Agenda — Richmond City Council, May 16, 2023 (part 6 of 11)

Official Species List
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06/14/2022 1
Official Species List
This list is provided pursuant to Section 7 of the Endangered Species Act, and fulfills the requirement for Federal agencies to "request of the Secretary of the Interior information whether any species which is listed or proposed to be listed may be present in the area of a proposed action".

This species list is provided by:

Sacramento Fish And Wildlife Office
Federal Building
2800 Cottage Way, Room W-2605
Sacramento, CA 95825-1846
(916) 414-6600
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06/14/2022 2
Project Summary
Project Code: 2022-0054185
Event Code: None
Project Name: Raven SR Bioenergy Project
Project Type: Commercial Development
Project Description: The proposed Raven SR Bioenergy Project (project) proposes to construct and operate a bioenergy system composed of the Raven SR multi-patented Steam/CO2 Reformation process at the project site. The non-combustible process would convert blended green waste and food waste obtained from the existing BMPC operation adjacent to the project site into renewable, transportation grade hydrogen that would be exported offsite for various renewable energy products. No hydrogen storage would occur onsite. The project would involve the erection of a modular structure and industrial canopy and would not add vehicle trips or other substantial traffic to the property.

Project Location:

Approximate location of the project can be viewed in Google Maps: https:// www.google.com/maps/@37.967288499999995,-122.38296104113344,14z Counties: Contra Costa County, California
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06/14/2022 3

1. Endangered Species Act Species
There is a total of 14 threatened, endangered, or candidate species on this species list.

Species on this list should be considered in an effects analysis for your project and could include species that exist in another geographic area. For example, certain fish may appear on the species list because a project could affect downstream species.

IPaC does not display listed species or critical habitats under the sole jurisdiction of NOAA Fisheries , as USFWS does not have the authority to speak on behalf of NOAA and the Department of Commerce.

See the "Critical habitats" section below for those critical habitats that lie wholly or partially within your project area under this office's jurisdiction. Please contact the designated FWS office if you have questions.

NOAA Fisheries, also known as the National Marine Fisheries Service (NMFS), is an office of the National Oceanic and Atmospheric Administration within the Department of Commerce.

Mammals

NAME STATUS
Salt Marsh Harvest Mouse Reithrodontomys raviventris
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/613
Endangered
Birds

NAME STATUS
California Clapper Rail Rallus longirostris obsoletus
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/4240
Endangered
California Least Tern Sterna antillarum browni
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/8104
Endangered
Western Snowy Plover Charadrius nivosus nivosus
Population: Pacific Coast population DPS-U.S.A. (CA, OR, WA), Mexico (within 50 miles of Pacific coast)
There is final critical habitat for this species. The location of the critical habitat is not available.

Species profile: https://ecos.fws.gov/ecp/species/8035
Threatened
1 1131
06/14/2022 4
Reptiles

NAME STATUS
Green Sea Turtle Chelonia mydas
Population: East Pacific DPS
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/6199
Threatened
Amphibians

NAME STATUS
California Red-legged Frog Rana draytonii
There is final critical habitat for this species. The location of the critical habitat is not available.

Species profile: https://ecos.fws.gov/ecp/species/2891
Threatened
Fishes

NAME STATUS
Delta Smelt Hypomesus transpacificus
There is final critical habitat for this species. The location of the critical habitat is not available.

Species profile: https://ecos.fws.gov/ecp/species/321
Threatened
Tidewater Goby Eucyclogobius newberryi
There is final critical habitat for this species. The location of the critical habitat is not available.

Species profile: https://ecos.fws.gov/ecp/species/57
Endangered
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06/14/2022 5
Flowering Plants

NAME STATUS
Marin Dwarf-flax Hesperolinon congestum
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/5363
Threatened
Showy Indian Clover Trifolium amoenum
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/6459
Endangered
Tiburon Jewelflower Streptanthus niger
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/4187
Endangered
Tiburon Mariposa Lily Calochortus tiburonensis
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/2858
Threatened
Tiburon Paintbrush Castilleja affinis ssp. neglecta
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/2687
Endangered
White-rayed Pentachaeta Pentachaeta bellidiflora
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/7782
Endangered
Critical habitats

THERE ARE NO CRITICAL HABITATS WITHIN YOUR PROJECT AREA UNDER THIS OFFICE'S JURISDICTION.
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06/14/2022 6
IPaC User Contact Information
Agency: Environmental Science Associates
Name: Sharon Dulava
Address: 787 The Alameda
Address Line 2: Suite 250
City: San Jose
State: CA
Zip: 95126
Email [email protected]
Phone: 9252859473
1134
Species Element Code Federal Status State Status Global Rank State Rank Rare Plant
Rank/CDFW
SSC or FP
Accipiter cooperii
Cooper's hawk
ABNKC12040 None None G5 S4 WL
Acipenser medirostris pop. 1
green sturgeon - southern DPS
AFCAA01031 Threatened None G2T1 S1
Antrozous pallidus
pallid bat
AMACC10010 None None G4 S3 SSC
Ardea alba
great egret
ABNGA04040 None None G5 S4
Asio flammeus
short-eared owl
ABNSB13040 None None G5 S3 SSC
Astragalus tener var. tener
alkali milk-vetch
PDFAB0F8R1 None None G2T1 S1 1B.2
Athene cunicularia
burrowing owl
ABNSB10010 None None G4 S3 SSC
Bombus caliginosus
obscure bumble bee
IIHYM24380 None None G2G3 S1S2
Bombus occidentalis
western bumble bee
IIHYM24250 None None G2G3 S1
Calystegia purpurata ssp. saxicola
coastal bluff morning-glory
PDCON040D2 None None G4T2T3 S2S3 1B.2
Chloropyron maritimum ssp. palustre
Point Reyes salty bird's-beak
PDSCR0J0C3 None None G4?T2 S2 1B.2
Chloropyron molle ssp. molle
soft salty bird's-beak
PDSCR0J0D2 Endangered Rare G2T1 S1 1B.2
Circus hudsonius
northern harrier
ABNKC11011 None None G5 S3 SSC
Danaus plexippus pop. 1
monarch - California overwintering population
IILEPP2012 Candidate None G4T2T3 S2S3
Dirca occidentalis
western leatherwood
PDTHY03010 None None G2 S2 1B.2
Egretta thula
snowy egret
ABNGA06030 None None G5 S4
Elanus leucurus
white-tailed kite
ABNKC06010 None None G5 S3S4 FP
Emys marmorata
western pond turtle
ARAAD02030 None None G3G4 S3 SSC
Fritillaria liliacea
fragrant fritillary
PMLIL0V0C0 None None G2 S2 1B.2
Helminthoglypta nickliniana bridgesi
Bridges' coast range shoulderband
IMGASC2362 None None G3T1 S1S2
BIOS selection
Raven SR Bioenergy Project Initial Study: 5 Mile Study Area Query Criteria:

Report Printed on Tuesday, June 14, 2022
Commercial Version -- Dated June, 3 2022 -- Biogeographic Data Branch Page 1 of 3 Information Expires 12/3/2022
Selected Elements by Scientific Name
California Department of Fish and Wildlife
California Natural Diversity Database
1135
Species Element Code Federal Status State Status Global Rank State Rank Rare Plant
Rank/CDFW
SSC or FP
Hoita strobilina
Loma Prieta hoita
PDFAB5Z030 None None G2? S2? 1B.1
Holocarpha macradenia
Santa Cruz tarplant
PDAST4X020 Threatened Endangered G1 S1 1B.1
Hydroprogne caspia
Caspian tern
ABNNM08020 None None G5 S4
Lasiurus cinereus
hoary bat
AMACC05030 None None G3G4 S4
Laterallus jamaicensis coturniculus
California black rail
ABNME03041 None Threatened G3T1 S1 FP
Melospiza melodia pusillula
Alameda song sparrow
ABPBXA301S None None G5T2T3 S2S3 SSC
Melospiza melodia samuelis
San Pablo song sparrow
ABPBXA301W None None G5T2 S2 SSC
Microtus californicus sanpabloensis
San Pablo vole
AMAFF11034 None None G5T1T2 S1S2 SSC
Nannopterum auritum
double-crested cormorant
ABNFD01020 None None G5 S4 WL
Northern Coastal Salt Marsh
Northern Coastal Salt Marsh
CTT52110CA None None G3 S3.2
Nycticorax nycticorax
black-crowned night heron
ABNGA11010 None None G5 S4
Pandion haliaetus
osprey
ABNKC01010 None None G5 S4 WL
Rallus obsoletus obsoletus
California Ridgway's rail
ABNME05011 Endangered Endangered G3T1 S1 FP
Rana draytonii
California red-legged frog
AAABH01022 Threatened None G2G3 S2S3 SSC
Reithrodontomys raviventris
salt-marsh harvest mouse
AMAFF02040 Endangered Endangered G1G2 S1S2 FP
Sorex vagrans halicoetes
salt-marsh wandering shrew
AMABA01071 None None G5T1 S1 SSC
Spergularia macrotheca var. longistyla
long-styled sand-spurrey
PDCAR0W062 None None G5T2 S2 1B.2
Spirinchus thaleichthys
longfin smelt
AFCHB03010 Candidate Threatened G5 S1
Symphyotrichum lentum
Suisun Marsh aster
PDASTE8470 None None G2 S2 1B.2
Thaleichthys pacificus
eulachon
AFCHB04010 Threatened None G5 S2
Trifolium hydrophilum
saline clover
PDFAB400R5 None None G2 S2 1B.2
Report Printed on Tuesday, June 14, 2022
Commercial Version -- Dated June, 3 2022 -- Biogeographic Data Branch Page 2 of 3 Information Expires 12/3/2022
Selected Elements by Scientific Name
California Department of Fish and Wildlife
California Natural Diversity Database
1136
Species Element Code Federal Status State Status Global Rank State Rank Rare Plant
Rank/CDFW
SSC or FP
Tryonia imitator
mimic tryonia (=California brackishwater snail)
IMGASJ7040 None None G2 S2
Valley Needlegrass Grassland
Valley Needlegrass Grassland
CTT42110CA None None G3 S3.1
Xanthocephalus xanthocephalus
yellow-headed blackbird
ABPBXB3010 None None G5 S3 SSC
Record Count: 44
Report Printed on Tuesday, June 14, 2022
Commercial Version -- Dated June, 3 2022 -- Biogeographic Data Branch Page 3 of 3 Information Expires 12/3/2022
Selected Elements by Scientific Name
California Department of Fish and Wildlife
California Natural Diversity Database
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6/14/22, 3:26 PM CNPS Rare Plant Inventory | Search Results https://rareplants.cnps.org/Search/result?frm=T&sl=1&quad=3712284:3712283:3812214:3812213: 1/5 Search Results
CNPS Rare Plant Inventory
45 matches found. Click on scientific name for details
Search Criteria: Quad is one of [3712284:3712283:3812214:3812213] ▲ SCIENTIFIC

NAME COMMON NAME FAMILY LIFEFORM

BLOOMING
PERIOD
FED
LIST
STATE
LIST
GLOBAL
RANK
STATE
RANK
CA
RARE
PLANT

RANK PHOTO
Amorpha
californica var.
napensis
Napa false
indigo
Fabaceae perennial
deciduous
shrub
Apr-Jul None None G4T2 S2 1B.2
© 2016 John
Doyen
Amsinckia lunaris bent-flowered
fiddleneck
Boraginaceae annual herb Mar-Jun None None G3 S3 1B.2
© 2011 Neal
Kramer
Arabis
blepharophylla
coast
rockcress
Brassicaceae perennial herb Feb-May None None G4 S4 4.3 © 2011 Neal
Kramer
Arctostaphylos
pallida
pallid
manzanita
Ericaceae perennial
evergreen shrub
Dec-Mar FT CE G1 S1 1B.1
No Photo
Available
Aspidotis carlottahalliaeCarlotta Hall's
lace fern
Pteridaceae perennial
rhizomatous
herb
Jan-Dec None None G3 S3 4.2
No Photo
Available
Astragalus tener
var. tener
alkali milkvetchFabaceae annual herb Mar-Jun None None G2T1 S1 1B.2 No Photo
Available
Calamagrostis
ophitidis
serpentine reed
grass
Poaceae perennial herb Apr-Jul None None G3 S3 4.3
No Photo
Available
Calochortus
tiburonensis
Tiburon
mariposa-lily
Liliaceae perennial
bulbiferous herb
Mar-Jun FT CT G1 S1 1B.1
No Photo
Available
Calochortus
umbellatus
Oakland startulipLiliaceae perennial
bulbiferous herb
Mar-May None None G3? S3? 4.2
No Photo
Available
Calystegia
purpurata ssp.
saxicola
coastal bluff
morning-glory
Convolvulaceae perennial herb (Mar)AprSepNone None G4T2T3 S2S3 1B.2 No Photo
Available
Castilleja affinis
var. neglecta
Tiburon
paintbrush
Orobanchaceae perennial herb
(hemiparasitic)
Apr-Jun FE CT G4G5T1T2 S1S2 1B.2
No Photo
1139 A il bl
6/14/22, 3:26 PM CNPS Rare Plant Inventory | Search Results https://rareplants.cnps.org/Search/result?frm=T&sl=1&quad=3712284:3712283:3812214:3812213: 2/5 Available
Castilleja ambigua
var. ambigua
johnny-nip Orobanchaceae annual herb
(hemiparasitic)
Mar-Aug None None G4T4 S3S4 4.2
©2011 Dylan
Neubauer
Chloropyron
maritimum ssp.
palustre
Point Reyes
salty bird'sbeak
Orobanchaceae annual herb
(hemiparasitic)
Jun-Oct None None G4?T2 S2 1B.2
©2017 John
Doyen
Chloropyron molle
ssp. molle
soft salty
bird's-beak
Orobanchaceae annual herb
(hemiparasitic)
Jun-Nov FE CR G2T1 S1 1B.2
No Photo
Available
Collomia
diversifolia
serpentine
collomia
Polemoniaceae annual herb May-Jun None None G4 S4 4.3
©2019 Zoya
Akulova
Dirca occidentalis western
leatherwood
Thymelaeaceae perennial
deciduous
shrub
JanMar(Apr)None None G2 S2 1B.2
© 2017
Steve
Matson
Eleocharis parvula small
spikerush
Cyperaceae perennial herb (Apr)JunAug(Sep)None None G5 S3 4.3 ©2018 Ron
Vanderhoff
Eriogonum
luteolum var.
caninum
Tiburon
buckwheat
Polygonaceae annual herb May-Sep None None G5T2 S2 1B.2 No Photo
Available
Erythranthe
laciniata
cut-leaved
monkeyflower
Phrymaceae annual herb Apr-Jul None None G4 S4 4.3
© 2017
Steven Perry
Erythranthe
nudata
bare
monkeyflower
Phrymaceae annual herb May-Jun None None G4 S4 4.3
John Doyen
2015
Fritillaria liliacea fragrant
fritillary
Liliaceae perennial
bulbiferous herb
Feb-Apr None None G2 S2 1B.2
© 2004
Carol W.

Witham
Helianthella
castanea
Diablo
helianthella
Asteraceae perennial herb Mar-Jun None None G2 S2 1B.2
1140
6/14/22, 3:26 PM CNPS Rare Plant Inventory | Search Results https://rareplants.cnps.org/Search/result?frm=T&sl=1&quad=3712284:3712283:3812214:3812213: 3/5 © 2013
Christopher
Bronny
Hesperolinon
congestum
Marin western
flax
Linaceae annual herb Apr-Jul FT CT G1 S1 1B.1
© 2009 Neal
Kramer
Hoita strobilina Loma Prieta
hoita
Fabaceae perennial herb MayJul(AugOct)None None G2? S2? 1B.1 © 2004
Janell
Hillman
Holocarpha
macradenia
Santa Cruz
tarplant
Asteraceae annual herb Jun-Oct FT CE G1 S1 1B.1
© 2011
Dylan
Neubauer
Iris longipetala coast iris Iridaceae perennial
rhizomatous
herb
MarMay(Jun)None None G3 S3 4.2
© 2014
Aaron
Schusteff
Isocoma arguta Carquinez
goldenbush
Asteraceae perennial shrub Aug-Dec None None G1 S1 1B.1 No Photo
Available
Lathyrus jepsonii
var. jepsonii
Delta tule pea Fabaceae perennial herb MayJul(AugSep)None None G5T2 S2 1B.2 © 2003 Mark
Fogiel
Leptosiphon
acicularis
bristly
leptosiphon
Polemoniaceae annual herb Apr-Jul None None G4? S4? 4.2 © 2007 Len
Blumin
Leptosiphon
grandiflorus
large-flowered
leptosiphon
Polemoniaceae annual herb Apr-Aug None None G3G4 S3S4 4.2 © 2003
Doreen L.

Smith
Lessingia
hololeuca
woolly-headed
lessingia
Asteraceae annual herb Jun-Oct None None G2G3 S2S3 3
© 2015
Aaron
Schusteff
Lilaeopsis
masonii
Mason's
lilaeopsis
Apiaceae perennial
rhizomatous
Apr-Nov None CR G2 S2 1B.1
No Photo
1141
6/14/22, 3:26 PM CNPS Rare Plant Inventory | Search Results https://rareplants.cnps.org/Search/result?frm=T&sl=1&quad=3712284:3712283:3812214:3812213: 4/5 herb Available
Pentachaeta
bellidiflora
white-rayed
pentachaeta
Asteraceae annual herb Mar-May FE CE G1 S1 1B.1
No Photo
Available
Piperia michaelii Michael's rein
orchid
Orchidaceae perennial herb Apr-Aug None None G3 S3 4.2
No Photo
Available
Plagiobothrys
glaber
hairless
popcornflower
Boraginaceae annual herb Mar-May None None GX SX 1A
No Photo
Available
Polygonum
marinense
Marin
knotweed
Polygonaceae annual herb (Apr)MayAug(Oct)None None G2Q S2 3.1 No Photo
Available
Ranunculus lobbii Lobb's aquatic
buttercup
Ranunculaceae annual herb
(aquatic)
Feb-May None None G4 S3 4.2
No Photo
Available
Senecio
aphanactis
chaparral
ragwort
Asteraceae annual herb JanApr(May)None None G3 S2 2B.2 No Photo
Available
Spergularia
macrotheca var.
longistyla
long-styled
sand-spurrey
Caryophyllaceae perennial herb Feb-May None None G5T2 S2 1B.2 No Photo
Available
Streptanthus
glandulosus ssp.
niger
Tiburon
jewelflower
Brassicaceae annual herb May-Jun FE CE G4T1 S1 1B.1
No Photo
Available
Suaeda
californica
California
seablite
Chenopodiaceae perennial
evergreen shrub
Jul-Oct FE None G1 S1 1B.1
No Photo
Available
Symphyotrichum
lentum
Suisun Marsh
aster
Asteraceae perennial
rhizomatous
herb
(Apr)MayNovNone None G2 S2 1B.2
No Photo
Available
Trifolium
amoenum
two-fork clover Fabaceae annual herb Apr-Jun FE None G1 S1 1B.1 No Photo
Available
Trifolium
hydrophilum
saline clover Fabaceae annual herb Apr-Jun None None G2 S2 1B.2 No Photo
Available
Triquetrella
californica
coastal
triquetrella
Pottiaceae moss None None G2 S2 1B.2
No Photo
Available
Showing 1 to 45 of 45 entries
Suggested Citation:

California Native Plant Society, Rare Plant Program. 2022. Rare Plant Inventory (online edition, v9-01 1.5). Website https://www.rareplants.cnps.org [accessed 14 June 2022].

CONTACT US ABOUT THIS WEBSITE ABOUT CNPS CONTRIBUTORS
1142
6/14/22, 3:26 PM CNPS Rare Plant Inventory | Search Results https://rareplants.cnps.org/Search/result?frm=T&sl=1&quad=3712284:3712283:3812214:3812213: 5/5 Send questions and comments
to [email protected].

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CNPS Home Page
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Copyright © 2010-2022 California Native Plant Society. All rights reserved. 1143
Raven SR Bioenergy Project C-1 ESA / D202100382
Updated Initial Study MND March 9, 2023

APPENDIX C
Updated Draft Mitigation Monitoring and
Reporting Program (MMRP)
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Raven SR Bioenergy Project C-1 ESA / D202100382
Updated Initial Study MND March 9, 2023

APPENDIX C - SECOND FINAL UPDATED MITIGATION MONITORING AND REPORTING PROGRAM Project Mitigation Measures
Implemented
By
Monitored By Monitoring and Reporting
Action
Monitoring
Schedule

4.1 Aesthetics – None Required

4.2 Agriculture and Forestry Resources – None Required

4.3 Air Quality
(Expanded) Mitigation Measure AQ-1: Best Management
Practices.1
 All subsequent projects, regardless of size,The project shall implement the following best management practices to reduce construction impacts, particularly fugitive dust, to a less-than-significant level:
 All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day, except when not required
for dust control.
 All haul trucks transporting soil, sand, or other loose material off-site shall be covered.
 All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street
sweepers at least once per day. The use of dry power
sweeping is prohibited.
 All vehicle speeds on unpaved roads shall be limited to 15 mph.
 All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.
 Idling times shall be minimized either by shutting
equipment off when not in use or reducing the maximum
idling time to 5 minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations [CCR]). Clear signage shall be provided for construction workers at all access points.  All construction equipment shall be maintained and
properly tuned in accordance with manufacturer’s
specifications. All equipment shall be checked by a
Project Applicant /
Construction
Contractor
Richmond
Building Division
and Engineering
Services
Department
Richmond Engineering Services
Department to verify inclusion of
BAAQMD BMPs in applicable
construction plans and specifications.

City of Richmond Building Division to
inspect site during construction to
ensure compliance with Project
construction plans.

Prior to issuance of
building permit.

Field inspections
during construction.

Verified by:

Date:
1 The additional bulleted items (single underlined) to Mitigation Measure AQ-1 were added as expanded mitigation at the Planning Commission. 1146
APPENDIX C - Second Final Updated Mitigation Monitoring and Reporting Program Raven SR Bioenergy Project C-2 ESA / D202100382
Updated Initial Study MND March 9, 2023
Project Mitigation Measures
Implemented
By
Monitored By Monitoring and Reporting
Action
Monitoring
Schedule
certified mechanic and determined to be running in proper condition prior to operation.
 Post a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust
complaints. This person shall respond and take corrective action within 48 hours. The Air District’s phone number shall also be visible to ensure compliance with applicable regulations.
 BMP #6: All excavation, grading, and/or demolition
activities shall be suspended when average wind speeds
exceed 20 mph.
 BMP #7: All trucks and equipment, including their tires, shall be washed off prior to leaving the site.
 BMP #8: Unpaved roads providing access to sites located 100 feet or further from a paved road shall be treated with a 6- to 12-inch layer of compacted layer of wood chips, mulch, or gravel.
 Additional BMP: Limit the simultaneous occurrence of
excavation, grading, and ground- disturbing construction activities.
 Additional BMP: Install wind breaks (e.g., trees, fences) on the windward side(s) of actively disturbed areas of
construction. Wind breaks should have at maximum 50
percent air porosity.
 Additional BMP: Plant vegetative ground cover (e.g., fastgerminating native grass seed) in disturbed areas as soon as possible and watered appropriately until vegetation is established.
 Additional BMP: Install sandbags or other erosion control measures to prevent silt runoff to public roadways from sites with a slope greater than one percent.
 Additional BMP: Minimize the amount of excavated
material or waste materials stored at the site.
 Additional BMP: Hydroseed or apply non-toxic soil
stabilizers to construction areas, including previously graded areas, that are inactive for at least 10 calendar days.
1147
APPENDIX C - Second Final Updated Mitigation Monitoring and Reporting Program Raven SR Bioenergy Project C-3 ESA / D202100382
Updated Initial Study MND March 9, 2023
Project Mitigation Measures
Implemented
By
Monitored By Monitoring and Reporting
Action
Monitoring
Schedule
 Require zero visible fugitive dust and use fence line air monitoring to demonstrate compliance with this
requirement.
 Set requirements for when dust generating operations
have to be shut down due to dust crossing the property
boundary or if dust is contained within the property
boundary but not controlled after a specified number of minutes.
 Prohibiting grading on days when a Spare the Air is in effect (https://www.sparetheair.org/) Prohibiting grading on days with an Air Quality Index forecast of greater than 100 for particulates for the project area.

4.4 Biological Resources
Mitigation Measure BIO-1: Avoid and Minimize Impacts to Nesting Birds, Except Rails.

To the extent practicable, Pproject construction activities requiring heavy equipment, or any tree trimming, shall be performed outside of the bird nesting season (February 1st through August 31st) to avoid impacts to nesting birds.

Project Applicant
/ Construction
Contractor
Qualified Biologist
Richmond
Building Division
and Planning
Division
City of Richmond Building Division to
ensure construction activities are
performed between February 1st and
August 31st.

Prior to any site
alterations or
issuance of building
permit.

Field inspections
during construction.

Verified by:

Date:

If these activities must be performed during the nesting bird season, a qualified biologist shall be retained to conduct a pre-construction survey in the project construction and staging areas for nesting birds and verify the presence or absence of nesting birds no more than 14 calendar days prior to construction activities or after any construction breaks of 14 calendar days or more. Surveys shall be performed for the project construction and staging areas and suitable habitat within 250 feet of the project construction and staging areas in order to locate any active passerine (perching bird) nests and within 500 feet of the project construction and staging areas to locate any active raptor (birds of prey) nest, including potential burrowing owl burrows.

If nesting birds and raptors do not occur within 250 and 500 feet of the Project area, respectively, then no further action is required if construction begins within 14 calendar days.

If active nests are located during the pre-construction bird nesting surveys, no-disturbance buffer zones shall be established around nests, with a buffer size established by the qualified biologist.

City of Richmond Planning Division to
receive and confirm survey report.

Field inspections
during construction.

Upon completion of
surveys.

Verified by:

Date:
1148
APPENDIX C - Second Final Updated Mitigation Monitoring and Reporting Program Raven SR Bioenergy Project C-4 ESA / D202100382
Updated Initial Study MND March 9, 2023
Project Mitigation Measures
Implemented
By
Monitored By Monitoring and Reporting
Action
Monitoring
Schedule
monitor the nest and has authority to halt construction if bird behavior indicates continued activities could lead to nest failure. Buffered zones shall be avoided during construction-related activities until young have fledged or the nest is otherwise abandoned. If active burrowing owl dens are found within the survey area, the project applicant shall implement measures at least equal to the 2012 (or subsequent applicable) CDFW Staff Report (CDFG, 2012), as determined by the qualified biologist.

Fish and Wildlife (USFWS) or the California Department of Fish and Wildlife (CDFW)), shall be avoided during the
breeding season from February 1 through August 31.

Field inspections
during construction.

Verified by:

Date:
 If areas within 500 feet of rail habitat cannot be avoided during the breeding season (February 1 through August 31),
protocol-level surveys shall be conducted to determine rail nesting locations. The surveys will focus on potential habitat that could be indirectly disturbed by construction activities during the breeding season to ensure that rails are not breeding within 500 feet of project activities.
 Survey methods for rails will follow the Site-Specific Protocol for Monitoring Marsh Birds, which was developed for use by USFWS and partners (Wood et al. 2017). Surveys are
concentrated during the approximate period of peak
detectability, January 15 to March 25 and are structured to efficiently sample an area in three rounds of surveys by broadcasting calls of target species during specific periods of each survey round. Call broadcast increase the probability of detection compared to passive surveys when no call
broadcasting is employed. This protocol has since been
adopted by Invasive Spartina Project (ISP) and Point Blue Conservation Science to survey Ridgway’s rails at sites throughout San Francisco Bay Estuary. The survey protocol for Ridgway’s rail is summarized below.
 Previously used survey locations (points) should be used when available to maintain consistency with past survey results. Adjacent points should be at least 200 meters
apart along transects in or adjacent to areas
representative of the marsh. Points should be located to Project Applicant
/ Construction
Contractor
Qualified Biologist
Richmond
Building Division
City of Richmond Building Division to
confirm surveys are conducted
pursuant to specified measures.

City of Richmond Planning Division to
receive and confirm survey report.

Field inspections
during construction.

Upon completion of
surveys.

Verified by:

Date:
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APPENDIX C - Second Final Updated Mitigation Monitoring and Reporting Program Raven SR Bioenergy Project C-5 ESA / D202100382
Updated Initial Study MND March 9, 2023
Project Mitigation Measures
Implemented
By
Monitored By Monitoring and Reporting
Action
Monitoring
Schedule
minimize disturbances to marsh vegetation. Up to 8
points can be located on a transect.
 At each transect, three surveys (rounds) are to be
conducted, with the first round of surveys initiated
between January 15 and February 6, the second round
performed February 7 to February 28, and the third round March 1 to March 25. Surveys should be spaced at least
one week apart and the period between March 25 to April 15 can be used to complete surveys delayed by logistical or weather issues. A Federal Endangered Species Act
Section 10(a)(1)(A) permit is required to conduct active surveys.
 Each point on a transect will be surveyed for 10 minutes each round. A recording of calls available from USFWS
is broadcast at each point. The recording consists of 5 minutes of silence, followed by a 30-second recording of Ridgway’s rail vocalizations, followed by 30 seconds of silence, followed by a 30-second recording of California black rail, followed by 3.5 minutes of silence.
 If no breeding Ridgway’s rails or black rails are detected during surveys, or if their breeding territories can be avoided by 500 feet (150 meters), then project activities may proceed at that location.
 If protocol surveys determine that breeding Ridgway’s rails or black rails are present in the project area, the following measures would apply to project activities conducted during their breeding season (February 1- August 31):
 The applicant shall coordinate with the USFWS- and
CDFW, as appropriate depending upon species, to
determine verify if project activities can continue during the nesting season based on nest location, natural visual barriers (e.g., levees) between the project and
marshlands, and the distance between proposed
activities and identified activity centers. If impact cannot be avoided during the rail nesting season, activities
would be delayed until after the nesting season.

Project Applicant
/ Construction
Contractor
Qualified Biologist
Richmond
Building Division
City of Richmond Building Division to
ensure construction activities are
performed between February 1st and
August 31st, based on agency
coordination per this measure.

City of Richmond Planning Division to
verify agency coordination and
outcome.

Field inspections
during construction.

Upon completion of
surveys.

Verified by:

Date:
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APPENDIX C - Second Final Updated Mitigation Monitoring and Reporting Program Raven SR Bioenergy Project C-6 ESA / D202100382
Updated Initial Study MND March 9, 2023
Project Mitigation Measures
Implemented
By
Monitored By Monitoring and Reporting
Action
Monitoring
Schedule

4.5 Cultural Resources
Mitigation Measure CUL-1a: Cultural Resources Awareness Training.

Prior to authorization to proceed, the City shall engage a qualified archaeologist, defined as an archaeologist meeting the U.S.

Secretary of the Interior’s Professional Qualification Standards for Archeology, to conduct a training program for all construction workers involved on site disturbance. On-site personnel shall attend a mandatory pre-project training that outlines the general archaeological sensitivity of the vicinity and the procedures to follow in the event an archaeological resource and/or human remains are inadvertently discovered.

Project Applicant /
Construction
Contractor
Qualified
Archaeologist
Richmond
Building Division
City of Richmond Building Division to
review and confirm documentation of
training, required personnel attending,
and scope of training.

Prior to
commencement of
any ground-disturbing
activities.

Verified by:

Date:

Mitigation Measure CUL-1b: Inadvertent Discovery of Cultural Materials or Tribal Cultural Resources.

The City shall notify a qualified archaeologist who will inspect the find within 24 hours of discovery and provide the City of an initial assessment. Pre-contact cultural materials might include obsidian and chert flaked-stone tools (e.g., projectile points, knives, scrapers) or toolmaking debris; culturally darkened soil (“midden”) containing heat-affected rocks, artifacts, or shellfish remains; stone milling equipment (e.g., mortars, pestles, handstones, or milling slabs); and battered stone tools, such as hammerstones and pitted stones.

Historic-era cultural materials might include building or structure footings and walls, and deposits of metal, glass, and/or ceramic refuse.

If the City determines, based on recommendations from a qualified archaeologist and a Native American representative (if the resource is pre-contact), that the resource may qualify as a historical resource or unique archaeological resource (as defined in CEQA Guidelines Section 15064.5) or a tribal cultural resource (as defined in PRC Section 21080.3), the resource shall be avoided if feasible.

Consistent with Section 15126.4(b)(3), this may be accomplished through planning construction to avoid the resource, incorporating the resource within open space, capping and covering the resource, or deeding the site into a permanent conservation easement.

If avoidance is not feasible, the City shall consult with a qualified archaeologist and a Native American representative (if the resource is pre-contact) to determine treatment measures to avoid, minimize, or mitigate any potential impacts to the resource pursuant to PRC Section 21083.2 and CEQA Guidelines Section 15126.4. This shall Project Applicant /
Construction
Contractor
Qualified
Archaeologist
If applicable,
Native American
representative
Richmond Building Division to review
and approve of archaeologist, of
cultural resources monitoring plan and
of the construction plan that includes
archaeological mitigation.

If resources are encountered,
Contractor to verify work is suspended
as required, review and approve
qualified archaeologist and
recommendations.

If resources encountered are found to
be qualifying as described in the
measure, the City to ensure
preservation measures are
implemented or that the ARDTP is
completed and submitted to NWIC.

City to inspect site during construction
to ensure compliance with project
construction plans.

Prior to issuance of
building permit for, or
commencement of,
any ground-disturbing
activities.

Field inspections
during construction.

Verified by:

Date:
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APPENDIX C - Second Final Updated Mitigation Monitoring and Reporting Program Raven SR Bioenergy Project C-7 ESA / D202100382
Updated Initial Study MND March 9, 2023
Project Mitigation Measures
Implemented
By
Monitored By Monitoring and Reporting
Action
Monitoring
Schedule
include documentation of the resource and may include data recovery (according to PRC Section 21083.2), if deemed
appropriate, or other actions such as treating the resource with culturally appropriate dignity and protecting the cultural character and integrity of the resource (according to PRC Section 21084.3).

Mitigation Measure CUL-2: Inadvertent Discovery of Human Remains.

If human remains are encountered during project implementation, the contractor shall halt all construction activities within 100 feet of the find and notify the City. The City shall contact the Contra Costa County Coroner who will determine that no investigation of the cause of death is required. If it is determined that the remains are Native American, the Coroner shall contact the Native American Heritage Commission within 24 hours. The Commission shall then identify the person or persons it believes to be the Most Likely Descendant from the deceased Native American, who in turn would make
recommendations for the appropriate means of treating the human remains and any grave goods.

Project Applicant /
Construction
Contractor
Qualified
Archaeologist
Richmond Building Division verify
mitigation measure on construction
plans.

Inspect site during construction to
ensure compliance with project
construction plans.

If needed, engage County Coroner
and ensure NAHC contact.

Prior to issuance of a
building permit for, or
commencement of,
any ground-disturbing
activities.

Field inspections
during construction.

Verified by:

Date:

4.6 Energy – None Required

4.7 Geology, Soils, and Mineral Resources - MM CUL-1a, CUL-1b, CUL-2 (see 4.5, Cultural Resources)

4.8 Greenhouse Gas Emissions – None Required

4.9 Hazards and Hazardous Materials – None Required

4.10 Hydrology and Water Quality – None Required

4.11 Land Use and Planning – None Required

4.12 Noise / Vibration – None Required

4.13 Population and Housing– None Required

4.14 Public Services and Recreation – None Required

4.15 Transportation – None Required

4.16 Tribal Cultural Resources - MM CUL-1a, CUL-1b, CUL-2 (see 4.5, Cultural Resources)

4.17 Utilities and Service Systems – None Required

4.18 Wildfire – None Required
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APPENDIX C - Second Final Updated Mitigation Monitoring and Reporting Program Raven SR Bioenergy Project C-8 ESA / D202100382
Updated Initial Study MND March 9, 2023 1153
Raven SR Bioenergy Project D-1 ESA / D202100382
Updated Initial Study MND March 9, 2023

APPENDIX D
Response to Comments Received on the Raven
SR Bioenergy Project Initial Study / Mitigated
Negative Declaration (November, 11, 2022)
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1155
180 Grand Avenue
Suite 1050
Oakland, CA 94612
510.839.5066 phone
510.839.5825 fax
esassoc.com
Memorandum
date November 30, 2022
to Lydia Elias, Planner I
Lina Velasco, Director
from Crescentia Brown, Project Director
Tim Sturtz, Project Manager
subject RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
Background
On October 7, 2022, the City of Richmond (Lead Agency) released for public review a Draft Initial Study (IS) and Mitigated Negative Declaration (MND) pursuant to the California Environmental Quality Act (CEQA) for the proposed Raven SR Bioenergy Project (Project) (SCH# 202201045). The original public review and comment period on the IS/MND was October 7, 2022 through November 7, 2022, and the City extended the comment period to November 22, 2022.

Although not required by CEQA, this document includes the comments received on the IS/MND (see Table 1) and responses to each comment.

TABLE 1

COMMENT LETTERS RECEIVED ON THE IS/MND
Letter # Entity Author(s) of Comment Letter/e-mail Comment Date Agencies – Public / Quasi-Public
1 Contra Costa Environmental
Health
Nicole Soto, REHS November 22, 2022
2 Berkeley Lab Vi H. Rapp, PhD, Deputy for Building and Industrial Applications Department
November 21, 2022
3 CalRecycle Harprit Mattu, Environmental Scientist November 7, 2022 4 Department of Toxic
Substances Control
Rebecca De Pont, Supervising Environmental
Planner
November 4, 2022
5 California State Senate Nancy Skinner, State Senator District 9 October 21, 2022 6 MCE Dawn Weisz, CEO October 20, 2022
7 Bay Area Air Quality
Management District
Kelly Malinowski, MPA | Senior Environmental
Planner
October 19, 2022
8 Republic Services Ken Lewis, P.E., General Manager October 13, 2022 continued
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RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 2 TABLE 1 (CONTINUED)

COMMENT LETTERS RECEIVED ON THE IS/MND
Letter # Entity Author(s) of Comment Letter/e-mail Comment Date Organizations / Individual
9 Environmental Justice Groups November 22, 2022
 Communities for a
Better Environment
Connie Cho, Attorney / Tessa Wardle, Staff
Researcher
 Sierra Club Teresa Cheng, Senior Campaign Representative  Asian Pacific
Environmental Network
Faraz Rizvi, Campaign and Policy Manager
 Richmond Our Power
Coalition
Katt Ramos, Managing Director - Richmond Our
Power Coalition
 Urban Tilth Kiara Pereira, Just Transition Organizer / Rafael Castro, Just Transition Organizer
 Natural Resources
Defense Council
Ann Alexander, Senior Attorney
10 Shell Hydrogen Humberto Orantes, Acting Commercial Head, North America
November 7, 2022
11 Powers Engineers James P. Hays, Business Unit Director November 7, 2022 12 Trails for Richmond Action
Committee (TRAC) Bruce Beyaert, TRAC Chair October 27, 2022 13 Benicia Fabrication & Machine Carmelo Santiago, CEO & President October 20, 2022 14 Contra Costa Construction and
Building Trades Council William Whitney October 17, 2022 15 Watlow Ashish Bhatnagar, Chief Technology Officer October 14, 2022 16 Iron Workers Local 378 Jason Gallia, Business Manager, Financial Manager/Treasurer October 13, 2022
17 Local Union No. 302
International Brotherhood of
Electrical Workers
Tom Hansen, Business Manager, Financial
Secretary October 13, 2022
18 Green Hydrogen Coalition Nicholas Connell, Policy Director October 10, 2022 19 Not Identified Christina Strawbridge October 10, 2022 No “substantial revisions” that would require recirculation of the IS/MND are warranted. Specifically, (1) no new, avoidable significant effect is identified and mitigation measures or project revisions must be added in order to reduce the effect to insignificance, or (2) The lead agency determines that the proposed mitigation measures or project revisions will not reduce potential effects to less than significance and new measures or revisions must be required (CEQA Guidelines Section 15073.5). Although a mitigation measure (AQ-1: Best Management Practices) is expanded with equal or more effective measures pursuant to Section 15074.1, recirculation of the MND is not required. The updated Mitigation Measure Monitoring and Reporting Program (MMRP) with the expanded mitigation measure is included as Attachment A to this memo. 1157
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 3 Comments and Responses
Responses focus on comments that pertain to the adequacy of the analysis in the IS/MND or to other aspects pertinent to the potential effects of the proposed Project on the environment pursuant to CEQA. Comments that address topics beyond the purview of the IS/MND or CEQA or that state opinions about the overall merit of the proposed Project are acknowledged for the public record and will be taken into account by City decision-makers.

DEPUTY HEALTH DIRECTOR

JOCELYN STORTZ, MS, REHS

ENVIRONMENTAL HEALTH DIRECTOR

CONTRA COSTA ----

HEALTH SERVICES
November 22, 2022
City of Richmond Planning Division
Attn: Lydia Elias
450 Civic Center Plaza- 2nd Floor
Richmond, CA 94804
lydia [email protected]
RE: PLN21-282-Raven SR Bioenergy Project
1 Parr Boulevard Richmond, CA 94801
APN: 408-140-009
Service Request #: SR0020187
Facility Identification#: FA0047036
Dear Lydia Elias:

CONTRA COSTA

ENVIRONMENTAL HEALTH
2120 Diamond Boulevard, Suite 100
Concord, California 94520
Ph (925) 608-5500
Fax (925) 608-5502
www.cchealth.org/eh/
Contra Costa Environmental Health (CCEH) has received a request for agency comment regarding the above referenced project. The following are our comments:

1. A permit from CCEH is required for any well or soil boring prior to commencing drilling activities, including those associated with water supply, environmental investigation and cleanup, or geotechnical investigation.

2. It is recommended that the project be served by public sewer and public water.

3. The CCEH is designated by the California Department of Resources Recycling and Recovery (CalRecycle) as the Local Enforcement Agency (LEA) for solid waste facilities, including landfills, transfer stations, and waste tire generators and haulers. The prospective operators of Raven SR should be directed to CCEH to submit a Registration Permit application and facility plan for a Transfer/Processing Facility.

4. In the Raven SR Bioenergy Project Initial Study subsection Odor Control, additional clarification is requested.
• What is the time frame for the feedstock to remain on the management area floor? • What do the odor control measures consist of?
10~ ~ ~~.J • Contra Costa Behavioral Health Services • Contra Costa Emergency Medical Services • Contra Costa Environmental Health & Hazardous Materials Programs • • Contra Costa Health, Housing & Homeless Services • Contra Costa Health Plan • Contra Costa Public Health • Contra Costa Regional Medical Center & Health Centers • 1-1 1-2 1-3 1-4 LETTER 1
1159

5. In the Raven SR Bioenergy Project Initial Study section 2.4 Technology, the document lists medical waste as one of the types of organic feedstocks. • Medical waste cannot be accepted at the solid waste facility, unless approved by the appropriate regulatory agency. Contact California Department of Public Health regarding medical waste permitting.

6. The project is adjacent to Class I & II landfills, the operator should ensure the project is compliant with the Post Closure Maintenance Plans of the landfills.

7. Substantial construction and demolition (C & D) waste could result from this project.

Hazardous construction and demolition materials should be separated from those that can be recycled or disposed.

8. Debris from construction or demolition activity must go to a solid waste or recycling facility that complies with the applicable requirements and can lawfully accept the material (e.g., solid waste permit, EA Notification, etc.). The debris must be transported by a hauler that can lawfully transport the material. Debris bins or boxes of one cubic yard or more owned by the collection service operator shall be identified with the name and telephone number of the agent servicing the container.

9. Non-source-separated waste materials must not be brought back to the contractor's yard unless the facility has the appropriate solid waste permit or EA Notification.

These comments do not limit an applicant's obligation to comply with all applicable laws and regulations. If you should have any questions, please do not hesitate to call me at (925) 608- 5550.

Sincerely,
Nicole Soto , REHS
Environmental Health Specialist II
cc
Harprit Mattu, California Department of Resources Recycling and Recovery [email protected]. gov
1-5 1-61-7
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RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 6 Responses to Letter 1 - Contra Costa Environmental Health 1-1 The comment specifies that the project must obtain a permit from Contra Costa Environmental Health (CCEH) for any well or soil boring prior to commencing drilling activities. The project applicant acknowledges this requirement and shall comply.
1-2 The comment recommends that the project be served by public sewer and public water. As specified in Section 4.17, Utilities and Service Systems, of the IS/MND, the proposed project will continue to be served by EBMUD and West County Wastewater District, which already serves the site. 1-3 The comment specifies application information that the project applicant/operator must obtain from CCEH as the Local Enforcement Agency (LEA) relevant to the proposed project facility and operation.

The project applicant/operator will submit and obtain all required permitting applications for the proposed Transfer/Processing Facility.
1-4 The comment requests clarification of the duration of time for the project’s feedstock to remain on the management area floor, and what the odor control measures consist of. The project applicant has clarified that all incoming organic feedstock material shall be received and stored under roof in designated areas and shall be processed within 48 hours of receipt. The project will incorporate control mechanisms to minimize possible additional odors from its operation. Odor control would be both preventative and performance based, triggered “if objectionable odors occur”, such as the immediate application of odor neutralizing solutions onsite as needed. Also, as previously mentioned in Response to Comment 1-4, the site shall be cleaned daily to remove loose material and litter. Boxes, bins, and containers shall be cleaned on a regular basis. The site and receiving area shall be swept regularly. Specifically, these will include preparation, implementation, and monitoring and annual evaluation of, and adherence to, the operational Odor Prevention and Management Plan (OPMP) detailed in project Condition No. 19.3 regarding odors and that is consistent with Contra Costa County requirements prior to commissioning and operation of the facility.

Condition No. 19.3 - Odor Containment. During the construction phase of the Project, the operational Odor Prevention and Management Plan (OPMP) shall be developed and implemented upon commissioning of the renewable fuels processes, intended to become an integrated part of daily operations at the Facility and other sites, so as to prevent any objectionable offsite odors and effect diligent identification and remediation of any potential objectionable odors generated by the facility and associated sites. The plan shall outline equipment that is in place and procedures that facility personnel shall use to address odor issues, facility wide. The OPMP shall include continuous evaluation of the overall system performance, identification of trends to provide an opportunity for improvements to the plan, and updating the odor prevention and management strategies, as necessary. This plan shall be retained at the facility for City or any other government agency inspection upon request. The following practices shall be included in the OPMP to reduce the potential of objectionable odors from the storage of renewable feedstocks, operation of the Facility, and any other odor generating activity:
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RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 7 • Develop operating procedures to inspect and evaluate the effectiveness of odor control equipment and operation of the wastewater treatment plant. • The OPMP shall include guidance for the proactive identification and documentation of odors through routine employee observations, routine operational inspections, and odor compliant investigations.
• Inspections to be conducted on a semi-annual basis.
• If there are fewer than an average of five confirmed complaints per year during the first 3 years of operation, then the inspection frequency can be reduced to an annual basis. • If there are more than five confirmed complaints in any single year, then the application shall develop additional mitigation strategies in consultation with the BAAQMD. • All odor complaints received by the facility shall be investigated as soon as is practical within the confines of proper safety protocols and site logistics. The goal of the investigation will be to determine if an odor originates from the facility and, if so, to determine the specific source and cause of the odor, and then to remediate the odor. • Prepare an annual evaluation report of the overall system performance, identifying any trends to provide an opportunity for improvements to the plan, and updates to the odor management and control strategies, as necessary. The report shall be provided to the City for review and approval.

Raven SR's novel system provides a unique opportunity to demonstrate a new hydrogen production technology that could revolutionize waste-to-hydrogen production. In addition to providing clean hydrogen fuel, the technology may also help the City of Richmond further divert waste from landfills to meet California's SB 1383's goal of reducing organic waste disposal by 75% from 2014 levels (up to 27 M tons of organic waste) by 2025.

In addition to reducing methane and short-lived climate pollutants from the landfill, Raven SR will also support and expand jobs in the community, including construction jobs to build their facilities. Raven SR recently signed a Project Labor Agreement with the Contra Costa Building & Construction Trades Council and the I.B.E.W. Local #1245, demonstrating their commitment to using the community's talents.

California has taken a leadership role in the nation for launching the hydrogen economy and Richmond has an opportunity, with Raven SR, to join the state in supporting advancement of hydrogen production, while also reducing emissions and addressing climate change. Because of this opportunity, I hope you will consider approving Raven SR's CUP application and the CEQA MND so they may begin construction this year and start production in early 2023.

Sincerely,
Vi H. Rapp, PhD
Deputy for Building and Industrial Applications Department I Research Scientist Lawrence Berkeley National Laboratory
Energy Technologies Area I Building Technologies and Urban Systems Division Office: 510-495-2035 I Email: [email protected]
Lawrence Berkeley National Laboratory
One Cyclotron Road I Berkeley, California 94720 / phone 510-486-4000 2-1 LETTER 2
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RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 9 Responses to Letter 2 – Berkeley Lab
2-1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment also opines that the proposed Project’s non-combustion system would reduce methane and short-lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision-makers as they consider the Project and whether or not to approve it.
________________________
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1001 I Street, Sacramento, CA 95814 | P.O. Box 4025, Sacramento, CA 95812 www.CalRecycle.ca.gov | (916) 322-4027
California Environmental Protection Agency
Department of
Resources Recycling and Recovery
Gavin Newsom
California Governor
Amelia Yana Garcia Gonzalez
Secretary for Environmental Protection
Rachel Machi Wagoner
CalRecycle Director
November 7, 2022
Lydia Elias, Planner I
City of Richmond Planning and Building Services Department 450 Civic Center Plaza
Richmond, CA 94804
[email protected]
Subject: SCH No. 2022100145 – Raven SR Bioenergy Project Mitigated Negative Declaration – Contra Costa County
Dear Lydia Elias,
Thank you for allowing the Department of Resources Recycling and Recovery (CalRecycle) staff to provide comments on the proposed project and for your agency’s consideration of these comments as part of the California Environmental Quality Act (CEQA) process.

Project Description
The City of Richmond Planning Department, acting as Lead Agency, has prepared and circulated a Notice of Completion (NOC) of a Draft Initial Study/Mitigated Negative Declaration (Draft IS/MND) in order to comply with CEQA and to provide information to, and solicit consultation with, Responsible Agencies in the approval of the proposed project.

The proposed Raven SR Project is located at 1 Parr Boulevard, Richmond, California. The location is within the West Contra Costa Sanitary Landfill (WCCSL) facility located in the northwest area of the City of Richmond, in Contra Costa County, California. For purpose of this environmental document, the project would occur within approximately 2.5 acres of the existing Republic Services Bulk Materials Processing Center (BMPC) within “Area A” of the WCCSL. The property is located approximately

0.25 miles west of Parr Boulevard (approximately 0.25 miles west from Richmond Parkway) via an unpaved access road. The northern boundary of the project site is the City of Richmond / Contra Costa County jurisdiction line; the project site is located wholly within the City of Richmond, except for use of an existing access/egress road located within the County. The project site is located within Assessor’s Parcel Number (APN) 408-140-009.

The proposed project would add a bioenergy system at the site. The non-combustion process would convert blended green waste and food waste, obtained from the existing LETTER 3
1165
1001 I Street, Sacramento, CA 95814 | P.O. Box 4025, Sacramento, CA 95812 www.CalRecycle.ca.gov | (916) 322-4027
BMPC operation adjacent to the project site, into renewable, transportation grade hydrogen that would be exported offsite for various renewable energy products. No long-term hydrogen storage would occur onsite. The project would involve the erection of a modular structure and industrial canopy.

The conversion method uses a non-combustion (i.e., anoxic, indirect external heating), low pressure process. The only chemicals added would be carbon dioxide (CO2), calcium carbonate (limestone), and steam (i.e., water heated into a vapor state). No hazardous materials would be used in the process. The conversion occurs in sealed rotating drums that drop out solid matter from the green and food waste feedstock, which would consist largely of biocarbon, along with dirt, glass, grit, rocks, and inorganic salts. The biocarbon materials are inert to the process (i.e., not gasified) and drop out in the first stage. The process also drops out excess water. Neither the biocarbon nor the water would be considered a hazardous material.

Prior to being received at the site, the material will be ground and screened at the WCCSL compost site. Maximum daily tonnage is estimated to be 99.9 wet tons per day of blended green waste and food waste. The Raven SR system may run up to 24 hours per day, seven days per week.

The operation would involve up to approximately 12 hydrogen tube trucks and up to approximately 15 biocarbon trucks (total 37 trucks) per week, each with an average trip of 40 miles after leaving the site. Considering this with other trucks and employees coming to and leaving the project site daily, the project is estimated to generate about 130 vehicle trips on a typical weekday.

Comments
CalRecycle staff’s comments on the proposed project are listed below. Where a specific location in the document is noted for the comment, please ensure the comment is addressed throughout all sections of the Draft IS/MND, in addition to the specific location noted.

Comments for the Draft IS/MND are summarized below:

1. Project Description, Daily Quantities and Operations, PDF Page 22 – “The Raven facility would receive up to 99.9 wet tons per day of blended green waste and food waste feedstock…” Receipt of this volume of solid waste for further processing will require a Transfer/Processing Facility Solid Waste Facility Permit. As a reminder, per PRC 40191 a solid waste facility cannot receive hazardous, radioactive, or medical wastes.

2. Project Description, Odor Control, PDF Page 23 – “Nuisance odor from Raven is unlikely since feedstock material would only be on the feedstock management area floor for relatively short periods of time.” The applicant should clarify how long the material will be stored in the storage bunkers or other designated material storage areas prior to being placed in the Raven SR’s Reformation Technology system? Given the putrescible nature of the incoming feedstock, what methods will the applicant utilize to control or prevent the propagation, 3-1
3-2
CONT.
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1001 I Street, Sacramento, CA 95814 | P.O. Box 4025, Sacramento, CA 95812 www.CalRecycle.ca.gov | (916) 322-4027
harborage and attraction of flies, rodents, or other vectors, and animals, and to minimize bird attraction.? Per Title 14 CCR Section 17410.1(a)(2) “facilities shall remove solid waste accepted at the site within 48 hours from the time of receipt.” Solid Waste Regulatory Oversight
Contra Costa Health Services is the Local Enforcement Agency (LEA) for Contra Costa County and responsible for providing regulatory oversight of solid waste handling activities, including inspections. Please contact Tim Kraus, the LEA, at 925.608.5549 to discuss the regulatory requirements for the proposed project.

Conclusion
CalRecycle staff thanks the Lead Agency for the opportunity to review and comment on the environmental document and hopes that this comment letter will be useful to the Lead Agency preparing the MND and in carrying out their responsibilities in the CEQA process.

CalRecycle staff requests copies of any subsequent environmental documents, copies of public notices and any Notices of Determination for this proposed project.

If the environmental document is adopted during a public hearing, CalRecycle staff requests 10 days advance notice of this hearing. If the document is adopted without a public hearing, CalRecycle staff requests 10 days advance notification of the date of the adoption and proposed project approval by the decision making body.

If you have any questions regarding these comments, please contact me at 916.341.6119 or by e-mail at [email protected].

Sincerely,
Harprit Mattu, Environmental Scientist
Permitting & Assistance Branch – North
Waste Permitting, Compliance & Mitigation Division
CalRecycle
cc: Eric Kiruja, Supervisor
Permitting & Assistance Branch – North
Tim Kraus, REHS, LEA
Contra Costa Health Services
3-3 3-4
3-2
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RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 13 Responses to Letter 3 - CalRecycle
3-1 The comment states that per PRC 40191 and given the proposed daily volume of a solid waste the proposed facility could receive, receipt of hazardous, radioactive, or medical wastes is not permitted. See Response to Comment 1-5 above regarding eligible feedstock. 3-2 The comment requests clarification of how long the feedstock material will be stored in the storage bunkers or other designated material storage areas prior to being placed in the Raven SR’s Reformation Technology system. See Responses to Comments 1-4 and 9-5 regarding potential odor control measures and impacts.
3-3 The comment specifies contact information for the project applicant and City to discuss the regulatory requirements for the proposed project. The project applicant acknowledges this requirement and shall comply.
3-4 The comment requests copies of any subsequent environmental documents, copies of public notices and any Notices of Determination for this proposed project, and specifies noticing timeframes. The Lead Agency will conduct all CEQA-related noticing and distribution of associated documents pursuant to CEQA Guidelines for an MND and City standards. Access to all project notices, documents and City actions on the project are available to the public at https://www.ci.richmond.ca.us/4365/Raven-SRBioenergy-Project. 1168
Printed on Recycled Paper
November 4, 2022
Lydia Elias, Planner 1
(Sent electronically to [email protected])
City of Richmond Planning Division
450 Civic Center Plaza-2nd Floor
Richmond, CA 94804
Phone: (510) 620-5558
Subject: Raven SR Bioenergy Project Draft Initial Study/Mitigated Negative Declaration (SCH 2022100145)
Dear Ms. Elias,
Thank you for the opportunity to review and comment on the draft Mitigated Negative Declaration for the Raven SR Bioenergy Project (SCH 2022100145). The Department of Toxic Substances Control (DTSC) has identified that your project may affect, and in turn be affected by, the West County Landfill Inc. Post-Closure Permit project (CAD041844002). The Post-Closure Project area is surrounded by the Class II portion of the West Contra Costa County Sanitary Landfill. Initial wastes received included demolition debris, municipal solid waste, and industrial waste. In later years, the site was designated to receive hazardous waste. The Project area has operated a corrective action groundwater monitoring program for the Hazardous Waste Management Facility (HWMF) since March 1996. This program consists of measuring leachate and groundwater levels to evaluate inward hydraulic gradients across the HWMF and E‐22R slurry walls, and the semiannual sampling and analysis of groundwater from 33 wells to monitor groundwater quality in the surficial, shallow, and medium water‐bearing zones (WBZs) beneath the Project area.

Additional information about the permit and groundwater contamination at the site is available here.

DTSC has the following comments on the draft Mitigated Negative Declaration and Initial Study for the Raven SR Bioenergy Project:

LETTER 4
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1. The proposed Raven SR Bioenergy Project’s construction may destabilize the contamination at the West County Landfill Inc. Post-Closure Permit beyond its existing containment system. This may result in, the potential contamination of additional groundwater.

2. The groundwater monitoring system funnels leachate to a treatment area near the proposed Raven SR Bioenergy Project that may be damaged during construction.

3. DTSC believes that City of Richmond must address these concerns to avoid any significant impacts under CEQA that may occur and ensure that the West County Landfill Inc. Post-Closure care is operational during and after construction of the SR Bioenergy Project.

Thank you for your assistance in protecting California’s people and environment from the harmful effects of toxic substances. If you have any questions or would like any clarification on DTSC’s comments, please contact Rebecca De Pont, Supervising Environmental Planner at (916) 255-3638 or [email protected].

Sincerely,
Rebecca De Pont
Supervising Environmental Planner, Permitting Division
Department of Toxic Substances Control
4-1
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RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 16 Responses to Letter 4 - Department of Toxic Substances Control 4-1 The comment claims that the project’s construction may destabilize the contamination at the West County Landfill Inc. Post-Closure Permit beyond its existing containment system, and that the existing groundwater monitoring system may be damaged during construction, resulting in potential contamination of additional groundwater and significant impacts under CEQA. The analysis understands that the existing systems directs leachate from the landfill to the treatment area located near the proposed project site (IS/MND, Section 2.2 Surrounding Uses and Conditions). The Geotechnical Investigation report prepared for the proposed project (Rockridge, 2022) involved investigation to depths of approximately 150 feet on and around the site. The investigation confirmed that the maximum depth of disturbance required for the project, specifically the foundation pads necessary to support the proposed project (up to approximately 30 to 33 feet) would not disturb existing groundwater or monitoring stations of leachate flows or migration. Thus the proposed project would not destabilize the existing containment system or groundwater condition during construction. Further, as indicated in Response to Comment 1-6, the project shall be compliant with the Post Closure Maintenance Plans of the landfills, in accordance with project Condition No. 4.5, the Closure/Post Closure Maintenance Plan required by CalRecycle, the San Francisco Regional Water Quality Control Board (SFRWQCB), and the LEA for the existing WCCSL.
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October 21, 2022
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
RE: Support for Raven SR’s Conditional Use Permit for Clean Hydrogen Facility Dear Ms. Elias,
I am writing in support of Raven SR’s Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a clean hydrogen/bioenergy facility at Republic Service’s West Contra Costa County Sanitary Landfill.

As the author of statewide legislation to jumpstart California’s use of hydrogen made from renewable sources, I am pleased that Raven is proposing to showcase a new clean hydrogen production technology in Richmond, using a waste-to-hydrogen process. In addition, Raven’s innovative project will help the city divert more waste from landfills to meet California’s goal of reducing organic waste disposal by 75% from 2014 levels by 2025.

I am also pleased that Raven has signed a Project Labor Agreement with the Contra Costa Building & Construction Trades Council and the I.B.E.W. Local #1245.

California has taken a leadership role in launching a clean hydrogen economy, and Richmond has the opportunity with Raven to advance clean fuels production and emissions reductions, and help our fight against climate change.

As such, I respectfully urge you approve Raven SR’s CUP application and the CEQA MND so they may begin construction this year and start production in early 2023.

Sincerely,
Nancy Skinner
State Senator, District 9
LETTER 5
5-1 1172
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 18 Responses to Letter 5 - California State Senate
5-1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment also opines that the proposed Project’s non-combustion system would reduce methane and short-lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision-makers as they consider the Project and whether or not to approve it.
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CONCORD OFFICE: 2300 Clayton Road, Suite 1150, Concord, CA 94520 SAN RAFAEL OFFICE: 1125 Tamalpais Avenue, San Rafael, CA 94901 mceCleanEnergy.org
Lydia Elias October 20, 2022
City of Richmond’s Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Ms. Elias,
Over the years, we have seen the incredible projects that have come to fruition in the City of Richmond. Keeping in tradition with this innovative, entrepreneurial spirit, we are pleased to watch the development of the Raven SR bioenergy facility at Republic Service’s West Contra Costa County Sanitary Landfill.

MCE’s mission is to confront the climate crisis by eliminating fossil fuel greenhouse gas emissions, producing renewable energy, and creating equitable community benefits. We understand the incredible impact that clean, green hydrogen offers California as we transition away from fossil fuels and decarbonize our economy. Raven SR’s proposed hydrogen production is expected to not only produce a consistent high-value multi-use hydrogen supply, but also reduce our community waste streams without incineration. This would help us meet our organic waste diversion goals (Senate Bill 1383) while minimizing existing methane and greenhouse gas emissions, and would avoid contributions to localized criteria air pollutants. We understand Raven SR has a PLA with the Contra Costa Building & Construction Trades Council and IBEW Local 1245, helping to ensure the quality of jobs produced at this site.

We are excited about this proposed technology, and the engagement with strong partners. In addition, we’re encouraged to see the project take root in Richmond as its first location.

In October, we attended an Alliance for Renewable Clean Hydrogen Energy Systems (ARCHES) event to discuss the possibilities that hydrogen offers California and how stakeholders must coordinate to obtain funds from the Department of Energy to create a regional Hydrogen Hub. It is likely that there could soon be strong demand for a limited supply of commercially available hydrogen. Raven’s production is poised to take advantage of this growing demand to meet decarbonization goals. Using hydrogen for transportation fuel is especially important to displace the diesel emissions of long-haul vehicles which disproportionally pollute lower-income and communities of color adjacent to transportation corridors.

Thank you for your consideration. We are supportive of these efforts and look forward to this project becoming a key part of California’s Northern California Hydrogen Hub in the future.

Sincerely,
Dawn Weisz, CEO
LETTER 6
6-1
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RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 20 Responses to Letter 6 - MCE
6-1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment also opines that the proposed Project’s non-combustion system would reduce methane and short-lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision-makers as they consider the Project and whether or not to approve it.
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From: Kelly Malinowski
To: Lydia Elias
Cc: Samuel Garcia; Lily MacIver; Wendy Goodfriend; Alison Kirk Subject: Raven SR Bioenergy Project
Date: Wednesday, October 19, 2022 2:44:33 PM
You don't often get email from [email protected]. Learn why this is important This email originated from outside of the City's email system. Do not open links or attachments from untrusted sources.

Hi Lydia,
We have reviewed the IS/MND for the Raven SR Bioenergy Project. We will not be sending a formal CEQA comment letter, but we did want to provide some additional dust mitigation measures that you could consider for the Construction Dust, related to AQ-1 Best Management Practices, below:

BMP #6: All excavation, grading, and/or demolition activities shall be suspended when average wind speeds exceed 20 mph.

BMP #7: All trucks and equipment, including their tires, shall be washed off prior to leaving the site.

BMP #8: Unpaved roads providing access to sites located 100 feet or further from a paved road shall be treated with a 6- to 12-inch layer of compacted layer of wood chips, mulch, or gravel.

Additional BMP: Limit the simultaneous occurrence of excavation, grading, and grounddisturbing construction activities.

Additional BMP: Install wind breaks (e.g., trees, fences) on the windward side(s) of actively disturbed areas of construction. Wind breaks should have at maximum 50 percent air porosity.

Additional BMP: Plant vegetative ground cover (e.g., fast-germinating native grass seed) in disturbed areas as soon as possible and watered appropriately until vegetation is established Additional BMP: Install sandbags or other erosion control measures to prevent silt runoff to public roadways from sites with a slope greater than one percent.

Additional BMP: Minimize the amount of excavated material or waste materials stored at the site.

Additional BMP: Hydroseed or apply non-toxic soil stabilizers to construction areas, including previously graded areas, that are inactive for at least 10 calendar days.

Require zero visible fugitive dust and use fence line air monitoring to demonstrate compliance with this requirement.

Set requirements for when dust generating operations have to be shut down due to dust crossing the property boundary or if dust is contained within the property boundary but not controlled after a specified number of minutes.

LETTER 7
7-1
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Prohibiting grading on days when a Spare the Air is in effect (https://www.sparetheair.org/) Prohibiting grading on days with an Air Quality Index forecast of greater than 100 for particulates for the project area
Please let us know if you have any questions, or would like to discuss! Best,
Kelly
Kelly Malinowski, MPA | Senior Environmental Planner
Planning and Climate Protection Division
Bay Area Air Quality Management District
Office: 415-749-8673
Pronouns: she/her
CONT.
7-1
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RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 23 Responses to Letter 7 - Bay Area Air Quality Management District 7-1 The comment provides additional dust mitigation measures for consideration, which the City and the project applicant has elected to incorporate in to Mitigation Measure AQ-1, as shown below.  Section 4.3, Air Quality, Criterion “b” (p. 39):

Mitigation Measures
AQ-1: Best Management Practices.

Clear signage shall be provided for construction workers at all access points.  All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation.  Post a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s phone number shall also be visible to ensure compliance with applicable regulations.
 BMP #6: All excavation, grading, and/or demolition activities shall be suspended when average wind speeds exceed 20 mph.
 BMP #7: All trucks and equipment, including their tires, shall be washed off prior to leaving the site.
 BMP #8: Unpaved roads providing access to sites located 100 feet or further from a paved road shall be treated with a 6- to 12-inch layer of compacted layer of wood chips, mulch, or gravel.
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RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 24  Additional BMP: Limit the simultaneous occurrence of excavation, grading, and grounddisturbing construction activities.  Additional BMP: Install wind breaks (e.g., trees, fences) on the windward side(s) of actively disturbed areas of construction. Wind breaks should have at maximum 50 percent air porosity.
 Additional BMP: Plant vegetative ground cover (e.g., fast-germinating native grass seed) in disturbed areas as soon as possible and watered appropriately until vegetation is established.
 Additional BMP: Install sandbags or other erosion control measures to prevent silt runoff to public roadways from sites with a slope greater than one percent.  Additional BMP: Minimize the amount of excavated material or waste materials stored at the site.
 Additional BMP: Hydroseed or apply non-toxic soil stabilizers to construction areas, including previously graded areas, that are inactive for at least 10 calendar days.  Require zero visible fugitive dust and use fence line air monitoring to demonstrate compliance with this requirement.
 Set requirements for when dust generating operations have to be shut down due to dust crossing the property boundary or if dust is contained within the property boundary but not controlled after a specified number of minutes.
 Prohibiting grading on days when a Spare the Air is in effect (https://www.sparetheair.org/) Prohibiting grading on days with an Air Quality Index forecast of greater than 100 for particulates for the project area.

These modifications do not change the adequacy of the analysis or impacts identified in the IS/MND, and no further analysis is warranted, pursuant to the findings enumerated in Section 1 of this memo. ________________________
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'c,R~ REPUBLIC ~'v SERVICES
October 13, 2022
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Lydia:
1 am writing lo provide our company's support of Raven SR's Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service's West Contra Costa County Sanitary Landfill (WCCSL).

Raven SR has developed a new hydrogen production technology that will revolutionize waste-to-hydrogen production. The Richmond location will be the first project of its type and the community has a significant opportunity to receive recognition for being the host location for this innovative project from the pro-hydrogen focused State of California and US Department of Energy. This project will be recognized nationally as an industry shifting and innovative approach to clean green hydrogen production.

The Raven project will also develop an additional local, reliable, and compliant outlet for organic wastes to complement the current composting operation on site. In addition to providing a new source of clean, green hydrogen fuel, the Raven project will also help the City of Richmond further divert organic waste from landfills to meet California's SB 1383 ·s goal of reducing organic waste disposal by 75% from 2014 levels by the compliance date of 2025.

The development of the Raven project will generate jobs not only in the City of Richmond, but also ancillary jobs throughout the area through engineering, fabrication, construction, fuels providers, waste management. and many other areas. To this end, Raven has recently signed a Project Labor Agreement with the Contra Costa Building & Construction Trades Council and the I.B.E. W. Local# 1245 relating to this project.

Because Raven's proprietary system utilizes a non-combustion process that generates minimal emissions. the project will reduce overall methane and short-lived climate pollutants emissions compared to other processes. Additionally, this project also provides a net positive reduction in greenhouse gases emissions when compared to other similar practices. This is an important and positive aspect to improving the air quality around the City of Richmond and surrounding communities.

California has taken a leadership role in the nation by launching the green hydrogen economy and setting aggressive greenhouse gas reductions goals. The City of Richmond 8-1
CONT. LETTER 8
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~R~ REPUBLIC ~'v SERVICES
I t
has the opportunity along with Raven SR to lead in this advancement and these very important initiatives with this project. We believe development of projects such as the Raven SR bioenergy facility at the WCCSL are essential for meeting California's greenhouse gas initiatives reduction goals and making a difference towards reversing climate change.

Thank you for your consideration and we respectfully request you approve Raven SR 's CUP application and the CEQA MND so they may begin construction this year and start production in early 2023.

Sincerely,
Ken Lewis, .

General Manager - North Bay
CONT.
8-1
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RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 27 Responses to Letter 8 - Republic Services
8-1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment also opines that the proposed Project’s non-combustion system would reduce methane and short-lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision-makers as they consider the Project and whether or not to approve it.
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November 22, 2022
Lydia Elias, Planner 1
City of Richmond Planning Division
450 Civic Center Plaza—2nd Floor
Richmond, CA 94804
510-620-5558
Submitted electronically via [email protected] Re: Comment on Draft Initial Study/Mitigated Negative Declaration (IS/MND) for Raven SR Bioenergy Project (PLN21-282)
Dear Ms. Elias,
Please accept these comments from the undersigned organizations concerning the Draft Initial Study and Mitigated Negative Declaration (IS/MND) for the Raven SR Bioenergy Project, Project No. PLN21-282 (Project). We are thankful for the opportunity to share our concerns during this extended comment period. For the reasons described below, we do not believe the analysis supporting the IS/MND is sufficient, and therefore request that you produce a full Environmental Impact Report (EIR).

Raven SR Inc. (Applicant) proposes the construction of a novel technology for creating hydrogen that has no real precedent, making the need to do a thorough environmental impact analysis even more important. We would like to work collaboratively with the City Planning Division to ensure that the already overburdened community in North Richmond does not face any unexpected cumulative impacts from this new project. While the project is being touted as green, such claims should not influence the need for thorough in-depth analysis of Project impacts under the California Environmental Quality Act (CEQA). We believe the City should be asking many more questions, and providing the public with transparent answers about the scope of the Project; and answering them in a full EIR.

I. Outstanding air permit items must be resolved and disclosed in order to properly assess the Project’s potential environmental impact
On May 11, 2022, the Bay Area Air Quality Management District (BAAQMD) determined that the Air Permit Application to construct the Raven SR Bioenergy Project (Application #31700) was incomplete. BAAQMD, as a responsible agency, needs complete information to weigh in on the review; and accordingly, the City needs such information to fully evaluate the Project’s air quality impacts. The Air Permit Application remains a live application LETTER 9
9-1
CONT.
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under review and the City’s IS/MND does not include a disclosure or assessment of essential information requested by BAAQMD in its letter.

Specifically, BAAQMD flagged a staggering 57 missing or incomplete items that still need to be disclosed and analyzed, including important information needed to assess community health impacts—such as missing Health Risk Assessment (HRA) forms for specific emission sources, missed potential sources of emissions (i.e. lime stored onsite and biochar if stored onsite), confirmation that formaldehyde would not be released from the bioengines, and clear enforceable limits on flare use. Until and unless all 57 concerns are addressed, the City should not move forward with a MND. Full information regarding air pollutant loads and impact is all the more important because the Project would be located in an already overburdened community.

II. Exceedances of chronic and acute thresholds for toxic chemicals trigger the need for a Health Risk Assessment (HRA)
Based on the current version of the BAAQMD Air Permit Application, emissions from the biogas engines powered by landfill gas (LFG) exceed chronic and acute thresholds that trigger the need for a Health Risk Assessment (HRA) under Rule 2-5 for eight different toxic chemicals. Acute HRA limits are exceeded for formaldehyde, while chronic limits are exceeded for 1,3-butadiene, acetaldehyde, acrolein, ammonia, benzene, diesel particulate matter (PM), formaldehyde, and naphthalene.

We also request that the City be conservative in determining the scope of an HRA for these chemicals. According to the Initial Study, an HRA was not conducted for the impacts of diesel PM from construction because sensitive receptors are not within 1,000 ft of the site and due to “trigger levels not applying to the project”. However, there are sensitive receptors (residences) within 0.75 miles, an elementary school within 1.1 mile and a health clinic within

1.2 miles, which is still close enough to warrant full analysis. In reviewing Rule 2-5, it is unclear why HRA trigger levels would not apply to this project. Further, while emissions of criteria pollutants NOx and VOCs are estimated to be below the BAAQMD threshold for significant impact, they are extraordinarily close to the threshold. NOx emissions are estimated at 9.05 tons per year (tpy) and VOCs at 9.19 tpy, both with a threshold of 10 tpy.

III. Cumulative pollution impacts should be considered more fully Increased emissions from this project adds to the cumulative pollution impacts of the many projects currently in operation and primed for development in North Richmond and adjacent Richmond areas—which is one of the most pollution burdened areas of the state.1 Full 1 OEHHA, CalEnviroScreen 4.0. Available at https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40. 9-2
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and robust cumulative impacts analysis, as required under CEQA, is thus particularly critical here.

Two cumulative impacts stand out with particular importance. First, there will be increased truck traffic as a result of this project, which is expected to add 100 trips per day of heavy duty trucks. The Initial Study minimizes the importance of this increase as ‘not significant’ because the area already has high truck volumes. However, this reasoning is exactly backwards: the existing high truck volumes points to the need to carefully assess potential cumulative impacts from even more heavy duty trucks. This is particularly so given, as described above, how close NOx and VOC pollutant emissions will potentially come to the BAAQMD threshold for significant impacts.

Second, there are two other hydrogen-related projects being evaluated by and/or within the City that are not recognized in this IS/MND:2,3 Chevron has proposed to expand its production of hydrogen for retail sale and Chevron has also proposed an almost certainly related application to construct a hydrogen fueling station. Chevron’s production expansion will result in increased air pollutant emissions; and it is very possible, in the absence of information to the contrary, that the hydrogen produced at the Project would be marketed via, inter alia, the proposed filling station. Yet these two other projects were not even mentioned in the MND.

All three projects should have been addressed in the IS/MND for a cumulative impacts analysis. Pollution increases from the Chevron production project should have been considered cumulatively with pollutant emissions from this Project. To the extent it remains unclear whether the hydrogen produced by the Raven project will be marketed at the proposed Chevron filling station, the City should have asked that question of Chevron and Raven, and adjusted its analysis accordingly - possibly even considering the two projects in one EIR, but at the very least considering their impacts cumulatively. Richmond is overall being driven toward a hydrogen economy that has the potential to be highly polluting, risking the health and safety of residents4,5; and it behooved the City to consider that direction as a whole before simply signing off on only one corner of it.
5 Raven SR, Renewable fuels company Raven SR announces strategic investment from Chevron, ITOCHU, Hyzon Motors and Ascent Hydrogen Fund. Available at
https://ravensr.com/investment-from-chevron-itochu-hyzon-motors-and-ascent-hydrogen-fund/. 4Chevron U.S.A. Inc., Chevron, Iwatani Announce Agreement to Build 30 Hydrogen Fueling Stations in California.

Available at
https://www.chevron.com/newsroom/2022/q1/chevron-iwatani-announce-agreement-to-build-30-hydrogen-fueling-s tations-in-california.
3 Raven SR, Renewable fuels company Raven SR announces strategic investment from Chevron, ITOCHU, Hyzon Motors and Ascent Hydrogen Fund. Available at
https://ravensr.com/investment-from-chevron-itochu-hyzon-motors-and-ascent-hydrogen-fund/. 2Chevron U.S.A. Inc., Chevron, Iwatani Announce Agreement to Build 30 Hydrogen Fueling Stations in California.

Available at
https://www.chevron.com/newsroom/2022/q1/chevron-iwatani-announce-agreement-to-build-30-hydrogen-fueling-s tations-in-california.
9-3
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IV. The biogas engines using landfill gas involves combustion, and the air pollution impacts of this combustion should be analyzed in more detail Landfill gas is primarily methane and CO2, but it also contains many toxic chemicals from the landfill contents. Based on past studies, biogas engines have potential to emit multiple toxic chemicals that are associated with the landfill contents.6 The Project includes the use of biogas engines to power the hydrogen extraction and purification process, and results in emissions of both criteria air pollutants and toxic air contaminants. While the Initial Study mentions the existing biogas engines already onsite and a lower emission profile from the new engines, it does not appear that the likely increased volume of landfill gas processed by the biogas engines was taken into account. A thorough multi-criteria lifecycle assessment is important to understanding the relevant air quality impact of the new biogas engines.

V. The odor mitigation plan is inadequate
The proposed odor mitigation measures are insufficient. The Initial Study states that the method of odor control would be to employ “control measures similar as those currently employed by WCCSL [West Contra Costa Sanitary Landfill].” However, those measures have already proven insufficient, as local residents are currently complaining of odors from WCCSL.

Moreover, possible solutions are framed as a form of deferred mitigation, a proposal to address an odor problem only if it arises later rather than a plan to address it from the start.

CEQA requires concrete and immediate mitigation plans, not promises to develop mitigation in the future.

And it is fairly clear that odor is going to be a problem. The site of this facility that would have piles of putrescible green waste is approximately 158 feet closer to residences than the existing composting facility. The IS claims that “nuisance odor from Raven is unlikely since feedstock material would only be on the feedstock management area floor for relatively short periods of time.” However, the air permit lists the duration of feedstock onsite as 12 hours. Since the facility is running 24/7, it seems unavoidable that there would be compost and green waste onsite at all times.

VII. Potential to convert and create other fuels
Finally, the Raven SR patented technology covers other fuel products that have greater climate implications than hydrogen. We question whether the intended use of the facility is fully 6 Konkol et al, 2022. Biogas Pollution and Mineral Deposits Formed on the Elements of Landfill Gas Engines. Materials. Available at https://www.ncbi.nlm.nih.gov/pmc/articles/PMC8999940/ 9-4 9-59-6
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disclosed, and whether there is any potential that the facility could be used down the line to make liquid fuels such as alternative aviation fuel. The Initial Study should have explored that possibility.

VI. Conclusion
We appreciate the opportunity to comment on this project and are especially grateful for the extension of the comment period. We hope to work collaboratively with the City to ensure the full consideration of impacts to the community of North Richmond.

Sincerely,
Connie Cho, CBE Attorney
Tessa Wardle, CBE Staff Researcher
Communities for a Better Environment
Teresa Cheng, Senior Campaign Representative
Sierra Club
Faraz Rizvi, Campaign and Policy Manager
Asian Pacific Environmental Network
Katt Ramos, Managing Director
Richmond Our Power Coalition
Kiara Pereira, Just Transition Organizer
Rafael Castro, Just Transition Organizer
Urban Tilth
Ann Alexander, Senior Attorney
Natural Resources Defense Council
9-6
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1187
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 33 Responses to Letter 9 - Environmental Justice Groups 9-1 The comment asserts that the outstanding air permit items for the proposed project must be resolved and disclosed in order to properly assess the project’s potential environmental impact. The CEQA and permitting processes are separate and distinct. The pendency of the air permit should not impact the CEQA process, rather the air permit will be constrained by CEQA.

The project applicant is working closely with the BAAQMD to acquire an air permit for the project. The information provided in the IS/MND reflects the best air emissions data available from the applicant at the time of publication for determining significance of the project. The final IS/MND include updates to the emission totals that are associated with updates to the permit application materials due to the applicant’s discussions with the air district. The emissions presented in the IS/MND are not anticipated to undergo any considerable changes prior to the issuance of an air permit. As such, the IS/MND is reflective of the best available information for assessing potential impacts to the atmospheric environment under BAAQMD guidance. No further analysis is warranted. 9-2 The comment asserts that exceedances of chronic and acute thresholds for toxic chemicals trigger the need for a Health Risk Assessment (HRA). The emissions of toxic air contaminants do exceed trigger thresholds for an HRA under air permitting rules and a HRA will be produced as part of the air permitting process. For permitting, a HRA is triggered by the project exceeding emission limits, irrespective of its location and proximity to sensitive receptors. However, under CEQA, we use HRA as a tool to answer checklist question 3 - whether the project would expose sensitive receptors to substantial pollutant concentrations. The BAAQMD recommends methodology and thresholds that can be used in this CEQA analysis. Since the checklist question specifically talks about exposure of sensitive receptors (and not emissions levels), using the BAAQMD's recommended zone of influence of 1000 feet is a reasonable way to screen for impacts and determine a less than significant impact if there are no receptors within that distance
For the proposed project and under the BAAQMD CEQA guidance, an HRA must be conducted for sensitive receptors identified within 1,000 feet of the project facility property line. However, no sensitive receptors exist within that buffer distance, nor within a distance of 2,000 feet of the property line. Given that the project does not have sensitive receptors within the distances indicated by the BAAQMD, an HRA was not developed as part with e CEQA IS/MND, but an HRA will be produced as part of the air permitting process. No further analysis is warranted.
9-3 The comment asserts that cumulative pollution impacts should be considered more fully in the IS/MND analysis. Similar to Response to Comment 9-2 regarding developing a HRA, the BAAQMD guidance indicates that a cumulative health risk analysis should be conducted for all sources within 1,000 feet of the project property line, but no the BAAQMD screening tool indicates that no additional sources exists within that distance. Additionally, no sensitive receptors are within 1,000 feet of the project property line, thereby negating the need for an HRA. A cumulative risk analysis is not provided as part of the IS/MND.

No further analysis is warranted.
9-4 The comment claims that the biogas engines using landfill gas involve combustion, and the air pollution impacts of this combustion should be analyzed in more detail than presented in the IS/MND analysis. The air permitting process being conducted by the applicant to acquire a permit from the BAAQMD will 1188
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 34 provided the additional detail that is being requested. As noted in Response to Comment 9-1, the most up to date estimates of air emissions from operation of the facility have been provided in the IS/MND and compared against the BAAQMD’s thresholds for significance. No further analysis is warranted. 9-5 The comment opines that the odor mitigation plan is inadequate due to the efficacy of the existing WCCSL odor control measures, the operational storage characteristics of the feedstock materials. The comment also cites that the project operation would be approximately 158 feet closer than the existing WCCLS to existing residents; that distance is currently 1,750 feet from the WCCSL.

The IS/MND states that “nuisance odor from Raven is unlikely since feedstock material would only be on the feedstock management area floor for relatively short periods of time.” The project applicant and operator, in coordination with City and BAAQMD staff, have further detailed the draft conditions of approval to fully address Raven operations specifically. As stated in Response to Comment 1-4, all incoming organic feedstock material shall be received and stored under roof in designated areas and shall be processed within 48 hours of receipt. Response to Comment 1-4 further details the requirements of Condition No. 19.3 that is consistent with Contra Costa County requirements prior to commissioning and operation of the facility. As with all conditions of approval, the proposed project’s adherence is presumed as part of the project, even though full text of conditions may not be stated in the environmental document.

The environmental impact under CEQA remains less than significant according to the applicable CEQA significance criteria, as analyzed in IS/MND Section 4.3, Air Quality (criterion “d”), which assumes adherence to Condition 19.3. No mitigation measure is required. For clarity and update, the following update is made to the IS/MND:
 Section 4.3, Air Quality, Criterion “d” (p. 41): Nuisance odor from Raven is unlikely since feedstock material would only be on the feedstock management area floor for relatively short periods of time; all incoming organic feedstock material shall be received and stored under roof in designated areas and shall be processed within 48 hours of receipt, pursuant to project Condition No. 19.3, which is incorporated as part of the proposed project… …The project may will incorporate control measures similar to those current employed by WCCSL, but expanded and tailored per project Condition No. 19.3, such as ensuring the input of feedstock into the system within a designated period of time from receiving it from WCCSL’s onsite organic material processing facility to prevent potential odor buildup; routine cleaning of floors, walls, and equipment; use of odor suppressants as deemed necessary. Also pursuant to Condition No. 19.3, oOdor control would be added to the management area if objectionable odors occur. The Raven facility could would also store topical treatment solutions (non-toxic and biodegradable) onsite, which would be applied to neutralize odors if an immediate need arises.
________________________
1189
November 7th, 2022
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Lydia,
I am writing in support of Raven SR’s Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service’s West Contra Costa County Sanitary Landfill.

Raven’s Waste to Renewable Hydrogen Project will provide important progress enabled by innovations in California policy and the hydrogen industry. Raven SR is providing the City of Richmond the opportunity to showcase a new hydrogen production technology that will revolutionize waste-to-hydrogen production. The focus in California policy on renewable content and carbon intensity enables the diversity of hydrogen production methods to make the best use of renewable feedstocks in California. Innovations improving the gaseous hydrogen approach by companies like Shell Hydrogen – including high-pressure high-capacity tube trailers that triple capacity while halving cost and refueling stations that enable up to 95% usable fraction – enable a market for distributed hydrogen production with significant benefits for the safety, environment, and economy in California. Please consider:
• New hydrogen production facilities can be built by a wide range of innovative companies, deploying technologies and production pathways that make the very best use of renewable resources in California.
• New hydrogen production facilities can be built in California, close to market, making use of local renewable resources and creating local employment and economic development.
• Hydrogen supply for mobility can become reliable and resilient most quickly, with rapid increase in the number and diversity of production facilities and in the aggregate hydrogen storage capacity in the system.
• Distributed gaseous hydrogen supply for mobility can be safer, lower cost and lower carbon intensity than centralized liquid hydrogen by avoiding the capital cost and energy requirements for liquefaction; minimizing the road transport distances, LETTER 1010-1
1190
costs, and emissions; and enabling storage without product loss to boil-off.

In closing, Shell is committed to a low carbon energy future, with more and cleaner energy, and is working to become a net-zero energy business by 2050 or sooner in step with society. Shell already offers customers a range of decarbonized renewable power, fuels, and energy products, including hydrogen dispensed as a transportation fuel. Thank you for your consideration and I respectfully ask that you approve Raven SR’s CUP application and the CEQA MND so they may begin construction this year and start production in early 2023.

Sincerely,
Humberto Orantes
Acting Commercial Head, North America
Shell Hydrogen
10-1 CONT.
1191
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 37 Responses to Letter 10 - Shell Hydrogen
10-1 The comment is in support of the proposed Project and does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision-makers as they consider the Project and whether or not to approve it.
________________________
1192
POWER ENGINEERS, INC.
2041 SOUTH COBALT POINT WAY
MERIDIAN, ID 83642 USA
PHONE
FAX
208-288-6100
208-288-6199

BOI (2022-11-07) JPH
Lydia Elias November 7, 2022
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Subject: Raven SR Conditional Use Permit (CUP)
Dear Lydia,
I am writing to provide my support of Raven SR’s Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service’s West Contra Costa County Sanitary Landfill.

Raven SR has developed a new hydrogen production technology for waste-to-hydrogen production. Richmond will be their first location, and the community has a significant opportunity to receive attention in the current pro-hydrogen focus by the State of California and Department of Energy. In addition to providing clean hydrogen fuel for the Bay area, Raven will also help Richmond further divert waste from landfills to meet California’s SB 1383’s goal of reducing organic waste disposal by 75% from 2014 levels (up to 27 M tons of organic waste) by 2025.

The development of the Raven systems will generate jobs not only in Richmond, but also ancillary jobs through the fabrication, fuels providers, engineering, waste management and so many other areas. Raven has signed a Project Labor Agreement with the Contra Costa Building & Construction Trades Council and the I.B.E.W. Local #1245.

Because Raven’s system is non-combustion with minimal emissions, they will actually be reducing methane and short-lived climate pollutants from the landfill, and there will be a positive reduction in greenhouse gases. This is such a positive aspect to improving the air around the Richmond area.

California has taken a leadership role in the nation for launching the hydrogen economy, and Richmond has the opportunity with Raven SR to lead the advancement of clean fuels production, emissions reduction, and reversing climate change in the East Bay region.

Thank you for your consideration and we respectfully request you approve Raven SR’s CUP application and the CEQA MND so they may begin construction this year.

Respectfully Submitted,
James P. Hays, PE
Business Unit Director, POWER Engineers
LETTER 1111-1
1193
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 39 Responses to Letter 11 - Powers Engineers
11-1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment also opines that the proposed Project’s non-combustion system would reduce methane and short-lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision-makers as they consider the Project and whether or not to approve it.
________________________
1194
Trails for Richmond Action Committee
TRAC
73 Belvedere Avenue
Richmond, CA 94801
Phone/Fax 510-235-2835
[email protected]
October 27, 2022
VIA Email:

Ms. Lydia Elias, Planner I
City of Richmond Planning Division
Dear Ms, Elias:

TRAC, the Trails for Richmond Action Committee, would like to comment on the October 7 Draft IS/MND for the Raven SR Bioenergy Project (PLN21-282).

The project site is very close to the Landfill Loop Trail, which is part of the regional San Francisco Bay Trail as shown on the attached Bay Trail map for Richmond. However, the draft IS/MND in many locations erroneously refers to the Wildcat Marsh Trail, e.g. in Sections 1.10, 2.9 & 4.1a and on Figure 4.1-1. The Wildcat Marsh Trail is located on West County Wastewater District property, whereas the Landfill Loop Trail is located on the Republic Services site of the Raven SR facility as shown by the attached orientation map posted at the Landfill Loop trailhead staging area.

Section 4.12 Noise and Vibration: The nearest noise-sensitive receptors would be those walking, bicycling and bird watching on the Landfill Loop Trail. Noise impacts on trail users should be assessed and mitigated as appropriate.

TRAC hopes that these comments will prove helpful in finalizing the IS/MND.

Sincerely,
Bruce Beyaert, TRAC Chair
Attachments:

Richmond Bay Trail Map
Wildcat Marsh & Landfill Loop Trail orientation map

LETTER 1212-1 12-2
1195

14.6” x 17.3” — Garrard Blvd.

Atlas Rd
San Pablo
80 580
Point San Pablo Yacht Harbor
Point Molate Beach Park
Point Pinole Regional
Shoreline
Point San Pablo
Point Wilson
Winehaven
Historic District
Shimada Park
Miller-Knox Regional
Shoreline
Point Isabel
Regional
Shoreline
Jay &
Barbara Vincent Park
RichmondSan Francisco
Ferry Terminal
Lucretia
Edwards
Park
Rosie the Riveter/
WWII Home Front
NHP Visitor Center
SS
Red Oak
Victory
Marina
Bay Park
Richmond
BART Station
E
P
B
S
El Cerrito del Norte BART Station
Cutting Blvd
Marina Bay
Gertrude Ave
Castro St
Hensley St
Richmond
El Cerrito
Richmond
y Wa inr a M
Keller
Beach
Ferry
Point
Point Molate
BrooksIsland
Point Potrero
Hall
Wright
Nevin Ave
Barrett Ave
Pennsylvania Ave
Ohio Ave
To Point Isabel
Regional Shoreline
Richmond Greenway
Landfill
Loop Trail
Boat Ramp St
Richmond Museum of History
West Macdonald
Point
Richmond 23rd St
Kaiser Shipyard 3
Richmond
Goodrick Ave
51st St
Wildcat Creek Trail
Canal Blvd
Harbour Way Soutn
Ho
man
Trail Open — Pilot Project
Richmond-San Rafael Bridge
Garrard Blvd
Regatta Blvd
Dornan Dr
Brickyard Cove
Pkwy Marina Bay
Open
Fall 2019
Ohlone Greenway
Wildcat
Marsh
Trail
Richmond
Wellness
Trail
Richmond Pkwy
Parkway
San Pablo Ave
Stenmark Dr
Welcome to
Richmond
August 2022
Over 36 miles of Bay Trail
linking a necklace of
12 shoreline parks
0 MILES

0.25 0.5 0.75 1
Bay Trail
Complete
Incomplete
Connector Trail
Complete
Incomplete
Parks/Open Space
Water Trail site
Water Trail site
(planned)
Water Bodies
Raven SR Bioenergy 1196
A part of the San Francisco Bay Trail
The story of this portion of the Bay Trail is one
based on the very essence of today's meaning
of ''green.'' Non-existent until now, the trail
incorporates fantastic views of San Pablo Bay,
Wildcat and San Pablo Creeks with remarkable examples of industrial water conservation and reuse, resource recovery, electrical generation, recycling and recreation.

Map Legend
~*'~' •• -·
~*'-J ■■■■■■■■■■■■■■■
Bay Trail suitable for walking, biking,
roller skating & wheelchair access
Bay Trail of compacted aggregate
c::.
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Distance markers and mileage
between two markers ~ Retention Pond
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~ Parking m Drinking Water
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AS A WORKING INDUSTRY, Republic Services has
established regulations that will assure continued public enjoyment of this unique portion of the Bay Trail that is located on private landfill property. Visitors use the trail at their own risk.

NORTH
'
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NOT ALLOWED: No dogs (excepting seeing eye dogs)
or horses. No fishing or swimming, fires, fireworks or
firearms, smoking, camping, motorized vehicles, boating, alcoholic beverages, straying off trail, climbing fences or on shoreline riprap, or feeding of wildlife. Bicycles are not allowed on the upper trail.

Credit for the Landfill Loop Trail goes to Larry Burch and Jay Vincent for their vision, and to Republic Services, Inc., and the Trails for Richmond Action Committee (TRAC) for carrying out this vision. Credit for the Wildcat Marsh Trail goes to East Bay Regional Park District for building and maintaining it, to West County Wastewater District for making their land available, and to funding from both the San Francisco Bay Trail Project and voter approval of East Bay Regional Park District Measure CC. :ni1.18mi
Compost
Garbage Mountain
(158 1 elevation)
Green Waste
Construction
& Demolition
Pickleweed Marsh
, mi
~
HOURS: The Landfill Loop Trail is generally open 8:30
a.m. to 4 p.m., seven days a week. The gates are
locked at 5 p.m. The trail will be closed on the
following holidays: New Year•s Day, Easter, July 4,
Labor Day, Thanksgiving and Christmas. Some trail
sections may be closed for routine maintenance. Call
510-262-1660 for trail information. Wildcat Creek Trail Head and Wildcat Marsh Trail are open dawn to dusk.
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1197
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 43 Responses to Letter 12 - Trails for Richmond Action Committee (TRAC) 12-1 The comment distinguishes the existing Landfill Loop Trail from the Wildcat Marsh Trail, both of which are part of the regional San Francisco Bay Trail. In the following instances, the IS/MND is updated to specify the two facilities that exist near to the proposed Project site.  Section 1.10, p. 6: Figure 1-3 shows the closest structure and development is the Golden Bear Waste Recycling Facility approximately 300 feet southwest of the proposed project location, and the West County Wastewater District Treatment Plant and the Landfill LoopWildcat Marsh Trail and trail head parking exist approximately 1,000 feet east of the project location.
 Section 2.9, p. 22: As part of the proposed project, off-site landscaping improvements to the Landfill LoopWildcat Marsh Trail and trail head parking located approximately 1,000 feet east of the project location. Due to limited space and potential safety hazards, no new plants or vegetation will be installed within the Raven project site. Instead, new trees will be added to the public parking area near the trailhead.
 Section 4.1a and Figure 1-1: Figure 4.1-1, Landfill LoopWildcat Marsh Trail Approach Toward Project Site (from East), captures part of the project site that would be visible to users of this public trail.

These modifications do not change the adequacy of the analysis or impacts identified in the IS/MND, and no further analysis is warranted, pursuant to the findings enumerated in Section 1 of this memo. 12-2 The comment asserts that trail users should be considered the nearest noise-sensitive receptors to the proposed Project and factored into the noise analysis. This consideration would not be consistent with the City’s established approach to noise analyses in other CEQA documents for project located adjacent to public trails. Moreover, users of the trail would be electing their activity in the noise environment and would be a temporary, relatively short-term recreational users, unlike residences, schools and medical facilities or wildlife species. No additional analysis is warranted in response to the comment. ________________________
1198
@Benicia
Fabrication
&Machine
10/20/2022
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Lydia,
I 01 East Channel Rd
Benicia, CA 94510
Phone (707) 745-8111
Fax (707) 745-8102
www.beniciafab.com
I am writing to provide our company's support of Raven SR's Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service's West Contra Costa County Sanitary Landfill.

Raven SR has developed a new hydrogen production technology that will revolutionize waste-to-hydrogen production, and as Richmond will be their first location, the community has a significant the opportunity to receive attention in the current pro-hydrogen focus by the State of California and Department of Energy. In addition to providing clean hydrogen fuel for the Bay area, Raven will also help Richmond further divert waste from landfills to meet California's SB 1383's goal of reducing organic waste disposal by 75% from 2014 levels (up to 27 M tons of organic waste) by 2025.

Because Raven's system is non-combustion with minimal emissions, they will actually be reducing methane and short-lived climate pollutants from the landfill, and there will be a positive reduction in greenhouse gases. This is such a positive aspect to improving the air around the Richmond area.

Thank you for your consideration and we respectfully request you approve Raven SR's CUP application and the CEQA MND so they may begin construction this year and start production in early 2023. sQJ
~ :I Santiago
CEO & President
Benicia Fabrication & Machine, Inc.
13-1
1199
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 45 Responses to Letter 13 - Benicia Fabrication & Machine 13-1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment also opines that the proposed Project’s non-combustion system would reduce methane and short-lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision-makers as they consider the Project and whether or not to approve it.
________________________
1200
Contra Costa Building and Construction Trades Council
2727 Alhambra Ave. Suite 5
Martinez, CA 94553
FAX (925) 372-7414
October 17, 2022
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Ms. Elias,
Bill Whitney
C.E.O.

Phone (925)228-0900
On behalf of the Contra Costa Building & Construction Trades Council we are writing in support of Raven SR's Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service's West Contra Costa County Sanitary Landfill.

Raven SR is poised to place the City of Richmond front and center in the production of clean hydrogen fuels not only in the Bay Area, but in the State of California. We have the opportunity to showcase a new hydrogen production technology that will revolutionize waste-to-hydrogen production. No longer will we be dependent on our hydrogen being shipped in from out of state, and we will ensure energy security for the owners of commercial and passenger hydrogen vehicles.

In addition to providing clean hydrogen fuel to our community, Raven will also help the City further divert waste from landfills to meet California's SB 1383's goal of reducing organic waste disposal by 75% from 2014 levels (up to 27 M tons of organic waste) by 2025.

Because Raven's system is non-combustion with minimal emissions, the company will actually be reducing methane and short-lived climate pollutants from the landfill, and we will see a positive reduction in greenhouse gases in our community. Clearly this project advances the production of clean fuels, as well as reducing emissions, and a crucial step in reversing climate change.

This project will be built with a PLA which means middle class, skilled and trained Union jobs. Local hire, apprenticeship training, and a veteran hire program are additional community benefits of the PLA.

We respectfully request that you approve Raven SR's CUP application and the CEQA MND so they may begin construction this year, which creates jobs for our Union workers, and starts the production of clean hydrogen as early as 2023.

Sincerely,
"v/)J_____/4,
William Whitney
14-1 LETTER 14
1201
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 47 Responses to Letter 14 - Contra Costa Construction and Building Trades Council
14-1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment also opines that the proposed Project’s non-combustion system would reduce methane and short-lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision-makers as they consider the Project and whether or not to approve it.
________________________
1202
WATLOW.

October 14, 2022
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Lydia,
I am writing to provide Watlow's support of Raven SR's Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service's West Contra Costa County Sanitary Landfill.

Raven SR has developed a new hydrogen production technology that will revolutionize waste-to-hydrogen production, and Watlow has been a proud technology partner providing our thermal expertise, engineering assistance and partnership towards this exciting and promising new technology.

We commend Richmond's vision and leadership becoming the first location to implement Raven's SR2 Reformer, representing the opportunity to receive both recognition and attention by the State of California and Department of Energy related to their desire to promote the hydrogen economy.

Watlow remains committed to Raven's efforts and we share a passion for providing leading products and solutions contributing to the advancement of clean fuels production, emissions reduction and energy transition.

Thank you for your consideration and we respectfully request that you approve Raven SR's CUP application and the CEQA MND so they may begin construction this year and start production in early 2023.

Please let me know if Watlow can be of any further assistance to you on your decision process.

Sincerely,
Dr. Ashish Bhatnagar
Chief Technology Officer
Watlow
12001 Lackland Road • St. Louis, M i ssouri 63146 USA
Phone: 314-878-4600 • www .watlow.com
15-1
1203
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 49 Responses to Letter 15 - Watlow
15-1 The comment is in support of the proposed Project and does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision-makers as they consider the Project and whether or not to approve it.
________________________
1204
IRON WORKERS LOCAL 378

UNION OFFICE OF BRIDGE, STRUCTURAL, ORNAMENTAL AND REINFORCING 3120 Bayshore Road, Benicia CA 94510 | www.ironworkers378.org P. (707) 746-6100 | F. (707) 746-0979
Jason
October 13, 2022
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Mrs. Elias,
On behalf of the Iron Workers Local 378, we are writing in support of Raven SR’s Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service’s West Contra Costa County Sanitary Landfill.

Raven SR is poised to place the City of Richmond front and center in the production of clean hydrogen fuels not only in the Bay Area, but in the State of California. We have the opportunity to showcase a new hydrogen production technology that will revolutionize wasteto-hydrogen production. No longer will we be dependent on our hydrogen being shipped in from out of state, and we will ensure energy security for the owners of commercial and passenger hydrogen vehicles. It may even generate additional drivers coming to our community to fuel their cars, increasing our retail and gas revenues.

In addition to providing clean hydrogen fuel to our community, Raven will also help the City further divert waste from landfills to meet California’s SB 1383’s goal of reducing organic waste disposal by 75% from 2014 levels (up to 27 M tons of organic waste) by 2025. In an era when disadvantage communities are pleading for improvements, Raven SR is providing us solutions. Because Raven’s system is non-combustion with minimal emissions, the company will actually be reducing methane and short-lived climate pollutants from the landfill, and we will see a positive reduction in greenhouse gases in our community. It is a win-win all the way around! California has taken a leadership role in the nation for launching the hydrogen economy, and Richmond has the opportunity with Raven SR to take our place in the advancement of clean fuels production, emissions reduction, and reversing climate change.

Thank you for your consideration and we respectfully request that you approve Raven SR’s CUP application and the CEQA MND so they may begin construction this year, creating jobs for our Union Iron Workers, and start production of clean hydrogen in early 2023.

Best Regards,
Jason Gallia
Business Manager
Financial Secretary/Treasurer
JG:ym
opeiu-29/afl-cio
Jason Gallia
Business
Manager/Financial
Secretary-Treasurer
Jason Lindsey
President/Business
Agent
James Ashcroft
Business Agent
Ken Miller
Business Agent/
Organizer
LETTER 16 16-1
1205
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 51 Responses to Letter 16 - Iron Workers Local 378
16-1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment also opines that the proposed Project’s non-combustion system would reduce methane and short-lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision-makers as they consider the Project and whether or not to approve it.
________________________
1206
Local Union No. 302
INTERNATIONAL BROTHERHOOD OF ELECTRICAL WORKERS REGULAR MEETING 4TH WEDS. EACH MONTH EXECUTIVE BOARD MEETS 3RD WEDS. EACH MONTH 1875 ARNOLD DRIVE MARTINEZ, CALIFORNIA 94553-4239
October 13, 2022
Lydia Elias
City of Richmond
TELEPHONE (925) 228-2302 • FAX (925) 228-0764
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Ms. Elias,
On behalf of the Members of IBEW Local 302 we are writing in support of Raven SR's Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service's West Contra Costa County Sanitary Landfill.

Sincerely,
Tom Hansen
Business Manager
Financial Secretary
TH:nlp
OPEIU#29:afl-cio
17-1
1207
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 53 Responses to Letter 17 - Local Union No. 302 International Brotherhood of Electrical Workers
17-1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment also opines that the proposed Project’s non-combustion system would reduce methane and short-lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision-makers as they consider the Project and whether or not to approve it.
________________________
1208
October 10, 2022
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Lydia,
I am writing in support of Raven SR’s Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service’s West Contra Costa County Sanitary Landfill.

Raven SR is providing the City of Richmond the opportunity to showcase a new hydrogen production technology that will revolutionize waste-to-hydrogen production. In addition to providing clean hydrogen fuel to the Richmond community, Raven will also help the City of Richmond further divert waste from landfills to meet California’s SB 1383’s goal of reducing organic waste disposal by 75% from 2014 levels (up to 27 M tons of organic waste) by 2025.

Another plus is that Raven has signed a Project Labor Agreement with the Contra Costa Building & Construction Trades Council and the I.B.E.W. Local #1245. The jobs that Raven SR will be generating for the Richmond community, in addition to the construction jobs to build the plant, are to be commended.

California has taken a leadership role in the nation for launching the hydrogen economy, and Richmond has the opportunity with Raven SR to support the advancement of clean fuel production, emissions reduction, and reversing climate change.

Thank you for your consideration, and I respectfully ask that you approve Raven SR’s CUP application and the CEQA MND so they may begin construction this year and start production in early 2023.

Sincerely,
/s/ Nicholas Connell
Nicholas Connell
Policy Director
Green Hydrogen Coalition
Tel: 949-558-1305
Email: [email protected]
LETTER 18 18-1
1209
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 55 Responses to Letter 18 - Green Hydrogen Coalition
18-1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision-makers as they consider the Project and whether or not to approve it.
________________________
1210
October 10, 2022
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Lydia,
I am writing in support of Raven SR’s Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service’s West Contra Costa County Sanitary Landfill.

Raven SR is providing the City of Richmond the opportunity to showcase a new hydrogen production technology that will revolutionize waste‐to‐hydrogen production. In addition to providing clean hydrogen fuel to our community, Raven will also help the City further divert waste from landfills to meet California’s SB 1383’s goal of reducing organic waste disposal by 75% from 2014 levels (up to 27 M tons of organic waste) by 2025.

I believe that because Raven’s system is non‐combustion with minimal emissions, the company will actually be reducing methane and short‐lived climate pollutants from the landfill, and we will see a positive reduction in greenhouse gases in our community. For once, a company that is trying to improve our environment!
Another plus is that Raven has signed a Project Labor Agreement with the Contra Costa Building & Construction Trades Council and theI.B.E.W. Local #1245. The jobs that Raven SR will be generating for our community, in addition to the construction jobs to build the plant, are to be commended. Jobs in Benicia will also be impacted with Benicia Fabrication, a subsidiary company, that is building the reforming units for the project. Benicia Fabrication is located in the Industrial Park of Benicia and founded in 1983. It specializes in the repair, maintenance and new construction of pressure vessels, heat exchangers and miscellaneous industrial equipment.

California has taken a leadership role in the nation for launching the hydrogen economy, and Richmond has the opportunity with Raven SR to take our place in the advancement of clean fuels production, emissions reduction, and reversing climate change.

Thank you for your consideration and I respectfully ask that you approve Raven SR’s CUPapplication and the CEQAMNDso they may begin construction this year and start production in early 2023.

Sincerely,
Christina Strawbridge
19-1 LETTER 19
1211
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 58 Responses to Letter 19 - Christina Strawbridge
19-1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision-makers as they consider the Project and whether or not to approve it.
________________________
1212
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1213

APP - A

ATTACHMENT A
Final Mitigation Monitoring and Reporting
Program (MMRP) (Update to IS/MND Appendix C)
1214
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1215
Raven SR Bioenergy Project A-1 ESA / D202100382
November 30, 2022

FINAL UPDATED MITIGATION MONITORING AND REPORTING PROGRAM Project Mitigation Measures
Implemented
By Monitored By
Monitoring and Reporting
Action
Monitoring
Schedule
Verification of
Compliance

4.1 Aesthetics – None Required

4.2 Agriculture and Forestry Resources – None Required

4.3 Air Quality
(Expanded) Mitigation Measure AQ-1: Best Management
Practices.
 All subsequent projects, regardless of size, shall
implement the following best management practices to
reduce construction impacts, particularly fugitive dust, to a less-than-significant level:
 All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day, except when not required
for dust control.
 All haul trucks transporting soil, sand, or other loose material off-site shall be covered.
 All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street
sweepers at least once per day. The use of dry power
sweeping is prohibited.
 All vehicle speeds on unpaved roads shall be limited to 15 mph.
 All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.
 Idling times shall be minimized either by shutting
equipment off when not in use or reducing the maximum
idling time to 5 minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations [CCR]). Clear signage shall be provided for construction workers at all access points.  All construction equipment shall be maintained and
properly tuned in accordance with manufacturer’s
specifications. All equipment shall be checked by a
certified mechanic and determined to be running in proper condition prior to operation.

Project Applicant /
Construction
Contractor
Richmond
Building Division
and Engineering
Services
Department
Richmond Engineering Services
Department to verify inclusion of
BAAQMD BMPs in applicable
construction plans and specifications.

City of Richmond Building Division to
inspect site during construction to
ensure compliance with Project
construction plans.

Prior to issuance of
building permit.

Field inspections
during construction.

Verified by:

Date:
1216
Final Updated Mitigation Monitoring and Reporting Program Raven SR Bioenergy Project A-2 ESA / D202100382
November 30, 2022
Project Mitigation Measures
Implemented
By Monitored By
Monitoring and Reporting
Action
Monitoring
Schedule
Verification of
Compliance
 Post a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust
complaints. This person shall respond and take corrective action within 48 hours. The Air District’s phone number shall also be visible to ensure compliance with applicable regulations.
 BMP #6: All excavation, grading, and/or demolition
activities shall be suspended when average wind speeds
exceed 20 mph.
 BMP #7: All trucks and equipment, including their tires, shall be washed off prior to leaving the site.
 BMP #8: Unpaved roads providing access to sites located 100 feet or further from a paved road shall be treated with a 6- to 12-inch layer of compacted layer of wood chips, mulch, or gravel.
 Additional BMP: Limit the simultaneous occurrence of
excavation, grading, and ground- disturbing construction activities.
 Additional BMP: Install wind breaks (e.g., trees, fences) on the windward side(s) of actively disturbed areas of
construction. Wind breaks should have at maximum 50
percent air porosity.
 Additional BMP: Plant vegetative ground cover (e.g., fastgerminating native grass seed) in disturbed areas as soon as possible and watered appropriately until vegetation is established.
 Additional BMP: Install sandbags or other erosion control measures to prevent silt runoff to public roadways from sites with a slope greater than one percent.
 Additional BMP: Minimize the amount of excavated
material or waste materials stored at the site.
 Additional BMP: Hydroseed or apply non-toxic soil
stabilizers to construction areas, including previously graded areas, that are inactive for at least 10 calendar days.
 Require zero visible fugitive dust and use fence line air monitoring to demonstrate compliance with this
requirement.
 Set requirements for when dust generating operations
have to be shut down due to dust crossing the property
1217
Final Updated Mitigation Monitoring and Reporting Program Raven SR Bioenergy Project A-3 ESA / D202100382
November 30, 2022
Project Mitigation Measures
Implemented
By Monitored By
Monitoring and Reporting
Action
Monitoring
Schedule
Verification of
Compliance
boundary or if dust is contained within the property
boundary but not controlled after a specified number of minutes.
 Prohibiting grading on days when a Spare the Air is in effect (https://www.sparetheair.org/) Prohibiting grading on days with an Air Quality Index forecast of greater than 100 for particulates for the project area.

4.4 Biological Resources
Mitigation Measure BIO-1: Avoid and Minimize Impacts to Nesting Birds, Except Rails.

To the extent practicable, project construction activities requiring heavy equipment, or any tree trimming, shall be performed outside of the bird nesting season (February 1st through August 31st) to avoid impacts to nesting birds.

Prior to any site
alterations or
issuance of building
permit.

Field inspections
during construction.

Verified by:

Date:

If nesting birds and raptors do not occur within 250 and 500 feet of the Project area, respectively, then no further action is required if construction begins within 14 calendar days.

If active nests are located during the pre-construction bird nesting surveys, no-disturbance buffer zones shall be established around nests, with a buffer size established by the qualified biologist.

Typically, these buffer distances are between 50 feet and 250 feet for passerines and between 150 feet and 500 feet for raptors. These distances may be adjusted depending on the level of surrounding ambient activity and if an obstruction, such as a building or structure, is within line-of-sight between the nest and construction. Reduced buffers may be allowed if a full-time qualified biologist is present to monitor the nest and has authority to halt construction if bird behavior indicates continued activities could lead to nest failure. Buffered zones shall be avoided during construction-related activities until young have fledged or the nest is otherwise abandoned. If active burrowing owl dens are found within the survey area, the project applicant shall implement measures at least equal to the 2012 (or Project Applicant
/ Construction
Contractor
Qualified Biologist
Richmond
Building Division
City of Richmond Building Division to
confirm surveys are conducted
pursuant to specified measures, and if
warranted, that buffer zone distances
are indicated in project plans and
adhered to during construction
activities.

City of Richmond Planning Division to
receive and confirm survey report.

Field inspections
during construction.

Upon completion of
surveys.

Verified by:

Date:
1218
Final Updated Mitigation Monitoring and Reporting Program Raven SR Bioenergy Project A-4 ESA / D202100382
November 30, 2022
Project Mitigation Measures
Implemented
By Monitored By
Monitoring and Reporting
Action
Monitoring
Schedule
Verification of
Compliance
subsequent applicable) CDFW Staff Report (CDFG, 2012), as determined by the qualified biologist.

Fish and Wildlife (USFWS) or the California Department of Fish and Wildlife (CDFW)), shall be avoided during the
breeding season from February 1 through August 31.

Field inspections
during construction.

Verified by:

Date:
 If areas within 500 feet of rail habitat cannot be avoided during the breeding season (February 1 through August 31),
protocol-level surveys shall be conducted to determine rail nesting locations. The surveys will focus on potential habitat that could be indirectly disturbed by construction activities during the breeding season to ensure that rails are not breeding within 500 feet of project activities.
 Survey methods for rails will follow the Site-Specific Protocol for Monitoring Marsh Birds, which was developed for use by USFWS and partners (Wood et al. 2017). Surveys are
concentrated during the approximate period of peak
detectability, January 15 to March 25 and are structured to efficiently sample an area in three rounds of surveys by broadcasting calls of target species during specific periods of each survey round. Call broadcast increase the probability of detection compared to passive surveys when no call
broadcasting is employed. This protocol has since been
adopted by Invasive Spartina Project (ISP) and Point Blue Conservation Science to survey Ridgway’s rails at sites throughout San Francisco Bay Estuary. The survey protocol for Ridgway’s rail is summarized below.
 Previously used survey locations (points) should be used when available to maintain consistency with past survey results. Adjacent points should be at least 200 meters
apart along transects in or adjacent to areas
representative of the marsh. Points should be located to minimize disturbances to marsh vegetation. Up to 8
points can be located on a transect.
 At each transect, three surveys (rounds) are to be
conducted, with the first round of surveys initiated
between January 15 and February 6, the second round
performed February 7 to February 28, and the third round Project Applicant
/ Construction
Contractor
Qualified Biologist
Richmond
Building Division
City of Richmond Building Division to
confirm surveys are conducted
pursuant to specified measures.

City of Richmond Planning Division to
receive and confirm survey report.

Field inspections
during construction.

Upon completion of
surveys.

Verified by:

Date:
1219
Final Updated Mitigation Monitoring and Reporting Program Raven SR Bioenergy Project A-5 ESA / D202100382
November 30, 2022
Project Mitigation Measures
Implemented
By Monitored By
Monitoring and Reporting
Action
Monitoring
Schedule
Verification of
Compliance
March 1 to March 25. Surveys should be spaced at least
one week apart and the period between March 25 to April 15 can be used to complete surveys delayed by logistical or weather issues. A Federal Endangered Species Act
Section 10(a)(1)(A) permit is required to conduct active surveys.
 Each point on a transect will be surveyed for 10 minutes each round. A recording of calls available from USFWS
is broadcast at each point. The recording consists of 5 minutes of silence, followed by a 30-second recording of Ridgway’s rail vocalizations, followed by 30 seconds of silence, followed by a 30-second recording of California black rail, followed by 3.5 minutes of silence.
 If no breeding Ridgway’s rails or black rails are detected during surveys, or if their breeding territories can be avoided by 500 feet (150 meters), then project activities may proceed at that location.
 If protocol surveys determine that breeding Ridgway’s rails or black rails are present in the project area, the following measures would apply to project activities conducted during their breeding season (February 1- August 31):
 The applicant shall coordinate with the USFWS- and
CDFW, as appropriate depending upon species, to
determine if project activities can continue during the nesting season based on nest location, natural visual
barriers (e.g., levees) between the project and
marshlands, and the distance between proposed
activities and identified activity centers. If impact cannot be avoided during the rail nesting season, activities
would be delayed until after the nesting season.

City of Richmond Planning Division to
verify agency coordination and
outcome.

Field inspections
during construction.

Upon completion of
surveys.

Verified by:

Date:

4.5 Cultural Resources
Mitigation Measure CUL-1a: Cultural Resources Awareness Training.

Prior to authorization to proceed, the City shall engage a qualified archaeologist, defined as an archaeologist meeting the U.S.

Secretary of the Interior’s Professional Qualification Standards for Archeology, to conduct a training program for all construction workers involved on site disturbance. On-site personnel shall attend a mandatory pre-project training that outlines the general archaeological sensitivity of the vicinity and the procedures to follow Project Applicant /
Construction
Contractor
Qualified
Archaeologist
Richmond
Building Division
City of Richmond Building Division to
review and confirm documentation of
training, required personnel attending,
and scope of training.

Prior to
commencement of
any ground-disturbing
activities.

Verified by:

Date:
1220
Final Updated Mitigation Monitoring and Reporting Program Raven SR Bioenergy Project A-6 ESA / D202100382
November 30, 2022
Project Mitigation Measures
Implemented
By Monitored By
Monitoring and Reporting
Action
Monitoring
Schedule
Verification of
Compliance
in the event an archaeological resource and/or human remains are inadvertently discovered.

Mitigation Measure CUL-1b: Inadvertent Discovery of Cultural Materials or Tribal Cultural Resources.

Historic-era cultural materials might include building or structure footings and walls, and deposits of metal, glass, and/or ceramic refuse.

If avoidance is not feasible, the City shall consult with a qualified archaeologist and a Native American representative (if the resource is pre-contact) to determine treatment measures to avoid, minimize, or mitigate any potential impacts to the resource pursuant to PRC Section 21083.2 and CEQA Guidelines Section 15126.4. This shall include documentation of the resource and may include data recovery (according to PRC Section 21083.2), if deemed
appropriate, or other actions such as treating the resource with culturally appropriate dignity and protecting the cultural character and integrity of the resource (according to PRC Section 21084.3).

Project Applicant /
Construction
Contractor
Qualified
Archaeologist
If applicable,
Native American
representative
Richmond Building Division to review
and approve of archaeologist, of
cultural resources monitoring plan and
of the construction plan that includes
archaeological mitigation.

If resources are encountered,
Contractor to verify work is suspended
as required, review and approve
qualified archaeologist and
recommendations.

If resources encountered are found to
be qualifying as described in the
measure, the City to ensure
preservation measures are
implemented or that the ARDTP is
completed and submitted to NWIC.

City to inspect site during construction
to ensure compliance with project
construction plans.

Prior to issuance of
building permit for, or
commencement of,
any ground-disturbing
activities.

Field inspections
during construction.

Verified by:

Date:
1221
Final Updated Mitigation Monitoring and Reporting Program Raven SR Bioenergy Project A-7 ESA / D202100382
November 30, 2022
Project Mitigation Measures
Implemented
By Monitored By
Monitoring and Reporting
Action
Monitoring
Schedule
Verification of
Compliance
Mitigation Measure CUL-2: Inadvertent Discovery of Human Remains.

Project Applicant /
Construction
Contractor
Qualified
Archaeologist
Richmond Building Division verify
mitigation measure on construction
plans.

Inspect site during construction to
ensure compliance with project
construction plans.

If needed, engage County Coroner
and ensure NAHC contact.

Prior to issuance of a
building permit for, or
commencement of,
any ground-disturbing
activities.

Field inspections
during construction.

Verified by:

Date:

4.6 Energy – None Required

4.7 Geology, Soils, and Mineral Resources - MM CUL-1a, CUL-1b, CUL-2 (see 4.5, Cultural Resources)

4.8 Greenhouse Gas Emissions – None Required

4.9 Hazards and Hazardous Materials – None Required

4.10 Hydrology and Water Quality – None Required

4.11 Land Use and Planning – None Required

4.12 Noise / Vibration – None Required

4.13 Population and Housing– None Required

4.14 Public Services and Recreation – None Required

4.15 Transportation – None Required

4.16 Tribal Cultural Resources - MM CUL-1a, CUL-1b, CUL-2 (see 4.5, Cultural Resources)

4.17 Utilities and Service Systems – None Required

4.18 Wildfire – None Required
1222
ERRATA SHEET #1
Raven SR Bioenergy Project
Updated Initial Study / Mitigated Negative
Declaration
Raven SR Bioenergy Project 1 ESA / D202100382
ERRATA SHEET #1 to the Updated Initial Study MND March 14, 2023 The following clarifications are made to the Updated Initial Study / Mitigated Negative Declaration published March 9, 2023:

Page 12 ends

number, as follows:
_____________________________
9 To be clear, the proposed project is a separate and independent project from other possible hydrogen-related projects within the City that may be proposed in the near future. The Raven project has a separate and independent owner, located on a separate and independent site, has a separate and completely independent source stream to make hydrogen, is proposing “green” hydrogen, and is seeking separate entitlements.

Additionally, baseline for the Raven project was established at the time that the completed application was filed by the applicant on July 30, 2021. At that time, other hydrogen-related projects were not in the entitlement process with the City. Months later Chevron submitted and application on November 15, 2021, for an alternatives fueling station that would include fueling equipment for hydrogen (H2) and compressed natural gas (CNG). That application did not propose the manufacturing of hydrogen. Additionally, after Raven’s project was received no other application has been received by the City for a hydrogen production project. As a result, the Raven project is not required to analyze the potential cumulative impacts for subsequent/potentially future projects as i) the fueling station application was submitted after the Raven project’s baseline; and/or ii) CEQA does not require analysis of speculative projects that have yet to be received. Finally, any hydrogen-related projects submitted after the Raven project or at some future date would be required to comply with CEQA. As part of that process, those projects would also need to include the Raven project in either the baseline or a reasonably foreseeable project for that project’s initial study – assuming that the type of project impacts overlap for the purposes of a cumulative analysis.

Page 21 ends

While the Raven SR technology can use a variety of potential feedstocks, the selected feedstock for this Project is a blend of urban greenwaste and organic food waste supplied by WCCSL. The first stage of the process to turn feedstock into a raw syngas begins with an externally heated “biomass steam reformer” and a “syngas steam reformer.” The raw syngas is then conditioned, compressed and processed through purification systems to produce hydrogen product: transportation-grade (compliant with SAE J2719) hydrogen. 11 1223
ERRATA SHEET #1
Raven SR Bioenergy Project 2 ESA / D202100382
ERRATA SHEET #1 to the Updated Initial Study MND March 14, 2023

Page 21 ends

11 “Conditioned” or “conditioning” refers to steps in the process to convert residual impurities, primarily sulfur compounds, into a form that can easily be removed from the syngas. If the sulfur is not removed, it will contaminate downstream catalyst/media, deactivating it, significantly reducing performance in downstream processing.

Page 26 ends

Safety and Controls
No Combustion Technology. The Raven SR’s facility’s controls would be distributed through the various process islands, taking their direction from a central Human-Machine Interface in the control room with centralized data collection. Process setpoints would be bounded by high/low alarm limitations to draw the operator’s attention to the specific problem. The control system would represent state-of-the-art digital technology with redundant instrumentation where necessary to ensure safe operation.

Page 27 ends

Safety Standards and Maintenance. Raven SR units are equippedThe project is being designed in accordance with continuous monitoring California Fire Code for all systems and can automatically shut down equipment installation containing flammable, combustible, or hazardous materials, and an equipment maintenance program agreed upon by the City and the Fire Marshall will be implemented.

Page 33 ends

3. Environmental Factors Potentially Affected
The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a “Potentially Significant Impact,” as indicated by the checklist on the following pages.

Aesthetics Agriculture and Forestry Resources Air Quality Biological Resources Cultural Resources Energy
Geology, Soils and Seismicity Greenhouse Gas Emissions Hazards /Hazardous Materials Hydrology and Water Quality Land Use and Planning Mineral Resources Noise/Vibration Population and Housing Public Services
Recreation Transportation Tribal Cultural Resources
Utilities and Service Systems Wildfire Mandatory Findings of Significance 1224
ERRATA SHEET #1
Raven SR Bioenergy Project 3 ESA / D202100382
ERRATA SHEET #1 to the Updated Initial Study MND March 14, 2023

Page 47 ends

TABLE 4.3-1

AVERAGE DAILY CONSTRUCTION-RELATED CRITERIA POLLUTANT EMISSIONS (TONS PER YEARPOUNDS PER DAY) WITHOUT MITIGATION
Project Average Daily
Construction Emissions by Year ROG NOx Exhaust PM10 Exhaust PM2.5 20222023 3.330.11 16.671.00 0.770.04 0.700.04
20232024 0.130.06 1.140.48 0.050.02 0.040.02
BAAQMD Threshold for Significant
Construction Impacts 1054 1054 1582 1054
Potential Significant Impact? No No No No
NOTES: Construction emissions were revised to account for the one-year construction schedule delay.

The applicable BAAQMD significance thresholds for pounds-per-day are now shown.

SOURCE: ESARamboll (Appendix A to this documentchecklist)

Page 47 ends

Fugitive emissions from piping components such as valves and pumps are also anticipated. Cooling towers, pressure storage tanks, raw water storage tanks, treated water storage tanks, bisulfite storage tanks, anti-scalant storage tanks, and condensate recovery tanks are exempt from the permit requirement under BAAQMD Regulation 2, Rule 1 (BAAQMD 2017c), as described in the permit application. Table 4.3-3 shows the anticipated emissions from the permitted sources. The air quality analysis prepared for the IS/MND is based on protocols used for the emissions analysis under review by the BAAQMD as part of the Authority to Construct (ATC) permit application.

Page 48 ends

correction to show deletion regarding Table 4.3-4, as follows:

Operational-related mobile source activities, such as employee commuting, truck trips for delivery and materials hauling, use of landscape equipment, and other sources would generate emissions of criteria air pollutants, their precursors, and toxic air contaminants (TACs). Area sources generally include fuel combustion from space and water heating, landscape maintenance equipment, and fireplaces/stoves, evaporative emissions from architectural coatings, and consumer products. Although these sources are not regulated under the BAAQMD’s air permitting program, Table 4.3-3 shows the anticipated emissions from auxiliary operations that are not the permitted sources. Table 4.3-4 shows the emissions from operational emission sources that are not part of the air permit application.
1225
ERRATA SHEET #1
Raven SR Bioenergy Project 4 ESA / D202100382
ERRATA SHEET #1 to the Updated Initial Study MND March 14, 2023

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TABLE 4.3-2

PROCESS OPERATIONS AIR PERMIT APPLICATION'S AVERAGE ANNUAL OPERATIONAL CRITERIA

POLLUTANT EMISSIONS
(TONS PER YEAR)
Project Operations
Emissions by Source CO NOx VOC/ROG SO2 PM10 PM2.5
Biogas engines 50.69 7.19 5.70 6.83 6.63 5.13 5.13
Green waste off gas N/A N/A 2.38 N/A N/A N/A
Fugitive component leaks N/A N/A 0.63 N/A N/A N/A
Limestone handling N/A N/A N/A N/A 0.003 0.0005
Limestone storage N/A N/A N/A N/A 0.016 0.0024
Flare 0.092 0.16 0.0098 0.0002 0.0086 0.0086
Fire pump engine 0.055 0.04 0.0022 0.00009 0.0033 0.0033 Total 50.84 7.39 8.72 7.47 6.64 5.16 5.14

Page 49 ends

TABLE 4.3-4

AVERAGE ANNUAL OPERATIONAL- RELATED CRITERIA POLLUTANT EMISSIONS (TONS PER YEAR)
Project Operations Emissions NOx VOC/ROG Exhaust PM10 Exhaust PM2.5 Air PermitProcess Operations 7.39 7.47 8.72 5.16 5.14
CalEEModAuxiliary Operations 3.75 1.66 0.18 0.47 0.35 0.05 0.13 0.05 Reduction in Flared Landfill Gas -8.71 -0.10 -3.35 -3.35 Overall Total 9.05

2.43 9.19

7.55 5.21

2.16 5.19

1.92 BAAQMD Threshold for Significant
Operational Impacts 10 10 15 10
Potential Significant Impact? No No No No
NOTES: Operational mobile emissions were revised to align with more detailed project information from the Project Applicant.

Source: ESA and Ramboll (Appendix A to this documentchecklist) and Ramboll Permit Application (Raven, 2022a)

Page 53 ends

follows:
particular matter (DPM) generated during construction would be less than significant.

Although the nearest sensitive receptor is located further than the 1,000-foot distance, Raven conducted a Health Risk Assessment (HRA) to quantify construction-related emissions and associated health risks due to DPM exposure during construction. The results of this analysis are presented in Appendix A. Even though an HRA was not required based on adopted thresholds, the HRA demonstrates that health impacts are 1226
ERRATA SHEET #1
Raven SR Bioenergy Project 5 ESA / D202100382
ERRATA SHEET #1 to the Updated Initial Study MND March 14, 2023 below significance thresholds, and the project would result in a less than significant impact during construction.

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Emissions from the loader were calculated using CalEEMod and included in the operational emissions, shown in Table 4.3-43. Reduced TAC emissions due to the reduction in flaring of landfill gas at the existing WCCSL flare were also quantified and included in this analysis.

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corrected, as follows:

TABLE 4.3-6

HEALTH RISK IMPACTS AT THE MAXIMUM EXPOSED SENSITIVE RECEPTORS Risk Scenario / Receptor Type
Maximum
Cancer Risk
(per million)
Chronic
Hazard Index
Acute
Hazard
Index
PM2.5
concentration
(μg/m3)
Construction + Operations
Worker 3.0 0.058 0.22 0.57
Resident 0.70 0.0086 0.0039 0.024
School 0.49 0.011 0.036 0.030
Clinic 0.46 0.0058 0.032 0.016
Landfill Reductions
Worker -5.7 -0.21 -0.49 -0.84
Resident -1.3 -0.018 -0.10 -0.042
School -0.81 -0.019 -0.091 -0.044
Clinic -0.79 -0.011 -0.077 -0.026
Project Construction + Operations with Landfill Reductions Worker -2.7 -0.16 -0.27 -0.27
Resident -0.57 -0.009 -0.064 -0.018
School -0.32 -0.0084 -0.055 -0.014
Clinic -0.33 -0.0056 -0.045 -0.010
BAAQMD Threshold of Significance 10.0 1.0 1.0 0.3
Exceeds Significance Threshold? No No No No
NOTES: Numbers may not appear to sum correctly due to rounding.

SOURCE: Ramboll (Appendix A to this document)
1227
ERRATA SHEET #1
Raven SR Bioenergy Project 6 ESA / D202100382
ERRATA SHEET #1 to the Updated Initial Study MND March 14, 2023

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TABLE 4.8-3

UNMITIGATED ANNUAL OPERATIONAL GREENHOUSE GAS EMISSIONS Source GHG (MTCO2e)
Process Operations
Biogas Engines 16,398
Flare 205
Fire Pump Engines 2.5
Auxiliary Operations
Area <1
Energy 80.5
Mobile 262.6 1909.2
Off-road 303.2
Waste 96.7
Water 17.0
Amortized Construction Emissions 6.2
Amortized Construction EmissionsLandfill Flare
Reductions (blended gas) 8.63 -9,019
Total Project GHG Emissions (blended gas) 697.17 9,999
Landfill Flare Reductions (100% LFG) -16,398
Total Project GHG Emissions (100% LFG) 2,620
NOTES:

A 30-year lifetime was assumed for the project, which was used to amortize construction emissions.

Landfill flare reductions were estimated based on the landfill gas usage of the Project biogas engines, which can operate using a blended gas consisting of at least 55 percent landfill gas and up to 100 percent landfill gas
MTCO2e = metric tons of carbon dioxide equivalent
Operational emissions are revised in this updated IS/MND to align with more detailed project information from the Project Applicant.

SOURCE: Data compiled by Environmental Science Associates and Ramboll. (See Appendix A to this documentchecklist.)

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Operation
The Raven SR system would run up to 24 hours per day, 7 days per week, although an average of 1.5 days per month are planned down times. The primary source of noise during project operation would be mechanical equipment associated with the Steam/CO2 Reformation system, including heating systems, HVAC equipment. Also, feedstock would be physically deposited in the receiving area via self-unloading transfer trucks or other suitable vehicles. The hydrogen compressors are industrial pieces that could generate noise up to as much as 85 dBa at 1.0 meter. Additionally, trucks used to distribute fuels generated on the site would be maneuvering within the parking lot of the proposed facility. As detailed in Section 2.5 (Technology), the purified, high-pressure hydrogen is not proposed to be flared but vented if necessary, thereby avoiding potential noise emissions that could be created by the high-pressure release.
_____________________________
1228
Exhibit C

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EXHIBIT C
Conditions of Approval
Raven SR (Planning Application No. PLN21-282)

NOTICE TO APPLICANT
In accordance with the provisions of Government Code Section 66020(d)(1), the imposition of fees, dedications, reservations, or exactions for this project are subject to protest by the project applicant at the time of approval or conditional approval of the development or within ninety (90) calendar days after the date of imposition of fees, dedications, reservation, or exactions imposed on the development project. This notice does not apply to those fees, dedications, reservations, or exactions which were previously imposed and duly noticed; or where no notice was previously required under the provisions of Government Code Section 66020(d)(1) in effect before January 1, 1997.

IMPORTANT: PLEASE READ CAREFULLY
This project is subject to a variety of discretionary conditions of approval. These include conditions based on adopted City plans and policies; those determined through plan review and environmental assessment essential to mitigate adverse effects on the environment including the health, safety, and welfare of the community; and recommended conditions for development that are not essential to health, safety, and welfare, but would on the whole enhance the project and its relationship to the neighborhood and environment.

Approval shall be considered null and void in the event of failure by the applicant and/or the authorized representative, architect, engineer, or designer to disclose and delineate all facts and information relating to the subject property and/or the proposed development.

Discretionary conditions of approval may be appealed. All code requirements, however, are mandatory and may only be modified by variance, provided the findings can be made.

Approval of this project may become null and void in the event that the site is not completed in accordance with all the conditions and requirements imposed on Planning Application No.

PLN21-282 (including design review and conditional use permits, the zoning ordinance, and all City standards and specifications. This project is granted, and the conditions imposed, based upon the application submittal provided by the applicant, including any operational statement. The application is material to the issuance of the project. Failure to operate in accordance with the conditions and requirements imposed may result in revocation of the project and in any other enforcement remedy available under the law. The City shall not assume responsibility for any deletions or omissions resulting from the project review process or for additions or alterations to any construction or building plans not specifically submitted and reviewed and approved pursuant to this Planning Application PLN21-282 (including conditional use and design review permits) or subsequent amendments or revisions. These conditions are conditions imposed solely upon the project as delineated herein and are not conditions imposed on the City or any third party. Likewise, imposition of conditions to ensure compliance with federal, state, or local laws and regulations does not preclude any other type of compliance enforcement.
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Exhibit C

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Project-Specific Conditions of Approval:

1. CUP: The Conditional Use Permit for the operations of the Raven Bioenergy Facility includes the following major components:
a. First and second stage reformers.
b. Hydrogen purifiers.
c. Compressors and ancillary materials storage.
d. Landfill gas conditioning.

2. Location: The Raven SR Facility is co-located on the site of the West Contra Costa Sanitary Landfill (WCCSL), which has separate conditions for use and permits. Some components of the WCCSL operation such as the scales may be utilized by the permittee. The WCCSL’s regulatory requirements shall at all times supersede the permittee regulatory requirements to the extent that they may conflict.

3. General Requirements: The project shall be in substantial compliance with the drawings submitted to the City of Richmond Planning Division (RPD) and included as drawings in the mitigated negative declaration. The Use Permit and Design Review Applications approved by this Conditional Use Permit (CUP) and subject to these Conditions of Approval shall consist of the following schematic plans and studies included in the permittee's Use Permit and Design Review Applications dated June 8, 2021 and September 29, 2022 respectively; and the revised Design Review Application and plans therein submitted September 29, 2022 and revised Landscaping Plan submitted October 25, 2022.

4. MMRP: The project shall comply with the adopted Mitigation Monitoring and Reporting Program.

5. Regulatory Agency Approvals: Subsequent to the approval of this CUP, the permittee shall obtain approvals from the regulatory agencies having permitting jurisdiction over the project, and obtain approvals or authorizations as necessary for constructing, serving, and operating the facility. The permittee shall notify the RPD if proposed or adopted conditions or requirements do not appear to be consistent with this CUP or the IS/MND. The regulatory agency approvals include, but are not limited to the following:
a. Prior to Construction: (a) General National Pollution Discharge Elimination System (NPDES) Construction Activities Storm Water Permit from the San Francisco Regional Water Quality Control Board (SFRWQCB). (b) Authority to Construct from the Bay Area Air Quality Management District (BAAQMD).
b. Prior to Operation: (a) General NPDES Industrial Activities Storm Water Permit (SFRWQCB). (b) Once grace period from Authority to Construct is complete, Permit to Operate from the BAAQMD. (c) Solid Waste Facility Permit (SWFP) from the Local Enforcement 1230
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Agency. (d) Wastewater Discharge Permit from West County Wastewater District.

6. Building Permits: Prior to issuance of the building permit for this project, the permittee shall prepare a building permit submittal that includes the final landscaping and irrigation plan, identifying quantities, species, sizes and locations of plantings, and locations, types, sizes, and quantities of irrigation fixtures. The final landscaping and irrigation plan shall be consistent with the requirements of the Water Efficient Landscaping Ordinance (Article 15.04.613 of the City Municipal Code) and include native and drought-tolerant plants where appropriate. Permittee shall install the plants within one (1) year of project approval.

7. Irrigation System: The applicant will make best efforts to use a drip irrigation system on all plantings shown in the Landscape Plans.

8. Additional Landscaping: The area beneath the trees in the Landscape Plan will be mulched with 2-inch redwood bark or other mulch.

9. Fire Hydrants: Prior to issuance of the building permit, the permittee shall submit a plan for location of fire hydrants that is in compliance with City of Richmond Fire Department regulations and policies.

10. Interpretive Panel: Prior to issuance of a certificate of occupancy, a 2’ x 3’ interpretive panel about the bioenergy facility shall be created and installed in a National Park Service low profile frame consistent with the design of Bay Trail interpretive panels installed elsewhere along the Landfill Loop Trail, replacing the existing interpretive panel. The design shall be developed in collaboration with TRAC, and the panel location shall be subject to approval by Republic Services and Richmond Planning Division (RPD).

11. Maintenance Documents: Permittee shall use its best efforts to ensure that the planning components maintained by Republic that are affected by the installation of this facility are updated no later than six months after operations commence. This condition is not intended to require Republic to update its SWFP, Air Permit, CUP or any other permit but simply to make updates to relevant ancillary site operating procedure documents.

These planning documents include: Traffic Control Plan, Emergency Response Plan, Fire Protection Component, and Storm Water Pollution Prevention Plan (SWPPP).

12. Design Review: All Design Review conditions of approval shall be printed on the informational page of the final construction plans submitted for building permits, along with annotations by the applicant of where the conditions have been met on the drawings. All conditions of approval shall be on all grading and construction plans, which shall be kept on the 1231
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project site at all times. It is the responsibility of the building developer to ensure that the project contractor and construction crew is aware of and adheres to all conditions of approval.

13. Compliance to Conditions: These Conditions of Approval refer to the development, including all construction and improvements activities, and the operation, including all management and maintenance activities, of the Facility. Regardless of the party(ies) who perform these activities, the owner of the Facility, herein referred to as “permittee”, shall be responsible for complying with all conditions. If the permittee engages vendor(s) or operator(s) to perform any of these activities, the contract with each vendor or operator shall include language requiring adherence to all conditions.

14. Administration and Enforcement of Conditions: The Richmond Planning Commission (Commission) is responsible for the administration and enforcement of these Conditions of Approval. Unless otherwise provided for, the Richmond Planning Division’s Director of Community Development or designee (RPD) shall administer and enforce these Conditions of Approval for the Commission.

15. Assignment of Responsibility: The Commission may assign the responsibility of administering specific Conditions of Approval or provisions of this CUP to the City Manager or his designee. a. The Commission may suspend the implementation of conditions or provisions of this CUP where such conditions or provisions are inconsistent with the terms of a contract or agreement entered into between the City and other units of government, or by the terms of a joint powers agreement where the City is a member of the joint powers agency.
b. If no contract or agreement is in force, as referred to in the above condition, the City retains authority to implement this CUP and all of its Conditions.

16. Permit to Run With The Land: The CUP for the Facility shall run with the land and shall continue to be valid upon a change of ownership of the site or structure which was the subject of the use permit application provided all provisions of the ordinance, the Zoning Ordinance, and all conditions placed on approval of the CUP are continually met; however, the current owner is responsible for notifying the RPD of any change in ownership. A change of ownership shall be interpreted to mean the acquisition of 5 percent or more of the value of the Facility covered by this CUP.

17. Compliance Objective: The permittee shall at all times comply with all applicable local, state, and federal laws and regulations.

18. Conditional Use Permit (CUP). Extent as provided for in this condition and 1232
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the following condition, the permittee shall at all times comply with the provisions and requirements of this CUP. The permittee shall comply with all correction and compliance orders issued by the City which relate to this CUP. A violation of any of these conditions or orders is cause for revocation of the CUP.

19. Solid Waste Facility Permit: Permittee shall secure and maintain a SWFP from the Contra Costa County Local Enforcement Agency (LEA) at the appropriate tier for the project with CalRecycle concurrence, if and as required The Contra Costa Health Services, Environmental Health Division Currently acts as the Local Enforcement Agency (LEA) for CalRecycle regarding solid waste enforcement issues. The permittee shall comply with all provisions and requirements of the SWFP. This CUP is not intended to supersede the existing landfill Solid Waste Facility Permit operating requirements, nor shall it conflict with said permit operating requirements.
a. Permittee shall maintain the Report of Facility Information (RFI) in accordance with the requirements of 14 Cal. Code Regs (CCR) section 182221.5 – Facility Plan, or relevant code section, should the SWFP be revised in the future to a different solid waste permit tier.

20. Closure/Post Closure Maintenance Plan: The Permittee’s operations shall be consistent with, and shall not conflict with, the Closure/Post Closure Maintenance Plan required by CalRecycle, the SFRWQCB, and the LEA for the existing WCCSL.

21. Bay Area Air Quality Management District: The permittee shall at all times comply with the provisions and requirements of the Authority to Construct and Permit to Operate entitlements issued by the Bay Area Air Quality Management District (BAAQMD).

22. Title: Title 14 and Title 27 of the California Code of Regulations (14 CCR and 27 CCR). The permittee shall at all times comply with the provisions and requirements of 14 CCR, Natural Resources, Division 7, current regulations of CalRecycle pertaining to nonhazardous waste management in California; and, Title 27, Environmental Protection, Division 2, Solid Waste, current regulations of CalRecycle and the State Water Resources Control Board pertaining to waste disposal on land.

23. Other Regulatory Approvals: Subsequent to the approval of this CUP, the permittee shall obtain approvals from the agencies, utilities, and parties having jurisdiction or control over the on-site and off-site improvements authorized by this CUP or by agencies having regulatory jurisdiction over the project. The permittee shall at all times comply with the regulations and requirements of these permits and approvals, as determined by the issuing agency, and shall notify the RPD if proposed or adopted conditions 1233
Exhibit C

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or requirements do not appear to be consistent with this CUP or the IS/MND.

24. Notice Coordination: Permittee shall transmit to the RPD, within 10 to 15 business days of origination or receipt by the permittee and allow for email of electronic files: (1) copies of all permits and approvals from regulatory agencies; (2) copies of all monthly, quarterly, and annual reports to other agencies concerning the design, operation, and maintenance of the Permittee, including air emissions reports; (3) all reports concerning any emergency incidents associated with Permittee or hauler operation; and (4) any other reports or documents requested by the RPD.

25. Use Permit Expiration: The project authorized pursuant to this CUP must be fully operational, meaning that it has begun the ramp-up period, within 2 years from the date of final approval or the final approval of the facility's Solid Waste Facilities Permit, whichever is later. If not fully operational within 2 years from the date of final approval, the permit shall be deemed expired, and all rights granted pursuant to the permit may be revoked.

Permittee may request from the RPD one or more year extensions of the validity period per Section 15.04.803.110 of the City’s Municipal Code.

26. Operative Date: This CUP is valid upon the approval of the same by the City Council.

27. Design Review Expiration: Design Review approval shall expire two years from the date of the approval of the same by the City Council, unless made permanent by the issuance of building permits and the commencement of construction. If the use(s) or structure(s) approved by this action is not established within such period of time, this approval shall be terminated and shall, thereafter, be null and void, unless the permittee or owner applies for an extension of time prior to expiration of the Design Review approval.

28. Permit Review: The RPD shall report after Raven SR’s first full year of operations and then once every five years to the Commission thereafter, or on such frequency as the Commission may require, on compliance with the Conditions of Approval of this CUP beginning one year after the commencement of operations of the facility. If the Commission finds that the permittee has not complied, it may take such corrective action as is required to remedy the situation. If the corrective action requires a modification to this CUP, such request for action shall be sent to the Commission for review and a public hearing on the matter. As a result of the review and public hearing, the Commission may recommend to the Council the appropriate corrective action. Nothing in this condition shall preclude the permittee from applying for amendments to the CUP at any time or preclude the City from addressing emergency situations or new requirements imposed by state legislation or the courts. Notwithstanding, 1234
Exhibit C

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an application for modification of the CUP or a new CUP for the property submitted by the Facility shall comply with the procedural requirements of the Municipal Code for amending or approving the same.

29. Delegation of Authority: In any instance where these conditions provide that the Commission will decide or act upon a matter, and the Commission has not assigned the responsibility to another unit of City government pursuant to Condition 15 and its subsection, the Commission may delegate the initial decision making or action with respect to that matter to the City Manager or his designee, provided that there shall be a right of appeal for the designee, to the Commission for any decision made by the Commission.

30. Interpretation of Conditions: The RPD is authorized to interpret these conditions in the event that any clarification is needed. Any interpretation of the permit by the RPD may be appealed per RMC 15.04.803.140 to the Commission by the permittee.

31. Emergency Operation: In the event of an emergency situation not officially declared by another agency, such as a road closure or on-site problem, the RPD may allow the permittee to alter the provisions of these conditions for operation. This authorization shall be limited in extent and time to that needed for correction of the situation.
a. Fires, other emergencies, or serious problems relating to public health and safety or nuisance condition shall be reported to applicable agencies in alignment with the requirements in operating permits. City shall be copied on such reports as are required in these permits.
b. In the event that materials are diverted from the site, the facility shall divert material from the site in accordance with its operating permits.

32. Availability of and Access to Records: The permittee shall make copies of all reports which must be submitted to regulatory agencies available to the public at the facility site during normal business hours by appointment except in an emergency. The permittee shall allow access to the facility site and to all operation records by the RPD and any government agency responsible for monitoring the facility or Its operation. This access shall not require prior notification.

33. Monitoring and Inspection: All monitoring reports, results of regulatory inspections and a summary of daily inspection reports shall be made available to the City upon request. Any indication of an emergency or other serious problem relating to public health and safety shall be immediately reported to the appropriate emergency response agencies.

Upon City request, City and permittee shall meet and confer regarding the content of reports received.
1235
Exhibit C

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34. Compliance with Conditions of Approval: The permittee shall reimburse the City for the cost of monitoring compliance with the CUP Conditions of Approval. The City may designate a staff person or consultant to do the monitoring. The permittee shall provide such information as the City may require reviewing plans and installations under the purview of the City.

Such initial compliance report demonstrating evidence of compliance with this permit shall be due from permittee one year after operations commence, and thereafter every five years in accordance with Condition

28. 35. Internship Program: The permittee shall undertake an internship program meeting the criteria of permittee’s proposal letter to the City dated November 18, 2022.

36. Eligible and Ineligible Feedstock: The permittee may accept Organic Waste consisting of pre-processed blended organic material including, but not limited to, landscaping and pruning waste, food waste, and other materials typically allowed in municipal organics collection programs, delivered from the onsite composting facility referred to as the WCCSL Organic Materials Processing Facility (OMPF). The Eligible Feedstock shall not include any material that is not permitted for acceptance at the OMPF. The OMPF has a loadchecking program in place to screen for and remove prohibited materials including material that is not acceptable under its permits. After screening and loadchecking at the OMPF, the organic material is pre-processed by grinding. The pre-processed organic feedstock will be delivered to the permittee’s facility by WCCSL personnel and vehicles. This material, as received by permittee, may include some level of “Incompatible Material” (as that term is defined by Section 17402 of the California Code of Regulations Title 14, Division 7), that was not removed through the pre-processing activities at the OMPF. Permittee shall be prohibited from adding any additional Incompatible Material to the pre-processed organic feedstock as received. In addition, if there is verifiable evidence that additional Incompatible Materials have been added to material received, beyond that inherent in the feedstock, permittee shall reject such loads. Permittee shall be prohibited from intentionally accepting industrial or medical waste in the eligible feedstock.

Permittee shall secure and maintain a SWFP from the Contra Costa County Local Enforcement Agency (LEA) at the appropriate tier for the project. If not otherwise required, Permittee shall conduct waste sorts at least once annually and otherwise in conformance with the requirements of the SWFP for the facility and shall report the results of such waste sorts to the City.
a. All loads of organic waste accepted shall originate from the OMPF and shall be transferred directly from such facility to Raven SR after having already been processed by screening, loadchecking and grinding. After acceptance at Raven SR, all material shall be fed across the initial stage of the system which includes a screen 1236
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to remove any oversized material (overs) and a magnetic separator to remove any unexpected metal prior to being loaded into the hydrogen conversion system equipment.

37. Eligible Loads: The permittee shall prepare and implement a program for checking loads at the Facility (Loadchecking Program). The load inspection program shall include inspection for smoldering loads, hazardous and other ineligible wastes, and the procedures for their handling and disposal. The Loadchecking Program shall be developed and implemented in compliance with Title 14, Code of California Regulations (CCR), Section 17409.5 and included with the approved SWFP for the facility. The program may be updated as needed in accordance with the LEA-approved Report of Facility Information (RFI).

38. Scales: The permittee or designee shall utilize the scales at the WCCSL to weigh incoming and outgoing vehicles. A weighing program, approved by the RPD and Director of Weights and Measures, shall be implemented to monitor material tonnage and origin.

39. Vehicle Operations: Operations of eligible vehicles on-site shall be allowed 24 hours per day, seven days per week.

40. Facility Hours: The Facility shall remain open for business seven days a week, excepting facility holidays and planned maintenance.

41. Processing Activity Hours of Operation: For the purposes of this condition, "processing activity" shall include, but not be limited to, the loading and unloading of material, processing of material and any other manipulation of materials. Processing activities at the facility may be conducted 24 hours a day, but if at any time operations exceed the noise limits in Condition 42, operator shall be limited to the following schedule: 5:00 a.m. to midnight, 7 days/week.
a. The RPD may administratively shorten or extend the hours of operation prescribed above. This action shall be taken only after consultation with the permittee and the LEA. To shorten the hours of operation, the Director shall find that the changes are needed to mitigate substantial noise, traffic, or similar impacts arising from the operation of the facility which were not known when this CUP was adopted. To extend the hours of operation, the Director shall find that the longer hours will not cause traffic, noise, glare, or similar impacts of facility operations to substantially increase in the vicinity.

42. Operating Noise Limits: Operator shall not cause operating noise measured at the Republic property boundary to exceed 70 dB at any time in accordance with Richmond Municipal Code 9.52.100. If noise measured at that location exceeds 70 dB, operator shall immediately limit operations 1237
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to the time period specified in Condition 41 until which time operator has made corrective actions and the RPD has approved extending hours of operation.

43. Noise Abatement Program: The permittee shall manage the Facility in a manner that minimizes impacts to sensitive receptors in the area. If noise complaints are received by the permittee and/or the City, noise abatement measures may be required by the RPD. These measures may take the form of a noise monitoring program to determine whether the facility meets the acceptable exterior noise level standards established in the Richmond General Plan 2030 as it may be amended from time to time; and also is inclusive of the limitations to facility noise in Condition 41. The location of noise monitoring devices, if required, shall be determined by the RPD. If operation activities cause the monitored noise levels at the property line of the selected receptor locations to exceed the DNL standards as set forth in the General Plan, the permittee shall institute noise reduction measures to bring the level within acceptable levels.

44. Facility Vehicles and Equipment: The permittee shall provide Facility vehicles and equipment with the best available noise suppressing equipment to minimize sound generation during construction and operation.

45. Noise Exemption Request: The permittee may request in writing, and the RPD may grant, exemptions to Conditions 41, 42, and 43 for specific times for cause.

46. Operations Information: The permittee shall post a sign at the Facility entrance which identifies the Facility to the public and prohibits public access.

47. Maximum Daily Quantities: The Facility may receive a daily maximum quantity of Organic Waste of 99.9 tons per day.

48. Maximum Storage Capacity: The Facility may have on-site at any given time the following maximum quantities of materials:
a. Organic Waste: 200 tons of unprocessed Organic Waste in storage. b. Pressurized Hydrogen Biproduct: Permittee shall not park more than one standard pressurized hydrogen gas truck with 80% or more product compared to fill capacity at the project site. One standard pressurized hydrogen gas trucks may additionally be parked as it is being filled.
c. Biocarbon: No more than 150 cubic yards of biocarbon, or the equivalent volume, shall be stored at the facility at any time without prior approval of the RPD. Covered biocarbon container design subject to review and approval by RPD prior to issuance of building permit.
d. Residuals: Residual material requiring disposal, if any, shall be 1238
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stored in roll-off boxes or other suitable containers and removed from the site within 48 hours of being generated, or otherwise as required by the SWFP.

49. Additional Operating Parameters Shall Include:
a. Operator shall comply with state minimum standards established under Title 14 and 27. Operational guidelines, procedures, and contingency plans shall be in conformance with the applicable provisions of the approved RFI.
b. Permittee shall use best management practices as specified in the approved RFI to prevent spontaneous combustion from occurring; or any gas leakage; or any excess heat leakage. If a fire incident occurs that triggers a notification requirement by other agencies, permittee shall concurrently provide such report to RPD. c. The permittee shall cooperate with the Bay Area Air Quality Management District, the City, and the County to identify and implement measures to minimize odor emissions. Odors caused by storage shall be controlled.
d. The permittee shall comply with Federal and State regulatory standards for operation; pollutant concentrations, pathogen reduction, monitoring, recordkeeping, and reporting.
e. The operator shall operate the facility according to industry standards and as described in the approved RFI, implementing Best Management Practices to control nuisances.
f. The permittee shall obtain power for all operations aside from vehicles via either combustion of landfill gas or the electrical grid infrastructure at WCCSL, and shall not at any time power operations of the plant and associated operations (aside from vehicles, operation of the flare pilot for emergency flaring of syngas, and emergency back-up power for fire pump) through any type of petroleum-based product.
g. Permittee has voluntarily agreed to make best efforts to hire employees, workers, and subcontractor components for jobs from the North Richmond community. During the Review required in Condition 28, Permittee shall describe the reasons for rejecting the application for any North Richmond applicants that apply. h. The City reserves the right to direct permittee to temporarily cease operations if the City has cause to find that permittee is failing to meet the requirements herein defined.

50. Construction Defined: For the purposes of this CUP, "construction" is identified as those activities which encompass the startup of equipment, preparation of the site (e. g. movement of earth and grading), installation of utilities, erection of structures, and improvements to the site (e.g. landscaping, fencing and placement of berms). Maintenance, repair, and servicing of equipment are not considered construction activities. The occasional use of temporary equipment such as portable grinders and 1239
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screens to process materials as part of site operations is not considered construction activities.

51. Hours of Construction: The permittee shall restrict outdoor construction activities to the period from 7:00 a.m. to 6:00 p.m. or sunset, whichever is later, Monday through Sunday. The RPD may administratively adjust the hours of construction described in this Condition. Such administrative adjustments are subject to the following requirements:
a. This action shall be taken only after consultation with the permittee and the LEA.
b. To shorten the hours of construction, the Director shall find that the changes are needed to mitigate substantial noise, traffic, or similar impacts arising from the operation of the facility which were not known when this CUP was adopted. To extend the hours of construction, the Director shall find that the longer hours will not cause traffic, noise, glare, or similar impacts of facility operations to substantially increase in the vicinity.

52. Construction Exemption Request: The permittee may request in writing, and the RPD may grant, exemptions to Condition 51 for specific times for cause.

53. Debris Recovery Program: At least 15 days prior to the issuance of a building permit the developer shall demonstrate compliance with the debris recovery program, which requires at least 65 percent of the jobsite debris generated by construction projects of 5,000 square feet or greater to be recycled, or otherwise diverted from landfill disposal.

54. Future Construction: No further construction is authorized two years after issuance of CUP permit. If permittee requests in writing, the RPD may grant, an extension to construction for a specified additional time period.

55. Equipment Activity and Maintenance: The permittee shall maintain Facility equipment in optimum working order. Equipment shall be shut off when not in use with the exception that engines shall be allowed to idle for up to 5 minutes (as required by the California Airborne Toxics Control Measure Title 13, Section 2485 of California Code of Regulations [CCR]).

Maintenance records, subject to review by both the City, shall be kept on all pieces of facility equipment.

56. Containment Features: Vehicle washing areas and maintenance structures shall be designed to ensure containment of liquids. All liquids collected from these areas shall be treated as required by WCCSD or other applicable regulations. The Plan shall be updated as needed in accordance with the approved RFI.

57. Lighting: Sufficient lighting shall be provided to allow for safe working 1240
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conditions during non-daylight hours. The permittee shall design and locate the lighting system to reduce glare and to not substantially impact area land uses. The permittee shall install directional shading on all outdoor lamps for night operation. In addition, focused security lamps with directional shading shall be installed as necessary. To conserve energy, the permittee shall utilize LED lamps where such use meets operational safety standards and is feasible, and where LED lamps would provide equal levels of illumination. Incandescent lamps may be retained in operations areas where illumination levels generated by prevailing LED technology would be inadequate to protect worker health and safety.

58. Exterior Lighting: Prior to issuance of any building permit, the applicant shall demonstrate that all exterior lighting has been designed and located so that all direct light is confined to the property and is satisfactory to the Community Development Director or his/her designee. Fixtures shall be appropriate to the style and scale of the architecture. The top of the fixture shall not exceed the height of the parapet or roof or eave of roof. No lights shall be greater than 3,000k LED.

59. Transportation and Circulation Plan: The permittee shall comply with the WCCSL Transportation and Circulation Plan. The Plan shall detail the onsite circulation including parking, vehicle storage, and queuing areas. If adjustments to the WCCSL Transportation and Circulation Plan are required to accommodate permittee’s operations, permittee shall be required to make the adjustments, subject to WCCSL and RPD approval.

60. Access Route: Access to and from the Facility site shall be, by vehicle type, via the following routes: (a) Commercial and recyclables haulers from I-80 from the north, Richmond Parkway, and Parr Boulevard: from the south - I-580, Castro Street, Richmond Parkway, and Parr Boulevard.

The permittee shall specify use of the above prescribed routes in all user contracts and shall notify noncontract users of these requirements. A more direct route for local commercial haulers may be submitted for review and approval by RPD. Exemption from these prescribed routes is allowed if detour routes are in force.

61. Zero or Near Zero Emission Vehicles: If the property owner/tenant/lessee uses its own vehicles to ship hydrogen product from the Facility, the property owner/tenant/lessee shall take all reasonable efforts to procure zero or near zero emission vehicles/trucks for criteria pollutant emissions to the extent that they are reasonably commercially available. If hydrogen product from the Facility is shipped by third-parties, the property owner/tenant/lessee shall make all reasonable efforts to request use of zero or near zero emission vehicles/trucks for criteria pollutant emissions from the third parties. In the event that there is a disruption in the manufacturing of zero or near zero emission vehicles/trucks, or that sufficient vehicles/trucks are not reasonably commercially available for the intended application, the “clean fleet requirements” may be adjusted as 1241
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minimally as possible by the RPD to accommodate the manufacturing disruption or unavailability of commercially available vehicles/trucks. The property owner/tenant/lessee shall provide all necessary documentation describing efforts made to meet clean fleet requirements as part of any adjustment request. The RPD staff may seek the recommendation of the California Air Resources Board in determining whether there has been a manufacturing disruption or insufficient vehicles/trucks reasonably commercially available for the intended application.

62. Site Services and Utilities Plan: The permittee shall maintain a Site Services and Utilities Plan, with components listed below.

63. Fire Protection Component: The permittee shall maintain a Fire Protection Component for the Facility meeting the requirements of the Richmond Fire Department (RFD) to contain and extinguish fires originating at the facility.

The program shall be subject to the approval of the RFD and RPD and may be updated as needed in accordance with the approved RFI. The Fire Protection Component shall address, but not be limited to, thefollowing:
a. Fire protection and suppression measures, including water supply, flow requirements, water storage, fire breaks, earth piles and compost operation requirements.
b. Fire apparatus water supply connections, extinguisher types and locations, including fire extinguishers on facility vehicles. c. Machinery and equipment inspection program.
d. Fire control training of employees.
e. Sprinkler and smoke detector systems if applicable.

64. Fire Department and District Permits: The permittee shall apply to and obtain from the RFD any Department or District permits and/or approvals which may be required to comply with Fire Code requirements.

65. Emergency Equipment Access: The permittee shall designate access points and routes for local fire protection agency access to all parts of the facility. The access points shall be included in the Site Design Plan and Fire Protection Component and shall be subject to the approval of the RFD or CC/WCFPD.

66. Load Inspection: The permittee shall check incoming loads for smoking or burning materials and potential pollutants and make provisions for extinguishing or properly disposing of these loads before processing.

67. Smoking Prohibitions: The permittee shall prohibit smoking on the facility except in designated areas. Signs shall be clearly posted.

68. Use of Reclaimed Wastewater: The permittee shall make every effort to use reclaimed wastewater, should it become available, for daily operations. Any proposal to use reclaimed wastewater shall comply with 1242
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all applicable City water conservation ordinances. The permittee shall report on this matter to the RPD.

69. Water Conservation Measures: The permittee shall incorporate water conservation measures into the construction and landscaping of the site.

These measures shall comply with all applicable City water conservation ordinances and be consistent with East Bay Municipal Utility District (EBMUD) policies and guidelines.

70. National Pollutant Discharge Elimination System Compliance: The permittee shall be required to comply with all rules, regulations, and procedures of the National Pollutant Discharge Elimination System (NPDES) for municipal, construction and industrial activities as promulgated by the California State Water Resources Control Board, or any of its regional water quality control boards (San Francisco Bay - Region II). These permits require the permittee to eliminate nonstormwater discharges to storm sewer systems; develop and implement a stormwater pollution prevention plan (SWPPP); and, develop and implement an appropriate monitoring program (MP). The Stormwater Pollution Prevention Plan (SWPPP) and the Monitoring Program (MP) shall become part of the Final Development and Improvements Plan.

71. Surface Drainage System: The permittee shall prepare and implement a plan for conveying surface drainage water, e.g. rain water, from the facility site to flow into the siltation control basin located behind (east of) the Golden Bear Waste Recycling Center. The system plan shall be included in the FDIP, shall be reviewed and approved by the RPWD, and may be updated as needed in accordance with the approved RFI.
a. The permittee will maintain adequate drainage control at the property in accordance with the requirements of the SWPPP. The drainage control system shall prevent ponding conditions. b. All areas subject to vehicular traffic or equipment shall allow ready access during all weather conditions.

72. Drainage Requirements: This development shall conform to the requirements of the site’s NPDES Industrial General Permit.

73. Seismic Design: The structures, drainage features, operating equipment, and all other facility components (e.g., tanks, storage units, and berms) shall be designed in accordance with the adopted California Building Code (latest edition) earthquake design criteria. The permittee shall provide substantiation to this effect in the Final Development and Improvements Plan. The permittee shall submit to the RPD for their review and approval facility designs, which shall be prepared by an independent registered geotechnical engineer and a structural engineer, that will demonstrate that the facility (e.g. all structures, berms, equipment, and materials/waste storage) will withstand the design earthquake, including the potential loss 1243
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of foundation support resulting from liquefaction of subsurface material and the potential impact from waste or soil settlement.

74. Post-Earthquake Inspection: The permittee shall inspect the project site following an earthquake of such magnitude to have caused damage to the facilities. The post-earthquake inspection report shall be submitted for review and approval to the RPD and other appropriate agencies. The permittee shall make all necessary repairs needed to assure the safety of employees and facility users prior to recommencing operation of the facility.

75. Prevention of Air Quality Deterioration: The permittee shall comply with the terms of the Authority to Construct and Permit to Operate issued by the BAAQMD.

76. BAAQMD Regulations: To the extent that any air quality regulation contained in these conditions of approval conflicts with the regulations of the BAAQMD, the regulations of the BAAQMD shall govern.

77. Odor Prevention and Management Plan (OPMP): During the construction phase of the Project, the operational Odor Prevention and Management Plan (OPMP) shall be developed and implemented upon commissioning of the renewable fuels processes, intended to become an integrated part of daily operations at the Facility and other sites, so as to prevent any objectionable offsite odors and effect diligent identification and remediation of any potential objectionable odors generated by the facility and associated sites. The plan shall outline equipment that is in place and procedures that facility personnel shall use to address odor issues, facility wide. The OPMP shall include continuous evaluation of the overall system performance, identification of trends to provide an opportunity for improvements to the plan, and updating the odor prevention and management strategies, as necessary. This plan shall be retained at the facility for City or any other government agency inspection upon request.

The following practices shall be included in the OPMP to reduce the potential of objectionable odors from the storage of renewable feedstocks, operation of the Facility, and any other odor generating activity:
a. Develop operating procedures to inspect and evaluate the effectiveness of odor control equipment and operation of the facility.
b. The OPMP shall include guidance for the proactive
identification and documentation of odors through routine employee observations, routine operational inspections, and odor compliant investigations.
c. Inspections to be conducted on a semi-annual basis.
d. If there are fewer than an average of five confirmed complaints per year during the first 3 years of operation, then the inspection frequency can be reduced to an annual basis. 1244
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e. If there are more than five confirmed complaints in any single year, then the application shall develop additional mitigation strategies in consultation with the BAAQMD.
f. All odor complaints received by the facility shall be investigated as soon as is practical within the confines of proper safety protocols and site logistics. The goal of the investigation will be to determine if an odor originates from the facility and, if so, to determine the specific source and cause of the odor, and then to remediate the odor.

78. OPMP Report: Prepare an annual evaluation report of the overall system performance, identifying any trends to provide an opportunity for improvements to the plan, and updates to the odor management and control strategies, as necessary. The report shall be provided to the City for review and approval.

79. Cleanup: The permittee shall undertake immediate cleanup of on-site spills that are a source of pollutants.

80. Air Quality Monitoring: If required by the Bay Area Air Quality Management District (BAAQMD), the permittee shall install air quality monitoring devices and establish an air quality monitoring program. The installations shall be shown in the Final Development and Improvements Plan. If excessive air pollution is determined to be occurring, the permittee shall make whatever installations or operations changes that the BAAQMD may specify.
a. One time every five years, in conjunction with the report required in Condition 28, the permittee shall conduct a multi-pollutant toxins test and report the findings of such to the City.
b. To demonstrate the biogenic nature of the feedstock, Raven shall sample the actual syngas generated from the feedstock at a point just upstream of the syngas compressor to demonstrate that there is less than 10% non-biogenic carbon content. Raven will sample the process tailgas two times per year, once during summer operation and once during winter operation, and the results of the sampling will be evaluated per the most recent ASTM D6866 method (or equivalent) reporting as a “percent Modern Carbon” (pMC) to demonstrate the ratio indicative of less than 10% (by weight of total carbon) non-biogenic content (i.e., calculated as pMC) in the total carbon of the process tailgas.

When operating in a steady state, the non-combustion, non-catalyst process shall maintain a second-stage gas exit temperature greater than 1,450° F as measured on a daily basis.

In the unlikely event that the sampling indicates the non-biogenic carbon content is 10% or greater, then Raven shall work with 1245
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Republic to determine the source of any non-biogenic carbon content and remove it from the feedstock used in the process.

The results of such testing and analysis shall be provided to the City when completed.

81. Public Health and Safety: The permittee shall manage the facility in a manner which does not impair the public health and safety of persons living in the vicinity, or facility users and employees.

82. Public Health and Safety Plan: The permittee shall prepare and submit for approval by the RFD and RPD a Public Health and Safety Plan. The plan shall include an Emergency Plan component to protect the facility and its employees from harm, and to protect the human health off-site in the event of an emergency. This plan may be updated as needed in accordance with the approved RFI.

83. Regulation Compliance: The permittee shall comply with all design measures, safety precautions and emergency response procedures as required by federal, state; and local laws and regulations; federal, state, and local agencies; and these Conditions of Approval.

84. Emergency Response Procedure: The permittee shall implement on-site and off-site emergency response procedures as outlined in the Emergency Plan, immediately upon a spill, release, explosion, or fire event.

85. Employee Training: The permittee shall develop and implement training and subsequent refresher training programs covering accident prevention, safety, identification and handling of hazardous materials, first aid, and instruction for use of equipment. The programs shall be subject to the approval of the RFD and may be updated as needed in accordance with the approved RFI.

86. Employee Safety
a. Permittee shall develop a Safety Site Operations Plan demonstrating how the project applicant will comply with all applicable local, state and federal laws that address standards for workplaces involving use, storage, handling and transport of hydrogen, including standards pertaining to incident reports, thresholds for requiring operations to cease in the event of hazardous incidents.
b. Permittee shall implement the OSHA standards applicable to workplaces where hydrogen is stored, used and/or produced, as well as OSHA Process Safety Management (29 CFR 1910.119) and the EPA Risk Management Program (Section 112(r) of the 1246
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Clean Air Act), commonly referred to as PSM/RMP.
c. The permittee shall provide or require employees to provide safety equipment, such as safety glasses, hard hats, safety shoes, gloves, coveralls, and noise reducers as may be required by union contract, state and federal safety agencies, and the RFD.

87. First Aid Equipment: The permittee shall provide and maintain supplies located in easily accessible areas. The first aid supplies shall be consistent with Occupational Safety and Health Administration requirements and subject to the approval of the RFD.

88. Emergency Communications: The permittee shall provide radio phones or telephones for employee use to call for medical and other emergency assistance. Phone numbers to use for outside emergency assistance shall be clearly posted in the work areas. The communications system shall be subject to the approval of the RFD.

89. Equipment Maintenance Program: Pursuant to California Fire Code Section 105 (including Sections 105.1.2 (Types of permits), 105.1.3 (Multiple permits for the same location), and 105.1.6 (Annual permit)), City shall authorize and through an agreed upon maintenance program will authorize an Annual Provisional Construction Permit (APCP) for activities related to work on existing systems and equipment installations containing flammable, combustible and or hazardous materials at the Facilities that would otherwise require an individual fire construction permit under the California Fire Code. When approved by the Fire Marshal, the APCP may also include other components including but not limited to devices, equipment, piping, and tubing within research and development locations only which convey or contain combustible, flammable, or hazardous materials that would otherwise require an individual fire construction permit.

90. Enclosed Flare: The emergency syngas flare shall be enclosed, unless otherwise approved by BAAQMD.

91. Hydrogen-Only Production: The project should produce hydrogen only and not any other products, except byproducts.

92. Bicycle Racks: There shall be convenient and secure bicycle parking provided on the project site.

93. Indemnification: The permittee agrees, on behalf of permittee and any successor in interest and assigns, to defend, indemnify, and hold harmless the City, its Council, Planning Commission, Design Review Board, advisory boards, officers, employees, consultants and agents (hereinafter "City") from any claim, action or proceeding (hereinafter 1247
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"Proceeding") brought against the City to attack, set aside, void or annul the City's actions regarding any development or land use permit, application, license, denial, approval or authorization, including, but not limited to, variances, use permits, developments plans, specific plans, general plan amendments, zoning amendments, approvals and certifications pursuant to the California Environmental Quality Act, and/or any mitigation monitoring program, or brought against the City due to acts or omissions in any way connected to the permittee's project, but excluding any approvals governed by California Government Code Section 66474.9. This indemnification shall include, but not be limited to, damages, fees and/or costs awarded against the City, if any, and costs of suit, attorney’s fees and other costs, liabilities and expenses incurred in connection with such proceeding whether incurred by permittee or City. If permittee is required to defend the City as set forth above, the City shall retain the right to select the counsel who shall defend the City, and in all circumstances the City is entitled to review and approve (as appropriate) all draft filings, proposed resolutions of the proceedings, or other actions proposed to be taken on behalf of the City by the counsel. 1248
Table of Contents
Raven SR Bioenergy Project i ESA / D202100382
Initial Study October 7, 2022

TABLE OF CONTENTS
Raven SR Bioenergy Project Initial Study
Page

1. General Project Information and Overview .................................................................. 1

1.1 Project Title .............................................................................................................. 1

1.2 Lead Agency Name and Address ............................................................................ 1

1.3 Project Case File Number........................................................................................ 1

1.4 Contact Person and Phone Number........................................................................ 1

1.5 Project Location ....................................................................................................... 1

1.6 Project Applicant’s Name and Address ................................................................... 2

1.7 Existing General Plan and Zoning Designation....................................................... 2

1.8 Purpose and Intended Use of this Document ......................................................... 2

1.9 Project Overview ...................................................................................................... 6

1.10 Environmental Setting.............................................................................................. 6

1.11 Required Discretionary Approvals ........................................................................... 6

1.12 Other Public Agencies Whose Approval is Required .............................................. 7

1.13 California Native American Tribes Consultation...................................................... 7

2. Project Description.......................................................................................................... 9

2.1 Existing Site Conditions and Ownership.................................................................. 9

2.2 Surrounding Uses and Conditions ........................................................................... 9

2.3 Site Plan and Structures ........................................................................................ 12

2.4 Technology............................................................................................................. 17

2.5 Operations.............................................................................................................. 19

2.6 Employment ........................................................................................................... 22

2.7 Transportation and Circulation............................................................................... 22

2.8 Construction, Site Coverage and Drainage ........................................................... 22

2.9 Off-site Improvements: Landscaping..................................................................... 23

3. Environmental Factors Potentially Affected .............................................................. 24

4. Environmental Checklist and Analysis....................................................................... 25

4.1 Aesthetics............................................................................................................... 25

4.2 Agriculture and Forestry Resources ...................................................................... 31

4.3 Air Quality............................................................................................................... 34

4.4 Biological Resources.............................................................................................. 43

4.5 Cultural Resources................................................................................................. 53

4.6 Energy .................................................................................................................... 57

4.7 Geology, Soils and Mineral Resources.................................................................. 61

4.8 Greenhouse Gas Emissions .................................................................................. 65

4.9 Hazards and Hazardous Materials......................................................................... 72

4.10 Hydrology and Water Quality................................................................................. 77

4.11 Land Use and Planning.......................................................................................... 82

4.12 Noise and Vibration................................................................................................ 84

4.13 Population and Housing......................................................................................... 90

EXHIBIT B
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4.14 Public Services and Recreation............................................................................. 91

4.15 Transportation ........................................................................................................ 93

4.16 Tribal Cultural Resources....................................................................................... 97

4.17 Utilities and Service Systems................................................................................. 99

4.18 Wildfire ................................................................................................................. 102

4.19 Mandatory Findings of Significance..................................................................... 104

5. Document Preparers ................................................................................................... 106 List of Figures
1-1 Regional Context ....................................................................................................... 3 1-2 Local Context – North Richmond .............................................................................. 4 1-3 Project Site and Surrounding Landfill Context .......................................................... 5 2-0 Birdseye View of Project Site .................................................................................. 10 2-1 Project Site and Raven SR Facility Areas............................................................... 11 2-2 Simulated 3D Site Development.............................................................................. 13 2-3a South Elevation (West End) .................................................................................... 14 2-3b South Elevation (East End) ..................................................................................... 15 2-4 Detailed Site Layout and Raven SR Facility Plan ................................................... 16 2-5 Raven SR Process Diagram ................................................................................... 18

4.1-1 Wildcat Marsh Trail Approach Toward Project Site (from E) .................................. 27

4.1-2 Onsite View toward Project Site ............................................................................. 29 List of Tables

4.3-1 Average Daily Construction-related Criteria Pollutant Emissions (pounds per day) Without Mitigation................................................................................... 36

4.3-2 Air Permit Application's Average Annual Operational Criteria Pollutant Emissions (tons per year)..................................................................................... 37

4.3-3 CalEEMod Average Daily Operational-Related Criteria Pollutant Emissions (pounds per day)................................................................................. 37

4.3-4 Average Annual Operational-Related Criteria Pollutant Emissions (tons per year) ............................................................................................................... 38

4.8-1 BAAQMD GHG Thresholds of Significance ............................................................ 67

4.8-2 Annual Construction-Related Greenhouse Gas Emissions .................................... 68

4.8-3 Unmitigated Annual Operational Greenhouse Gas Emissions .............................. 70

4.12-1 Localized Roadway Traffic Noise ............................................................................ 86

4.12-2 Construction Equipment Noise Levels .................................................................... 87

4.12-3 Reference Noise Levels for Stationary Noise Sources Associated with the Proposed Project............................................................................................ 89

4.15-1 Project Daily Trip Generation Summary.................................................................. 95

4.15-2 Project VMT Summary............................................................................................. 96 Appendix
A Emissions Data, Assumptions and Modeling Files ................................................A-1 B Special Status Species Lists .................................................................................B-1 C Draft Mitigation Monitoring and Reporting Program (MMRP) ............................... C-1 1250

1. General Project Information
Raven SR Bioenergy Project 1 ESA / D202100382
Initial Study October 7, 2022

1. General Project Information

1.1 Project Title
Raven SR Bioenergy Project

1.2 Lead Agency Name and Address
City of Richmond (City)
Planning and Building Services Department
450 Civic Center Plaza
PO Box 4046
Richmond, CA 94804-1630

1.3 Project Case File Number
City Project Case Number: PLN21-282

1.4 Contact Person and Phone Number
Lina Velasco, Director of Community Development
Community Development Department
[email protected]
(510) 620-6841

1.5 Project Location
1 Parr Boulevard, Richmond, California (generally).

The proposed Raven SR Project location is within the West Contra Costa Sanitary Landfill (WCCSL) facility located in the northwest area of the City of Richmond, in Contra Costa County, California. For purpose of this environmental document, the project would occur within approximately 2.5 acres of the existing Republic Services Bulk Materials Processing Center (BMPC) within “Area A” of the WCCSL.
1,2 The property is located approximately 0.25 miles
west of Parr Boulevard (approximately 0.25 miles west from Richmond Parkway) via an unpaved access road. The northern boundary of the project site is the City of Richmond / Contra Costa County jurisdiction line; the project site is located wholly within the City of Richmond, except for use of an existing access/egress road located within the County. The project site is located within Assessor’s Parcel Number (APN) 408-140-009.
1 Actual project operations will occur on a subset area of approximately 1.3 acres that Raven SR will lease from BMPC.
2 “Area A” of the WCCSL is approximately 12 acres in the upland portion of the property that encompasses pollution control facilities and stockpile areas (separate from the closed Class I and active Class II landfill areas, the runoff ponds or lagoons delineated as “Area B”, and tidal waters delineated as “Area C”). Shown in Figure 3-1, Vicinity Map, of the Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions, June 2004. SCH. 2002102057. 1251

1. General Project Information
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Initial Study October 7, 2022
See Figure 1-1, Regional Context; Figure 1-2, Local Context – North Richmond; and Figure 1-3, Project Site and Surrounding Landfill Setting, on the following pages.

1.6 Project Applicant’s Name and Address
Raven SR S1, LLC 3
Matt W. Murdock CEO
PO Box 1360
Pinedale, WY 82941

1.7 Existing General Plan and Zoning Designations
The project site and surrounding area is located within the “Open Space” General Plan land use designation and “Open Space” zoning district.

1.8 Purpose and Intended Use of this Document
The purpose of this Draft Initial Study/Mitigated Negative Declaration (IS/MND) is to identify any potential environmental impacts that would result from implementation of the proposed project pursuant to California Environmental Quality Act (CEQA) Guidelines. As the project site is wholly located within the City limits, the City of Richmond has discretionary authority over the proposed project and is the lead agency in the preparation of this Draft IS/MND. The intended use of this document is disclose the potential environmental impacts and mitigation measures, if any, and to provide the basis for input from public agencies, organizations, and interested members of the public.

This CEQA document is a stand-alone analysis for the proposed project. Where appropriate and suitable, setting and context information from prior CEQA documents certified for the WCCSL/BMPC facility and operations is used in parts of this Draft IS/MND given that the project site is located within the WCCSL/BMPC facility.4 However, no part of the proposed project affects existing WCCSL/BMPC operations; the proposed development and Raven SR system is a wholly independent utility, except that it would use feedstock available from the current BMPC operation. Mitigation measures identified in this document will apply solely to the proposed project and do not conflict with any applicable mitigation measures identified in the previously certified WCCSL/BMPC CEQA documents. Similarly, and addressed separately from this CEQA document, the proposed project requires approval of a City of Richmond Conditional Use Permit (see Section 1.11, below), which is wholly independent from the existing City Conditional Use Permit (CU 1101132 as amended) and Contra Costa County Land Use Permit (LUP 2054-92 as amended) for the WCCSL/BMPC, as well as any existing permits, control 3 The project applicant is referred to throughout as “Raven SR”. “Raven SR” also refers to the multi-patented process/system. “Raven” refers to the proposed facility. 4 Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions, June 2004; and Addendum to the Final EIR for the WCCSL BMPC and Related Actions, 2009.

SCH. 2002102057.
1252
Figure 1-1
Regional Context
SOURCE: Raven LLC, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator 1253
Figure 1-2
Local Context - North Richmond
SOURCE: Raven LLC, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator 1254
Raven SR
Facility Location
WCCSL Organics Materials
Processing Facility (OMPF)
West Entrance & Scale Plaza
Parr Blvd
Wildcat Marsh Trail
Golden Bear Transfer Station
West County
Water District
Treatment Plant
WCCSL Organics Materials
Processing Facility (OMPF)
West Entrance & Scale Plaza
Parr Blvd
Wildcat Marsh Trail
Raven SR
Facility Location
Contra Costa County
City of Richmond
Golden Bear Transfer Station
West County
Water District
Treatment Plant
Figure 1-3
Project Site and Surrounding Landll Context
SOURCE: Raven LLC, 2022; ESA, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator Wildcat Creek Marsh Closed Class I Disposal Site Bay Trail / Levee Waste Recycling Facility Stormwater Leachate Trailhead/ Parking Lot
Basin Pond Golden Bear
1255

1. General Project Information
Raven SR Bioenergy Project 6 ESA / D202100382
Initial Study October 7, 2022
measures or cooperative agreements executed by various regulatory agencies that have permitting authority for the WCCSL/BMPC.

The remainder of this Section 1 provides an overview of the project’s primary characteristics and its environmental setting and required discretionary approvals. Section 2 describes the project in more detail, Section 3 is the draft environmental declaration, and Section 4 is the environmental checklist that evaluates the potential environmental impacts that may result from construction or operation of the proposed project. Section 5 contains the List of Preparers.

1.9 Project Overview
The Raven SR Bioenergy Project (project) proposes to construct and operate a bioenergy system composed of the Raven SR multi-patented Steam/CO2 Reformation process at the project site.5 The non-combustion process would convert blended green waste and food waste, obtained from the existing BMPC operation adjacent to the project site, into renewable, transportation grade hydrogen that would be exported offsite for various renewable energy products. No long-term hydrogen storage would occur onsite. The project would involve the erection of a modular structure and industrial canopy.

1.10 Environmental Setting
As shown in Figure 1-2, industrial use and natural waterways create the environment setting of the project site. The WCCSL facility spans approximately 340 acres generally between Parr Boulevard and San Pablo Bay, south of San Pablo Creek. This area is composed of expansive planted disposal areas/landfill mounds, runoff control ponds and lagoons, the organic material processing facility and composting areas, and the location of the proposed project (within part of the BMPC area), is situated in the southeast area of the WCCSL facility. San Pablo Creek and the San Pablo and Wildcat Creek tidal marshlands exist north and south of the WCCSL facility. Open water of San Pablo Bay is approximately 0.25 miles west from the project site.

Figure 1-3 shows the closest structure and development is the Golden Bear Waste Recycling Facility approximately 300 feet southwest of the proposed project location, and the West County Wastewater District Treatment Plant and the Wildcat Marsh Trail and trail head parking exist approximately 1,000 feet east of the project location. The surrounding uses are industrial, commercial and open space; the nearest sensitive receptors to the project site are residential uses, an elementary school, and a health clinic, all within approximately 0.75 to 1.2 miles southeast in the North Richmond area.

1.11 Required Discretionary Approvals
 City of Richmond (Lead Agency): Adoption of the CEQA Documentation, Mitigated Negative Declaration; Conditional Use Permit for a new activity and facility to convert 5 CO2 is carbon dioxide.
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Initial Study October 7, 2022
organic waste to hydrogen6; and various development permits, including but not limited to site preparation, construction and building activities.

1.12 Other Agencies Whose Review or Approval Is Required  Bay Area Air Quality Management District (BAAQMD): Issuance of an Authority to Construct (ATC) for the associated air pollutant emissions. Raven SR has applied for an ATC air permit to be issued by BAAQMD. This permit application is currently undergoing review.
 State Water Resources Control Board: Raven SR would submit Notices of Intent (NOI) to the State Water Board. Raven SR would submit the Construction NOI prior to any grading on the project site obtain coverage under both the statewide General Permit for Discharges of Storm Water Associated with Construction Activity and General Permit for Storm Water Discharges Associated with Industrial Activities. The Industrial NOI would be submitted prior to operation of the waste conversion system.  State Department of Resource Recovery and Recycling (CalRecycle) and Local Enforcement Agency (LEA): Issuance of Solid Waste Facility Permit (SWFP).

1.13 California Native American Tribes Consultation
Pursuant to Public Resources Code section 21080.3.1, on May 4, 2022, the City received a response for consultation from a representative of the Confederated Villages of Lisjan.

Consultation occurred on May 18, 2022, during which the tribe posed no concerns with the proposed project or potential mitigation measures as it relates to impacts to tribal cultural resources and cultural resources. See Section 4.16, Tribal Cultural Resources, of this checklist for more detail.
6 The existing WCCSL facility operates under an existing City of Richmond Conditional Use Permit (CUP) and other resources agency permits.
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2. Project Description
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2. Project Description

2.1 Existing Site Conditions and Ownership
Existing conditions of the project site are shown in Figure 2-0, Birdseye View of Project Site and Surrounding. The proposed Raven SR operation would be developed on approximately 1.3 acres that Raven SR would lease within part of the existing Republic Services BMPC property shown in Figure 2-0, however it would operate separately from the existing BMPC operation, which extends west of the project site. Figure 2-1, Project Site and Raven SR Facility Areas, delineates the proposed 2.5-acres that is referred to as the “project site” and highlights the 1.3 acres where the Raven facilities and operations would occur. The project site is relatively flat and partially paved, with the remainder consisting of compacted soil and ruderal groundcover along the north edge. No trees or landscaping exist.

The existing landfill power plant and maintenance building are primary structures near the project site, and both would remain. Existing trailers housing ancillary uses on the site would be removed, and remnant concrete foundations from previous uses exist on the north portion of the site. (See Figure 2-0).

The project site is currently served by utility infrastructure and services by East Bay Municipal Utilities District (EBMUD), West County Wastewater District, PG&E, and City of Richmond police, fire and emergency services departments.

The owner of the property is West County Sanitary Landfill, Inc., a subsidiary of Republic Services, Inc.

2.2 Surrounding Uses and Conditions
As highlighted in Figure 2-1, the project site is bound by existing fencing on the north, east and south, and connects to the surrounding WCCSL areas and operations via existing service road.

Not part of the proposed project, but within part of the BMPC property shown in Figure 2-0, the existing WCCSL maintenance building, power plant, and a leachate treatment facility sit within 50 to 100 feet of the site, and leachate tanks operate just west of the north driveway into the property from the main WCCSL access road.

Figure 1-3 shows the nearby Golden Bear Waste Recycling Facility, located approximately 300 feet southwest of the property. Also, the West County Wastewater District Treatment Plant and the Wildcat Marsh Trail and trail head parking exist approximately 1,000 feet southeast of the property. Figure 1-2 and Figure 1-3 show the surrounding expanse consists of components of the 340-acre WCCSL facility, which consists of several distinct operations that function as a whole.

Notably, these areas and uses include grass-covered disposal areas that are landfill mounds, runoff control ponds and lagoons, and composting areas, in addition to the tidal marshlands of San Pablo and Wildcat Creek tidal marshlands. Open water of San Pablo Bay is approximately

0.25 miles westward from the project site. (WCCSL BMPC Draft EIR, 2003) 1259
Figure 2-0
Birdseye View of Project Site and Surrounding (from SE) SOURCE: ESA, 2022; Google Earth, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator 1260
Conversion Operation
(modular building and canopy)
Fire Water Tank
& Equipment
Export Panels/Trucks
Figure 2-1
Project Site and Raven SR Facility Areas
N
SOURCE: Raven LLC, 2022; ESA, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator Bulk Materials Processing Center Property Raven SR Facility Areas 1261

2. Project Description
Raven SR Bioenergy Project 12 ESA / D202100382
Initial Study October 7, 2022

2.3 Site Plan and Structures
Figure 2-2, Simulated 3D Site Development, illustrates the proposed facility and key operation components simulated in a birds-eye view. All Raven SR’s materials handling systems would be located inside a proposed modular structure. The proposed project would erect a new stand-alone modular structure where storage uses and remnant foundations currently exist at the north edge of the property. The proposed modular structure and industrial metal canopy for the feed (or input) area would contain three primary areas for the three-stage process of the operation described below.

Figures 2-3a and 2-3b, South Elevations, illustrate the proposed facility and key operations in elevation, and Figure 2-4, Detailed Site Layout and Raven SR Facility Plan, identifies each component in detail. The total new building area would be approximately 40,000 square feet. The industrial feed material handler would be up to 31 feet tall and the tallest facility element. Other elements of height and size include the nitrogen tank (30 feet tall); the cooling tower and the fire water tank (both 25.5 feet tall); and the industrial metal canopy over the feed/unload storage area, the adjacent steam reformer structure, and the nitrogen tank (each 26 feet tall). 1262
Leachate
Tanks
WCCSL
Maintenance
Building
Bay Trail/Levee
Power
Generation
Building
Leachate Pond
Closed Class I Disposal Site
Figure 2-2
Simulated 3D Site Development
SOURCE: Raven LLC, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator 1263
Figure 2-3a
South Elevation (West End)
SOURCE: Raven LLC, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator 1264
Figure 2-3b
South Elevation (East End)
SOURCE: Raven LLC, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator 1265












 
 



   
Figure 2-4
Detailed Site Layout and Raven SR Facility Plan
SOURCE: Raven LLC, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator 1266

2. Project Description
Raven SR Bioenergy Project 17 ESA / D202100382
Initial Study October 7, 2022

2.4 Technology
Raven SR’s multi-patented Steam/CO2 Reformation technology can convert a variety of organic waste feedstocks into a hydrogen-rich synthesis gas (syngas) through a three-step process shown in Figure 2-5, Raven SR Process Diagram.
7 Organic feedstocks include biomass, municipal
solid waste, bio-solids, industrial waste, sewage, medical waste, or a combination of these, obtained from the existing WCCSL. The first stage of the process to turn feedstock into a raw syngas begins with an externally-heated “biomass steam reformer” and a “syngas steam reformer”. The raw syngas is then polished, and then processed through purification of hydrogen to make the hydrogen product: transportation-grade hydrogen-rich syngas.

The technology is strictly non-combustion (i.e., anoxic, indirect heating), low pressure, and a catalyst-free process. As indicated in Figure 2-5, early in the process, the system sequesters solid carbon in a byproduct, biocarbon (also referred to as “biochar”), which is a salable product that can be used for fertilizer or filler for concrete, for example. The biocarbon mixture also includes elements within the organic waste feedstock (dirt, glass, grit, rocks, inorganic salts, etc.) that are inert to the process, not gasified, and drop out in the first stage, avoiding slag and tars.8 The amount of biocarbon mixture is approximately 15 to 20 percent of the volume of dry feedstock input. (Also see Section 2.5, Safety and Controls, Non-Combustion, below.) Solid material that goes through the feed handling system, including any volatile material (such as plastics, refrigerants, batteries) that may incidentally flow through to the rotary reformer would be converted to syngas as they thermally decompose by exposure to temperatures in the range of 1,400 degrees F. Any volatile material would become part of the syngas, and non-volatile, inert material would report to the biocarbon solid phase. No emissions would be generated by any volatile materials that may inadvertently enter the process. (Also see Feedstock Processing, below.)
As also shown in Figure 2-5, the waste heat or “tail gas” from the conversion process can be blended with existing landfill gas (LFG, gas produced from the decomposition of organic solid wastes in the landfill) to generate power and increase the efficiency of the process. At some point in the cycle, the tail gas would no longer recycle into the process and instead go to the stack or flare, described below.

Flare System
Raven SR anticipates use of its flare system as a backup for the evacuation or venting of syngas and, on rare occasion, vent hydrogen product. The flare system would be in the constant state of readiness through a hooded, continuous propane pilot system. Use of the flare would be no more than 100 hours per year and occur on three typical instances:
7 Hydrogen-rich, 55 to 63 percent H2. 8 The biocarbon is considered sterile following thermal treatment by the first stage of the process, when biological pathogens (if any) are destroyed by elevated temperature and residence time of approximately 45 minutes. 1267
Feedstock
Management
Biomass Steam
Reforming
Syngas Steam
Reforming
Syngas
Polishing
Hydrogen
Purification
Blend of
Greenwaste
and Organic
Foodwaste
Overs
To Compost
Biochar
Tailgas
Hydrogen
Product
Power Generation Blend of LFG and
Tailgas
Stack
Or
Flare
LFG
Electricity
To Process
Supplemental
Electricity
From Grid
Richmond ONE – Simplified Block Flow Diagram
Copyright 2022 Raven SR, USA
Figure 2-5
Raven SR Process Diagram
SOURCE: Raven LLC, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator 1268

2. Project Description
Raven SR Bioenergy Project 19 ESA / D202100382
Initial Study October 7, 2022

1. System start-up: During start-up of the system, off-spec syngas would be generated and evacuated from the system to the flare for destruction of volatiles.

2. System shut-down: Whether for emergency shut-down or planned shutdown, the system would require its inventory of syngas to be vented to the flare for destruction of volatiles.

3. No off-take available: On the rare occasion when a product load-out truck is not available (e.g., traffic, breakdown, etc.) or an unplanned outage on the export equipment is experienced, and arrangements are in process for replacement and/or repair, Raven SR must vent valuable hydrogen product to the flare as it would have no provision for emergency storage.

These instances have been quantified in Raven SR’s air permit application to BAAQMD.

In 1993, the California Environmental Protection Agency’s Department of Toxic Substances Control (DTSC) determined that the Raven SR process for the production of syngas from biomass and other carbonaceous solids was not categorized as either incineration or combustion and was therefore a suitable technology for use in California.9

2.5 Operations
Pre-Processing and Load Checks
The origin of the feedstock and the pre-processing and screening redundancies built into the system processes would to ensure that little or no material contamination that is incompatible with the Raven SR process would be introduced to the conversion system. First, Republic Services would grind and screen the incoming mix of green waste and organic food waste before delivering the feedstock to Raven. Any non-compostable material and other prohibited wastes would be minimized through Republic’s screening and load checking programs that occur at its compost facility. 10
After screening and load checking, the organic material is pre-processed by grinding to reduce volume, provide for a uniform mixture of material and particle size, and further screen out any remaining contaminants. The pre-processed organic material would then be delivered approximately 2,500 feet from the compost area to the Raven SR facility by Republic personnel and vehicles. The trucks would consist of self-unloading transfer trucks or other suitable vehicles that would discharge loads as directed by a spotter onto the floor of Raven SR’s material 9 According to the definitions listed in Section 260.10, Title 40, Code of Federal Regulations (40 CFR) and Section 66260.10, Title 22, California Code of Regulations (22 CCR). Also, since 2017, a Raven pilot engineering unit, sized at 100 wet pounds per day of feedstock, has been operating at the UC Berkeley’s Richmond Field Station and is permitted for operation by the Bay Area Air Quality Management District (BAAQMD) under permit Nos. 23993 and 23320.
10 A load checking program are developed in compliance with Title 14, Code of California Regulations (CCR), §17409.5, and generally address the number of load checks to be performed; the location for the storage of prohibited wastes removed during the load checking process that is separately secured or isolated; records of load checks and the personnel training.
1269

2. Project Description
Raven SR Bioenergy Project 20 ESA / D202100382
Initial Study October 7, 2022
receiving area. There the material would be visually inspected and then pushed by a loader into storage bunkers or other designated material storage areas. The pre-processed feedstock material would be fed into a metering hopper to cross a screen to remove any oversized material, and then a magnetic separator to remove any unexpected metal. Any oversized material would be returned to Republic’s composting facility, and any recovered metal would be sent for recycling.

As discussed above in 2.4, Technology, if any materials are missed by the screening processes and enters the rotary reformer, those materials become part of process feed and would eventually become syngas or biocarbon.

Daily Quantities and Operations
The Raven facility would receive up to 99.9 wet tons per day of blended green waste and food waste feedstock to produce approximately 14 tons per day of biocarbon and up to 4,800 kilograms (kg) (5.3 tons) of hydrogen per day.11 Feedstock would be weighed on Republic scales before arriving at the Raven SR site, and the commodities that come out of the process would be weighed on Republic scales outside of the Raven SR site. The WCCSL material that would be diverted to the Raven SR facility by Republic represents a portion of their permitted 250 tons per day of compost processing capacity.

The Raven SR process and facility is designed for continuous operation without many start-ups or shut-downs. Accordingly, the Raven SR system would run up to 24 hours per day, seven days per week, although an average of 1.5 days per month are planned down times. This totals approximately 8,300 hours of operation per year.

Energy and Fuel Use
The plant would consume approximately 6.0+ MW of electricity (MWe) to operate and produce the 4,800 kg of hydrogen per day (200 kg of hydrogen per hour). The majority of the power would come from onsite power generation using newly installed engines, that would replace existing, inefficient engines. The fuel to be used for the generation is the existing LFG from the Republic Services BMPC, combined with the tail gas from the pressure swing absorber (PSA) unit to purify the hydrogen product. Republic Services would receive approximately 0.5 MW from the power generation for its onsite operation needs and the rest would be used to power the proposed project. Any additional electrical power required beyond that generated onsite would come from an existing PG&E power drop to the site, as also indicated in Figure 2-5.

Safety and Controls
No Combustion. The Raven SR’s facility’s controls would be distributed through the various process islands, taking their direction from a central Human-Machine Interface in the control room with centralized data collection. Process setpoints would be bounded by high/low alarm 11 While Raven SR can produce synthetic liquid fuels, the proposed Richmond location proposes to only produce transportation grade hydrogen due to the interest of the local and regional markets for non-fossil fuel based hydrogen.
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2. Project Description
Raven SR Bioenergy Project 21 ESA / D202100382
Initial Study October 7, 2022
limitations to draw the operator’s attention to the specific problem. The control system would represent state-of-the-art digital technology with redundant instrumentation where necessary to ensure safe operation.

Because the process itself is oxygen-free, there would be no opportunity within the process for explosion. Piping and vessels would be periodically scanned with infrared equipment to identify hot spots or gas leaks that may threaten safety. If hot spots or leaks were identified, immediate steps would be taken to correct or mediate the condition. Also, remote monitoring of the facility by Raven SR corporate provides oversight of the operation and early identification of problems as they development. The facility would maintain a “Plant Safety Handbook” and establish procedures to be followed if events threaten the safety of the facility or surroundings. The facility would maintain and evolve Standard Operating Procedures for aspects of the plant that require frequent intervention, for example, accepted procedures to accept a truck for loading of hydrogen product, to fill to regulated maximum allowable pressures, to ensure a cool-down period to allow the pressurized gas to shed the heat of compression, etc.

Safety Standards and Maintenance. Raven SR units are equipped with continuous monitoring systems and can automatically shut down plant operations without human intervention. The project would comply with applicable Environmental Protection Agency (EPA) risk management plan (RMP) and Occupational Safety and Health Administration (OSHA) process safety management (PSM) guidelines, as may be applied to the facility to ensure the safety of its operations staff and the surrounding community. A maintenance program of regular and preventative maintenance would also be implemented to maintain equipment in a reliable manner.

Fugitive Emissions. The system is a closed process once the organic feedstock input is managed. Mechanical seals prevent fugitive emission from the first-stage reformer which operates under mild pressure. The first stage vessel (SR1) has mechanical seals with pressurized nitrogen, which would prohibit the release of fugitive emissions. Tail gas generated by the process is combined with LFG and used as a fuel to generate additional energy.

Odor Control. Odors may exist from the organic feedstock input that is already produced and processed at the WCCSL. Nuisance odor from Raven is unlikely since feedstock material would only be on the feedstock management area floor for relatively short periods of time. However, odor control for the proposed Raven SR operation would be in place to minimize possible odors.

Also, the proposed industrial metal canopy would be placed over the feedstock floor and infeed equipment to prevent stormwater contact. Odor control would be added to the management area if objectionable odors occur. The facility could also store topical treatment solutions (non-toxic and biodegradable) onsite, which would be applied to neutralize odors if an immediate need arises.

Hydrogen Storage and Export Panel. The hydrogen product is compressed for short term storage before being exported via truck-mounted tube trailers for delivery to facilities using hydrogen for transportation or processes needing green hydrogen. There is no compression tank in the design. The produced hydrogen would be onboarded by a hydrogen gas export panel designed by a global manufacturer of hydrogen fueling stations to industry standards, 1271

2. Project Description
Raven SR Bioenergy Project 22 ESA / D202100382
Initial Study October 7, 2022
incorporating best-practice Health, Safety, Security and Environment (HSSE) design. The panel is compliant with National Fire Protection Association (NFPA) industry standards for handling hydrogen.

Onsite Water Tank / Fire Equipment. A new 250,000-gallon integrated fire water tank and diesel engine is proposed in the northeast corner of the site emergency use, as required by fire department regulations The fire water tank would be up to 25.5 feet tall . (Shown in Figures 2-1 through 2-4.)

2.6 Employment
Raven would employ approximately three to four employees per shift for the operation of the Raven facility, for a total of nine to 12 new employees to cover all shifts and provide necessary support of the facility. The facility would not involve customers onsite.

2.7 Transportation and Circulation
As indicated under “Safety Controls” above, the proposed project would export the produced hydrogen offsite via truck-mounted tube trailers (shown in Figures 2-2 through 2-4). The operation would involve up to approximately 12 hydrogen tube trucks and up to approximately 15 biocarbon trucks (total 37 trucks) per week, each with an average trip of 40 miles after leaving the site. Considering this with other trucks and employees coming to and leaving the project site daily, the project is estimated to generate about 130 vehicle trips on a typical weekday.

In addition, the Raven SR system would only use feedstock from ongoing existing BMPC operations on the property that would not leave the WCCSL site. Figures 2-2 and 2-4 show where WCCSL feedstock supply trucks would approach and exit the Raven facility from the feedstock prep area, and in addition to Figure 2-3a show three stalls where the tube trucks would connect to a hose and receive the hydrogen product. The tube trailers would idle for no more than five minutes once at project site, as required per State regulations.

2.8 Construction, Site Coverage and Drainage
Raven anticipates initiating construction activity on the project site in Fourth Quarter of 2022, which would continue for approximately eight months. Start-up of the plant is projected to begin in early the Second or Third Quarter of 2023.

Construction proposed is to demolish the existing materials and remove existing equipment from the project site, lightly regrade the site, add up to six inches of fill, and erect the new facility. The existing project site is mostly paved and partially pervious compacted soil and ruderal groundcover (see Figure 2-1). Existing materials to be excavated include remnant concrete foundations that would be pulverized and partially used as fill material.

The maximum depth of excavation would be up to 2.5 feet. All excavation spoils and remaining concrete debris would remain on the landfill site. Minimal fill, approximately 250 cubic yards, 1272

2. Project Description
Raven SR Bioenergy Project 23 ESA / D202100382
Initial Study October 7, 2022
would be hauled on site for grading; only demolition materials (asphalt and concrete) would be off hauled.

Approximately 0.76 acres of the 2.5-acre project site is currently impervious concrete or asphalt.

The proposed project would repave the existing 0.76 acres in addition to adding approximately

1.21 acres of impervious area (including modular structures), resulting in a total of 1.97 acres (or 78 percent) of impervious area on the site. Approximately 0.53 acres of unpaved area along the north edge of the site would remain undisturbed. There are no natural drainage paths on the site.

The project would adhere to all applicable regulatory stormwater runoff controls and would pursue its own National Pollutant Discharge Elimination System (NPDES) permit. The project’s stormwater plan would be integrated into the existing WCCSL system and ensure drainage from the proposed project site would drain towards existing stormwater runoff control ponds (or bioretention facility) to which the rest of the WCCSL property currently drains.

2.9 Off-site Improvements: Landscaping
As part of the proposed project, off-site landscaping improvements to the Wildcat Marsh Trail and trail head parking located approximately 1,000 feet east of the project location. Due to limited space and potential safety hazards, no new plants or vegetation would be installed within the Raven project site. Instead, new trees would be added to the public parking area near the trailhead.

Eleven drought-tolerant trees would be planted: either six large Coast Live Oak (Quercus agrifolia) or Big Leaf Maple (Acer macrophyllum), and five small California Buckeye (Aesculus californica). Both species are on City’s approved list of trees. Tree size planted would be associated with 15-gallon containers
1273

3. Environmental Factors Potentially Affected

3. Environmental Factors Potentially Affected
The environmental factors checked below would be potentially affected by this project, involvingat least one impact that is a "Potentially Significant Impact," as indicated by the checklist on thefollowing pages.

Aesthetics
Biological Resources
Geology, Soils and Seismicity
Hydrology and Water QualityNoise/VibrationRecreationUtilities and Service Systems Agriculture and Forestry Resources
Cultural Resources
II Greenhouse Gas EmissionsII Land Use and Planning
Population and Housing
II Transportation
Wildfire
Air Quality
EnergyHazards /Hazardous MaterialsMineral Resources
Public Services
Tribal Cultural Resources
Mandatory Findings of Significance
Determination: (To be completed by Lead Agency)
On the basis of this initial study:

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 in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.

I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTALIMPACT 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 potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATIONpursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR orNEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposedproject, no further environmental documentation is required. (/• /.>/\! •JL.
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Date
Printed Name For
Raven SR Bioenergy ProjectInitial Study
24 ESA /D202100382
October 7, 2022
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4. Environmental Checklist and Evaluation
Raven SR Bioenergy Project 25 ESA / D202100382
Initial Study October 7, 2022

4. Environmental Checklist and Evaluation

4.1 Aesthetics
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Aesthetics
Except as provided in Public Resources Code Section 21099, would the project:
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 building 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 point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing
scenic quality?

d) Create a new source of substantial light or glare
which would adversely affect day or nighttime views in the area?

Setting
The project site is within the WCCSL within an industrial, commercial, and open space setting of North Richmond. It is an integrated solid waste management and disposal facility and does not have significant visual value. Grading on the site over the years has resulted in topographic variations created by the hill forms or mounds that are the grass-covered landfills. The hill forms range from between elevations 110 and 160 feet above mean sea level, with up to an additional seven feet of soil layer (WCCSL BMPC Draft EIR, 2003). The area has little or no distinctive visual features, except for leachate treatment ponds, runoff control ponds and lagoons, and marshlands of Wildcat Creek.

Despite the absence of significant visual value within the WCCSL itself, the site provides extensive views in all directions, including unobstructed panoramic views of San Pablo Bay, San Pablo Ridge and Mt. Tamalpais across the Bay. The visual quality of the WCCSL has been assessed in numerous CEQA analyses over the years, and each determined that no aspect of the WCCSL operations would significantly affect visual quality. (WCCSL BMPC Draft EIR, 2003) Evaluation
a) Have a substantial adverse effect on a scenic vista? 1275

4. Environmental Checklist and Evaluation
Raven SR Bioenergy Project 26 ESA / D202100382
Initial Study October 7, 2022
Less than Significant Impact. Visual access the WCCSL from nearby public areas are distant and limited, largely because the surrounding areas are mostly at lower elevations than that of the WCCSL; distant views are blocked by buildings or landscaping. Views toward the WCCSL and the project site from Richmond Parkway are blocked by trees and the property is difficult to distinguish from adjacent and background across the Bay.

Northbound and southbound motorists on the Richmond Parkway can view the WCCSL, but views are limited, short-term and sometimes obscured or blocked by median landscaping or intervening trees and buildings. The proposed project site within part of the BMPC area is not visible from offsite areas as it is at an even lower elevation and behind intervening berms and levees.

Figure 4.1-1, Wildcat Marsh Trail Approach Toward Project Site (from East), captures part of the project site that would be visible to users of this public trail. The viewshed from this location does not capture any scenic vistas in the direction of the project site. Views toward the opposite direction of the site from the trail provides direct expansive views of the Wildcat Creek Marsh. Moreover, once developed, the facilities will appear consistent with the industrial nature of the existing visible facilities. The project would not have an adverse effect on a scenic vista. The impact would be less than significant.
b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic building within a State Scenic Highway? No Impact. No designated scenic highways currently exist within the City of Richmond, according to California Scenic Highway Program mapping system. (Caltrans, 2016) While the City’s prior 1994 General Plan and General Plan EIR identified portions of Richmond Parkway as having a positive aesthetic value, the proposed project site is not visible from the parkway. (Richmond, 2011)
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 point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
1276
Raven SR Bioenergy Project Initial Study
Figure 4.1-1
Wildcat Marsh Trail Approach Toward Project Site (from East) SOURCE: ESA, 2022
2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator 1277

4. Environmental Checklist and Evaluation
Raven SR Bioenergy Project 28 ESA / D202100382
Initial Study October 7, 2022
Less than Significant Impact. The 340-acre WCCSL facility, in which the project site sits, consists of several distinct operations that function as a whole. Notably, these operations and areas include grass-covered disposal areas, notably the main central, landfill hill, runoff control ponds and lagoons, and composting areas, in addition to the tidal marshlands of Wildcat Creek. As previously stated in this section, numerous environmental reviews pursuant to CEQA have been conducted on all WCCSL activities, all of which determined that none of the activities would significantly affect the visual quality of the facility.

The proposed project could be visible from points along the adjacent and lower Bay Trail, since segments of the Trail allow users to observe, from a safe distance, some recycling activities within the WCCSL property. To the extent that the proposed project facilities and operation could be visible, the views would be distant and would not be adverse relative to other visible WCCSL activities. Figure 4.1-2, Onsite View Toward Project Site, shows the existing visual character in which the proposed project would exists.

All feedstock material for the proposed operation would be organic materials sorted from the existing BMPC operation; no feedstock would be brought directly to the Raven facility from offsite. Product from the project operation would leave the project site in hydrogen tube trucks and biocarbon trucks. Therefore, operations of the Raven facility are not expected to be a source of litter that could exacerbate litter and dumping in the nearby neighborhoods.

Overall, the project’s effect on existing visual character or quality of public views of the site and its surroundings would be less than significant. d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Less than Significant Impact. Many activities within the WCCSL facility operate 24 hours a day, seven days per week, including the BMPC activities and waste recovery operations. Other onsite processing operations operate until midnight. All existing operations operate under approved County and City use permits, which requires all lighting systems to reduce glare and to not substantially impact area residents. Existing lighting is varied and includes various sizes of portable and directional flood lights on certain operations.
1278
Figure 4.1-2
Onsite View Toward Project Site
SOURCE: ESA, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator 1279

4. Environmental Checklist and Evaluation
Raven SR Bioenergy Project 30 ESA / D202100382
Initial Study October 7, 2022
The proposed project would also operate 24 hours a day, seven days per week, and would be developed within an existing, functional area of the BMPC operation, which is currently lighted. The project proposes LED lighting mounted on 30-foot-tall poles. Like the existing WCCSL and BMPC conditions, the additional lighting would be focused and shaded, incorporating directional shading (down-shot reflectors) to limit light pollution during night operations. The project would place nine single-light fixtures at throughout the site and three double-light fixtures in the truck loading area in the south portion of the site. Also, the continuous propane pilot light that fuels the flare system used as needed to evacuate or vent organic syngas or on rare occasion vent hydrogen product, would be hooded, thus minimizing its visibility from offsite.

Given existing lighting conditions and that the proposed project site is located within the varied topography of the WCCSL and would not be directly visible from offsite locations, the proposed project would not substantially alter current lighting conditions.

Moreover, any new lighting would not affect nighttime views in the area. This impact would be less than significant.

References
California Department of Transportation (Caltrans), 2016. Scenic Highways Program. Available at:
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8 057116f1aacaa. Accessed June 3, 2022.

City of Richmond, 2011. General Plan 2030 EIR. August 2011.

Contra Costa County, 2003. Draft Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions, SCH# 2002102057. November 2003.
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4.2 Agriculture and Forestry Resources
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Agriculture and Forestry Resources
In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the State’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:
a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland), as
shown on the maps prepared pursuant to the Farmland
Mapping and Monitoring Program of the California
Resources Agency, to non-agricultural use?

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?

Setting
The project site and its surroundings are zoned for “Open Space”, and has no history of agricultural uses (Richmond, 2012). Richmond sanitary service operations initiated within the area that is now the WCCSL in the early 1950s on previously undeveloped land.

Evaluation
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program (FMMP) of the California Resources Agency, to nonagricultural use?) 1281

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No Impact. The project site is located entirely within an area of and surrounded by industrial, commercial and open space uses. The site is not identified as Prime Farmland, Unique Farmland, or Farmland of Statewide or Local Importance by the FMMP, but is designated as Other Land, and is surrounded by lands designated as Urban Land and Other Land. The proposed project would have no impact on important farmland. (DLRP, 2012)
b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? No Impact. The project site and its surroundings are zoned for “Open Space”, and has no history of agricultural uses (Richmond, 2012). Also, the site is not covered by a Williamson Act contract (DLRP, 2012) Therefore, the proposed project would have no impact regarding existing agricultural zoning 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))?
No Impact. The proposed project site is not zoned as forest land or timberland, and there are no forests on the project site. No impact would occur with implementation of the proposed project.
d, e) Result in the loss of forest land or conversion of forest land to non-forest use? 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?
No Impact. As stated above, the proposed project is not zoned as forest land and there are no forests on the project site. The project would not result in the loss of forest land or conversion of forest land to non-forest uses, and would have no impact.

Also, the project would be constructed and operated entirely within a previously developed area within the WCCSL that is designated as Other Land by the FMMP. The project site does not contain farmland or forest land and there are no aspects of the project that would affect any agricultural land or forest land off-site. Therefore, the proposed project would not result in conversion of farmland or forest land, on-site or offsite, to a non-agricultural use or non-forest use. The project would have no impact.

References
California Department of Conservation, Division of Land Resource Protection (DLRP), 2012.

Contra Costa County Williamson Act FY 2012/2013. Available at:
ftp://ftp.consrv.ca.gov/pub/dlrp/wa/. Accessed May 12, 2022. 1282

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DLRP, 2014. Farmland Mapping and Monitoring Program. Contra Costa County Important Farmland Available at: www.conservation.ca.gov/dlrp/FMMP/Pages/Index.aspx. Accessed May 12, 2022.

City of Richmond, 2012. Richmond General Plan 2030: Land Use Element. April 25, 2012. 1283

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4.3 Air Quality
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Air Quality
Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations.

Would the project:
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 nonattainment under an applicable federal or State ambient air quality standard?

c) Expose sensitive receptors to substantial pollutant
concentrations? 
d) Result in other emissions (such as those leading to
odors or) adversely affecting a substantial number of
people?

Setting
The project site is located in Contra Costa County, which is in the San Francisco Bay Area Air Basin (SFBAAB), within the jurisdiction of the Bay Area Air Quality Management District (BAAQMD). The SFBAAB is currently designated as a nonattainment area for state and national ozone standards and national particulate matter ambient air quality standards. Development projects can contribute to a region’s adverse air quality impacts on a cumulative basis so the BAAQMD considered the emission levels for which a project’s individual emissions would be cumulatively considerable when developing thresholds of significance for air pollutants. The significance thresholds used for project construction and operational impact analyses are based on thresholds set in the BAAQMD’s CEQA Guidelines (BAAQMD 2017b).

For the purposes of this air quality analysis, sensitive receptors are defined as facilities and land uses that include members of the population that are particularly sensitive to the effects of air pollutants, such as children, the elderly, and people with illnesses. Examples of these types of uses include schools, hospitals, and daycare centers. Residential areas are also considered sensitive to poor air quality because these sensitive individuals could be present there, and people usually stay home for extended periods of time, which results in greater exposure to ambient air quality. There are no sensitive receptors within 1,000 feet of the project site. The nearest sensitive receptors to the project site are residences at generally West Gertrude Avenue/Malcolm Drive (approximately 0.75 miles southeast), Verde Elementary School at 2000 Giaramita Street (approximately 1.1 miles southeast), and Contra Costa Health Clinic at 1501 Fred Jackson Way (approximately 1.2 miles southeast).
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Evaluation
a) Conflict with or obstruct implementation of the applicable air quality plan? Less than Significant Impact. BAAQMD is the regional air quality authority in the project area. Primary goals of BAAQMD’s adopted 2017 Clean Air Plan are to protect public health by achieving attainment of air quality standards (BAAQMD, 2017a). The plan includes a wide range of proposed control measures, which consist of actions to reduce the non-attainment pollutants: state and federal 8-hour ozone standard, the state 1- hour ozone standard, the state PM10 standard, and the state and federal PM2.5 standards.

BAAQMD guidance states that “if approval of a project would not result in significant and unavoidable air quality impacts, after the application of all feasible mitigation, the project would be considered consistent with the Clean Air Plan” (BAAQMD 2017b). As indicated in the discussion of criteria “b” and “c” below, the project would not result in significant air quality impacts. Therefore, this impact would less than significant. 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?
Construction
Emissions from the construction phase of the project would be generated primarily from heavy duty equipment such as excavators, cranes, and forklifts. Criteria air pollutant emissions from equipment and on-road vehicle exhaust were estimated using CalEEMod (version 2020.4.0); modeling output files are included in Appendix A to this checklist.

Construction is assumed to take place over an eight-month period. Project specific data for construction phasing schedule and equipment fleet provided by the Project Applicant was used in the model to estimate emissions for the construction period. The total emissions (without mitigation) generated over the duration of construction were divided by the number of construction days for each partial construction year to determine average annual emissions from construction. Emissions from equipment and vehicle exhaust are presented in Table 4.3-1. As shown in the table, emissions of reactive organic gases (ROG) and nitrogen oxides (NOx), which are ozone precursors, and particulate matter (PM10 and PM2.5) would all be below their respective significance thresholds, which for construction have been established by BAAQMD in terms of average annual emissions. 1285

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TABLE 4.3-1

AVERAGE DAILY CONSTRUCTION-RELATED CRITERIA POLLUTANT EMISSIONS (TONS PER YEAR) WITHOUT MITIGATION
Project Average Daily
Construction Emissions by Year ROG NOx Exhaust PM10 Exhaust PM2.5 2022 0.11 1.00 0.04 0.04
2023 0.06 0.48 0.02 0.02
BAAQMD Threshold for
Significant Construction Impacts
10 10 15 10
Potential Significant Impact? No No No No
SOURCE: ESA (Appendix A to this checklist)
Operations
After the project is built, operational emissions, including stationary, mobile, and area sources, are anticipated to occur continuously throughout the project’s lifetime. The project is anticipated to begin operations in 2023.

The Project Applicant has submitted an air permit application that includes multiple stationary sources, shown in Table 4.3-2. According to the applicant’s air permit application, the majority of emissions would be generated from the biogas engine combustion process, where the engines emit exhaust that heats up a green waste rotary drier. The biogas engines are included in the list of proposed permitted sources, along with a green waste storage pile of up to 200 tons, a sheltered storage of limestone pellets would be used as a co-feed to the feedstock needed to reduce acid gas formation in the system process, a diesel-fired fire pump engine, as well as a flare that is a backup for the evacuation or venting of organic syngas or on rare occasion vent hydrogen product.

Notably, the project would replace an existing biogas-fired engine with three (3) newer, lower emitting, and more efficient Waukesha or Jenbacher engines. This replacement would result in a lower emissions profile in contrast to operating the facility using the existing engine. The project is also expected to increase the functional use of landfillproduced biogas, thereby reducing the amount of organic gas sent to a flare for venting or evacuation and ultimately reducing the flare-based emissions.

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landscape maintenance equipment, and fireplaces/stoves, evaporative emissions from architectural coatings, and consumer products. Table 4.3-4 shows the emissions from operational emission sources that are not part of the air permit application.

TABLE 4.3-2

AIR PERMIT APPLICATION'S AVERAGE ANNUAL OPERATIONAL CRITERIA POLLUTANT EMISSIONS (TONS PER YEAR)
Project Operations
Emissions by Source CO NOx VOC/ROG SO2
Exhaust
PM10
Exhaust
PM2.5
Biogas engines 50.69 7.19 5.70 6.63 5.13 5.13
Green waste off gas N/A N/A 2.38 N/A N/A N/A
Fugitive component leaks N/A N/A 0.63 N/A N/A N/A
Limestone handling N/A N/A N/A N/A 0.003 0.0005
Limestone storage N/A N/A N/A N/A 0.016 0.0024
Flare 0.092 0.16 0.0098 0.0002 0.0086 0.0086
Fire pump engine 0.055 0.04 0.0022 0.00009 0.0033 0.0033 Total 50.84 7.39 8.72 6.64 5.16 5.14
SOURCE: Ramboll Permit Application (Raven, 2022a)
TABLE 4.3-3

CALEEMOD AVERAGE ANNUAL OPERATIONAL-RELATED CRITERIA POLLUTANT EMISSIONS (TONS PER YEAR)
Project Operations Emissions
by Category ROG NOx Exhaust PM10 Exhaust PM2.5
Area 0.18 0 0 0
Energy <0.01 0.05 <0.01 <0.01
Mobile 0.14 0.16 <0.01 <0.01
Offroad 0.15 1.45 0.05 0.04
Waste N/A N/A 0 0
Water N/A N/A 0 0
Total 0.47 1.66 0.05 0.05
SOURCE: ESA (Appendix A to this checklist)
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TABLE 4.3-4

AVERAGE ANNUAL OPERATIONAL- RELATED CRITERIA POLLUTANT EMISSIONS (TONS PER YEAR)
Project Operations Emissions NOx VOC/ROG Exhaust
PM10
Exhaust
PM2.5
Air Permit 7.39 8.72 5.16 5.14
CalEEMod 1.66 0.47 0.05 0.05
Overall Total 9.05 9.19 5.21 5.19
BAAQMD Threshold for Significant
Operational Impacts 10 10 15 10
Potential Significant Impact? No No No No
Source: ESA (Appendix A to this checklist) and Ramboll Permit Application (Raven, 2022a) These tables show that on a project-level assessment, emissions do not exceed significant thresholds determined by BAAQMD for criteria pollutants emitted during operations, and therefore are less than significant.

Construction Air Emissions
Less than Significant Impact. Construction activities would result in emissions of the following non-attainment pollutants: reactive organic gases (ROG) and nitrogen oxides (NOx), which are ozone precursors, and particulate matter (PM10 and PM2.5). These pollutant emissions would be generated in the form of fugitive dust (PM10 and PM2.5) and in the form of exhaust by construction equipment, on-road vehicle trips of haul trucks for delivering construction material, water trucks for site dust control, and construction worker commutes to and from the project site.

Construction Dust
Less than Significant Impact, after Mitigation. Activities that generate dust include excavation and equipment movement across unpaved construction sites. Dust can be an irritant causing watering eyes or irritation to the lungs, nose, and throat. Excavation, grading, and other construction activities can cause wind-blown dust that adds PM10 and PM2.5 to the local atmosphere. The BAAQMD has taken a qualitative approach to addressing fugitive dust emissions during construction, such that any project that implements the BAAQMD Basic Construction Mitigation Measures Recommended for All Projects (Best Management Practices) would not result in a significant impact with respect to fugitive dust (BAAQMD 2017b). Mitigation Measure AQ-1: Best Management Practices, provided below, specifies BAAQMD recommended measures and would apply to all individual projects to address construction dust. In conclusion, while air emissions from construction equipment are all below the BAAQMD CEQA thresholds construction dust emissions are always considered significant within the SFBAAB unless the mitigation measures below are applied.
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Mitigation Measures
AQ-1: Best Management Practices.

All subsequent projects, regardless of size, shall implement the following best management practices to reduce construction impacts, particularly fugitive dust, to a less-than-significant level:
 All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day, except when not required for dust control.
 All haul trucks transporting soil, sand, or other loose material off-site shall be covered.
 All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.
 All vehicle speeds on unpaved roads shall be limited to 15 mph.  All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.
 Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations [CCR]). Clear signage shall be provided for construction workers at all access points.
 All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation.
 Post a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s phone number shall also be visible to ensure compliance with applicable regulations.

Operational Air Emissions
Less than Significant Impact. Based on the operational emissions modelled and summarized in Table 4.3-4 above, activitiesrelated to operating the bioenergy system would all be below significance thresholds.
c) Expose sensitive receptors to substantial pollutant concentrations? Construction
Less than Significant Impact. Construction equipment and associated heavy-duty truck traffic generate diesel exhaust, which is a known TAC. Construction exhaust emissions may pose health risks for sensitive receptors. However, there are no sensitive receptors 1289

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nearby the project site, which is zoned for open space uses. The nearest sensitive receptors are 0.75 miles southeast, or more than 1,000 feet, which is the distance considered in the BAAQMD CEQA Guidelines. Therefore, any concentrations of diesel particular matter (DPM) generated during construction would be less than significant.

Operations
Less than Significant Impact. The proposed project would introduce a new source of DPM and PM2.5 emissions due to the installation of an emergency diesel generator at the centralized treatment facility that would use California Air Resources Board (CARB)- certified diesel fuel. Emergency generators would be subject to BAAQMD permit requirements, which would ensure that operation of these generators would not significantly impact nearby receptors. These activities would result in minimal TAC emissions for emergency operations only (typically less than 50 hours per year), and therefore have negligible associated health risks to existing sensitive receptors in the area, the nearest being 0.75 miles from the project site. Other annual TAC concentrations from non-emergency operations of the generator were estimated in an annual emissions summary for operations at the project site (Raven, 2022a). An HRA was not conducted due to there not being any sensitive receptors within 1,000 feet of the project site and trigger levels not applying to the project. There would also be a rubber-tired loader associated with operations that would run 24 hours a day 7 days a week. Emissions from the loader were calculated using CalEEMod and included in the operational emissions, shown in Table 4.3-4.
d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Less than Significant Impact. Existing uses on and near the WCCSL include operations that are among typical odor sources of concern. These include wastewater treatment plants, sanitary landfills, transfer stations, composting facilities, petroleum refineries, chemical manufacturing facilities, and auto body shops. As a hydrogen production facility, the project would include organic feedstock processed during operations at the WCCSL, which is known to create odors. WCCSL implements various control measures to minimize odors associated with operation of the mixed waste processing.

The nearest sensitive receptors to the project site are residences at generally West Gertrude Avenue/Malcolm Drive, approximately 0.75 miles southeast. This is closer than the 1.0-mile odor screening distance for greenwaste handling established in the BAAQMD’s CEQA Guidelines. Also, an elementary school and a health clinic exist approximately 1.1 and 1.2 miles, respectively, from the project site - slightly beyond the screening distance. Uses between the project site and these the nearest sensitive receptors to the southeast include the West County Wastewater District Treatment Plant, EBMUD’s North Richmond Water Reclamation Plant, the Richmond Sanitary District, and other refuse services, automobile repair and towing businesses, and lawn services, etc. Topography in the area is relative flat, and no substantial areas of vegetation exist. 1290

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The prevailing wind direction in this area for the majority of the year (February through November) is from the south, blowing away from area of sensitive receptors. This prevailing wind direction shifts to the north, blowing toward the sensitive receptor area, for approximately two months of the year (December and January).

Nuisance odor from Raven is unlikely since feedstock material would only be on the feedstock management area floor for relatively short periods of time. Nor would the system’s tail gas or the as-needed flare generate noticeable odor. Also, other than the input of organic feedstock within the system, the process would not involve the storage or processing of other potentially odorous materials nor contribute to odor from nearby existing WCCSL activities. Regardless, as described in Section 2, Project Description¸ the project would involve odor control mechanisms to minimize possible additional odors from its operation. The proposed industrial metal canopy would be placed over the feedstock floor and infeed equipment to prevent stormwater contact. The project may incorporate control measures similar to those current employed by WCCSL, such as ensuring the input of feedstock into the system within a designated period of time from receiving it from WCCSL’s onsite organic material processing facility to prevent potential odor buildup; routine cleaning of floors, walls, and equipment; use of odor suppressants as deemed necessary. Odor control would be added to the management area if objectionable odors occur. The Raven facility could also store topical treatment solutions (non-toxic and biodegradable) onsite, which would be applied to neutralize odors if an immediate need arises. To the extent that any new sources of odor is attributable to the proposed project, the project applicant shall promptly log and respond to any complaints and remediated.

Therefore, any odor impacts from the proposed project would not be considered substantial nor likely contribute substantially to any existing odor sources of the WCCSL.

The impact would be less than significant.

References
BAAQMD, 2017a. Clean Air Plan, Spare the Air, Cool the Climate. April 19, 2017. Available at https://www.baaqmd.gov/~/media/files/planning-and-research/plans/2017-clean-airplan/attachment-a_-proposed-final-cap-vol-1-pdf.pdf?la=en. Accessed December 2020.

BAAQMD, 2017b. CEQA Air Quality Guidelines. Available online:
https://www.baaqmd.gov/~/media/files/planning-andresearch/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en. Accessed April 22, 2022.

BAAQMD, 2017c. Regulations 2 Permits Rule 1 General Requirements. Available online:
https://www.baaqmd.gov/~/media/dotgov/files/rules/regulation-2-rule1/documents/20171206_fr_0201- pdf.pdf?la=en&rev=42c6de7702484ea58dfcbcecaeafa29f. Accessed May 1, 2022.

RAVEN, 2022a Air Permit Application-Bioenergy Facility. Prepared by Ramboll US Consulting, Inc., (Ramboll) for Raven SR, April 2022.
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4.4 Biological Resources
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Biological Resources
Would the project:
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 United States 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, and regulations or by the California Department of Fish and Wildlife or United
States 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 wildlife nursery sites? 
e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?

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?

Setting
The project site is located in the upland area of the approximately 340-acre WCCSL, within the context of expansive grasslands and hills. The WCCSL borders San Pablo Bay and tidal marshland of naturalized portions of San Pablo and Wildcat creeks. The broader surrounding area of the WCCSL property is a low density industrial and open space area.

The local context in Figure 1-2 shows the project site located approximately 0.25-mile east of the San Pablo Bay shoreline, mudflats, and open water. The tidal marshland of San Pablo Creek is approximately 0.3 miles north/northeast of the project site, bordering the WCCSL north boundary which is an elevated levee. As shown in Figure 2-0, the marshlands of Wildcat Creek sit 1293

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approximately 280 feet south/southeast of the project site, bordering the WCCSL south boundary, which is also an elevated levee. A closed Class I landfill is immediately north of the project site and the main access road supports a cover of non-native grassland and ruderal vegetation species.

No trees exist on the project site. Several landscape trees occur at the Golden Bear Waste Recycling Facility, located approximately 300 feet southwest of the project site.

Biological resources were characterized through the review and compilation of existing information and a biological reconnaissance survey conducted by ESA biologists on June 29, 2022. The study area included the project construction area plus a 250-foot buffer, to account for potential indirect impacts to special-status species. The study area for special-status plant species includes the project construction area, plus a 10-foot buffer due to the lack of potential for indirect impacts to plants. No detailed surveys were conducted for special-status plants or wildlife or are deemed necessary based on the developed and manipulated conditions of the project site and surroundings, the scope of the proposed project’s construction and operations, and the proposed standard methods to minimize disturbance to sensitive resources in the vicinity.

Species / Habitats
The uplands of the WCCSL are either devoid of vegetation from on-going landfill operations and roadways, or are dominated by nonnative grasses and forbs. Plant species observed in the grassland at the periphery of the project site are dominated by non-native species such as Italian rye grass (Festuca perennis), wild oats (Avena spp.), storksbill (Erodium cicutarium), bristly oxtongue (Helminthotheca echioides), and ribwort (Plantago lanceolata). Several weedy species are also present along the margins of the site, including fennel (Foeniculum vulgare), wild radish (Raphanus spp.), black mustard (Brassica nigra), curly dock (Rumex crispus), prickly lettuce (Lactuca serriola), and iceplant (Carpobrotus edulis). Clumps of native coyote brush (Baccharis pilularis) are scattered through grasslands, road margins, and upper edge of the marshlands and levees.

While the highly disturbed project site provides little habitat that is suitable for special-status plants and wildlife, the surrounding grasslands and wetlands provide habitat for a variety of wildlife and plant species. Wildlife observed in the surrounding study area during the site reconnaissance survey include American crow (Corvus brachyrhynchos), red-tailed hawk (Buteo jamaicensis), western bluebird (Sialia mexicana), barn swallow (Hirundo rustica), common raven (Corvus corax), Canada goose (Branta canadensis), wild turkey (Meleagris gallopavo), blacknecked stilt (Himantopus mexicanus), turkey vulture (Cathartes aura), mallards (Anas platyrhynchos), killdeer (Charadrius vociferus), and several gull species (Larus spp.).

Sensitive aquatic habitats occur outside of the project boundary, and include wetlands, sloughs, creek channels, and the San Pablo Bay shoreline. San Pablo Creek is located approximately 600 feet east/northeast of the project site and is separated from WCCSL developed areas by a levee.

San Pablo Creek is tidally influenced and flows into the San Francisco Bay after flowing through San Pablo Creek Marsh. Emergent salt marsh vegetation occurs approximately 280 feet south/southwest of the project site within Wildcat Marsh, 0.3 miles north/northeast of the project site. Numerous shorebirds, waterfowl, and other wildlife use the marsh and mudflats for foraging and resting; however, the marsh is beyond the 250-foot project study area. 1294

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A number of special-status animal species have been reported from nearby creeks and marshes, including the state and federally-endangered salt marsh harvest mouse (Reithrodontomys raviventris) and California Ridgway’s rail (Rallus longirostris obsoletus), state-threatened California black rail (Laterallus jamaicensis coturniculus), and several other species considered to be California Species of Special Concern and Fully Protected by the State. Appendix B presents the special-status species considered in the analysis, including each species’ legal or protective status, habitat requirements, and blooming period (for plants), and the potential for occurrence within study areas. Higher elevations of the marsh typically provide important refuge for small mammals and birds during storms and high tides. However, due to the extent of developed and otherwise disturbed habitat on the project site, the narrow band of cover along the levee slope, and the intensity of human activity, the project site is not expected to provide upland retreat habitat for wildlife species, including species associated with salt marsh and other wetland habitats.

Several special-status plant species are known from the uplands and coastal salt marsh habitats along the shoreline of San Francisco and San Pablo Bays, but none have been reported from the vicinity of the WCCSL. A single occurrence of fragrant fritillary (Fritillaria liliacea) was reported from the Point Richmond area in 1900, but this occurrence is believed to have been extirpated by development, and suitable habitat is absent on the site. Other special-status plant species known from marshland habitat along the shoreline of San Pablo Bay include: the State rare soft-haired bird’s beak (Chloropyron molle ssp. molle), Mason’s lilaeopsis (Lilaeopsis masonii), and San Francisco gumplant (Grindelia hirsutula var. maritima). These California Rare Plant Rank 1B species are considered rare under Section 13580 of the California Environmental Quality Act (CEQA) Guidelines. None have been reported from the WCCSL, and suitable habitat is absent on portions of the site proposed for improvements.

Wetlands
No wetlands or other aquatic resources occur within the project site. Jurisdictional wetlands and unvegetated waters extend over the northern coastal salt marsh, open water habitat, and San Pablo Creek channel. The sloughs, creek channel, and bay shoreline which border the WCCSL property are all under tidal influence. The upland portions of the WCCSL property do not support wetlands, and the engineered basins designed for runoff control and leachate treatment, including basins located to the south and west of the project site, are exempt from state and federal wetland jurisdiction.

Evaluation
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 United States Fish and Wildlife Service?
A list of special-status species that occur in the project region was identified based upon review of existing information, including queries of the California Natural Diversity Database (CNDDB), U.S. Fish and Wildlife Service (USFWS) Official Species List, and 1295

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the California Native Plant Society (CNPS). Habitats at the project area were assessed for their potential to support special-status species using information about local species occurrences and species’ habitat requirements, in combination with the site visit described above (Appendix B).

Plants
No special-status plant species are expected to occur on the disturbed project site. Site preparation for the project would involve minimal grading for the erection of the modular building and the replacement of existing compacted soil, ruderal groundcover and partially paved areas where special-status plants are not expected to occur. Hence, no impacts would occur to special-status plants.

Wildlife
The project site exists within a previously disturbed upland portion of the WCCSL that does not provide habitat for special-status wildlife species. Due to the extent of past development, no special-status wildlife species are expected to occur within the project site. Additionally, basins and runoff control ponds located to the south and west of the project site do not provide suitable habitat for special-status species.

Beyond the site boundaries, surrounding wetland and annual grassland habitat may provide habitat for special-status wildlife species. The following species are considered to have the potential to occur within these areas: short-eared owl (Asio flammeus), western burrowing owl (Athene cunicularia hypugaea), northern harrier (Circus hudsonius), loggerhead shrike (Lanius ludovicianus), California black rail (Laterallus jamaicensis coturniculus), and California Ridgway’s rail (Rallus longirostris obsoletus). Short-eared owl, western burrowing owl, northern harrier, and loggerhead shrike are California Species of Special Concern. Uplands and wetlands outside of the project site provide potential foraging habitat for these species. Upland grassland and ruderal habitats provide potential nesting habitat. Short-eared owl and northern harrier are ground nesting species, while loggerhead shrikes nest in shrubs and occasionally items such as brush piles, generally between two and four feet off the ground. Western burrowing owls nest underground in burrows dug by mammals such as California ground squirrels (Otospermophilus beecheyi).

California Ridgway’s is listed as endangered under both the Federal Endangered Species Act (FESA) and the California Endangered Species Act (CESA), and is a state fullyprotected species. Ridgway’s rails are found in tidal and brackish marshes where they typically construct nests in or under dense marsh vegetation, such as marsh gumplant and pickleweed at an elevation high enough to avoid inundation during high tides. California black rail is listed as threatened under CESA and is a state fully-protected species. This species nests and forages in tidal emergent wetland. Suitable marsh habitat for both of these species is present within 500 feet of the project site and multiple occurrences are known from marshes adjacent to or nearby the project site. 1296

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In addition to the aforementioned special-status species, common raptors and other bird species may forage in uplands and marshes on the edges of the study area. While no trees exist on the project site, trees approximately 300 feet southwest of the project site at the Golden Bear Waste Recycling Facility have potential to support raptor nesting. Current activity on the project site involves large truck traffic, human activity, operation of machinery and elevated noise levels. Regardless, some bird species, such as killdeer (Charadrius vociferus) and American crow (Corvus brachyrhynchos), tend to be highly tolerant of human disturbance and may still nest in areas with relatively high levels of human activity.

Construction
Less than Significant Impact, after Mitigation. Bird species listed under FESA and CESA, as well as non-ESA-listed birds, are afforded conservation protections. Breeding birds are protected under California Fish and Game Code (FGC) Section 3503 and raptors are protected under Section 3503.5. In addition, FGC Section 3513 and the Federal MBTA (16 USC, Sec. 703 Supp. I, 1989) prohibit the killing, possession, or trading of migratory birds. Finally, FGC Section 3800 prohibits the taking of non-game birds, which are defined as birds occurring naturally in California that are not game birds or fully protected species. Impacts during the non-breeding season are not considered significant, primarily due to the birds’ mobility and ability to access other high-quality foraging habitat in the region. Also, the project site is disturbed and provides poor habitat for nesting birds. However, equipment staging and project construction could render the site and adjacent areas temporarily unsuitable for breeding birds due to the noise, vibration, and increased activity levels associated with grubbing, earth moving, heavy equipment operation, and increased human presence even when the nest itself is unaffected. These activities could cause birds that have established a nest prior to the start of construction to change their behavior or even abandon an active nest, putting eggs and nestlings at risk for mortality. This would be considered a significant impact.

Implementation of Mitigation Measure BIO-1: Avoid and Minimize Impacts to Nesting Birds, Except Rails, and Mitigation Measure BIO-2: Avoid and Minimize Impacts to California Black Rail and California Ridgway’s Rail would reduce potential constructionrelated impacts to nesting special-status birds to a less-than-significant level by requiring avoidance of construction-related work during the nesting bird season, or if avoidance of the nesting season is not possible, pre-construction nesting bird surveys and establishment of no-construction buffer zones around active bird nests. With implementation of Mitigation Measures BIO-1 and BIO-2, construction-related impacts would be less than significant.

Mitigation Measure BIO-1: Avoid and Minimize Impacts to Nesting Birds, Except Rails
To the extent practicable, project construction activities requiring heavy equipment, or any tree trimming, shall be performed outside of the bird nesting season (February 1st through August 31st) to avoid impacts to nesting birds. If these activities must be 1297

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performed during the nesting bird season, a qualified biologist shall be retained to conduct a pre-construction survey in the project construction and staging areas for nesting birds and verify the presence or absence of nesting birds no more than 14 calendar days prior to construction activities or after any construction breaks of 14 calendar days or more. Surveys shall be performed for the project construction and staging areas and suitable habitat within 250 feet of the project construction and staging areas in order to locate any active passerine (perching bird) nests and within 500 feet of the project construction and staging areas to locate any active raptor (birds of prey) nest, including potential burrowing owl burrows. If nesting birds and raptors do not occur within 250 and 500 feet of the project area, respectively, then no further action is required if construction begins within 14 calendar days.

If active nests are located during the pre-construction bird nesting surveys, nodisturbance buffer zones shall be established around nests, with a buffer size established by the qualified biologist. Typically, these buffer distances are between 50 feet and 250 feet for passerines and between 150 feet and 500 feet for raptors. These distances may be adjusted depending on the level of surrounding ambient activity and if an obstruction, such as a building or structure, is within line-of-sight between the nest and construction. Reduced buffers may be allowed if a full-time qualified biologist is present to monitor the nest and has authority to halt construction if bird behavior indicates continued activities could lead to nest failure. Buffered zones shall be avoided during construction-related activities until young have fledged or the nest is otherwise abandoned. If active burrowing owl dens are found within the survey area, the Project Applicant shall implement measures at least equal to the 2012 (or subsequent applicable) CDFW Staff Report (CDFG, 2012), as determined by the qualified biologist.

Mitigation Measure BIO-2: Avoid and Minimize Impacts to California Black Rail and California Ridgway’s Rail
 To minimize or avoid the loss of individual California black rail and Ridgway’s rail, construction activities requiring heavy equipment, adjacent to tidal marsh areas (within 500 feet [150 meters] or a distance determined in coordination with U.S. Fish and Wildlife (USFWS) or the California Department of Fish and Wildlife (CDFW)), shall be avoided during the breeding season from February 1 through August 31.  If areas within 500 feet of rail habitat cannot be avoided during the breeding season (February 1 through August 31), protocol-level surveys shall be conducted to determine rail nesting locations. The surveys will focus on potential habitat that could be indirectly disturbed by construction activities during the breeding season to ensure that rails are not breeding within 500 feet of project activities.

Survey methods for rails will follow the Site-Specific Protocol for Monitoring Marsh Birds, which was developed for use by USFWS and partners (Wood et al. 2017).

Surveys are concentrated during the approximate period of peak detectability, January 15 to March 25 and are structured to efficiently sample an area in three rounds of surveys by broadcasting calls of target species during specific periods of each survey round. Call broadcast increase the probability of detection compared to passive surveys when no call broadcasting is employed. This protocol has since been 1298

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adopted by Invasive Spartina Project (ISP) and Point Blue Conservation Science to survey Ridgway’s rails at sites throughout San Francisco Bay Estuary. The survey protocol for Ridgway’s rail is summarized below.
 Previously used survey locations (points) should be used when available to maintain consistency with past survey results. Adjacent points should be at least 200 meters apart along transects in or adjacent to areas representative of the marsh. Points should be located to minimize disturbances to marsh vegetation.

Up to 8 points can be located on a transect.
 At each transect, three surveys (rounds) are to be conducted, with the first round of surveys initiated between January 15 and February 6, the second round performed February 7 to February 28, and the third round March 1 to March 25.

Surveys should be spaced at least one week apart and the period between March 25 to April 15 can be used to complete surveys delayed by logistical or weather issues. A Federal Endangered Species Act Section 10(a)(1)(A) permit is required to conduct active surveys.
 Each point on a transect will be surveyed for 10 minutes each round. A recording of calls available from USFWS is broadcast at each point. The recording consists of 5 minutes of silence, followed by a 30-second recording of Ridgway’s rail vocalizations, followed by 30 seconds of silence, followed by a 30-second recording of California black rail, followed by 3.5 minutes of silence.  If no breeding Ridgway’s rails or black rails are detected during surveys, or if their breeding territories can be avoided by 500 feet (150 meters), then project activities may proceed at that location.
 If protocol surveys determine that breeding Ridgway’s rails or black rails are present in the project area, the following measures would apply to project activities conducted during their breeding season (February 1- August 31):
 The applicant shall coordinate with the USFWS- and CDFW, as appropriate depending upon species, to determine if project activities can continue during the nesting season based on nest location, natural visual barriers (e.g., levees) between the project and marshlands, and the distance between proposed activities and identified activity centers. If impact cannot be avoided during the rail nesting season, activities would be delayed until after the nesting season.

Operations
Less than Significant Impact. Current activity on the project site involves large truck traffic, human activity, operation of machinery and elevated noise levels associated with the Republic Services BMPC property and the existing landfill power plant. The proposed Raven SR operation is not expected to significantly change the level of activity that is currently conducted within the project area and, therefore, long-term operation of the Raven SR operation is not expected to result in significant impacts to biological resources within the project area.
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There is also existing permanent lighting associated with the current 24-hour activities of the BMPC and the project site. The proposed project would not substantially increase existing nighttime lighting to result in an adverse impact to existing bird species. The project proposes LED lighting mounted on 30-foot-tall poles. Similar to existing conditions, the project lighting would be focused and shaded, incorporating directional shading (down-shot reflectors) to limit light pollution during night operations. The project would place nine single-light fixtures at throughout the site and three double-light fixtures in the truck loading area in the south portion of the site.

No part of the proposed facility would exceed 31 feet in height, which is the height of the industrial feed material handler. Other elements of height and size include the nitrogen tank (30 feet tall); the cooling tower and the fire water tank (both 25.5 feet tall); and the industrial metal canopy over the feed/unload storage area, the adjacent steam reformer structure, and the nitrogen tank (each 26 feet tall). Therefore, no part of the project would exceed 45 feet in height, in which case the project would comply with the City of Richmond’s Bird-Safe Buildings Municipal Ordinance.

Overall, the proposed project also would not alter any of the area’s natural resources or native vegetation in a way that could adversely impact biological resources. The impact would be less than significant.
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of Fish and Wildlife or United States Fish and Wildlife Service?
No Impact. The project site does not contain any riparian habitat or other sensitive natural communities. The nearest sensitive habitat is well-preserved coastal salt marsh occur along the San Pablo Bay shoreline, Wildcat Marsh, and along the upper banks of San Pablo Creek. The project site is located 0.25 miles east of the shoreline, approximately 0.3 miles south of San Pablo Creek’s upper banks, and within 300 feet of Wildcat Marsh, which is separated from the project site by the Bay Trail levee. The proposed project does not involve any activity that would affect these areas. Therefore, the proposed project would have no impact.
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? No Impact. The project site does not contain any State or federally protected wetlands.

The proposed development would not impact any waterbodies in any way and therefore would have no impact on protected wetlands.
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 wildlife nursery sites? 1300

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Less than Significant Impact. The project site is not in a natural condition and contains development and current truck and other operations of the BMPC. Due to the existing developed nature of the site, the project site does not provide suitable habitat to be considered a wildlife nursery site. Additionally, wildlife movement within the project site is restricted by existing privacy fencing that surrounds the project area. While the surrounding uplands and wetlands provide habitat for the movement of native resident and migratory wildlife, activities associated with the project are not expected to directly impact these areas or impede wildlife movement. Therefore, this impact would be less than significant.
e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Less than Significant Impact. Construction or operation of the proposed project would not conflict with any local policies or ordinances protecting biological resources. There are no existing trees on the project site, nor are any proposed due to limited space and potential safety hazards. However, as part of the proposed project, off-site landscaping improvements are proposed to the Wildcat Marsh Trail and trail head parking located approximately 1,000 feet east of the project site. Eleven drought-tolerant trees would be planted: either six large Coast Live Oak (Quercus agrifolia) or Big Leaf Maple (Acer macrophyllum), and five small California Buckeye (Aesculus californica). Both species are on City’s approved list of trees. Tree size planted would be associated with 15-gallon containers. The project is subject to and would adhere to the City’s local tree protection policies and regulations. Also, as addressed under Section 4.12, Noise and Vibration, of this checklist, the project would adhere to the City of Richmond Noise Ordinance regarding noise levels during temporary construction activity, as well as the operational noise levels. Therefore, this impact would be less than significant. 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?
No Impact. The project site does not lie within the boundaries of any an adopted Habitat Conservation Plan (HCP) or Natural Community Conservation Plan (NCCP) or any other approved local, regional, or State habitat conservation plan.

References
California Department of Fish and Game (CDFG). 2012. Staff Report on Burrowing Owl Mitigation. Dated March 7, 2012.

California Department of Fish and Wildlife (CDFW). List of Vegetation Alliances and Associations (or Natural Communities List), Vegetation Classification and Mapping Program. Available online: www.dfg.ca.gov/biogeodata/vegcamp/natural_comm_list.asp.

Accessed June 14, 2022.
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CDFW. California Natural Diversity Database (CNDDB) for 7.5-minute topographic quadrangles Richmond, Briones Valley, San Francisco North, Oakland West, Oakland East, Petaluma Point, Mare Island, Benicia, San Quentin, Commercial Version. Accessed June 14, 2022.

CDFW. Natural Diversity Database. 2022. Special Animals List. Periodic publication.

CDFW. Special Vascular Plants, Bryophytes, and Lichens List. Accessed 2022.

California Native Plant Society (CNPS). Inventory of Rare and Endangered Plants (online edition, Z
), California Native Plant Society, Sacramento, CA. Available at:
www.rareplants.cnps.org. Accessed June 14, 2022.

City of Richmond, 2012. Richmond General Plan 2030: Conservation, Natural Resources and Open Space Element. Adopted April 25, 2012.

Contra Costa County 2004. Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions, SCH. 2002102057. June 2004.

Contra Costa County 2009. Addendum to the Final EIR for the WCCSL BMPC and Related Actions, SCH. 2002102057. 2009.

United States Fish and Wildlife Service (USFWS). 2022. List of threatened and endangered species that may occur in your proposed project location, and/or may be affected by the Raven SR Bioenergy Project. Consultation Code: 2022-0054185. June 14, 2022.

Wood, J.K., Nur, N., Salas, L. and O.M.W. Richmond. 2017. Site-specific Protocol for Monitoring Marsh Birds: Don Edwards San Francisco Bay and San Pablo Bay National Wildlife Refuges. Prepared for the U.S. Fish and Wildlife Service, Pacific Southwest Region Refuge Inventory and Monitoring Initiative. Point Blue Conservation Science.

Petaluma, CA.
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4.5 Cultural Resources
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Cultural Resources
Would the project:
a) Cause a substantial adverse change in the
significance of a historical resource as pursuant to
Section 15064.5?

b) Cause a substantial adverse change in the
significance of an archaeological resource pursuant to
Section 15064.5?

c) Disturb any human remains, including those interred
outside of formal cemeteries? 
Setting
To determine the cultural resources sensitivity of the project site, ESA completed a records search and background research, including a review of historic maps, aerial imagery, and geologic/soils data. ESA staff conducted a records search at the Northwest Information Center (NWIC) of the California Historical Resources Information System on March 23, 2022 (File No. 21-1575). The purpose of the records search was to (1) determine whether known cultural resources have been recorded in the vicinity of the project site; (2) assess the likelihood for unrecorded cultural resources to be present based on historical references and the distribution of nearby sites; and (3) develop a context for the identification and preliminary evaluation of cultural resources. The records search consisted of an examination of the following documents:
 NWIC digitized base maps (USGS San Quentin, CA 7.5-minute topographic map), to identify recorded archaeological sites and studies within a 0.5-mile radius of the project site.  NWIC digitized base maps (USGS San Quentin, CA 7.5-minute topographic map), to identify recorded historic-era resources of the built environment (building, structures, and objects) within and adjacent to the project site.
 Resource Inventories: California Inventory of Historical Resources, California Historical Landmarks, Built Environment Resource Directory (BERD) (through March 2020) and Archaeological Determinations of Eligibility (as of April 2012) for Contra Costa County.

No cultural resources have been previously recorded in the vicinity of the project site and there are no historic-age architectural resources in or adjacent to the project site. The nearest cultural resources are a series of pre-contact archaeological sites nearly 1 mile to the east that contribute to the Lower San Pablo Creek Archaeological District. These resources would not be impacted by the proposed project. The underlying geology of the project site consists of artificial fill over Holocene Bay Mud deposits. The historic shoreline is approximately 0.4 miles (2,000 feet) east of the project site; pre-contact and historic-era archaeological sites in this environment would be located at or very near to the historic shoreline.
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Therefore, this analysis concludes that the sensitivity for pre-contact and historic-era archaeological resources is low and the potential to uncover archaeological resources during project implementation is also low.

Evaluation
a) Cause a substantial adverse change in the significance of a historical resource as pursuant to Section 15064.5?
No Impact. CEQA Guidelines Section 15064.5 requires the lead agency to consider the effects of a project on historical resources. A historical resource is defined as any building, structure, site, or object listed in or determined to be eligible for listing in the California Register of Historical Resources (California Register), or determined by a lead agency to be significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, or cultural annals of California. The following discussion focuses on architectural and structural resources. Archaeological resources, including those that are potentially historical resources according to CEQA Guidelines Section 15064.5, are addressed below under question b).

As a result of the records search and background research, it was determined that there are no architectural or structural resources in or adjacent to the project site that potentially qualify as historical resources, as defined in CEQA Guidelines Section 15064.5. As such, there are no historical resources present within the project site and there would be no impact on historical resources.
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5?
Less than Significant Impact, after Mitigation. This section discusses archaeological resources, both as historical resources according to CEQA Guidelines Section 15064.5, as well as unique archaeological resources, as defined in California Public Resources (PRC) (CEQA) Section 21083.2(g). A significant impact would occur if the project would cause a substantial adverse change to an archaeological resource through physical demolition, destruction, relocation, or alteration of the resource.

Based on the results of the background research and environmental context, the potential for encountering archaeological resources during project implementation is low. However, in the unlikely event that a previously unrecorded archaeological resource is identified during project ground-disturbing activities and found to qualify as a historical resource or a unique archaeological resource, any impacts on the resource resulting from the project could be potentially significant.

Implementation of Mitigation Measure CUL-1a: Cultural Resources Awareness Training and Mitigation Measure CUL-1b: Inadvertent Discovery of Cultural Materials or Tribal Cultural Resources would reduce potentially significant impacts to less than significant. In the event of an inadvertent discovery of any cultural materials or tribal cultural resource, 1304

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these mitigation measures would ensure that all personnel complete a cultural resources awareness training prior to any ground-disturbing activity and that work halts in the vicinity until a qualified archaeologist can make an assessment and provide additional recommendations if necessary, including contacting Native American tribes.

Mitigation Measure CUL-1a: Cultural Resources Awareness Training.

Prior to authorization to proceed, the City shall engage a qualified archaeologist, defined as an archaeologist meeting the U.S. Secretary of the Interior’s Professional Qualification Standards for Archeology, to conduct a training program for all construction workers involved on site disturbance. On-site personnel shall attend a mandatory pre-project training that outlines the general archaeological sensitivity of the vicinity and the procedures to follow in the event an archaeological resource and/or human remains are inadvertently discovered.

Mitigation Measure CUL-1b: Inadvertent Discovery of Cultural Materials or Tribal Cultural Resources.

If pre-contact or historic-era cultural materials are encountered during project implementation, all construction activities within 100 feet of the find shall halt and the contractor shall notify the City. The City shall notify a qualified archaeologist who will inspect the find within 24 hours of discovery and provide the City of an initial assessment. Pre-contact cultural materials might include obsidian and chert flaked-stone tools (e.g., projectile points, knives, scrapers) or toolmaking debris; culturally darkened soil (“midden”) containing heat-affected rocks, artifacts, or shellfish remains; stone milling equipment (e.g., mortars, pestles, handstones, or milling slabs); and battered stone tools, such as hammerstones and pitted stones.

Historic-era cultural materials might include building or structure footings and walls, and deposits of metal, glass, and/or ceramic refuse.

This shall include documentation of the resource and may include data recovery (according to PRC Section 21083.2), if deemed appropriate, or other actions such as treating the resource with culturally appropriate dignity and protecting the cultural character and integrity of the resource (according to PRC Section 21084.3). c) Disturb any human remains, including those interred outside of formal cemeteries? 1305

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Less than Significant Impact, after Mitigation. The records search and background research conducted for the project determined that no human remains are known to exist within the project site. Therefore, the project is not anticipated to impact human remains, including those interred outside of formal cemeteries. While unlikely, if any previously unknown human remains were encountered during ground-disturbing activities, impacts on the human remains resulting from the project could be potentially significant.

Implementation of Mitigation Measure CUL-2: Inadvertent Discovery of Human Remains, would reduce potentially significant impacts to less than significant. This measure shall comply with applicable state laws, including Section 7050.5 of the Health and Safety Code. This would require work halt in the vicinity of a find and the immediate notification of the County Coroner. If the Coroner determines that the human remains are Native American, they would notify the California Native American Heritage Commission, who shall appoint a Most Likely Descendant (PRC Section 5097.98).

Mitigation Measure CUL-2: Inadvertent Discovery of Human Remains.

If human remains are encountered during project implementation, the contractor shall halt all construction activities within 100 feet of the find and notify the City.

The City shall contact the Contra Costa County Coroner who will determine that no investigation of the cause of death is required. If it is determined that the remains are Native American, the Coroner shall contact the Native American Heritage Commission within 24 hours. The Commission shall then identify the person or persons it believes to be the Most Likely Descendant from the deceased Native American, who in turn would make recommendations for the appropriate means of treating the human remains and any grave goods.

References
Northwest Information Center (NWIC), Records Search File No. File No. 21-1575. On file, ESA, March 23, 2022.
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4.6 Energy
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Energy
Would the project:
a) Result in potentially significant environmental
impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project
construction or operation?

b) Conflict with or obstruct a State or local plan for
renewable energy or energy efficiency? 
Setting
In 2020, more than 35 percent of the electricity PG&E delivered to its customers came from eligible renewable resources including solar, wind, bioenergy, geothermal and small hydropower and is on target to meet the 2045 goal (PG&E, 2021). As introduced in Section 2, Project Description, the Raven SR project would consume electricity to operate, the majority of the power would come from updated onsite power generation, and the fuel to be used is the existing LFG combined with tail gas from the project operation. An existing PG&E power drop is available to the project site.

Evaluation
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Less than Significant Impact. Both construction and operation of the project would involve expenditure of energy. Below are discussions of the energy resources that would be consumed during construction and operation of the project.

Construction
During construction, energy use would be both direct and indirect. Direct energy use would include the consumption of fuel (typically gasoline and diesel fuel) for the operation of construction equipment and vehicles. Energy in the form of electricity may also be consumed by some pieces of construction equipment, such as welding machines, power tools, lighting, etc.; however, the amount of consumed electricity would be relatively minimal. Indirect energy use would include the energy required to make the materials and components used in construction. This includes energy used for extraction of raw materials, manufacturing, and transportation associated with manufacturing. 1307

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CEQA focuses on the efficient use of energy rather than comparisons of estimated energy amounts to be consumed to quantitative significance thresholds. Construction activities at the project site would occur over a period of approximately 8 months. Construction activities would include use of heavy-duty construction equipment and offsite vehicles to transport equipment, materials, and workers to the project component sites.

Energy use requirements in the form of diesel fuel that would be consumed by off-road construction equipment at the project site have been estimated based on the GHG emissions estimates obtained from the CalEEMod modeling conducted for the Air Quality and GHG analysis in Sections 4.3 and 4.8, respectively, of this checklist. GHG emissions from CalEEMod were used in conjunction with The Climate Registry’s 2021 default factors for calculating carbon dioxide (CO2) emissions from diesel fuel (TCR, 2021). The analysis assumes that all off-road construction equipment would be fueled by diesel.

The analysis assumes that light-duty automobiles and trucks used by commuting construction workers would be fueled by gasoline, and that vendor vehicles and trucks that would haul demolition debris, soil, and other materials would use diesel fuel. This analysis assumes that no electric on-road vehicles would be used during project construction. GHG emissions associated with commuting workers and vendor and haul trips were estimated using information provided by the City for estimated trip counts and CalEEMod default trip lengths.

In addition to fuels used by equipment and vehicles, construction activities would use water for dust suppression and management, which in turn would require electricity to supply, treat, and transport the water to the project area.

It is estimated that over the entire construction period of the project, off-road equipment and on-road vender and haul trucks would consume approximately 25,061 gallons of diesel fuel, and commuting worker vehicles would consume approximately 146 gallons of gasoline.

Due to the relatively small scope of the project, as well as the limited duration of construction activities, the consumption of fuel energy during construction would be temporary, localized, and would amount to a very small fraction of the 47 million gallons of diesel and 336 million gallons of gasoline sold in Contra Costa County (California Energy Commission [CEC], 2020). Vehicles used for project construction and operation would be required to comply with all federal and state efficiency standards. Additionally, there are no project characteristics or features that would be inefficient or that would result in the use of equipment and vehicles in a manner that would be less energy efficient than similar construction projects.

Therefore, project construction would not result in wasteful, inefficient, or unnecessary use of energy, and would result in a less-than-significant impact associated with energy consumption.
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Operation
Once operational, the majority of the project’s power requirements would come from electricity generated onsite. The electricity would be generated using equipment such as newly installed Jenbacher generator sets. The fuel that would be used for the generation is LFG from the Republic Services landfill, blended with the tail gas from a pressure swing adsorption (PSA) unit to purify the hydrogen product. Republic Services would offtake approximately 0.5 MW from the power generation for its onsite operational needs and the rest of the generated energy would be used to power the hydrogen plant. The plant would consume approximately 6.0+ MWe to operate and produce 200 kg of hydrogen per hour. Any additional electricity needed to operate the facility would be sourced from an existing PG&E power drop to the site and no new distribution power line would be required for the project. Operation and maintenance of the new facility would require 3 to 4 employees per shift, for a total of 9 to12 new employees per day to cover all shifts and provide necessary support of the facility; energy use from employee trips would therefore be minimal. Energy would be consumed by new truck trips to the site, with is also relatively minimal at up to approximate 100 truck trips per week. The facility would not involve customers onsite.

Since the majority of the required power would be generated onsite, and the power would be used to produce hydrogen fuel at the plant, the energy use associated with the project would be net positive (i.e. more power would be generated than consumed) and not be considered inefficient or wasteful and hence, this impact would be considered less than significant.
b) Conflict with or obstruct a State or local plan for renewable energy or energy efficiency?
No Impact. As discussed above, project construction would require the use of off-road construction equipment and on-road trucks. Construction activities would comply with state and local requirements designed to minimize idling and associated emissions, which would also minimize the use of fuel. Specifically, pursuant to 13 CCR Sections 2485 and 2449, idling of commercial vehicles over 10,000 pounds and off-road equipment over 25 horsepower would be limited to a maximum of five minutes. Fuel use for project construction would be consistent with typical construction and manufacturing practices, and energy standards such as the Energy Policy Acts of 1975 and 2005, which promote strategic planning and building standards that reduce consumption of fossil fuels, increase use of renewable resources, and enhance energy efficiency.

Once operational, the project’s primary energy use would be electricity generated onsite using a fuel that would consist of LFG combined with tail gas. Energy used for operational vehicle trips would be negligible. Any additional electricity would be provided by PG&E, which would be subject to SB 100 under California’s Renewable Portfolio Standard (RPS) Program. Signed into law by Governor Brown, SB 100 increased California’s RPS target to 60 percent of total electric retail sales by 2030, and requires 100 percent of electric retail sales to come from eligible renewable or carbon1309

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free resources by 2045. PG&E, as the utility provider, is subject to these requirements.

There are no aspects of the proposed project that would conflict with or obstruct a state or local plan for renewable energy or energy efficiency, so there would be no impact.

References
California Energy Commission (CEC), 2020. 2020 California Annual Retail Fuel Outlet Report Results (CEC-A15), August 31, 2020. Available: https://www.energy.ca.gov/media/3874.

Accessed April 26, 2022.

Pacific Gas & Electricity (PG&E), 2021. PG&E Currents, April 19, 2021. Available:
https://www.pgecurrents.com/2021/04/19/a-renewable-revolution-how-pge-and-itscustomers-helped-write-californias-clean-energy-success-story/. Accessed April 26, 2022.

The Climate Registry (TCR), 2021. 2021 Default Emission Factors, Table 2.1—U.S. Default Factors for Calculating CO2 Emissions from Combustion of Transport Fuels. May 2021.

Available: https://www.theclimateregistry.org/wp-content/uploads/2021/05/2021-DefaultEmission-Factor-Document.pdf?mc_cid=4b45d12237&mc_eid=5f138d1baa. Accessed March 29, 2022.
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4.7 Geology, Soils and Mineral Resources
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Geology and Soils
Would the project:
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as
delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the State
Geologist for the area or based on other substantial
evidence of a known fault? Refer to Division of
Mines and Geology Special Publication 42.

ii) Strong seismic ground shaking? 
iii) Seismic-related ground failure, including
liquefaction? 
iv) Landslides? 
b) Result in substantial soil erosion or the loss of
topsoil? 
c) 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?

d) Be located on expansive soil, as defined in Table 18- 1-B of the Uniform Building Code (1994), creating
substantial direct or indirect risks to life or property? 
e) 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?

f) Directly or indirectly destroy a unique
paleontological resource or site or unique geologic
feature?

Mineral Resources
Would the project:
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?

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Setting
There are several known active faults in the vicinity of the project site. The location lies within a geologic province of the San Francisco Bay named the “Richmond Basin," bounded by the San Pablo and Hayward faults. The active fault in the region that are capable of producing the most significant ground shaking at the project site is the Hayward Fault, located approximately 3.7 miles southwest of the project site. (Rockridge, 2022)
A Geotechnical Investigation report was prepared for the proposed project (Rockridge, 2022).

The project site is blanketed by about 12 to 18 feet of heterogeneous fill, the upper five feet of which in the areas studied generally appears to be relatively well compacted. The fill is underlain by young bay sediments known locally as Bay Mud, which extends to depths of approximately 110 to 117 feet below ground surface (bgs). Bay Mud layer is generally soft to depths of approximately 50 to 60 feet bgs, but can be more stiff below, depending on the degree of over consolidation. The Bay Mud is underlain by alluvium consisting of dense to very dense sand/silty sand that extends to the maximum depth explored (120 feet bgs).

This analysis considers information from the geotechnical investigation as well as from numerous studies conducted for the WCCSL property.

Evaluation
Geological Resources and Soils
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving (i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42. (ii) Strong seismic ground shaking? (iii) Seismic-related ground failure, including liquefaction? (iv) Landslides?
Less than Significant Impact. Intense ground shaking during a large earthquake would be expected at the project site, particularly given its close proximity of the nearest active fault. The project would adhere to standard industry practices, code requirements, and any geotechnical recommendations or design parameters identified in the geotechnical study prepared for the project (Rockridge, 2022). (for the proposed earthwork, foundation slabs, and any surrounding related improvements, utilities, or paved areas associated with the project, would reduce the potential impacts associated with ground shaking during a major seismic event; seismically-related ground failure, including liquefaction for which the project area is susceptible (Richmond, 2012). The project would also adhere to all requirements in the applicable versions of the California Building Code, which would generally reduce known seismic hazards to minimize potential adverse effects. The project would introduce an industrial operation and modular structures on the project site, involving up to three to four employees onsite at any particular time, and no customers.

The impact would be less than significant.
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b) Result in substantial soil erosion or the loss of topsoil? Less than Significant Impact. The project, which relatively flat and partially paved and partially compacted soil and ruderal groundcover, would develop and implement an Erosion Control Plan and applicable best management practices as part of the National Pollutant Discharge Elimination System (NPDES) Construction General Permit, would reduce potential impacts associated with erosion to a less than significant level. c) 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?
Less than Significant Impact. As mentioned in criterion “a” above, the project would adhere to standard industry practices, code requirements, and any geotechnical recommendations or design parameters that would reduce the likelihood of landslide, lateral spreading, subsidence, liquefaction or collapse due to unstable geologic units or soil. Based on the results of previous analyses, most of the sand layers present at the site (primarily within the Bay Mud) are sufficiently dense, have sufficient clay content, and/or are overlain by a sufficient thickness of Bay Mud, such that the potential for liquefaction is low although the site is in a liquefaction hazard zone (see “a”). The greatest potential for liquefaction is approximately 0.3 miles northward, adjacent to San Pablo Creek. The project site is not located on areas of landfill, which also sits upon Bay Mud and is susceptible to risks of settlement over time. The impact would be less than significant.
d) Be located on expansive soil, as defined in Table 18- 1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? No Impact. Expansive soil is not known to exist at the WCCSL site (County, 2004). No impact would occur.
e) 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?
No Impact. The project does not proposed installation or use of septic tanks or alternative wastewater disposal systems; the site is currently served by West County Wastewater District sanitary sewer service and facilities which would continue with the proposed project.
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Less than Significant Impact, after Mitigation. Based on the evaluation in Section 4.5, Cultural Resources, in this checklist, the potential for encountering paleontological or unique geologic features on the project site during ground-disturbing activities for the 1313

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proposed project is unlikely. However, the implementation of Mitigation Measure CUL1a: Cultural Resources Awareness Training, Mitigation Measure CUL-1b:

Mineral Resources
a, b) 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? 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?
No Impact. The proposed project would not require the use of vast amounts of natural resources or mineral resources for construction or operation. Input to the operation is existing organic feedstock from the project site. No impact would occur.

References
City of Richmond, 2012. Richmond General Plan Update Environmental Impact Report. SCH. 2008022018. 2012.

City of Richmond, 2012. Richmond General Plan 2030: Public Safety and Noise Element. Table

3.7-4, Liquefaction. 2012.

Contra Costa County 2004. Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions, SCH. 2002102057. June 2004.

Contra Costa County 2009. Addendum to the Final EIR for the WCCSL BMPC and Related Actions, SCH. 2002102057. 2009.
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4.8 Greenhouse Gas Emissions
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Greenhouse Gas Emissions
Would the project:
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 for the purpose of reducing the emissions of
greenhouse gases?

Setting
State and Regional
The California Global Warming Solutions Act (Assembly Bill [AB] 32, 2006), as amended, sets statewide greenhouse gas (GHG) emissions caps. The California Air Resources Board (CARB) established the Climate Change Scoping Plan, which outlined a framework for achieving the emission reduction goals set in the California Global Warming Solutions Act. In 2016, SB 32 and its companion bill AB 197 established a new climate pollution reduction target of 40 percent below 1990 levels by 2030 and included provisions to ensure the benefits of State climate policies reach into disadvantaged communities.

Senate Bill (SB) 375 requires CARB to develop regional GHG reduction goals for the automobile and light truck sectors. The Plan Bay Area 2040 is a plan to achieve regional GHG reduction goals by improving transportation access, maintaining the region’s infrastructure, and enhancing resilience to climate change through strategies such as fostering open space. There are a number of other laws in California intended to reduce GHG emissions through the regulation of construction standards, growth, and municipal operations.

Governor Brown signed Executive Order B-55-18 in September 2018 to establish a statewide goal to achieve carbon neutrality as soon as possible, and no later than 2045, and to achieve and maintain net negative emissions thereafter. In response to this Executive Order, CARB’s Draft 2022 Scoping Plan Update (May 10, 2022) presents several scenarios for achieving carbon neutrality statewide no later than 2045.

Significance Threshold
Greenhouse gas impacts are, by their nature, cumulative impacts because one project by itself cannot cause global climate change. As such, GHG emissions are evaluated under CEQA as a cumulative impact. To evaluate cumulative impacts, a lead agency must assess (1) whether the overall cumulative impact would be significant and, (2) if the overall impact is significant, 1315

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whether the incremental contribution that the individual project under review would add to the overall cumulative problem would be cumulatively considerable.

A conservative threshold of significance for determining the cumulative impact of a project’s GHG emissions is “net zero” emissions. This concept is supported by the BAAQMD in its Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans (BAAQMD, 2022), which states: “If a land use project incorporates all of the design elements necessary for it to be carbon neutral by 2045, then it will contribute its portion of what is needed to achieve the State’s climate goals and will help to solve the cumulative problem. It can therefore be found to make a less-than-cumulatively-considerable climate impact” (BAAQMD 2022).

Further, the State’s Office of Planning and Research’s (OPR) Final Statement of Reasons for Senate Bill 97 revisions to the CEQA Guidelinesstate that, “AB32, and regulations implementing that statute, will require reductions in emissionsfrom certain sectors in the economy, but do not preclude new emissions. Moreover, as explainedin the Initial Statement of Reasons, the proposed amendments do not establish a zero emissions threshold of significance because there is no ‘one molecule rule’ in CEQA” (CNRA, 2009).

For GHG thresholds, the BAAQMD published the 2022 Justification Report that presents GHG thresholds, which are based on AB 32 and California Climate Change Scoping Plan reduction targets and strategies developed to reduce GHG emissions statewide (BAAQMD 2022). These thresholds are presented in Table 4.8-1. This analysis focuses on presenting Project GHG emissions for informational purposes and evaluating the project against the BAAQMD 2022 GHG significance thresholds.

The new BAAQMD thresholds are focused on land development projects, and the legacy stationary source threshold for operational GHG emissions is 10,000 MTCO2e. This threshold is not being currently updated in the BAAQMD, as staff are focusing on creating land use project and plan thresholds (BAAQMD 2022). This analysis focuses on net zero emissions and the new draft thresholds, while also taking into account the existing BAAQMD threshold. 1316

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TABLE 4.8-1

BAAQMD GHG THRESHOLDS OF SIGNIFICANCE
(MUST INCLUDE A OR B FOR OPTION SCHEME)
Existing and Draft Air District Thresholds
Legacy Stationary Source
Threshold
10,000 MTCO2e
Option A Projects must include, at a minimum, the following project design elements:
1) Buildings
a. No natural gas (residential and non-residential)
2) Transportation
a. Achieve compliance with EV requirements in the most recently adopted version of CALGreen1 Tier 2
b. Achieve SB 743 target of 15% reduction in VMT per capita below regional average Option B Be consistent with a local GHG Reduction Strategy that meets the criteria under the CEQA Guidelines Section 15183.5(b)
1 Part 11 of the Title 24 Building Energy Efficiency Standards is referred to as the California Green Building Standards (CALGreen) Code SOURCES: BAAQMD 2022. Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans, April.

Evaluation
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Less than Significant Impact. GHG emissions would be generated during both construction and operational phases of the project.

Construction
The combustion of diesel fuel to provide power for the operation of various construction equipment results in the generation of GHGs. Construction emissions associated with the project were estimated using project-specific information provided by the Project Applicant, such as construction schedule and phasing; types, number, and horsepower rating of constructionequipment to be used, their daily usage in terms of hours per day, and the number of dayseach piece of equipment is used over the construction period; and information on construction vehicle trips for worker commute, equipment and material transport and hauling trips. Appendix A to this checklist contains the data and assumptions used to estimate the construction-phase GHG emissions that would be associated with the project.

Carbon Dioxide (CO2), methane (CH4) and nitrous oxide (N2O) emissions from off-road construction equipment and construction vehicle trips were derived from the CalEEMod run to estimate criteria air pollutant emissions. N2O and CH4 emissions were multiplied 1317

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by their respective Global Warming Potentials GWPs (25 and 298) and added to the CO2 emissions to obtain CO2e emissions.

Construction of the proposed project is anticipated to occur over a period of approximately eight months. It is estimated that project construction would generate a total of approximately 258.9 MTCO2e over an 8-month construction period, as shown in Table 4.8-2. BAAQMD does not have adopted significance thresholds for constructionrelated GHG emissions in its 2017 CEQA Guidelines (BAAQMD, 2017). However, it recommends that the Lead Agency (i.e., the City of Richmond) quantify and disclose construction GHG emissions and incorporate best management practices to reduce GHG emissions during construction, as applicable.

TABLE 4.8-2

ANNUAL CONSTRUCTION-RELATED GREENHOUSE GAS EMISSIONS
Year GHG (MTCO2e)
2022 178.3
2023 80.6
Total 258.9
Amortized 8.63
NOTES:

MTCO2e = metric tons of carbon dioxide equivalent
Construction-related GHG emissions were amortized over 30 years, which is a commonly accepted method for including construction emissions as part of the proposed project’s average annual emissions.

SOURCE: Data compiled by Environmental Science Associates in 2022 (Appendix A to this checklist)
In addition, the GHG thresholds proposed by the BAAQMD in response to SB 32’s GHG reduction goals also do not contain significance thresholds for construction (BAAQMD, 2022). GHG emissions from the construction phase of a project represent a very small portion of emissions over the project’s lifetime, which for the projects such as the proposed project would be at least 30 years.

The BAAQMD’s proposed thresholds are instead designed to address operational GHG emissions from land use development projects which represent the majority of a project GHG emissions. The primary source of GHG emissions from construction is dieselpowered construction equipment. Large reductions in construction emissions are difficult to realize because there are currently no economical alternatives to diesel fuel for powering most construction equipment. Improvements in statewide regulations governing construction equipment and fuel standards driven by SB 32 and other initiatives will also contribute to reduced emissions from construction activities. Therefore, GHG emissions associated with project construction would be considered less than significant.

Though not required as mitigation to reduce a significant impact, implementation of Mitigation Measure AQ-1: Best Management Practices, identified above in Section

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benefits. Therefore, GHG emissions associated with project construction would be considered less than significant.

Appendix A contains details on the calculations and assumptions used to estimate construction GHG emissions as well as model outputs.

Operational
The current BAAQMD thresholds have been set using the “fair share” analysis, which looks at how new land use development projects need to be designed and built to ensure that they will be consistent with the goal of carbon neutrality by 2045 (BAAQMD 2022).

The existing legacy stationary source threshold is 10,000 MTCO2e annually.

The proposed system takes up to 99.9 wet-tons per day (WTPD) of blended green waste (GW), food waste (FW), using landfill gas (LFG) to provide power to the process and converts the feed into renewable, transportation grade hydrogen. This waste would otherwise be put into the landfill where it would produce GHG emissions in the form of methane gas. The landfill gas would also otherwise be creating GHG emissions if not for the bioenergy facility taking it and converting it into hydrogen. By redirecting this waste into the Raven SR, it reduces the amount of GHG emissions produced at the project site.

Biogenic CO2 emissions from green waste are not accounted for in operational GHG impacts as they are a result from materials that are derived from living cells, not fossil fuels (BAAQMD 2017b).

The system does not have any free oxygen in its process, and instead uses steam promoted processes to thermally decompose the feed into its chemical elements. This process does not involve any type of combustion, and therefore does not have an GHG emissions associated with the system operational emissions. Once project operations fully begin, GHG emissions are expected to be net negative.

Table 4.8-3 shows operational emissions calculated using CalEEMod (version 2020.4.0) added to the amortized construction emissions to get the total annual project GHG emissions. BAAQMD does not currently have a quantitative threshold for GHG emissions. The current qualitative significant thresholds are found in Table 4.8-1. The project would satisfy the BAAQMD Best Available Control Technology (BACT) requirements, and thus the proposed project is consistent with the 2017 Climate Change Scoping Plan as well as the draft 2022 Scoping Plan Update in terms of following the GHG reduction strategy to reach the statewide goal of climate neutrality by 2045. 1319

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TABLE 4.8-3

UNMITIGATED ANNUAL OPERATIONAL GREENHOUSE GAS

EMISSIONS
Source GHG (MTCO2e)
Area <1
Energy 80.5
Mobile 262.6
Off-road 303.2
Waste 96.7
Water 17.0
Amortized Construction Emissions 8.63
Total Project GHG Emissions 697.17
NOTES:

A 30-year lifetime was assumed for the project, which was used to amortize construction emissions.

MTCO2e = metric tons of carbon dioxide equivalent
SOURCE: Data compiled by Environmental Science Associates. See Appendix A to this checklist.

Based on the state carbon neutrality goal for 2045, the proposed project would contribute its portion of what is needed to achieve the State’s climate goals and would help to solve the cumulative climate problem. It can therefore be found to make a less-thancumulatively-considerable climate impact. The project emission calculations, along with the supporting data from the life cycle analysis, shows that the project would be below both the new draft significant thresholds and the legacy stationary source threshold, with the possibility of reaching net negative GHG emissions, contributing to the determination of the project having a less than significant impact and a less-than-cumulativelyconsiderable climate impact. Therefore, operation of the proposed project would have a less than significant impact.
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
Less than Significant Impact. In response to AB 32 GHG reduction goals, CARB adopted the Climate Change Scoping Plan, which outlined a framework for achieving the emission reduction goals set in the California Global Warming Solutions Act. The Scoping Plan was most recently updated in 2017 (2017 Scoping Plan; CARB, 2017) to address California’s 2030 GHG target and identifies how the State can reach the 2030 climate target established by SB 32 while making substantial advancements toward the 2050 climate goal established by Executive Order (EO) S-3-05 (2005).

The City of Richmond developed and adopted a climate action plan (CAP) in 2016 to meet a city-wide 2020 GHG emissions target consistent with AB 32 and achieve reductions in line with the longer-term statewide goal to reduce emissions 80 percent below 1990 levels by 2050, as established by Executive Order B-3-15. 1320

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The project would generate GHG emissions primarily from operational activities and would most likely result in net negative emissions on an annual basis. As such, the project would help the City achieve its long-term GHG emissions goal. Neither the 2017 Scoping Plan Update or the City’s existing CAP contain any actions or measures that address GHG emissions from construction. The majority of electricity supplied to the project would come from an onsite power generator, fueled by LFG from the Republic Services WCCSL. Any additional power required would be supplied from an on-site PG&E power drop; PG&E is required to comply with SB 100 and the RPS. SB 100 requires that the proportion of electricity from renewable sources be 60 percent by 2030 and 100 percent renewable power by 2045. Therefore, the project would be consistent with all applicable plans, policies and regulations adopted for the purpose of reducing GHG emissions. This impact would be less than significant.

References
Bay Area Air Quality Management District, (BAAQMD) 2022. Justification Report 2022.

Available online: Microsoft Word - FINAL CEQA Thresholds Report for Climate Impacts 03_30_22 revisions with tracked changes (baaqmd.gov). Accessed on May 11, 2022.

Bay Area Air Quality Management District, (BAAQMD) 2017. CEQA Air Quality Guidelines 2017. Available online: https://www.baaqmd.gov/~/media/files/planning-andresearch/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en. Accessed May 17, 2022.

The City of Richmond, 2016. Climate Action Plan 2016. Available online:
https://www.ci.richmond.ca.us/DocumentCenter/View/40636/CAP-combined. Accessed May 11, 2022.

California Air Resources Board (CARB), 2017. California’s 2017 Climate Change Scoping Plan.

Available
online:https://ww2.arb.ca.gov/sites/default/files/classic/cc/scopingplan/scoping_plan_2017 .pdf. Accessed on April 26, 2022.

California Natural Resources Agency (CNRA), 2009. 2009 California Climate Adaptation Strategy. Available online:
https://resources.ca.gov/CNRALegacyFiles/docs/climate/Statewide_Adaptation_Strategy. pdf. Accessed May 17, 2022.

Raven SR Republic Service Summary, 2021. Carbon Life Cycle Analysis, Life Cycle Associates, LLC.
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4.9 Hazards and Hazardous Materials
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Hazards and Hazardous Materials
Would the project:
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 one-quarter 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 located within an airport land use plan or, where such a plan has not been adopted, within two
miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?

f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency
evacuation plan?

g) Expose people or structures, either directly or
indirectly to a significant risk of loss, injury or death involving wildland fires?

Setting
The project site sits within the existing WCCSL which does not accept hazardous wastes; under State and federal laws, the landfill is permitted to accept non-hazardous wastes only. Although the municipal solid waste stream does contain small quantities of hazardous wastes that result from disposal of household waste and waste from small quantity generators, such as auto repair, auto dealers, and gas stations, the proposed project only involves a variety of organic waste feedstock. As discussed below and in Section 2.5 (Non-Combustion), the Raven SR process incorporates internal safety functions and would adhere to numerous applicable state and federal regulations, plans and procedures that apply specifically to its production of hydrogen gas from 1322

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organic solids. The project facility and operation located within the WCCSL would also benefit from the numerous existing safety regulations, plans and procedures.

A Phase I Environmental Site Assessment has been prepared for the project (CEC, 2022). The Phase I reports relevant site conditions observed include the storage of various commonly used hazardous materials, such as used oil, lubricants, anti-freeze, HDPE pipe sealant, pipe glue solvent, spray paint, and household cleaning supplies. All observed materials were properly stored and maintained. The Phase I also reports numerous above-ground storage tanks (ASTs) containing petroleum products located within and near the existing landfill power plant and maintenance buildings near the project site.

As previously described, the project is contiguous to a closed hazardous waste landfill portion of the WCCSL operation. Also, the project site was formerly occupied by three leachate evaporation ponds. Groundwater contamination on the WCCSL site was confirmed in a January 2021 Corrective Action Groundwater Monitoring Program Report.12 Groundwater at the WCCSL also has reported PFAS chemicals detected in groundwater. This is considered a recognized environmental condition (REC), but regularly monitored and the results are submitted to the State regulatory agency. Additionally, the groundwater impact is not expected to pose a risk of unacceptable exposure to workers at the project site. (CEC, 2022) Evaluation
a, b) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? 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? Less than Significant Impact. The proposed operation of transforming blended green waste and food waste into transportation-grade hydrogen-rich synthesis gas (syngas) and charcoal (biochar) could result in an adverse effect through the exposure to or spill of chemicals. The green waste and food waste feedstock would not be considered a hazardous material. Also, in 1993, DTSC determined that the Raven SR process for the production of syngas from organic solids was not categorized as either incineration or combustion and was therefore a suitable technology for use in California.13 The conversion method uses a non-combustion (i.e., anoxic, indirect external heating), low pressure process. The only chemicals added would be carbon dioxide (CO2), calcium 12 CEC, 2022. Operation of a groundwater monitoring system and a groundwater extraction system is required under the West County Landfill (WCL) corrective action groundwater monitoring program (CAGMP), in accordance with Corrective Action Enforcement Order, Docket Number 20061079 dated September 26, 2007. 13 According to the definitions listed in Section 260.10, Title 40, Code of Federal Regulations (40 CFR) and Section 66260.10, Title 22, California Code of Regulations (22 CCR). Also, since 2017, a Raven pilot engineering unit, sized at 100 wet pounds per day of feedstock, has been operating at the UC Berkeley’s Richmond Field Station and is permitted for operation by the Bay Area Air Quality Management District (BAAQMD) under permit Nos. 23993 and 23320.
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carbonate (limestone), and steam (i.e., water heated into a vapor state). No hazardous materials would be used in the process. The conversion occurs in sealed rotating drums that drop out solid matter from the green and food waste feedstock, which would consist largely of biocarbon, along with dirt, glass, grit, rocks, and inorganic salts. The biocarbon materials are inert to the process (i.e., not gasified) and drop out in the first stage. The process also drops out excess water. Neither the biocarbon nor the water would be considered a hazardous material.

There would be no long-term hydrogen storage onsite; the material would be fed directly into the tube trucks and transported offsite. For transportation, the United States Department of Transportation (USDOT) classifies hydrogen gas as a Division 2.1 Flammable Gas. Vehicles transporting flammable gas are mandated to display USDOT flammable gas placards. The proposed project would pump the hydrogen gas into standard pressurized hydrogen gas trucks, called tube trailers. The gaseous hydrogen is compressed to pressures of 380 gas (about 5,500 pounds per square inch [psig]) or higher into long cylinders that are stacked on a trailer that the truck hauls. This gives the appearance of long tubes, hence the name tube trailer.

To support development of the hydrogen economy, development of tube trailers capable of storing hydrogen at pressure of about 500 bar are approved for use on public throughways use by USDOT regulations (Federal Motor Carrier Safety Administration, 49 CFR Part 393). Such tube trailers are routinely used to transport hydrogen gas, as well as other gases such as natural gas and propane. Regulations regarding the design of tube trailers that transport hydrogen gas is in OSHA 1910.103, Subpart H, Hydrogen, which includes requirements for the containers, pressure relief valves, piping, tubing, fittings, and labeling. On-road transport of hydrogen gas must comply with applicable USDOT regulations, which include equipment requirements and driver safety training. In California, a specific driver’s license is required, a commercial driver’s license with a Hazard Materials endorsement.

A new 250,000-gallon integrated fire water tank and diesel engine is proposed in the northeast corner of the site for emergency use, as required by fire department regulations (see Figures 2-1 through 2-4). Diesel fuel is classified as a hazardous material, and therefore the above ground tanks would require compliance with containment requirements in a Spill Prevention, Control, and Countermeasure (SPCC) Plan pursuant to federal requirements. Propane for the continuous flare pilot would be supplied from a standard 1000-gallon propane tank installed on-site. A local propane supplier would service and fill the tank as needed.

Overall, the project operations would be equipped with continuous monitoring systems and can automatically shut down plant operations without human intervention.

Specifically, the facility’s controls would be distributed through the various process islands, taking their direction from a central Human-Machine Interface in the control room with centralized data collection. Process setpoints would be bounded by high/low alarm limitations to draw the operator’s attention to the specific problem. The control 1324

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system would represent state-of-the-art digital technology with redundant instrumentation where necessary to ensure safe operation.

Because the process itself is oxygen-free, there would be no opportunity within the process for explosion. As previously described (Section 2.5), piping and vessels would be periodically scanned with infrared equipment to identify hot spots or gas leaks that may threaten safety. If hot spots or leaks were identified, immediate steps would be taken to correct or mediate the condition. Also, remote monitoring of the facility by Raven SR corporate provides oversight of the operation and early identification of problems as they development.

The project would comply with applicable Environmental Protection Agency (EPA) risk management plan (RMP) and Occupational Safety and Health Administration (OSHA) process safety management (PSM) guidelines, as may be applied to the facility to ensure the safety of its operations staff and the surroundings A maintenance program of regular and preventative maintenance would be developed to maintain equipment in a reliable manner.

The project’s adherence to all regulatory requirements mentioned in this section, combined with the Raven RS process, materials and operations, the impact would be less than significant.
c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? No impact. As discussed above, the proposed project would not emit hazardous emissions or handle hazardous materials or waste. Moreover, the project site is located approximately 1.1 miles from Verde Elementary School at 2000 Giaramita Street.

Therefore, no impact would occur.
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?
No impact. An inactive waste disposal area that is a Class I Hazardous Waste Management Facility (HWMF) is located within the WCCSL and directly north of the BMPC and project site (see Figure 1-3 in Chapter 1, and Figure 2-0 in Chapter 2). The facility was closed pursuant to State and federal regulations, and final cap construction was completed prior to 2003. It is a totally enclosed facility with required environmental control systems. The proposed project site is not within the previous HWMF area; therefore, no impact would occur.
e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?
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No impact. The proposed project is not located within an airport land use plan, and the closest airport to the project site is the San Rafael Airport located approximately 8.3 miles southeast. Therefore, the proposed project would not be located within two miles of an airport, and no impact would occur.
f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Less than Significant Impact. In the event of a large-scale disaster, emergency response to the site would be coordinated by WCCSL facility, City and County fire responders, and in adherence to the WCCSL Emergency Response and Evaluation Plan and local agency protocols. Emergency fire control procedures are also included in the composting and wood waste recycling operations plans. The WCCSL facility and project site are accessed from and exit to Parr Boulevard, and a serious of roadways and paths throughout the 340-acre WCCSL provide sufficient width for emergency access. The proposed project would be developed within part of the existing BMPC property and would not create new or interfere with existing access or egress roads. Therefore, there is no potential for the project to impair implementation of emergency evacuation or an adopted emergency response plan.
g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
Less than Significant Impact. The project site is flat and surrounded by the WCCSL facility, which is composed of grass-covered disposal areas of the landfill mounds, runoff control ponds and lagoons, and composting areas, and tidal marshlands of San Pablo and Wildcat Creek. Open water of San Pablo Bay is approximately 0.25 miles westward from the project site. Wildfire hazard maps show the site as not being within a high wildfire hazard zone (CPUC, 2018). Further, as discussed in criteria “a and b”, the project would include a new 250,000-gallon integrated fire water tank and diesel engine is proposed for emergency use, as required by fire department regulations.

References
California Public Utilities Commission. Fire-Threat Map – State of California. January 19, 2018.

CEC, 2022. Phase I Environmental Site Assessment, West Contra Cost Sanitary Landfill, 1.5- Acre Clean Energy Development Project, 1 Parr Boulevard, Richmond California 94801.

June 30, 2022.

Contra Costa County 2004. Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions, SCH. 2002102057. June 2004.

Contra Costa County 2009. Addendum to the Final EIR for the WCCSL BMPC and Related Actions, SCH. 2002102057. 2009.
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4.10 Hydrology and Water Quality
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Hydrology and Water Quality
Would the project:
a) Violate any water quality standards or waste
discharge requirements or otherwise substantially
degrade surface or groundwater quality?

b) Substantially decrease groundwater supplies or
interfere substantially with groundwater recharge such
that the project may impede sustainable groundwater
management of the basin?

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:
(i) result in substantial erosion or siltation on- or
off-site; 
(ii) substantially increase the rate or amount of surface runoff in a manner which would result in flooding onor off-site; 
(iii) 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; or

(iv) impede or redirect flood flows? 
d) In flood hazard, tsunami, or seiche zones, risk
release of pollutants due to project inundation? 
e) Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater
management plan?

Setting
No surface water bodies exist on the project site. As previously described throughout other sections of this analysis, the following surface water bodies exist within the WCCSL property and directly south/southwest of the project site: runoff ponds or lagoons delineated as “Area B” and tidal waters delineated as “Area C” (shown in Figure 3-1, Vicinity Map, of the 2004 EIR).

San Pablo Creek is approximately 0.3 miles north of the project site, and Wildcat Creek is approximately 280 feet south/southeast of the project site, bordering the WCCSL south boundary which is an elevated levee (see Figure 2-0 and Figure 2-1 in Chapter 2 of this 1327

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document). Many small tributaries that drain and feed the brackish marshlands of these creeks, and the 100-year flood flows in San Pablo Creek would be totally contained in the channel.

Open water of San Pablo Bay is approximately 0.25 miles west of the project site. The levees around the WCCSL have been designed and maintained to exceed flood levels and the upland portions are located outside wetlands under U.S. Army Corps of Engineers (Corps) jurisdiction.

Depth to groundwater at specific areas of the project site can range from 5 to 7 feet or up to 10- 1/2 feet below the ground surface. The depth to groundwater varies seasonally. Groundwater contamination on the WCCSL site was confirmed in a Phase I Environmental Site Assessment prepared for the project (CEC, 2022). This recognized environmental condition (REC) is regularly monitored and the results are submitted to the State regulatory agency. There are no anticipated plans for use of existing groundwater by the Project.

Evaluation
a, b) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality? Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin? Less than Significant Impact. WCCSL implements a Storm Water Pollution Prevention Plan (SWPPP) under the NPDES permit, as amended. The drainage plan for the WCCSL, which currently encompasses the project site, accommodates the 100-year storm event.

The WCCSL is managed to prevent the infiltration of surface water into the waste materials and to maximize and control the amount of surface water that runs off via overland flow with berms, bench drains, down drains, which would manage runoff from the project. Area 1 runoff is diverted to the siltation control basin located behind (east of) the Golden Bear Waste Recycling Center.

As introduced in Section 2.8, Construction, Site Coverage and Drainage, the project would adhere to all applicable regulatory stormwater runoff controls and will pursue its own NPDES permit. The project’s SWPPP would be developed prior to construction and operation of the facility and flows would be integrated into the existing WCCSL system and ensure drainage from the proposed project site would drain towards existing stormwater runoff control ponds (or bioretention facility) to which the rest of the WCCSL property currently drains. The drainage control systems would be designed such that the two systems are segregated and independent of one another. This would minimize the creation of contact water (water that has come into contact with organic feedstock) as well as protecting the site from various health and safety hazards.

The receiving and handling area would be in a modular structure and industrial canopy to minimize rainfall from coming in contact with the feedstock material. The receiving area would also incorporate a berm at the opening of the receiving area to keep any potential contact water inside. The aprons around the facility would direct any rainfall away from the canopy and into the stormwater drainage and management system described above. 1328

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Any excess contact water that may be generated inside the canopy receiving area will either be reabsorbed into incoming feedstock or collected via floor drains and diverted to the facility’s sanitary sewer.

The SWPPP also requires site inspections and a preventive storm water control maintenance program, with triggers for evaluation monitoring and corrective action as needed under RWQCB review and oversight pursuant to State regulations. Also, neither construction nor operation of the project would involve use of groundwater. Taken together, the proposed stormwater program and project development would not impair water quality or decrease groundwater. The impact is less than significant. 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:
(i) result in substantial erosion or siltation on- or off-site; (ii) substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site;
(iii) 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; or
(iv) impede or redirect flood flows?
Less than Significant Impact. The proposed project would involve minimal grading as needed to prepare the site for new paving and foundations for the proposed modular buildings. The site is current flat and would remain so, except for slight grading around the proposed modular structure to prevent contact water. As described in Section 2.8, Construction, Site Coverage and Drainage, in Chapter 2, the proposed project would add approximately 1.21 acres of new impervious surface area (including modular structures) to the existing 0.76 acres of impervious area that would be repaved. This would result in approximately 78 percent of the project site (2.5 acres) being impervious. Approximately

0.53 acres, or 22 percent, of unpaved area along the north boundary of the site would remain undisturbed.

Although the amount of impervious area on the project site would nearly double compared to the existing conditions, the proposed drainage management would effectively manage increased flows to the existing system and not exceed the capacity of the system. A draft Stormwater Control Plan has been prepared for the project (Power, 2022). It delineates two nearly equally-sized drainage management areas (DMA 1 and DMA 2) across the project site. DMA 1 is the northern part of the site where the modular building and facilities are proposed and its flows would drain to an existing pump that is part of the existing stormwater system. DMA 2 is generally the south and southwest part of the project site where existing development and paved areas exist for truck traffic and 1329

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circulation; its flows would integrate directly into the existing stormwater system. The DMA’s are delineated to effectively capture and direct runoff to not exceed the existing system. Based on the 24-hour, 100-year storm, pre-development flow is estimated at

11.89 cubic feet per second (cfs). Post-development is estimated at 12.47 cfs, which is less than 5 percent potential change.

Also, permanent source controls would be implemented to address potential runoff flows, including. Examples include use of equipment closures and regular inspection of potential pollutant sources for debris or blockages that may interfere with intended stormwater flows. Adherence to the SWPPP under the NPDES permit (see criterion “a and b”) would also minimize erosion as well as polluted runoff.

Overall, the proposed site alterations would not result in changes in stormwater flows that could exceed the capacity of the existing stormwater control system to which the project site would flow. The impact is less than significant.
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
Less than Significant Impact. The California Geological Survey has mapped tsunami inundation areas along the Richmond shoreline, and the project site is located within the hazard zone (CGS, 2021). Seiche risk at areas along Richmond’s shoreline are minimal because there are no large confined bodies of water with depths that would cause this hazard (City of Richmond, 2011). As discussed in the above Setting, the 100-year flood flows in San Pablo Creek adjacent to the project site and would be totally contained in the channel, also the levees around the WCCSL have been designed and maintained to exceed flood levels. Therefore, risk of inundation at the site is low, particularly due to risk of a seiche or flooding on the project site. The impacts would be less than significant. e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Less than Significant Impact. As discussed in criterion “a”, the proposed project would not conflict with implementation of the existing water quality plan nor release pollutants from its construction or operation.

References
State of California, 2021, Tsunami Hazard Area Map, Contra Costa County; produced by the California Geological Survey, the California Governor's Office of Emergency Services, and AECOM; dated 2021. Accessed and printed September 13, 2022.

Contra Costa County 2004. Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions, SCH. 2002102057. June 2004.
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Contra Costa County 2009. Addendum to the Final EIR for the WCCSL BMPC and Related Actions, SCH. 2002102057. 2009.

City of Richmond, 2012. Richmond General Plan Update Environmental Impact Report. SCH. 2008022018. 2012.

Power, 2022. Draft Stormwater Control Plan for Raven One, July 22, 2022. 1331

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4.11 Land Use and Planning
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Land Use and Planning
Would the project:
a) Physically divide an established community? 
b) Cause a significant environmental impact due to a
conflict with any land use plan, policy, or regulation
adopted for the purpose of avoiding or mitigating an
environmental effect?

Setting
The proposed project area is the existing approximately 340-acre WCCSL, a self-contained area and operation within the broader area of industrial and open space land uses, including the Bay Trail / Wildcat Creek Marsh Trail. Other nearby uses include the West County Wastewater District Treatment Plant, EBMUD’s North Richmond Water Reclamation Plan, the Richmond Sanitary District, and other refuse services, automobile repair and towing businesses, and lawn services, etc. The Richmond Parkway is a major roadway through the area and spurs the Parr Boulevard approach to the WCCSL and adjacent uses. The next nearest established community is the residential development at generally West Gertrude Avenue/Malcolm Drive, approximately 0.75 miles southeast.

Evaluation
a) Physically divide an established community?
No Impact. The proposed operation is consistent with current BMPC activities on the site. Therefore, the project could not divide any established community. The project would have no impact.
b) Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
Less than Significant Impact. The proposed facility and operation to convert blended green waste and food waste obtained from the existing BMPC operation adjacent to the project site into renewable, transportation grade hydrogen would not conflict with any existing land use plan, policy or regulation intended to mitigate environmental effects. As proposed, the project does not require approval of an amendment to any aspect of the General Plan or the City’s Zoning Ordinance or Map. CEQA does not require the project to be consistent with all policies in the General Plan, nor does it require an assessment of 1332

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compliance with every applicable General Plan policy. Overall, the project advances Policy EC2.2 Climate-Friendly Fuel Support production and distribution of climatefriendlier fuels (when and if any are identified) and identify appropriate locations for fuel storage and distribution (Energy and Climate Change Element). This impact would be less than significant.

References
City of Richmond, 2012. Richmond General Plan Update Environmental Impact Report. SCH. 2008022018. 2012.

City of Richmond, 2012. Richmond General Plan 2030: Public Safety and Noise Element. Table

3.7-4, Liquefaction. 2012.

City of Richmond, 2012. Richmond General Plan 2030: Conservation, Natural Resources and Open Space Element. 2012.

City of Richmond, 2012. Richmond General Plan 2030 Historic Resources Element. 2012.

City of Richmond, 2012. Richmond General Plan 2030: Energy and Climate Change Element. 2012.

Contra Costa County 2004. Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions, SCH. 2002102057. June 2004.

Contra Costa County 2009. Addendum to the Final EIR for the WCCSL BMPC and Related Actions, SCH. 2002102057. 2009.
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4.12 Noise and Vibration
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Noise
Would the project result in:
a) Generation of a substantial temporary or permanent
increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other
agencies?

b) Generation of 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?

Setting
The proposed project is located entirely within the City of Richmond. The West County Wastewater District Treatment Plant and other industrial uses exist east of the property. The nearest residential receptors are 0.75 miles (approximately 3,949 feet) southeast from the project site. Approximately 7- to 8-foot-high sound walls were installed at these residences when Richmond Parkway was constructed to lower noise levels (WCCSL BMPC, 2003).

The primary noise sources in the vicinity of the project site include vehicles on adjacent and nearby roadways: Richmond Parkway and Parr Boulevard. The existing ambient noise environment in the project vicinity may be characterized by traffic noise modeling conducted for a previous EIR (City of Richmond, 2011) for primary roadways. Results of this traffic modeling are presented in Table 4.12-1 and are representative of transportation noise levels generated by roadways.
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TABLE 4.12-1
LOCALIZED ROADWAY TRAFFIC NOISE 1
Roadway Segment Description
Predicted, Ldn2, dB at 50 feet
Background
Richmond Parkway Gertrude Street and Parr Boulevard 75.9 Richmond Parkway Parr Boulevard and San Pablo Avenue 74.7 NOTES:
1 Analytical Environmental Services. 2011. Point Molate Mixed-Use Tribal Destination Resort and Casino Project. Available online: https://www.ci.richmond.ca.us/DocumentCenter/View/7685/Section_4p11?bidId= 2 Ldn is the energy average of the A-weighted sound levels occurring during a 24-hour period, and which accounts for the greater sensitivity of most people to nighttime noise by weighting noise levels at night (“penalizing” nighttime noises).

SOURCE: Brown and Buntin Associates, 2008.

Evaluation
a) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.

Less than Significant Impact. Noise would be generated during both construction and operational phases of the project.

Construction
Construction of the proposed project would occur over a period of approximately eight months, starting Fourth Quarter of 2022, and start-up of the plant is projected to begin in the Second to Third Quarter of 2023..

Project construction would result in temporary increases in ambient noise levels. Onsite construction activities would require the use of heavy construction equipment (e.g., excavator, loader, crane) that would generate varying noise levels. Offsite construction noise sources would consist of passing trucks and other construction-related vehicles.

City of Richmond Noise Ordinance, Section 15.04.605.060, regulates construction noise by allowing construction work that generates noise to occur weekdays between the hours 7:00 a.m. and 6:00 p.m., except outside of these hours or on Sundays and federal holidays unless a temporary waiver is granted by the Building Official or his or her authorized representative (City of Richmond, 2018).

The proposed project would adhere to the City’s construction work hours. The City’s construction noise level limitation of 75 dBA is used to assess whether daytime Leq construction-related noise levels would cause a substantial temporary or periodic increase in ambient noise levels at sensitive receptor locations. City of Richmond Noise Ordinance, 9.52.110 Temporary construction activity, limits noise levels measured at SFR-1, SFR-2, SFR-3 Zoning Districts (Single-Family Residential) to 75 dBA between the hours of 7:00 a.m. to 7:00 p.m. on weekdays.
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The operation of each piece of equipment would not be constant throughout the day, as equipment would be turned off when not in use. Over a typical workday, the equipment would be operated at different locations and all the equipment would not operate concurrently at the same location within the project site or roadways to and from the site. Construction noise levels have been estimated using typical equipment source noise levels suggested in the Federal Highway Administration’s (FHWA) Roadway Construction Noise Model (RCNM) and based on the type of construction equipment that are proposed to be used. To quantify construction-related noise exposure that would occur at the nearest sensitive receptors, it was assumed that the two loudest pieces of construction equipment would operate concurrently at the location within the project site and construction vehicle paths to the nearest sensitive receptor locations.

The estimated Lmax and Leq for each of the two loudest pieces of equipment that would be used to construct the project components, and the combined Leq noise level associated with the two loudest pieces of construction equipment at the closest sensitive receptor locations for each project component are identified in Table 4.12-2. The combined Leq construction noise levels would not exceed the City’s construction noise level limitation of 75 dBA described in Table 4.12-2. This modest noise contribution would not increase the existing ambient noise level at the nearest receptor.

TABLE 4.12-2

CONSTRUCTION EQUIPMENT NOISE LEVELS
Type of
Equipment
Distance to Closest
Sensitive Receptor
(feet)
Equipment
Lmax, dBA
Equipment Hourly
Leq, dBA/Usage%
Combined Leq at
Sensitive
Receptor, dBA
Demolition
Crushing/Proc.

Equipment 3,949 (Residences)

52.3 45.3/20%

46.2 Excavators 42.8 38.8/40%
Site Preparation
Tractors
3,949 (Residences)

46.0 42.1/40%

45.6 Rough Terrain
Forklifts 47.0 43.1/40%
Grading
Excavators
3,949 (Residences)

42.8 38.8/40%

43.7 Tractors 46.0 42.1/40%
Building Construction
Rough Terrain
Forklifts
3,949 (Residences)

45.4 41.5/40%

46.0 Other Construction
Equipment 47.0 44.0/50%
NOTES: Lmax = maximum instantaneous noise level; Leq = the equivalent sound level used to describe noise over a specified period of time, in terms of a single numerical value; Lmax = the instantaneous maximum noise level measured during the measurement period of interest.

SOURCE: Federal Highway Administration, 2008. FHWA Roadway Construction Noise Model, Version 1.1, December 2008. 1336

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In addition to on-site construction equipment, the project would also result in short-term increases in local daytime traffic volumes. The project components would each add up to approximately 84 one-way daily construction-related vehicle trips to area roadways, including 72 one-way daily hauling trips, 4 one-way daily vendor trips, and 8 one-way daily worker trips. The project truck trips would access the nearest freeway (Interstate 580) via Parr Boulevard and Richmond Parkway and would not utilize roadways with noise-sensitive land uses. Therefore, the associated increase in short-term construction vehicular noise levels would not be expected to increase noise levels in the vicinity of existing sensitive receptors beyond the levels described in Table 4.12-2.

City of Richmond Noise Ordinance, Section 9.52.100, regulates operational noise levels from public property at residential areas. Per Section 9.52.100, noise levels caused by mechanic equipment on public property in residential areas should not result in noise levels in excess of 65 dBA measured at any boundary of a residential zone (City of Richmond, 2022). Guidelines identified in the Richmond General Plan 2030, Action SN4.A, proposed commercial and industrial uses that locate in an area with day-night average sound level (Ldn) of 55 or greater to provide noise study reports the City’s goal for maximum outdoor noise levels in residential areas is 60 Ldn (City of Richmond, 2012). The 65 dBA Leq measured at any boundary of a residential zone is used here to assess whether operational noise levels would cause a substantial permanent increase in ambient noise levels.

It is not possible to provide specific noise levels at individual receptor locations that would result from operation of stationary sources. However, the nearest noise-sensitive receptor would be approximately 0.75 miles from the project site property line.

Table 4.12-3 presents reference noise levels for many of the stationary sources for informational purposes. Given the data in Table 4.12-3 and the known distance to the nearest noise receptors, the operational noise levels would be substantially below the 65 dBA standard of the City of Richmond Noise Ordinance and the operational noise impact would be less than significant.
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TABLE 4.12-3

REFERENCE NOISE LEVELS FOR STATIONARY NOISE SOURCES ASSOCIATED WITH THE PROPOSED

PROJECT
Stationary
Noise Source
Documented Sound
Levels (dBA)
Noise Level at
Nearest
Receptor Source
HVAC Equipment 72–78 dBA at 30 feet without
acoustical treatments
19-25 dBA Trane, Sound Data and Application
Guide, 2002
Standby Diesel Generator 75–90 dBA at 23 feet
(size dependent) without acoustical
enclosure
19-34 dBA Cummins Power Generation,
Sound Attenuated and Weather
Protective Enclosures, 2008
Loading Dock 77 dBA at 20 feet 20 dBA Urban Crossroads, Moreno Valley Walmart Noise Impact Analysis,
2015
NOTES:
dBA = A-weighted decibels; ESA = Environmental Science Associates; HVAC = heating, ventilation and air conditioning SOURCE: Data compiled by Environmental Science Associates in 2022. (Additional sources noted above.) b) Generation of excessive groundborne vibration or groundborne noise levels? Less than Significant Impact. Operations and maintenance of the project facility would not include any sources of vibration that would be considered excessive. Groundborne vibration and noise associated with some construction activities, including the use of pile drivers, blasting, and vibratory rollers, can cause excessive vibration. The project would not include any such activities. Groundborne vibration and noise levels generated by the types of equipment required to prepare the site and construct the proposed facility would be minimal and would not cause human annoyance or structure damage at a distance of 25 feet or beyond from the source (FTA, 2018). No existing historic structures that would be potentially vulnerable to vibration are located in the immediate vicinity of the project site such that any damage related to groundborne vibration from construction activities would occur. This impact would be less than significant and mitigation measures are not warranted.
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?
No Impact. The project is located approximately 8.3 miles southeast of the San Rafael Airport and is not located within the 55 dBA Ldn noise contours for the San Rafael Airport (City of San Rafael, 2021). The proposed project would not involve the development of noise-sensitive land uses that would be exposed to excessive aircraft noise. Therefore, there would be no impact.

References
California Department of Transportation (Caltrans), 2013. Technical Noise Supplement (TeNS).

September 2013.
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City of Richmond, 2012. Richmond General Plan 2030, Chapter 12, Public Safety and Noise.

April 25, 2012.

City of Richmond, 2022. Richmond Municipal Code, Article 15.04.605 - Noise. March 16, 2022.

City of San Rafael, 2012. San Rafael General Plan 2040 & Downtown Precise Plan, Chapter 4.13, Noise. January, 2021.

Federal Highway Administration (FHWA), 2008. FHWA Roadway Construction Noise Model, Version 1.1, December 2008.

Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual. September 2018. Available:
https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transitnoise-and-vibration-impact-assessment-manual-fta-report-no-0123_0.pdf. Accessed March 31, 2022.
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4.13 Population and Housing
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Population and Housing
Would the project:
a) 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)?

b) Displace substantial numbers of existing people or
housing, necessitating the construction of
replacement housing elsewhere?

Setting
As previously discussed in Section 4.11, Land Use and Planning, in this section, the project area entails open space and a range of industrial and commercial uses. No housing exists within 0.75 miles of the area, and the proposed project would be developed within existing BMPC facilities and operations.

Evaluation
a) 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)?
No Impact. The proposed project does not entail new housing, roads or other infrastructure that would induce substantial growth; the new business would involve 3 to 4 new employees per shift, for a total of 9 to12 new employees per day, which would not constitute substantial population growth. There would be no impact. b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
No Impact. No housing or people exist on the project site. The project would have no impact.

References
None.
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4.14 Public Services and Recreation
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Public Services
Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
a) Fire protection? 
b) Police protection? 
c) Schools? 
d) Parks? 
e) Other public facilities? 
Recreation
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?  Setting
The project area is currently serviced by the Richmond Fire Department (RFD), which also manages the West County Fire District, which also serves San Pablo, El Sobrante, and unincorporated areas of Western Contra Costa County, including North Richmond. The nearest fire station is RFD Station 62 at 1065 7th Street, Richmond.

Evaluation
Public Services
a) Fire Protection and Emergency Medical
Less than Significant Impact. The project site would be served by the same fire and emergency services that currently serve the WCCSL. The project would also install a new 250,000-gallon fire water tank and diesel engine in the northeast corner of the site for emergency use, as required by fire department regulations The fire water tank would be up to 25.5 feet tall and include two pumps, a small jockey pump for normal circulation, and the diesel-powered fire pump (shown in Figures 2-1 through 2-4.) All 1341

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construction-related mitigation measures identified in this analysis would apply to that development onsite.

The proposed operation would involve up to 3 to 4 new employees per shift and would not involve customers onsite. Also, the Raven SR system itself is not a combustion process and would incorporate several safety measures, including continuous monitoring systems, automatic plant operations shut down without human intervention, compliance with applicable EPA RMP and OSHA PSM guidelines, including applicable USDOT regulations for the on-road transport of hydrogen gas. Overall, the project would not result in noticeable increased demand for service that would require new fire or emergency medical facilities. The impact would be less than significant. b,c) Police Protection, Schools, Parks, Other
No Impact. The project would not involve changes that would increase the demand for policy protection on the project site. There would be no impact. Also, the project would not involve changes that would increase the demand for schools, parks or other public services. There would be no impact.

Recreation
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?
No Impact. The project would not introduce new people onsite that would increase the use of recreational facilities or parks. New population would consist of up to 3 to 4 new employees per shift; no customers would be onsite. There would be no impact 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?
No Impact. The project would include new or expanded recreational facilities or parks.

There would be no impact.

References
City of Richmond, 2011. General Plan 2030 – Map 12.6 Police and Fire Services. August 2011.

City of Richmond, 2012. Richmond General Plan Update Environmental Impact Report. SCH. 2008022018. 2012.

Google Earth Pro, Richmond Fire Stations, June 2022.
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4.15 Transportation
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Transportation
Would the project:
a) Conflict with a program plan, ordinance or policy of the circulation system, including transit, roadway,
bicycle and pedestrian facilities?

b) Would the project conflict or be inconsistent with
CEQA Guidelines Section 15064.3, subdivision (b)? 
c) Substantially increase hazards due to a geometric
design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm
equipment)?

d) Result in inadequate emergency access? 
Setting
The Richmond Parkway is a major roadway in the area that extends from Interstate 580 near the east approach to the Richmond-San Rafael Bridge northeasterly to Interstate 80 near Hilltop Drive. Parr Boulevard from Richmond Parkway is the main approach to the project site within the WCCSL and other nearby uses.

Evaluation
a) Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities? Less than Significant Impact. Table 4.15-1 summarizes the daily vehicle trip generation for the project based on the expected number of employees and truck activity at the site.

Since trucks are larger and operate slower than passenger vehicles, a passenger car equivalent (PCE) ratio of 2.0 is used to convert the truck trips to passenger vehicle trips (each truck is counted as two passenger vehicles). Accounting for PCE trips, the project is estimated to generate about 130 net new PCE trips on a typical weekday. 1343

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TABLE 4.15-1

PROJECT DAILY TRIP GENERATION SUMMARY
Use Amount Daily Trip Rate Passenger Car
Equivalent (PCE) a Daily Trips
Employees 12b 2.5c 1.0 30
Trucks 25 d 2.0e 2.0 100
Total trips (PCE) 130
NOTES:
a A PCE of 2.0 is used for trucks because they are lager and operate slower than passenger vehicles b Per the Project Applicant and described in Chapter 2, Project Description c One inbound and one outbound trip per employee per day plus 0.5 trips per employee per day for other trips such as deliveries, running errands, etc.
d Per the Project Applicant and as described in Chapter 2, Project Description, 125 trucks would serve the site during a typical week.

This estimate assumes they would be evenly distributed on five weekdays e One inbound and one outbound trip per truck
SOURCE: Fehr & Peers, 2022
The addition of 130 new trips on a typical weekday would not substantially increase the motor vehicle volumes on the nearby streets, including Parr Boulevard and Richmond Parkway. In addition, considering that both streets currently have high truck volumes because they serve primarily industrial areas, the additional trips generated by the project would not conflict with existing and proposed transit, roadway, bicycle, and pedestrian facilities in the project vicinity. The project would also not modify any transit, roadway, bicycle, or pedestrian facilities and would not conflict with existing or proposed facilities in the project vicinity.

The project would be consistent with programs, plans, ordinances, and policies addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. The impact is less than significant.
b) Would the Project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
Less than Significant Impact. CEQA Guidelines Section 15064.3, added in December 2018 and consistent with the requirements of SB 743, states that vehicle miles traveled (VMT) is the most appropriate metric to assess the environmental impacts of a project on transportation.

The City of Richmond adopted VMT analysis guidelines, methodology, and thresholds of significance on April 6, 2021, consistent with the Contra Costa Transportation Authority (CCTA)’s adopted VMT guidelines, which are also consistent with the State’s Office of Planning and Research’s (OPR) Technical Advisory on Evaluating Transportation Impacts in CEQA (December 2018). The City of Richmond guidelines includes screening criteria for development projects that meet certain criteria that can readily lead to the conclusion that they would not cause a significant impact on VMT. The screening criterion applicable to the project is the Small Projects criterion, which states that projects 1344

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generating less than 836 VMT per day can be presumed to cause a less than significant impact on VMT.

Error! Not a valid bookmark self-reference. summarizes the estimated VMT generated by the project on a typical weekday. Since the City of Richmond’s adopted guidelines, which are based on the CCTA Guidelines and consistent with CEQA Guidelines section 15064.3, subdivision (a) state that the VMT analysis for transportation impact purposes can focus solely on VMT generated by passenger vehicles and light-duty trucks and not include the VMT generated by heavy trucks, the project VMT summarized in Error! Not a valid bookmark self-reference. does not include the VMT generated by trucks for the project. As shown in Error! Not a valid bookmark self-reference., the project is estimated to generate 174 VMT per day, which is below the screening criterion of 836 VMT per day. Therefore, the project can be presumed to have a less than significant impact on VMT and is consistent with CEQA Guidelines section 15064.3, subdivision (b) and the impact is less than significant.

TABLE 4.15-2

PROJECT VMT SUMMARY
Use Amount Daily VMT Rate Total VMT
Employees 12a 14.5b 174
Total 174
Threshold 836
Below Threshold? Yes
NOTES:
a Per the Project Applicant and described in Chapter 2, Project Description b Daily commute VMT per worker in 2020 based on the CCTA Travel Demand Model for TAZ 10347, where the project is located c Per the Project Applicant and as described in Chapter 2, Project Description, 125 trucks would serve the site during a typical week. This estimate assumes they would be evenly distributed on five weekdays d Per the Project Applicant and described in Chapter 2, Project Description, average truck trip would be 40 miles; assuming two trips (one inbound and one outbound) per truck.

SOURCE: Fehr & Peers, 2022
c) Substantially increase hazards due to a geometric design feature, (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? Less than Significant Impact. The project would not modify the access point to the existing WCCSL facility, the internal circulation within WCCSL, or the public right-ofway. Passenger vehicles and trucks would continue to access the project site through Parr Boulevard and Richmond Parkway. The project is located in an industrial area with high volume of large trucks already present on surrounding roadways, including Parr Boulevard and Richmond Parkway. The additional trucks added by the project would not result in incompatible uses or increase hazards. Thus, the impact on hazards due to a geometric design feature or incompatible uses is less than significant. d) Result in inadequate emergency access?
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Less than Significant Impact. As discussed above, the project would not modify the access point to the existing WCCSL facility, the internal circulation within WCCSL, or the public right-of-way. Emergency vehicles would continue to access the project site on Parr Boulevard.

The project would be designed and constructed according to the applicable fire and safety standards at the time of construction. Therefore, the WCCSL site would continue to be accessible by fire and emergency vehicles through public streets and the internal roadways within the WCCSL. Thus, the impact on emergency access is less than significant.

References
California State’s Office of Planning and Research’s (OPR) Technical Advisory on Evaluating Transportation Impacts in CEQA (December 2018).
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4.16 Tribal Cultural Resources
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Tribal Cultural Resources
Would the project:
a) Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either 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, and that is:
i) 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), or

ii) 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
5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead
agency shall consider the significance of the
resource to a California Native American tribe.

Setting
ESA contacted the California State Native American Heritage Commission (NAHC) on October 20, 2021, to request a search of the NAHC’s Sacred Lands File and a list of Native American representatives who may have knowledge of tribal cultural resources in the project vicinity or interest in the proposed project. The NAHC replied to ESA by email on November 19, 2021, noting that the Sacred Lands File has no record of any sacred sites within the project site. The NAHC response included a list of 15 Native American representatives from 13 tribal groups who may have knowledge of tribal cultural resources in the vicinity of the project site.

On May 4, 2022, the City received a response for consultation from Chairwoman Corrina Gould of the Confederated Villages of Lisjan. On May 18, 2022, the City held a virtual meeting with tribal members, Chairwoman Gould, Deja, and Cheyenne, to discuss the project and any potential impacts to cultural resources. Based on the discussion, the tribe has no concerns with the project as it relates to impacts to tribal cultural resources and cultural resources, and is comfortable with the proposed mitigation measures. See Section 4.5, Cultural Resources, of this checklist for a summary of ESA’s NWIC records search and cultural resources sensitivity assessment. 1347

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Evaluation
a.i, a.ii)
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), or significance of the resource to a California Native American tribe.

Less than Significant Impact, after Mitigation. CEQA requires the lead agency to consider the effects of a project on tribal cultural resources. As defined in PRC Section 21074, tribal cultural resources are sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are listed, or determined to be eligible for listing, on the national, state, or local register of historical resources.

Based on the NWIC records search and the NAHC SLF negative search results, there are no known tribal cultural resources listed or determined eligible for listing in the California Register of Historical Resources or included in a local register of historical resources as defined in PRC Section 5020.1(k), pursuant to PRC Section 21074(a)(1), would be affected by the project. No tribal cultural resources have been identified by Native American representatives, and background research did not identify any tribal cultural resources. In addition, the City did not determine any resource that could potentially be affected by the project to be a significant tribal cultural resource pursuant to criteria set forth in PRC Section 5024.1(c).

In the event that cultural materials are identified during project construction activities that are determined to be tribal cultural resources, implementation of Mitigation Measure CUL-1a: Cultural Resources Awareness Training, Mitigation Measure CUL-1b:

Inadvertent Discovery of Cultural Materials or Tribal Cultural Resources, and Mitigation Measure CUL-2: Inadvertent Discovery of Human Remains, all identified above in Section 4.5, Cultural Resources, would reduce potentially significant impacts to less than significant. These mitigation measures would ensure that all personnel complete a cultural resources awareness training prior to any ground-disturbing activity and that work halt in the vicinity of a find until a qualified archaeologist and a Native American representative can make an assessment and provide additional recommendations.

References
Northwest Information Center (NWIC), Records Search File No. File No. 21-1575. On file, ESA, March 23, 2022.
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4.17 Utilities and Service Systems
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Utilities and Service Systems
Would the project:
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 which serves or may serve the
project that it has adequate capacity to serve the
project’s projected demand in addition to the provider’s existing commitments?

d) Generate solid waste in excess of State or local
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment of solid waste reduction goals?

e) Comply with federal, State, and local management
and reduction statutes and regulations related to solid waste?

Setting
The project site, within the WCCSL BMPC, is currently served by all public utilities, including water and wastewater treatment by EBMUD and West County Wastewater District, respectively, as well as the reuse of runoff water, and PG&E provides electric power, natural gas.

Evaluation
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?
Less than Significant Impact. The existing WCCSL would use offtake approximately

0.5 MW from the power generation for Republic’s onsite operation needs and the rest would be used to power the proposed project. Any additional electrical power required beyond that generated onsite would come from an existing PG&E power drop to the site.

The project would also involve a new 250,000-gallon integrated fire water tank and diesel engine for emergency use, per fire regulations, but would continue to be served by RFD 1349

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and the West County Fire District. As previously discussed in 4.14, Public Services and Recreation, all construction-related mitigation measures identified in this analysis would apply to that development onsite, which would ensure any environmental effects from the project would be less than significant.
b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? Less than Significant Impact. Steam is injected into the process to promote the thermal decomposition of the feedstock. Estimated water flow required for boiler feedwater and for cooling tower make-up is about 70 percent of the total required and is on the order of 60 gallons per minute (gpm) (81,500 gallons per day [gpd]). Adding in required water flow for overall processes and wash water for cleaning, the total water flow required for the project is estimated to be 81 gpm (116,200 gpd) (Raven, 2022b).

Potable water is available for both domestic and fire protection to the subject property from existing major facilities (e.g., reservoirs, pumping plants), which are serviced and maintained by EBMUD. Service would be granted subject to compliance with the District’s regulations governing water service and Schedule of Rates and Charges, which may include water main extensions and/or off-site pipeline improvements (Raven SR, 2022c). For this analysis, it is not anticipated that the proposed project would require new water supplies for its operation to the extent that it would make future water supplies insufficient. The impact would be less than significant. c) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? Less than Significant Impact. Wastewater generated by the process is mainly cooling tower blowdown, RO system blowdown, and boiler system blowdown, along with a small flow from the syngas wash columns. Intermittent flow is from potable sources (restrooms, sinks, etc.) and area wash down water. Wastewater would be generated from the syngas wash columns, which can potentially contain low concentrations of organic compounds. Wastewater would be treated before it is discharged to the sewer systems through sump and grease/oil where the organic content would be removed for capture/reclaim/disposal, and the water portion sent to the wastewater sewer.

Total wastewater discharge from all project processes (or waste streams) is estimated to be 50,200 gallons per day, and the West County Wastewater District would permit this additional use upon its determination that the discharge may be covered by the Districts’ Pretreatment and/or Pollution Prevention programs (Raven, 2022b).

Discussions are occurring between the project applicant and the West County Wastewater District and are in the permitting process. At this time, there are no anticipated capacity issues expected. Given the small scale of the proposed project, the lack of notable new population onsite, it is reasonable that the West County Wastewater District, as 1350

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wastewater treatment provider, would maintain adequate capacity to meet its demands with the addition of the proposed project. The impact would be less than significant. d,e) Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? Comply with federal, State, and local management and reduction statutes and regulations related to solid waste?
Less than Significant Impact. The project would not generate substantial solid waste but would convert existing organic waste into a reusable fuel product. Therefore, the project would not conflict with existing local or other laws or policies regarding the reduction, reuse and management of solid waste. The impact would be less than significant.

References
City of Richmond, 2012. Richmond General Plan Update Environmental Impact Report. SCH. 2008022018. 2012.

Contra Costa County 2004. Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions, SCH. 2002102057. June 2004.

Contra Costa County 2009. Addendum to the Final EIR for the WCCSL BMPC and Related Actions, SCH. 2002102057. 2009.

RAVEN SR, 2022b. West County Wastewater District Wastewater Discharge Permit Application. October 2022.

RAVEN SR, 2022c. Correspondence from Tracy Barrow, East Bay Municipal Utilities District, to Mike Fatigati, Raven SR. September 2022.
______________________________
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4.18 Wildfire
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Wildfire
If located in or near State Responsibility Areas or lands classified as very high fire hazard severity zones, would the project:
a) Substantially impair an adopted emergency
response plan or emergency evacuation plan? 
b) Due to slope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose project
occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a 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 structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope
instability, or drainage changes?

Setting
The project site borders expansive non-native grassland and ruderal species in open and that can get very dry during summer months. Factors that contribute to the risk of fire include dense and fire-prone vegetation, poor access to fire-fighting equipment because of slopes or inadequate roads, lack of adequate water pressure and service in fire-prone locations, and seasonal atmospheric conditions that result in warm, dry fire seasons with strong afternoon winds. Wildfire hazard maps show the site as not being within a high wildfire hazard zone (CPUC, 2018).

Evaluation
a) Substantially impair an adopted emergency response plan or emergency evacuation plan?
Less than Significant Impact. As discussed under Section 4.15, Transportation, the project would not modify the access point to the existing WCCSL facility, the internal circulation within WCCSL, or the public right-of-way. Therefore, the project would not impair any existing plans for emergency response or evaluation. The impact would be less than significant.
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b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
Less than Significant Impact. Certain project characteristics could have the potential to exacerbate wildfire risks, such as diesel fuel storage for the fire water take. However, no hazardous materials would be used in the conversion process. The biocarbon materials produced are inert to the process (i.e., not gasified). Also, the conversion process also derives electricityfrom fuel cells or turbines and/or internal combustion engine generator sets.

The project site is relatively flat, within the context of marshlands and Bay shoreline, and would also include a new fire water tank and diesel engine per fire regulations onsite. The tank would be used for emergency use, although the project site would still being served by the RFD and the West County Fire District. The impact would be less than significant. 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?
No Impact. The project site is fully served by existing infrastructure that currently service the WCCSL. It would not require the installation or maintenance of additional infrastructure that may exacerbate fire risk. There would be 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
Less than Significant Impact. The project would not introduce new people on the site, other than up to three to four employees per shift. As previously mentioned, the site is relatively flat, not located within downstream flood or landslide areas. The proposed project is not located in a high wildfire hazard zone (CPUC, 2018). The impact would be less than significant.

References
California Public Utilities Commission. Fire-Threat Map – State of California. January 19, 2018.

City of Richmond, 2011. General Plan 2030 – Map 12.6 Police and Fire Services. August 2011.

City of Richmond, 2012. Richmond General Plan Update Environmental Impact Report. SCH. 2008022018. 2012.
1353

4. Environmental Checklist and Evaluation
Raven SR Bioenergy Project 104 ESA / D202100382
Initial Study October 7, 2022

4.19 Mandatory Findings of Significance
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Mandatory Findings of Significance
a) Does the project have the potential to substantially degrade the quality of the environment, substantially
reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community,
substantially 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?

Findings
a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially 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?
Less than Significant Impact, after Mitigation. The proposed project may result in potential construction-related impacts to nesting special-status birds and to California Black Rail and California Ridgway’s Rail. The potential impacts are reduced to less than significant by requiring surveys and avoidance of construction-related work during specific times of year:
 Mitigation Measure BIO-1: Avoid and Minimize Impacts to Nesting Birds, Except Rails
 Mitigation Measure BIO-2: Avoid and Minimize Impacts to California Black Rail and California Ridgway’s Rail
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4. Environmental Checklist and Evaluation
Raven SR Bioenergy Project 105 ESA / D202100382
Initial Study October 7, 2022
The proposed project may result in potential impacts to Cultural Resources, Paleontological Resources (Geology and Soils), and Tribal Cultural Resources, unless the following mitigation measures are implemented, which would reduce the potential impacts to less than significant:
 Mitigation Measure CUL-1a: Cultural Resources Awareness Training  Mitigation Measure CUL-1b: Inadvertent Discovery of Cultural Materials or Tribal Cultural Resources
 Mitigation Measure CUL-2: Inadvertent Discovery of Human Remains. 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)? Less than Significant Impact, after Mitigation. The project does not result in a cumulative consideration impact for any environmental factors. One common exception, this evaluation does identify the BAAQMD Basic Construction Mitigation Measures Recommended for All Projects (Best Management Practices) to address fugitive dust during construction, which applies even though the project’s construction air emissions are all below the BAAQMD CEQA thresholds of significance. The BMPs also apply to all individual projects and ensure that a significant impact with respect to fugitive dust is less than significant.
 Mitigation Measure AQ-1: Best Management Practices.

Given the relatively small scope of the proposed project, its limited potential impacts, as well as the mitigation measures identified in this Draft IS/MND and listed below, the incremental effects of the project are not cumulatively considerable when considered with the potential effects of past, current, and probable future projects. The project does not have any significant cumulative impacts. Impacts would be less than significant. c) Does the project have environmental effects, which will cause substantial adverse effects on human beings, either directly or indirectly? Less than Significant Impact, after Mitigation. All impacts identified in this Draft IS/MND are either less than significant after implementation of identified mitigation measures (all listed above), or less than significant without the need for mitigation. Of those impacts, only the potential impact of PM10 and PM2.5 (fugitive dust) being added to the local atmosphere during construction has the potential to adversely affect human beings, directly or indirectly. As discussed under finding “b” above, the project’s implementation of Mitigation Measure AQ-1: Best Management Practices, would reduce the impact to less than significant.
1355

5. Document Preparers
Raven SR Bioenergy Project 106 ESA / D202100382
Initial Study October 7, 2022

5. Document Preparers

5.1 CEQA Consultant
ESA
180 Grand Avenue – Suite 1050
Oakland, CA 94612
Phone 510.839.5066
Project Director Crescentia Brown
Project Manager Tim Sturtz
Air Quality/GHG Chris Easter, Director
Air Quality/GHG Tim Sturtz, Principal
Madison Castelazo, Analyst
Energy Bailey Setzler, Planner
Noise/Vibration Chris Sanchez, Senior Technical Associate Hazardous Materials Michael Burns, Environmental Scientist Biological Resources Sharon, Dulava, Biologist
Cultural Resources Heidi Koenig, RPA
Tribal Consultation Heidi Koenig, RPA
Senior Review / Other Topics Crescentia Brown
Graphics Ron Teitel

5.2 Technical Subconsultant
Fehr & Peers Transportation
2201 Broadway – Suite 602
Oakland, CA 94612
Phone 510.835.1943
Transportation Sam Tabibnia, Senior Associate
1356
Raven SR Bioenergy Project A-1 ESA / D202100382
Initial Study October 7, 2022

APPENDIX A
Emissions Data, Assumptions and Modeling Files
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This page is intentionally blank.
1358
RAVEN
Contra Costa County, Annual
Project Characteristics -
Land Use - Project specific info
Construction Phase - Project specific information
Off-road Equipment - Project specific information
Off-road Equipment - Project specific information
Off-road Equipment - Project specific information
Off-road Equipment - Project specific information
Trips and VMT - Client provided information
Grading - Project specific information
Vehicle Trips - Project specific information
Area Coating - Project specific information

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population General Light Industry 40.00 1000sqft 1.30 40,000.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
5 Wind Speed (m/s) 2.2 Precipitation Freq (Days) 58

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Pacific Gas and Electric Company
Operational Year 2023
CO2 Intensity
(lb/MWhr)
203.98 CH4 Intensity 0.033
(lb/MWhr)
N2O Intensity 0.004
(lb/MWhr)
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Construction Off-road Equipment Mitigation -
Operational Off-Road Equipment - Project specific information Stationary Sources - Emergency Generators and Fire Pumps - Table Name Column Name Default Value New Value
tblConstructionPhase NumDays 200.00 138.00
tblConstructionPhase NumDays 20.00 5.00
tblConstructionPhase NumDays 4.00 30.00
tblConstructionPhase NumDays 2.00 30.00
tblGrading AcresOfGrading 15.00 4.00
tblLandUse LotAcreage 0.92 1.30
tblOffRoadEquipment HorsePower 97.00 247.00
tblOffRoadEquipment HorsePower 78.00 81.00
tblOffRoadEquipment HorsePower 78.00 97.00
tblOffRoadEquipment HorsePower 212.00 187.00
tblOffRoadEquipment HorsePower 85.00 247.00
tblOffRoadEquipment HorsePower 158.00 97.00
tblOffRoadEquipment HorsePower 158.00 187.00
tblOffRoadEquipment HorsePower 80.00 247.00
tblOffRoadEquipment HorsePower 100.00 97.00
tblOffRoadEquipment HorsePower 100.00 89.00
tblOffRoadEquipment LoadFactor 0.37 0.40
tblOffRoadEquipment LoadFactor 0.48 0.73
tblOffRoadEquipment LoadFactor 0.48 0.37
tblOffRoadEquipment LoadFactor 0.43 0.41
tblOffRoadEquipment LoadFactor 0.78 0.40
tblOffRoadEquipment LoadFactor 0.38 0.37
tblOffRoadEquipment LoadFactor 0.38 0.41
tblOffRoadEquipment LoadFactor 0.38 0.40
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2.0 Emissions Summary
tblOffRoadEquipment LoadFactor 0.40 0.37
tblOffRoadEquipment LoadFactor 0.40 0.20
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 1.00 tblOffRoadEquipment OffRoadEquipmentUnitAmount 3.00 2.00 tblOffRoadEquipment UsageHours 6.00 8.00
tblOffRoadEquipment UsageHours 7.00 8.00
tblOperationalOffRoadEquipment OperDaysPerYear 260.00 365.00 tblOperationalOffRoadEquipment OperHoursPerDay 8.00 24.00 tblOperationalOffRoadEquipment OperOffRoadEquipmentNumber 0.00 1.00 tblTripsAndVMT HaulingTripNumber 0.00 20.00
tblTripsAndVMT HaulingTripNumber 0.00 32.00
tblTripsAndVMT HaulingTripNumber 0.00 20.00
tblTripsAndVMT VendorTripNumber 7.00 4.00
tblTripsAndVMT WorkerTripNumber 10.00 2.00
tblTripsAndVMT WorkerTripNumber 20.00 2.00
tblTripsAndVMT WorkerTripNumber 10.00 2.00
tblTripsAndVMT WorkerTripNumber 17.00 2.00
tblVehicleTrips ST_TR 1.99 0.67
tblVehicleTrips SU_TR 5.00 0.67
tblVehicleTrips WD_TR 4.96 0.67
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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
2022 0.1109 1.0010 0.9211 2.0500e0034.8300e0030.0433 0.0481 9.8000e0040.0411 0.0420 0.0000 176.5135 176.5135 0.0420 8.4000e004177.8124 2023 0.0572 0.4813 0.5134 9.4000e0041.3300e0030.0217 0.0230 3.7000e0040.0208 0.0212 0.0000 80.1650 80.1650 0.0148 3.8000e00480.6476 Maximum 0.1109 1.0010 0.9211 2.0500e0034.8300e0030.0433 0.0481 9.8000e0040.0411 0.0420 0.0000 176.5135 176.5135 0.0420 8.4000e004177.8124 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
2022 0.1109 1.0010 0.9211 2.0500e0033.6600e0030.0433 0.0469 8.5000e0040.0411 0.0419 0.0000 176.5133 176.5133 0.0420 8.4000e004177.8122 2023 0.0572 0.4813 0.5134 9.4000e0041.3300e0030.0217 0.0230 3.7000e0040.0208 0.0212 0.0000 80.1649 80.1649 0.0148 3.8000e00480.6476 Maximum 0.1109 1.0010 0.9211 2.0500e0033.6600e0030.0433 0.0469 8.5000e0040.0411 0.0419 0.0000 176.5133 176.5133 0.0420 8.4000e004177.8122 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 18.99 0.00 1.64 9.63 0.00 0.21 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) 1 7-1-2022 9-30-2022 0.4036 0.4036
2 10-1-2022 12-31-2022 0.6761 0.6761
3 1-1-2023 3-31-2023 0.5375 0.5375
Highest 0.6761 0.6761

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 0.1771 0.0000 3.7000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 7.1000e0047.1000e0040.0000 0.0000 7.6000e004 Energy 5.3000e0030.0482 0.0405 2.9000e0043.6600e0033.6600e0033.6600e0033.6600e0030.0000 79.9440 79.9440 5.4500e0031.5000e00380.5276 Mobile 0.0133 0.0161 0.1306 2.8000e0040.0289 2.1000e0040.0292 7.7300e0031.9000e0047.9200e0030.0000 25.5208 25.5208 1.5700e0031.1800e00325.9122 Offroad 0.1481 1.4534 0.8266 3.4300e0030.0487 0.0487 0.0448 0.0448 0.0000 300.7720 300.7720 0.0973 0.0000 303.2039 Waste 0.0000 0.0000 0.0000 0.0000 10.0684 0.0000 10.0684 0.5950 0.0000 24.9439 Water 0.0000 0.0000 0.0000 0.0000 2.9346 4.6310 7.5656 0.3022 7.2100e00317.2675 Total 0.3438 1.5177 0.9981 4.0000e0030.0289 0.0525 0.0815 7.7300e0030.0486 0.0564 13.0030 410.8685 423.8714 1.0015 9.8900e003451.8558 Unmitigated Operational
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3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 7/18/2022 7/22/2022 5 5
2 Site Preparation Site Preparation 7/25/2022 9/2/2022 5 30 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 CalEEMod Version: CalEEMod.2020.4.0 Page 6 of 28 Date: 8/11/2022 11:05 AM RAVEN - Contra Costa County, Annual
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3 Grading Grading 9/5/2022 10/14/2022 5 30
4 Building Construction Building Construction 9/19/2022 3/29/2023 5 138 OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Demolition Air Compressors 1 8.00 81 0.73
Demolition Crushing/Proc. Equipment 1 8.00 247 0.40
Demolition Dumpers/Tenders 1 8.00 16 0.38
Demolition Excavators 1 8.00 97 0.37
Site Preparation Dumpers/Tenders 1 8.00 16 0.38
Site Preparation Excavators 3 8.00 187 0.41
Site Preparation Plate Compactors 2 8.00 8 0.43
Site Preparation Rough Terrain Forklifts 1 8.00 97 0.37 Site Preparation Tractors/Loaders/Backhoes 1 8.00 247 0.40 Grading Crawler Tractors 1 8.00 187 0.41
Grading Excavators 1 8.00 158 0.38
Grading Rollers 1 8.00 247 0.40
Grading Tractors/Loaders/Backhoes 1 8.00 97 0.37
Building Construction Air Compressors 1 8.00 97 0.37
Building Construction Cranes 1 8.00 231 0.29
Building Construction Generator Sets 1 8.00 84 0.74
Building Construction Other Construction Equipment 1 8.00 172 0.42 Building Construction Rough Terrain Forklifts 1 8.00 89 0.20 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): 4
Acres of Paving: 0
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3.2 Demolition - 2022
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 2.7900e0030.0193 0.0205 5.0000e0059.1000e0049.1000e0048.9000e0048.9000e0040.0000 4.3996 4.3996 4.1000e0040.0000 4.4099 Total 2.7900e0030.0193 0.0205 5.0000e0059.1000e0049.1000e0048.9000e0048.9000e0040.0000 4.3996 4.3996 4.1000e0040.0000 4.4099 Unmitigated Construction On-Site

3.1 Mitigation Measures Construction
Water Exposed Area
Building Construction Welders 2 8.00 46 0.45
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
Demolition 4 2.00 0.00 20.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Site Preparation 8 2.00 0.00 32.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Grading 4 2.00 0.00 20.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Building Construction 7 2.00 4.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2020.4.0 Page 8 of 28 Date: 8/11/2022 11:05 AM RAVEN - Contra Costa County, Annual
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3.2 Demolition - 2022
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 5.0000e0051.7100e0033.6000e0041.0000e0051.7000e0042.0000e0051.9000e0045.0000e0051.0000e0056.0000e0050.0000 0.6262 0.6262 2.0000e0051.0000e0040.6563 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 1.0000e0051.0000e0051.2000e0040.0000 4.0000e0050.0000 4.0000e0051.0000e0050.0000 1.0000e0050.0000 0.0319 0.0319 0.0000 0.0000 0.0322 Total 6.0000e0051.7200e0034.8000e0041.0000e0052.1000e0042.0000e0052.3000e0046.0000e0051.0000e0057.0000e0050.0000 0.6581 0.6581 2.0000e0051.0000e0040.6884 Unmitigated Construction Off-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
Off-Road 2.7900e0030.0193 0.0205 5.0000e0059.1000e0049.1000e0048.9000e0048.9000e0040.0000 4.3996 4.3996 4.1000e0040.0000 4.4099 Total 2.7900e0030.0193 0.0205 5.0000e0059.1000e0049.1000e0048.9000e0048.9000e0040.0000 4.3996 4.3996 4.1000e0040.0000 4.4099 Mitigated Construction On-Site
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3.3 Site Preparation - 2022
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
Fugitive Dust 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0177 0.1696 0.1377 5.0000e0045.6500e0035.6500e0035.2400e0035.2400e0030.0000 43.0480 43.0480 0.0135 0.0000 43.3865 Total 0.0177 0.1696 0.1377 5.0000e0040.0000 5.6500e0035.6500e0030.0000 5.2400e0035.2400e0030.0000 43.0480 43.0480 0.0135 0.0000 43.3865 Unmitigated Construction On-Site
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3.3 Site Preparation - 2022
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 7.0000e0052.7400e0035.8000e0041.0000e0052.7000e0042.0000e0053.0000e0047.0000e0052.0000e0051.0000e0040.0000 1.0019 1.0019 3.0000e0051.6000e0041.0501 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 8.0000e0056.0000e0057.3000e0040.0000 2.4000e0040.0000 2.4000e0046.0000e0050.0000 6.0000e0050.0000 0.1911 0.1911 1.0000e0051.0000e0050.1929 Total 1.5000e0042.8000e0031.3100e0031.0000e0055.1000e0042.0000e0055.4000e0041.3000e0042.0000e0051.6000e0040.0000 1.1930 1.1930 4.0000e0051.7000e0041.2430 Unmitigated Construction Off-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
Fugitive Dust 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0177 0.1696 0.1377 5.0000e0045.6500e0035.6500e0035.2400e0035.2400e0030.0000 43.0480 43.0480 0.0135 0.0000 43.3864 Total 0.0177 0.1696 0.1377 5.0000e0040.0000 5.6500e0035.6500e0030.0000 5.2400e0035.2400e0030.0000 43.0480 43.0480 0.0135 0.0000 43.3864 Mitigated Construction On-Site
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3.4 Grading - 2022
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
Fugitive Dust 2.1200e0030.0000 2.1200e0032.3000e0040.0000 2.3000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0166 0.1854 0.1437 3.5000e0047.5100e0037.5100e0036.9100e0036.9100e0030.0000 30.8182 30.8182 9.9700e0030.0000 31.0674 Total 0.0166 0.1854 0.1437 3.5000e0042.1200e0037.5100e0039.6300e0032.3000e0046.9100e0037.1400e0030.0000 30.8182 30.8182 9.9700e0030.0000 31.0674 Unmitigated Construction On-Site
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3.4 Grading - 2022
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 5.0000e0051.7100e0033.6000e0041.0000e0051.7000e0042.0000e0051.9000e0045.0000e0051.0000e0056.0000e0050.0000 0.6262 0.6262 2.0000e0051.0000e0040.6563 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 8.0000e0056.0000e0057.3000e0040.0000 2.4000e0040.0000 2.4000e0046.0000e0050.0000 6.0000e0050.0000 0.1911 0.1911 1.0000e0051.0000e0050.1929 Total 1.3000e0041.7700e0031.0900e0031.0000e0054.1000e0042.0000e0054.3000e0041.1000e0041.0000e0051.2000e0040.0000 0.8173 0.8173 3.0000e0051.1000e0040.8492 Unmitigated Construction Off-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
Fugitive Dust 9.5000e0040.0000 9.5000e0041.0000e0040.0000 1.0000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0166 0.1854 0.1437 3.5000e0047.5100e0037.5100e0036.9100e0036.9100e0030.0000 30.8182 30.8182 9.9700e0030.0000 31.0674 Total 0.0166 0.1854 0.1437 3.5000e0049.5000e0047.5100e0038.4600e0031.0000e0046.9100e0037.0100e0030.0000 30.8182 30.8182 9.9700e0030.0000 31.0674 Mitigated Construction On-Site
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3.5 Building Construction - 2022
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 0.0729 0.6117 0.6119 1.0900e0030.0291 0.0291 0.0279 0.0279 0.0000 91.9681 91.9681 0.0179 0.0000 92.4146 Total 0.0729 0.6117 0.6119 1.0900e0030.0291 0.0291 0.0279 0.0279 0.0000 91.9681 91.9681 0.0179 0.0000 92.4146 Unmitigated Construction On-Site
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3.5 Building Construction - 2022
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 3.5000e0048.5500e0032.5900e0033.0000e0059.9000e0049.0000e0051.0800e0032.9000e0049.0000e0053.8000e0040.0000 3.1336 3.1336 7.0000e0054.6000e0043.2713 Worker 2.1000e0041.5000e0041.8200e0031.0000e0055.9000e0040.0000 6.0000e0041.6000e0040.0000 1.6000e0040.0000 0.4777 0.4777 2.0000e0051.0000e0050.4823 Total 5.6000e0048.7000e0034.4100e0034.0000e0051.5800e0039.0000e0051.6800e0034.5000e0049.0000e0055.4000e0040.0000 3.6113 3.6113 9.0000e0054.7000e0043.7535 Unmitigated Construction Off-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
Off-Road 0.0729 0.6117 0.6119 1.0900e0030.0291 0.0291 0.0279 0.0279 0.0000 91.9680 91.9680 0.0179 0.0000 92.4145 Total 0.0729 0.6117 0.6119 1.0900e0030.0291 0.0291 0.0279 0.0279 0.0000 91.9680 91.9680 0.0179 0.0000 92.4145 Mitigated Construction On-Site
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3.5 Building Construction - 2023
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 0.0569 0.4756 0.5101 9.1000e0040.0217 0.0217 0.0208 0.0208 0.0000 77.2516 77.2516 0.0148 0.0000 77.6205 Total 0.0569 0.4756 0.5101 9.1000e0040.0217 0.0217 0.0208 0.0208 0.0000 77.2516 77.2516 0.0148 0.0000 77.6205 Unmitigated Construction On-Site
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3.5 Building Construction - 2023
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 1.4000e0045.6200e0031.8400e0033.0000e0058.3000e0043.0000e0058.6000e0042.4000e0043.0000e0052.7000e0040.0000 2.5248 2.5248 5.0000e0053.7000e0042.6349 Worker 1.6000e0041.1000e0041.4100e0030.0000 5.0000e0040.0000 5.0000e0041.3000e0040.0000 1.4000e0040.0000 0.3886 0.3886 1.0000e0051.0000e0050.3922 Total 3.0000e0045.7300e0033.2500e0033.0000e0051.3300e0033.0000e0051.3600e0033.7000e0043.0000e0054.1000e0040.0000 2.9134 2.9134 6.0000e0053.8000e0043.0271 Unmitigated Construction Off-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
Off-Road 0.0569 0.4756 0.5101 9.1000e0040.0217 0.0217 0.0208 0.0208 0.0000 77.2515 77.2515 0.0148 0.0000 77.6204 Total 0.0569 0.4756 0.5101 9.1000e0040.0217 0.0217 0.0208 0.0208 0.0000 77.2515 77.2515 0.0148 0.0000 77.6204 Mitigated Construction On-Site
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3.5 Building Construction - 2023
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 1.4000e0045.6200e0031.8400e0033.0000e0058.3000e0043.0000e0058.6000e0042.4000e0043.0000e0052.7000e0040.0000 2.5248 2.5248 5.0000e0053.7000e0042.6349 Worker 1.6000e0041.1000e0041.4100e0030.0000 5.0000e0040.0000 5.0000e0041.3000e0040.0000 1.4000e0040.0000 0.3886 0.3886 1.0000e0051.0000e0050.3922 Total 3.0000e0045.7300e0033.2500e0033.0000e0051.3300e0033.0000e0051.3600e0033.7000e0043.0000e0054.1000e0040.0000 2.9134 2.9134 6.0000e0053.8000e0043.0271 Mitigated Construction Off-Site
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4.0 Operational Detail - Mobile
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 0.0133 0.0161 0.1306 2.8000e0040.0289 2.1000e0040.0292 7.7300e0031.9000e0047.9200e0030.0000 25.5208 25.5208 1.5700e0031.1800e00325.9122 Unmitigated 0.0133 0.0161 0.1306 2.8000e0040.0289 2.1000e0040.0292 7.7300e0031.9000e0047.9200e0030.0000 25.5208 25.5208 1.5700e0031.1800e00325.9122

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
General Light Industry 26.80 26.80 26.80 78,243 78,243
Total 26.80 26.80 26.80 78,243 78,243
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 General Light Industry 9.50 7.30 7.30 59.00 28.00 13.00 92 5 3

4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH General Light Industry 0.558086 0.056127 0.180570 0.129764 0.024304 0.005480 0.007016 0.007028 0.000551 0.000343 0.026017 0.001231 0.003481 CalEEMod Version: CalEEMod.2020.4.0 Page 19 of 28 Date: 8/11/2022 11:05 AM RAVEN - Contra Costa County, Annual
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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 tons/yr MT/yr
Electricity
Mitigated

0.0000 0.0000 0.0000 0.0000 0.0000 27.4981 27.4981 4.4500e0035.4000e00427.7700 Electricity
Unmitigated

0.0000 0.0000 0.0000 0.0000 0.0000 27.4981 27.4981 4.4500e0035.4000e00427.7700 NaturalGas
Mitigated

5.3000e0030.0482 0.0405 2.9000e0043.6600e0033.6600e0033.6600e0033.6600e0030.0000 52.4460 52.4460 1.0100e0039.6000e00452.7576 NaturalGas
Unmitigated

5.3000e0030.0482 0.0405 2.9000e0043.6600e0033.6600e0033.6600e0033.6600e0030.0000 52.4460 52.4460 1.0100e0039.6000e00452.7576

5.1 Mitigation Measures Energy
Historical Energy Use: N
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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
General Light
Industry
982800 5.3000e0030.0482 0.0405 2.9000e0043.6600e0033.6600e0033.6600e0033.6600e0030.0000 52.4460 52.4460 1.0100e0039.6000e00452.7576 Total 5.3000e0030.0482 0.0405 2.9000e0043.6600e0033.6600e0033.6600e0033.6600e0030.0000 52.4460 52.4460 1.0100e0039.6000e00452.7576 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
General Light
Industry
982800 5.3000e0030.0482 0.0405 2.9000e0043.6600e0033.6600e0033.6600e0033.6600e0030.0000 52.4460 52.4460 1.0100e0039.6000e00452.7576 Total 5.3000e0030.0482 0.0405 2.9000e0043.6600e0033.6600e0033.6600e0033.6600e0030.0000 52.4460 52.4460 1.0100e0039.6000e00452.7576 Mitigated
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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
General Light
Industry
297200 27.4981 4.4500e0035.4000e00427.7700
Total 27.4981 4.4500e0035.4000e00427.7700
Unmitigated
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
General Light
Industry
297200 27.4981 4.4500e0035.4000e00427.7700
Total 27.4981 4.4500e0035.4000e00427.7700
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 tons/yr MT/yr
Mitigated 0.1771 0.0000 3.7000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 7.1000e0047.1000e0040.0000 0.0000 7.6000e004 Unmitigated 0.1771 0.0000 3.7000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 7.1000e0047.1000e0040.0000 0.0000 7.6000e004

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

0.0209 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

0.1562 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Landscaping 3.0000e0050.0000 3.7000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 7.1000e0047.1000e0040.0000 0.0000 7.6000e004 Total 0.1771 0.0000 3.7000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 7.1000e0047.1000e0040.0000 0.0000 7.6000e004 Unmitigated
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7.1 Mitigation Measures Water

7.0 Water Detail

0.0209 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

0.1562 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Landscaping 3.0000e0050.0000 3.7000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 7.1000e0047.1000e0040.0000 0.0000 7.6000e004 Total 0.1771 0.0000 3.7000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 7.1000e0047.1000e0040.0000 0.0000 7.6000e004 Mitigated
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Total CO2 CH4 N2O CO2e
Category MT/yr
Mitigated 7.5656 0.3022 7.2100e00317.2675
Unmitigated 7.5656 0.3022 7.2100e00317.2675

7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
General Light
Industry

9.25 / 0 7.5656 0.3022 7.2100e00317.2675
Total 7.5656 0.3022 7.2100e00317.2675
Unmitigated
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7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
General Light
Industry

9.25 / 0 7.5656 0.3022 7.2100e00317.2675
Total 7.5656 0.3022 7.2100e00317.2675
Mitigated

8.1 Mitigation Measures Waste

8.0 Waste Detail
Total CO2 CH4 N2O CO2e
MT/yr
Mitigated 10.0684 0.5950 0.0000 24.9439
Unmitigated 10.0684 0.5950 0.0000 24.9439
Category/Year
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8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
General Light
Industry

49.6 10.0684 0.5950 0.0000 24.9439
Total 10.0684 0.5950 0.0000 24.9439
Unmitigated
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
General Light
Industry

49.6 10.0684 0.5950 0.0000 24.9439
Total 10.0684 0.5950 0.0000 24.9439
Mitigated

9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type Rubber Tired Loaders 1 24.00 365 203 0.36 Diesel
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11.0 Vegetation
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
Equipment Type tons/yr MT/yr
Rubber Tired
Loaders

0.1481 1.4534 0.8266 3.4300e0030.0487 0.0487 0.0448 0.0448 0.0000 300.7720 300.7720 0.0973 0.0000 303.2039 Total 0.1481 1.4534 0.8266 3.4300e0030.0487 0.0487 0.0448 0.0448 0.0000 300.7720 300.7720 0.0973 0.0000 303.2039 UnMitigated/Mitigated

10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Emergency Generator 1 0 50 0 0.73
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
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Raven SR Bioenergy Project B-1 ESA / D202100382
Initial Study October 7, 2022

APPENDIX B
Special Status Species Lists
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1388
June 14, 2022
United States Department of the Interior

FISH AND WILDLIFE SERVICE
Sacramento Fish And Wildlife Office
Federal Building
2800 Cottage Way, Room W-2605
Sacramento, CA 95825-1846
Phone: (916) 414-6600 Fax: (916) 414-6713
In Reply Refer To:

Project Code: 2022-0054185
Project Name: Raven SR Bioenergy Project
Subject: List of threatened and endangered species that may occur in your proposed project location or may be affected by your proposed project
To Whom It May Concern:

The enclosed species list identifies threatened, endangered, proposed and candidate species, as well as proposed and final designated critical habitat, that may occur within the boundary of your proposed project and/or may be affected by your proposed project. The species list fulfills the requirements of the U.S. Fish and Wildlife Service (Service) under section 7(c) of the Endangered Species Act (Act) of 1973, as amended (16 U.S.C. 1531 et seq.).

New information based on updated surveys, changes in the abundance and distribution of species, changed habitat conditions, or other factors could change this list. Please feel free to contact us if you need more current information or assistance regarding the potential impacts to federally proposed, listed, and candidate species and federally designated and proposed critical habitat. Please note that under 50 CFR 402.12(e) of the regulations implementing section 7 of the Act, the accuracy of this species list should be verified after 90 days. This verification can be completed formally or informally as desired. The Service recommends that verification be completed by visiting the ECOS-IPaC website at regular intervals during project planning and implementation for updates to species lists and information. An updated list may be requested through the ECOS-IPaC system by completing the same process used to receive the enclosed list.

The purpose of the Act is to provide a means whereby threatened and endangered species and the ecosystems upon which they depend may be conserved. Under sections 7(a)(1) and 7(a)(2) of the Act and its implementing regulations (50 CFR 402 et seq.), Federal agencies are required to utilize their authorities to carry out programs for the conservation of threatened and endangered species and to determine whether projects may affect threatened and endangered species and/or designated critical habitat.

A Biological Assessment is required for construction projects (or other undertakings having similar physical impacts) that are major Federal actions significantly affecting the quality of the human environment as defined in the National Environmental Policy Act (42 U.S.C. 4332(2) 1389
06/14/2022 2
(c)). For projects other than major construction activities, the Service suggests that a biological evaluation similar to a Biological Assessment be prepared to determine whether the project may affect listed or proposed species and/or designated or proposed critical habitat. Recommended contents of a Biological Assessment are described at 50 CFR 402.12.

If a Federal agency determines, based on the Biological Assessment or biological evaluation, that listed species and/or designated critical habitat may be affected by the proposed project, the agency is required to consult with the Service pursuant to 50 CFR 402. In addition, the Service recommends that candidate species, proposed species and proposed critical habitat be addressed within the consultation. More information on the regulations and procedures for section 7 consultation, including the role of permit or license applicants, can be found in the "Endangered Species Consultation Handbook" at:
http://www.fws.gov/endangered/esa-library/pdf/TOC-GLOS.PDF Migratory Birds: In addition to responsibilities to protect threatened and endangered species under the Endangered Species Act (ESA), there are additional responsibilities under the Migratory Bird Treaty Act (MBTA) and the Bald and Golden Eagle Protection Act (BGEPA) to protect native birds from project-related impacts. Any activity, intentional or unintentional, resulting in take of migratory birds, including eagles, is prohibited unless otherwise permitted by the U.S. Fish and Wildlife Service (50 C.F.R. Sec. 10.12 and 16 U.S.C. Sec. 668(a)). For more information regarding these Acts see https://www.fws.gov/birds/policies-and-regulations.php.

The MBTA has no provision for allowing take of migratory birds that may be unintentionally killed or injured by otherwise lawful activities. It is the responsibility of the project proponent to comply with these Acts by identifying potential impacts to migratory birds and eagles within applicable NEPA documents (when there is a federal nexus) or a Bird/Eagle Conservation Plan (when there is no federal nexus). Proponents should implement conservation measures to avoid or minimize the production of project-related stressors or minimize the exposure of birds and their resources to the project-related stressors. For more information on avian stressors and recommended conservation measures see https://www.fws.gov/birds/bird-enthusiasts/threats-tobirds.php.

In addition to MBTA and BGEPA, Executive Order 13186: Responsibilities of Federal Agencies to Protect Migratory Birds, obligates all Federal agencies that engage in or authorize activities that might affect migratory birds, to minimize those effects and encourage conservation measures that will improve bird populations. Executive Order 13186 provides for the protection of both migratory birds and migratory bird habitat. For information regarding the implementation of Executive Order 13186, please visit https://www.fws.gov/birds/policies-and-regulations/ executive-orders/e0-13186.php.

We appreciate your concern for threatened and endangered species. The Service encourages Federal agencies to include conservation of threatened and endangered species into their project planning to further the purposes of the Act. Please include the Consultation Code in the header of this letter with any request for consultation or correspondence about your project that you submit to our office.
1390
06/14/2022 3
▪
Attachment(s):

Official Species List
1391
06/14/2022 1
Official Species List
This list is provided pursuant to Section 7 of the Endangered Species Act, and fulfills the requirement for Federal agencies to "request of the Secretary of the Interior information whether any species which is listed or proposed to be listed may be present in the area of a proposed action".

This species list is provided by:

Sacramento Fish And Wildlife Office
Federal Building
2800 Cottage Way, Room W-2605
Sacramento, CA 95825-1846
(916) 414-6600
1392
06/14/2022 2
Project Summary
Project Code: 2022-0054185
Event Code: None
Project Name: Raven SR Bioenergy Project
Project Type: Commercial Development
Project Description: The proposed Raven SR Bioenergy Project (project) proposes to construct and operate a bioenergy system composed of the Raven SR multi-patented Steam/CO2 Reformation process at the project site. The non-combustible process would convert blended green waste and food waste obtained from the existing BMPC operation adjacent to the project site into renewable, transportation grade hydrogen that would be exported offsite for various renewable energy products. No hydrogen storage would occur onsite. The project would involve the erection of a modular structure and industrial canopy and would not add vehicle trips or other substantial traffic to the property.

Project Location:

Approximate location of the project can be viewed in Google Maps: https:// www.google.com/maps/@37.967288499999995,-122.38296104113344,14z Counties: Contra Costa County, California
1393
06/14/2022 3

1. Endangered Species Act Species
There is a total of 14 threatened, endangered, or candidate species on this species list.

NOAA Fisheries, also known as the National Marine Fisheries Service (NMFS), is an office of the National Oceanic and Atmospheric Administration within the Department of Commerce.

Mammals

NAME STATUS
Salt Marsh Harvest Mouse Reithrodontomys raviventris
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/613
Endangered
Birds

NAME STATUS
California Clapper Rail Rallus longirostris obsoletus
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/4240
Endangered
California Least Tern Sterna antillarum browni
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/8035
Threatened
1 1394
06/14/2022 4
Reptiles

NAME STATUS
Green Sea Turtle Chelonia mydas
Population: East Pacific DPS
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/6199
Threatened
Amphibians

NAME STATUS
California Red-legged Frog Rana draytonii
There is final critical habitat for this species. The location of the critical habitat is not available.

Species profile: https://ecos.fws.gov/ecp/species/2891
Threatened
Fishes

NAME STATUS
Delta Smelt Hypomesus transpacificus
There is final critical habitat for this species. The location of the critical habitat is not available.

Species profile: https://ecos.fws.gov/ecp/species/57
Endangered
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06/14/2022 5
Flowering Plants

NAME STATUS
Marin Dwarf-flax Hesperolinon congestum
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/5363
Threatened
Showy Indian Clover Trifolium amoenum
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/6459
Endangered
Tiburon Jewelflower Streptanthus niger
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/4187
Endangered
Tiburon Mariposa Lily Calochortus tiburonensis
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/2858
Threatened
Tiburon Paintbrush Castilleja affinis ssp. neglecta
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/2687
Endangered
White-rayed Pentachaeta Pentachaeta bellidiflora
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/7782
Endangered
Critical habitats

THERE ARE NO CRITICAL HABITATS WITHIN YOUR PROJECT AREA UNDER THIS OFFICE'S JURISDICTION.
1396
06/14/2022 6
IPaC User Contact Information
Agency: Environmental Science Associates
Name: Sharon Dulava
Address: 787 The Alameda
Address Line 2: Suite 250
City: San Jose
State: CA
Zip: 95126
Email [email protected]
Phone: 9252859473
1397
Species Element Code Federal Status State Status Global Rank State Rank Rare Plant
Rank/CDFW
SSC or FP
Accipiter cooperii
Cooper's hawk
ABNKC12040 None None G5 S4 WL
Acipenser medirostris pop. 1
green sturgeon - southern DPS
AFCAA01031 Threatened None G2T1 S1
Antrozous pallidus
pallid bat
AMACC10010 None None G4 S3 SSC
Ardea alba
great egret
ABNGA04040 None None G5 S4
Asio flammeus
short-eared owl
ABNSB13040 None None G5 S3 SSC
Astragalus tener var. tener
alkali milk-vetch
PDFAB0F8R1 None None G2T1 S1 1B.2
Athene cunicularia
burrowing owl
ABNSB10010 None None G4 S3 SSC
Bombus caliginosus
obscure bumble bee
IIHYM24380 None None G2G3 S1S2
Bombus occidentalis
western bumble bee
IIHYM24250 None None G2G3 S1
Calystegia purpurata ssp. saxicola
coastal bluff morning-glory
PDCON040D2 None None G4T2T3 S2S3 1B.2
Chloropyron maritimum ssp. palustre
Point Reyes salty bird's-beak
PDSCR0J0C3 None None G4?T2 S2 1B.2
Chloropyron molle ssp. molle
soft salty bird's-beak
PDSCR0J0D2 Endangered Rare G2T1 S1 1B.2
Circus hudsonius
northern harrier
ABNKC11011 None None G5 S3 SSC
Danaus plexippus pop. 1
monarch - California overwintering population
IILEPP2012 Candidate None G4T2T3 S2S3
Dirca occidentalis
western leatherwood
PDTHY03010 None None G2 S2 1B.2
Egretta thula
snowy egret
ABNGA06030 None None G5 S4
Elanus leucurus
white-tailed kite
ABNKC06010 None None G5 S3S4 FP
Emys marmorata
western pond turtle
ARAAD02030 None None G3G4 S3 SSC
Fritillaria liliacea
fragrant fritillary
PMLIL0V0C0 None None G2 S2 1B.2
Helminthoglypta nickliniana bridgesi
Bridges' coast range shoulderband
IMGASC2362 None None G3T1 S1S2
BIOS selection
Raven SR Bioenergy Project Initial Study: 5 Mile Study Area Query Criteria:

Report Printed on Tuesday, June 14, 2022
Commercial Version -- Dated June, 3 2022 -- Biogeographic Data Branch Page 1 of 3 Information Expires 12/3/2022
Selected Elements by Scientific Name
California Department of Fish and Wildlife
California Natural Diversity Database
1398
Species Element Code Federal Status State Status Global Rank State Rank Rare Plant
Rank/CDFW
SSC or FP
Hoita strobilina
Loma Prieta hoita
PDFAB5Z030 None None G2? S2? 1B.1
Holocarpha macradenia
Santa Cruz tarplant
PDAST4X020 Threatened Endangered G1 S1 1B.1
Hydroprogne caspia
Caspian tern
ABNNM08020 None None G5 S4
Lasiurus cinereus
hoary bat
AMACC05030 None None G3G4 S4
Laterallus jamaicensis coturniculus
California black rail
ABNME03041 None Threatened G3T1 S1 FP
Melospiza melodia pusillula
Alameda song sparrow
ABPBXA301S None None G5T2T3 S2S3 SSC
Melospiza melodia samuelis
San Pablo song sparrow
ABPBXA301W None None G5T2 S2 SSC
Microtus californicus sanpabloensis
San Pablo vole
AMAFF11034 None None G5T1T2 S1S2 SSC
Nannopterum auritum
double-crested cormorant
ABNFD01020 None None G5 S4 WL
Northern Coastal Salt Marsh
Northern Coastal Salt Marsh
CTT52110CA None None G3 S3.2
Nycticorax nycticorax
black-crowned night heron
ABNGA11010 None None G5 S4
Pandion haliaetus
osprey
ABNKC01010 None None G5 S4 WL
Rallus obsoletus obsoletus
California Ridgway's rail
ABNME05011 Endangered Endangered G3T1 S1 FP
Rana draytonii
California red-legged frog
AAABH01022 Threatened None G2G3 S2S3 SSC
Reithrodontomys raviventris
salt-marsh harvest mouse
AMAFF02040 Endangered Endangered G1G2 S1S2 FP
Sorex vagrans halicoetes
salt-marsh wandering shrew
AMABA01071 None None G5T1 S1 SSC
Spergularia macrotheca var. longistyla
long-styled sand-spurrey
PDCAR0W062 None None G5T2 S2 1B.2
Spirinchus thaleichthys
longfin smelt
AFCHB03010 Candidate Threatened G5 S1
Symphyotrichum lentum
Suisun Marsh aster
PDASTE8470 None None G2 S2 1B.2
Thaleichthys pacificus
eulachon
AFCHB04010 Threatened None G5 S2
Trifolium hydrophilum
saline clover
PDFAB400R5 None None G2 S2 1B.2
Report Printed on Tuesday, June 14, 2022
Commercial Version -- Dated June, 3 2022 -- Biogeographic Data Branch Page 2 of 3 Information Expires 12/3/2022
Selected Elements by Scientific Name
California Department of Fish and Wildlife
California Natural Diversity Database
1399
Species Element Code Federal Status State Status Global Rank State Rank Rare Plant
Rank/CDFW
SSC or FP
Tryonia imitator
mimic tryonia (=California brackishwater snail)
IMGASJ7040 None None G2 S2
Valley Needlegrass Grassland
Valley Needlegrass Grassland
CTT42110CA None None G3 S3.1
Xanthocephalus xanthocephalus
yellow-headed blackbird
ABPBXB3010 None None G5 S3 SSC
Record Count: 44
Report Printed on Tuesday, June 14, 2022
Commercial Version -- Dated June, 3 2022 -- Biogeographic Data Branch Page 3 of 3 Information Expires 12/3/2022
Selected Elements by Scientific Name
California Department of Fish and Wildlife
California Natural Diversity Database
1400
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1401
6/14/22, 3:26 PM CNPS Rare Plant Inventory | Search Results https://rareplants.cnps.org/Search/result?frm=T&sl=1&quad=3712284:3712283:3812214:3812213: 1/5 Search Results
CNPS Rare Plant Inventory
45 matches found. Click on scientific name for details
Search Criteria: Quad is one of [3712284:3712283:3812214:3812213] ▲ SCIENTIFIC

NAME COMMON NAME FAMILY LIFEFORM

BLOOMING
PERIOD
FED
LIST
STATE
LIST
GLOBAL
RANK
STATE
RANK
CA
RARE
PLANT

RANK PHOTO
Amorpha
californica var.
napensis
Napa false
indigo
Fabaceae perennial
deciduous
shrub
Apr-Jul None None G4T2 S2 1B.2
© 2016 John
Doyen
Amsinckia lunaris bent-flowered
fiddleneck
Boraginaceae annual herb Mar-Jun None None G3 S3 1B.2
© 2011 Neal
Kramer
Arabis
blepharophylla
coast
rockcress
Brassicaceae perennial herb Feb-May None None G4 S4 4.3 © 2011 Neal
Kramer
Arctostaphylos
pallida
pallid
manzanita
Ericaceae perennial
evergreen shrub
Dec-Mar FT CE G1 S1 1B.1
No Photo
Available
Aspidotis carlottahalliaeCarlotta Hall's
lace fern
Pteridaceae perennial
rhizomatous
herb
Jan-Dec None None G3 S3 4.2
No Photo
Available
Astragalus tener
var. tener
alkali milkvetchFabaceae annual herb Mar-Jun None None G2T1 S1 1B.2 No Photo
Available
Calamagrostis
ophitidis
serpentine reed
grass
Poaceae perennial herb Apr-Jul None None G3 S3 4.3
No Photo
Available
Calochortus
tiburonensis
Tiburon
mariposa-lily
Liliaceae perennial
bulbiferous herb
Mar-Jun FT CT G1 S1 1B.1
No Photo
Available
Calochortus
umbellatus
Oakland startulipLiliaceae perennial
bulbiferous herb
Mar-May None None G3? S3? 4.2
No Photo
Available
Calystegia
purpurata ssp.
saxicola
coastal bluff
morning-glory
Convolvulaceae perennial herb (Mar)AprSepNone None G4T2T3 S2S3 1B.2 No Photo
Available
Castilleja affinis
var. neglecta
Tiburon
paintbrush
Orobanchaceae perennial herb
(hemiparasitic)
Apr-Jun FE CT G4G5T1T2 S1S2 1B.2
No Photo
1402 A il bl
6/14/22, 3:26 PM CNPS Rare Plant Inventory | Search Results https://rareplants.cnps.org/Search/result?frm=T&sl=1&quad=3712284:3712283:3812214:3812213: 2/5 Available
Castilleja ambigua
var. ambigua
johnny-nip Orobanchaceae annual herb
(hemiparasitic)
Mar-Aug None None G4T4 S3S4 4.2
©2011 Dylan
Neubauer
Chloropyron
maritimum ssp.
palustre
Point Reyes
salty bird'sbeak
Orobanchaceae annual herb
(hemiparasitic)
Jun-Oct None None G4?T2 S2 1B.2
©2017 John
Doyen
Chloropyron molle
ssp. molle
soft salty
bird's-beak
Orobanchaceae annual herb
(hemiparasitic)
Jun-Nov FE CR G2T1 S1 1B.2
No Photo
Available
Collomia
diversifolia
serpentine
collomia
Polemoniaceae annual herb May-Jun None None G4 S4 4.3
©2019 Zoya
Akulova
Dirca occidentalis western
leatherwood
Thymelaeaceae perennial
deciduous
shrub
JanMar(Apr)None None G2 S2 1B.2
© 2017
Steve
Matson
Eleocharis parvula small
spikerush
Cyperaceae perennial herb (Apr)JunAug(Sep)None None G5 S3 4.3 ©2018 Ron
Vanderhoff
Eriogonum
luteolum var.
caninum
Tiburon
buckwheat
Polygonaceae annual herb May-Sep None None G5T2 S2 1B.2 No Photo
Available
Erythranthe
laciniata
cut-leaved
monkeyflower
Phrymaceae annual herb Apr-Jul None None G4 S4 4.3
© 2017
Steven Perry
Erythranthe
nudata
bare
monkeyflower
Phrymaceae annual herb May-Jun None None G4 S4 4.3
John Doyen
2015
Fritillaria liliacea fragrant
fritillary
Liliaceae perennial
bulbiferous herb
Feb-Apr None None G2 S2 1B.2
© 2004
Carol W.

Witham
Helianthella
castanea
Diablo
helianthella
Asteraceae perennial herb Mar-Jun None None G2 S2 1B.2
1403
6/14/22, 3:26 PM CNPS Rare Plant Inventory | Search Results https://rareplants.cnps.org/Search/result?frm=T&sl=1&quad=3712284:3712283:3812214:3812213: 3/5 © 2013
Christopher
Bronny
Hesperolinon
congestum
Marin western
flax
Linaceae annual herb Apr-Jul FT CT G1 S1 1B.1
© 2009 Neal
Kramer
Hoita strobilina Loma Prieta
hoita
Fabaceae perennial herb MayJul(AugOct)None None G2? S2? 1B.1 © 2004
Janell
Hillman
Holocarpha
macradenia
Santa Cruz
tarplant
Asteraceae annual herb Jun-Oct FT CE G1 S1 1B.1
© 2011
Dylan
Neubauer
Iris longipetala coast iris Iridaceae perennial
rhizomatous
herb
MarMay(Jun)None None G3 S3 4.2
© 2014
Aaron
Schusteff
Isocoma arguta Carquinez
goldenbush
Asteraceae perennial shrub Aug-Dec None None G1 S1 1B.1 No Photo
Available
Lathyrus jepsonii
var. jepsonii
Delta tule pea Fabaceae perennial herb MayJul(AugSep)None None G5T2 S2 1B.2 © 2003 Mark
Fogiel
Leptosiphon
acicularis
bristly
leptosiphon
Polemoniaceae annual herb Apr-Jul None None G4? S4? 4.2 © 2007 Len
Blumin
Leptosiphon
grandiflorus
large-flowered
leptosiphon
Polemoniaceae annual herb Apr-Aug None None G3G4 S3S4 4.2 © 2003
Doreen L.

Smith
Lessingia
hololeuca
woolly-headed
lessingia
Asteraceae annual herb Jun-Oct None None G2G3 S2S3 3
© 2015
Aaron
Schusteff
Lilaeopsis
masonii
Mason's
lilaeopsis
Apiaceae perennial
rhizomatous
Apr-Nov None CR G2 S2 1B.1
No Photo
1404
6/14/22, 3:26 PM CNPS Rare Plant Inventory | Search Results https://rareplants.cnps.org/Search/result?frm=T&sl=1&quad=3712284:3712283:3812214:3812213: 4/5 herb Available
Pentachaeta
bellidiflora
white-rayed
pentachaeta
Asteraceae annual herb Mar-May FE CE G1 S1 1B.1
No Photo
Available
Piperia michaelii Michael's rein
orchid
Orchidaceae perennial herb Apr-Aug None None G3 S3 4.2
No Photo
Available
Plagiobothrys
glaber
hairless
popcornflower
Boraginaceae annual herb Mar-May None None GX SX 1A
No Photo
Available
Polygonum
marinense
Marin
knotweed
Polygonaceae annual herb (Apr)MayAug(Oct)None None G2Q S2 3.1 No Photo
Available
Ranunculus lobbii Lobb's aquatic
buttercup
Ranunculaceae annual herb
(aquatic)
Feb-May None None G4 S3 4.2
No Photo
Available
Senecio
aphanactis
chaparral
ragwort
Asteraceae annual herb JanApr(May)None None G3 S2 2B.2 No Photo
Available
Spergularia
macrotheca var.
longistyla
long-styled
sand-spurrey
Caryophyllaceae perennial herb Feb-May None None G5T2 S2 1B.2 No Photo
Available
Streptanthus
glandulosus ssp.
niger
Tiburon
jewelflower
Brassicaceae annual herb May-Jun FE CE G4T1 S1 1B.1
No Photo
Available
Suaeda
californica
California
seablite
Chenopodiaceae perennial
evergreen shrub
Jul-Oct FE None G1 S1 1B.1
No Photo
Available
Symphyotrichum
lentum
Suisun Marsh
aster
Asteraceae perennial
rhizomatous
herb
(Apr)MayNovNone None G2 S2 1B.2
No Photo
Available
Trifolium
amoenum
two-fork clover Fabaceae annual herb Apr-Jun FE None G1 S1 1B.1 No Photo
Available
Trifolium
hydrophilum
saline clover Fabaceae annual herb Apr-Jun None None G2 S2 1B.2 No Photo
Available
Triquetrella
californica
coastal
triquetrella
Pottiaceae moss None None G2 S2 1B.2
No Photo
Available
Showing 1 to 45 of 45 entries
Suggested Citation:

California Native Plant Society, Rare Plant Program. 2022. Rare Plant Inventory (online edition, v9-01 1.5). Website https://www.rareplants.cnps.org [accessed 14 June 2022].

CONTACT US ABOUT THIS WEBSITE ABOUT CNPS CONTRIBUTORS
1405
6/14/22, 3:26 PM CNPS Rare Plant Inventory | Search Results https://rareplants.cnps.org/Search/result?frm=T&sl=1&quad=3712284:3712283:3812214:3812213: 5/5 Send questions and comments
to [email protected].

About the Inventory
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About the Rare Plant Program
CNPS Home Page
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Database
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CalPhotos
Copyright © 2010-2022 California Native Plant Society. All rights reserved. 1406
Raven SR Bioenergy Project C-1 ESA / D202100382
Initial Study October 7, 2022

APPENDIX C
Draft Mitigation Monitoring and Reporting
Program (MMRP)
1407
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1408
Raven SR Bioenergy Project C-1 ESA / D202100382
Initial Study October 7, 2022
MITIGATION MONITORING AND REPORTING PROGRAM – APPENDIX C Project Mitigation Measures
Implemented
By Monitored By
Monitoring and Reporting
Action
Monitoring
Schedule
Verification of
Compliance

4.1 Aesthetics – None Required

4.2 Agriculture and Forestry Resources – None Required

4.3 Air Quality
Mitigation Measure AQ-1: Best Management Practices.

All subsequent projects, regardless of size, shall implement the following best management practices to reduce construction impacts, particularly fugitive dust, to a less-than-significant level:
 All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day, except when not required for dust control.
 All haul trucks transporting soil, sand, or other loose material off-site shall be covered.
 All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is
prohibited.
 All vehicle speeds on unpaved roads shall be limited to 15 mph.
 All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.
 Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of
Regulations [CCR]). Clear signage shall be provided for construction workers at all access points.
 All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and
determined to be running in proper condition prior to
operation.
 Post a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust
complaints. This person shall respond and take corrective Project Applicant /
Construction
Contractor
Richmond
Building Division
and Engineering
Services
Department
Richmond Engineering Services
Department to verify inclusion of
BAAQMD BMPs in applicable
construction plans and specifications.

City of Richmond Building Division to
inspect site during construction to
ensure compliance with Project
construction plans.

Prior to issuance of
building permit.

Field inspections
during construction.

Verified by:

Date:
1409
Mitigation Monitoring and Reporting Program – APPENDIX C Raven SR Bioenergy Project C-2 ESA / D202100382
Initial Study October 7, 2022
Project Mitigation Measures
Implemented
By Monitored By
Monitoring and Reporting
Action
Monitoring
Schedule
Verification of
Compliance
action within 48 hours. The Air District’s phone number shall also be visible to ensure compliance with applicable
regulations.

4.4 Biological Resources
Mitigation Measure BIO-1: Avoid and Minimize Impacts to Nesting Birds, Except Rails.

Prior to any site
alterations or
issuance of building
permit.

Field inspections
during construction.

Verified by:

Date:

If nesting birds and raptors do not occur within 250 and 500 feet of the Project area, respectively, then no further action is required if construction begins within 14 calendar days.

If active nests are located during the pre-construction bird nesting surveys, no-disturbance buffer zones shall be established around nests, with a buffer size established by the qualified biologist.

Typically, these buffer distances are between 50 feet and 250 feet for passerines and between 150 feet and 500 feet for raptors. These distances may be adjusted depending on the level of surrounding ambient activity and if an obstruction, such as a building or structure, is within line-of-sight between the nest and construction. Reduced buffers may be allowed if a full-time qualified biologist is present to monitor the nest and has authority to halt construction if bird behavior indicates continued activities could lead to nest failure. Buffered zones shall be avoided during construction-related activities until young have fledged or the nest is otherwise abandoned. If active burrowing owl dens are found within the survey area, the project applicant shall implement measures at least equal to the 2012 (or subsequent applicable) CDFW Staff Report (CDFG, 2012), as determined by the qualified biologist.

Project Applicant
/ Construction
Contractor
Qualified Biologist
Richmond
Building Division
City of Richmond Building Division to
confirm surveys are conducted
pursuant to specified measures, and if
warranted, that buffer zone distances
are indicated in project plans and
adhered to during construction
activities.

City of Richmond Planning Division to
receive and confirm survey report.

Field inspections
during construction.

Upon completion of
surveys.

Verified by:

Date:
1410
Mitigation Monitoring and Reporting Program – APPENDIX C Raven SR Bioenergy Project C-3 ESA / D202100382
Initial Study October 7, 2022
Project Mitigation Measures
Implemented
By Monitored By
Monitoring and Reporting
Action
Monitoring
Schedule
Verification of
Compliance
Mitigation Measure BIO-2: Avoid and Minimize Impacts to California Black Rail and California Ridgway’s Rail
 To minimize or avoid the loss of individual California black rail and Ridgway’s rail, construction activities requiring heavy equipment, adjacent to tidal marsh areas (within 500 feet [150 meters] or a distance determined in coordination with U.S.

Fish and Wildlife (USFWS) or the California Department of Fish and Wildlife (CDFW)), shall be avoided during the
breeding season from February 1 through August 31.

Field inspections
during construction.

Verified by:

Date:
 If areas within 500 feet of rail habitat cannot be avoided during the breeding season (February 1 through August 31),
protocol-level surveys shall be conducted to determine rail nesting locations. The surveys will focus on potential habitat that could be indirectly disturbed by construction activities during the breeding season to ensure that rails are not breeding within 500 feet of project activities.
 Survey methods for rails will follow the Site-Specific Protocol for Monitoring Marsh Birds, which was developed for use by USFWS and partners (Wood et al. 2017). Surveys are
concentrated during the approximate period of peak
detectability, January 15 to March 25 and are structured to efficiently sample an area in three rounds of surveys by broadcasting calls of target species during specific periods of each survey round. Call broadcast increase the probability of detection compared to passive surveys when no call
broadcasting is employed. This protocol has since been
adopted by Invasive Spartina Project (ISP) and Point Blue Conservation Science to survey Ridgway’s rails at sites throughout San Francisco Bay Estuary. The survey protocol for Ridgway’s rail is summarized below.
 Previously used survey locations (points) should be used when available to maintain consistency with past survey results. Adjacent points should be at least 200 meters
apart along transects in or adjacent to areas
representative of the marsh. Points should be located to minimize disturbances to marsh vegetation. Up to 8
points can be located on a transect.
 At each transect, three surveys (rounds) are to be
conducted, with the first round of surveys initiated
between January 15 and February 6, the second round
performed February 7 to February 28, and the third round March 1 to March 25. Surveys should be spaced at least
one week apart and the period between March 25 to April Project Applicant
/ Construction
Contractor
Qualified Biologist
Richmond
Building Division
City of Richmond Building Division to
confirm surveys are conducted
pursuant to specified measures.

City of Richmond Planning Division to
receive and confirm survey report.

Field inspections
during construction.

Upon completion of
surveys.

Verified by:

Date:
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Mitigation Monitoring and Reporting Program – APPENDIX C Raven SR Bioenergy Project C-4 ESA / D202100382
Initial Study October 7, 2022
Project Mitigation Measures
Implemented
By Monitored By
Monitoring and Reporting
Action
Monitoring
Schedule
Verification of
Compliance
15 can be used to complete surveys delayed by logistical or weather issues. A Federal Endangered Species Act
Section 10(a)(1)(A) permit is required to conduct active surveys.
 Each point on a transect will be surveyed for 10 minutes each round. A recording of calls available from USFWS
is broadcast at each point. The recording consists of 5 minutes of silence, followed by a 30-second recording of Ridgway’s rail vocalizations, followed by 30 seconds of silence, followed by a 30-second recording of California black rail, followed by 3.5 minutes of silence.
 If no breeding Ridgway’s rails or black rails are detected during surveys, or if their breeding territories can be avoided by 500 feet (150 meters), then project activities may proceed at that location.
 If protocol surveys determine that breeding Ridgway’s rails or black rails are present in the project area, the following measures would apply to project activities conducted during their breeding season (February 1- August 31):
 The applicant shall coordinate with the USFWS- and
CDFW, as appropriate depending upon species, to
determine if project activities can continue during the nesting season based on nest location, natural visual
barriers (e.g., levees) between the project and
marshlands, and the distance between proposed
activities and identified activity centers. If impact cannot be avoided during the rail nesting season, activities
would be delayed until after the nesting season.

City of Richmond Planning Division to
verify agency coordination and
outcome.

Field inspections
during construction.

Upon completion of
surveys.

Verified by:

Date:

4.5 Cultural Resources
Mitigation Measure CUL-1a: Cultural Resources Awareness Training.

Prior to authorization to proceed, the City shall engage a qualified archaeologist, defined as an archaeologist meeting the U.S.

Prior to
commencement of
any ground-disturbing
activities.

Verified by:

Date:
1412
Mitigation Monitoring and Reporting Program – APPENDIX C Raven SR Bioenergy Project C-5 ESA / D202100382
Initial Study October 7, 2022
Project Mitigation Measures
Implemented
By Monitored By
Monitoring and Reporting
Action
Monitoring
Schedule
Verification of
Compliance
Mitigation Measure CUL-1b: Inadvertent Discovery of Cultural Materials or Tribal Cultural Resources.

Historic-era cultural materials might include building or structure footings and walls, and deposits of metal, glass, and/or ceramic refuse.

If avoidance is not feasible, the City shall consult with a qualified archaeologist and a Native American representative (if the resource is pre-contact) to determine treatment measures to avoid, minimize, or mitigate any potential impacts to the resource pursuant to PRC Section 21083.2 and CEQA Guidelines Section 15126.4. This shall include documentation of the resource and may include data recovery (according to PRC Section 21083.2), if deemed
appropriate, or other actions such as treating the resource with culturally appropriate dignity and protecting the cultural character and integrity of the resource (according to PRC Section 21084.3).

If resources are encountered,
Contractor to verify work is suspended
as required, review and approve
qualified archaeologist and
recommendations.

If resources encountered are found to
be qualifying as described in the
measure, the City to ensure
preservation measures are
implemented or that the ARDTP is
completed and submitted to NWIC.

City to inspect site during construction
to ensure compliance with project
construction plans.

Prior to issuance of
building permit for, or
commencement of,
any ground-disturbing
activities.

Field inspections
during construction.

Verified by:

Date:
1413
Mitigation Monitoring and Reporting Program – APPENDIX C Raven SR Bioenergy Project C-6 ESA / D202100382
Initial Study October 7, 2022
Project Mitigation Measures
Implemented
By Monitored By
Monitoring and Reporting
Action
Monitoring
Schedule
Verification of
Compliance
Mitigation Measure CUL-2: Inadvertent Discovery of Human Remains.

Project Applicant /
Construction
Contractor
Qualified
Archaeologist
Richmond Building Division verify
mitigation measure on construction
plans.

Inspect site during construction to
ensure compliance with project
construction plans.

If needed, engage County Coroner
and ensure NAHC contact.

Prior to issuance of a
building permit for, or
commencement of,
any ground-disturbing
activities.

Field inspections
during construction.

Verified by:

Date:

4.6 Energy – None Required

4.7 Geology, Soils, and Mineral Resources - MM CUL-1a, CUL-1b, CUL-2 (see 4.5, Cultural Resources)

4.8 Greenhouse Gas Emissions – None Required

4.9 Hazards and Hazardous Materials – None Required

4.10 Hydrology and Water Quality – None Required

4.11 Land Use and Planning – None Required

4.12 Noise / Vibration – None Required

4.13 Population and Housing– None Required

4.14 Public Services and Recreation – None Required

4.15 Transportation – None Required

4.16 Tribal Cultural Resources - MM CUL-1a, CUL-1b, CUL-2 (see 4.5, Cultural Resources)

4.17 Utilities and Service Systems – None Required

4.18 Wildfire – None Required
1414
180 Grand Avenue
Suite 1050
Oakland, CA 94612
510.839.5066 phone
510.839.5825 fax
esassoc.com
Memorandum
date November 30, 2022
to Lydia Elias, Planner I
Lina Velasco, Director
from Crescentia Brown, Project Director
Tim Sturtz, Project Manager
subject RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
Background
On October 7, 2022, the City of Richmond (Lead Agency) released for public review a Draft Initial Study (IS) and Mitigated Negative Declaration (MND) pursuant to the California Environmental Quality Act (CEQA) for the proposed Raven SR Bioenergy Project (Project) (SCH# 202201045). The original public review and comment period on the IS/MND was October 7, 2022 through November 7, 2022, and the City extended the comment period to November 22, 2022.

Although not required by CEQA, this document includes the comments received on the IS/MND (see Table 1) and responses to each comment.

TABLE 1

EXHIBIT C
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RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 2 TABLE 1 (CONTINUED)

COMMENT LETTERS RECEIVED ON THE IS/MND
Letter # Entity Author(s) of Comment Letter/e-mail Comment Date Organizations / Individual
9 Environmental Justice Groups November 22, 2022
 Communities for a
Better Environment
Connie Cho, Attorney / Tessa Wardle, Staff
Researcher
 Sierra Club Teresa Cheng, Senior Campaign Representative  Asian Pacific
Environmental Network
Faraz Rizvi, Campaign and Policy Manager
 Richmond Our Power
Coalition
Katt Ramos, Managing Director - Richmond Our
Power Coalition
 Urban Tilth Kiara Pereira, Just Transition Organizer / Rafael Castro, Just Transition Organizer
 Natural Resources
Defense Council
Ann Alexander, Senior Attorney
10 Shell Hydrogen Humberto Orantes, Acting Commercial Head, North America
November 7, 2022
11 Powers Engineers James P. Hays, Business Unit Director November 7, 2022 12 Trails for Richmond Action
Committee (TRAC) Bruce Beyaert, TRAC Chair October 27, 2022 13 Benicia Fabrication & Machine Carmelo Santiago, CEO & President October 20, 2022 14 Contra Costa Construction and
Building Trades Council William Whitney October 17, 2022 15 Watlow Ashish Bhatnagar, Chief Technology Officer October 14, 2022 16 Iron Workers Local 378 Jason Gallia, Business Manager, Financial Manager/Treasurer October 13, 2022
17 Local Union No. 302
International Brotherhood of
Electrical Workers
Tom Hansen, Business Manager, Financial
Secretary October 13, 2022
18 Green Hydrogen Coalition Nicholas Connell, Policy Director October 10, 2022 19 Not Identified Christina Strawbridge October 10, 2022 No “substantial revisions” that would require recirculation of the IS/MND are warranted. Specifically, (1) no new, avoidable significant effect is identified and mitigation measures or project revisions must be added in order to reduce the effect to insignificance, or (2) The lead agency determines that the proposed mitigation measures or project revisions will not reduce potential effects to less than significance and new measures or revisions must be required (CEQA Guidelines Section 15073.5). Although a mitigation measure (AQ-1: Best Management Practices) is expanded with equal or more effective measures pursuant to Section 15074.1, recirculation of the MND is not required. The updated Mitigation Measure Monitoring and Reporting Program (MMRP) with the expanded mitigation measure is included as Attachment A to this memo. 1416
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 3 Comments and Responses
Responses focus on comments that pertain to the adequacy of the analysis in the IS/MND or to other aspects pertinent to the potential effects of the proposed Project on the environment pursuant to CEQA. Comments that address topics beyond the purview of the IS/MND or CEQA or that state opinions about the overall merit of the proposed Project are acknowledged for the public record and will be taken into account by City decision-makers.

The following pages present each comment letter with each individual comment bracketed with a numeric code, followed by the corresponding response to each individual comment. 1417
1-1 1-2 1-3 1-4 LETTER 1
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1-5 1-61-7
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RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 6 Responses to Letter 1 - Contra Costa Environmental Health 1-1 The comment specifies that the project must obtain a permit from Contra Costa Environmental Health (CCEH) for any well or soil boring prior to commencing drilling activities. The project applicant acknowledges this requirement and shall comply.
1-2 The comment recommends that the project be served by public sewer and public water. As specified in Section 4.17, Utilities and Service Systems, of the IS/MND, the proposed project will continue to be served by EBMUD and West County Wastewater District, which already serves the site. 1-3 The comment specifies application information that the project applicant/operator must obtain from CCEH as the Local Enforcement Agency (LEA) relevant to the proposed project facility and operation.

Condition No. 19.3 - Odor Containment. During the construction phase of the Project, the operational Odor Prevention and Management Plan (OPMP) shall be developed and implemented upon commissioning of the renewable fuels processes, intended to become an integrated part of daily operations at the Facility and other sites, so as to prevent any objectionable offsite odors and effect diligent identification and remediation of any potential objectionable odors generated by the facility and associated sites. The plan shall outline equipment that is in place and procedures that facility personnel shall use to address odor issues, facility wide. The OPMP shall include continuous evaluation of the overall system performance, identification of trends to provide an opportunity for improvements to the plan, and updating the odor prevention and management strategies, as necessary. This plan shall be retained at the facility for City or any other government agency inspection upon request. The following practices shall be included in the OPMP to reduce the potential of objectionable odors from the storage of renewable feedstocks, operation of the Facility, and any other odor generating activity:
1420
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 7 • Develop operating procedures to inspect and evaluate the effectiveness of odor control equipment and operation of the wastewater treatment plant. • The OPMP shall include guidance for the proactive identification and documentation of odors through routine employee observations, routine operational inspections, and odor compliant investigations.
• Inspections to be conducted on a semi-annual basis.
• If there are fewer than an average of five confirmed complaints per year during the first 3 years of operation, then the inspection frequency can be reduced to an annual basis. • If there are more than five confirmed complaints in any single year, then the application shall develop additional mitigation strategies in consultation with the BAAQMD. • All odor complaints received by the facility shall be investigated as soon as is practical within the confines of proper safety protocols and site logistics. The goal of the investigation will be to determine if an odor originates from the facility and, if so, to determine the specific source and cause of the odor, and then to remediate the odor. • Prepare an annual evaluation report of the overall system performance, identifying any trends to provide an opportunity for improvements to the plan, and updates to the odor management and control strategies, as necessary. The report shall be provided to the City for review and approval.

Also see Response to Comment 9-5 regarding the related environmental impacts of odor. 1-5 In response to the comments statement regarding medical waste as one of the types of organic feedstocks, the project applicant has clarified, as limited by project Condition No. 8.1 regarding eligible feedstocks, that the project shall be prohibited from intentionally accepting industrial or medical waste in the eligible feedstock. The IS/MND is updated as shown below.
 2.4 Technology (p. 17)
Organic feedstocks include biomass, municipal solid waste, bio-solids, industrial waste, sewage, medical waste, or a combination of these, obtained from the existing WCCSL. 1-6 The comment seeks to ensure the project is compliant with the Post Closure Maintenance Plans of the landfills. Project Condition No. 4.5 specifically requires that the project operations shall be consistent with, and shall not conflict with, the Closure/Post Closure Maintenance Plan required by CalRecycle, the SFRWQCB, and the LEA for the existing WCCSL.
1-7 The comment addresses the treatment of hazardous construction and demolition materials, the required management of debris from construction or demolition activity, and states that non-source-separated waste materials must not be brought back to the contractor's yard unless the facility has the appropriate solid waste permit or EA Notification. Each of these requirements are part of standard local, State and federal regulatory requirements and project conditions pertaining to solid waste, water/ stormwater resources, and hazardous site conditions. The project applicant acknowledges this requirement and shall comply.
________________________
1421
2-1 LETTER 2
1422
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 9 Responses to Letter 2 – Berkeley Lab
2-1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment also opines that the proposed Project’s non-combustion system would reduce methane and short-lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision-makers as they consider the Project and whether or not to approve it.
________________________
1423
1001 I Street, Sacramento, CA 95814 | P.O. Box 4025, Sacramento, CA 95812 www.CalRecycle.ca.gov | (916) 322-4027
California Environmental Protection Agency
Department of
Resources Recycling and Recovery
Gavin Newsom
California Governor
Amelia Yana Garcia Gonzalez
Secretary for Environmental Protection
Rachel Machi Wagoner
CalRecycle Director
November 7, 2022
Lydia Elias, Planner I
City of Richmond Planning and Building Services Department 450 Civic Center Plaza
Richmond, CA 94804
[email protected]
Subject: SCH No. 2022100145 – Raven SR Bioenergy Project Mitigated Negative Declaration – Contra Costa County
Dear Lydia Elias,
Thank you for allowing the Department of Resources Recycling and Recovery (CalRecycle) staff to provide comments on the proposed project and for your agency’s consideration of these comments as part of the California Environmental Quality Act (CEQA) process.

The proposed project would add a bioenergy system at the site. The non-combustion process would convert blended green waste and food waste, obtained from the existing LETTER 3
1424
1001 I Street, Sacramento, CA 95814 | P.O. Box 4025, Sacramento, CA 95812 www.CalRecycle.ca.gov | (916) 322-4027
BMPC operation adjacent to the project site, into renewable, transportation grade hydrogen that would be exported offsite for various renewable energy products. No long-term hydrogen storage would occur onsite. The project would involve the erection of a modular structure and industrial canopy.

Comments for the Draft IS/MND are summarized below:

2. Project Description, Odor Control, PDF Page 23 – “Nuisance odor from Raven is unlikely since feedstock material would only be on the feedstock management area floor for relatively short periods of time.” The applicant should clarify how long the material will be stored in the storage bunkers or other designated material storage areas prior to being placed in the Raven SR’s Reformation Technology system? Given the putrescible nature of the incoming feedstock, what methods will the applicant utilize to control or prevent the propagation, 3-1
3-2
CONT.
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1001 I Street, Sacramento, CA 95814 | P.O. Box 4025, Sacramento, CA 95812 www.CalRecycle.ca.gov | (916) 322-4027
harborage and attraction of flies, rodents, or other vectors, and animals, and to minimize bird attraction.? Per Title 14 CCR Section 17410.1(a)(2) “facilities shall remove solid waste accepted at the site within 48 hours from the time of receipt.” Solid Waste Regulatory Oversight
Contra Costa Health Services is the Local Enforcement Agency (LEA) for Contra Costa County and responsible for providing regulatory oversight of solid waste handling activities, including inspections. Please contact Tim Kraus, the LEA, at 925.608.5549 to discuss the regulatory requirements for the proposed project.

Richmond City CouncilMay 16, 2023

Richmond City Council
May 16, 2023