U.S. Department of Transportation
Pipeline and Hazardous Materials Safety Administration
Natural Gas Distribution Infrastructure Safety and Modernization Grant Program
The City of Palo Alto
Palo Alto, California
Categorical Exclusion Documentation
NGDISM-FY23-CE-2024-04
PHMSA Office of Planning and Analytics
Environmental Policy and Justice Division
Matt Fuller
[email protected]
City of Palo Alto
Aaron Perkins
[email protected]
1. Overview
This document serves as the Pipeline and Hazardous Materials Safety Administration's (PHMSA) determination of applicability of Department of Energy's (DOE) B5.4 categorical exclusion (CE) for repair or replacement of pipelines for the project identified below. Effective July 3, 2024, PHMSA adopted DOE's CE in accordance with the Section 109 of the National Environmental Policy Act, enacted as part of the Fiscal Responsibility Act of 2023, which allows a federal agency to "adopt" another federal agency's CEs for proposed actions. The project identified below was provisionally awarded federal funding through PHMA's Natural Gas Distribution Infrastructure Safety and Modernization (NGDISM) grant program. This document describes the proposed action and the anticipated impacts of that action and documents the applicability of the use of DOE CE B5.4.
2. Project Description/Proposed Action
Project Title Gas Main Replacement Project 25
Project Location Palo Alto, Santa Clara County, California Project Description/Proposed Action:
The Gas Main Replacement Project 25 is part of the Council-approved Capital Improvement Program (CIP) to ensure reliable gas services for the City of Palo Alto residents and customers. This Project specifically targets the replacement of aging Polyvinyl Chloride (PVC) mains and services, as well as severely corroded steel mains and services, both of which are nearing the end of their operational life expectancy and pose significant risks due to embrittlement and corrosion. A total of 25,081.00 linear feet of main line and associated service lines will be replaced.
The primary goals of this Project are to replace the embrittled PVC mains and services that are susceptible to cracking during earth movement, potentially leading to gas leaks, and to replace severely corroded steel mains and services that lack adequate cathodic protection due to previously installed fittings, which have resulted in leaks discovered through the City's mobile and walking leak surveys.
Question Information
Describe the location and dimensions of all ground The Gas Main Replacement Project in the City of disturbing activities and provide a map depicting the Palo Alto involves extensive ground-disturbing location(s) where ground disturbance would occur. activities across numerous streets, including (e.g., width and depth of trenching or excavation for Northampton Drive, Southampton Drive, Newel borings, location of regulator stations, etc.) Drive, Greenwich Place, Walter Hays Drive, Erstwild Court, Stanley Ways, Jordan Place, Lois Lane, Sutter
Avenue, Clara Drive, Ross Road, Price Court, Stern
Avenue, Allen Court, Loma Verde Place, Torreya
Court, Toyon Place, Ross Court, Stone Lane,
Talisman Court, and Middlefield Road. A majority of
the project will be completed using directional
boring with some trenching along a total of 25,081
linear feet. Excavations will be approximately 4 feet
by 4 feet at gas service tees and tie-in pits will vary NGDISM-FY23-CE-2024-04 Page |2
between 5 feet by 10 feet or 5 feet. Each trench will
measure 2 feet in width and vary in depth from 18
inches to 60 inches, depending on the depth at
which the existing utility pipelines are buried.
If the exact location where new pipe would be The Project covers a total of approximately 25,081 installed or where other work would occur, provide linear feet of distribution main pipeline the width of the ROW and/or the general area replacement. The width right of way (ROW) in these encompassing the footprint where all work would residential and commercial areas ranges from 45 to occur. Include the anticipated footprint and depth of 60 feet. Within this ROW, the construction activities new pipe installation. will occupy a narrower work zone, excavations will be approximately 4 feet by 4 feet at gas service tees
and tie-in pits will vary between 5 feet by 10 feet or
5 feet. Each trench will measure 2 feet in width and
vary in depth from 18 inches to 60 inches,
depending on the depth at which the existing pipes
are buried.
Will service lines be replaced? Yes
Will meters or other equipment be replaced? If so, Yes, the City will replace gas meters with new smart provide a description detailing what meter meters under Gas Main Replacement Project due to components, etc. will be replaced and indicate if this outdated meters, many of which are 20-25 years will require ground disturbance, if the equipment will old, manufacturer of these meters is no longer be attached to existing structures, etc. standard, and some of the meters developed gas leaks over time. The replacement involves several
components of the meter system, including the
meters themselves and the associated hardware.
The new meters will be attached to the existing
structures to minimize ground disturbance.
However, some ground disturbance may occur if
existing setups do not meet the requirements for
the new smart meters.
What portions of the pipeline will be abandoned? All portions of the pipeline to be replaced as part of What portions of the pipeline will be removed? the Gas Main Replacement Project 25 will be abandoned.
No portions of the pipeline will be removed. The City
of Palo Alto's pipeline upgrade project will involve
abandoning all the replaced pipeline sections.
Question Information
What construction methods will be Directional boring; Cut and cover (trenching); Replacement used? adjacent to existing pipe; Abandonment of an existing pipe for a new location.
NGDISM-FY23-CE-2024-04 Page | 3
Does the project require a new right- No new right-of-way or easement needed. of-way not currently in the ownership
of the utility? If new ROW will occur,
please provide a description of the
property to be acquired (existing
condition and land use).
How many linear feet of pipe will be 25,081.00 Linear feet of distribution main replaced or repaired?
2.1. Proposed Pipeline Replacement Details
Existing Pipeline Pipeline Operating Reduced Year installed Pipeline Diameter in Material (cast Pressure (PSI) Pressure if if known.
Length in feet inches iron, bare Possible (PSI)
steel, coated
steel, PVC)
1,415.00 feet 2.00 Coated steel 25.00 1939
1,012.00 feet 2.00 Coated steel 25.00 1945
4,291.00 feet 2.00 Coated steel 25.00 1950
663.00 feet 2.00 Coated steel 25.00 1953
1,086.00 feet 2.00 Coated steel 25.00 1954
1,486.00 feet 2.00 Coated steel 25.00 1955
2,782.00 feet 3.00 Coated steel 25.00 1939
96.00 feet 4.00 Coated steel 25.00 1972
523.00 feet 2.00 PVC 25.00 1955
365.00 feet 2.00 PVC 25.00 1971
956.00 feet 2.00 PVC 25.00 1972
860.00 feet 2.00 PVC 25.00 1973
529.00 feet 2.00 PVC 25.00 1976
1,054.00 feet 2.00 1985
5,045.00 feet 4.00 25.00 1972
720.00 feet 4.00 PVC 25.00 1975
1,189.00 feet 4.00 PVC 25.00 1976
3. Resource Review
The following information represents questions posed to the project proponent identified on the cover page of this document for the project that was provisionally awarded grant funds under PHMSA's NGDISM program. The information and justification section includes the applicant's response. PHMSA's conclusions are based on applicant provided information, independently reviewed by PHMSA. The mitigation measures identified include best management practices and were reviewed and confirmed by the project proponent.
NGDISM-FY23-CE-2024-04 Page | 4
Air Quality and Greenhouse Gases (GHG)
Question Information and Justification
Is the project located in an area designated by the EPA Yes, based on review of the EPA Greenbook the as non-attainment or maintenance status for one or project is in a nonattainment area for ozone, carbon more of the National Ambient Air Quality Standards monoxide and and PM2.5. 2 (NAAQS) ?
Will the construction activities produce emissions that No. exceed de minimis thresholds (tons per year)?
Will mitigation measures be used to capture No.
blowdown??
Will project proponent commit to reducing pressure No.
on the segments/lines to be replaced, prior to
venting?
Estimate the current leak rate per mile based on the The existing leak rate is estimated to be 543 kg/year. type of pipeline material. Based on mileage of
Replacement of pipelines would result in a leak rate
replacement and new pipeline material, estimate the
of approximately 130 kg/year. This would result in an
total reduction of methane.
estimated reduction of 325 kg/year in the first-year
(factoring in venting emissions) and 413 kg/year, each
year after. This would result in a reduction of
approximately 8,175 kg/year over a 20-year
timeframe.
Is there any other information relevant to the project The City will incorporate comprehensive measures to area or the proposed work as it pertains to Air Quality address and mitigate impacts on air quality and and Greenhouse Gas? greenhouse gas emissions. By implementing best construction practices, adhering to regulatory
standards, and focusing on long-term improvements
in system efficiency and leak reduction, the Project
aims to deliver a reliable gas service system to the
community.
Conclusion:
The project area is located within Palo Alto, Santa Clara County, CA. Based on EPA's Greenbook, the project area falls within a non-attainment area for the 8-hour ozone and a maintenance area for PM 2.5 national ambient air quality standard (NAAQS).5 Therefore, PHMSA must ensure that the project would not interfere with the state's plan to maintain national standards for air quality. PHMSA reviewed information provided by the applicant and estimated the emissions that would likely be produced by the construction equipment that would be used to install pipelines. This information was used in conjunction with EPA's MOVES model to determine if the project would exceed EPA's thresholds for NAAQS. PHMSA's assessment is that due to the relatively minor scope of the proposed action, impacts on local air quality resulting from construction 1 Criteria Air Pollutants | US EPA
2 https://www.epa.gov/green-book/green-book-national-area-and-county-level-multi-pollutant-information * Blowdown refers to the venting of natural gas in current facilities, in order to begin rehabilitation, repair, or replacement activities. 4 https://www.epa.gov/green-book/green-book-national-area-and-county-level-multi-pollutant-information 5 https://www3.epa.gov/airquality/greenbook/anayo_ca.html 6 https://www.epa.gov/moves
NGDISM-FY23-CE-2024-04 Page | 5
activities, such as dust and exhaust from construction equipment, would be temporary and fall below EPA's de minimis thresholds'. Thus, the Proposed Action does not require a General Conformity Analysis under Section 176(c) (4) of the Clean Air Act at the proposed project sites.
The Proposed Action would result in minor air quality impacts associated with construction activities, including the intentional venting of methane contained in the existing pipelines prior to replacement. Pipeline blowdowns are typically necessary to ensure that construction and maintenance work can be conducted safely on depressurized natural gas facilities and pipelines. Venting methane is required when service is switched from the existing line to the newly constructed line, but the volume of vented gas can depend on the ability to reduce pressure on the pipe segment or other mitigation actions. As described in the Tier 1 EA, methane leaks from natural gas distribution pipelines increase with age and are considerably higher for cast iron and steel pipelines, as compared with plastic. Replacing leak prone pipe with newer, more durable materials would reduce leaks and methane emissions. Based on the current leak rate of the existing pipes within the project area described above, this project would reduce overall emissions. Therefore, it is PHMSA's assessment that the proposed project would provide a net benefit to air quality from the overall reduction of greenhouse gas emissions.
Mitigation Measures:
• Use on-road and non-road vehicles efficiently by minimizing speeds and the number of vehicles; • Minimize excavation to the greatest extent practical; • Use cleaner, newer, non-road equipment as much as practicable; • Minimize all vehicle idling and at minimum, conforming with local idling regulations; • Ensure that all vehicles and equipment are in proper operating condition; • On-road and non-road engines must meet EPA exhaust emission standards (40 CFR Parts 85, 86, and 89);
• Cover open-bodied trucks while transporting materials; • Use water or other approved dust suppressants at construction sites and on unpaved roadways, as necessary;
• Minimize the area of soil disturbance to that necessary for construction; • Minimize construction site traffic by using offsite parking and shuttle buses, as necessary; • Minimize the idling of equipment.
Water Resources
Question Information and Justification
Are there water resources within the project area, Yes, according to USFWS National Wetland Inventory such as wetlands, streams, rivers, or floodplains? If so, (NWI). would the project temporarily or permanently impact There will be no impacts to water resources. To avoid wetlands or waterways? If water resources are impacting Matadero Creek and Barron Creek, the present but will not be impacted, please describe how
GMR 25 will employ directional boring, implement
these impacts will be avoided (e.g. directional boring
erosion and sediment control measures if needed,
under the resource, etc.)
properly stabilize the site, and comply with the Valley Water requirements. These strategies will ensure that
Matadero Creek will remain unaffected by the
construction activities and maintain its water quality. 7 De Minimis Tables | US EPA
NGDISM-FY23-CE-2024-04 Page | 6
For Matadero and Barron Creeks, the stand-off
distance is a minimum of 50 feet from the entry and
exit pit when drilling the gas main pipeline under the
creek. The distance is approximated based on the soil
condition, which is alluvial soil, to ensure drilling
safety and structural integrity. However, actual
distances might vary based on environmental
conditions at each site. Following local regulations
from Valley Water is important to avoid negative
impacts on the creeks and their surrounding areas.
Adhering to these regulations and thoroughly
examining each site allows for determining the most
suitable stand-off distances to ensure safe and
environmentally responsible drilling operations.
Under the Clean Water Act, is a Section 401 State No.
certification potentially required? If yes, describe
anticipated permit and how project proponent will
ensure permit compliance.
Under the Clean Water Act, is a USACE Section 404 No.
Permit required for the discharge of dredge and fill
material? If yes, describe anticipated permit and how
project proponent will ensure permit compliance.
Under the Clean Water Act, is an EPA or State Section No, there would only be less than an acre of land 402 permit required for the discharge of pollutants into disturbed at any one time. the waters of the United States? Is a Stormwater
Pollution Prevention Plan (SWPPP) required? If yes, A SWPPP will be developed by the contractor. describe how project proponent will ensure permit
compliance.
Will work activities take place within a FEMA designated FEMA's flood maps® indicate the project area is in floodplain? If so, describe any permanent or temporary FEMA Flood Zones A, AH, and AE. These are impacts and the required coordination efforts with considered Special Flood Hazard Areas and state or local floodplain regulatory agencies. correspond to the one percent annual chance of flooding (100-year floodplain).
Is the project located in a Coastal Zone? Will the No, the project is not located within a designated proposed project activities affect any coastal use or coastal zone. The California Coastal Zone does not natural resource of the coastal zone, requiring a include the area of jurisdiction of the San Francisco Consistency Determination and Certification? Please Bay Conservation and Development Commission nor provide any relevant information regarding how the any tributary flowing into this area. ' project proponent normally coordinates with the
applicable state's coastal zone management agency.
Is there any other information relevant to the project Several measures need to be implemented to comply area or the proposed work as it pertains to Water with Valley Water's permit requirements and mitigate Resources. the impacts of installing a gas pipeline under 8 FEMA Flood Map Service Center | Welcome!
9 Boundaries - California Ocean Protection Council
NGDISM-FY23-CE-2024-04 Page | 7
Matadero and Barron Creeks. Staging and laydown
areas should be placed outside wetlands and
floodplains to minimize disruption. Any disturbed
areas must be restored to pre-construction contours,
and reseeded with native plant species as needed, to
rehabilitate the natural habitat. Implement erosion
and sediment control measures, such as silt fences
and check dams, to prevent sediment from entering
the waterways. Invasive plant species should be
removed and replaced with native vegetation to
enhance the habitat for local wildlife. Continuous
monitoring of riparian planting areas for five to seven years is essential to ensure the success of mitigation
efforts.
Conclusion:
PHMSA reviewed NWI maps, as well as the FEMA national flood hazard maps. There are two channelized streams in the project area. Both of these water resources will be crossed by directional bore methods and no direct impacts will occur. The City of Palo Alto and/or it's contractor will obtain appropriate authorizations, if needed, from Santa Clara Vally Water and coordinate with the local floodplain manager, if necessary, for work located in a special flood hazard area. Best management practices will be used, and all areas will be litigation Measure
• Avoid staging and laydown areas in wetlands or floodplains; • Reseed disturbed areas with native plant species, as needed; • Restore disturbed areas to pre-construction contours; • Adhere to additional mitigation measures in accordance with applicable permits; • Use Best Management Practices during construction to control sediment and erosion and prevent pollutants from entering adjacent waterways;
• Coordinate with the appropriate FEMA representative or local floodplain coordinator when work will occur in FEMA designated special flood hazard areas, as needed. • Adhere to all additional mitigation measures outlined in any permits issued by Valley Water, including specific requirements related to bank protection, sediment removal, and vegetation management.
Groundwater and Hazardous Materials/Waste
Question Information and Justification
Does the project have potential to encounter and No.
impact groundwater? If yes, describe potential impacts
from construction activities.
Will the project require boring or directional drilling that | Yes. During all boring and directional drilling may require pits containing mud and inadvertent return activities, a vacuum truck will contain drilling fluids fluids? If yes, describe measures that will be taken and avoid contamination. In the event of an during construction activities to prevent impacts to accidental release of hazardous material or waste, NGDISM-FY23-CE-2024-04 Page | 8
groundwater resources. If boring or directional drilling the City will promptly notify emergency response will not require pits, please describe why these will not agencies, local residents, and regulatory bodies to be required and how fluids will be contained address the situation quickly. These measures aim to reduce the risk of groundwater contamination and
ensure the safe handling of hazardous materials
throughout the Project.
Will the project potentially involve a site(s) No, based on review of EPA's NEPAssist tool. 10 contaminated by hazardous waste? Sites identified as
containing hazardous waste/materials can be
identified through EPA's NEPAssist tool
https://nepassisttool.epa.gov/nepassist/nepamap.aspx
or local databases identifying Superfund, Brownfields,
etc. If hazmat sites are identified in or near areas
where work will occur, describe how the proposed
work poses no risk and/or what mitigative measures
will be used to avoid identified sites.
Is there any indication that the pipeline was ever used No. to convey coal gas? If yes, PHMSA will work with the
project proponent for required studies.
Does the project have the potential to encounter or No. disturb lead pipes or asbestos?
Is there any other information relevant to the project To minimize potential impacts on groundwater and area or the proposed work as it pertains to hazardous materials during the gas pipeline Groundwater and hazardous materials/waste. installation under Matadero and Barron Creeks, the City will implement a Stormwater Pollution
Prevention Plan (SWPPP) to manage runoff and
prevent pollutants from reaching groundwater.
Hazardous materials will be securely stored with
secondary containment if needed, and all waste will
be properly segregated and disposed of according to
regulations, ensuring effective management and
protection of groundwater during boring and drilling
activities.
Conclusion:
PHMSA reviewed EPA's NEPAssist website to identify any hazardous waste, brownfields properties or superfund sites identified in the project area. There were some hazardous waste sites identified near the project area which includes facilities that are generators, transporters, treaters, storers, or disposers of hazardous waste. These will not be impacted by the proposed project. There were no brownfields sites or superfund sites identified in the project area. It is not anticipated that the project would intercept groundwater. During all boring and directional drilling activities, a vacuum truck will contain drilling fluids and avoid contamination. In the event of an accidental release of hazardous material or waste, the City will 10 https://nepassisttool.epa.gov/nepassist/nepamap.aspx NGDISM-FY23-CE-2024-04 Page | 9
promptly notify emergency response agencies, local residents, and regulatory bodies to address the situation quickly. These measures aim to reduce the risk of groundwater contamination and ensure the safe handling of hazardous materials throughout the Project. Best management practices will be used, and the City will implement a SWPPP to manage runoff and prevent pollutants from reaching groundwater. Hazardous materials will be securely stored with secondary containment if needed, and all waste will be properly segregated and disposed of according to regulations, ensuring effective management and protection of groundwater during boring and drilling activities.
Mitigation Measures:
• Develop and adhere to a Stormwater Pollution Prevention Plan; • Avoid boring/drilling, staging and laydown areas within EPA superfund sites or areas containing known waste;
• Adhere to applicable groundwater and/or soil management plans; • Develop and implement an HDD Inadvertent Return and Contingency Plan to establish operational procedures and responsibilities for the prevention, containment, and clean-up of inadvertent returns associated with the directional drilling on the Project.
Biological Resources
Question Information and Justification
Based on review of IPaC and NOAA Fisheries database, Yes, based on review of the USFWS's Information fo are there any federally threatened or endangered 'lanning and Consultation (IPaC). Additionally species and/or critical habitat potentially occurring California state resources were inventoried to identify within the geographic range of the project area? species listed under the California Endangered Species Act.
Are there any known State or Federally, listed No
threatened or endangered species or habitat areas for
State or Federally listed species present in or
immediately adjacent to areas where work will occur?
If yes, describe how project proponent will avoid
impacts to listed species or habitat. If there are
potential impacts to federally listed species or critical habitat, PHMSA will work with the project proponent
to conduct necessary consultation with resource
agencies.
Will there be any tree clearing or removal of woody No
vegetation involved with the proposed work?
Is there any other information relevant to the project The Project will not impact areas adjacent to habitats area or the proposed work as it pertains to Biological for federally listed species. To ensure compliance with Resources? environmental regulations, construction will be scheduled outside peak wildlife seasons, low-impact
techniques like horizontal directional drilling will be used, buffer zones will be established, best
management practices for erosion control will be
NGDISM-FY23-CE-2024-04 Page | 10
implemented, an adaptive management plan will
address unforeseen issues, and post-construction
restoration with native vegetation will enhance
habitat quality.
Conclusion:
The project area is built out and is comprised of residential and commercial areas. PHMSA requested an official species list through the USFWS's IPaC website. The following species were identified as potentially occurring in the project area:
• Salt Marsh Harvest Mouse Reithrodontomys raviventris (endangered) • California Least Tern Sternula antillarum browni (endangered) • California Ridgway"s Rail Rallus obsoletus obsoletus (endangered) • Marbled Murrelet Brachyramphus marmoratus (threatened) • Western Snowy Plover Charadrius nivosus nivosus (threatened) • Yellow-billed Cuckoo Coccyzus americanus (threatened) • Green Sea Turtle Chelonia mydas (threatened)
• Northwestern Pond Turtle Actinemys marmorata (proposed threatened) • San Francisco Garter Snake Thamnophis sirtalis tetrataenia (endangered) • California Red-legged Frog Rana draytonii (endangered) • California Tiger Salamander Ambystoma californiense (endangered) • Foothill Yellow-legged Frog Rana boylii (endangered)
• Monarch Butterfly Danaus plexippus (candidate)
• California Seablite Suaeda californica (endangered)
• Fountain Thistle Cirsium fontinale var. fontinales (endangered) • Marin Dwarf-flax Hesperolinon congestum (threatened)
• San Mateo Thornmint Acanthomintha obovata ssp. Duttonii (endangered) • Showy Indian Clover Trifolium amoenum (endangered)
There was no critical habitat identified within the project area. Numerous state listed species were identified within the general geographical range but none within the ROW where work will occur. All project work will be within the right-of-way within developed areas and therefore, the immediate project area has very limited biological resources present. Therefore, in accordance with Section 7 of the Endangered Species Act PHMSA's assessment is that the project would have no effect to any of the threatened or endangered species listed above. Under Section 7(a)(4) of the Endangered Species Act (ESA), federal agencies must confer with the USFWS if their action would jeopardize the continued existence of a proposed species; therefore, PHMSA's assessment is that the project is unlikely to jeopardize the continued existence of the northwestern pond turtle. As a candidate species, the Monarch butterfly receives no statutory protection under the ESA. PHMSA's assessment is that the project would have no adverse impacts to state listed species and would not cause more than minor adverse impacts to other biological resources in the project area.
Mitigation Measures:
N/A
Cultural Resources
Question Information and Justification
NGDISM-FY23-CE-2024-04 Page 11
Please describe all ground disturbing activities The Gas Main Replacement Project 25 involves associated with the project (including pipeline various ground-disturbing activities, including pipeline installation, service line installation, gas meter installation, gas service replacement, and gas meter replacements, metering station construction or replacements. Pipeline installation will require demolition, etc.). What is the maximum depth, width excavations of approximately 4 feet by 4 feet at gas and length of excavations for each activity involving service tees and tie-in pits will vary between 5 feet by ground disturbance? 10 feet or 5 feet. Each trench will measure 2 feet in width and vary in depth from 18 inches to 60 inches,
depending on the depth at which the existing pipes
are buried. Gas meter replacements generally involve
minimal ground disturbance due to surface work.
Will ground disturbance take place entirely in existing Yes. The Gas Main Replacement Project 25 will occur ROW or utility easements? Will it be restricted entirely entirely within the existing rights-of-way (ROW). This to paved areas or will some disturbance take place in approach minimizes the impact on private and grassy, undisturbed, or natural areas? commercial properties and ensures all work complies with local regulations and standards. Also, conducting
construction activities within existing ROW helps
avoid additional permitting or easement acquisition.
The ground disturbance for the Gas Main
Replacement Project 25 will not be restricted entirely
to paved areas. While most of the work will occur
within existing rights-of-way (ROW), often paved,
some disturbance may occur in grassy or disturbed
areas when replacing gas service lines. Proper
measures will be taken to minimize environmental
impact, and restoration practices will be used to
restore disturbed areas to their original condition
after construction.
Has the entire project area (width, length and depth) Yes. The original installation or other activities been previously disturbed by the original installation previously disturbed the Gas Main Replacement or other activities? If so, provide documentation or a Project 25 area. The existing gas mains, gas service description of prior ground disturbances, such as road lines, and related infrastructure, such as gas meters, or utility cross sections, plans or as-builts. If were installed in the past, involving significant ground documentation is not available provide justification for disturbance at that time. This includes the installation how the ground was previously disturbed. of pipelines and gas meter replacements, which requires excavation in paved and unpaved areas
within the rights-of-way. Additionally, routine
maintenance and upgrades over the years may have
caused further disturbance in these areas. Therefore,
the current project will primarily occur within areas
that have already experienced some level of
disturbance due to prior installations and activities.
Does the project involve any physical impacts to No.
buildings or structures? Please provide a description of NGDISM-FY23-CE-2024-04 Page | 12
the work that may affect buildings or structures and
provide addresses and/or a map showing the
locations.
Please describe the project area and provide several The project area for the Gas Main Replacement photographs to show the character of the project area Project 25 in Palo Alto covers various residential and and surrounding properties. Is it a residential or commercial streets. This area mainly features commercial area? Are the nearby properties old or residential neighborhoods, established homes, and modern? Streetscapes and views looking down the modern constructions, with well-maintained lawns, ROW to show flanking properties are preferred. Please trees, and sidewalks lining the streets. In contrast, provide a photo key and/or captions to identify where commercial areas, particularly along Middlefield the photos were taken and what they are showing. Road, exhibit a mix of businesses, including shops and office buildings, showing historic and contemporary
architectural designs. Looking down the right-of-way
(ROW) in these areas, one can see different property
types, from older homes and new residences to
diverse business fronts.
Does the project involve construction or installation of Yes. The project involves constructing and installing any new aboveground components? If so, describe the new aboveground components, including meter components, identify their location and provide boxes and gas lids. These components include representative images of the components. replacing outdated gas meters with smart meters mounted above ground at residential and commercial
properties. These installations, including the new gas
meter boxes and gas lids on some houses and the
protection of the meters and access points, are
crucial for upgrading the gas distribution
infrastructure and ensuring safety, reliability, and
compliance with operational standards.
Are there any nearby properties or resources that Yes. The project involves areas where nearby either appear to be or are documented to have been properties are over 45 years old. Many of these constructed more than 45 years ago?" Does there residential neighborhoods feature homes constructed appear to be a group of properties of similar age, in the early to mid-20th century, showing the city's design, or method of construction? Or are there any diverse architectural history. Palo Alto's Historic designed landscapes such as a park or cemetery? Preservation Ordinance protects these properties Please provide photographs of any properties that during construction projects. These properties may be more than 45 years in age and would have the contribute to the historical fabric of the community potential to be affected by the project (such as and necessitate careful planning to avoid impacting properties that include meter replacements, service their integrity during the gas main replacement line replacements or buildings within 10 feet of the
areas proposed for pipeline main replacement under
pavement). Multiple properties may be photographed Yes, there appear to be a group of properties of together in a streetscape view and if there are many similar age, design, or method of construction. properties over 45 years in age, representative photos
may be provided of a neighborhood rather than Many homes in the project areas were built in the individual photos of each property. early to mid-20th century and share similar 11 Local tax and property records or historic maps may indicate dates of construction.
NGDISM-FY23-CE-2024-04 Page | 13
architectural styles, such as Craftsman, Colonial
Revival, and mid-century modern designs. These
neighborhoods reflect the building trends of their
time, with standard construction methods and
materials. This uniformity in age and design helps
maintain the historic and aesthetic character of the
community, which is considered during gas main
replacement projects to ensure preservation and
minimal disruption.
Yes, there are designed landscapes present in the
project area.
The project areas' neighborhoods show a mix of older
homes (over 45 years old) and modern constructions,
with architectural styles like Craftsman, Colonial
Revival, and mid-century modern designs. These
properties often have trees, well-maintained lawns,
and sidewalks. Middlefield Road and other
commercial streets blend old and new commercial
buildings, such as shops and office buildings.
Designed landscapes in the area include Mitchell
Park, a significant recreational space, and other local parks that provide green spaces for the community.
There are no known cemeteries directly within the
project area.
Will project implementation require removal or Yes
disturbance of any stone or brick sidewalk, roadway,
or landscape materials or other potentially old or The project will likely require removing or disturbing unique features? Please provide a handful of various sidewalks, roadways, and landscape representative photos of the project area to show the materials, which may include old or unique features. character of the roadway and sidewalk materials in the This includes stone or brick sidewalks, asphalt or project and staging areas. Include a photo key and/or concrete roadways, and lawns across multiple streets. captions of what the photos are showing and where Efforts will be made to document existing conditions, they were taken. minimize impact, and restore any disturbed areas to their original condition after construction. This
ensures that the historical and aesthetic integrity of
the neighborhoods is preserved.
Is there any other information relevant to the project No. area or the proposed work as it pertains to Cultural
Resources?
Conclusion:
PHMSA identified properties based on available information on previously identified historic properties in the NGDISM-FY23-CE-2024-04 Page | 14
APE, including the National Register of Historic Places (NRHP) database and data received from the California Office of Historic Preservation. PHMSA also conducted research to determine if there are any previously unidentified properties within the APE that are 45 years of age or older and may be eligible for the NRHP. This research revealed no NRHP listed or eligible properties within the APE or within a half-mile.
A letter was sent on November 5, 2024, to the California State Historic Preservation Officer (SHPO) and all consulting parties outlining the Section 106 process, including a description of the undertaking, delineation and justification of the APE, identification of historic properties and an evaluation and proposed finding of effects. Based on this consultation, PHMSA proposed a finding that the Proposed Action would not adversely affect historic properties. PHMSA has requested comments on the Section 106 process, identification of historic properties, and proposed finding within 30 days of receipt of the letter. Concurrence was received from the California Office of Historic Preservation on November 6, 2024.
PHMSA also invited the following federally recognized tribes to participate in consultation by separate letter on November 5, 2024:
Amah Mutsun Tribal Band
• Amah Mutsun Tribal Band of Mission San Juan Bautista
• Costanoan Rumsen Carmel Tribe
• Indian Canyon Mutsun Band of Costanoan
• Muwekma Ohlone Tribe of the SF Bay Area
• Tamien Nation
• The Ohlone Indian Tribe
Wuksachi Indian Tribe/Eshom Valley Band
Mitigation Measures:
• lf, during project implementation, a previously undiscovered archaeological or cultural resource that is or could reasonably be a historic property is encountered or a previously known historic property will be affected in an unanticipated manner, all project activities in the vicinity of the discovery will cease and The City of Palo Alto will immediately notify PHMSA. This may include discovery of cultural features (e.g., foundations, water wells, trash pits, etc.) and/or artifacts (e.g., pottery, stone tools and flakes, animal bones, etc.) or damage to a historic property that was not anticipated. PHMSA will notify the State Historic Preservation Office and participating federally recognized tribes and conduct consultation as appropriate in accordance with 36 CFR § 800.13. Construction in the area of the discovery must not resume until PHMSA provides further direction. The City of Palo Alto will strictly adhere to PHMSA's Unanticipated Discoveries Protocols.
• In the event that unmarked human remains are encountered during permitted activities, all work shall halt and shall immediately contact PHMSA as well as the proper authorities in accordance with applicable state statutes to determine if the discovery is subject to a criminal investigation, of Native American origin, or associated with a potential archaeological resource. At all times human remains must be treated with the utmost dignity and respect. Human remains and associated artifacts will be left in place and not disturbed. No skeletal remains or materials NGDISM-FY23-CE-2024-04 Page 15
associated with the remains will be photographed, collected, or removed until PHMSA has conducted the appropriate consultation and developed a plan of action. Project activities shall not resume until PHMSA provides further direction.
• All work, material, equipment, and staging to remain within the road's existing right-of-way or utility easement or other staging areas as identified in the environmental documentation. If the scope of work changes in any way that may alter the effects to historic properties as described herein, the grant recipient must notify PHMSA, and consultation may be reopened under Section 106.
Section 4(f)
Question Information and Justification
Are there Section 4(f) properties within or immediately Yes. There are several Section 4(f) properties in the adjacent to the project area? 4(f) properties include project's vicinity, which include publicly owned parks, publicly owned parks, recreational areas, wildlife or recreational areas, and historic sites. Notable parks in waterfowl refuges, and historic sites. If yes, provide a general vicinity include Ramos Park, Mitchell Park, list of properties and/or a map of 4(f) properties as an Eleanor Pardee Park, and Rinconada Park. attachment. Additionally, the area includes historic districts like the Professorville Historic District and the Ramona
Street Architectural District, along with various
individual historic properties listed in Palo Alto's
Historic Inventory.
Will any construction activities temporarily impact use No. of the park including but not limited to access to any
portion of the park, parking lots, trails, recreational fields, etc.?
Will any construction activities occur within the No.
property boundaries of a Section 4(f) property? If so,
please detail these activities and indicate if these are temporary or permanent uses of the Section 4(f)
property.
Is there any other information relevant to the project There will be no excavation or installation work within area or the proposed work as it pertains to Section the parks and there will be no impacts to ingress or 4(f)? egress as access to the parks will remain open and unencumbered. There could be minor disruptions to
traffic in the general areas of the parks and increased noise levels resulting from construction activities.
Conclusion:
Section 4(f) of the US Department of Transportation (USDOT) Act of 1966 as amended (Section 4(f)) (49 U.S.C. § 303(c)); is a federal law that applies to transportation projects that require funding or other approvals by the USDOT. Section 4(f) prohibits the Secretary of Transportation from approving any program or project which requires the use of any publicly owned land from a public park, recreation area, or wildlife and waterfowl refuge NGDISM-FY23-CE-2024-04 Page | 16
of national, state, or local significance, or any land from an historic site of national, state, or local significance unless:
• There is no feasible and prudent alternative to the use of the land; The program or project includes all possible planning to minimize harm to such park, recreational area; wildlife and waterfowl refuge, or historic site, resulting from such use.
PHMSA conducted a review of properties that are located within the Project Area to identify properties that qualify as Section 4(f). While there are several public parks in the general vicinity where the work would occur, no work will occur within any public park and ingress and egress will remain unencumbered.
Mitigation Measures:
• The City of Palo Alto shall ensure that full public access to, and use of all adjacent public parks is maintained during construction.
• Ensure construction activities do not interfere with public access to and/or use of public recreational facilities during construction.
Land Use and Transportation
Question Information and Justification
Will the full extent of the project boundaries remain Yes, all work on mains would take place within the within the existing right-of-way or easements? If no, existing ROW. please describe any right-of-way acquisitions or
additional easements needed.
Will the project result in detours, transportation Yes. Any work that may lead to detours, restrictions, or other impacts to normal traffic flow or transportation restrictions, or disruptions to normal to existing transportation facilities during traffic flow will adhere to the standards of the City of construction? How long are construction activities Palo Alto's Transportation Department. Necessary estimated to last? guidelines and permits will be secured before commencing work, and no permanent changes to
transportation facilities will occur.
379 working days.
Will there be any permanent change to existing No.
transportation facilities? If so, what are the changes, and how would the changes affect the public?
Will the project interrupt or impede emergency No, the project would not interrupt or impede response services from fire, police, ambulance or any emergency response services. other emergency or safety response providers? If so,
describe any coordination that will occur with
emergency response providers? How long will service
interruptions last, if applicable.
NGDISM-FY23-CE-2024-04 Page | 17
Is there any other information relevant to the project NO. area or the proposed work as it pertains to Land Use
and Transportation?
Conclusion:
The project is replacing/upgrading the existing pipe and would not include new pipeline to serve any additional areas. During construction, there may be short-term impacts to adjacent residences, businesses and normal traffic patterns. Potential impacts include an increase in noise, dust, and transportation accessibility, as a result of construction and construction staging. Staging will be on paved surfaces. The City of Palo Alto normally allows the contractor to store up to four pieces of equipment and backfill material for each week on paved City street ROW such as parking spots during active construction. Staging will move with the project. The City of Palo Alto will ensure that traffic flows are maintained to the greatest extent possible and traffic control measures will be used to assist traffic through construction areas as needed. Coordination with state and local agencies regarding detours and routing adjustments will occur, and potentially impacted residents and business owners will be notified. A traffic control plan will be in place before construction, and the City of Palo Alto, or their designated contractors will coordinate with the appropriate agency well before any impacts to emergency services or essential agency functions. Additionally, all areas will be restored to pre- construction conditions. There will be no permanent changes to land use.
Mitigation Measures:
• Restore all Impacted areas to pre-construction conditions; • Maintain traffic flows to the extent possible
• Use traffic control measures to assist traffic negotiating through construction areas, as needed.
• Coordinate with state and local agencies regarding detours and/or routing adjustments during construction
• Notify potentially impacted residents and/or business owners (access, parking, etc.) • Have a traffic control plan in place, prior to construction, and coordinate with the appropriate agency well in advance of any impacted emergency services or essential agency functions.
Noise and Vibration
Question Information and Justification
Will the project construction occur for longer than a Yes. month at a single project location?
Will the project location be in proximity (less than 50- Yes. The project is in close proximity to various ft.) to noise sensitive receivers (residences, schools, sensitive noise receptors. houses of worship, etc.)? If so, what measures will be
taken to reduce noise and vibration impacts to No high-noise or high-vibration machinery will be sensitive receptors? used for construction. The City of Palo Alto will conduct public outreach to inform residents or
business owners about the schedule of nearby
construction work. Additionally, the Contractor will
NGDISM-FY23-CE-2024-04 Page 18
comply with all local noise ordinances to minimize
impacts on nearby residential or commercial
properties.
Will the project require high-noise and vibration No.
inducing construction methods? If so, please specify.
Will the project comply with state and local Yes. The City of Palo Alto's noise ordinance aims to ordinances? If so, identify applicable ordinances and protect the peace, health, safety, and welfare of its limitations on noise/vibration times or sound levels. residents by regulating excessive, unnecessary, and unreasonable noises from various sources. According
to Chapter 9.10 of the Palo Alto Municipal Code,
noise limits are set for different types of properties:
Residential Property Noise Limits stipulate that noise
levels must not exceed 55 decibels (dBA) during
daytime hours (7:00 AM to 10:00 PM) and 50 dBA
during nighttime hours (10:00 PM to 7:00 AM).
Commercial and Industrial Property Noise Limits
require noise levels not exceeding 70 dBA during
daytime hours (7:00 AM to 10:00 PM) and 65 dBA
during nighttime (10:00 PM to 7:00 AM). Public
Property Noise Limits specify that noise levels must
not exceed 70 dBA at 25 feet from the source during
daytime (8:00 AM to 8:00 PM on weekdays and 9:00
AM to 8:00 PM on weekends). Additionally, any
construction activities must comply with these noise
limits, and high-noise machinery is restricted during
specific hours to minimize disturbances to nearby
residents and businesses. Exceptions can be granted
through special permits if necessary.
Will construction activities require large bulldozers, No. hoe ram, or other vibratory equipment within 20 ft of
a structure?
Is there any other information relevant to the project The City of Palo Alto will adhere to the City's noise area or the proposed work as it pertains to Noise and ordinance by limiting construction activities to regular Vibration? weekday hours when noise restrictions are not in effect.
Conclusion:
The project is located in residential neighborhoods and other areas with commercial buildings, such as shops and office buildings. The ambient noise consists of a combination of environmental noise from road traffic, construction, industry, the built environment, population density and other sources. The pipeline replacement project would result in temporary construction noise impacts; however, no vibration impact should occur.
Construction for the project is anticipated to last 10-14 months. The City of Palo Alto will adhere to the City's NGDISM-FY23-CE-2024-04 Page | 19
noise ordinance by limiting construction activities to regular weekday hours when noise restrictions are not in effect.
Mitigation Measures:
Adhere to all local, city and/or state noise regulations.
Environmental Justice
Question Information and Justification
Using the EPA EJScreen or census data12, is the project Based on review of socioeconomic data using the located in an area of minority and/or low-income EPAs EJScreen, the population residing within the individuals as defined by USDOT Order 5610.2(c)? general project area contains 10% low income and 58% minority populations. The percentage of these
populations is below the Santa Clara County average
of 16% low income and 71% minority populations.
Will the project displace existing residents or workers No from their homes and communities? If so, what is the
expected duration?
Will the project require service disruptions to homes Yes. Residents or business owners are expected to and communities? If so, what is the expected experience a brief service interruption during the gas communication and outreach plan to the residents service transfer. Customers affected by this and the duration of the outages? interruption will be notified in advance. Notification letters and the City of Palo website will be used to
inform residents about the temporary disruption.
Are there populations with Limited English Proficiency According to EJScreen, 6% of households speak located in the project area? If so, what measures will limited English. be taken to provide communications in other
languages?
Is there any other information relevant to the project The City of Palo Alto will issue advance public area or the proposed work as it pertains to notifications through letters and its website regarding Environmental Justice? service disruptions and construction schedules to all affected properties, including nearby residents and
businesses.
Conclusion:
Executive Order (E.O.) 14096—"Revitalizing Our Nation's Commitment to Environmental Justice for AlI" was enacted on April 21, 2023. E.O. 14096 on environmental justice does not rescind E.O. 12898 - "Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations," which has been in effect since February 11, 1994 and is currently implemented through DOT Order 5610.2C. This implementation will continue until further guidance is provided regarding the implementation of the new E.O. 14096 on environmental justice.
12 https://www.census.gov/quickfacts/fact/table/US/PST045222 NGDISM-FY23-CE-2024-04 Page | 20
The Proposed Action alternative would result in an overall reduction in GHG emissions. Construction activities would result in minor temporary air quality impacts, including the intentional venting of existing distribution lines prior to replacement. Noise impacts associated with construction are anticipated to be minor. Traffic impacts would be temporary and only minor disruptions to services would occur. However, removal of leak prone pipe would reduce leaks and the potential for incidents, resulting in an increase in pipeline safety across the system while also improving operation and reliability. Therefore, consistent with Executive Order 12898 and DOT Order 5610.2(c), PHMSA's assessment is that the project would not result in disproportionately high and adverse effects on minority or low-income populations, or other underserved and disadvantaged communities.
Mitigation Measures:
• Provide advanced notification of service disruptions and construction schedule to all affected parties including residents and businesses adjacent to the project area. • Coordinate service disruptions and construction schedule with local community leaders and groups, as applicable.
Maintain service at temporary facilities, if appropriate.
Promote public engagement to reduce project delivery delays and public controversy. • Develop outreach plans to involve and engage all populations.
Safety
Question Information and Justification
Has a risk profile been developed to describe the Yes, as described in the Distribution Integrity condition of the current infrastructure and potential Management Program (DIMP). safety concerns?
Has a public awareness program been developed and Yes. The City of Palo Alto Utilities has developed and implemented that follows the guidance provided by the implemented a public awareness program that aligns American Petroleum Institute (API) Recommended with the guidance provided by the American Petroleum Practice (RP) 1162? Institute (API) Recommended Practice (RP) 1162. This program is designed to ensure effective communication
and public safety regarding pipeline operations and
includes measures for public outreach tailored to the
needs of the community and stakeholders.
Does the project area include pipes prone to leakage? Yes. The project area for the Gas Main Replacement Project 25 includes pipes that are prone to leakage.
Many of the existing gas pipelines, made from older
materials like steel and PVC and installed decades ago, are susceptible to leaks due to age-related corrosion
and embrittlement. Replacing these old pipelines with
new, durable MDPE pipes will significantly reduce the
risk of leaks and enhance the safety and reliability of the gas distribution system.
NGDISM-FY23-CE-2024-04 Page | 21
Will construction safety methods and procedures to Yes. The Contractor must adhere to all standard protect human health and prevent/minimize hazardous construction safety methods and procedures. materials releases during construction, including
personal protection, workplace monitoring and site-
specific health and safety plans, be utilized? If yes,
document measures and reference appropriate safety
plans.
Has an assessment of the project been performed to Yes. The City of Palo Alto's Distribution Integrity analyze the risk and benefits of implementation? Management Program (DIMP) plan includes an evaluation of risks and threats to the system's integrity.
Is there any other information relevant to the project The City of Palo Alto will implement standard area or the proposed work as it pertains to Safety? construction safety methods and procedures, conduct regular safety audits of crews working in the field,
and perform subsequent follow-up reporting as
required
The City will also ensure that DIMP procedures are
updated annually. Construction work must adhere to
industry best practices and comply with local, state,
and federal regulations, including safety requirements
and necessary inspections.
Conclusion:
The project would reduce the risk profile of existing pipeline systems prone to methane leakage and would also benefit disadvantaged rural and urban communities with the safe provision of natural gas. The project responds to the need to address the potentially unsafe condition of the natural gas distribution system of pipelines. The repair, rehabilitation, or replacement of pipelines would be constructed in accordance with industry best practices and would comply with all local, state, and federal regulations, including those for safety.
The abandonment of the existing pipeline would be conducted in accordance with PHMSA requirements found in 49 CRF 192.727 and 195.402(c)(10). These requirements include disconnecting pipelines from all sources and supplies of gas, purging all combustibles and sealing the facilities left in place. These requirements for purging and sealing abandoned pipelines would ensure that the abandoned pipelines are properly purged and cleaner and pose no risk to safety in their abandoned state. Therefore, PHMSA's assessment is that this replacement project would improve the overall safety of the existing pipeline infrastructure.
Mitigation Measures:
• Incorporate public awareness programs, as necessary
Use standard construction safety methods and procedures; • Ensure DIMP procedures are updated as necessary;
• Ensure work is constructed in accordance with industry best practices • Comply with all local, state, and federal regulations.
NGDISM-FY23-CE-2024-04 Page 22
4. Categorical Exclusion Determination
Categorical Exclusions to be Applied:
As the proposed action is repair, replacement, upgrading, rebuilding, or minor relocation of pipelines within existing rights-of-way to an existing natural gas pipeline, the following Categorical Exclusion, as listed in the DOE NEPA implementing procedures, 10 CFR 1021, adopted by PHMSA effective July 3, 202413 applies:
B5.4 Repair or Replacement of Pipelines
Repair, replacement, upgrading, rebuilding, or minor relocation of pipelines within existing rights-of- way, provided that the actions are in accordance with applicable requirements (such as Army Corps of Engineers permits under section 404 of the Clean Water Act). Pipelines may convey materials including, but not limited to, air, brine, carbon dioxide, geothermal system fluids, hydrogen gas, natural gas, nitrogen gas, oil, produced water, steam, and water.
Eligibility Criteria:
The proposed activity meets the eligibility criteria of 10 CFR 1021.410(b) because the proposed action does not have any extraordinary circumstances that might affect the significance of the environmental effects, is not connected to other actions with potentially significant impacts [40 CFR 1508.25(a)(I)], is not related to other actions with individually insignificant but cumulatively significant impacts [40 CFR 1508.27(b)(7)], and is not precluded by 40 CFR 1506.1 or 10 CFR 1021.211 concerning limitations on actions during environmental impact statement preparation.
The "Integral Elements" of 10 CFR 1021 are satisfied because the proposed action will not:
1. Threaten a violation of statutory, regulatory, or permit requirements for environment, safety, and health, including requirements of DOE and/or Executive Orders;
2. Require siting and construction or major expansion of waste storage, disposal, recovery, or treatment facilities (including incinerators), but the proposal may include categorically excluded waste storage, disposal, recovery, or treatment actions or facilities;
3. Disturb hazardous substances, pollutants, contaminants, or Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)-excluded petroleum and natural gas products that preexist in the environment such that would be uncontrolled or un-permitted releases;
4. Have the potential to cause significant impacts on environmentally sensitive resources, which includes (i) property (sites, buildings, structures, and objects) of historical, archeological, or architectural significance; (ii) federally-listed and state-listed threatened or endangered species or their habitat, federally-protected marine mammals and essential fish habitat and otherwise federally-protected species; (iii) floodplains and wetlands; (iv) federally and state designated areas (wilderness areas, national parks, national monuments, national natural landmarks, wild and scenic rivers, wildlife refuges, scenic areas, and marine sanctuaries); (v) prime or unique farmland; (vi) special sources of water (sole- source aquifers, wellhead protection areas, and other vital water resources); and (vii) tundra, coral reefs, or rain forests); or
5. Involve genetically engineered organisms, synthetic biology, governmentally designated noxious weeds, or invasive species.
13 Federal Register :: Adoption of Department of Energy Categorical Exclusion Under the National Environmental Policy Act NGDISM-FY23-CE-2024-04 Page 23
Compliance Action:
PHMSA is aware of the November 12, 2024 decision in Marin Audubon Society v. Federal Aviation Administration, No. 23-1067 (D.C. Cir. Nov. 12, 2024). To the extent that a court may conclude that the Council on Environmental Quality (CEQ) regulations implementing NEPA are not judicially enforceable or binding on this agency action, PHMSA has nonetheless elected to follow those regulations at 40 C.F.R. Parts 1500-1508, in addition to the USDOT Procedures for Considering Environmental Impacts - DOT Order 5610.1C at https://www.transportation.gov/office-policy/transportation-policy/procedures-considering-environmental- impacts-dot-order-56101c, to meet the agency's obligations under NEPA, 42 U.S.C. §§ 4321 et seq.
The proposed action satisfies the DOE NEPA eligibility criteria and integral elements, does not pose extraordinary circumstances, or includes conditions that must be implemented to ensure significant effects are avoided, and meets the requirements for the CE referenced above. Based on my review of the proposed action, I have determined that the proposed action fits within the specified categorical exclusion, the other regulatory requirements set forth above are met, and the proposed action is hereby categorically excluded from further NEPA review.
Digitally signed by SHELBY
MATTHEW FULLER
MATTHEW
Date: 2024.12.12 11:10:28
FULLER -05'00'
NGDISM-FY23-CE-2024-04 Page 24
Project Area Map
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Project Area
Name: Palo Alto Pipeline Replacement Service Layer Credits: USGS The National Map: National Boundaries Dataset, Scale: 24,000 3DEP Elevation Program, Geographic Names Information System, National Hydrography Dataset, National Land Cover Database, National Structures Dataset, Total Acreage: 85 and National Transportation Dataset; USGS Global Ecosystems; U.S. Census Palo Alto, Santa Clara County, CA Bureau TIGER/Line data; USFS Road data; Natural Earth Data; U.S. Department of State HIU; NOAA National Centers for Environmental Information