ordinance
and Inert Debris Transfer Facility Site Permitting
PROJECT APPLICANT City of Palo Alto
250 Hamilton Avenue
Palo Alto, California 94301
PROJECT LOCATION The Deconstruction/Construction Materials Management would
apply to the entire City of Palo Alto (City), which is located in
Santa Clara County. The inert debris transfer facility is located at
1237 San Antonio Road, Palo Alto, California 94303 (APN # 116-
01-013 and 116-01-047).
PROJECT DESCRIPTION The proposed project is the adoption of a new
Deconstruction/Construction Materials Management Ordinance
(Ordinance) and the approval of an inert debris transfer facility
to consolidate materials for offsite transfer for the City of Palo
Alto (City). The Ordinance will result in changes to Chapter 5.24
of the City’s Municipal Code.
PUBLIC REVIEW
PERIOD
PUBLIC HEARING
COMMENTS
This NOi and the Draft Initial Study and Negative Declaration are
available for public review and comment pursuant to Section 21092
and 21092.3 of the Public Resources Code and CEQA Guidelines
Section 15072. The comment period begins on Friday, March 22,
2019 and ends on Thursday, April 11, 2019.
This NOi and the Draft Initial Study and Negative Declaration may be
reviewed at the following locations in Palo Alto: Planning and
Community Environment office (250 Hamilton Avenue), Downtown
Library (270 Forest Avenue, Palo Alto, CA 94301), or Rinconda
Library (1213 Newell Road, Palo Alto, CA 94303). It may also be
viewed online at:
https:ljwww.cityofpaloalto.org/news/displaynews.asp?News1D=4538&Target%20ID=319
The City Council is anticipated to consider the project as part of its
regularly scheduled meeting on May 20, 2019. The meeting will start
at 5:00 PM and will be held at the City of Palo Alto Council
Chambers, located in City Hall at 250 Hamilton Avenue. The meeting
agenda will be posted to the City Council's website. Interested
parties should check the City Council agenda on the City's website to
confirm the meeting time, date, and location:
https:ljwww.cityofpaloalto.org/gov / depts/ cou/cou nci I agendas.asp
Please send comments by mail or e-mail, before on April 11, 2019,
to:
Claire Hodgkins, AICP, Planner
City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301
Claire.Hodgkins@cityofpaloalto.org
If you require additional project information, please contact
Claire Hodgkins at {650) 329-2116
Attachment E
Not Yet Approved
2019053001
Ordinance No. _____
Ordinance of the Council of the City of Palo Alto Amending Title 5 of the Palo
Alto Municipal Code to Repeal Chapter 5.24 (Construction and Demolition
Debris Diversion Facilities) and Add a New Chapter 5.24, Entitled
Deconstruction and Construction Materials Management, to Establish
Regulations Related to the Management of Deconstruction and Construction
Debris and Materials
The Council of the City of Palo Alto ORDAINS as follows:
SECTION 1. Findings and Declarations. The City Council finds and declares as follows:
A. The process of demolition, construction, renovation and remodel of buildings
and structures generates significant amounts of waste that is either disposed in landfills or
combined into a mixed waste that then has to be processed and sorted. The disposal and burial
of waste in landfills leads to an increase in greenhouse gas emissions, increase in carbon
emissions, and substantial environmental impacts associated with building removal.
B. The practice of freely allowing project applicants, developers and contractors to
combine the materials generated at construction and demolition sites into a mixed waste
product encourages them to pay little attention to the quantity of the waste created from each
construction and demolition project, the amount of waste that is disposed in landfills and the
associated environmental impact. There is an opportunity to augment regulations to improve
the effectiveness of reuse and recycling of construction site materials generated on projects
within Palo Alto.
C. The deconstruction and source separation of construction and demolition
related waste leads to handling discards as resources, not waste. It leads to highest and best
use of materials, higher recovery levels, and greater recyclability of materials. Deconstruction
also follows the waste management and zero waste hierarchy of reduce, reuse, recycle, and
compost, and reduces the volume and toxicity of waste and materials.
D. The City of Palo Alto updated its Zero Waste Plan in 2018, with new provisions
designed to help the City reach its goal of 95% diversion of materials from landfills by 2030, and
80% reduction of greenhouse gases by the same year. Waste from construction and demolition
related activities represent over 40% of the waste from Palo Alto that is disposed in landfills,
hampering Palo Alto from achieving zero waste.
E. Policies that promote deconstruction methods instead of demolition, and
require materials to be source separated to maximize the salvage of building materials for
reuse and to increase higher level of diversion of recyclable and compostable materials, will
reduce the amount of landfilled waste, increase recovery of materials and reduce greenhouse
Attachment E
Not Yet Approved
2019053001 2
gas emissions. These strategies are crucial for conserving resources and protecting the
environment, and integral to Palo Alto’s goal of zero waste.
SECTION 2. Chapter 5.24 of Title 5 (Construction and Demolition Debris Diversion Facilities) is
hereby repealed and replaced in its entirety with a new Chapter 5.24 to read as follows:
Chapter 5.24
Deconstruction and Construction Materials Management
Sections:
5.24.010 Purpose
5.24.020 Definitions
5.24.030 Applicability
5.24.040 Salvage survey and reuse required
5.24.050 Deconstruction and source separation of materials
5.24.060 Material collection
5.24.070 No unauthorized containers
5.24.080 Exclusions
5.24.090 Administration by City Manager
5.24.100 Enforcement and penalties
5.24.010 Purpose
The accumulation, collection, removal and disposal of waste associated with construction,
deconstruction and demolition activities must be controlled for the protection of the public
health, safety and welfare, and the natural environment. State law addresses this need
through the California Integrated Waste Management Act of 1989 and the California Green
Building Code, which requires local governments to require fifty percent of construction debris
be diverted from the landfill, and Senate Bill 1374, which requires annual reporting to the state
on progress made in the diversion of construction related materials, including information on
programs and ordinances implemented and quantitative data, where available. Required
minimum diversion rates by project type are covered under the California Green Building Code
and the City's local amendments in Title 16, Building Regulations, of this code. In 2016, the City
adopted sustainability, waste diversion and climate action goals of 80% reduction in
greenhouse gases and 95% diversion of materials from landfills by 2030. The City may adopt,
implement, and enforce requirements, rules and regulations for local reuse and recycling of
materials that are more stringent or comprehensive than California law, and this Chapter
establishes local requirements to further both state law and the City’s adopted policies.
This Chapter’s goals are to implement best practice methods for separation, handling, and
delivery of deconstruction and construction site materials to maximize the salvage of building
materials for reuse, to reduce the amount of construction and deconstruction related materials
Attachment E
Not Yet Approved
2019053001 3
disposed in landfills and to establish deconstruction and source separation requirements. The
requirements of this Chapter are in addition to, the requirement in Chapter 16.14 of this code
to achieve a specified diversion of materials generated from an applicable construction project.
5.24.020 Definitions
For purposes of this Chapter, terms defined in Chapter 5.20 shall have the same meanings in
this Chapter 5.24. The following terms shall have the ascribed definition for the purposes of
applying the criteria of this Chapter and other chapters as referenced.
a. "Approved facility" means a reuse, recycling, composting, or materials recovery facility
which the Director has determined can accept diverted materials, has obtained all
applicable federal, state and local permits, and is in full compliance with all applicable
regulations for reuse, recycling, composting, and/or materials recovery.
b. "Applicant" means (a) any individual, firm, limited liability company, association,
partnership, political subdivision, government agency, municipality, industry, public or
private corporation, or any other entity whatsoever who applies to the City for, or who is
issued, the applicable permits to undertake a construction, remodeling, or demolition
project within Palo Alto, and (b) the owner of the real property that is subject to the
permit.
c. "Construction and demolition debris" or “construction and deconstruction materials”
means (1) discarded materials generally considered to be non-water soluble and non-
hazardous in nature (as defined by California Code of Regulations, Title 22, § 66261.3 et
seq.), including but not limited to, metal, glass, brick, concrete, porcelain, ceramics,
asphalt, pipe, gypsum wallboard, and lumber from the construction or destruction of a
structure as part of a construction or demolition project or from the renovation of a
structure and/or landscaping, including rocks, soil, trees, and other vegetative matter
that normally results from land clearing, landscaping and development operations for a
construction project; and (2) remnants of new materials, including but not limited to,
cardboard, paper, plastic, wood, glass and metal from any construction, renovation
and/or landscape project.
d. “Contractor” means any person or entity holding, or required to hold, a contractor’s
license under the laws of the State of California, and who performs any construction,
deconstruction, demolition, remodeling, renovation, or landscaping service relating to
buildings or accessory structures in the city.
e. “Covered project” means any project that is required to comply with the provisions of
this Chapter 5.24, as described in Section 5.24.030.
Attachment E
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f. “Deconstruction” means the systematic and careful dismantling of a structure, typically
in the opposite order it was constructed, in order to maximize the salvage of materials
and parts for reuse and recycling.
g. “Demolition” means the partial or complete destroying, tearing down, dismantling or
wrecking of any building or structure.
h. “Diversion” means any activity, including recycling, source reduction, reuse,
deconstruction, or salvaging of materials, which causes materials to be diverted from
disposal in landfills and instead puts the material to use as the same or different usable
product.
i. “Recycling" means the process of collecting, sorting, cleansing, treating, and
reconstituting materials that would otherwise become solid waste, and returning them
to the economic mainstream in the form of raw material for new or reconstituted
products which meet the quality standards necessary to be used in the marketplace. This
term does not include transformation as that term is defined in Public Resources Code
section 40180.
j. "Reuse" means further or repeated use of materials or items, including sale or donation
of items, but not including recycling.
k. “Reuse organization” means an organization approved by the City to provide salvage
surveys and accept materials or items for reuse.
l. "Salvage" means the controlled removal of items and material from a building,
construction, or demolition site for the purpose of on- or off-site reuse, or storage for
later reuse. Examples of items that may be salvaged include air conditioning and heating
systems, columns, balustrades, fountains, gazebos, molding, mantels, pavers, planters,
quoins, stair treads, trim, wall caps, bath tubs, bricks, cabinetry, carpet, doors, ceiling
fans, lighting fixtures, electrical panel boxes, fencing, fireplaces, flooring materials of
wood, marble, stone or tile, furnaces, plate glass, wall mirrors, door knobs, door
brackets, door hinges, marble, iron work, metal balconies, structural steel, plumbing
fixtures, refrigerators, rock, roofing materials, siding materials, sinks, stairs, stone,
stoves, toilets, windows, wood fencing, lumber and plywood.
m. "Source separated single recyclable materials" means recyclable materials that are
separated from other recyclable materials or solid waste and placed in separate
containers according to type or category of materials and directly marketed as a single
commodity.
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5.24.030 Applicability
This Chapter shall be applicable to all residential and commercial projects that include a whole
structure demolition requiring a demolition permit. However, this Chapter shall not apply to
those projects comprised solely of the demolition of an accessory dwelling unit, or to any
project for which the completed demolition permit application was submitted to the City prior
to July 1, 2020.
5.24.040 Salvage survey and reuse required
a. All applicants and other persons who undertake a covered project shall complete a
salvage survey provided by a reuse organization or other third party approved by the
City, prior to the issuance of a demolition permit. The survey shall itemize the materials
and items eligible for salvage and reuse and the estimated weights.
b. Upon completion of the deconstruction and source separation of materials, the
applicant or person responsible for the covered project shall ensure the items listed on
the salvage survey are delivered to, collected by or received by, and certified by a reuse
organization or other third party approved by the City, and shall submit to the City proof
of delivery of salvage items in accordance with City regulations.
5.24.050 Deconstruction and source separation of materials
a. All applicants and other persons who undertake a covered project where materials can
be recycled or composted shall deconstruct buildings and structures in a manner to
divert the maximum feasible amount of materials and debris from disposal in landfills.
All construction and deconstruction materials shall be source separated. Materials to be
source separated for recycling include, but are not limited to, steel, glass, brick,
concrete, asphalt, roofing material, pipe, gypsum, sheetrock, lumber, wood, pallets,
rocks, sand, soil, clean cardboard, paper, plastic, carpet, wood and metal scraps.
Materials to be composted include, but are not limited to, trees, shrubs, plant cuttings,
food scraps, and other material as designated by the City.
b. All persons undertaking a covered project shall submit proof of reuse, recycling and
composting in accordance with City regulations.
c. The City, or its collector at City’s direction, shall be authorized to inspect, upon
reasonable notice, and audit individual waste streams generated at covered projects to
determine compliance with this Section.
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5.24.060 Material collection
Projects using a container provided by the City’s collector pursuant to the provisions of Chapter
5.20 shall be deemed to have complied with the requirement to take construction and
deconstruction related waste and source separated materials to an approved facility. Persons
using any other method of collection shall dispose of such debris at an approved facility in
accordance with City regulations.
5.24.070 No unauthorized containers
No person other than the City’s collector may place containers within Palo Alto.
5.24.080 Exclusions
The provisions of this Chapter shall not apply to the following:
a. Dangerous Structures. Any building or structure that has been determined to be
dangerous, structurally unsafe or otherwise hazardous to human life, and is required to
be abated by demolition.
b. No Suitable Materials. Any building or structure that does not have materials that are
suitable for reuse, recycling, or compost, as determined by the Director of Public Works.
Materials unsuitable for reuse, recycling, or compost include insulation, painted or
treated wood, rubber, and non-recyclable plastics.
c. De Minimus Exception. The Director of Public Works may waive any of the requirements
of this Chapter if documentation satisfactory to the Director is provided to establish that
the materials are not reusable, recyclable or compostable, the materials are incidental
in quantity, or providing appropriate containers at the particular site would be unduly
difficult.
5.24.090 Administration by City Manager
a. The City Manager shall adopt written rules and regulations, not inconsistent with this
Chapter, as may be necessary for the proper administration and enforcement of this
Chapter.
b. The City Manager shall resolve all disputes concerning the administration or
enforcement of this Chapter, and his or her decision shall be final.
5.24.100 Enforcement and penalties
a. The Director of Public Works shall have primary responsibility for enforcement of this
Chapter. The Director of Public Works is authorized to take any and all other actions
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reasonable and necessary to enforce this Chapter.
b. Violation of any provision of this Chapter shall be subject to the provisions and penalties
set forth in Title 1 of the Municipal Code unless otherwise specified.
c. The remedies and penalties provided in this Section are cumulative and not exclusive.
SECTION 3. If any section, subsection, clause or phrase of this Ordinance is for any reason held
to be invalid, such decision shall not affect the validity of the remaining portion or sections of
the Ordinance. The Council hereby declares that it should have adopted the Ordinance and
each section, subsection, sentence, clause or phrase thereof irrespective of the fact that any
one or more sections, subsections, sentences, clauses or phrases be declared invalid.
SECTION 4. The potential environmental impacts of this Ordinance were evaluated in an Initial
Study/Negative Declaration (IS/ND) prepared in accordance with the California Environmental
Quality Act (“CEQA”), which IS/ND the Council considered and adopted by separate resolution
prior to taking action to approve this Ordinance.
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SECTION 5. This Ordinance shall be effective on the thirty-first day after the date of its
adoption.
INTRODUCED:
PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
____________________________ ____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
____________________________ ____________________________
Assistant City Attorney City Manager
____________________________
Director of Public Works
For more information contact Zero Waste Palo Alto at:
(650) 496‐5910 or zerowaste@cityofpaloalto.org
BAN REQUIRE
REQUIRE
PHASE III ‐ 2025
PHASE II ‐ 2021
BAN
DISPOSABLE FOODWARE REDUCTION PLAN
Zero Waste Palo Alto
The goal of the Disposable Foodware Reduction Plan is to reduce the amount of single‐use, disposable
foodware generated in Palo Alto, encourage the use of reusable foodware, and to ensure that single‐use
disposable items that are effectively recovered are either recycled or composted. The plan has a
phased approach beginning with straws and other small single‐use disposable plastics.
PHASE I ‐ 2019
BAN REQUIRE
Plan date 5/17/19.
1. Single-use disposable foodware items.
a. Plastic straws.
b. Plastic utensils.
c. Plastic drink stirrers.
d. Plastic drink plugs.
e. Plastic food and drink picks.
f. Plastic drink accoutrements.
2. Plastic produce bags.
1. Banned foodware, if offered, must be compostable or
reusable.
2. All disposable foodware must be aceptable in the City's
collection program.
3. Disposable foodware must be offered only upon request or via
self-serve station.
4. Businesses to provide receipts only upon request.
5. Produce and meat bags must be reusable or compostable.
1. All disposable plastic foodware.
2. Disposable foodware for dine-in.
3. Use of fluorinated compounds in
compostable foodware.
1. Any remaining disposable single-use foodware must be
compostable and acceptable in the City's compost collection
program.
2. Charge for non-reusable cups and containers.
3. Reusable foodware for dine-in.
4. All new construction and tenant improvements for food
service establishments required to install a dishwasher.
1. Single-use disposable foodware for take-
out.
1. All food service establishments mush have a dishwasher or
sign-up for a dishwasher service, or sign-up for a reusable
foodware service program.
2. Reusable foodware for take-out.
Plas c
Straws
Plas c
Utensils
Plas c
Beverage Plugs
Plas c
S rrers
DISPOSABLE FOODWARE REDUCTION PLAN
PHASE I ‐ 2019
BANNED FOODWARE
OTHER REQUIREMENTS
Foodware
Items
Must Be
Reusable Or
Compostable
Must Be
Accepted In
City's
Collection
Program
Disposable
Foodware &
Receipts
Only Upon
Request
Other Plastic
Accoutrements
Attachment G
1) SALVAGE SURVEY AND REUSE
Currently - Only residential whole house demolition permits are required to complete a salvage survey. Permittees are
not required to salvage materials on the survey.
NEW: Salvage surveys will be required on all projects within each phase; survey and certification on materials and
items accepted to be conducted by City approved reuse organizations.
2) DECONSTRUCTION AND SOURCE SEPARATION
Currently – Demolition is allowed, and construction related waste can be mixed. All projects that are $25,000 or more
in value are required to submit a debris management plan to the City and contractors must input weights into Green
Halo to track the project tonnage with a goal of achieving 80% diversion for each project.
NEW: Deconstruction and source separation will be required on all projects within each phase. Materials must be
source separated and delivered to City approved materials recovery facilities.
3) GREENWASTE AS THE APPROVED COLLECTOR
Currently - Contractors are allowed to use any waste hauler for collection of source separated material in debris
boxes.
NEW: Contractors will utilize GreenWaste to haul all materials if using containers (bins or debris boxes) at project
sites. Contractors can continue to self-haul material by using trucks but must still source separate materials in
accordance with City requirements and deliver materials to City approved processing facilities.
~
Phases Deconstruction Phases Summary
Number of
Estimated
Projects
Phase 1 - effective July 2020
Salvage survey, reuse and source separation on residential
and commercial projects required to obtain permits for
complete demolition 114
Phase 2 - effective ~January 2022 Salvage survey, reuse and source separation on all
projects valued at $100,000 or more 334
Phase 3 - effective ~January 2023 Lower threshold to $50,000 or more 138
Deconstruction & Construction Materials Management
(Deconstruction Ordinance – Chapter 5.24)
Attachment H
~-Stanford
,, HEALTH CARE
STANFORD MEDICINE
May 23 , 2019
Phil Bobel
Assistant Director
City of Palo Alto Public Works Department
250 Hamilton Avenue
Palo Alto, California 94301
9 Stanford
V Children's Health
Lucile Packard
Children's Hospital
Stanford
RE: Letter to Request Exemption in Disposable Foodware Reduction Ordinance for Hospitals
When Necessary for the Delivery of Patient Care Services
Dear Assistant Director Bobel:
Thank you for discussing the City of Palo Alto's Foodware Reduction Plan and the Phase I Ordinance
scheduled to be considered by the City Council on June 10, 2019 with Jon Cowan and Diana Bautista.
Based on this discussion and extensively reviewing what is available regarding the ordinance, we
respectfully request an exemption for hospitals when necessary for the delivery of patient care services .
Both of our organizations have prioritized environmental sustainability for more than two decades. We
moved to green cleaning supplies in the early 2000's and at the same time increased our onsite recycling.
We have been using compostable plates and silverware in our cafeterias for some time. And last, but
definitely not least, Lucile Packard Children's Hospital's new main hospital received LEED platinum
status. We remain committed to continuously improving and adding to our sustainability efforts.
While we have already voluntarily achieved much of what is to be included in the draft ordinance, we
have also identified examples where we will not be able to meet the requirements of the ordinance based
on patient care or related needs or regulatory requirements . For example, plastic is cutTently requir ed to
properly care for ce1iain of our patients. Changes to foodware can be complicated in a hospital
environment, as all potential changes must be evaluated for patient impact, workplace violence risk, as
well as compliance with multiple state and federal health care regulations. For example, our Food
Services departments assess patient impact on an ongoing basis. As another example, our Environmental
Health & Safety departments assess utensils for workplace violence risk from emergency department or
psychiatric unit patients.
To elaborate:
• Paper straws have been tried but do not cutTently work for patients who need to bend them or to
drink more slowly due to their compromised health.
• Plastic supplies may be required as part of the 96-hour emergency supplies regulators require
hospitals to maintain. Plastic supplies may also be required to continue to serve patients during
power outages that impact dishwashers.
• We believe replacing biodegradable utensils with compostable units may be feasible, but would
need to receive certification from our Environmental Health & Safety that this change is safe for
our patients and staff.
• Out-of-city vendors may deliver produce or meat in plastic bags or other materials as part of the
large-scale operations required to support hospitals.
The examples above are intended to be illustrative but not exhaustive for the feasibility for hospitals to
comply with the blanket prohibitions we understand are in the ordinance.
We are committed to continue to work collaboratively regarding disposable foodware reduction, but we
believe that the unique operating requirements for hospitals necessitate an exemption to accommodate the
delivery of patient care services. Such a tailored exemption will allow for an ongoing dialogue with city
staff so that feasible changes can be implemented rather than changes that would harm our patients.
Thank you for your consideration.
Sincerely,
Nancy Olson, Chief Government
& Community Relations Officer
Stanford Health Care
Sherri R. Sager, Chief Government
& Community Relations Officer
Lucile Packard Children's. Hospital Stanford
cc: Brad Eggleston, Director of Public Works, City of Palo Alto
Ed Shikada, City Manager, City of Palo Alto
2
May 14,
2019
Mayor Eric Filseth Members of the City
Council of Palo Alto City of Palo Alto, Office
of the City Clerk 250 Hamilton Ave. Palo
Alto, CA 94301 Submitted via:
city.council@cityofpaloalto.org
Re: Support for Disposable Foodware Reduction Plan Policy with Strong Request to Include
Additional Provisions that Strengthen the Measure
Dear Mayor Filseth and Members of the City Council of Palo Alto:
The undersigned write in general support of the proposed Zero Waste plan and policy
regarding single-use disposable foodware items. However, we urge the Council to incorporate
various provisions anticipated in the City’s Zero Waste Plan but not included in the proposed
policy.
We applaud the Council for considering a measure to reduce single-use foodware and City Staff
for developing a comprehensive plan that considers the safety and health of consumers and the
needs of local business to address some of the key challenges of managing litter and solid
waste. Prioritizing the reduction of single-use foodware is important because these are products
that:
●are used in a matter of minutes but can persist in the environment for thousands of years
(if made from nonbiodegradable plastic),
●contain a variety of toxic chemicals that migrate into food and beverages and impact
human health,
●are easily littered, requiring significant city resources to remove from streets and storm
drains,
●overwhelm the City’s waste management system, and are a significant cost to manage,
●are unsustainable in terms of the resources use in their production, the pollution associated
with their disposal, and the climate impacts associated with their consumption.
Attachment I
City staff have conducted a commendable scoping process gaining public input on a proposed
plan to address the reduction of single-use foodware. We agree with the framework adopted but
not the delay in addressing items listed in phases II and III. We strongly urge the Council to
adopt a comprehensive foodware reduction policy at this time that incorporates the first two
phases into the proposed current policy, with a phased-in implementation approach. We agree
with the proposal that the ordinance immediately:
(1) ban single-use plastic straws, utensils, stirrers, plugs, picks and other drink
accoutrements, and require that if offered they be compostable or reusable; (2)
Ensure these items are acceptable in the City’s collection program; (3) Ensure
these items are available only upon request or at a self-serve station; (4)
Require that businesses provide receipts only upon request; (5) Require that
produce and meat bags be reusable or compostable.
However, the items in Phase II of the Plan should also be incorporated as
follows.
Banning the use of PFAS compounds should not be delayed- it should be immediate. This
class of chemicals is among the greatest threats to human health. They are highly persistent and
those that have been studied are carcinogenic and endocrine disrupting at extremely low levels,
plus they easily migrate from packaging into food and beverages. There are alternatives that are
safer. Other cities, including San Francisco, Berkeley, and the State of Washington, have
already banned the use of these chemicals in foodware.
All the other measures in Phase II should be incorporated into the ordinance with a two
year timeline from the date of the ordinance’s adoption. This includes the following:
● A 25 cent customer charge for single-use take-out cups. Like single-use grocery bags,
there is an easy-to-adopt reusable, Bring Your Own (BYO), alternative. Many people
already bring their own reusable cup. A charge would encourage a significant change in
behavior. Like grocery bag charges, which have resulted in 80% transition to reusables, a
charge on cups would significantly decrease the waste associated with take-out beverages,
which is estimated to be 13% of the street litter on Bay Area streets. The City 1 of Berkeley
already enacted a similar measure with a one year timeline.
● A charge on single-use take-out foodware. As the City of Berkeley recognized, BYO
food containers are more challenging for customers and for businesses to adapt to.
Customers need to have access to reusable containers on deposit when and where they
make their take-out food order, plus convenient drop off locations for the dirty containers.
More time is needed for third party reusable container programs to scale in
1 Clean Water Action’s Taking Out the Trash 2011 Survey.
https://www.mercurynews.com/2011/06/19/survey-pinpoints-sources-of-trash-in-san-francisco-bay/
http://www.cleanwater.org/files/smeyer@cleanwater.org/FINAL%20TOTT%20Report.pdf
the Bay Area. This ordinance could, like the Berkeley ordinance, direct the City to
provide grant resources and technical assistance to help scale such programs.
● Reusable foodware for dine-in. The Zero Waste Plan signals making this requirement
effective within two years (2021). We urge that the City Council include this measure in
phase 1, with a two year date of implementation (effective 2021). Including this measure in
the ordinance puts local food businesses on notice that they will need to comply and gives
them time to prepare to do so. It also signals that the City Council is serious about reducing
single-use disposable foodware. This is exactly what the City of Berkeley did in their
ordinance.
● New construction food service must demonstrate adequate dishwashing capacity. the
Zero Waste Plan signals making this requirement effective within two years (2021). We urge
that the City Council include this measure in the proposed ordinance with a two year date of
implementation (effective 2021). Including this measure in the ordinance puts local food
businesses on notice that they will need to comply and gives them time to prepare to do so.
Add a policy focused on reducing waste from online food ordering as part of Phase 1.
●OPT IN -requirement. Add a requirement that online food ordering businesses have an
“opt in” disposable accessory policy. This would mandate that when a customer places a
food order through Doordash, Caviar, Postmates or other online apps, they have to
REQUEST single-use items like utensils and napkins. While some online apps allow
customers to refuse these items, we believe the default should not be to provide them.
Reducing single-use products in food service settings is not only good for the environment and
saving the City money spent on cleanup and waste management. It’s good for business, as
demonstrated by ReThink Disposable, a program being implemented by Clean Water Fund in
partnership with the City. Participating businesses are saving thousands of dollars per year when
2 they implement measures to reduce single-use packaging and transition to reusable food
service.
Thank you for considering this important measure. We urge you to make these changes and enact
a single-use foodware reduction policy as soon as possible.
Please see our signature page for those signing this
letter. 2 www.rethinkdisposable.org