Richmond City Council
May 16, 2023

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. 1427
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
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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
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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
CONT.
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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.
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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.

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.
 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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8-1
CONT. LETTER 8
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CONT.
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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
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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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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 1447
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.
________________________
1448
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
1449
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.
1450
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.
________________________
1451
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
1452
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.
________________________
1453
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
1454

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 1455
1456
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. ________________________
1457
101 East Channel Rd
BeniCta Benicia,CA 94510
Fabrication phone (70T> 745-8i1 {
&Machine" Fa"(707)J45:810L
www.beniciafab.com
10/20/2022
Lydia Ellas
City of RichmondCommunity Development Department
450 Civic Center Plaza, PO Box 4046Richmond, CA 94804Dear Lydia,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 ofabioenergy 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 m 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 13 83's goal of reducing organic waste disposal by 75% from2014 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. Ravenhas signed a Project Labor Agreement with the Contra Costa Building & Construction Trades Council andthe 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, andreversing climate change in the East Bay region.

Thank you for your consideration and we respectfully request you approve Raven SR's CUP applicationand the CEQA MND so they may begin construction this year and start production in early 2023. /Carmeld Santiago
CEO & President
Benicia Fabrication & Machine, Inc.
13-1 LETTER 13-1
1458
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.
________________________
1459
14-1 LETTER 14
1460
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.
________________________
1461
^WATLOW
October 14, 2022
Lydia Elias
City of RichmondCommunity Development Department
450 Civic Center Plaza, PO Box 4046Richmond, CA 94804Dear 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-hydrogenproduction, 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 theu- 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,
^ybL St^i •i^z^^C^-<-^
Dr. Ashish Bhatnagar
Chief Technology Officer
Watlow
12001 Lackland Road • St. Louis, Missouri 63146 USA
Phone: 314-878-4600 * www.watlow.com
LETTER 1515-1
1462
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.
________________________
1463
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
1464
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.
________________________
1465
Local Union No. 302
INTERNATIONAL BROTHERHOOD ©OF ELECTRICAL TOKERS
REGULAR MEETING 4T^, '/.'EDS EACH MONTH °-T:'~; EXECUTIVE BOARD MEETS 3RD WEDS EACH MONTH 1875 ARNOLD DRIVE • MARTINEZ, CALIFORNIA 94553-4239
TELEPHONE (925) 228-2302 • FAX (925) 228-0764
October 13, 2022
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804Dear Ms. Etias,
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.

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 passengerhydrogen 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 ourcommunity. 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, apprenticeshiptraining, 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 as2023.

Y^vw
Tom Hansen
Business ManagerFinancial Secretary
TH:nlp
OPEIU#29:afl-cio
LETTER 1717-1
1466
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.
________________________
1467
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
1468
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.
________________________
1469
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
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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.
________________________
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APP - A

ATTACHMENT A
Final Mitigation Monitoring and Reporting
Program (MMRP) (Update to IS/MND Appendix C)
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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:
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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
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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.

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.

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:
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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.

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.

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.

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:
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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.

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:

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:
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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.

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.

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 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:
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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.

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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ATTACHMENT 1
PROPOSED RESOLUTION NO. 22-18

A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF

RICHMOND, ADOPTING AN MITIGATED NEVATIVE DECLARATION AND MITIGATION MONITORING AND REPORTING PROGRAM; AND APPROVING

CONDITIONAL USE AND DESIGN REVIEW PERMITS FOR THE RAVEN BIOENERGY PROJECT (PLN21-282).

WHEREAS, on July 30, 2021, Raven SR, LLC (“applicant” or “permittee”), filed Planning Application No. PLN21-282, requesting approval of design review and conditional use permits for the proposed Raven Bioenergy Project (“project”) to be located at 1 Parr Boulevard in the OS (Open Space) District, Assessor’s Parcel No. 408-140-009 (“project site”); and
WHEREAS, the project involves the construction and operation of a bioenergy facility that would convert food and green waste into transportationgrade hydrogen; and WHEREAS, the project is governed by the Richmond General Plan and Richmond Municipal Code (“RMC”); and
WHEREAS, the Project is subject to the California Environmental Quality Act (“CEQA”) (Public Resources Code 21000-21189) and the State CEQA Guidelines (California Code of Regulations, Title 14, Division 6, Chapter 3, Sections 15000-15387); and
WHEREAS, the City, as the lead agency under CEQA, prepared an environmental initial study for the project; and
WHEREAS, based on the analysis in the initial study, the Community Development Director determined that the potentially significant effects of the project could be reduced to a less-than-significant level through implementation of specific mitigation measures, and subsequently, a mitigated negative declaration was prepared; and
WHEREAS, on November 7, 2022, a notice of intent to adopt a mitigated negative declaration (“NOI”) was distributed for 30-day public review and comment period, in accordance with CEQA Guidelines Section 15072 and 15105; and
WHEREAS, on December 7, 2022, the public review and comment period for the mitigated negative declaration was extended for an additional 15 days to allow interested parties more time to review the document; and 1483
Res. No. 22-18

WHEREAS, on or prior to December 2, 2022, notice of the December 15, 2022 public hearing was given in accordance with RMC Section 15.04.803.070 (Public Notice) and applicable State law; and
WHEREAS, on December 15, 2022, the Planning Commission considered the mitigated negative declaration (State Clearinghouse #2022100145) and held a public hearing on the project, at which time oral and/or written testimony was considered; and
WHEREAS, the record of proceedings (“Record”) upon which the Planning Commission bases its decision regarding the Project includes, but is not limited to: (1) all staff reports, City files and records and other documents prepared for and/or submitted to the Planning Commission, and the City relating to the project; (2) the evidence, facts, findings and other determinations set forth in this resolution; (3) the City of Richmond General Plan and the RMC; (4) all applications, designs, plans, studies, data and correspondence submitted by the applicant in connection with the project; (5) all documentary and oral evidence received at public hearings or submitted to the City relating to the project; and (6) all other matters of common knowledge to the Planning Commission including, but not limited to, City, state and federal laws, policies, rules regulations, reports, records and projections related to development within the City and its surrounding areas.

NOW, THEREFORE, the Planning Commission resolves and finds as follows:

Mitigated Negative Declaration Findings:

1. Prior to acting on the project, the Planning Commission has considered the mitigated negative declaration together with any comments received during the public review process.

2. There is no substantial evidence that the project will have a significant effect on the environment.

3. The mitigated negative declaration reflects the City of Richmond’s independent judgement and analysis.

Conditional Use Permit Findings and Statements of Fact:

4. The location of the proposed conditional use is in accordance with the General Plan and any specific plan and land use designations for the project site.

Statement of Fact: The project site is not located in any specific plan area. The General Plan land use designation for the project site is 1484
Res. No. 22-18

“Open Space”. According to the General Plan, this designation is intended to include wetlands, mudflats, creek corridors and other natural preservation areas, as well as private lands used for recreational purposes or deed-restricted for open space preservation, and utilities. The proposed use falls under the classification of “Utilities, Major” and is therefore consistent with the General Plan land use designation. RMC Section 15.04.104.020 defines “Utilities, Major” as generating plants, electric substations, and solid waste collection, including transfer stations and materials recovery facilities, solid waste treatment and disposal, water or wastewater treatment plants, biomass and waste to energy conversion facilities, and similar facilities of private companies, public agencies or public utilities.

5. The location, size, design and operating characteristics of the proposed use will be compatible with and will not adversely affect the livability or appropriate development of adjacent properties and the surrounding neighborhood.

Statement of Fact: The project site is in a non-residential area that is dominated by industrial uses with similar operating characteristics, including the West County Wastewater District Treatment Plant, EBMUD’s North Richmond Water Reclamation Plant, the Richmond Sanitary District, and other refuse services.

6. The proposed use will not create any nuisances arising from the emission of odor, dust, gas, noise, vibration, smoke heat or glare at a level exceeding ambient conditions.

Statement of Fact: The project is required to comply with RMC Articles

15.04.604 (Lighting and Illumination), 15.04.605 (Noise), and

15.04.608 (Performance Standards). These articles prescribe standards and limitations designed to avoid potential nuisances from glare, noise, odors, particulate matter, air contaminants, and vibration.

The mitigated negative declaration also identifies measures that the project will implement to mitigate the project’s potential air quality impacts.

7. The proposed use complies with all applicable provisions of Article XV.

Statement of Fact: The proposed use falls under the classification of “Utilities, Major” and this classification is permitted in the OS (Open Space) District after review and approval of a conditional use permit by the Planning Commission. RMC Section 15.04.206.040 (Development Standards) prescribes development standards for the OS District and the project meets these standards which include minimum and maximum height, setbacks, and floor area ratio. The project also 1485
Res. No. 22-18

complies with RMC Article 15.04.805 (Design Review), which requires Major Design Review for industrial additions or improvements over 1,000 square feet. On October 26, 2022, the Design Review Board considered the project and recommended the Planning Commission grant design review approval, subject to conditions of approval.

8. The site of the proposed use is adequately served by highways, streets, water, sewer and other public facilities and services.

Statement of Fact: The project site is in an area adequately served by existing public infrastructure, streets, and highways such as Richmond Parkway and Interstates 80 and 580. In addition, there is adequate capacity in nearby public facilities and services to serve the project site.

Design Review Permit Findings:

9. The project is consistent with General Plan and any applicable specific plans;
Statement of Fact: The project site is not located in any specific plan area. The General Plan land use designation for the project site is “Open Space”. According to the General Plan, this designation is intended to include wetlands, mudflats, creek corridors and other natural preservation areas, as well as private lands used for recreational purposes or deed-restricted for open space preservation, and utilities. The proposed use falls under the classification of “Utilities, Major” and is therefore consistent with the General Plan land use designation. RMC Section 15.04.104.020 defines “Utilities, Major” as generating plants, electric substations, and solid waste collection, including transfer stations and materials recovery facilities, solid waste treatment and disposal, water or wastewater treatment plants, biomass and waste to energy conversion facilities, and similar facilities of private companies, public agencies or public utilities. The project will advance several General Plan policies, including EC2.2 (ClimateFriendly Fuel) which calls for supporting the production and distribution of climate-friendlier fuel at appropriate locations; and EC5.1 (Green Businesses and Jobs), which calls for promoting green industries, including those that fill the growing need for clean fuels.

10. The project is consistent with any applicable design guidelines; Statement of Fact: There are no design guidelines in place for the area in which the project is located; however, the Design Review Board considered the project on October 26, 2022, and recommended the Planning Commission grant design review approval, subject to 1486
Res. No. 22-18

conditions of approval.

11. The project is consistent with any approved tentative map, use permit, variance, or other planning or zoning approval that the project required; Statement of Fact: The design review and conditional use permit for the project have been reviewed concurrently to ensure consistency between the approvals. No tentative map, variance, or other planning or zoning approval are being requested.

12. The project is consistent with the design review criteria in Section

15.04.805.04:
a. The overall design of the project, including its scale, massing, site plan, exterior design, and landscaping, reflects design integrity and the relationship of form and function in a coherent manner.
b. The project design evidences a sense of place and
consideration of scale, mass, height, building siting, an privacy in a neighborhood and community context; does not overwhelm or adversely impact adjoining properties; and respects
prevailing setbacks and the scale and heights of neighboring buildings and how they relate to the street.
c. The project’s design elements, materials, signage, and landscaping are internally consistent, fully integrated with one another, and applied in a manner that is visually consistent with the proposed architectural design.
d. Lighting and lighting fixtures are designed to complement buildings, be of appropriate scale, provide adequate light over walkways and parking areas to create a sense of pedestrian safety, and avoid creating glare.
e. The proposed building design and landscaping supports public safety and security by allowing for surveillance of the street by people inside buildings and elsewhere on the site.
f. Landscaping is designed to be compatible with and enhance the architectural character of the buildings on site. Proposed planting materials avoid conflicts with views, lighting, and signage.

Statement of Fact: The project will meet design criteria a through f. The project will achieve a design that will be compatible with the surrounding 1487
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uses in the area. The project buildings will be low in height to reduce impacts on views and are within the existing WCCSL property. The project includes landscaping improvements offsite to the Landfill Loop Trail and the trail head parking lot. Conditions of approval will ensure any new lighting and lighting fixtures are designed to avoid creating glare.

NOW, BE IT FURTHER RESOLVED that based on the findings set forth herein and the Record as a whole, the Planning Commission hereby adopts the mitigated negative declaration (Exhibit B) and mitigation monitoring and reporting program (Exhibit C); and approves the design review and conditional use permit for Planning Application No. PLN21-282, subject to the following conditions of approval:

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 1488
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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 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).
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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 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.
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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 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 1491
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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 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 expiration of the appeal period for the Commission’s approval (10 days after Commission approval).

27. Design Review Expiration: Design Review approval shall expire two years from the date of final approval, 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 1492
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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.

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 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 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, facility shall divert material from the site in accordance with its operating permits.
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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.

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 1494
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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 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 1495
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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 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.

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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 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.
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f. The permittee shall obtain power for all operations aside from vehicles via either combustion of landfill gas or the pre-existing 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, and emergency back-up power for fire pump) through any type of petroleum-based product. g. Permittee shall make best efforts to hire employees, workers, and subcontractor components for jobs from the North Richmond community.
h. The flare for the facility shall be fully hooded and any burning shall not be visible at any time.

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 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. 1498
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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 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.

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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 Emission Vehicles: The property owner/tenant/lessee shall make all reasonable efforts to procure zero emission vehicles/trucks. In the event that there is a disruption in the manufacturing of zero emission vehicles/trucks or that sufficient vehicles/trucks are not commercially available for the intended application, the “clean fleet requirements” may be adjusted as 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 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, the following:
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.

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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 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.
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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 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 1502
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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.
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 1503
Res. No. 22-18

shall make whatever installations or operations changes that the BAAQMD may specify.

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 Equipment: 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.
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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. Hooded Flare: The flare shall be hooded, unless otherwise approved by BAAQMD.

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

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

93. Indemnification: The permittee agrees, on behalf of himself, his 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 "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 1505
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set forth above, the City shall retain the right to select the counsel who shall defend the City.

I certify that the foregoing Resolution was adopted by the Planning Commission of the City of Richmond at a meeting held on December 15, 2022, by the following vote:

Ayes: Chair Tucker, Vice-Chair Harrison, Secretary Brubaker, Commissioner Soofiani
Noes: None.

Absent: Commissioner Loy, Commissioner Agarwal
Abstain: None
DAVID TUCKERPlanning Commission Chair
Approved as to Form:

JAM^WNCIOSenior Assistant City Attorney

David A Tucker 1506
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1 March 21, 2023
Lina Velasco
Community Development Director
City of Richmond
Re: Raven SR Bioenergy Project (PLN21-282)
Dear Lina:

Thank you for advising Raven SR regarding the status of our application for the Raven SR Bioenergy Project (PLN21-282) (Raven Project) and confirming that the 90-day continuance was granted to address the comments raised in the appeal of the Raven Project Conditional Use Permit (CUP) and the October 7, 2022 Initial Study/ Mitigated Negative Declaration (October IS/MND). We received notice on March 9, 2023 that the City released the Raven Project Updated IS/MND for public review and comment. We understand that the new hearing date is tentatively scheduled for the May 2, 2023 City Council meeting.

You asked that we provide the following documents for the City’s consideration regarding the Raven Project:
 Raven’s response to the Appeal of the City Planning Commission Decision to Adopt Initial Study/Mitigated Negative Declaration (IS/MND) for the Raven SR Bioenergy Project (PLN21-282) filed by Communities for a Better Environment (CBE) and Natural Resources Defense Council (NRDC) on December 19, 2022 (Appeal); and  A Health Risk Assessment (HRA) for review by the City’s CEQA consultant, ESA.

In reviewing the Appeal, it occurred to us that there may be some confusion about the proposed Raven Project and the information contained in the October 2022 draft IS/MND. The Raven SR team prepared responses to the questions raised in the Appeal in order to address CBE and NRDC’s comments and concerns in a more robust manner. We agree with CBE and NRDC that the IS/MND would benefit from further clarifications and amplifications regarding the project description, as well as the available technical information and analyses. Much of this information was already generated as part of our air permit application, so we asked our consultants to compile this information for the City’s use.

With this in mind, we have enclosed following updated description for the Raven Project that includes further details about the operational aspects of the Raven SR technology (see Attachment A). The updated project description also includes information Raven has compiled as part of its permitting process that describes safety protocols, standards and management plans in response to the Appeal. Based on the updated project description information and technical analyses our technical team completed, we also prepared a redlined version of the October 2022 1526
2 Draft IS/MND for the Planning Department and ESA’s use to identify the corresponding sections of the IS/MND that the Raven team believed would benefit from further clarification and the updated project information. We submitted the redlined version of the Draft IS/MND on February 22, 2023 reflecting our changes to correspond to the clarifications contained in the attached updated project description. Additionally, the updated project description and the information we submitted to the City on February 22, 2023 answers some of CBE and NRDC’s questions about the Raven Project.

We appreciate CBE and NRDC bringing their concerns to the City’s attention. Raven is committed to sharing information about its Project in a transparent manner and believes that the proposed Raven SR technology will result in environmental and economic benefits for the Richmond community, while supporting the State’s efforts to increase the production of lowcarbon fuels. Raven SR looks forward to working many years in the City of Richmond, reducing waste and providing clean fuels for the region, and wants to be a good neighbor to the residents of the community.

Thank you for your consideration.

Regards,
Mike Fatigati
Raven SR
Chief Technology Officer
cc: Lydia Elias
Shannon Chaffin
Matt Murdock
John Scanlon
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1 Raven SR Responses to Appeal
Raven SR reviewed CBE and NRDC’s Appeal filed against the City of Richmond (City) Planning Commission’s approval of the Raven One Project. The Raven One Project proposes to convert a blend of urban green waste and organic food waste into hydrogen. CBE and NRDC expressed their concerns about the City’s analysis of the Raven One Project and noted that the City’s analysis in the initial study (IS)/mitigated negative declaration (MND) is governed by the “fair argument” standard. We acknowledge that the fair argument standard applies to a lead agency’s preparation and adoption of an IS/MND. Raven SR believes that the additional clarifying information about our project included with this submittal will assist in informing the City’s further review of the Raven One Project and allay the concerns of the Appellants.

Before addressing CBE and NRDC’s Appeal, first we would like to provide some background about Raven SR’s technology and provide clarifying information about our Project. Following this discussion, we have prepared a guide for the City staff and decisionmakers, and the Appellants to use to find answers to their questions in the Updated IS /MND and the technical appendices. We also have provided some updated information in response to the outdated data used by the Appellants in their Appeal.

Raven One Project Objectives
Raven SR believes its Project is aligned with California’s goals for a transition to a hydrogen fuel infrastructure. Our Project results in the production of hydrogen from waste materials with lower power demand and lower demand of fresh water when compared to other, more traditional means of producing hydrogen, and it does so at a negative carbon intensity (CI) score. A transition from fossil fuels to renewable hydrogen fuel will greatly reduce GHG impacts, and reduce air pollution in the nearby community. The benefits that will accrue to the community that hosts the Project include reduced air pollution from reduced flaring of LFG, from displacement of fossil-fueled heavy-duty trucks, and from avoided landfill emissions.

Reduction in Pollution and Greenhouse Emissions
Landfills are the third largest source of methane in both California and the US. California Senate Bill (SB) 1383 requires 75 percent of all organic waste to be diverted from landfills by 2025.

Diversion of organic waste by the Raven One process will eliminate up to 34,000 metric tons of mixed green and food waste from the WCCSL landfill each year. This will also potentially avoid emissions of 7,200 metric tons of methane per year from organic waste in the landfill. The hydrogen that Raven will produce also will displace diesel truck engines that are major producers of toxic emissions and particulates, not to mention light-duty vehicles. For example, if Raven produces 2,342,000 kgs of H2 and 50% is for heavy-duty vehicles and 50% is light-duty vehicles, then the avoided emissions from vehicles alone represents a significant reduction. 1528
2 Importantly, Raven will also replace highly polluting generation sets and flaring that today, contribute to significant pollution in the Richmond area.

And all of this locally produced and regionally used.

Hydrogen
The use of low-carbon hydrogen is a cornerstone of California’s transition away from fossil fuels. Nearly all of the hydrogen currently produced and used in California is manufactured from fossil fuels. The Raven One Project is designed to produce hydrogen from the conversion of green waste and food waste obtained from the co-located WCCSL, using technology that will use demonstrably less electricity per mass unit of hydrogen produced than electrolysis, and with a lower carbon footprint. No other biofuel, liquid or gaseous, will be produced at the Richmond Project site. The renewable hydrogen will initially be used as transportation fuel for light-, medium-, and heavy-duty vehicles powered by fuel cells. Other potential uses of low-carbon hydrogen include replacements for fossil-based natural gas and the manufacturing of green electro fuels, all designed to reduce California’s carbon footprint.

Hydrogen fuel cell electric vehicles (FCEVs) are an enabling technology required for (1) achieving Governor Newsom’s target of 5 million zero-emission vehicles on the road in California by 2030; (2) meeting environmental goals directed toward removing the emissions of carbon and criteria pollutants from the transportation sector; (3) retaining the range, fueling time, and scalability (for example, light-, medium-, and heavy-duty vehicles) to which the public is accustomed; and (4) succeeding in achieving fuel independence.

To keep pace with the expanding FCEV population and fueling capacity, the supply of renewable hydrogen must expand rapidly. The renewable hydrogen market in California is still in the early stages of development. No fully dedicated renewable hydrogen production plants are operating anywhere in the state. Reformed biomethane from anaerobic digestions using existing steam methane reformation (SMR) capacity is the dominant supply approach.

Raven’s hydrogen production process has several advantages over other methods such as SMR and even over other green methods, such as electrolysis. First, it uses less electricity per kilogram of hydrogen than electrolysis. Second, it disposes of waste that would otherwise be a persistent environmental problem. Third, it produces hydrogen close to where it will be used.

A goal of the Raven Project is to reduce emissions from the co-located 1980’s vintage Waukesha (3 x Model 7042 GL) landfill gas generators currently located on the WCCSL site. These obsolete, aging, highly polluting generators would be removed from the site and replaced with new, low pollution Jenbacher engines (3 x JGS 420 GS-L.LC), equipped with the best available 1529
3 air emissions control technology. This replacement will contribute to improvements in air quality for the Richmond community.

California policy calling for a 80% reduction in CO2 emissions from the 1990 level by 2050 will create new demand for low to zero-carbon hydrogen and necessitate a shift in current demand from fossil-derived hydrogen to low-carbon hydrogen. Hydrogen transportation fuel produced from biomass such as green waste and food waste, in the case of Raven SR’s Project, is a low-carbon fuel from renewable feedstock. Diversion of this organic waste will help fulfill the legislative mandates of California Senate Bill 1383 to significantly reduce short-lived climate pollutants such as methane by converting methane producing organic wastes to hydrogen.

With this background in mind, the following addresses the specific issues raised in the Appeal.

References in the headings below to sections refer to the corresponding sections identified in the Appeal. Our responses to the comments in the Appeal refer to specific page numbers and section references from the March 9, 2022, Updated IS/MND.

Section III.A.i. Significant Information Regarding Air Quality is Missing From The Record, Which the City Should Review Before Issuing a CEQA Determination The Raven Project represents a first-of-a-kind use of renewable feedstocks with a novel technology to produce a next generation fuel for transportation. The Project configuration is quite different from those previously studied and evaluated by regulatory agencies. For that reason, we believed it was important to establish a line of communication with engineers at BAAQMD for the purpose of consultation going forward.

Having initiated discussions with the appropriate team at BAAQMD, we were immediately informed of the need to first file an air permit application and pay the associated fee, after which we could engage the BAAQMD team in discussions regarding process, evaluation of alternate project configurations, and other concerns and implications raised concerning the location of the Project within a community newly designated as “overburdened.” Raven SR filed a preliminary application, in order to commence discussions with the BAAQMD.

BAAQMD published notice of the preliminary application as required, thus notifying the region of the Raven Project and supporting a process by which BAAQMD could develop their understanding of the project. Following BAAQMD’s initial review of data from the preliminary application, Raven SR received the anticipated ‘letter of incomplete’ from the District, which established a platform for Raven engineers and BAAQMD engineers to intelligently and diligently discuss and adhere to the requirements for the project.

Since that initial filing, Raven SR engineers and consultants have continued to work with BAAQMD to answer their questions regarding the expected emissions profile of the Raven Project. The configuration of the project has certainly evolved from its conception in response to concerns about the safety and welfare of the community. The data presented to the BAAQMD since the preliminary filing has been developed by working closely with our engineering team and with equipment suppliers for selection of best-in-class equipment. The Updated Air Quality and Greenhouse Gas Assessment Technical Memo and Updated Air Quality and New Health 1530
4 Risk Assessment Technical Memo attached as Appendix A to the City’s March 2022 Updated IS/MND is based on the information Raven submitted to the BAAQMD as part of the processing of its authority to construct permit.

Section III.A.ii. There is Substantial Evidence of a Fair Argument that the Project Will Have a Significant Health Risk Impact from its Air Quality Impacts Upon becoming aware of the Appellant’s concerns, Raven SR immediately commissioned Ramboll to undertake a Health Risk Assessment (HRA) utilizing the same protocols used by BAAQMD. The Updated Air Quality and Greenhouse Gas Assessment Technical Memo and Updated Air Quality and New Health Risk Assessment Technical Memo attached as Appendix A to the City’s March 2022 Updated IS/MND contains the HRA requested by the Appellants. The HRA determined that the Raven Project would not result in a significant impact, and does not exceed the risk threshold allotted to “overburdened” communities.

Appellants expressed concern that emissions of criteria pollutants from the Raven Project, while below the threshold for mitigation, is not sufficiently low, suggesting that the adopted threshold limits should not apply. As a result of this opportunity to review the data, Ramboll, the expert consultants retained by Raven SR, determined that the Project had erred in double-counting some of the emissions from point sources, with the result that the Project is even less impactful than was first discussed in the City’s October IS/MND.

Raven SR cannot account for the emissions data attributed to LFG engines as outlined in this section of the Appellant’s comments and would instead refer Appellants to the information supplied to BAAQMD for selected equipment that includes Selective Catalytic Reduction (SCR) and an oxidative catalyst for VOC destruction – equipment that improves upon the dated and ineffective equipment now in operation at WCCSL.

As demonstrated in Section 4.3 of the March 2023 Updated IS/MND and Appendix B, the Project’s air quality and health risk impacts would all be below levels of significance and the Project would not result in a significant impact.

Section III.A.iii. The City Failed to Rebut the Substantial Evidence for a Fair Argument that The Project Will Have a Significant Health Risk Impact from its Air Quality Impacts As part of the HRA commissioned by Raven SR (see Attachment B of this document and Appendix A of the City’s March 2023 Updated IS/MND), dispersion models of the immediate area of potential impact by the Raven Project were developed in accordance with methodology used by BAAQMD and studied, with a focus on nearby receptors as identified by the Appellants in their Appeal. The results of the HRA confirmed the earlier findings of Ramboll and ESA as set forth in the October 2022 IS/MND assessment of no significant impact.–the Project’s potential impacts during its Construction and Operation phases are below thresholds of significance for impacts on overburdened communities, and as the City determined in the October 2022 IS/MND, the City similarly found in the March 2023 Updated IS/MND that the Project will not result in a significant health risk impact or air quality impacts to any sensitive receptors. Substantial evidence contained in Appendix B to the Updated IS/MND demonstrates 1531
5 that the Project would result in less than significant air quality, greenhouse gas emissions and health risk impacts.

Raven SR reviewed the various sources and characteristics of the Project emissions during its Construction and Operation phases. In conducting the review, our team realized that we had erred in our calculations by a duplication of emissions in our accounting. This has been corrected with a net result that the emissions profile of the project has been further reduced.

The proposed Project would not result in a Significant Health Risk Impact.

Section III.A.iv. Insufficient Public Outreach
Raven SR has presented at more than 15 group meetings and is continuing to expand its outreach efforts to neighborhood groups and organizations in the Richmond community. Raven SR held an open house for the community on March 8 and continues to work with several community leaders to ensure its outreach is touching key areas. Various community groups participating in Raven SR’s briefings include: NRDC, West County Mayors, Council on Industry, Communities For A Better Environment, Urban Tilth, Richmond Future Coalition Sierra Club, Richmond Our Power Coalition, North Richmond Advisory Committee, West Water District Joint Powers Agency, Asian Pacific Environmental Network, West County Sierra Club, City of Hercules, Richmond Neighborhood Coordinating Council, El Cerrito Rotary Club, Richmond Rotary Club, Council on Industry/Richmond Chamber of Commerce Breakfast, Iron Triangle Neighborhood, Senator Nancy Skinner’s office, Assemblywoman Buffy Wicks’ office, Congressman John Garamendi’s office, Richmond Planning Commissioners, Councilman Cesar Zepada, Supervisor John Gioia, Councilwoman Gayle McLaughlin, and Councilwoman Claudia Jimenez.

Section III.B. Cumulative Impacts
Appellants suggest that Raven SR speculates about the potential and cumulative pollution impacts resulting from two other hydrogen projects in the Richmond area. Raven SR notes the following:

1. Raven SR is the project applicant for the Raven One Project. Our project is located within the existing landfill that was subject to a prior environmental impact report and an analysis of cumulative impacts at that time. Our project is not related to other hydrogen efforts that the Appellants indicated may be under consideration for the Richmond area.

We have attempted to identify the other projects referred to by the Appellants. We believe that one of the references may be to a possible concept at the Chevron Richmond refinery to produce additional hydrogen from their existing reactors. To our knowledge, Chevron may have discussed this concept with the City but there was no record of an application for any approvals. We have not been able to identify a second project; nor is it identified by the Appellants.

2. Appellants seem to misunderstand the facts regarding the additional traffic that may be generated by the Raven Project. Appellants suggest that the project will lead to an additional 100 trips per day by “heavy-duty trucks”. The Appellants seem to be confused 1532
6 about the number of actual project-generated truck trips. Section 2.8 of the Updated IS/MND accounts for the presence of 25 heavy-duty trucks that will be associated with the project. However, for the purposes of comparison, the study then converts those truck trips into “passenger car equivalents” by first multiplying the number of trucks by two, accounting for their round trips to the site. That figure is then again multiplied by a factor of another two (arriving at 100 passenger car equivalents; 25 x 2 x 2) to conform with accepted practice in assessing vehicular pollution impacts. Thus, the actual number of truck trips is 25, not 100.

Section III.C. Hazards and Safety
Appellants believe that the October 2022 IS/MND was vague in describing an intent to comply with various health, hazard, and process safety management regulations. In the IS/MND, the Raven Project was described as being subject to various local, state, and federal programs governing the health and safety of workers in industry. Section 2.6 of the March 2023 Updated IS/MND also referred to Raven SR’s intended compliance with the OSHA Process Safety Management (29 CFR 1910.119) and the EPA Risk Management Program (Section 112(r) of the Clean Air Act), commonly referred to as PSM/RMP. These programs provide a process for safety, mechanical reliability and operator involvement. PSM/RMP is mandatory for systems that exceed a threshold of 10,000 pounds of flammable material. The Raven Project will NOT exceed this threshold but will voluntarily comply with the program requirements. Various other programs administered at the state and local levels require documentation and reporting (with periodic audit of the site and updating of requisite documentation) for processes associated with the project’s operations and maintenance. Though Appellants raise the question of “how much” description of intent to comply is sufficient to allay concerns, Raven SR appreciates the opportunity to revise and expand upon its intent to comply with an amplified discussion within the revised IS/MND of those programs under which is it legally compelled to operate.

Appellants seem to suggest that Raven SR must implement mitigation measures beyond those that have been anticipated by experts in process engineering and plant operations in the conduct of the design of the Raven Project. Those experts were retained primarily for their experience base and their facility with and understanding of governing standards for civil (including environmental and traffic), mechanical, and chemical engineering practices. Team consultants were selected for their expertise in the characterization and evaluation of best practices regarding the mitigation of pollutants, health risks, and plant operations. The construction arm of the Raven SR team was selected in part for their demonstrated exemplary record of on-the-job safety as well as cost and schedule management. Raven’s team of recognized experts have undertaken standard, reasonable efforts and best management practices to mitigate foreseeable risks and to incorporate standard best management practices into the Project design and operation.

Appellants identify hazards presented by the production and transport of hydrogen. Raven SR is not the first to have produced hydrogen, nor are its off-takers the first to transport hydrogen. The standards and practices for engineering, design, and operation that are and will be utilized, with ever improving sensors and instrumentation for process control, reasonably demonstrate the intent and capability of Raven SR and its project team to minimize and mitigate risk as explained in Section 2.6 of the Updated IS/MND.
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7 For example, the plant itself is open to the air. Any inadvertent leakage of hydrogen, which is 14 times lighter than air, will quickly disperse. Opportunities for containment of hydrogen in sufficient amounts to risk an on-site explosion are negligible. Tube trailers used for the transport of the hydrogen product have been engineered and produced with great attention to safety, programs for which are administered by the US DOT.

Appellants quote from a notable paper on the impact of hydrogen released into the atmosphere and its contribution to potentiating the impact of other greenhouse gases. A review of that paper reveals the author’s conclusions that the hypothetical reactions and mechanisms presented therein are not proven, but instead are only offered with a “high level of uncertainty” as topics for further research. In our own research, we uncovered claims in a publication1 suggesting that replacement of the entire global fossil fuel infrastructure with hydrogen, and with a leakage rate of 1% (average for the global system), would result in greenhouse gas impacts 0.6% lower than the current system. In mentioning this reference, it is Raven SR’s intention to acknowledge that, like all science, the science of climate change is evolving as new information is made available.

It is our belief based on extensive scientific research, however, that a transition to renewable fuels like hydrogen, is, on the whole, beneficial to the environment and to society.

Section III.D. Project Description
Raven SR appreciates the opportunity to further refine and clarify the Project Description for the City’s use as set forth in Section 2 of the March 2023 Updated IS/MND. We are optimistic about the benefits to the City of Richmond by our novel technological approach of converting urban green wastes and organics to hydrogen for the transition from fossil fuels, including increasing diversity of options for waste utilization, reduced emissions, and local jobs. We have attached our updated project description clarifying information to this letter to assist the Appellants in their review of our Project.

Appellants ask about the future energy supply to the Raven Project in the event that the LFG supply is exhausted. Raven SR believes this question to be largely speculative, but also observes that it is the goal of the State of California (and PG&E) to be 100% reliant on renewable power within the same 15-20 year timeframe suggested by Appellants. Thus, one can reasonably speculate that the project will continue to utilize 100% renewable power in any configuration of the state’s future power portfolio.

Section III.E. Additional Concerns
The condition of the groundwater at the site has been at the center of attention for Republic Services and WCCSL as stewards of an old, closed landfill. A review of recent results from groundwater monitoring stations in the vicinity of the plot identified for the Raven Project show little to no evidence of the incursion of leachate from the landfill. The results of the Geotechnical survey conducted on behalf of Raven SR did not result in detection of groundwater or waste 1Derwent, Richard & Simmonds, Peter & O'Doherty, Simon & Manning, Alistair & Collins, William & Stevenson, David (2006). Global environmental impacts of the hydrogen economy. Int. J. Nuclear Hydrogen Production and Application Int. J. Nuclear Hydrogen Production and Application. 1. 57-67. 10.1504/IJNHPA.2006.009869. 1534
8 materials to a level of 150 feet. This survey was done to measure the load carrying capability of the soil mix and out of a concern that pilings might have been required to support the anticipated loads. The result of the study is that construction may proceed using concrete slabs varying in thickness to 18 inches, sufficient for load carrying. No digging or excavation beyond 6 feet of depth is anticipated for the necessary installation of pipes for wastewater and freshwater conveyance for the Raven Project. The City of Richmond included this information in the March 2023 Updated IS/MND and further documented that the proposed Project will not result in a significant hazardous materials impact.

Raven SR has directed that the groundwater under the available plot provided by Republic be sampled to establish a baseline to be used against future sampling.

Raven SR has confirmed with soil experts and subsequently directed that additional provisions be taken for the safety of construction labor to install impermeable vapor barriers under the concrete slabs to contain and prevent any migration to the surface of soil VOCs that may be present.

Raven provided the information above, and the technical studies included in the City’s Updated IS/MND to further clarify and amplify the Project construction and operation and address the comments raised by Appellants. The robust technical information we have provided for the City’s use in the Updated IS/MND demonstrates the Raven Project would not result in any significant impacts that cannot otherwise be mitigated to a less than significant level. Raven is committed to implementing best management practices for the safety of the community and our employees during the construction and operation of the Raven One Project. 1535

ATTACHMENT A
9 Raven SR, Inc.

Project Description: Richmond S-1
Introduction:

Raven SR will be constructing and operating one of its Steam/CO2 Reformation systems at the West Contra Costa Sanitary Landfill ("WCCSL") in Richmond, CA to convert up to 99.9 wet-tons per day (WTPD) of blended green waste and food waste into renewable, transportation grade hydrogen. The WCCSL is operated by Republic Services.

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

Summary of Technology:

Raven SR’s patented, Steam/CO2 Reformation technology can convert a wide variety of carbonaceous (organic) feedstocks into a hydrogen-rich synthesis gas (syngas). The technology is strictly non-combustion (i.e., anoxic, indirect heating), low pressure, and catalyst-free1 process transforming carbonaceous feedstocks into a hydrogen-rich synthesis gas.2 The synthesis gas can be converted to downstream renewable energy products such as transportation-grade hydrogen and nitrogen-free Fischer-Tropsch (FT) liquid fuels, methanol, olefins, as well as electricity derived from fuel cells or turbines and/or internal combustion engine generator sets. Raven SR’s patented technology offers a variety of feedstock options and a menu of output alternatives.

The Raven SR system is designed to be modular with a small footprint and recycles waste heat to increase process efficiency. Apart from the advantage of physically reducing organic waste into clean fuels, the Raven SR system has low-air emissions and sequesters solid carbon in a useful and salable byproduct (biocarbon), in quantities usually around 15-20% of total feedstock input dry volume. The sterile3 biochar is composed of many 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. The biocarbon is a saleable product that can be used for fertilizer, filler for concrete etc. 2 Carbonaceous feedstocks include biomass, biogas, municipal solid waste, bio-solids, industrial waste, sewage, medical waste, etc.
3 Following thermal treatment by the first stage reformer, biological pathogens (if any) are destroyed by elevated temperature and residence time of ~45 minutes.
1536

ATTACHMENT A
10 3 Stage Process:

There are three stages of the process (see Figure 1 below). To convert the organic waste feedstock into hydrogen, the process begins with an externally-heated, sealed rotary reformer which turns feedstock into a raw syngas which is then “polished” using a second steam reformer making a hydrogen-rich syngas (55-63% H2). From there the syngas may be processed through an industry standard water gas shift reactor (WGS) and a pressure swing absorption (PSA) unit producing transportation-grade hydrogen. If the desired output is synthetic fuels (diesel, jet, etc.) instead, the process would use FT vessels (forming long chain hydrocarbons through an exothermic, catalytic process) in place of the hydrogen unit.

Figure 1 – Simplified Schematic of the Raven SR Process Feedstock Input:

Solid feedstock is best processed when wet and after being pre-sorted to reclaim any valuable metals and recyclables. The solid feedstock is 1-2” diameter so that it can be manipulated by the rotary reformer.

Ideally, the feedstock will have a moisture content between 40-55%. Feedstock with excess moisture can be treated with a dewatering screw, while steam can be added if the moisture content is too low.  No combustion. The Raven SR system does not have any free-oxygen in its process (see Section 260.10, Title 40, Code of Federal Regulations (40 CFR) and Section 66260.10, Title 22, California Code of Regulations (22 CCR)). Instead, it uses a chemical process provoked by steam to break down waste into its base chemical elements. This process has two key benefits: by not burning the feedstock, it converts more of the waste feedstock into fuel and there are no typical or hazardous combustion emissions (i.e., particulate matter, oxides of nitrogen and sulfur, dioxins and dibenzofuran) from the conversion system.
 Flexible inputs. Raven SR systems can convert multiple types of biomass, solid waste, landfill gas, wastewater, or a combination of these, and can switch between them. 1537

ATTACHMENT A
11  Highest safety standards. Raven SR units are equipped with continuous monitoring systems and can automatically shut down plant operations without human intervention. The project will comply with applicable RMP/PSM guidelines.

Description of operations:

The Raven facility will receive up to 99.9 WTPD of blended green waste and food waste feedstock to produce up to 4,800 kg of hydrogen per day. Along with hydrogen, about 20 tons per day of biocarbon is produced from the system. The system is electrically heated and, with balance of plant loads, consumes about 5 MW of electricity.

The solid feedstock from the WCCSL is taken from existing on-site grinding operations and will be trucked approximately 2,500 feet from the existing landfill facility footprint by WCCSL’s existing equipment to Raven SR’s solids handling system which will prepare the feedstock for thermal processing. All Raven SR’s materials handling systems will be located inside a building. The rest of the facility will also be underneath an industrial metal canopy with partial drop-down walls. This system mixes the feed with granular lime which is fed directly into the systems first stage reformer (SR1) through a lock hopper which prevents the incursion of air with the feed. SR1 heats the material in a reducing environment (i.e., anoxic), thermally decomposing the organic compounds, converting a portion of the feedstock into syngas. While the residual biocarbon is collected as it comes out at the end of SR1 process, the “raw” syngas exits for further processing – all fully contained. All inerts like rocks, glass, grit, sand, and other inerts that was in the feed will be collected with the biocarbon. At this point, the syngas will go into the second stage reformer (SR2).

SR2 converts the remaining methane and other remaining hydrocarbons into syngas. The resulting gas is mostly hydrogen, carbon monoxide, carbon dioxide and water. The syngas then goes through a complete polishing to remove impurities such as particulates, H2S, HCl, or HCN. The syngas moves into a water gas shift reactor (WGS) converting CO to H2, and finally into a pressure swing adsorption (PSA) unit to purify the hydrogen product. The remaining tail gas, containing residual hydrogen and CO2, from the PSA are sent to the power generation engines. 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.

Upon startup, the plant will consume approximately 5 MWe to operate and produce 200 kg/hr of hydrogen. The majority of this power will come from onsite power generation using newly installed Jenbacher engine generator sets (these engines will replace existing, inefficient engines). The fuel to be used for the generation is the landfill gas (LFG) from Republic Services landfill, combined with the tail gas from the PSA. Approximately 2.2 MW will be generated from the LFG, and 0.5 MW from the tail gas produced in the conversion process. The energy value of the tail gas comes from the unrecovered residual of hydrogen from the PSA. Republic Services will offtake approximately 0.5 MW from the power generation for their onsite operation needs and the rest will be used to power the hydrogen plant. The additional electrical power required beyond that generated onsite will come from an existing PG&E power drop to the site.

Some key points:
1538

ATTACHMENT A
12  Run Time: The system is designed to run 24/7 with 1.5 days per month allotted for scheduled maintenance, this is an average across a quarter. This is approximately 8,300 hours of operation per year. The system is design for continuous operation without many start-ups or shut-downs.  Fugitive Emissions: The system is a closed process from the first-stage reformer to the PSA.

Mechanical seals prevent fugitive emission from the first-stage reformer which operates under pressure that is only slightly above atmospheric. The unit will be shielded from sun and rain with a canopy that will also serve as the suction for thermal oxidation of waste gases. Any fugitives from the vessel will be accumulated and sent to the thermal oxidizer for destruction; continuous monitoring systems for criteria pollutants will be incorporated.  Odor Control: Odor control will be in place to minimize possible odors. A canopy will be placed over the feedstock tip floor and infeed equipment to the process to prevent stormwater contact. The canopy will collect air from the feedstock management area and use that air as primary air for downstream control of emissions.
 Only Hydrogen: While Raven SR can produce synthetic liquid fuels, the Richmond location is only going to produce transportation grade hydrogen due to the interest of the local and regional markets for non-fossil fuel based hydrogen.
 Hydrogen Export Panel: The produced hydrogen will be onboarded by Shell designed hydrogen gas export panel incorporating best-practice Health, Safety, Security and Environment (HSSE) and compliant with industry standards for handling hydrogen.  Truck volumes: Approximately 28 hydrogen tube trucks and 7 biocarbon trucks (total 35) per week with an average trip of 40 miles. There will be no additional WCCSL traffic as the Raven system will only use feedstock from ongoing onsite WCCSL operations.  Vehicular Circulation: Presently no changes are being proposed or required to vehicular circulation entering or exiting the project site.
 Tube-truck idle time: No more than 5 minutes once at project site (as required per state regulations)
 Standard throughput: The current plan has the same throughput over time, but because the system is modular its capacity could be increased in the future.  Employees: Raven will be employing approximately 3-4 employees per shift for the operation of the Raven facility. Raven will be hiring 9-12 new employees exclusively for this project to cover all shifts and provide necessary support the facility.

Timing:

Raven SR anticipates breaking ground for the Richmond facility in Q3 2022. It is expected to launch production in early Q1 of 2023.

Principal Environmental Permits Required:

The City of Richmond has determined that the proposed Raven system at the WCCSL will require a conditional use permit (CUP) and will the Lead Agency for the CEQA environmental review process. The Bay Area Air Quality Management District will need to issue an Authority to Construct (ATC) for the air 1539

ATTACHMENT A
13 pollutant emissions of the project. A solid waste Transfer and Processing permit will be required from the CA Department of Resource Recovery and Recycling (CalRecycle). Raven has submitted the necessary CUP application to the City of Richmond and is preparing the necessary application forms and supporting information for the ATC and CalRecycle permits.

Other permits such as Storm Water permits from the CA Water Resources Control Board and hazardous materials and waste generation permitting by Contra Costa County Health Services will also be required for the project.

The CEQA document will address the above agencies’ permitting needs as the permits all require discretionary decision making by the respective agency.

Primary Project Site Layout
A rendering of the Richmond site, without the protective canopy, is shown below, which is approximately

1.5 acres:
1540

ATTACHMENT A
14 1541

ATTACHMENT B
15 Health Risk Assessment (Ramboll)
HRA Tables.pdf
1542
Construction Subphase1 Start Date End Date Year Number of Work Days Days per Week
Demolition 7/17/2023 7/21/2023 2023 5 5
Site Preparation 7/24/2023 9/1/2023 2023 30 5
Grading 9/4/2023 10/13/2023 2023 30 5
Building Construction 9/18/2023 3/28/2024 2024 139 5
Notes:

1. All construction phasing information was provided by the Project Sponsor. The start and end dates of construction subphases were adjusted due to project delays.

Table 1
Construction Schedule
Raven SR
Richmond, CA
1543
7/17/2023
Construction
Subphase(s) Equipment Name1 Fuel1 Number1 Horsepower2 Days Per Phase1
Daily Usage
(hours/day)1 Utilization1 Uncontrolled Engine Tier3
Air Compressors Diesel 1 37 5 8 100% No Specific Tier
Crushing/Proc. Equipment Gasoline 1 12 5 8 100% No Specific Tier Excavators Diesel 1 36 5 8 100% No Specific Tier
Dumpers/Tenders Diesel 2 16 5 8 100% No Specific Tier
Excavators Diesel 3 36 30 8 100% No Specific Tier
Tractors/Loaders/Backhoes Diesel 1 84 30 8 100% No Specific Tier Rough Terrain Forklifts Diesel 1 96 30 4 100% No Specific Tier Dumpers/Tenders Diesel 1 16 30 8 100% No Specific Tier
Plate Compactors Diesel 2 8 30 8 100% No Specific Tier
Crawler Tractors Diesel 1 87 30 8 100% No Specific Tier Rollers Diesel 1 36 30 8 100% No Specific Tier
Tractors/Loaders/Backhoes Diesel 1 84 30 8 100% No Specific Tier Excavators Diesel 1 36 30 8 100% No Specific Tier
Cranes Diesel 1 367 139 8 100% No Specific Tier
Rough Terrain Forklifts Diesel 1 96 139 8 100% No Specific Tier Air Compressors Diesel 1 37 139 8 100% No Specific Tier Generator Sets Diesel 1 14 139 8 100% No Specific Tier
Welders Diesel 2 46 139 8 100% No Specific Tier
Other Construction Equipment Diesel 1 82 139 8 100% No Specific Tier Notes:

1. 2.

3. Abbreviations:

ARB - California Air Resources Board
CalEEMod - California Emissions Estimator Model
References:

Table 2
Construction Equipment
Raven SR
Richmond, CA
Anticipated Construction Start Date:

The California Emissions Estimator Model (CalEEMod). Available at: http://www.caleemod.com/ Demolition
Site Preparation
Grading
Building Construction
Construction equipment information was provided by the Project Sponsor or based on CalEEMod defaults if not given.

Equipment horsepower is based on CalEEMod Appendix G defaults.

Equipment engine tiers are based on CalEEMod fleet averages. 1544
Type Source Methodology and Formula Reference
Construction
Equipment Off-Road Equipment1 Ec = Σ(EFc * HP * LF * Hr * UF * C) OFFROAD2017 and
ARB/USEPA Engine
Standards
Construction
Fugitive Dust
Mechanical Dismemberment,
Grading, Truck Loading CalEEMod® CalEEMod
Exhaust – Running ER = Σ(EFR * VMT * C) , where
VMT = Trip Length * Trip Number EMFAC2021
Brake Wear and Tire Wear EBW,TW = Σ(EFBW,TW * VMT * C), where VMT = Trip Length * Trip Number EMFAC2021
Exhaust - Idling EI = Σ(EFI * Trip Number *TI* C) EMFAC2021 Entrained Road Dust ERD = Σ(EFRD * VMT * C) , where
VMT = Trip Length * Trip Number
ARB 2021 Miscellaneous
Process Methodology 7.9
Notes:

1. Ec: off-road equipment exhaust emissions (lb)
EFc: emission factor (g/hp-hr). CalEEMod default emission factors used HP: equipment horsepower. From CalEEMod defaults
LF: equipment load factor. From OFFROAD2017
Hr: equipment hours
UF: Utilization factor
C: unit conversion factor

2. ER: running exhaust and running losses emissions (lb) EFR: running emission factor (g/mile). From EMFAC2021
VMT: vehicle miles traveled
C: unit conversion factor
The calculation involves the following assumptions:
a. All material transporting and soil hauling trucks are heavy-heavy duty trucks.

EI: vehicle idling emissions (lb).

EFI: vehicle idling emission factor (g/hr-trip). From EMFAC2021 TI: idling time
C: unit conversion factor
ERD: entrained road dust emissions (lb)
EFRD: annual average emission factor (lb/VMT) = k*(sL)^0.91 * (W)^1.02 * (1-P/4N) k: particle size multiplier for particle size range
sL: roadway silt loading [grams per square meter - g/m2] W: average weight of vehicles traveling the road [tons] P = number of “wet” days in county with at least 0.01 in of precipitation during the annual averaging period N = number of days in the averaging period
VMT: vehicle miles traveled
C: unit conversion factor
Abbreviations:

ARB: California Air Resources Board lb: pound
BW: Brake Wear LF: Load Factor
EF: Emission Factor mi: mile
EMFAC: EMission FACtor Model USEPA: United States Environmental Protection Agency g: gram RL: Running Losses
HP: horsepower VMT: vehicle miles traveled
References:

Table 3
Emission Calculation Methodology
Raven SR
Richmond, CA
Construction and
Operational OnRoad Mobile
Sources2
On-road mobile sources include truck and passenger vehicle trips. Emissions associated with mobile sources were calculated using the following formulas.
b. Trip Length: The one-way trip length as calculated based on CalEEMod Appendix G defaults for Contra Costa County or provided by the Project Sponsor
c. Trip Number: Worker, vendor and hauling trip rates were provided by the Project Sponsor.

ARB/USEPA. 2013. Table 1: ARB and USEPA Off-Road Compression-Ignition (Diesel) Engine Standards. Available online at:
http://www.arb.ca.gov/msprog/ordiesel/documents/Off-Road_Diesel_Stds.xls The California Emissions Estimator Model (CalEEMod). Available at: http://www.caleemod.com/ California Air Resources Board (ARB) 2021. EMFAC2021. Available at: https://ww2.arb.ca.gov/our-work/programs/mobile-source-emissionsinventory/msei-modeling-tools 1545
Trip Data
Trip Rates1 (one-way
trips/subphase)
Worker Trips Vendor Trips Hauling Trips Worker Trips Vendor Trips Hauling Trips Demolition 2023 5 2 0 100 12.9 7.4 20
Site Preparation 2023 30 2 0 0 12.9 7.4 20
Grading 2023 30 2 0 0 12.9 7.4 20
Building Construction 2023 76 2 4 0 12.9 7.4 20
Building Construction 2024 63 2 4 0 12.9 7.4 20
EMFAC Data4
Trip Type EMFAC Settings Fuel Type
Worker Gasoline
Vendor Diesel
Hauling Diesel
Notes:

1. 2.

3. Abbreviations:

CalEEMod - California Emissions Estimator Model
EMFAC2021 - California Air Resources Board EMission FACtor model LDA - light-duty automobiles
LDT - light-duty trucks
HHDT - heavy-heavy duty trucks
sqft - square feet
References:

Worker, vendor, and hauling trip lengths are based on CalEEMod Appendix G defaults for Contra Costa County.

Emissions were calculated using emission factors from EMFAC2021 with the specified settings and fleet and fuel assumptions.

The California Emissions Estimator Model (CalEEMod). Available at: http://www.caleemod.com/ California Air Resources Board (ARB) 2021. EMFAC2021. Available at: https://ww2.arb.ca.gov/our-work/programs/mobile-source-emissions-inventory/msei-modeling-tools Trip Lengths2 (miles/one-way trip)
Construction
Fleet Mix
Contra Costa County
Calendar Years 2023-2024
Annual Season
Aggregated Model Year
EMFAC2007 Vehicle Categories
25% LDA, 50% LDT1, 25% LDT2
50% MHDT, 50% HHDT
100% HHDT
Construction Phase Construction Subphase Year Construction Days
Table 4
Richmond, CA
Raven SR
Construction Trips
Worker, vendor, and hauling trip rates were provided by the Project Sponsor.

Trip Rates1 (trips/day)
1546
Roadway Category Silt Loading1
(g/m2) Travel Fraction1
Freeway 0.015 50%
Major 0.032 37%
Collector 0.032 9%
Local - Urban 0.32 4%
Weighted Silt Loading Factor 0.035 100%
Notes:

1. Abbreviations:

ARB - Air Resources Board
g - gram(s)
m - meter
References:

California Air Resources Board (ARB). 2021. Miscellaneous Process Methodology 7.9, Entrained Road Travel, Paved Road Dust. March. Available online at:
https://ww3.arb.ca.gov/ei/areasrc/fullpdf/2021_paved_roads_7_9.pdf Table 5
Silt Loading Emission Factors
Raven SR
Richmond, CA
Entrained Roadway Dust Constants for San Francisco County Travel fraction by roadway category and silt loading are based on ARB's Entrained Road Travel Emission Inventory Source Methodology Tables 2 and 4, respectively. 1547
Road Dust Equation1
E [lb/VMT] = [k*(sL)^0.91 * (W)^1.02]*(1-P/4N)
Parameters2,3 Value
E = annual average emission factor in the same units as k [calculated] k = particle size multiplier for particle size range
PM2.5 (lb/VMT) 3.3E-04
sL = roadway silt loading [grams per square meter - g/m2] 0.035 W = average weight of vehicles traveling the road [tons] 2.4 P = number of “wet” days in county with at least 0.01 in of precipitation during the annual averaging period3 30
N = number of days in the averaging period 365
Entrained Road Dust Emission Factors
PM2.5 Emission Factor [lb/VMT] 3.74E-05
Notes:

1. 2.

3. Abbreviations:

ARB - California Air Resources Board lb - pound
CalEEMod - California Emissions Estimator Model PM2.5 - particulate matter less than 2.5 microns EMFAC - EMission FACtor Model VMT - vehicle miles traveled g - gram
References:

The number of "wet" days for Richmond, CA is from CalEEMod Appendix G Table G-2 (30 days).

California Air Resources Board (ARB). 2021. Miscellaneous Process Methodology 7.9, Entrained Road Travel, Paved Road Dust. March. Available online at: https://ww3.arb.ca.gov/ei/areasrc/fullpdf/2021_paved_roads_7_9.pdf The California Emissions Estimator Model (CalEEMod). Available at: http://www.caleemod.com/ Table 6
Emission Factors for Entrained Roadway Dust
Raven SR
Richmond, CA
Road dust equation and parameters are from the California Air Resources Board's (ARB) 2021 Miscellaneous Process Methodology 7.9 for Entrained Road Travel, Paved Road Dust.

The silt loading emission factor assumes Contra Costa County default roadway fractions and silt loading levels from ARB 2021. Other parameters (average weight of vehicles, size multipliers) are from ARB 2021. PM2.5 is assumed to be 15% of PM10 based on paved road dust sampling in California (ARB Speciation Profile #471), which is a more representative fraction than provided in the older AP-42 fugitive dust methodology as discussed in ARB 2021 (page 17). 1548
Worker Trip length (miles/trip) 0.189
Vendor Trip Length (miles/trip) 0.189
Hauling Trip Length (miles/trip) 0.189
PM2.5 Emission Factor [lb/VMT] 3.74E-05
PM2.5
Demolition 2023 5 2 0 100 2 0 19 21 7.8E-04
Site Preparation 2023 30 2 0 0 11 0 0 11 4.2E-04
Grading 2023 30 2 0 0 11 0 0 11 4.2E-04
Building Construction 2023 76 2 4 0 29 58 0 86 0.0032
Building Construction 2024 63 2 4 0 24 48 0 72 0.0027
Notes:

1. 2.

Abbreviations:

CalEEMod - California Emissions Estimator Model lb - pound PM2.5 - particulate matter less than 2.5 microns VMT - vehicle miles traveled Table 7
Emission Calculation for Entrained Roadway Dust
Raven SR
Richmond, CA
Construction Area Subphase Year Construction
Days
Entrained Road Dust Emission Factors2
Calculated
1000 feet
1000 feet
1000 feet
Inputs
Trip Length1
Entrained road dust emission factors were obtained from Table 6.

Total VMT
(miles)
Total Emissions
(lb)
Construction
VMTs for worker, vendor, and hauling are obtained from Table 4.

Vendor Trips
(trips/day)
Hauling Trips
(trips/subphase)
Worker VMT
(miles)
Vendor VMT
(miles)
Hauling VMT
(miles)
Worker Trips
(trips/day)
1549
PM2.5 PM2.5
days ton lb/day ton/yr
Construction 2023 5.0 828 3.5E-04 0.0031 0.57 0.0014
Notes:

1. 2.

0.053 = k, PM2.5 particle size multiplier (dimensionless)

3.90 = mean wind speed (U), meters per second, Oakland International Airport

8.7 = U, mean wind speed (mph)
2 = M, material moisture content (%)

3. 0.053 = k, PM2.5 particle size multiplier (dimensionless)

0.058 = EFL-TSP, lb/ton

4. Abbreviations:

CalEEMod - California Emissions Estimator Model
cy - cubic yards
EF - emission factor
lb - pounds
PM2.5 - particulate matter less than 2.5 microns
VMT - vehicle miles traveled
yr - years
Table 8
Fugitive Dust Emissions from Demolition Activity
Raven SR
Richmond, CA
Construction Area Year
Number
of Days
Emissions were estimated conservatively assuming no fugitive dust control measures.

Building
Waste1
Emission Factor -
Mechanical or
Explosive
Dismemberment2
Emission Factor -
Debris Loading3
Uncontrolled
Emissions4
PM2.5
lb/ton lb/ton
Building square footage was provided by the Project Sponsor. Conversion of building waste to tons assumes an average soil density of 1.5 grams per cubic centimeter, per the CalEEMod User's Guide, Appendix C Truck Loading.

Emission factor calculated following guidance in the CalEEMod User's Guide, Appendix C Mechanical or Explosive Dismemberment, which is based of AP 42 Section 13.2.4.3 for batch drop operations. The equation is:

EF = k*(0.0032)*(U/5)1.3/(M/2)1.4 (lb/ton of debris)
Emission factor calculated following guidance in the CalEEMod User's Guide, Appendix C Debris Loading, which is based of AP 42 Section

13.2. The equation is:

EF = k*EFL-TSP
1550
PM2.5
acre/8hr-day acre/day mile/day lb/VMT
Construction Grading 2023 30 Crawler Tractors 1 100% 0.5 0.50 0.34 0.17 1.72 Notes:

1. 2. Based on CalEEMod® default daily acres graded by equipment type, Table G-14, below.

Equipment
Acres Graded per 8
Hour Day
Crawler Tractors 0.5
Graders 0.5
Rubber Tired Dozers 0.5
Scrapers 1

3. AS = AS, acres graded per day (varies by sub-activity); in this case using maximum estimated disturbed acres/day 12 = Wb, blade width of grading equipment (CalEEMod® default) in ft

3. 7.1 = S, mean vehicle speed (mph) (AP-42 default)

0.6 = FPM10, PM10 scaling factor (AP-42 default)

0.031 = FPM2.5, PM2.5 scaling factor (AP-42 default)
Abbreviations:
mph - miles per hour
PM2.5 - particulate matter less than 2.5 microns
ft - feet VMT - vehicle miles traveled
lb - pounds yr - year
EF - emission factor
Grading VMT2 Uncontrolled PM2.5
Emission Factor3
Uncontrolled
Emissions
Maximum graded area calculated following guidance in the CalEEMod® User's Guide, Appendix C.

VMT per day calculated following guidance in the CalEEMod® User's Guide, Appendix C, which is based on AP-42, Section 11.9 for grading equipment. The equation is:

Emission factors calculated following guidance in the CalEEMod® User's Guide, Appendix C, which is based on AP-42, Section 11.9 for grading equipment. The equations are:

CalEEMod® - California Emissions Estimator Model
lb/yr
Total Work Days
(per year) Equipment Quantity Utilization %
CalEEMod
Grading rate2
Maximum Area
Disturbed1
Table 9
Fugitive Dust Emissions from Off-Road Grading Activity
Raven SR
Richmond, CA
Construction Area Construction
Subphase1 Year
1551
PM2.5
days # trips ton ton lb/day ton/yr
Construction Demolition 2023 5 100 828 828 2.85E-05 4.7E-03 1.2E-05 Notes:

1. 2.

0.053

3.9 8.7
12 Abbreviations:

CalEEMod - California Emissions Estimator Model
EF - emission factor
lbs - pounds
PM2.5 - particulate matter less than 2.5 microns
Table 10
Fugitive Dust Emissions from Truck Loading Activity
Raven SR
Richmond, CA
Construction Area Construction Subphase Year
Number of
Days
lb/ton
Emission factor calculated following guidance in the CalEEMod User's Guide, Appendix C, which is based on AP-42, Section 13.2.4 for aggregate handling. The equation is:

EF = k x (0.0032) x (U/5)1.3 / (M/2)1.4 , where the following default values are used:

PM2.5
Haul Trips Total Material
Loaded1
Material
Loaded
Uncontrolled
Emission Factor2 Uncontrolled Emissions
= kPM2.5, PM2.5 particle size multiplier
= mean wind speed (U), meters per second, Oakland International Airport = mean wind speed (U), miles per hour
= material moisture content (M), %
Total materials loaded for demolition phase were the building waste converted from square feet to tons assuming an average soil density of 1.5 grams per cubic centimeter, per the CalEEMod User's Guide, Appendix C Truck Loading. Total exported materials for other phases is assumed to be zero, as provided by the Project Sponsor. 1552
DPM PM2.5 DPM PM2.5
2023 0.0018 0.0018 1.9E-07 3.9E-07
2024 9.0E-04 8.3E-04 1.1E-07 2.2E-07
Notes:

1. Abbreviations:

BAAQMD - Bay Area Air Quality Management District
CalEEMod® - California Emissions Estimator Model®
DPM - diesel particulate matter
PM2.5 - particulate matter less than 2.5 microns
References:

Construction TAC emissions were estimated from on-site off-road emissions, where all PM10 tailpipe emissions are assumed to be DPM (although a portion of this is likely not from diesel sources). On-road emissions from hauling, vendor and worker vehicles were estimated using a modeled trip length of 1000 ft. The inclusion of on-road emissions is conservative as the estimated traffic volumes do not exceed the screening levels recommended by BAAQMD (i.e., more than 10,000 vehicles per day and 100 trucks per day) and can be considered minor sources (BAAQMD 2011).

Recommended Methods for Screening and Modeling Local Risks and Hazards. 2012. BAAQMD. May. Available online at: https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/risk-modeling-approach-may2012.pdf?la=en The California Emissions Estimator Model (CalEEMod). Available at: http://www.caleemod.com/ California Environmental Quality Act (CEQA) Guidelines. 2017. Bay Area Air Quality Management District (BAAQMD). May. Available online at: http://www.baaqmd.gov/~/media/files/planning-andresearch/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en Table 11
Modeled Emission Rates - Project Construction Sources
Raven SR
Richmond, CA
Year
Construction Emissions1 [g/s]
Offroad Onroad
1553
Biogas Engines1 Green Waste
Offgas2 Flare2
Fire Pump
Engine2 Biogas Engines1 Green Waste Offgas2 Flare2
Fire Pump
Engine2
(g/s) (g/s) (g/s) (g/s) (g/s) (g/s) (g/s) (g/s)
1,1-Dichloroethane (Ethylidene dichloride) 0.0017 -- -- -- 0.0017 -- -- -- 1,1-Dichloroethene (Vinylidene chloride) 7.3E-05 -- -- -- 7.3E-05 -- -- -- 1,1,1-Trichloroethane (Methyl chloroform) 3.3E-05 -- -- -- 3.3E-05 -- -- -- 1,1,2-Trichloroethane (Vinyl trichloride) 9.7E-06 -- -- -- 9.8E-06 -- -- -- 1,1,2,2-Tetrachloroethane 1.2E-05 -- -- -- 1.2E-05 -- -- -- 1,3-Butadiene 3.9E-06 -- -- -- 4.0E-06 -- -- --
1,4-Dichlorobenzene 1.7E-04 -- -- -- 1.7E-04 -- -- --
1,4-Dioxane (1,4-Diethylene dioxide) 6.4E-06 -- -- -- 6.4E-06 -- -- -- Acetaldehyde 0.0062 1.3E-04 1.2E-05 -- 0.0062 8.7E-05 2.0E-07 -- Acrolein 8.0E-04 -- 7.7E-06 -- 8.0E-04 -- 1.3E-07 --
Acrylonitrile 7.8E-06 -- -- -- 7.8E-06 -- -- --
Allyl Chloride (3-Chloropropene) 5.6E-06 1.6E-06 -- -- 5.6E-06 1.0E-06 -- -- Ammonia 1.5E-05 2.3E-04 -- -- 0.48 1.5E-04 -- --
Arsenic -- -- 5.7E-07 -- -- -- 9.5E-09 --
Benzene 0.0042 -- 2.3E-05 -- 0.0042 -- 3.8E-07 --
Benzyl Chloride 7.3E-06 -- -- -- 7.3E-06 -- -- --
Beryllium -- -- 1.7E-08 -- -- -- 2.8E-10 --
Cadmium -- -- 3.1E-06 -- -- -- 5.2E-08 --
Carbon Disulfide 5.6E-06 1.8E-06 -- -- 5.6E-06 1.2E-06 -- -- Carbon Tetrachloride 1.1E-05 -- -- -- 1.1E-05 -- -- --
Chlorobenzene 4.2E-05 -- -- -- 4.2E-05 -- -- --
Ethyl Chloride (Chloroethane) 8.7E-05 -- -- -- 8.7E-05 -- -- -- Chloroform 6.9E-05 -- -- -- 6.9E-05 -- -- --
Copper -- -- 2.4E-06 -- -- -- 4.0E-08 --
Diesel particulate matter -- -- -- 0.83 -- -- -- 9.4E-05 Dioxins PCDDs 3.6E-09 -- -- -- 3.6E-09 -- -- --
Ethylbenzene 6.0E-04 7.3E-06 2.7E-05 -- 6.0E-04 4.9E-06 4.5E-07 -- Ethylene Dibromide (1,2-dibromoethane) 1.4E-05 -- -- -- 1.4E-05 -- -- -- Ethylene Dichloride (1,2-dichloroethane) 2.9E-04 3.3E-06 -- -- 2.9E-04 2.2E-06 -- -- Formaldehyde 0.031 -- 6.3E-04 -- 0.031 -- 1.0E-05 --
n-Hexane 0.0027 -- 1.8E-05 -- 0.0027 -- 2.9E-08 --
Hydrochloric Acid (Hydrogen Chloride) 0.48 -- -- -- 0.10 -- -- -- Hydrofluoric Acid (Hydrogen Fluoride) 0.015 -- -- -- 0.0031 -- -- -- Hydrogen Sulfide (H2S) 2.1E-06 -- -- -- 2.1E-06 -- -- -- Isopropyl alcohol (IPA, 2-Propanol) 6.9E-05 1.4E-05 -- -- 6.9E-05 9.1E-06 -- -- Lead -- -- 1.4E-06 -- -- -- 2.4E-08 --
Manganese -- -- 1.1E-06 -- -- -- 1.8E-08 --
Mercury 3.3E-08 -- 7.4E-07 -- 3.3E-08 -- 1.2E-08 --
Methanol (Methyl alcohol) 2.3E-05 0.0073 -- -- 2.4E-05 0.0049 -- -- Methyl Bromide (Bromomethane) 6.9E-06 -- -- -- 6.9E-06 -- -- -- Methyl Ethyl Ketone (2-butanone) 1.1E-05 2.7E-04 -- -- 1.1E-05 1.8E-04 -- -- Methyl tert-Butyl Ether 6.4E-06 -- -- -- 6.4E-06 -- -- -- Methylene Chloride (dichloromethane) 0.0074 -- -- -- 0.0074 -- -- -- Naphthalene 5.2E-04 4.6E-07 1.7E-06 -- 5.2E-04 3.1E-07 2.9E-08 -- Nickel -- -- 6.0E-06 -- -- -- 1.0E-07 --
PAH Equivalents as Benzo(a)pyrene 1.0E-05 -- 1.9E-08 -- 1.0E-05 -- 3.2E-10 -- Perchloroethylene (tetrachloroethylene) 0.0040 -- -- -- 0.0040 -- -- -- Propene (Propylene) 6.8E-04 1.0E-05 0.0021 -- 6.8E-04 6.6E-06 3.5E-05 -- Selenium -- -- 3.4E-08 -- -- -- 5.7E-10 --
Styrene 1.8E-05 1.8E-05 -- -- 1.8E-05 1.2E-05 -- --
Toluene 9.4E-04 1.3E-05 1.0E-04 -- 9.4E-04 8.4E-06 1.7E-06 -- Trichloroethylene 8.4E-04 -- -- -- 8.5E-04 -- -- --
Vanadium -- -- 6.5E-06 -- -- -- 1.1E-07 --
Vinyl Acetate 1.3E-05 7.9E-05 -- -- 1.3E-05 5.2E-05 -- -- Vinyl Chloride (chloroethylene) 0.0011 -- -- -- 0.0011 -- -- -- Xylene (Total) 7.5E-04 7.6E-06 7.7E-05 -- 7.5E-04 2.7E-06 1.3E-06 -- Notes:

1. 2.

Abbreviations:

BAAQMD - Bay Area Air Quality Management District
g - gram
s - second
Biogas engine TAC emissions were estimated by BAAQMD using concentrations and speciation from facility data, and assuming 85% abatement efficiency.

Estimated TAC emissions were consistent with previous operational emission analyses for BAAQMD air permit application.

Table 12
Modeled Emission Rates - Project Operational Sources
Raven SR
Richmond, CA
Acute Chronic
Pollutant
1554
Acute Chronic
Landfill Flare Landfill Flare
(g/s) (g/s)
1,1-Dichloroethane (Ethylidene dichloride) 75-34-3 0.011 0.011 1,1-Dichloroethene (Vinylidene chloride) 75-35-4 4.9E-04 4.9E-04 1,1,1-Trichloroethane (Methyl chloroform) 71-55-6 2.2E-04 2.2E-04 1,1,2-Trichloroethane (Vinyl trichloride) 79-00-5 6.5E-05 6.5E-05 1,1,2,2-Tetrachloroethane 79-34-5 8.2E-05 8.2E-05
1,3-Butadiene 106-99-0 2.6E-05 2.6E-05
1,4-Dichlorobenzene 106-46-7 0.0011 0.0011
1,4-Dioxane (1,4-Diethylene dioxide) 123-91-1 4.3E-05 4.3E-05 Acetaldehyde 75-07-0 0.041 0.041
Acrolein 107-02-8 0.0053 0.0053
Acrylonitrile 107-13-1 5.2E-05 5.2E-05
Allyl Chloride (3-Chloropropene) 107-05-1 3.7E-05 3.7E-05 Ammonia 7664-41-7 1.0E-04 3.2
Benzene 71-43-2 0.028 0.028
Benzyl Chloride 100-44-7 4.8E-05 4.8E-05
Carbon Disulfide 75-15-0 3.7E-05 3.7E-05
Carbon Tetrachloride 56-23-5 7.5E-05 7.5E-05
Chlorobenzene 108-90-7 2.8E-04 2.8E-04
Ethyl Chloride (Chloroethane) 75-00-3 5.8E-04 5.8E-04
Chloroform 67-66-3 4.6E-04 4.6E-04
Dioxins PCDDs 1-08-6 2.4E-08 2.4E-08
Ethylbenzene 100-41-4 0.0040 0.0040
Ethylene Dibromide (1,2-dibromoethane) 106-93-4 9.2E-05 9.2E-05 Ethylene Dichloride (1,2-dichloroethane) 107-06-2 0.0020 0.0020 Formaldehyde 50-00-0 0.20 0.21
n-Hexane 110-54-3 0.018 0.018
Hydrochloric Acid (Hydrogen Chloride) 7647-01-0 3.2 0.64 Hydrofluoric Acid (Hydrogen Fluoride) 7664-39-3 0.10 0.020 Hydrogen Sulfide (H2S) 2148-87-8 1.4E-05 1.4E-05
Isopropyl alcohol (IPA, 2-Propanol) 67-63-0 4.6E-04 4.6E-04 Mercury 7439-97-6 3.3E-08 3.3E-08
Methanol (Methyl alcohol) 67-56-1 1.6E-04 1.6E-04
Methyl Bromide (Bromomethane) 74-83-9 4.6E-05 4.6E-05
Methyl Ethyl Ketone (2-butanone) 78-93-3 7.1E-05 7.1E-05 Methyl tert-Butyl Ether 1634-04-4 4.3E-05 4.3E-05
Methylene Chloride (dichloromethane) 75-09-2 0.049 0.049 Naphthalene 91-20-3 0.0035 0.0035
PAH Equivalents as Benzo(a)pyrene 1150/1151 6.8E-05 6.8E-05 Perchloroethylene (tetrachloroethylene) 127-18-4 0.027 0.027 Propene (Propylene) 115-07-1 0.0045 0.0045
Styrene 100-42-5 1.2E-04 1.2E-04
Toluene 108-88-3 0.0062 0.0063
Trichloroethylene 79-01-6 0.0056 0.0056
Vinyl Acetate 108-05-4 8.4E-05 8.4E-05
Vinyl Chloride (chloroethylene) 75-01-4 0.0073 0.0073
Xylene (Total) 1330-20-7 0.0050 0.0050
Notes:

1. Abbreviations:

BAAQMD - Bay Area Air Quality Management District
g - gram
s - second
Existing landfill flare TAC emission reductions were calculated based on BAAQMD estimates for biogas engines TAC emissions and assuming no abatement efficiency.

Pollutant CAS
Table 13
Modeled Emission Rates - Existing Landfill Flare Reductions Raven SR
Richmond, CA
1555
Construction Sources
Source
Dimension Release Height Initial Vertical Dimension
Initial Lateral
Dimension
[m] [m] [m] [m]
Construction Equipment1 Area 1 Approximate
Equipment Area 5.0 1.16 --
Fugitive Dust2 Area 1 Approximate
Equipment Area 0.0 1 --
Operational Sources3
Release Height
[m]
Green Waste Offgas Area 1 4.97
Stack Height Stack Velocity Exit Diameter Stack
Temperature
[m] [m/s] [m] °F
Biogas Engines Point 3 7.92 52.39 0.20 850
Flare Point 1 12.19 0.18 2.24 1,500
Fire Pump Engine Point 1 1.83 13.17 0.20 869
Existing Landfill Sources4
Stack Height Stack Velocity Exit Diameter Stack
Temperature
[m] [m/s] [m] °F
Flare Point 2 12.19 0.15 2.51 1,502
Notes:

1. 2.

3. 4.

Abbreviations:
°F - Fahrenheit
BAAQMD - Bay Area Air Quality Management District m - meter CRRP - Community Risk Reduction Plan s - second
HRA - Health risk assessment USEPA - United States Environmental Protection Agency References:

Source Source Type Number of
Sources
Source Source Type Number of
Sources
Table 14
Modeling Parameters
Raven SR
Richmond, CA
Number of
Sources Source Source Type
Source Source Type Number of
Sources
Construction off-road equipment was modeled as one area source covering the parcel under construction. According to the CRRP-HRA methodology, release height of a modeled area source representing construction equipment was set to 5 meters and the initial vertical dimension is set to the release height divided by 4.3.

Construction fugitive dust will be modeled as one area source covering the parcel under construction. According to the 2012 San Francisco Community HRA methodology, the initial vertical dimension of the modeled fugitive dust area source will be set to 1 meter and the release height will be set to 0 meters consistent with SCAQMD LST methods.

USEPA. 2022. User's Guide for the AMS/EPA Regulatory Model (AERMOD). Office of Air Quality Planning and Standards. Research Triangle Park, North Carolina. EPA-454/B-22-007, June 2022). Available at: https://gaftp.epa.gov/Air/aqmg/SCRAM/models/preferred/aermod/aermod_userguide.pdf South Coast Air Quality Management District (SCAQMD). 2008. Final Localized Significance Threshold Methodology. July. Available at:
http://www.aqmd.gov/docs/default-source/ceqa/handbook/localized-significance-thresholds/final-lst-methodology-document.pdf?sfvrsn=2 The existing landfill flare stack parameters were estimated by POWER Engineers and obtained from the Semi-Annual Monitoring Report 2021 submitted by West Contra Costa Sanitary Landfill to BAAQMD, available at: https://www.baaqmd.gov/~/media/files/engineering/title-vpermits/a1840/a1840_wccc_landfill_053122_2021_a-pdf.pdf?la=en&rev=af45f67469484d85b592e41dd6866b23 Bay Area Air Quality Management District (BAAQMD). 2012. The San Francisco Community Risk Reduction Plan: Technical Support Documentation.

December. Available at: https://www.gsweventcenter.com/Appeal_Response_References/2012_1201_BAAQMD.pdf.

Bay Area Air Quality Management District (BAAQMD). 2020. Health Risk Assessment Modeling Protocol. December. Available online at:
https://www.baaqmd.gov/~/media/files/ab617-community-health/facility-risk-reduction/documents/baaqmd_hra_modeling_protocol-pdf.pdf?la=en San Francisco Department of Public Health (SF DPH), San Francisco Planning Department (SF Planning), and Ramboll. 2020. San Francisco Citywide Health Risk Assessment: Technical Support Documentation. Available online at:
https://www.sfdph.org/dph/files/EHSdocs/AirQuality/Air_Pollutant_Exposure_Zone_Technical_Documentation_2020.pdf For Project operation, the biogas engines, flare, and fire pump engine are modeled as point sources. The green waste storage pile is modeled as an area source. Source parameters were provided by the Project Sponsor. 1556
Construction+Operation
Daily Breathing
Rate (DBR)1
Exposure
Duration (ED)2
Fraction of Time
at Home (FAH)3
Exposure
Frequency
(EF)4
Averaging
Time (AT)
Modeling
Adjustment
Factor5
Intake Factor,
Inhalation (IFinh)
[L/kg-day] [years] [unitless] [days/year] [days] [unitless] [m3/kg-day] 2023 3rd Trimester 361 0.46 1 350 25,550 1.0 0.0023
2023 Age 0-<2 Years 1,090 0.54 1 350 25,550 1.0 0.0081
2024 Age 0-<2 Years 1,090 0.24 1 350 25,550 1.0 0.0036
Age 0-<2 Years 1,090 1.22 1 350 25,550 1.0 0.0182
Age 2-<16 Years 572 14 1 350 25,550 1.0 0.11
Age 16-30 Years 261 14 0.73 350 25,550 1.0 0.037
2023 16-70 years 230 1 -- 250 25,550 4.2 0.0023
2024 16-70 years 230 0.24 -- 250 25,550 4.2 0.0005
Operation All 16-70 years 230 23.76 -- 250 25,550 4.2 0.053 2023 Age 2-<9 Years 640 1 -- 180 25,550 4.2 0.0045
2024 Age 2-<9 Years 640 0.24 -- 180 25,550 4.2 0.0011
Age 2-<9 Years 640 2.76 -- 180 25,550 4.2 0.0124
Age 2-<16 Years 520 4 -- 180 25,550 4.2 0.015
Operation-Only
Daily Breathing
Rate (DBR)1
Exposure
Duration (ED)6
Fraction of Time
at Home (FAH)3
Exposure
Frequency
(EF)4
Averaging
Time (AT)
Modeling
Adjustment
Factor5
Intake Factor,
Inhalation (IFinh)
[L/kg-day] [years] [unitless] [days/year] [days] [unitless] [m3/kg-day] 3rd Trimester 361 0.25 1 350 25,550 1.0 0.0012
Age 0-<2 Years 1,090 2 1 350 25,550 1.0 0.030
Age 2-<16 Years 572 14 1 350 25,550 1.0 0.11
Age 16-30 Years 261 14 0.73 350 25,550 1.0 0.037
Worker Operation All 16-70 years 230 25 -- 250 25,550 4.2 0.056 Age 2-<9 Years 640 4 -- 180 25,550 4.2 0.018
Age 2-<16 Years 520 4 -- 180 25,550 4.2 0.015
Notes:

1. 2.

3. 4.

5. 6.

Calculation:

IFinh = DBR * FAH * EF * ED * CF / AT
CF = 0.001 (m3/L)
Abbreviations:

AT - averaging time IFinh - intake factor
BAAQMD - Bay Area Air Quality Management District kg - kilogram DBR - daily breathing rate L - liter
ED - exposure duration m3
- cubic meter
EF - exposure frequency OEHHA - Office of Environmental Health Hazard Assessment References:

Table 15
Exposure Parameters
Raven SR
Richmond, CA
Population Receptor Age Group
Exposure Parameters
Project Phase Year
BAAQMD. 2020. Health Risk Assessment (HRA) Modeling Protocol. December.

OEHHA. 2015. Air Toxics Hot Spots Program Risk Assessment Guidelines. Guidance Manual for Preparation of Health Risk Assessments. February.

Daily breathing rates for residents reflect default breathing rates from OEHHA 2015 and BAAQMD 2016 as follows: 95th percentile 24-hour daily breathing rate for 3rd trimester and age 0-<2 years; 80th percentile for ages 2 years and older (per BAAQMD 2016 and 2020 Health Risk Assessment (HRA) Modeling Guidelines). Daily breathing rates for workers assume 230 L/kg-8 hours, which represents the 95th percentile 8-hour breathing rate based on moderate activity of 16-70 years-old age range, per BAAQMD 2016 and 2020 Health Risk Assessment (HRA) Modeling Guidelines. Daily breathing rates for school receptors reflect 95th percentile 8-hour daily breathing rates for Moderate Intensity Activity for all ages.

Exposure duration for residents is assumed to begin at the start of construction and continue for 30 years of operation. Exposure duration for workers is assumed to begin at the start of construction and continue for 25 years of operation. Exposure duration for school receptors was assumed to include ages 5-13 for children attending Kindergarten through 8th Grade.

Fraction of time spent at home is conservatively assumed to be 1 (i.e., 24 hours/day) for age groups from the third trimester to less than 16 years old based on the recommendation from BAAQMD (BAAQMD 2016 and 2020) and OEHHA (OEHHA 2015).

The fraction of time at home for adults age 16-30 reflects default OEHHA guidance (OEHHA 2015) as recommended by BAAQMD (2016 and 2020).

Exposure frequency reflects default resident, worker, and school receptor exposure frequencies from OEHHA 2015 and BAAQMD 2016.

Modeling adjustment factors are calculated based on the methodology from OEHHA's Guidance Manual for Preparation of Health Risk Assessments (2015). The MAF for the worker and school receptors is calculated to adjust from 24 hours/day to 8 hours/day and from 7 days/week to 5 days/week ([24 hours/8 hours] * [7 days/5 days] = 4.20). Resident types are expected to be exposed 24 hours/day and 7 days/week; as a result, the MAF is 1.

All
Operation All
BAAQMD. 2016. Air Toxics NSR Program Health Risk Assessment (HRA) Guidelines. January.

Resident
Construction Worker
School
Construction
Operation
Construction
Exposure duration for residents is assumed for 30 years of operation and for workers is assumed for 25 years of operation. Exposure duration for school receptors was assumed to include ages 5-13 for children attending Kindergarten through 8th Grade.

Population Project Phase Receptor Age Group
Exposure Parameters
Year
School
Resident Operation All
Operation All
1557
Cancer Potency
Factor
Acute Noncancer Reference
Exposure Level
Chronic Noncancer
Reference Exposure Level
(mg/kg-day)-1 (μg/m3) (μg/m3)
1,1-Dichloroethane (Ethylidene dichloride) 75-34-3 0.0057 -- -- 1,1-Dichloroethene (Vinylidene chloride) 75-35-4 -- -- 70 1,1,1-Trichloroethane (Methyl chloroform) 71-55-6 -- 68000 1000 1,1,2-Trichloroethane (Vinyl trichloride) 79-00-5 0.057 -- -- 1,1,2,2-Tetrachloroethane 79-34-5 0.2 -- --
1,3-Butadiene 106-99-0 0.6 660 2
1,4-Dichlorobenzene 106-46-7 0.04 -- 800
1,4-Dioxane (1,4-Diethylene dioxide) 123-91-1 0.027 3000 3000 Acetaldehyde 75-07-0 0.01 470 140
Acrolein 107-02-8 -- 2.5 0.35
Acrylonitrile 107-13-1 1 -- 5
Allyl Chloride (3-Chloropropene) 107-05-1 0.021 -- --
Ammonia 7664-41-7 -- 3200 200
Arsenic 7440-38-2 12 0.2 0.015
Benzene 71-43-2 0.1 27 3
Benzyl Chloride 100-44-7 0.17 240 --
Beryllium 7440-41-7 8.4 -- 0.007
Cadmium 7440-43-9 15 -- 0.02
Carbon Disulfide 75-15-0 -- 6200 800
Carbon Tetrachloride 56-23-5 0.15 1900 40
Chlorobenzene 108-90-7 -- -- 1000
Ethyl Chloride (Chloroethane) 75-00-3 -- -- 30000
Chloroform 67-66-3 0.019 150 300
Copper 7440-50-8 -- 100 --
Diesel particulate matter 9-90-1 1.1 -- 5
Dioxins PCDDs 1-08-6 130000 -- 0.00004
Ethylbenzene 100-41-4 0.0087 -- 2000
Ethylene Dibromide (1,2-dibromoethane) 106-93-4 0.25 -- 0.8 Ethylene Dichloride (1,2-dichloroethane) 107-06-2 0.072 -- 400 Formaldehyde 50-00-0 0.021 55 9
n-Hexane 110-54-3 -- -- 7000
Hydrochloric Acid (Hydrogen Chloride) 7647-01-0 -- 2100 9 Hydrofluoric Acid (Hydrogen Fluoride) 7664-39-3 -- 240 14 Hydrogen Sulfide (H2S) 7783-06-4 -- 42 10
Isopropyl alcohol (IPA, 2-Propanol) 67-63-0 -- 3200 7000 Lead 7439-92-1 0.042 -- --
Manganese 7439-96-5 -- -- 0.09
Mercury 7439-97-6 -- 0.6 0.03
Methanol (Methyl alcohol) 67-56-1 -- 28000 4000
Methyl Bromide (Bromomethane) 74-83-9 -- 3900 5
Methyl Ethyl Ketone (2-butanone) 78-93-3 -- 13000 --
Methyl tert-Butyl Ether 1634-04-4 0.0018 -- 8000
Methylene Chloride (dichloromethane) 75-09-2 0.0035 14000 400 Naphthalene 91-20-3 0.12 -- 9
Nickel 7440-02-0 0.91 0.2 0.014
PAH Equivalents as Benzo(a)pyrene 1-15-0 -- -- --
Perchloroethylene (tetrachloroethylene) 127-18-4 0.021 20000 35 Propene (Propylene) 115-07-1 -- -- 3000
Selenium 7782-49-2 -- -- 20
Styrene 100-42-5 -- 21000 900
Toluene 108-88-3 -- 5000 420
Trichloroethylene 79-01-6 0.007 -- 600
Vanadium 7440-62-2 -- 30 --
Vinyl Acetate 108-05-4 -- -- 200
Vinyl Chloride (chloroethylene) 75-01-4 0.27 180000 --
Xylene (Total) 1330-20-7 -- 22000 700
Notes:

1. Abbreviations:
-- - not available or not applicable mg/kg-day - milligrams per kilogram per day ARB - Air Resources Board OEHHA - Office of Environmental Health Hazard Assessment Cal/EPA - California Environmental Protection Agency µg/m3 - micrograms per cubic meter
CAS - chemical abstract services
Reference:

Table 16
Toxicity Values
Raven SR
Richmond, CA
Cal/EPA. 2022. OEHHA/ARB Consolidated Table of Approved Risk Assessment Health Values. September. Available at:
http://www.arb.ca.gov/toxics/healthval/contable.pdf.

Chemical1 CAS Number
Toxicity values are taken from ARB's Consolidated Table of OEHHA/ARB Approved Risk Assessment Health Values. 1558
Excess Lifetime
Cancer Risk (in
a million)1
Non-Cancer
Hazard Index
(unitless)2,3
Acute Hazard
Index
(unitless)4
PM2.5
Concentration
(µg/m3, Annual
Average)3
Excess Lifetime
Cancer Risk (in
a million)1
Non-Cancer
Hazard Index
(unitless)2,3
Acute Hazard
Index
(unitless)4
PM2.5
Concentration
(µg/m3, Annual
Average)3
Project Construction +
Operations 2.0 0.079 0.15 0.57 0.33 0.0042 0.022 0.030
Project Operations 2.0 0.079 0.15 0.57 0.31 0.0042 0.022 0.030 Landfill Reductions -16 -0.66 -1.6 -0.84 -2.8 -0.040 -0.22 -0.051 Project Construction +
Operations with Landfill
Reductions
-14 -0.58 -1.4 -0.27 -2.5 -0.036 -0.20 -0.021
Project Operations with
Landfill Reductions -14 -0.58 -1.4 -0.27 -2.5 -0.036 -0.20 -0.021

BAAQMD CEQA
Significance Threshold5 10 1.0 1.0 0.30 10 1.0 1.0 0.30 Excess Lifetime
Cancer Risk (in
a million)1
Non-Cancer
Hazard Index
(unitless)2,3
Acute Hazard
Index
(unitless)4
PM2.5
Concentration
(µg/m3, Annual
Average)3
Excess Lifetime
Cancer Risk (in
a million)1
Non-Cancer
Hazard Index
(unitless)2,3
Acute Hazard
Index
(unitless)4
PM2.5
Concentration
(µg/m3, Annual
Average)3
Project Construction +
Operations 0.20 0.0045 0.018 0.032 0.17 0.0023 0.016 0.016 Project Operations 0.20 0.0045 0.018 0.032 0.17 0.0023 0.016 0.016 Landfill Reductions -1.6 -0.037 -0.17 -0.047 -1.4 -0.021 -0.14 -0.026 Project Construction +
Operations with Landfill
Reductions
-1.4 -0.033 -0.15 -0.015 -1.3 -0.018 -0.12 -0.010
Project Operations with
Landfill Reductions -1.4 -0.033 -0.15 -0.015 -1.3 -0.018 -0.12 -0.010

BAAQMD CEQA
Significance Threshold5 10 1.0 1.0 0.30 10 1.0 1.0 0.30 Notes:

1. 2.

3. 4.

5. Abbreviations:

ASF - Age Sensitivity Factors PM2.5 - particulate matter 2.5 microns or less CPF - Cancer Potency Factor REL - Reference Exposure Level HI - hazard index TAC - Toxic Air Contaminant
HQ - hazard quotient ug - microgram
m - meter UTM - Universal Transverse Mercator
MEI - maximally exposed individual
References:

Table 17
Project Health Impacts
Raven SR
Richmond, CA
Source
School Clinic
Source
Worker Resident
Thresholds from BAAQMD California Environmental Quality Act (CEQA) 2017 Guidelines.

California Environmental Quality Act (CEQA) 2017 Guidelines. Available at: http://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa_guidelines_may2017-pdf BAAQMD. Regulation 2 Permits Rule 5 New Source Review of Toxic Air Contaminants. Available at: https://www.baaqmd.gov/~/media/dotgov/files/rules/reg-2-permits/2021- amendments/documents/20211215_rg0205-pdf.pdf?la=en&rev=c403a2e96fde4799b1aa950cd4367aa2 Excess lifetime cancer risks are estimated as the upper-bound incremental probability that an individual will develop cancer over a lifetime as a direct result of exposure to potential carcinogens. The estimated risk is expressed as a unitless probability. The cancer risk attributed to the emissions associated with the Project was calculated based on the modeled annual average concentration, the intake factor for a resident child, the Cancer Potency Factors (CPF) for the TACs, and the Age Sensitivity Factors (ASF).

The potential for exposure to result in adverse chronic noncancer effects is evaluated by comparing the estimated annual average air concentration to the noncancer chronic Reference Exposure Level (REL) for each chemical. When calculated for a single chemical, the comparison yields a ratio termed a chronic hazard quotient (HQ). To evaluate the potential for adverse chronic noncancer health effects from simultaneous exposure to multiple chemicals, the chronic hazard quotients for all chemicals are summed, yielding a hazard index (HI).

PM2.5 concentration and Non-Cancer Hazard Index represent annual values.

The acute non-cancer HI analysis assumes that all sources are operating in any one hour time period, which is a conservative assumption. 1559
Lifetime Excess Cancer
Risk1 PM2.5 Concentration1
(in a million) (µg/m3)
Existing Stationary Sources -- -- --
Highway2 1.3 -- 0.026
Major Streets2 0.46 -- 0.014
Roadway Total 1.8 -- 0.040
Railways2 3.7 -- 0.0049
Existing Total 5.4 -- 0.045
Project Construction + Operations
with Landfill Reductions -14.04 -0.58 -0.27
Total -8.6 -0.58 -0.227
Exceeds Threshold? NO NO NO
Existing Stationary Sources -- -- --
Highway2 1.3 -- 0.026
Major Streets2 5.30 -- 0.168
Roadway Total 6.6 -- 0.194
Railways2 4.3 -- 0.0059
Existing Total 10.9 -- 0.200
Project Construction + Operations
with Landfill Reductions -2.48 -0.04 -0.02
Total 8 -0.04 0.18
Exceeds Threshold? NO NO NO
Existing Stationary Sources -- -- --
Highway2 2.1 -- 0.042
Major Streets2 1.14 -- 0.032
Roadway Total 3.2 -- 0.074
Railways2 14.9 -- 0.0202
Existing Total 18.1 -- 0.094
Project Construction + Operations
with Landfill Reductions -1.37 -0.03 -0.01
Total 17 -0.03 0.079
Exceeds Threshold? NO NO NO
Existing Stationary Sources -- -- --
Highway2 1.4 -- 0.029
Major Streets2 1.37 -- 0.039
Roadway Total 2.8 -- 0.067
Railways2 5.6 -- 0.0077
Existing Total 8.4 -- 0.075
Project Construction + Operations
with Landfill Reductions -1.27 -0.02 -0.01
Total 7.1 -0.02 0.065
Exceeds Threshold? NO NO NO
Existing Stationary Sources -- -- --
Highway2 1.3 -- 0.026
Major Streets2 0.46 -- 0.014
Roadway Total 1.8 -- 0.040
Railways2 3.7 -- 0.0049
Existing Total 5.4 -- 0.045
Project Operations with Landfill
Reductions -14.08 -0.58 -0.27
Total -8.6 -0.58 -0.227
Exceeds Threshold? NO NO NO
Existing Stationary Sources -- -- --
Highway2 1.3 -- 0.026
Major Streets2 5.30 -- 0.168
Roadway Total 6.6 -- 0.194
Railways2 4.3 -- 0.0059
Existing Total 10.9 -- 0.200
Project Operations with Landfill
Reductions -2.50 -0.04 -0.02
Total 8 -0.04 0.18
Exceeds Threshold? NO NO NO
Existing Stationary Sources -- -- --
Highway2 2.1 -- 0.042
Major Streets2 1.14 -- 0.032
Roadway Total 3.2 -- 0.074
Railways2 14.9 -- 0.0202
Existing Total 18.1 -- 0.094
Project Operations with Landfill
Reductions -1.37 -0.03 -0.01
Total 17 -0.03 0.079
Exceeds Threshold? NO NO NO
Existing Stationary Sources -- -- --
Highway2 1.4 -- 0.029
Major Streets2 1.37 -- 0.039
Roadway Total 2.8 -- 0.067
Railways2 5.6 -- 0.0077
Existing Total 8.4 -- 0.075
Project Operations with Landfill
Reductions -1.27 -0.02 -0.01
Total 7.1 -0.02 0.065
Exceeds Threshold? NO NO NO
Threshold 100 10 0.80
School
Clinic
Operation
Worker
Resident
Clinic
Construction + Operation
Worker
Resident
School
Table 18
Cumulative Health Impacts
Raven SR
Richmond, CA
Scenario Receptor Type Source Noncancer Chronic
HI1
1560
Table 18
Cumulative Health Impacts
Raven SR
Richmond, CA
Notes:
1 2
Abbreviations:

HI - hazard index PM2.5 - particulate matter less than 2.5 microns m
3 - cubic meter µg - microgram
MEIR - maximum exposed individual receptor
References:

If the cell is marked with "--", no risk was calculated. For existing stationary sources, this is because the source was more than 1,000 feet from the onsite MEIR. For roadways, the chronic HI is not calculated in the BAAQMD screening tool.

Cancer risk and PM2.5 concentration values were determined using BAAQMD screening tools and are based on the maximum impact of a raster cell located on the MEIR.

Bay Area Air Quality Management District (BAAQMD). 2020. Permitted Sources Risk and Hazards Map. June. Available at:
https://baaqmd.maps.arcgis.com/apps/webappviewer/index.html?id=2387ae674013413f987b1071715daa65 Bay Area Air Quality Management District (BAAQMD). 2020. Health Risk Calculator Beta 4.0. March. Available at: https://www.baaqmd.gov/~/media/files/planning-andresearch/ceqa/tools/baaqmd-health-risk-calculator-beta-4-0-xlsx.xlsx?la=en&rev=dab7d85a772d45caa9c99e59395bf12d\ 1561
180 Grand Avenue
Suite 1050
Oakland, CA 94612
510.839.5066 phone
510.839.5825 fax
esassoc.com
Memorandum
date April 25, 2023
to Lina Velasco, Director, Director of Community Development from Crescentia Brown, Project Director, ESA
Tim Sturtz, Project Manager, ESA
subject RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

1.0 Background

1.1 Original IS/MND
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 proposed Project involves the construction and operation of a bioenergy facility that converts food and green waste into transportation-grade hydrogen for various renewable energy products (PLN21-282). 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, to allow for additional opportunity for public review. Approximately 19 written comments were received during this period.

Although not required by CEQA, the City responded in writing to all written comments received on the IS/MND during the public review period. The Project was then presented to the City’s Planning Commission at a public hearing on December 15, 2022, to consider approval of the Project by approval of the IS/MND and Mitigation Monitoring and Reporting Program (MMRP) and Design Review and Conditional Use Permit. After consideration of all the evidence before it, including public comment, both written and oral, the Planning Commission then approved the Project. The approval was then appealed.

1.2 Updated IS/MND
Given the comments provided during the December 15, 2022, hearing and in the written appeal, the City prepared an Updated IS/MND that contained additional information that clarified, amplified, or otherwise more fully explained the information in the original IS/MND. Although recirculation of the Updated IS/MND was not required by CEQA, the City recirculated that document to make the additional clarifying information available to the public for review and comment. The public review and comment period on the Updated IS/MND was originally March 9, 2023 through April 7, 2023, and was then re-noticed on March 14, 2023, and extended to April 12, 2023. A total of 19 written comments were received during that period. 1562
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 2 Each commenter is listed below in Table 1. Again, while not required by CEQA, the City has responded in writing – individually or by master responses - to all written comments received during the public review period; all comments and responses are presented in Section 2.0.

TABLE 1

COMMENT LETTERS RECEIVED ON THE IS/MND
Letter # Entity
Author(s) of Comment
Letter/e-mail Comment Date
Page
No.

Agencies – Public / Quasi-Public
A EBMUD David J. Rehnstrom, Manager of
Water Distribution Planning
March 29, 2023 7
B Port of Oakland Danny Wan, Executive Director April 12, 2023 13 C CalRecycle Harprit Mattu, Environmental
Scientist
April 12, 2023 17
Organizations
D Communities for a Better
Environment
Donnie Cho, Staff Attorney;
Tessa Wardle, Northern
California Staff Researcher;
Keala Uchoa, Richmond Youth
Organizer
April 12, 2023 21
E National Resources Defense Council Ann Alexander, Senior Staff Attorney
April 12, 2023 35
F Sierra Club, San Francisco Bay Norman La Force, Vice-Chair April 12, 2023 37 G Energy Efficiency Finance Corp. John C. MacLean, President April 12, 2023 39 H Sunflower Alliance Shoshana Wechsler, CoCoordinatorApril 12, 2023 45 I International Union of Elevator
Constructors
Ryan Lange, Business
Representative
April 5, 2023 47
J Sprinkler Fitters and Apprentices Jeffrey J. Dixon, Business Manager / Financial Secretary
April 5, 2023 49
K International Brotherhood of
Electrical Workers
Tom Hansen, Business
Manager
April 4, 2023 53
L Contra Costa Building and
Construction Trade Council
Bill Whitney April 4, 2023 55
Individuals
M Griselda Rivera-Orochena Richmond Community Member April 12, 2023 57 N Ayush Dahal Youth San Pablo Resident April 12, 2023 61 O Gil Friend - April 12, 2023 65
P Lazuli Trujano Richmond Community Member
and CBE Community Organizer
April 11, 2023 69
Q Anna Henry - April 10, 2023 71
R Maxim Scrogin - April 5, 2023 75
S Sunari Weaver-Anderson North Richmond Community
Member & Occidental College
Student (Class of 2024)
Undated 77
Attachments
1 (to Letter D) – West Contra Costa Sanitary Landfill (WCCSL) Summary Report (2021-2070) 2 (to Letter D) – Pacific Gas and Electric Company’s (PG&E) Preliminary Engineering Study (PES), 2022 3 (to Response to Letter D) – Raven One Hydrogen Vent Sound Attenuation, 2023 1563
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 3 2.0 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.

2.1 Consolidated Response: Conditions Requiring Preparation of an EIR
Numerous public comments received on the October 2022 IS/MND and March 2023 Updated IS/MND assert that the City should reverse its approval of the IS/MND and, instead, prepare a full Environmental Impact Report (EIR). This is a comprehensive response to address this recurring topic, and it is intended to reduce repetitive responses in this Comments and Responses section. Individual comments to which this Consolidated Response relates are Response to Comments D-1, D-8, H-1, M-3, N-3, P-5, Q-9 and S-6.

2.1.1 CEQA Guidance
CEQA only requires preparation of an EIR “if there is substantial evidence, in light of the whole record before the lead agency, that the project may have a significant effect on the environment.” (Public Resources Code [PRC] section 21080(d)) To assess whether an EIR is warranted, the City, as Lead Agency, conducted preparation of an Initial Study, reflecting its independent judgement, to determine if the Project would have a significant effect on the environment. Pursuant to CEQA Guidelines, the Initial Study considered all phases of the proposed Project; relied on expert opinion supported by facts, technical studies or other substantial evidence to document its findings; and circulated the Initial Study for public review. (CEQA Guidelines section 15063(1) through 15063(4))
As described in Section 1.0 (Background), the City prepared and circulated the updated Initial Study that clarified, amplified, or otherwise more fully explained the Project and certain analyses. The analysis presented in the October 2022 IS/MND and the March 2023 Updated IS/MND showed that there was no substantial evidence in the record that the proposed Project may have a significant effect on the environment (CEQA Guidelines section 15570). Mitigation measures are identified to reduce potentially significant impacts to less than significant, supported by substantial evidence in the Updated IS/MND and its appendices.

2.1.2 IS/MND Analysis and Findings
Some comments suggest that a fair argument remains that significant impacts exist regarding air quality, cumulative impacts, and hazards and safety. Each is discussed below.

Air Quality and Human Health Risk
Section 4.3, Air Quality, of the October 2022 IS/MND presents the air quality analysis for construction and operations of the proposed Project and cumulative conditions, conducted in accordance with methodology used by BAAQMD. The result of that analysis was that the proposed Project would not exceed any applicable thresholds of significance to result in any potentially significant air quality impacts. Preparation of the March 2023 Updated IS/MND clarified the air quality analysis, which resulted in updates to criteria pollutant emissions, none of which changed the original less-than-significant impacts previously identified. 1564
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 4 The HRA was presented as Appendix A to the Updated IS/MND. The HRA involved dispersion models of the immediate area, developed in accordance with methodology used by BAAQMD and studied, with a focus on nearby receptors as identified by the appellants in the appeal. Although the nearest sensitive receptor is located farther than the 1,000-foot distance, the analysis included a Health Risk Assessment (HRA) to quantify construction-related and operational emissions and associated health risks during Project construction and operation for an area within 6,000 feet of the proposed Project footprint. Also, while conducting the HRA, corrections were made to prior calculation errors involving a duplication of emissions. The net result of the corrections was that the emissions profile of the Project was reduced.

The HRA determined that, “The proposed project provides an overall reduction of cancer risk, chronic hazard index, acute hazard index, and particulate matter concentrations as compared to the portions of the existing landfill flare operation it would be replacing.” Thus, the HRA and the Updated IS/MND determined that the Project would result in less-than-significant environmental impacts to the community.

The results of the HRA confirmed the October 2022 IS/MND finding of no significant impacts; the Project’s potential impacts during its construction and operation phases were below thresholds of significance for impacts on overburdened communities. Similarly, the analysis in the Updated IS/MND determined that the Project would not result in a significant air quality or health risk impact impacts to any sensitive receptors. Overall, the substantial evidence contained in the Updated IS/MND and its Appendix A supports that the Project would not result in a significant air quality or health risk impacts.

Cumulative Impacts
A recurring concern of several commenters suggest that the Project analysis speculates about the potential and cumulative pollution impacts resulting from two other hydrogen projects in the Richmond area. Footnote 9 on page 12 of the Updated IS/MND describes how “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,” details the separate and speculative nature of the other projects, and explains that CEQA does not require analysis of speculative projects that have yet to be received.

Further, the Updated IS/MND explains that future hydrogen-related projects submitted to the City after the Raven Project (or at some future date) would be required to comply with CEQA. Those CEQA analyses would include consideration of the Raven Project in either the baseline or a reasonably foreseeable project (assuming that the type of project impacts overlap for the purposes of a cumulative analysis). For these reasons, the cumulative pollution impact analysis in the Updated IS/MND is appropriate and clearly described; no relevant information gaps exist. Substantial evidence contained in the Updated IS/MND and its Appendix A supports that the Project would not result in a significant cumulative impact.

Safety
Appellants and numerous other comments suggest that the October 2022 IS/MND was vague in describing an intent for the Project to comply with various health, hazard, and process safety management regulations. In the IS/MND, the Project was described as being subject to various local, state, and federal programs governing the health and safety of workers in industry. Section 2.6 (Operations) of the Updated IS/MND IS/MND also referred to Raven SR’s intended compliance with the OSHA Process Safety Management (29 CFR 1910.119) and the EPA Risk Management Program (Section 112(r) of the Clean Air Act), commonly referred to as PSM/RMP. 1565
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 5 These programs provide a process for safety, mechanical reliability and operator involvement. PSM/RMP is mandatory for systems that exceed a threshold of 10,000 pounds of flammable material. The proposed Project will not exceed this threshold, but will voluntarily comply with the program requirements. Various other programs administered at the state and local levels require documentation and reporting (with periodic audit of the site and updating of requisite documentation) for processes associated with the Project’s operations and maintenance. An Individual Response (D-12 to Letter D in the following section) details the Raven team’s experts who were selected for their expertise in characterizing and evaluating best practices regarding the mitigation of pollutants, health risks, and plant operations and that have undertaken standard, reasonable efforts and best management practices to mitigate foreseeable risks and to incorporate standard best management practices into the Project design and operation. The standards and practices for engineering, design, and operation that are and will be utilized, with ever improving sensors and instrumentation for process control, reasonably demonstrate the intent and capability of the Project to minimize and mitigate risk. For all the reasons above, the Updated IS/MND is clear and detailed about the Project’s intent regarding compliance with all applicable health and safety management regulations. No relevant information gaps exist.

2.1.3 Conclusion
In summary, the Updated IS/MND determined that all potentially significant environmental impacts with the Project would be mitigated to a less-than-significant level, including the topics of concern raised in numerous comments, as discussed above. (Each impact and corresponding mitigation measure for the Project is identified in the Updated Draft Mitigation Monitoring and Reporting Program (MMRP) (Appendix C to the Updated IS/MND). Overall, for all the reasons above, and given the substantial evidence the Updated IS/MND, its appendices, and this document, no relevant information gaps exists. Nor does the proposed Project result in significant cumulative impacts that would trigger the need for a full EIR.

2.2 Individual Comments and Responses
The following pages present each comment letter with each individual comment bracketed with a numeric code, followed by the corresponding response.
1566
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 6 This page is intentionally blank.
1567
A-1 Letter A
A-2
1568
A-3
A-2
(cont.)
1569
1570
SS
W
U
U
FC

RIGHT OF WAY
MIN 20’

APPLICANT PIPELINE

DESIGN CRITERIA

RIGHT OF WAY EXTENDS
5’ BEYOND APPURTENCES
FC

SUBGRADE

FINISH GRADE

NO PERVIOUS PAVEMENT

NO HYDRANTS ON CURVES,

STREET CORNERS, OR
WITHIN 5' OF DRIVEWAY
24"
36"
5'min
10'min
7'min
5'min
12"min
12"min 12"min 12"min
SD 4'min

JOINT TRENCHES

SHALL NOT

CONFLICT WITH

THE CRITERIA IN

THE DIAGRAM
4203 • 5/21
W = WATER
24" cover to subgrade
36" cover to final grade
7' inset from face of curb
U = UTILITY
min 12" vertical clearance
min 5' horizontal clearance
SD = STORM DRAIN
min 12" below water
min 4' horizontal clearance
SS = SANITARY SEWER
min 12" below water
min 10' horizontal clearance
FC= FACE OF CURB
1571
March2021
Applicant Pipeline Design Criteria
EBMUD values applicant pipeline projects and is committed to providing a thorough and efficient design.

To ensure an efficient design process and to avoid significant delays the design criteria below should be adhered to when submitting improvement plans.

Design Criteria
 Water mains shall be seven (7) feet from face of curb.  Water mains shall maintain a minimum one (1) foot vertical and five (5) foot horizontal clearance from other utilities.
 Gas mains shall meet the one (1) foot vertical separation requirement by installing the gas main below the water main only.
 Water mains shall maintain a minimum ten (10) foot horizontal clearance (O.D. to O.D.) and be located a minimum one (1) foot above any sewer main. Title 22 CCR  Water mains shall maintain a minimum four (4) feet horizontal clearance (O.D. to O.D.) and be located a minimum one (1) foot above any storm drain. Title 22 CCR  Water mains shall have a 36-inch cover to final grade and 24-inch cover to pavement subgrade.  Joint trenches that are in conflict with the criteria above may delay the project. Submit to EBMUD final joint trench plans (no intent plans) which include the size of the joint trench and the utilities located inside.
 Water mains shall not be installed under pervious pavement.  Water mains installed under decorative pavement, pavers, or stamped concrete will require an additional paving agreement.
 Hydrants shall not be located on curved sections of street, street corners, or within five feet of a driveway.
 Right of ways for 6-inch and 8-inch water mains shall be a minimum of 20 feet wide and extend five (5) feet past the water main centerline.
 Right of ways for 12-inch to 24-inch water mains shall be a minimum of 20 feet wide and extend eight (8) feet past the water main centerline.

Please contact the New Business Office representative assigned to your project if there are any questions regarding the requirements listed above. Meeting this criteria will enable the most efficient design possible.
1572
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 12 Responses to Letter A - EBMUD
A-1 The City acknowledges EBMUD’s conditions of approval for water service stated in the comment. The City would require the Project applicant, Raven SR, to adhere to the conditions of approval of such service, including the request for a water service estimate to further determine the costs and conditions of providing water service for the proposed Project. Specifically, as stated in Updated IS/MND Section

4.17, Utilities and Service Systems, (Criterion “b”), EBMUD service would be granted subject to the Project’s “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….” A-2 If approved, the proposed Project would be required to adhere to all applicable permitting requirements and conditions that pertain to EBMUD's provision of water services, including rights-of-way and separation requirements as stated in the comment. The IS/MND explains that current water service and infrastructure at and near the Project site are serviced and maintained by EBMUD, as well as comply with all EBMUD design standards, which includes that the design not result in EBMUD having to handle hazardous materials.

A-3 No recycled water infrastructure currently exists at the Project site. In compliance with the Project’s Condition of Approval (COA) #68, the Project shall make every effort to use reclaimed wastewater, should it become available, for daily operations; and Project COA #69 (Water Conservation Measures) directs the Project to incorporate water conservation measures into the construction and landscaping of the site, in compliance with all applicable City water conservation ordinances and be consistent with East Bay Municipal Utility District (EBMUD) policies and guidelines. ________________________
1573
April 12, 2023
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Re: Raven SR’s Conditional Use Permit Application
Dear Ms. Elias,
The Port of Oakland (Port) is writing in support of Raven SR’s Conditional Use Permit for the construction and operation of a bioenergy facility at Republic Service’s closed West Contra Costa County Sanitary Landfill.

The Port of Oakland is committed to achieving zero-emissions operations. The Port believes that hydrogen fuel is an important initiative that will complement other carbon-free energy solutions, such as solar, hydro, wind, and battery storage technologies that are all needed to reach California’s clean air, clean energy, and climate goals.

Projects like Raven SR’s are needed to ensure that there is a local supply of clean hydrogen fuel available for use as a transportation fuel at the Oakland seaport and airport. Clean hydrogen fuel can also be used to generate clean electricity in microgrids, which will improve resilience and lessen demand on the power grid.

The Port of Oakland is eager to support projects that help commercialize zero-emissions technologies. Clean hydrogen fuel will contribute towards California’s efforts to eliminate reliance on fossil fuels. We urge the City of Richmond to approve Raven SR’s Conditional Use Permit so they may begin construction this year and start production in early 2024.

Please contact Ms. Tracy Fidell, Port Associate Environmental Planner/Scientist ([email protected]) if you have further questions regarding this letter of support.

Sincerely,
Danny Wan
Executive Director
B-1
1574
2 Lydia lias
City of Richmond
April 12, 2023
Pg. 2
CC:

Kristi McKenney, Chief Operating Officer
Matthew Davis, Director of Governmental Affairs
Colleen Liang, Acting Director of Environmental Programs and Planning 1575
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 15 Responses to Letter B – Port of Oakland
B-1 The comment is in support of the proposed Project and discusses merits of the Project. It does not raise a significant environmental issue, concerns about the environmental analyses, or information in the IS/MND. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the IS/MND and the proposed Project. ________________________
1576
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 16 This page is purposefully blank.
1577
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
Yana Garcia
Secretary for Environmental Protection
Rachel Machi Wagoner
CalRecycle Director
April 12, 2023
Lydia Elias, Planner I
City of Richmond Planning Department
450 Civic Center Plaza
Richmond, CA 94804
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 an Updated Initial Study/Mitigated Negative Declaration (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 updated IS/MND document is meant to clarify, amplify, and refine the language of the draft IS/MND.

Among others, the update provides additional description of proposed operational details, information from a health risk assessment (HRA), and more details regarding the project’s impacts on air quality and greenhouse gases. The Updated Initial Study/Mitigated Negative Declaration has concluded that the proposed project will not result in any adverse effects which fall within the “Mandatory Findings of Significance” contained in Section 15065 of the State CEQA Guidelines.

The project site is located at 1 Parr Boulevard, in the City of Richmond, Contra Costa County, California. It 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 the environmental document, the project would occur within approximately 2.5 acres of the existing Bulk Materials Processing Center (BMPC) 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 C-1 Letter C
1578
1001 I Street, Sacramento, CA 95814 | P.O. Box 4025, Sacramento, CA 95812 www.CalRecycle.ca.gov | (916) 322-4027
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 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-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 reduce existing flaring of landfill gas (LFG) produced from the decomposition of organic solid wastes in the WCCSL facility, and would help reduce greenhouse gas emissions and produce renewable “green” hydrogen using a low-carbon process. The project would also involve the construction of a modular structure and industrial canopy.

Comments
CalRecycle does not have any additional comments beyond the comments previously submitted for the Draft Initial Study/Mitigated Negative Declaration on November 7, 2022.

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].

C-1
(cont.) C-2 C-3
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1001 I Street, Sacramento, CA 95814 | P.O. Box 4025, Sacramento, CA 95812 www.CalRecycle.ca.gov | (916) 322-4027
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
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RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 20 Responses to Letter C - CalRecycle
C-1 The comment accurately describes characteristics of the proposed Project. No additional comment is made.

C-2 The comment confirms that it has no additional comments on the IS/MND than previously submitted.

C-3 The comment does not raise a significant environmental issue, concerns about the environmental analyses, or information in the IS/MND. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the proposed Project. The comment also specifies a duration of advance noticing for any hearing or decision on the proposed Project, which is consistent with the City’s 10-day advance notice issued prior to the May 16, 2023, public hearing on the appeal and the Project.
________________________
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April 12, 2023
Via electronic mail ([email protected])
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, P.O. Box 4046
Richmond, CA 94804
Re: Updated IS/MND Documents for Raven SR Bioenergy Project Dear Lydia Elias,
Thank you for the opportunity to comment on a revised Initial Study/Mitigated Negative Declaration (IS/MND) for the Raven SR Bioenergy Project. We appreciate the added detail in the revised IS/MND aimed at addressing the points we raised in our appeal. However, after extensive engagement with Richmond community members, we continue to believe any new development in Richmond –especially North Richmond
1– should not risk any sustained increase in air pollution emissions or industrial safety risks. Furthermore, under the California Environmental Quality Act (CEQA), there is still a fair argument that there are potentially significant impacts on air quality; cumulative impacts; hazards and safety, as raised in our appeal filed December 19, 2022.
2 Therefore, the Richmond City Council should reverse
the Richmond Planning Commission decision to approve an IS/MND and undertake a full Environmental Impact Review before permit approval.
3 Before enumerating our outstanding concerns about the IS/MND, we begin with a broader observation.

Upon reviewing the revised analysis, our community has been dismayed to learn of the excessive flaring currently taking place at the West Contra Costa Sanitary Landfill (WCCSL). Contra Costa County, the City, West Contra Costa Sanitary Landfill, Inc., and Republic Services should have prevented this avoidable pollution through upgrades to the now-defunct biogas engines.

Regarding the updated Raven SR IS/MND, we are thankful that the project proponent has provided the City with additional meaningful analysis and detail about the project aimed at addressing the majority of 3 Under the City of Richmond CEQA Guidelines and Procedures, Section 11.2.I.1 on Appeal Decisions: “The City Council shall affirm, modify, or reverse the original decision…[and when modified or reversed]...state the specific reasons…If the decision to require an ND or MND is reversed, an EIR shall be prepared.” Available at:
https://www.ci.richmond.ca.us/DocumentCenter/View/307/CEQA-Guidelines-and-Procedures?bidId=. 2 We incorporate by reference any unaddressed issues from the appeal filed December 19, 2022. 1 Office of Environmental Health Hazards Assessment (OEHHA), CalEnviroScreen 4.0. Available at https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40. 1 D-1 D-2 D-3 Letter D
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our concerns in the appeal. However, as we will detail below, not all concerns have been alleviated and additional concerns arise from the updates provided.

Summary of Key Outstanding Concerns

1. The City fails to treat polluting emissions from landfill gas flaring consistently.

2. The City fails to analyze and provide safeguards for the inevitable decline of landfill gas.

3. The potential for unacceptable levels of dioxin formation in the hydrogen production process itself has not been evaluated or mitigated.

4. The City must be explicit about whether hydrogen will be flared or vented as a safety practice, with proper air quality and greenhouse gas (GHG) impact analysis as well as mitigation.

5. The City should consider additional mitigation measures and community benefits in a full EIR process.

1. The City fails to treat polluting emissions from landfill gas flaring consistently.

While we appreciate that the analysis of the Raven SR project anticipates a decrease in flaring at the WCCSL by bringing in more efficient biogas engines, we are surprised that the project proponent is seeking to claim these reductions as part of their project without also accounting for the emissions coming from any continued flaring of landfill gas that remains. The reduction in landfill gas flaring and the remaining landfill gas flaring are inextricably linked, and it does not make sense to account for one part of this equation without taking into account the other. While we applaud the conservative approach in considering the scenario of the biogas engines running on 55% landfill gas, there would still be landfill gas flaring taking place as a part of this connected system. Therefore, either both the landfill gas flare reductions and the continued flaring emissions should be considered, or neither should.

In Table 4.3-4, the IS/MND provides projected emissions from project operations, including the reductions in flared landfill gas. However, missing from these calculations are the emissions from continued flaring of the remaining landfill gas that will continue to occur alongside the Raven SR project.

In this table, we observe that without the landfill gas flaring reductions, the project operations would exceed the BAAQMD significance threshold for NOx emissions. 4,5

2. The City fails to analyze and provide safeguards for the inevitable decline of landfill gas.

While we appreciate the added mention in the revised IS/MND of what would happen when the landfill gas declines and eventually runs out, it is still insufficient. It is important that the City explicitly require a system with a backstop in place to control the Pressure Swing Absorption Unit tail gas emission once the landfill gas runs out. The City should direct the project applicant to create a thoughtful plan for 5 Additionally, as stated in our appeal letter, regulatory guidelines are not meant to invalidate substantial evidence of a fair argument that there is a significant environmental effect. The City can and should use its independent responsibility to look at evidence beyond any regulatory standards from other agencies to decide whether an EIR must be prepared. See Bay Area Air Quality Management District (BAAQMD), CEQA Guidelines, Section 1.1 Purpose, https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa_guidelines_may2017-pdf. 4 Either way, any potentially significant impact should trigger an EIR, even if a project may provide a “net” benefit in some areas. See e.g., Lighthouse Field Beach Rescue v. City of Santa Cruz (2005) 131 Cal.App.4th 1170. 2 D-3
(cont.) D-4 D-5
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reconfiguration under this inevitable future condition, and to clarify that the project proponent will need to return to the City for approval of such a reconfiguration.

3. There is potential for unacceptable levels of dioxin formation in the hydrogen production process that has not been evaluated or mitigated.

While we also greatly appreciate the additional modeled emissions calculations for toxic air contaminants from the biogas engines in the Updated IS/MND
6 , there is still concern regarding dioxin formation in the hydrogen production process itself. The project in Richmond would constitute a pilot project for this specific proprietary technology. This is still a relatively novel technology with aspects that need further evaluation and mitigation, such as the potential formation of dioxins and furans (which can also be referred to as Polychlorinated dibenzo-p-dioxins and furans (PCDD/Fs). 7,8 One study found: “. . . a recent
assessment of the literature indicates that [biomass] gasification cannot always reduce PCDD/Fs emissions to acceptable levels, and thus a common belief on the replacement of incineration with gasification in order to reduce PCDD/Fs emissions seems overly simplistic.” 9 In other words, there is the
potential for dioxin formation above acceptable levels in biomass gasification projects. This potential also exists in an atmosphere without oxygen, as identified in a 2021 study by Kirkok et al. where the authors suggest that one hypothesis for this is the presence of oxygen in feedstock materials. 10 Dioxins are persistent and highly toxic compounds at low levels, and the potential formation of dioxins during this project’s process must be studied and minimized. 11 These studies provide a basis for a
reasonable assumption that there is evidence to support a fair argument of potential significant impact on air quality.

4. The City must be explicit about whether hydrogen product will be flared or vented as a safety practice, with proper air quality and greenhouse gas (GHG) impact analysis as well as mitigation.
11 U.S. EPA website, Learn about Dioxin: “Dioxins are called persistent organic pollutants (POPs), meaning they take a long time to break down once they are in the environment….Dioxins are highly toxic and can cause cancer, reproductive and developmental problems, damage to the immune system, and can interfere with hormones.” Available at:
https://www.epa.gov/dioxin/learn-about-dioxin#:~:text=Dioxins%20are%20highly%20toxic%20and,the%20fatty%2 0tissue%20of%20animals%20.
10 Kirkok et al., 2021, Dioxin and dibenzofuran like molecular analogues from the pyrolysis of biomass materials—the emerging challenge in bio-oil production. Available at:
https://bmcchem.biomedcentral.com/articles/10.1186/s13065-020-00732-z 9 Safavi et al., 2022. Dioxin Formation in Biomass Gasification: A Review. Available at:
https://www.mdpi.com/1996-1073/15/3/700/htm
8 Gao, 2016. Dioxins and dioxin-like compounds in thermochemical conversion of biomass. Available at:
https://www.diva-portal.org/smash/get/diva2:917094/FULLTEXT01.pdf 7 Safavi et al., 2022. Dioxin Formation in Biomass Gasification: A Review. Available at:
https://www.mdpi.com/1996-1073/15/3/700/htm
6 Updated Raven SR IS/MND, Memo from Ramboll to Richmond Planning and Building Service Department, Raven SR CEQA Air Quality and Health Risk Assessment, Table 12: Modeled Emission Rates, p. 227. 3 D-5
(cont.) D-6 D-7
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It is currently unclear based on this IS/MND whether the facility will be flaring or directly venting hydrogen as a safety backup. This choice should be explicit and explained, as the revised IS/MND alludes to both possibilities.

We caution against venting the hydrogen as it is a greenhouse gas effect multiplier, particularly given that part of this project’s purpose is to reduce GHG emissions. When hydrogen is released directly into the atmosphere, it works to decrease “the tropospheric concentration of hydroxyl radicals (OH), the major tropospheric oxidant, and thereby increase the atmospheric lifetime of methane” and its global warming potential.
12 Hydrogen has a carbon intensity of 5.8, meaning it has 5.8 times more global warming potential than CO2.
13 If the project plans to vent hydrogen, the resulting global warming potential must be included in the calculation of the project’s Unmitigated Annual Operational Greenhouse Gas Emissions estimations. If this is the chosen route, we also call for a clear permit condition limiting the direct venting of hydrogen.

Emitting NOx from flaring hydrogen is also far from ideal, as NOx emissions create smog and are linked with respiratory disease including asthma.
14,15
If flaring is the proposed safety practice, then we urge the City to require a specific plan for minimizing flaring, that curbs safety risks and caps additional pollution emitted by flaring.

Ultimately how the hydrogen is handled should be decided based on calculations of climate and community impacts, not only to avoid noise emissions from flaring. In order to avoid these unnecessary emissions, the addition of a system to store the hydrogen product as a backup should be considered.

5. The City should consider additional mitigation measures and community benefits in a full EIR process.

Members of the frontline North Richmond community, Richmond, and West Contra Costa County more broadly are dismayed to see novel, additional industrial endeavors in an already disproportionately pollution-burdened area, especially one that does not fulfill any of the community’s many critical needs.

Given that there is a fair argument that there is still a potential for significant impacts, a full EIR should be prepared for the City. To inform the EIR process, our community engagement with Richmond youth, working class community members, and Richmond residents more broadly has generated several ideas for mitigation and community benefits.
15 Hajmohammadi et al., 2022, Association between short-term NOx exposure and asthma exacerbations in East London: A time series regression model. Available at:
https://www.sciencedirect.com/science/article/abs/pii/S2212095522000918 14 ATSDR, 2002, Nitrogen Oxides. Available at: https://www.atsdr.cdc.gov/toxfaqs/tfacts175.pdf 13 Derwent et al., 2006, Global environmental impacts of the hydrogen economy. Available at:
https://agage.mit.edu/publications/global-environmental-impacts-hydrogen-economy#:~:text=Hydrogen%20is%20th erefore%20an%20indirect,a%20100%2Dyear%20time%20horizon. 12 Warwick et al., 2022, Atmospheric Implications of Increased Hydrogen Use. Available at:
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1067144/atmosphe ric-implications-of-increased-hydrogen-use.pdf
4 D-7
(cont.) D-8
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The current IS/MND did not allow the City to consider the full scope of what potential mitigations could be added to this project. Additional mitigation measures could include the following:
● Given the novel nature of this development, the City should require regular monitoring of operations, including air monitoring for Criteria Air Pollutants and Toxic Air Contaminants.

While the addition of fenceline monitoring for visible fugitive dust is an excellent place to start, it is insufficient in an area already disproportionately overburdened by pollution. The data collected from this monitoring should be publicly available.
● The applicant has expressed interest in using zero emission vehicles (ZEVs) for the heavy duty trucks that will transport the hydrogen and biocarbon product. The city should make adopting operational zero emission heavy duty fleets a requirement and part of the permit conditions. This mitigation measure is critical because the revised IS/MND confirms the estimation of 100 additional heavy-duty truck trips per day. A full EIR would also need to provide a full analysis of the community impacts of this increase and the need for additional mitigation should be assessed. ● Development of a renewable energy transition plan for when the landfill gas runs out. Rather than relying on PG&E’s energy transition, renewable energy infrastructure that Richmond residents can also benefit from should be developed.
● The City should require a more transparent and extensive process safety and hazard protection system prior to project approval. This project should employ a rigorous warning system and safety accountability process, including timelines for regular incident reports with causal analyses updates to the City Council and thresholds for requiring operations to cease.

Through our community engagement work with key community stakeholders, we have identified additional community benefits that could be appropriate to consider for this project:
● Local workforce, prioritizing North Richmond residents, with safe working conditions and fair wages.
● Investment in public goods and services for the City of Richmond or East Bay Community Just Transition Fund.
● Investment in local renewable energy and resilience infrastructure and projects in North Richmond.
● Investment in health care access and healthy food access because Richmond is a health care desert as well as a food access desert.
● Investment in general operating expenses for local public education for young people in Richmond.

Thank you again for the opportunity to comment.

Sincerely,
Connie Cho, Staff Attorney
Tessa Wardle, Northern California Staff Researcher
Keala Uchôa, Richmond Youth Organizer
Communities for a Better Environment
5 D-8
(cont.) D-9 D-10 D-11 D-12 D-13
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RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 26 Responses to Letter D – Communities for a Better Environment D-1 This introductory comment reiterates prior concerns that despite added information in the Updated IS/MND a fair argument still remains that significant impacts exist regarding air quality, cumulative impacts, and hazards and safety. The comment reiterates that warrants reversal of the City’s approval of an IS/MND and, instead, preparation of a full Environmental Impact Report (EIR).

The Consolidated Response regarding conditions requiring preparation of a full EIR (starting on p. 3 of this document) discusses the impact findings for each of these specific topics relative to those conditions for preparation of an EIR. The subsequent comments in this Letter D elaborate on specific aspects of the aforementioned topics, and full responses are presented for each in Responses to Comments D-4 through D-12. In summary, the Updated IS/MND findings are consistent with CEQA’s requirements that an EIR is not required as the impacts of the Project are less than significant.

D-2 The comment describes excessive flaring that it states is occurring at the West Contra Costa Sanitary Landfill (WCCSL).

This would be an existing condition to which the proposed Project could not have contributed. In other words, without the proposed Project the WCCSL would still be engaged in operations including flaring.

Moreover, CEQA does not require that the analysis of the proposed Project quantify or evaluate preexisting activities at the Project location for purposes of its environmental effects. Pursuant to CEQA, the focus of the environmental analysis is the potential effects of the proposed Project on the existing conditions. The existing conditions include current WCCSL operations. The comment does not raise a significant environmental issue, concerns about the environmental analyses, or information in the IS/MND.

D-3 The comment enumerates “key outstanding concerns” that are each discussed in detail in the subsequent comments in this letter.

See Response to Comment D-4 regarding the treatment of polluting emissions from landfill gas (LFG) flaring (Concern 1). See Response to Comment D-5 regarding the planning for the decline of LFG (Concern 2). See Response to Comment D-6 regarding dioxin formation (Concern 3). See Response to Comment D-7 regarding clarification of hydrogen flaring or venting (Concern 4). See Response to Comment D-8 regarding additional mitigation measures, and see Response to Comment D-9 regarding community benefits (Concern 5).

D-4 The comment asserts that the City fails to treat polluting emissions from LFG flaring consistently. In response, the proposed Project will have the capacity to handle all of the LFG currently produced by WCCSL.

Upon commencement of Raven’s operation, there will be no remaining LFG flaring at WCCSL during normal operations. As clarified throughout the Updated IS/MND, the only flaring that potentially could occur at WCCSL after the proposed Project is underway would be during periods when Raven’s process is shut down, such as during system maintenance. See expanded and clarified discussions of flare use in the Updated IS/MND at Section 1.9 (Project Overview); Section 2.5 (Technology), under the heading Flare System; throughout Section 4.3, Air Quality; and Table 4.8-3, Unmitigated Annual Operational GHG Emissions, on p. 88 of Section 4.8, Greenhouse Gas Emissions. Moreover, even in the unlikely 1587
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 27 event that flaring was to occur after the Raven Project is in operation, any flaring of LFG at WCCSL represents an existing baseline condition associated with the existing landfill operations and not as a result of Raven’s process. The Updated IS/MND presents the proposed change in emissions and impacts from the Project, including emissions associated with Raven’s operations, as well as reductions from baseline conditions at the WCCSL.

With respect to the footnotes cited in the comment, the City conducted an independent analysis of the potential Project impacts and determined that all environmental impacts are less than significant or could be mitigated to a less-than-significant level based on its review of the facts and evidence in support of the analysis. The Updated IS/MND findings are consistent with CEQA’s requirements that an EIR is not required when the impacts of a Project are less than significant.

D-5 The comment asserts that the City fails to analyze and provide safeguards for the inevitable decline of LFG.

After release of the Updated IS/MND, Raven provided additional clarifying information to the City about the LFG and the source of power for the system once the LFG is depleted. In summary, Figure 1 on the following page shows the LFG decline over time, based on information provided in the attached report regarding the closed WCCSL Summary Report (2021-2070) (Attachment 1 to this document). As Figure 1 illustrates, the projected volume, in cubic feet per minute, is not expected to deplete by even 50 percent of the current volume by 2055, with a roughly linear decline between now and then.

Additionally, Pacific Gas and Electric Company’s (PG&E) Preliminary Engineering Study (PES) (Attachment 2 to this document), shows that 2.5 megawatts (MW) will be available to the Raven facility upon commissioning, and up to 5.5 MW by 2025 through distribution system upgrades, as described therein. The Raven facility will only consume incremental electricity from the grid as needed to make up for any reduction in onsite power generation due to depletion of the LFG. As shown in Figure 1, the rate of LFG decline is limited so that, as additional incremental renewable and zero-carbon generation is brought online to meet the requirements of Senate Bill (SB) 100 (as modified by SB 1020, Stats. 2022, Ch. 361, Sec. 4), eligible renewable energy and zero-carbon resources supply 90 percent of all retails sales to California end-use customers by 2035, and 95 percent by 2040 and 100 percent by 2045 (see Cal.

Pub. Res. Code § 454.53(a)). Any incremental electricity delivered from the grid to make up for depletion of LFG is expected to be increasingly clean, such that the carbon intensity of the produced hydrogen will remain low and should not result in significant additional greenhouse gas emissions.

Taken together, the information above demonstrates that the estimated decline of LFG will occur over multiple decades. Normal operation of the Project will consume all LFG and tail gas to produce power for the Project.
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RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 28 FIGURE 1: WCCSL LFG Decline Over Time
D-6 The comment asserts that there is potential for unacceptable levels of dioxin formation in the hydrogen production process that has not been evaluated or mitigated.

The Raven SR multi-patented Steam/CO2 Tri-Reformation technology is a non-combustion, non-catalyst process that converts blended green waste and food waste, obtained from the existing on-site West Contra Costa Sanitary Landfill Organic Materials Processing Facility (OMPF) operation (as clarified on p. 3 of the Updated IS/MND) adjacent to the Project site, into renewable, transportation grade hydrogen. This process produces syngas and is not categorized as incineration or combustion. The process operates in an oxygen deficient/free atmosphere at temperatures of 1,000+ degrees Celsius. In the unlikely event that dioxins could be produced (which they cannot where there is no exposure to free or available air in a closed system), the severe temperatures within process would result in their destruction.

The technical papers referenced in the comment do not apply to the Raven technology; they describe the effects of different technologies than that used by Raven. The Kirkok et al. paper (2021) focuses on pyrolysis of biomass (cellulose and amino acids) in a partial oxygen (6 percent) environment at temperature of 200-700 C. The Safavi et al paper (2021) looks at thermal processes, primarily incineration, which is a combustion process with oxygen, and different feedstocks (MSW, plastic waste, sewage, etc.). The Safevi et al paper states the main ingredients for dioxin formation are an organic material, a chlorine source and a metallic catalyst. The Raven One process does not have a chlorine 1589
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 29 source or metallic catalyst. And in the conclusion section, the Safevi et al paper states, without the presence of oxygen, dioxin formation is significantly reduced in reactors above 800 C. As previously stated, the Raven One process will operate above this temperature.

Overall, the operating conditions referred to in the papers provided with the comment are not similar to the Raven One process. The proposed Project would not generate dioxins and would not result in any potential significant impacts. The Updated IS/MND findings are consistent with CEQA’s requirements that an EIR is not required when the impacts of a Project are less than significant.

D-7 The comment asserts that the City must be explicit about whether hydrogen product will be flared or vented as a safety practice, with proper air quality and greenhouse gas emissions impact analysis as well as mitigation.

Regarding the commenter’s question about whether hydrogen would be vented or flared, as indicated in the Updated IS/MND (on p. 24, under the heading Flare System), hydrogen would be vented to the atmosphere, rather than flared, in the event no off-taker is available. Combustion of hydrogen produces nitrogen oxides (NOx) emissions. Hydrogen is not identified as a criteria pollutant, and is not itself a greenhouse gas.1 Thus, venting was identified as the environmentally superior approach for the process.

At 200 kg/hour capacity, if there is a hydrogen vent from the high pressure hydrogen compressor system, that would equate to 7.3 pounds of hydrogen/min or 0.12 pounds/second release. As the facility’s valuable product, Raven SR has designed the facility to minimize any potential product losses during normal operation. Venting would occur only rarely, including during unexpected operational safety circumstances or emergency shut-down situations. The worst case release scenario of this kind would be the venting of a full hydrogen tube trailer, which would be at the trailer’s relief valve, and potentially up to 1000 kg capacity, which is depended on trailer capacity. This type of release is separate from the facility equipment and processes.

Venting is expected to produce noise should an emergency event occur. This is due to the high pressure of the hydrogen (potentially 8,000+ psig) going to a low-pressure (atmospheric). The reference noise level could be estimated up estimated 114 dB at the source – approximately 15- to 20-feet above grade onsite (see Attachment 3 to this document). However, the noise created from emergency venting would be is less than 65 dB at the property line (64 dB) and access to Republic’s main entrance parking (54 dB) (which is closest to nearby receptors), and would be for a duration of approximately ten minutes or less.

Project operations would be suspended during an emergency event. Factoring in the attenuation of this brief, intermittent sound over the 0.75-mile distance to the nearest sensitive receptor would be significantly reduced and within the ranges anticipated by Municipal Code 9.52.100. The noise created from venting during the emergency event would also be exempt from the Noise Ordinance (section

15.04.605.020(a)), and would not affect the less than significant operational noise impact identified in the Updated IS/MND. Also, Raven will consider a range of noise attenuation features such as baffling, etc., that may be viable to incorporated into the Project to reduce this potential noise nuisance that has an already low probability of occurring, and is already less than significant. The goal would be to adhere to 1 See, e.g., T. Koch, T. Muralidharan, K. Ramirez, A. Well and T. Weiss, Rocky Mountain Institute, “Hydrogen Reality Check #1:

Hydrogen Is Not a Significant Warming Risk,” May 9, 2022, https://rmi.org/hydrogen-reality-check-1-hydrogen-is-not-a-significantwarming-risk. 1590
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 30 Project COA #42 (Operating Noise Limits) which limits operating noise measured at the Republic property boundary to exceed 70 dB at any time in accordance with Richmond Municipal Code 9.52.100.

Overall, the Updated IS/MND determined based on reasonable worst case assumptions supported by substantial evidence that the proposed venting would not result in a significant impact. The findings are consistent with CEQA’s requirements that an EIR is not required when the impacts of a Project are less than significant.

D-8 The comment states that by not preparing a full EIR, the City did not consider the full scope of what potential mitigations could be added to the Project.

The Updated IS/MND determined that all potentially significant environmental impacts would be mitigated to a less than significant level. In addition to the topics addressed generally in the Consolidated Response regarding conditions requiring preparation of a full EIR (starting on p. 3 of this document), the Project does not result in significant impacts that would trigger the need for the comment’s proposed additional measures for the reasons discussed below.

First, many of the additional measures requested by the comment would not be considered mitigation measures for the purposes of avoiding or substantially reducing potentially significant environmental impacts of the Project and/or exceed the scope of the proposed Project and its effects.

Second, the Updated IS/MND identified mitigation measures that are designed to avoid and substantially lessen potentially significant impacts of the Project. Each mitigation measure is identified and discussed in Section 4 (Environmental Checklist and Evaluation) of the Updated IS/MND and listed in the Updated Draft MMRP, which is Appendix C to the Updated IS/MND. The City prepared the Updated IS/MND taking into consideration the additional clarifying Project information from the Project applicant, and then confirmed whether or not the Project would result in less-than-significant impacts in accordance with CEQA’s requirements. The analysis also considered the full scope of applicable mitigation measures to address potentially significant Project impacts so that any Project impacts were mitigated to less than significant.

Under each requested mitigation measure, the request either is not required to mitigate a potentially significant impact and would not be fully feasible, is redundant with other mitigation measures already identified in the Updated IS/MND, is already included in the Project, or would exceed the scope of the Project and its associated impacts. Each of the requested additional measures is addressed in the following Responses to Comments D-9 through D-12.

D-9 The comment specifies an additional mitigation measure that could be added to the Project and that pertains to regular monitoring of operations, including air monitoring for criteria air pollutants and toxic air contaminants (TACs), and the insufficiency of fenceline monitoring (in Mitigation Measure AQ-1).

The Project applicant clarifies that the proposed Project is not the first to involve the conversion of biomass to hydrogen or other forms of renewable energy. Moreover, the suggested mitigation measure calls for monitoring of speculative impacts that substantial evidence in the Updated IS/MND has demonstrated would not occur. Nonetheless, the Project applicant agrees to implement all dust control measures to address fugitive dust as discussed on pages 51 and 52 of the Updated IS/MND, and listed in Mitigation Measure AQ-1, in order to confirm that elevated levels (if they were to occur) of dust comply 1591
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 31 with adopted standards. The Updated IS/MND findings are consistent with CEQA’s requirements that an EIR is not required when the impacts of a Project are less than significant. Also, written documentation that the Project applicant submits to public agencies is considered to be available as a public record under the Public Records Act.

D-10 The comment specifies an additional mitigation measure that could be added to the Project and that pertains to requiring operational zero emission heavy duty fleets, but erroneously interpreting the number of additional heavy-duty truck trips per day associated with the Project.

First, as clarified in the Updated IS/MND in Section 2.8, Transportation and Circulation, on page 31, and in Table 4.15-1 (Project Daily Trip Generation Summary) on page 118, approximately 50 trucks would access/egress the site daily (25 round trips). Table 4.15-1 further clarifies that reference to “100 truck trips per day” is the result of converting truck trips to a passenger car equivalent (PCE) by applying a factor of 2.0 for purpose of accounting for the size and speed of trucks versus passenger cars; conservatively, 100 PCE truck trips were factored into the operational emissions and energy analyses in the Updated IS/MND.

Second, Section 4.3, Air Quality, of the Updated IS/MND evaluated the air quality impacts associated with the increased trips per day generated by the projected trucks, and concluded the impacts were less than significant (see p. 54 of the Updated IS/MND). Similarly, Section 4.15, Transportation, of the Updated IS/MND discussed for informational purposes (under Criterion “a”) that traffic impacts associated with 80 additional heavy duty truck trips (or 100 truck PCEs) on a typical weekday would not substantially increase the motor vehicle volumes on the nearby streets; the transportation impact that considered vehicle trip counts was less than significant (see Criterion “a” starting on p. 117 of the Updated IS/MND).

Regarding the suggested requirement that all of the heavy-duty trucks entering and leaving the facility be zero emission vehicles, Raven will not have direct control over trucks entering and existing the site to obtain product, even in cases where Raven may hold third-party contracts, and therefore could not mandate that the operators use zero emission vehicles. Additionally, electric vehicle heavy-duty trucks are not currently commercially available. Further, the proposed Project does not include Raven delivering product off-site – in which case it would have control of its truck fleet. Nonetheless, the Project applicant expects that truck fleets will convert over time to zero, or near zero, emissions vehicles, as such vehicles would become commercially available. Pursuant to Project COA #61 (Zero Emission Vehicles), the Project applicant will make reasonable efforts to procure zero or near-zero emission vehicles/trucks, to the extent that such vehicle/trucks continue to be manufactured and are commercially available. The Project applicant will encourage the owners of those heavy-duty vehicles to use them when servicing the Raven facility. The Updated IS/MND findings are consistent with CEQA’s requirements that an EIR is not required when the impacts of a Project are less than significant.

D-11 The comment specifies an additional mitigation measure that could be added to the Project and that pertains to the development of a renewable energy transition plan for when the LFG runs out.

As discussed in Response to Comment D-5 and depicted in Figure 1, above, based on a WCCSL summary report (2021-2070), the expected decline of LFG provided is not a rapid decline and occurs over decades. According to the summary report, for the next 10 years, the estimated LFG decline is on 1592
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 32 the order of 18 percent total (1.8 percent per year average). The current plan for future electrical supply for the proposed Project would draw additional capacity from PG&E, who will expand their renewable energy portfolio to comply with state requirements.

The proposed Project is to further renewable energy infrastructure in Richmond. As the Updated IS/MND stated at the top of page 11, “The purpose of Raven SR’s proposed project and its non-combustion Raven SR process is to reduce pollution, help reduce greenhouse gas emissions, and produce renewable and green hydrogen using a low-carbon process.” The proposed Project is intended to contribute to efforts to accelerate progress in green hydrogen production in furtherance of the transition from combustion of fossil fuels in accordance with CARB’s 2022 Scoping Plan for Achieving Carbon Neutrality. Statewide and local Richmond residents will benefit from the proposed Project’s efforts to implement the State’s plans for a transition to renewable energy, given the proposed Project’s renewable energy technology enabling the conversion of organic feedstock to hydrogen.

See specific clarifications of this topic in the Updated IS/MND, on the second to last paragraph on page 87 in Section 4.3, Air Quality (under Criterion “a”), and on page 125 in Section 4.17, Utilities and Service Systems (under Criterion “a”). The Updated IS/MND findings are consistent with CEQA’s requirements that an EIR is not required when the impacts of a Project are less than significant.

D-12 The comment specifies an additional mitigation measure that could be added to the Project and that pertains to need for a more transparent and extensive process safety and hazard protection system for the Project with specific reporting and corrective thresholds for City action.

The proposed Project incorporates a transparent and extensive safety plan into Project construction and operation as described in detail under Safety and Controls on pages 26 through 30 in Section 2.6 (Operations) of the Updated IS/ MND. Raven indicates that it has assembled a team of experts in process engineering, plant operations, civil engineering (including environmental and traffic), and chemical engineering to incorporate best practices into the design and operation of the Project. Its consultants were selected for their expertise in mitigating pollutants, assessing and mitigating health risks, and plant operations. Raven also indicates that the construction arm of its team was chosen for their exemplary record of on-the-job safety, cost management, and schedule management.

Raven explains that its team of recognized experts has adopted rigorous health and safety standards beyond those required by applicable regulations to mitigate foreseeable risks and incorporate best management practices into the design and operation of the Project. Continuous improvement of safety culture will be a priority throughout the life of the plant, with regular training, monitoring, reporting, and auditing of processes associated with the Project's operations and maintenance.

As discussed in the previously-cited pages of the Updated IS/MND, during the design phase, every node (i.e., intersections of piping, electrical etc.) will be reviewed for operational and safety issues in a process proctored by an independent expert with the goal of identifying and mitigating potential hazards. During commissioning, every wire, motor, valve, and pipe will be re-examined to identify and address variances from design.

Raven’s safety and hazard protection system has been built into its Project design as described in further detail under the heading “Safety and Controls” in Section 2.6 (Operations) of the Updated IS/MND. As discussed therein, piping and vessels will be periodically scanned with infrared equipment to identify hot 1593
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 33 spots or gas leaks that may threaten safety. If hot spots or leaks are identified, immediate steps will be taken to correct or mediate the condition. Also, remote monitoring of the facility by Raven will provide oversight of the operation and early identification of problems as they develop.

In summary, the Project applicant will comply with all applicable local, state and federal laws, as discussed in the Consolidated Response “safety” (starting on p.4 of this document) and 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. These laws and regulations are mandatory.

Also, several Project COAs establish the scheduled review and monitoring of the Project’s operations, including the assessment of the Project’s compliance with applicable federal, state, and local laws and regulations pertaining to safety precautions and emergency response. These include Project COA #17 (Compliance Objective); COA #28 (Permit Review), which includes the City’s assessment of corrective actions if needed; COA #49 (Additional Operating Parameters Shall Include); and COA #83 (Regulation Compliance).

The Updated IS/MND findings are consistent with CEQA’s requirements that an EIR is not required when the impacts of a Project are less than significant. Also, the process safety and hazard protections described above will be implemented as part of the safety site operations plan referenced in the Project’s COAs.

D-13 The comment identifies additional community benefits that it suggests could be appropriate for the City to consider for the Project. Each of the suggested community benefits (re-stated and bulleted below for ease of review) do not pertain to the potential environmental effects of the proposed Project or other topics relevant under CEQA. Each suggestion exceeds the scope of the proposed Project and focuses on existing conditions in the Richmond community rather than potential impacts caused by the proposed Project. Nonetheless, the following addresses each community benefit that CBE has identified. The responses below are acknowledged for the public record and will be taken into account by City decisionmakers.  Local workforce, prioritizing North Richmond residents, with safe working conditions and fair wages.

The Project applicant has already signed a project labor agreement with the unions and will be offering two internships per year to trade or community college students.  Investment in public goods and services for the City of Richmond or East Bay Community Just Transition Fund.

The Project applicant already supports local businesses, contractors and various community organizations in the City of Richmond and Western Contra Costa County.  Investment in local renewable energy and resilience infrastructure and projects in North Richmond.

As discussed in Section 2 (Project Description) of the Updated IS/MND, the purposes of the proposed Project and its non-combustion Raven SR process are to reduce pollution, help reduce greenhouse gas emissions, and produce renewable and green hydrogen using a low carbon process. 1594
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 34 The Project is designed to convert blended green waste and food waste into renewable, low-carbon, transportation grade hydrogen. Use of low-carbon hydrogen as a substitute for petroleum based fuels in heavy duty vehicles and other applications would reduce criteria pollutant emissions and greenhouse gas emissions in Richmond, thereby demonstrating a commitment to an investment in local renewable energy in the community.
 Investment in health care access and healthy food access because Richmond is a health care desert as well as a food access desert.

The proposed Project is a renewable energy project, and improving access to food and health care is not within its scope.
 Investment in general operating expenses for local public education for young people in Richmond.

The draft Conditional Use Permit (CUP) requires that Raven SR must contribute 1 percent of its construction fund to the Richmond City Arts Program. That fee is approximately $500,000. ________________________
1595

April 12, 2023
Via electronic mail ([email protected])
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, P.O. Box 4046
Richmond, CA 94804
Re: Updated IS/MND Documents for Raven SR Bioenergy Project Dear Lydia:

Thank you for the opportunity to comment on the revised Initial Study and Mitigated Negative Declaration (IS/MND) for the Raven SR Bioenergy Project (Project). We appreciate the City and project proponents having taken the time to review and address many of our concerns with the inadequacy of the first iteration of the IS/MND. The revised document, and the associated Health Risk Assessment (HRA), represent significant progress toward addressing earlier gaps in information concerning the Project’s potential impact on the health and safety of the surrounding community.

That said, we fully support Communities for a Better Environment and the communities it represents in calling for the remaining information gaps to be filled, as well as for both additional mitigation measures and community benefits. We therefore urge you to engage in dialogue with community representatives prior to any project approval, to ensure that all remaining information gaps they have identified are filled, and to develop mitigation measures and a community benefits agreement.

Very truly yours,
Ann Alexander
Senior Staff Attorney, National Resources Defense
Council
Letter E
E-1
1596
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 36 Responses to Letter E – National Resources Defense Council E-1 The comment states full support of the comments submitted by the Community for a Better Environment and the communities it represents. See Response to Comments in Letter D regarding the purported information gaps and additional mitigation measures and community benefits. ________________________
1597
Sierra Club
2101 Webster St #1300
Oakland, CA 94612
April 12, 2023
Via electronic mail ([email protected])
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, P.O. Box 4046
Richmond, CA 94804
Re: Updated IS/MND Documents for Raven SR Bioenergy Project Dear Lydia:

Thank you for the opportunity to comment on the revised Initial Study and Mitigated Negative Declaration (IS/MND) for the Raven SR Bioenergy Project (Project). We appreciate the City and project proponents having taken the time to review and address many of our concerns with the inadequacy of the first iteration of the IS/MND. The revised document, and the associated Health Risk Assessment (HRA), represent significant progress toward addressing earlier gaps in information concerning the Project’s potential impact on the health and safety of the surrounding community.

That said, we fully support Communities for a Better Environment and the communities it represents in calling for the remaining information gaps to be filled, as well as for both additional mitigation measures and a community benefits agreement (CBA) aimed at addressing the Project’s likely impacts. We therefore urge you to engage in dialogue with community representatives prior to any project approval, to ensure that all remaining information gaps they have identified are filled, and to develop mitigation measures and a CBA to address remaining project impacts.

Sincerely,
Norman La Force
Vice-Chair, Sierra Club West Contra Costa County Group
Letter F
F-1
1598
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 38 Responses to Letter F – Sierra Club, San Francisco Bay F-1 The comment states appreciation for the Updated IS/MND, yet states full support of the comments submitted by the Community for a Better Environment and the communities it represents. See Response to Comments in Letter D regarding the purported information gaps and additional mitigation measures and community benefits.
________________________
1599
Energy Efficiency Finance Corp.
phone: 1-360-339-3936 Fax: 1-206-774-0411 Address: 3336 Libby Road NE, Olympia, WA USA 98506 April 12, 2023
Ms. Lydia Elias
City of Richmond, Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
sent by email to: [email protected].

Re: Raven SR Bioenergy Project
Dear Ms. Elias: I am writing in support of the Raven SR Bioenergy Project to be located at West Contra Costa Sanitary Landfill and which will capture landfill gas (LFG) that is otherwise being flared and also convert organic waste to useful hydrogen energy. I have been introduced to this project by Libba and Gifford Pinchot. My work is in clean energy and environmental project finance and I have worked on developing and raised financing for LFG, waste-toenergy, anerobic bio-digester (selling renewable natural gas into the California LCFS market as managed by the CARB), recycling and composting facility and other environmental projects in my 35+ year career. I also served on the Board of my Windham County solid waste management district for several years while living in Brattleboro, Vermont where we operated a landfill, installed an LFG capture and energy plant and developed a materials recovery facility.

I see the Raven project as a waste utilization project, making value added use of waste and LFG, and also providing significant local air quality benefits. As I learn and think about the Raven project from the public sector and public official point of view and put myself in City Council member shoes, questions I would be asking are: a) does the project generate local environmental benefits and improve air quality?, b) is the project consistent with State and local climate objectives and standards?, c) what are the financial benefits and risks to the City in the project undertaking?
It seems that the answers to a) and b) are clearly yes, reflecting, for example, the “Raven SR Project Air Quality and Greenhouse Gas Assessment” prepared by Ramboll US Consulting, Inc. dated February 23, 2023 (attached for ease of reference). The Raven facility reduces local air pollution, hence local health risks even before accounting for emission reductions achieved by replacing diesel trucks with hydrogen fueled ones, and reduces greenhouse gas emissions consistent with State climate goals. Further inputs from scientists and permitting authorities on these questions a) and b) could be sought to confirm the local environmental and GHG reduction benefits from the project and inform the City’s decision.

While I have not studied the project sufficiently to detail answers to question c) concerning City financial benefits and risks, my understanding is that the project will be implemented and operated on a turnkey basis by the project developer, thus managing project risks, and will generate savings and revenues for the City and landfill operation, and that the developer has a demonstrated track record and capabilities. Further assessment of this question c) in the context of completing project implementing agreements could be conducted.

Letter G
G-1
1600
I wish you all the best in conducting your analysis and supporting the City Council’s decision on this project. If I can be of any support, please contact me at 360-339-3936 or by email at [email protected].

Sincerely,
John C. MacLean
President
Attachment
Raven SR Project Air Quality and Greenhouse Gas Assessment” prepared by Ramboll US Consulting, Inc. dated February 23, 2023
cc: Gifford and Libba Pinchot
1601
1 Lydia Elias
From: John MacLean <[email protected]>
Sent: Wednesday, April 12, 2023 3:13 PM
To: Lydia Elias
Cc: Gifford Pinchot III; Libba Pinchot
Subject: Re: Letter in support of the Raven SR Bioenergy Project Follow Up Flag: Follow up
Flag Status: Flagged
This email originated from outside of the City's email system. Do not open links or attachments from untrusted sources.

Dear Ms. Elias:  One more thought to share…I understand that some environmental organizations are advocating for H2 production exclusively from electrolysis, powered by renewable energy.  I have been learning about, and evaluating possible investments in the developing H2 economy, and while I also advocate for green H2 infrastructure, I think that (i) this Raven project should be evaluated on its own merits, especially the local air quality benefits, and (ii) there is definitely room within the future H2 economy for this project’s modest production volumes.  Thank you for your public service.  Sincerely, John MacLean John MacLean, President
Energy Efficiency Finance Corp.
3336 Libby Road NE
Olympia, WA 98506
Cell = 360-339-3936
Fax = 206-774-0411
[email protected]
Skype handle = john.coleman.maclean
On Apr 12, 2023, at 11:53 AM, John MacLean <[email protected]> wrote:

Dear Ms. Elias:  Attached please find my letter in support the Raven SR Bioenergy Project to be located at West Contra Costa Sanitary Landfill; also attached is one study shared with me by Mr. Gifford Pinchot (copied here) which assesses the local air quality and environmental benefits and greenhouse gas emissions reductions estimated to be achieved by this project.  I wish you and your colleagues all the best in your review and decision process.  Sincerely, John MacLean
<MacLean letter to City of Richmond CA supporting Raven project Apr 12 2023.pdf> <Raven HRA Memo_0307_with tables and figures.pdf>
You don't often get email from [email protected]. Learn why this is important 1602
2 <Raven AQ GHG Memo_0227_with tables and figures.pdf>
John MacLean, President
Energy Efficiency Finance Corp.
3336 Libby Road NE
Olympia, WA 98506
Cell = 360-339-3936
Fax = 206-774-0411
[email protected]
Skype handle = john.coleman.maclean
1603
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 43 Responses to Letter G – Energy Efficiency Finance Corp.

G-1 The comment states its support of the proposed Project and considers factors that public officials should consider for the Project. The comment does not raise a significant environmental issue, concerns about the environmental analyses, or information in the IS/MND. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the IS/MND and the Project. ________________________
1604
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 44 This page is purposefully blank.
1605
1 Lydia Elias
From: Shoshana Wechsler <[email protected]>
Sent: Wednesday, April 12, 2023 4:38 PM
To: Lydia Elias
Subject: Raven SR Project
Follow Up Flag: Follow up
Flag Status: Flagged
This email originated from outside of the City's email system. Do not open links or attachments from untrusted sources.

Attn:

Lydia Elias
Richmond City Planner
Community Development Department
City of Richmond
450 Civic Center Plaza, P.O. Box 4046
Richmond, CA 94804
Re: Raven SR Project
Dear Ms. Elias,
I am writing on behalf of the Sunflower Alliance, an environmental and climate justice organization in the East Bay with over 4,000 supporters. Many of our active members are residents of Richmond, or residents of neighboring communities. The health and safety of Richmond and North Richmond residents has been a top priority for us in the work we’ve been doing over the last decade.

Given the complexities of this project, we strongly recommend that the Planning Department and City Council reverse the decision of the Planning Commission and call for the commission of a full Environmental Impact Report on the Project.

Very sincerely yours,
Shoshana Wechsler, Co‐Coordinator
Letter H
H-1
1606
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 46 Responses to Letter H – Sunflower Alliance
H-1 The comment recommends that a full EIR be prepared for the Project, but cites only “the complexities of this project” as justification. Regardless, see the Consolidated Response (starting on p.3 of this document) regarding conditions requiring preparation of a full EIR. ________________________
1607
April 5, 2023
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 closed West Contra Costa County Sanitary Landfill.

While I fully support the opportunity to file an appeal to decisions made by the Planning Commission, it is clear that Raven SR’s proposed project meets the requirements of an IS/MND, and as shown by their Health Risk Assessment, they will be improving the air quality and reducing health risks in our community.

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 SR 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.

Our community has been calling for cleaner technologies and better emissions for many years, versus the current fossil fuel refinery system. Raven SR is providing that alternative and we need to embrace it and allow our residents to breathe easier, take advantage of new jobs, as well as youth education programs that Raven would like to bring into the Richmond school system.

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. Raven SR will be creating around 10 jobs, 2 internships, 100-150 constructions jobs and approximately 60 indirect jobs for our community.

California has taken a leadership role in the nation in 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 CUP application and the CEQA IS/MND so they may begin construction this year and start production in early 2023.

Sincerely,
Ryan Lange
Business Representative
IUEC Local 8
Letter I
I-1
1608
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 48 Responses to Letter I – International Union of Elevator Constructors I-1 The comment supports the proposed Project and discusses merits of the Project. It does not raise a significant environmental issue, concerns about the environmental analyses, or information in the IS/MND. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the IS/MND and the proposed Project. ________________________
1609
Letter J
J-1
1610
1611
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 51 Responses to Letter J – Sprinkler Fitters and Apprentices J-1 The comment is in support of the proposed Project and discusses merits of the Project. It does not raise a significant environmental issue, concerns about the environmental analyses, or information in the IS/MND. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the IS/MND and the proposed Project. ________________________
1612
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 52 This page is purposefully blank.
1613
Letter
K K-1
1614
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 54 Responses to Letter K – International Brotherhood of Electrical Workers K-1 The comment is in support of the proposed Project and discusses merits of the Project. It does not raise a significant environmental issue, concerns about the environmental analyses, or information in the IS/MND. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the IS/MND and the proposed Project. ________________________
1615
Letter L
L-1
1616
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 56 Responses to Letter L – Contra Costa Building and Construction Trade Council
L-1 The comment is in support of the proposed Project and discusses merits of the Project. It does not raise a significant environmental issue, concerns about the environmental analyses, or information in the IS/MND. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the IS/MND and the proposed Project. ________________________
1617
1 Lydia Elias
From: Griselda Rivera-Orochena <[email protected]>
Sent: Wednesday, April 12, 2023 4:43 PM
To: Lydia Elias
Subject: Raven SR Project
Follow Up Flag: Follow up
Flag Status: Flagged
This email originated from outside of the City's email system. Do not open links or attachments from untrusted sources.

Re: Raven SR Project
To Lydia Elias, Richmond City Planner,
Thank you for the opportunity to comment on the Raven SR Project. I am... Griselda Rivera-Orochena a community resident of Richmond who lives with elderly family members.

I would like to raise concerns regarding Raven SR Project:

1. 2.

3. My first concern is a result of living with elders

4. who are immunocompromised. From what I have learned this project would release harmful and cancerous chemicals such as formaldehyde. Richmond is a community that faces a lot of pollution and I don't think that this project would benefit the community in any

5. direct way.

6. 7.

8. 9. From my research I have learned that Hydrogen

10. is a highly volatile and explosive chemical and after the incident that happened in Ohio, to say that the chances of an explosion happening are small is an understatement of the impact an explosion can have in the community of Richmond. This concerns me because

11. In summary,I believe the city of Richmond should consider a full EIR and create community safety plans for the worse case scenario. It is the job and should be the priority of our city council to keep its community residents safe.

Sincerely,
Letter M
M-1
1618
2 Griselda Rivera-Orochena
Richmond Community Member
‐‐
Griselda Rivera‐Orochena
CSU Dominguez Hills 2021
[email protected]
1619
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 59 Responses to Letter M – Griselda Rivera
M-1 The comment states that the proposed Project would release harmful and cancerous chemicals, such as formaldehyde, mentions concern that hydrogen is highly volatile and explosive, and calls for preparation of a community safety plan. Cancerous materials, otherwise referred to as toxic air contaminants or TACs, were assessed as part of the HRA conducted as part of the CEQA analysis (see Consolidated Response “Air Quality and Human Health Risk” starting on p.3 of this document). TACs were tabulated and modeled. Tables 4.3-4 and 4.3-5 on pages 49 and 50, respectively, of the Updated IS/MND show that the Project would not exceed applicable BAAQMD thresholds, and the impact would be less than significant. The modeled results of health risks would not exceed the BAAQMD thresholds and, when combined with landfill reductions, are expected to reduce the overall health burden to the community (see Response to Comment N-1).

Also see the Consolidated Response (starting on p. 3 of this document) regarding conditions requiring preparation of a full EIR.
________________________
1620
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 60 This page is purposefully blank.
1621
1 Lydia Elias
From: Ayush Dahal <[email protected]>
Sent: Wednesday, April 12, 2023 4:50 PM
To: Lydia Elias
Subject: raven sr
Follow Up Flag: Follow up
Flag Status: Flagged
This email originated from outside of the City's email system. Do not open links or attachments from untrusted sources.

Dear Lydia Elias,
My name is Ayush Dahal and I am a life-long resident of San Pablo with asthma. I am writing to you in my personal capacity as a youth community member, but I also serve as a youth intern for Communities for a Better Environment and the Asian Pacific Environmental Network. Thank you for the opportunity to comment on a revised Initial Study/Mitigated Negative Declaration (IS/MND) for the Raven SR Bioenergy Project.

As a young community member who has been fighting for a greener and more environmentally friendly Richmond for over 7 years, I am very concerned about the impacts on our community’s health from the proposed Raven SR project’s increase in truck traffic, the potential for explosive accidents in our community from transporting the Hydrogen produced on the site, and the cumulative impact of Greenhouse Gas emissions.

1. 2.

3. As a resident with

4. asthma, I am aware of the health impacts of air pollution in my already overburdened community. The proposed project would bring an additional 100 heavy duty truck trips per day to our community. I want to see the city of Richmond require the use of zero emissions

5. heavy duty fleets as part of the permit conditions for the Raven SR project to ensure that my community is not burdened from more truck traffic emissions.

6. 7.

8. 9. I would really like

10. more transparency and community engagement in the decision-making process for the Raven SR project. It is crucial that the community is fully informed about the potential risks and benefits of the project and has a voice in the decision-making process. Thus, You don't often get email from [email protected]. Learn why this is important Letter N
N-2 N-3 N-1
1622
2 11. I would like to see the city of Richmond require a full environmental impact report (EIR) for the project to fully assess the impact of the proposed project on the community.

12. Thank you for your consideration of my concerns and ideas.

Sincerely,
Ayush Dahal
Youth San Pablo Resident
N-3
(cont.)
1623
RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration 63 Responses to Letter N – Ayush Dahal
N-1 The comment raises concerns about community health impacts from increased truck traffic associated with the Project; see Response to Comment D-10 and Response to Comment N-2 regarding truck emissions. The comment also raises concern with explosive potential from transporting hydrogen produced on the Project site; see Response to Comment D-12 and Consolidated Response “safety” (starting on p. 4 of this document). Also regarding the transport of hydrogen, the transportation of compressed gases such as hydrogen are regulated by the federal Department of Transportation, OSHA, and other federal and State laws. These laws and regulations are mandatory and set safety standards for transportation and handling.

The comment raises concern about cumulative impacts of greenhouse gas emissions. As analyzed in Criterion “a” (starting on p. 87) in Section 4.8, Greenhouse Gas Emissions, of the Updated IS/MND, the Project uses LFG to provide power to the process that converts blended green waste into renewable, transportation grade hydrogen. Thus, it reduces the amount of greenhouse gas emissions produced at the Project site. Further, the Raven SR system does not have any free oxygen in its process, and instead uses steam-promoted processes to thermally decompose the blended green waste into its chemical elements.

The process does not involve any type of combustion, and therefore does not have greenhouse gas emissions associated with the system operational emissions. Once Project operations fully begin, greenhouse gas emissions are expected to be net negative.