then on page 87 the report claims that the dosimeter was 60 feet from Grand Ave and centered halfway along the northern property line. This is a sloppy and inaccurate report, I requested the noise study be redone but have received absolutely no reply from the planning department. It is unacceptable that nobody in Planning would respond on what will actually be a significant noise concern. Somebody in Planning should needs to be held accountable.
Attachment D Agenda Report Page 109
described as right in front of Shell as LT-2 is accurately described as, “… in front of the home at 12 Wildwood.”
Attachment D Agenda Report Page 110
Here we see one of the two noise dosimeters- both were aimed directly at Grand Avenue with the intention of capturing as much noise as possible so that they could then conclude that there would be no significant noise impact.
LT-1 was located on Grand Ave and aimed right at the intersection with Wildwood.
Thank you for your consideration on these important issues, Mike & Bernice Gallagher
Attachment D Agenda Report Page 111
Shell
150 N Dairy Ashford Rd
Houston, TX 77079
United States
Website: www.shell.com
Delivered Via Email
City Council
City of Piedmont
120 Vista Avenue
Piedmont, CA 94611
Re: 29 Wildwood Avenue, EV Charging Station
Conditional Use Permit CUP2023-001
Non-Residential Sign Permit SIGN2023-001
Design Review Permit DRPC2023-025
Variance VAR2024-002
November 14, 2024
Dear Mayor Cavenaugh and Councilmembers,
We are writing in advance of the November 18, 2024, City Council meeting, at which you will have the opportunity to consider the above-referenced applications related to the proposed conversion of a longstanding gas station and auto repair shop to an EV charging station (the “Project”) at 29 Wildwood Avenue (the “Property”).
At the October 28, 2024, Planning Commission meeting, Planning Department staff presented a draft resolution for approval of the Project with 24-hour operations, and explained that with conditions, the applications meet all of the applicable criteria for approval. The Planning Commission then voted to recommend approval of the Project, with a reduction in hours from 24 hours a day to 6am-10pm daily.
At the Planning Commission hearing, all Commissioners present voted in favor of the Project; the only “no” vote was reflected concerns thatrestricting the hours of operation at the site would be a missed opportunity to encourage more residents to convert to electric vehicles. We agree.
Our goal with all our assets is to be a valued member of the community. The Shell group of companies run 24-hour operations of varying sizes and complexity throughout the world and are willing to take actions to help alleviate our neighbors’ concerns (such as the dimmable lighting discussed below).
Attachment E Agenda Report Page 112
That said, we are submitting this letter to address the Planning Commission’s recommendation of restricted hours, and request that you approve the Project with 24-hour operations, as proposed.
A. Project Overview and Benefits
The Project will replace a long-standing gas station and auto-repair shop with a 14-stall EV charging station. The Project should be approved for the following reasons:
• The Project will beautify a property at the gateway to the City of Piedmont, adding 9,000 square feet of native plant landscaping, appropriate signage, and dimmable lighting. • The existing Shell gas station and auto shop had occupied the site for almost 100 years and closed in 2023.
• The Project will reactivate the site with a use similar to the one that operated there for the last 100 years and will make several significant physical improvements, including canopies for shade and weather protection, new fencing, focused exterior lighting, new signage, and native plant landscaping.
• Currently, the location is vacant and unpopulated at a night. • A 24-hour station will provide a fast EV charging location that will help ease range anxiety for those considering purchasing an electric vehicle, which may in turn assist with the City’s stated goals of encouraging EV adoption
B. Shell is Experienced with 24-Hour Operations and will Implement a 24-Hour Monitoring System at the Site.
1. Shell’s Joint Venture has over 70 retail internal combustion engine fueling locations with 24-Hour Operations in the Bay Area alone
Shell Recharge has 13 standalone EV charging station sites in development across the country, all of which are proposed for 24/7 operation, including one across the Bay on a similar residentialadjacent site on 19th Avenue in San Francisco.
Although these EV development sites are not yet operational, Additionally, there are numerous third party-operated Shell-branded gas stations open for self-service use 24 hours a day across the Bay Area (although portions of these sites, such as service bays or the convenience store may close earlier. Of these Shell-branded gas stations, we identified over 35 sites that are in or adjacent to residential Attachment E Agenda Report Page 113
properties in communities such as Berkeley, Daly City, Mountain View, San Francisco, San Mateo, San Jose, and Sunnyvale among others.
2. 24-Hour Monitoring
The operations team is currently working with its third-party security camera provider to create an alert management response system.
Once in place, the system will allow alerts to be triggered by events (potentially including a vehicle parked at the site for an extended period, people on-site for an extended period, debris blocking access to part of the site, or vandalism. Alerts will be received by Shell’s operations team or security vendor and may be escalated externally. Additionally, security camera footage will be stored in the cloud, providing the ability to review past footage to determine the cause of any security events and/or site operations issues.
This site is anticipated to be a part of that monitored network, subject to the finalization of our security contracts and protocols. As negotiations progress, we are happy to discuss.
Additionally, signage at the Property will provide the number to a 24/7 customer support hotline and will advise customers or passersby to call 911 in the event of an emergency.
C. 24-Hour Operations are Appropriate and Beneficial for this Site 24-hour operations will provide a convenient location for Piedmont residents and workers to charge during early morning or late-night hours. The Project will provide a convenient location for residents and workers coming in and out of the city to charge their vehicles when in-home charging is either not an option or not fast enough. This could include those with non-traditional work hours, people traveling to deal with nighttime emergencies, or people traveling to and from the airport.
The proposed EV charging station is similar to other Piedmont uses that operate 24 hours a day, like gas stations and ATMs. It is common for self-service uses like gas stations, EV charging stations, and ATMs to operate 24-hours a day, and the City Code does not impose hours of operations restrictions on these types of businesses. In fact, in 2009, this City Council approved a Conditional Use Permit to allow 24/7 use of the gas pumps at 340 Highland Avenue for credit card use. (See City Council Resolution No. 25-09.)
There will be no accessory uses that will encourage lingering at the Property. Similar to gasoline pumps found even in the Piedmont area that allow for overnight self-service, the proposed EV charging station will not include a market or vending machines —i.e., nothing on site is anticipated to encourage Attachment E Agenda Report Page 114
people to stay longer than it takes to complete a charge. To help discourage drivers from staying at the site longer than the charging session, idles fees will be incurred if drivers remain plugged in after the vehicle is finished charging.
24-hour activation means lighting at night. By activating the site overnight, the proposed use will provide lighting at night.
There were no hours restrictions on the prior longstanding gas station. The Property has been operated as a Shell gas station since 1928, long before Piedmont’s Zoning Ordinance was enacted. This means that the existing gas station was not subject to any entitlements that imposed hours of operations conditions. The proposed EV charging use is essentially a continuation of a nearly 100-year old use and should not be subject to significant new operational restrictions.
The proposed EV charging use will generate less operational noise than the prior gas station. For one, the removal of the auto repair shop, which involves the use of power tools and vehicle lifts, will further reduce operational noise at the Property.
The recommended conditions of approval require limiting equipment noise to acceptable levels.
The proposed conditions of approval require that equipment-related noise at the property line be kept to a maximum of 50 dBA, consistent with Building Code Section 8.02.020 EE. Noise testing of the equipment must be completed prior to a final inspection of the site, and any necessary “modifications in order to meet the sound requirements including a sound barrier or an enclosure, are subject to staff review and approval.”
The eight-foot-tall solid wall recommended as a condition of approval and focused lighting will minimize potential impacts on nearby residents. The project will include a boundary wall along the north side of the Property to limit potential disruption to the neighbors. The lighting will be dimmable at night and focused downward to prevent light overflow to the surrounding streets.
D. Conclusion
We believe that a 24-hour EV charging location will provide a convenient EV charging hub that will make more convenient for residents to charge their electric vehicles away from home. Shell Recharge is committed to being a respectful neighbor and will implement a monitoring system at the Property. The same approval for internal combustion engines allowing for 24/7 hrs for fuel dispensing in the 2009 CUP for the Highland Ave fuelling station should similarly be provided for electric vehicle charging at our facility. Accordingly, and for the reasons outlined herein, we respectfully request that you approve the Project for 24-hour a day operation.
Attachment E Agenda Report Page 115
Please do not hesitate to contact me with any additional questions. Thank you.
Yours sincerely,
Lydell Lauro
Shell Recharge
cc:
Vice Mayor Betsy Smegal Andersen
Councilmember Jennifer Long
Councilmember Conna McCarthy
Councilmember Tom Ramsey
Attachment E Agenda Report Page 116