Cities Index.
Attachment 2 - Raven SR_ Draft_ISMND.pdf

Richmond City Council
May 16, 2023

Document
Attachment 2 - Raven SR_ Draft_ISMND.pdf
Meeting
May 16, 2023
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Richmond City Council
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Text extracted from the city's file for reading and search. Open the original on pub-richmond.escribemeetings.com. That file is the official record.

Table of Contents

Raven SR Bioenergy Project

i

ESA

/
D202100382

Initial Study

October 7,
2022

TABLE OF CONTENTS

Raven SR Bioenergy Project Initial Study

Page

1. General Project Information

and Overview

................................
................................
..

1 1.1

Project Title

................................
................................
................................
..............

1 1.
2 Lead Agency Name and Address

................................
................................
............

1 1.3

Project Case File Number

................................
................................
........................

1 1.4

C
ontact Person and Phone Number

................................
................................
........

1 1.5

Project Location

................................
................................
................................
.......

1 1.6

Projec
t Applicant’s Name and Address

................................
................................
...

2 1.7

Existing General Plan
and Zoning
Designation

................................
.......................

2 1.
8 Purpose and Intended Use of this Document

................................
.........................

2 1.
9 Project Overview

................................
................................
................................
......

6 1.1
0 Environmental Setting

................................
................................
..............................

6 1.11

Required Discretionary Approvals

................................
................................
...........

6 1.1
2 Other Public A
gencies Whose Approval is Required

................................
..............

7 1.1
3 California Native American Tribes Consultation

................................
......................

7 2
.

Project Description

................................
................................
................................
..........

9 2
.1

Existing
Site

Conditions and Ownership

................................
................................
..

9 2
.2

Surrounding Uses and Conditions

................................
................................
...........

9 2
.3

Site Plan and
Structures

................................
................................
........................

12 2
.4

Technology

................................
................................
................................
.............

17 2
.5

Op
erations

................................
................................
................................
..............

19 2.6

Employment

................................
................................
................................
...........

22 2.7

Transportation and Circulation

................................
................................
...............

22 2.8

Construction
,

Site Coverage

and Drainage

................................
...........................

22 2.
9 Off
-
site Improvements: Landscaping

................................
................................
.....

23 3.

Environmental Factors Potentially Affected

................................
..............................

24 4
.

Environmental Checklist

and Analysis

................................
................................
.......

2 5

4.1 Aesthetics

................................
................................
................................
...............

2 5

4. 2

Agriculture and
Forestry Resources

................................
................................
......

3 1

4. 3

A
ir
Quality

................................
................................
................................
...............

3 4

4.4 Biological Resources

................................
................................
..............................

43 4.5

Cultural

Res
ources

................................
................................
................................
.

53 4.6

Energy

................................
................................
................................
....................

57 4.
7 Geology, Soils and Mineral Resources

................................
................................
..

61 4.
8 Greenhouse Gas Emissions

................................
................................
..................

65 4.9

Hazards and Hazardous Materials
................................
................................
.........

7 2

4. 10

Hydrology and Water Quality

................................
................................
.................

77 4.1
1 Land Use and Planning

................................
................................
..........................

82 4.1
2 Noise

and Vibration

................................
................................
................................

84 4.1
3 Population

and
Housing

................................
................................
.........................

90 Table of Contents

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4.1 4

Public Services

and Recreation

................................
................................
.............

91 4.1
5 Transportation

................................
................................
................................
........

93 4.1
6 Tribal Cultural Resources
................................
................................
.......................

97 4.17

Utilities and Service System
s

................................
................................
.................

99 4.1
8 Wildfire

................................
................................
................................
.................

102

4.1 9

Mandatory Findings of Significance

................................
................................
.....

104

5 .

Document
Preparers

................................
................................
................................
...

106

List of Figures

1 -
1 Regional Context

................................
................................
................................
.......

3 1
-
2 Local Context
–

North Richmond

................................
................................
..............

4 1
-
3 Project Site and Surrounding
Landfill
Context

................................
..........................

5 2
-
0 Birdseye View of Project Si
te

................................
................................
..................

10 2
-
1 Project Site

and Raven SR Facility Areas

................................
...............................

11 2
-
2 Simulated

3D Site Development
................................
................................
..............

13 2
-
3 a

South Elevation (
West E
nd)

................................
................................
....................

14 2
-
3 b

South Elevation (
E
ast
E
nd)

................................
................................
.....................

15 2
-
4 Detailed Site Layout and
Raven SR
Facility Plan

................................
...................

16 2
-
5 Raven SR Process Diagram

................................
................................
...................

18 4
.1
-
1 Wildcat Marsh Trail Approach Toward Project Site (from E )

................................
..

27 4.1
-
2 Onsite View toward Project Site

................................
................................
.............

29 List of Tables

4 .3
-
1 Average Daily Construction
-
related Criteria Pollutant Emissions (pounds
per day) Without Mitigation

................................
................................
...................

3 6

4.3 -
2 Air Permit Ap
plication's Average Annual Operational Criteria Pollutant Emissions (tons
per year)

................................
................................
.....................

3 7

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

................................
................................
.................

3 7

4.3 -
4 Average Annual Operational
-
Related Criteria Pollutant Emissions
(tons

per year)

................................
................................
................................
...............

3 8

4.8 -
1 BAAQMD GHG Thresholds of Significance

................................
............................

67 4.8
-
2 Annual Construction
-
Related Greenhouse Gas Emissions

................................
....

68 4.8
-
3 Unmitigated Annual Operational Greenhouse Gas Emissions

..............................

70 4.12
-
1 Localized Roadway Traffic Noise

................................
................................
............

86 4.12
-
2 Construc
tion Equipment Noise Levels

................................
................................
....

87 4.12
-
3 Reference Noise Levels for Stationary Noise Sources Associated with the Proposed Project

................................
................................
............................

89 4.15
-
1 Project Daily Trip Generation Summary

................................
................................
..

95 4.15
-
2 Project VMT Summary
................................
................................
.............................

96 Appendix

A

Emissions Data, Assumptions and Mo
deling Files

................................
................

A
-
1 B

Special Status Species Lists

................................
................................
.................

B
-
1 C

Draft
Mitigation Monitoring and Reporting Program

(MMRP)

...............................

C
-
1 1
. General Project Information

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1. General Project Information

1.1 Project Title

Raven SR Bioenergy Project

1.2 Lead Agency Name and Address

City

o
f Richmond

(City)

Planning and Build
ing Services Department

450 Civic Center Plaza

PO Box 4046

Richmond, CA 94804
-
1630

1.3 Project Case File Number

City Project Case Number:

PLN21
-
282

1.4 Contact Person and Phone Number

Lina Velasco, Director of Community Development

Community Development Departm
ent

[email protected]

(510) 620
-
6841

1.5 Pr
o
j
e
c
t L
o
c
a
t
i
on

1 Parr Boulevard, Richmond, California

(generally)
.

The proposed

Raven SR P
roject location is

within the West Contra Costa Sanitary Landfill
(WCCSL) facility
located in the northwest area o
f the

City of Richmond, in Contra Costa County,
California.

For purpose of
this environmental

document, t
he project

would

occur
within
approximately

2.5 acres
of

the existing
Republic Services
Bulk Materials Processing Center
(BMPC)
within “Area A”
of the
WCCSL
.
1 ,
2 T
he 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 jur
isdiction line
; the project
site is located
wholly within the City of Richmond, except for
use of
an

existing access/egress road located within the County
.

The project site is located
within

Assessor’s Parcel Number (APN)
408
-
140
-
009
.

1 Actual project operations will occur on a subset area of approximately 1.3 acre s that Raven SR will lease from
BMPC.

2 “Area A” of the WCCSL is approximately 12 acres in the upland portion of the property that encompasses p ollution
control facilities and stockpile areas (separate from
the
closed
Class I and active Class II
landfill a
reas,
the
runoff
ponds
or lagoons delineated as “
Area B
”
, and tidal waters

delineated as “
Area C
”
).

Shown in
Figure 3
-
1, Vicinity
Map, of the

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

1. General Project Information

Raven SR Bioenergy Project

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See
Figure 1
-
1, Regi
onal Context
;
Figure 1
-
2, Local Context
–

North Richmond
; and
Figure
1 -
3, Project Site and
Surrounding

Landfill Setting
, on the following pages.

1.6 Project Applicant’s Name and Address

Raven SR

S1
,
LLC

3 Matt W. Murdock CEO

PO Box 1360

Pinedale, WY 82941

1.7 Exis
ting General Plan and Zoning Designations

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

1.8 Purpose and Intended Use of this Document

The purpose of this Draft Initi
al Study/Mitigated Negative Declaration (IS/MND) is to identify any potential environmental impacts that would result from implementation of the proposed project pursuant to California Environmental Quality Act (CEQA) Guidelines.

As the project site
is who
lly located within the City limits, t
he City
of Richmond
has discretionary authority over the
proposed project and is the
lead agency

in the preparation of this
Draft
IS/MND. The intended
use of this document is
disclose the potential environmental impacts

and mitigation measures, if
any,

and to provide the basis for input from public agencies, organizations, and interested members of the public.

This CEQA document is a stand
-
alone analysis for the proposed project. Where appropriate and suitable, setting a
nd context information from prior CEQA documents certified for the WCCSL
/
BMPC facility
and operations is used in parts of this Draft IS/MND given that the project site is
located
within the WCCSL/BMPC facility.
4 However, no part of the proposed
project aff
ects existing WCCSL/BMPC operations; the proposed development and Raven SR system is a wholly independent utility, except that it
would

use feedstock available from the
current BMPC operation. Mitigation measures identified in this document will apply sole ly to the
proposed project and do not conflict with any applicable mitigation measures identified in the previously certified WCCSL/BMPC CEQA documents. Similarly, and addressed separately from this CEQA document, the proposed project requires approval of a City of Richmond
Conditional
Use Permit

(see Section 1.11, below), which is wholly independent from the existing City Conditional Use Permit (
CU 1101132

as amended
)
and Contra Costa County Land Use Permit
(LUP 2054
-
92 as amended) for the WCCSL/BMPC, as w
ell as any existing permits, control

3 The project applicant is referred to throughout as “Raven SR”. “Raven SR” also refers to the multi -
patented
process/system.

“Raven” refers to the proposed facility.

4 Environmental Impact Report on the West Contra
County Sanitary Landfill Bulk Materials Processing Center and Related Actions
,
June 2004
; and
Addendum to the

Final

EIR

for the WCCSL BMPC and Related Actions
, 2009
.

SCH. 2002102057.

Figure 1-1
Regional Context
Raven SR Bioenergy Project Initial StudySOURCE: Raven LLC, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator Figure 1-2
Local Context - North Richmond
Raven SR Bioenergy Project Initial StudySOURCE: Raven LLC, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator Raven SR
Facility Location
WCCSL Organics Materials
Processing Facility (OMPF)
West Entrance & Scale Plaza
Parr Blvd
Wildcat Marsh Trail
Golden Bear Transfer Station
West County
Water District
Treatment Plant
WCCSL Organics Materials
Processing Facility (OMPF)
West Entrance & Scale Plaza
Parr Blvd
Wildcat Marsh Trail
Raven SR
Facility Location
Contra Costa County
City of Richmond
Contra Costa County
City of Richmond
Golden Bear Transfer Station
West County
Water District
Treatment Plant
Figure 1-3
Project Site and Surrounding Land/f_ill Context
Raven SR Bioenergy Project Initial StudySOURCE: Raven LLC, 2022; ESA, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator

1. General Project Information

Raven SR Bioenergy Project

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2022

measures or cooperative agreements executed by various regulatory agencies that ha ve permitting
authority for the WCCSL/BMPC.

The remainder of this
S
ection
1 provides a
n overview
of the project
’s

primary
characteristics

and
its
environmental

setting and required
discretionary approvals
.

Section 2

describes the project in
more detail,
Se
ction 3

is the draft environmental declaration, and

Section 4
is the

environmental
checklist that
evaluates

the

potential
environmental
impacts that may result from

construction or
operation of the

proposed
project
.

Section
5 contains the List of Preparers
.

1.9 Project Overview

The Raven SR Bioenergy Project (project) proposes to construct and operate a bioenergy system composed of the Raven SR multi
-
patented Steam/CO
2 Reformation process at the project site.
5 The
non
-
combust
ion

process
would

convert blended gr
een waste and food waste
,

obtained from
the existing BMPC operation adjacent to the project site ,

into renewable, transportation grade
hydrogen that
would

be exported offsite for various renewable energy products.

No
long
-
term
hydrogen storage
would

occur
onsite.

The project would involve the erection of a modular
structure and
industrial
canopy
.

1.10 Environmental Setting

As
shown in Figure 1
-
2, i
ndustrial use and natural waterways create the environment setting of the project site.

The

WCCSL facility spans
app
roximately

340 acres

generally between Parr
Boulevard and San Pablo Bay, south of San Pablo Creek
. This area is composed of
expansive
planted
disposal areas
/landfill mounds
, runoff control ponds and lagoons, the organic material processing facility and com
posting areas
, and the location of the proposed project (within
part of
the BMPC area), is situated in the southeast area of the WCCSL facility.

San Pablo Creek

and

the
San

Pablo

and
Wildcat

Creek

tidal
marshlands

exist north and south of the WCCSL facilit
y
.

O
pen
water of
San Pablo Bay

is approximately 0.25 miles west from the project site.

Figure 1
-
3 shows t
he closest
structure and
development is the Golden Bear Waste Recycling
Facility approximately 300 feet southwest of the proposed project location
, an
d the West
County
Wastewater

District Treatment Plant and the Wildcat
Marsh
Trail and trail head
parking
exist
approximately 1,000

feet east of the
project location. The
surrounding uses are industrial
,

commercial

and open space
; the
nearest
sensitive rece
ptors to the project site are
residential uses
,
an elementary school, and a health clinic, all within approximately 0. 75 to 1.2 miles
southeast in
the North Richmond area.

1.11 Required Discretionary Approvals

City of Richmond (Lead Agency)
:

Adoption of the
CEQ
A
Documentation, Mitigated
Negative Declaration;

Conditional Use Permit

for

a new activity and facility to convert

5 CO
2 is
carbon dioxide.

1. General Project Information

Raven SR Bioenergy Project

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organic waste to

hydrogen
6 ; and

various development permits, including but
not limited
to
site preparation, construction and building activit
ies
.

1.12 Other Agencies
Whose
Review or
Approval Is Required

Bay Area Air Quality Management District (BAAQMD
)
: I
ssuance of an Authority to
Construct (ATC) for the associated air pollutant emissions.

Raven SR has applied for an
ATC

air permit
to be issued by B
AAQMD
.

This permit application is currently
undergoing
review.

Sta
te Water Resources Control Board
:

Raven SR
would

submit Notices of Intent
(NOI) to the State Water Board.

Raven SR
would

submit t
he Construction NOI prior to
any grading on the project site
obtain coverage under both the statewide General Permit for Discharges of Storm Water Associated with Construction Activity and General Permit for Storm Water Discharges Associat
ed with Industrial Activities. T
he Industrial NOI
would be
submitted prior to
operation of the waste conversion system.

State Department of Resource Recovery and Recycling (CalRecycle)

and Local
Enforcement Agency (LEA)
:

Issuance of
Solid Waste Facility Permit (SWFP).

1.13 California Native American Tribes Consultation

P
ursuant to Publi
c Resources Code section 21080.3.1
,

on May 4, 2022, the City received a
response for consultation from a representative of the Confederated

Villages of Lisjan.

Consultation occurred on

May 18, 2022,
during which

the tribe
posed

no concerns with the
propose
d
project
or potential mitigation measures
as it relates to impacts to tribal cultural
resources and cultural resources. See
Section 4.
16 ,

Tribal Cultural Resources
,
of this checklist for
more detail
.

6 The existing WCCSL facility operates under an

existing City of Richmond Conditional Use Permit (CUP) and other resources agency permits.

1. General Project Information

Raven SR Bioenergy Project

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Blank Page

2. Project Description

Raven SR Bioenergy Project

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2. Project Description

2.1 Existing
Site Conditions

and
Ownership

Existing
conditions of the project site are shown in
Figure 2
-
0, Birdseye View of Project Site

and Surrounding
.

T
he proposed Raven SR operation would be developed on approximately 1.3 acres
that Raven
SR
would

lease within
par
t of
the existing Republic Services

BMPC property

shown in Figure 2
-
0 , however it
would

operate separately from the existing

BMPC
operation
,
which
extends west of the project site
.

Figure
2 -
1, Project Site and Raven SR Facility Areas
,

delineates
the propos
ed

2.5 -
acre
s that is referred to as the “
project site
” and highlights the 1.3
acres where the
Raven facilities

and operations
would

occur.

The
project site is relatively flat and
partially paved,
with
the remainder

consisting of

compacted soil and ruderal
groundcover

along
the north edge. N
o trees or landscaping exist.

T
he existing landfill power plant and
maintenance building

are
primary
structures
near

the project
site
,

and
both
would

remain. Existing

trailers
housing

ancillary
uses
on the site
would be
r
emoved
, and
remnant concrete foundations

from previous
uses

exist on the
north portion of the
site
.

(See Figure 2
-
0).

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

The owner of the property is West County
Sanitary
Landfill, Inc.
,

a
subsidiar
y

of Republic
Services, Inc.

2.2 Surrounding

Uses and Conditions

As highlighted in

Fi
gure 2
-
1 , the project site is
bound

by
existing fencing on the north, east and
south
, and connect
s

to the
surrounding
WCCSL
areas and operations

via existing
service
road
.

Not part of the proposed project, but within
part of
the BMPC property

shown in
Figu
re

2 -
0 , t
he
existing WCCSL maintenance building
, power plant,

and a leachate treatment facility sit within
50 to 100 feet of the
site
, and
leachate tanks

operate just west of the
north
driveway

into the
property

from the main WCCSL access road
.

Figure
1 -
3 shows the

nearby
Golden Bear Waste Recycling Facility
,

located approximately 300
feet southwest of the property
.

Also, t
he
West
County Wastewater

District Treatment Plant

and
the Wildcat
M
ars
h
Trail and trail head
parking
exist

approximately
1,000
feet
so
uth
east of the
property.

Figure 1
-
2 and Figure 1
-
3 show t
he
surrounding
expanse
consists of

components of the
340
-
acre WCCSL facility
,
which consists of several distinct operations that function as a whole.

Notably, these
areas and uses
include
grass
-
cover
ed

disposal areas

that are
landfill

mounds
,

runoff control ponds and lagoons
,
and composting

areas
, in addition to

the
tidal marshlands of
San Pablo and Wildcat Creek tidal marshlands
. Open water of San Pablo Bay is approximately

0.25 miles westward from t
he project site.
(WCCSL BMPC Draft EIR, 2003)

Figure 2-0
Birdseye View of Project Site and Surrounding (from SE) Raven SR Bioenergy Project Initial StudySOURCE: ESA, 2022; Google Earth, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator Conversion Operation
(modular building and canopy)
Conversion Operation
(modular building and canopy)
Fire Water Tank
& Equipment
Fire Water Tank
& Equipment
Export Panels/TrucksExport Panels/Trucks
Figure 2-1
Project Site and Raven SR Facility Areas
N
Raven SR Bioenergy Project Initial StudySOURCE: Raven LLC, 2022; ESA, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator Bulk Materials Processing Center Property Raven SR Facility Areas

2. Project Description

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2.3 Site Plan and
Structures

Figure 2
-
2,
Simulated

3D Site Development
, illustrates the proposed fa
cility and key operation
components

simulated in a birds
-
eye view
.

All Raven SR’s materials handling systems would be
located inside
a

proposed modular structure
.

The proposed project
would

erect a new stand
-
alone
modular structure where storage uses
and r
emnant foundations
currently exist
at the north edge

of
the property
. The proposed modular structure and ind
ustrial metal canopy

for the feed (or input)
area would

contain
three primary areas for the three
-
stage process of the operation described
below
.

F
igure
s

2 -
3 a and 2
-
3b
,
South

Elevation
s
,

illustrate the proposed facility and key operations in
elevation, and
Figure 2
-
4, Detailed Site Layout and Raven SR Facility Plan
, identifies each
component in detail.

The total new building area

would be

approximate
ly 40,000 square feet
. The

industrial
feed
material handler

would be up to
31 feet tall

and the tallest
facility

element.

Other
elements of height and size include the nitrogen tank (30 feet tall); the cooling tower and the fire water tank (both 25.5 feet
tall); and the
ind
ustrial metal canopy

over the feed/unload storage area,
the adjacent steam reformer structure, and the nitrogen tank (each 26 feet tall) .

Leachate
Tanks
Leachate
Tanks
WCCSL
Maintenance
Building
Bay Trail/LeveeBay Trail/Levee
Power
Generation
Building
Leachate Pond
Closed Class I Disposal SiteClosed Class I Disposal Site Figure 2-2
Simulated 3D Site Development
Raven SR Bioenergy Project Initial StudySOURCE: Raven LLC, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator Figure 2-3a
South Elevation (West End)
Raven SR Bioenergy Project Initial StudySOURCE: Raven LLC, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator Figure 2-3b
South Elevation (East End)
Raven SR Bioenergy Project Initial StudySOURCE: Raven LLC, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator 
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







Figure 2-4
Detailed Site Layout and Raven SR Facility Plan
Raven SR Bioenergy Project Initial StudySOURCE: Raven LLC, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator

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2.4 Technology

Raven SR
’s multi
-
patented

Steam/CO
2 Reformation technology can convert a variety of
organic

waste
feedstocks into a hydrogen
-
rich synth
esis gas (syngas)

through a three
-
step process shown
in
Figure 2
-
5 , Raven SR Process Diagram
.
7 Organic feedstocks include
biomass, municipal
solid waste, bio
-
solids, industrial waste, sewage, medical waste,
or a combination of these
,
obtained from the exis
ting
WCCSL
.

T
he first stage of the process to turn feedstock into a raw syngas begins with an externally
-
heated

“
biomass
steam

reformer
”

and a “syngas steam
reformer”
.

The

raw syngas is then
polished
,

and then processed
through purification of hydrogen
to
mak
e

the

hydrogen product
:

transportation
-
grade
hydrogen
-
rich syngas
.

The technology is strictly non
-
combustion (i.e., anoxic, indirect heating), low pressure, and a catalyst
-
free process.

As indicated in Figure 2
-
5 , e
arly in the process, t
he system seque
sters solid
carbon in a byproduct, biocarbon

(also referred

to as “biochar”)
, which is a salable product that
can be used for fertilizer or filler for concrete, for example. The biocarbon mixture also includes

elements within the organic waste feedstock (d
irt, glass, grit, rocks, inorganic salts, etc.) that are inert to the process, not gasified, and drop out in the first

stage, avoiding slag and tars.
8 The
amount of biocarbon
mixture

is approximately 15 to 20 percent of the volume of dry feedstock input.
(Also see Section 2.5,
Safety and Controls, Non
-
Combustion
, below.)

Solid material that goes through the feed handling system, including any volatile material (such
as
plastics
,
refrigerants, batteries) that may incidentally flow through to the rotary refo rmer would
be converted to syngas as they thermally decompose by exposure to temperatures in the range of 1,400

degrees
F
.

Any volatile material
would
become part of the syngas
, and
non
-
volatile, inert
material
would

report to the biocarbon solid phase.

No

emissions would be generated by any
volatile material
s that may inadvertently enter the process. (Also see
Feedstock Processing
,
below.)

As also shown in Figure 2
-
5 , the waste heat or “tail gas” from the conversion process can be blended

with existing lan
dfill gas (LFG, gas produced from the decomposition of organic solid wastes in the landfill) to generate power and increase the efficiency of the process.

At some point

in the cycle
,
the

tail gas
would

no longer recycle into the process and
instead
go to t
he
stack or
flare
, described below
.

Flare System

Raven SR anticipates use of its flare system

as

a backup for the
evacuation or venting

of
sy
n
gas
and, on rare occasion, vent hydrogen product
.

The flare system
would be in the constant state of
readiness th
rough a hoo
ded, continuous propane pilot

system. Use of the flare would be no more
than 100 hours per year and occur on three typical instances:

7 Hydrogen
-
rich
,
55 to 63 percent H
2 .

8 The biocarbon is considered sterile following thermal treatment by the first stage of the process, when biological pathogen
s (if any) are destroyed by elevated temperature and residence time of approximately 45 minutes.

Feedstock
Management
Biomass Steam
Reforming
Syngas Steam
Reforming
Syngas
Polishing
Hydrogen
Purification
Blend of
Greenwaste
and Organic
Foodwaste
Overs
To Compost
Biochar
Tailgas
Hydrogen
Product
Power GenerationBlend of LFG and
Tailgas
Stack
Or
Flare
LFG
Electricity
To Process
Supplemental
Electricity
From Grid
Richmond ONE – Simplified Block Flow Diagram
Copyright 2022 Raven SR, USA
Figure 2-5
Raven SR Process Diagram
Raven SR Bioenergy Project Initial StudySOURCE: Raven LLC, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator

2. Project Description

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1. System start
-
up: During start
-
up of the system, off
-
spec syngas
would

be

generated and
evacuated from the system to the flare for destruction of

volatiles.

2. System shut
-
down: Whether for emergency shut
-
down or planned shutdown,

the system
would

require its inventory of syngas to be vented to the

flare for destruction of volat
iles.

3. No off
-
take available: On the rare occasion when a product load -
out truck

is not available
(e.g., traffic, breakdown, etc.) or an unplanned outage on the export equipment is experienced, and arrangements are in process

for replacement and/or repair,
Raven SR
must vent valuable hydrogen

product to the flare as it
would

have no provision for
emergency storage.

These instances have been quantified in Raven SR
’s

air permit application

to BAAQMD.

In 1993, the California Environmental Protection Agency’s D epartment of Toxic Substances
Control (DTSC) determined that the Raven SR process for the production of syngas from biomass and other carbonaceous solids was not categorized as either incineration or combustion and was therefore a suitable technology for u
se in California.
9 2.5

Operations

Pre
-
Processing and Load Checks

The origin of the feedstock and the pre
-
processing and screening redundancies built into the
system processes
would

to ensure that little or no material contamination that is incompatible with t
he Raven SR process
would

be introduced to the conversion system.

First,
Republic
Services
would

grind and

screen the incoming mix of green waste and organic food waste before delivering the feedstock to Raven. Any non
-
compostable material and other prohib
ited wastes
would be
minimized

through Republic’s screening and load checking programs

that occur at
its
compost facility.

10 After screening and load checking, the organic material is pre -
processed by grinding to reduce
volume
,

provide for a uniform mixtu
re of material and particle size
, and further screen out any
remaining contaminants
.

T
he pre
-
processed organic
material would then be
delivered
approximately 2,500
feet
from the compost area to the Raven SR facility
by Republic personnel
and vehicles. The
trucks
would

consist of self
-
unloading transfer trucks or other suitable vehicles

that would discharge
loads as directed by a spotter onto the floor of
Raven SR’s

material

9 According to the definitions listed in Section 260.10, Title 40, Code of Federal Regulations (40 CFR) and Section 66260.10, Title 22, California Code
of Regu
lations (22 CCR). Also, s
ince 2017, a Raven pilot engineering unit,
sized at 100 wet pounds per day of feedstock, has been operating at the UC Berkeley’s Richmond Field Station and is permitted for operation by the Bay Area Air Quality Management District (BAAQMD) under permit Nos. 23993
and 23320.

10 A load checking program are developed in compliance with Title 14, Code of California Regulations (CCR), §17409.5, and generally address the number of load checks to be performed; the location for the storage o f
prohibited wastes removed during the load checking process that is separately secured or isolated; records of load checks and the personnel training.

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receiving area.

There

the material
would be

visually inspected and then pushed by a
loader into
storage bunkers or other designated material storage areas. The pre -
processed feedstock material
would

be fed into a metering hopper to cross a screen to remove any oversized material, and then a magnetic separator to remove any unexpected meta
l. Any oversized material would be returned
to Republic’s composting facility, and any recovered metal would

be sent for recycling.

As discussed above in 2.4,
Technology
, if any materials
are

missed by the screening processes
and enters the rotary reforme
r, those materials become part of process feed and
would

eventually
become syngas or biocarbon.

Daily Quantities and Operations

The Raven facility
would

receive
up
to 99.9

wet tons per day

of blended green waste and food
waste feedstock to produce
approxim
ately

14 tons per day of biocarbon and
up to 4,800
kilograms (kg)
(5.3 tons)
of hydrogen per day.
11 Feedstock

would
be weighed on Republic scales
before arriving at the Raven
SR site, and the

commodities that come out of the
process would be

weighed on Repu
blic scales outside of the Raven
SR
site. The

WCCSL

material
that would be
diverted to the Raven
SR
facility by Republic represents a portion of their permitted 250 tons per day of compost processing capacity
.

The
Raven SR process and facility i
s design
ed

for continuous operation without many start
-
ups or
shut
-
downs.

Accordingly, the

Raven SR system
would

run
up to
24 hours per day,
seven

days per
week,
although
an average of

1.5 days per month are planned down
times
. This
totals

approximately 8,3
00 hours
of operation per year.

Energy and Fuel Use

The plant
would

consume approximately
6 .0
+

MW of electricity (MWe) to operate and produce
the 4,800
kg of hydrogen per
day

(200 kg of hydrogen per hour)
. The majority of th
e

power
would

come from onsite power gene
ration using newly installed engine
s
,
that
would

replace
existing, inefficient
engines
.

The fuel to be used for the generation is the
existing
LFG

from the
Republic Services BMPC
, combined with the tail gas from
the
pressure swing absorber

(PSA)
unit to pu
rify the hydrogen product. Republic Services
would

receive
approximately 0.5 MW
from the power generation for
its
onsite operation needs and the rest
would

be used to power the
proposed project
. Any additional electrical power required beyond that generate d onsite
would

come from an existing PG&E power drop to the site
, as also indicated in Figure 2
-
5 .

Safety and Controls

No Combustion.

The
Raven SR’s facilit
y’s

controls
would be

distributed through the various
process islands
,

taking their direction from
a central Human
-
Machine Interface in the control
room with centralized data collection. Process setpoints would

be bounded by high/low alarm

11 While Raven SR can produce synthetic liquid fuels, the proposed
Richmond location
proposes to
only pr
oduce
transportation grade hydrogen

due to the interest of the local and regional markets for non -
fossil fuel based
hydrogen.

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limitations

to

draw

the operator’s attention to the specific problem. The control system would
represent state
-
of
-
t
he
-
art digital technology with redundant instrumentation where necessary to ensure safe operation.

Because the process itself is oxygen
-
free, there
would be

no opportunity within the process for
explosion. Piping and vessels
would
be periodically scanned
with
infrared
equipment to identify
hot spots or gas leaks that may threaten safety.

If hot spots or leaks were
identified, immediate
steps
would

be taken to correct or mediate the condition.

Also, r
emote monitoring of the facility
by Raven SR corporate
pr
ovides

oversight of the operation and early identification of problems as they development. The facility
would
maintain a “Plant Safety Handbook” and establish
procedures to be followed
if

events threaten the safety of the facility

or surroundings
. The fac
ility
would

maintain and evolve Standard Operating Procedures for aspects of the plant th at

require
frequent intervention
, for example,
accepted procedure
s

to accept a truck for loading of hydrogen
product,
to
fill to
regulated

maximum allowable pressures,

to ensure a
cool
-
down period to allow
the pressurized gas to shed the heat of compression, etc.

Safety Standards

and Maintenance
.

Raven SR units are equipped with continuous
monitoring systems and can automatically shut down plant operations without human

intervention. The project
would

comply with applicable
Environmental Protection Agency (EPA)
risk management plan (RMP) and

Occupational Safety and Health Administration (OSHA)
process safety management (PSM) guidelines
, as may be applied to the facility
to ensure the
safety of its operations staff and the surrounding community .

A maintenance program of regular
and preventative maintenance would also be implemented to maintain equipment in a reliable manner.

Fugitive Emissions.

The system is a closed proc
ess
once the orga
nic feedstock input is
managed
. Mechanical seals prevent fugitive emission from the first -
stage reformer which
operates under
mild

pressure.

The first stage vessel (SR1) has mechanical seals with pressurized nitrogen, which would prohibit
the release of fugitive emissions.

Tail gas generated by the
process is combined with LFG and used as a fuel to generate additional energy.

Odor Control.

Odors may exist from the organic feedstock input that is already produced and processed at the
WCCSL
.

N
uisance odor
from Raven
is unlikely
since

feedstock material
would

only be on the feedstock management area floor for relatively short periods of time . However,
o
dor control for the proposed
Raven SR
operation
would

be in place to minimize possible odors.

Also, t
he proposed industrial metal canopy
would

be placed over the feedstock floor and infeed
equipment to prevent stormwater
contact.

O
dor control
w
ould be added to the management area if
objectionable odors
occur.

The facility could also store topical
treatment solutions (non
-
toxic and
biodegradable) onsite, which would be applied to neutralize odors if an immediate need arises.

Hydrogen

Storage and

Export Panel.

The hydrogen product is compressed for short term
storage before being exported via truck
-
m
ounted tube trailers for delivery to facilities using
hydrogen for transportation or processes needing green hydrogen .

There is no compression tank
in the design
.

T
he produced hydrogen
would

be onboarded by
a
hydrogen gas export panel
designed by a global
manufacturer of hydrogen fueling stations

to industry standards
,

2. Project Description

Raven SR Bioenergy Project

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Init
ial Study

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incorporating best
-
practice Health, Safety, Security and Environment (HSSE) design
. The panel

is

compliant with
National Fire Protection Association (NFPA)
industry standards for handling
hyd
rogen.

Onsite
Water Tank /
Fire Equipment
.

A

new
250
,000
-
gallon

integrated

fire

water tank and
diesel engine
is proposed

in the northeast corner of the site

emergency use
, as required by fire
department regulations

The fire water tank would be up to 25.5
feet tall
.

(
Shown in
Figure
s 2
-
1 through 2
-
4 .)

2.6 Employment

Raven
would

employ

approximately
three

to
four

employees per shift for the operation of the
Raven facility, for a total of
nine

to
12 new employees to cover all shifts and provide necessary suppor
t of the facility.

The facility would not involve customers onsite
.

2.7 Transportation and Circulation

As indicated under
“
Safety Controls”
above, t
he proposed project
would

export the produced
hydrogen offsite via truck
-
mounted tube trailers

(shown in Figures

2 -
2 through 2
-
4)
.

The
operation
would

involve
up to
approximately
12 hydrogen tube trucks and
up to approximately 15

biocarbon trucks (total
37 trucks
) per week
,

each
with an average trip of 40 miles

after leaving the
site
.

Considering this with other tru
cks and employees coming to and leaving the project site daily, the project is estimated to generate about 130 vehicle trips on a typical weekday.

In addition,
the Raven SR system
would

only use feedstock from ongoing existing
BMPC

operations on the prope
rty

that would not leave the WCCSL site.

Figure
s

2 -
2 and
2 -
4 show
where
WCCSL feedstock supply trucks would approach and exit the Raven facility from the feedstock prep area
,

and
in addition to Figure
2 -
3 a

show three stalls where the tube
trucks

would
conn
ect to
a hose and receive the hydrogen product. The t
ube trailers
would
idle for
no more than
five

minutes once at project site, as required per State regulations .

2.8 Construction
,

Site Coverage

and Drainage

Raven anticipates
initiating construction activity

on the project site
in
Fourth

Quarter

of
2022
,
which would contin
ue for approximately
eight

months.

Start
-
up of the plant

is projected to

begin

in early
the Second or Third
Q
uarter

of 2023.

Construction proposed is to demolish
the existing
materials

and r
emove existing equipment

from
the project site
, lightly regrade the site, add up to six inches of fill, and erect
the new facility. The
existing project site is mostly paved and partially pervious compacted soil and ruderal groundcover (see Figure 2
-
1 ). E
x
isting materials

to be excavated include

remnant
concrete
foundations that
would

be pulverized and partially used as fill material.

The maximum
depth of excavation would be up to 2.5 feet. All excavation spoils and remaining concrete debris
would

remain o
n the landfill site.

Minimal
fill
, approximately 250 cubic yards,

2. Project Description

Raven SR Bioenergy Project

23 ESA

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Initial Study

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2022

would be hauled on site

for grading
; only demolition materials (asphalt and concrete) would be off hauled.

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

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

1.21 acres of impervious area (including modular structures), resulting in a total of 1.97 acres (or 78 percent) of impervious area on the site.

Approximately 0.53 acres of unpaved area along the
north edge of the site would remain undisturbed. There are no natural drainage paths on the site.

The project would adhere to all applicable regulatory stormwater runoff controls and would

pursue its own N
ational Pollutant Discharge Elimination System (NPDES) permit. The project’s stormwater plan would be integrated into the existing WCCSL system and ensure drainage from the proposed project site
would

drain towards existing stormwater runoff control ponds
(or
bioretention facility) to which the rest of the WCCSL property currently drains.

2.9 Off
-
site Improvements: Landscaping

As part of the proposed project, off
-
site landscaping improvements to the Wildcat Marsh Trail and trail head parking located approximat
ely 1,000 feet east of the project location. Due to
limited space and potential safety hazards, no new plants or vegetation would

be installed within
the Raven project site. Instead, new trees
would

be added to the public parking area near the
trailhead.

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

planted would be
associated with
1 5
-
gallon containers

3. Environmental Factors Potentially Affected

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

Aesthetics
Biological Resources
Geology, Soils and Seismicity
Hydrology and Water Quality
Noise/Vibration
Recreation
Utilities and Service Systems
Agriculture and Forestry Resources
Cultural Resources
II Greenhouse Gas Emissions
II Land Use and Planning
Population and Housing
II Transportation
Wildfire
Air Quality
Energy
Hazards /Hazardous Materials
Mineral Resources
Public Services
Tribal Cultural Resources
Mandatory Findings of Significance
Determination: (To be completed by Lead Agency)
On the basis of this initial study:

I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.

I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.

I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.

I find that the proposed project MAY have a "potentially significant impact" or "potentially significant unless mitigated" impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.

I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, no further environmental documentation is required. (/• /.>/\!•JL.
f.^
1^- 10 [ 07 i ^'-^
^ignatyre
/^'
Date
Printed Name For
Raven SR Bioenergy Project
Initial Study
24 ESA /D202100382
October 7, 2022

4. Environmental Checklist and
E
valuation

Raven SR Bioenergy Project

25 ESA

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Initial Study

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4. Environmental Checklist and
Evaluation

4.1 Aesthetics

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Les
s

than

Significant

Impact

No

Impact

Aesthetics

Except

as

provided

in Public Resources Code Section 21099, would
the

project:

a)

Have

a
substantial

adverse

effect

on

a

scenic

vista?

b)

Substantially damage

scenic resources, includ
ing,

but

not

limited to, trees,

rock outcroppings,
and

historic

building

within
a

State

Scenic Highway?

c)

In

non
-
urbanized

areas, substantially

degrade

the

existing

visual

character

or

quality

of public views of

the
site

and its surroundings
?

(Public

views are those

that

are

experienced

from publicly

accessible

vantage point).

If

the

project is

in

an

urbanized

area,

would

the

project conflict

with

applicable zoning and

other

regulations

governing

scenic quality?

d)

Create

a

new
source

of

substantial

light or

glare

which

would

adversely

affect
day

or

nighttime

views

in

the

area?

Setting

The
project site is within the
WCCSL
within

an

industrial
, commercial,

and open space
setting of
North Richmond. It is an integrated solid
waste management and

disposal facility and does not
have significant visual value.

Grading on the site over the years has
resulted in

topographic

variation
s created by the
hill forms
or mounds that are
the grass
-
covered landfills
. The hill forms

range
from

between elevations 110 and 160 feet
above mean sea level, with up to an additional
seven
feet of soil layer

(
WCCSL BMPC Draft EIR, 2003)
.

The area has

little or no distinctive
visual features
, except for

l
eachate

treatment
ponds
,
runoff control ponds and
lagoons,

and
marshlands of Wildcat Creek.

Despite the abse
nce of significant visual value

within the WCCSL itself, the site

provides
extensive views in all directions
, including u
nobstructed panoramic views of San Pablo Bay
, San
Pablo Ridge and Mt. Tamalp
ais across the Bay
.

The visual quality of the WCCSL has been
assessed

in n
umerous
CEQA analyses over the years
,

and
each
determined that no aspect of the
WCCSL operations would significantly affect visual quality .

(
WCCSL BMPC Draft EIR, 2003)

Evaluation

a)

Have a substantial adverse effect on a scenic vista?

4. Environmental Checklist and
Evaluation

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ial Study

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Less than Significant Impact
.

Visual access th
e

W
CCSL from nearby
public
areas
are
distant and limited
, largely because
the
surrounding

areas are mostly at
lower

elevation
s

than that
of the WCCSL; dista
nt views are blocked by buildings or landscaping.

Views
toward the WCCSL and the project site from Richmond Parkway are blocked by trees and the property is difficult to distinguish

from adjacent and background across the Bay
.

Northbound and southbound mot
orists on the Richmond Parkway can view

the WCCSL,
but views are limited, short
-
term and sometimes obscured or blocked by median

landscaping or intervening trees and buildings. The proposed project site within part of
the BMPC area

is not visible from offs
ite areas
as it is at an even
lower elevation

and
behind intervening berms and
levees
.

Figure 4.1
-
1, Wildcat Marsh Trail Approach Toward Project Site (from East) ,
captures part of the project site that would be visible to users of this public trail. The v
iewshed from this location does not capture any scenic vistas in the direction of the project site. Views toward the opposite direction of the site from the trail provides direct expansive views of the Wildcat Creek Marsh. Moreover, once developed, the fac ilities
will appear consistent with the industrial nature of the existing visible facilities. The project
would

not have an adverse effect on a scenic vista.

The impact would be less than
significant.

b)

Substantially damage scenic resources, including,

bu
t not limited to, trees, rock
outcroppings, and historic building within a State Scenic Highway?

No Impact
.

No
designated
scenic highways currently exist
within the City of Richmond,
according to California Scenic Highway
Program
mapping system.
(Caltrans,

2016
)

While the City’s prior 1994 General Plan and General Plan EIR identified portions of Richmond Parkway as having a positive aesthetic value, the proposed
project site is not
visible from the parkway. (Richmond, 2011)

c)

In non
-
urbanized areas, substa
ntially degrade the

existing visual character or
quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project confl
ict with applicable zoning and other
regulations governing scenic quality?

Raven SR Bioenergy Project Initial Study
Figure 4.1-1
Wildcat Marsh Trail Approach Toward Project Site (from East) SOURCE: ESA, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator

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Less than Significant Impact
.

The 340
-
acre WCCSL facility
,

in which the project site
sits
,

consists of several distinc
t operations that function as a whole. Notably, these
operations and areas
include
grass
-
covered disposal areas
, notably the main
central
,

landfill

hill
,

runoff control ponds and lagoons, and composting
areas
, in addition to
the
tidal marshlands of Wildcat

Creek
.

As previously stated in this section, numerous
e
nvironmental reviews
pursuant to

CEQA have been conducted on all WCCSL activities,
all of which determined that none of the activities would significantly affect the visual quality of the facility.

Th
e proposed
project

could

be visible from points along the adjacent and lower Bay Trail
, since se
gments of the Trail allow users
to observe, from a safe distance, some
recycling activities within the WCCSL

property
. T
o the extent that the proposed project
f
acilities and operation

c
ould

be visible, the views
would

be distant and would not be
adverse
relative

to other visible WCCSL
activities.

Figure 4.1
-
2, Onsite View Toward
Project Site
, shows the existing
visual character

in which

the proposed project would

exists.

All feedstock material for the proposed operation
would

be
organic
material
s sorted from
the existing BMPC operation; no feedstock
would

be brought directly to the Raven
facility from offsite.

Product from the project operation
would

leave the pr
oject site in
hydrogen tube trucks and biocarbon trucks
. Therefore, o
perations of the Raven facility
are not expected to be a source of
litter that

could exacerbate litter and dumping in the
nearby neighborhoods.

Overall, t
he project’s effect on existing
visual character or quality of public views of the
site and its surroundings would be less than significant.

d)

Create a new source of substantial light or glare

which would adversely affect day
or nighttime views in the area?

Less than Significant

Impact
.

Many activities
within

the WCCSL facility operate 24
hours a day, seven days per week, including the
BMPC activities

and waste recovery
operations. Other onsite processing operations operate until midnight. All existing operations operate under approved C
ounty and City use permits, which requires all
lighting system
s

to reduce glare and to not substantially impact area residents.

Existing
lighting is varied and includes various sizes of portable and directional flood lights

on
certain operations.

Figure 4.1-2
Onsite View Toward Project Site
Raven SR Bioenergy Project Initial StudySOURCE: ESA, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator

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The proposed project would also operate 24 hours a day, seven days per week, and would

be developed within an existing, functional area of the BMPC operation, which is currently lighted.

The project proposes LED lighti
ng mounted on 30
-
foot
-
tall poles.

Like
the existing WCCSL and BMPC conditions,
the

additional lighting would be focused and
shaded, incorporating directional shading
(down
-
shot reflectors) to limit light pollution
during

night operation
s
.

The project would

place nine single
-
light fixtures at throughout
the site and three double
-
light fixtures in the truck loading area in the south portion of the site.

Also, the continuous
propane
pilot light

that fuels the flare system used as needed to
evacuate or vent org
anic
sy
n
gas
or

on rare occasion vent hydrogen product
, would
be
hooded
, thus minimizing its v
isibility

from offsite
.

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

Moreover, any new lighting would not
affect nighttime views
in the area.

This i
mpact
would be less than significant.

References

Cali
fornia Department of Transportation

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

City of Richmond, 2011.

General Plan 2030

EIR
. August
2011
.

Contra Costa County
, 2003
. Draft Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions ,
SCH#
2002102057
.

November 2003.

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4.2 Agriculture and Forestry Resources

Env
ironmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Agriculture

and

Forestry

Resources

In

determining whether

impacts

to

agricultural

resources

are

signif
icant
environmental

effects,

lead

agencies may

refer

to

the

California Agricultural

Land Evaluation and Site Assessment

Model

(1997)

prepared

by

the

California
Dept.

of
Conservation

as

an

optional

model

to
use
in assessing

impacts
on

agriculture

and

farmla
nd.

In

determining
whether

impacts
to

forest

resources,

including

timberland,

are

significant

environmental
effects,

lead

agencies

may

refer

to

information compiled by the

California

Department
of

Forestry

and Fire

Protection regarding

the
State’s

inventor
y

of

forest

land,

including
the

Forest

and

Range Assessment Project
and

the

Forest

Legacy

Assessment
project;
and

forest

carbon

measurement

methodology provided

in

Forest

Protocols

adopted

by
the

California Air

Resources Board.

Would

the

project:

a)

Convert

Prime Farmland,

Unique Farmland, or

Farmland of

Statewide

Importance (Farmland),
as

shown

on

the maps

prepared

pursuant

to

the

Farmland
Mapping and

Monitoring

Program

of

the

California

Resources

Agency,

to
non
-
agricultural

use?

b)

Conflict

with

existing

zoning for

agricultural

use,

or

a

Williamson

Act contract?

c)

Conflict

with

existing

zoning for,

or

cause

rezoning

of,

forest land

(as
defined

in Public Resources

Code

Section

12220(g)),

timberland
(as

defined by Public

Resources

Code

Section 4526),

or

timberland

zoned

Timberland

Production
(as

defined
by

Government

Code
Section

51104(g))?

d)

Result

in
the

loss

of

forest

land

or

conversion

of

forest

land
to

non
-
forest use?

e)

Involve

other cha
nges

in
the

existing

environment

which, due

to

their

location

or

nature, could result

in

conversion

of

Farmland,

to

non
-
agricultural

use

or

conversion

of forest

land
to

non
-
forest use?

Setting

The p
roject site
and its surroundings are
zoned for
“Open

Space”
, and has no history of
agricultural uses (Richmond, 2012).

Richmond sanitary service operations initiated
within the
area that is now the WCCSL

in the early 1950s

on previously undeveloped land.

Evaluation

a
)

Convert Prime Farmland, Unique Farmland
, or

Farmland of Statewide Importance
(Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program
(FMMP)
of the California Resources Agency, to non
-
agricultural use?)

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No Impact
.

The p
roject

site is

located entirely
within a
n area of and
surrounded by
industrial
, commercial and

open space use
s
. The site is not identified as Prime Farmland,
Unique Farmland, or Farmland of Statewide or

Local Importance by the FMMP, bu
t is
designated as Other Land
,

and

is

surrounded by

l
ands designated as

Urban Land and
Other Land
. The proposed p
roject would have no impact on important farmland.

(DLRP,
201
2)

b)

Conflict with existing zoning for agricultural use, or a

Williamson Act contract?

No Impact
.

The p
roject site
and its surrounding
s are
zoned for
“Open Space”
, and
has

no
history of agricultural uses

(Richmond, 2012)
.

Also,
the site is not covered by a
Williamson Act contract

(DLRP, 2012)

Therefore
, the
proposed
p
roject would
have no
impact regarding

existing agricultural zoning or a

Williamson Act contract
.

c)

Conflict with existing zoning for, or cause rezoning

of, forest land (as defined in
Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Producti on (as
defined by Government Code Section 51104(g))?

No Impact
.

The proposed project

site is not zoned as forest land or timberland, and there are no forests on the
project

site. No impact would occur with implementation of the
proposed project
.

d, e
)

Resu
lt in the loss of forest land or conversion of

forest land to non
-
forest use?
Involve other changes in the existing environment

which, due to their location or
nature, could result in conversion of Farmland, to non
-
agricultural use or
conversion of forest
land to non
-
forest use?

No Impact
.

As stated above, the proposed project

is not zoned as forest land a
nd there are
no forests on the project site. The p
roject would not result in the loss of forest land or
conversion of forest land to non
-
forest uses, and
would have no impact.

Also, the project

would be constructed and operated entirely within a previously developed area

within the WCCSL that is

designated as Other Land by the FMMP. The
project site

does not contain farmland
or forest land
and there are no
aspects of the
p
roject that would affect any agricultura
l land or forest land off
-
site. Therefore, the
proposed project
would not result in conversion of farmland

or forest land
, on
-
site or off
-
site, to a non
-
agricultural use

or

non
-
forest use. The
p
roject

would have no impact.

References

California Department of Conservation, Division of Land Resource Protection (DLRP), 201 2 .

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

4. Environmental Checklist and Evaluation

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

City of Richmond, 2012.

Richmond General Plan 2030: Land Use Element.

April 25, 2012.

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Evaluation

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ial Study

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4.3 Air

Quality

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporat
ed

Less

than

Significant

Impact

No

Impact

Air Quality

Where

available,

the significance

criteria

established by
the

applicable air

quality management district

or

air

pollution

control

district

may

be

relied

upon

to

make

the following determinations.

Would

the

project:

a)

Conflict

with

or

obstruct

implementation of
the

applicable

air

quality plan?

b)

Result

in
a

cumulatively

considerable

net increase

of

any

criteria pollutant for

which

the

project

region

is

non
-
attainment

under

an

applicable

federal

or

State

ambient

air

quality

standard?

c)

Expose

sensitive

receptors
to

substantial

pollutant

concentrations?

d)

Result

in other

emissions (such

as

those

leading

to

odors

or) adversely

affecting

a
substant
ial

number

of

people?

Setting

The project
site

is

located in
Contra Costa

County, which is in the San Francisco Bay Area Air
Basin (
SFBAAB
), within the jurisdiction of the Bay Area Air Quality Management District (BAAQMD).

The SFBAAB is currently des
ignated as a nonattainment area for state and national
ozone standards and national particulate matter ambient air quality standards. Development projects can contribute to a region’s adverse air quality impacts on a cumulative basis so the BAAQMD consider
ed the emission levels for which a project’s individual emissions would be cumulatively considerable when developing thresholds of significance for air pollutants. The significance thresholds used for project construction and operational impact analyses ar e based on
thresholds set in the BAAQMD’s CEQA Guidelines (BAAQMD 2017b).

For the purposes of this air quality analysis, sensitive receptors are defined as facilities and land uses that include members of the population that are particularly sensitive to the effects of air
pollutants, such as children, the elderly, and people with illnesses. Examples of these types of uses include schools, hospitals, and daycare centers. Residential areas are also considered sensitive to poor air quality because these sens
itive individuals could be present there, and people
usually stay home for extended periods of time, which results in greater exposure to ambient air quality
.

There are no sensitive receptors within 1
,
000 feet of the
project

site. The nearest sensitive
rec
eptors
to

the project site
are

r
esiden
ces at generally West Gertrude Avenue/Malcolm Drive
(
approximately 0.
75 miles

southeast
),

Verde Elementary School

at 2000 Giaramita Street
(approximately

1.1 miles

southeast
)
,

and

Contra Costa Health Clinic

at 1501 Fre
d Jackson Way
(
approximately

1.2 miles

southeast
)
.

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Evaluation

a)

Conflict with or obstruct implementation of the applicable air quality plan?

Less than Significant Impact
.

BAAQMD is the regional air quality authority in the
p
roject area.

Primary goals of
BAAQMD’s adopted

2017 Clean Air Plan

are to protect
public health by achieving attainment of air quality standards

(BAAQMD, 2017a)
. The
plan includes a wide range of proposed control measures, which consist of actions to reduce the non
-
attainment pollutant
s
:
state and federal 8
-
hour ozone standard, the state 1
-
hour ozone standard, the state PM
10 standard, and the state and federal PM

2.5 standards
.

BAAQMD guidance states that “if approval of a project would not result in significant and unavoidable air quali
ty impacts, after the application of all feasible mitigation, the project would be considered consistent with the Clean Air Plan” (BAAQMD 2017b).

As
indicated in the discussion of
criteria “
b
”

and
“
c
”

below, the
p
roject would not result in
significant air
quality impacts. Therefore, this impact would less than significant .

b)

Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non
-
attainment under an applicable federal or state
ambient air quality st
andard?

Construction

Emissions from the construction phase of the project would be generated primarily from heavy duty equipment such as excavators, cranes, and forklifts.

C
riteria air pollutant
emissions
from equipment and on
-
road vehicle exhaust
were e
stimated using CalEEMod
(version 2020.4.0)
;

modeling output files are included in
Appendix A

to this checklist
.

Construction

is assumed to take place over
a
n eight
-
month period
. Project specific data
for construction phasing schedule and equipment fleet pr ovided by the
P
roject
A
pplicant
was used in the model to estimate emissions
for

the construction period.

The total
emissions
(without mitigation)
generated over the duration of construction
were

divided by
the number of construction days for each
partial
c
onstruction year to determine average
annual

emissions from construction. Emissions from equipment and vehicle exhaust are presented in
Table
4 .3
-
1 .

As shown in the table, emissions of
reactive organic gases
(ROG) and nitrogen oxides (NOx), which are ozone

precursors, and particulate matter
(PM
10 and PM

2.5 )
would all be below their respective significance thresholds, which for construction have been established by BAAQMD in terms of average annual

emissions.

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T
ABLE

4 .3
-
1 A
VERAGE
D
AILY
C

ONSTRUCTION
-

RELATED

C

RITERIA
P

OLLUTANT
E

MISSIONS

(

TONS PER YEAR
)

W
ITHOUT
M

ITIGATION

Project Average Daily
Construction Emissions by
Year

ROG

NO
x

Exhaust PM
10 Exhaust PM

2.5 2022

0 .
11 1.00

0.04 0.04

2023

0.06 0.48

0.02 0.02

BAAQMD Threshold for
Significant Construction Imp
acts

10 10

15 10

Potential Significant Impact?

No

No

No

No

SOURCE:

ESA (Appendix A

to this checklist
)

Operations

After
the

project is built, operational emissions, including
stationary,
mobile
,

and area
sources, are anticipated to occur continuously th
roughout the project’s lifetime.

The
project is anticipated to begin operations in 2023.

The
P
roject
A
pplicant has submitted an air permit application that includes multiple stationary sources
,
shown in
Table
4 .3
-
2 . According to the applicant’s air permit

application, the majority of emissions
would

be generated from the biogas engine
combustion process, where the engines emit exhaust that heats up a green waste rotary drier. The biogas engines are included in the list of proposed permitted sources, along with a green waste storage pile of up to 200 tons, a sheltered storage of limestone pellets

would

be used as a co
-
feed to the feedstock

needed to reduce acid gas formation in the
system process, a diesel
-
fired fire pump engine, as well as a flare that is a

backup for
the

evacuation

or venting
of organic
syngas

or on rare occasion vent hydrogen product
.

Fugitive emissions from piping components such as valves and pumps are also anticipated. Cooling towers, pressure storage tanks, raw water storage tanks, tre ated
water storage tanks, bisulfite storage tanks, anti
-
scalant storage tanks, and condensate
recovery tanks are exempt from the permit requirement under BAAQMD Regulation 2, Rule 1 (BAAQMD 2017c), as described in the permit application.

Table
4 .3
-
3 shows
the
anticipated emissions from the permitted sources.

Notably, the project
would

replace an existing biogas
-
fired engine with
three (
3 )

newer,
lower emitting, and more efficient

Waukesha or Jenbacher

engine
s.

This replacement
would

result in a lower emiss
ions
profile
in contrast to operating the facility using the
existing engine. The project is also expected to increase the functional use of landfill -
produced biogas, thereby reducing the amount
of organic gas sent to a flare for
venting or
evacuation

and
ultimately reducing the flare
-
based emissions.

Operational
-
related
mobile source
activities, such as
employee commuting, truck trips for
delivery and materials hauling
, use of landscape equipment,
and other sources w
ould
generate emissions of criteria air

pollutants, their precursors, and
toxic air contaminants
(
TACs
)
. Area sources generally include fuel combustion from space and water heating,

4. Environmental Checklist and Evaluation

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landscape maintenance equipment, and fireplaces/stoves, evaporative emissions from architectural coatings, and co
nsumer products.

Table
4 .3
-
4 shows the emissions from
operational emission sources that are not part of the air permit application.

T
ABLE

4 .3
-
2 A
IR
P
ERMIT
A

PPLICATION
'
S
A
VERAGE
A
NNUAL
O

PERATIONAL
C

RITERIA
P

OLLUTANT
E

MISSIONS

(

TONS PER YEAR
)

Project Oper
ations
Emissions by Source

CO

NO
x

VOC/ROG

SO
2 Exhaust
PM
10 Exhaust
PM

2.5 Biogas engines

50.69 7.19

5.70 6.63

5.13 5.13

Green waste off

gas

N/A

N/A

2.38 N/A

N/A

N/A

Fugitive component leaks

N/A

N/A

0 .63

N/A

N/A

N/A

Lime
stone

handling

N/A

N/A

N/A

N/
A

0 .003

0 .0005

Lime
stone

storage

N/A

N/A

N/A

N/A

0 .016

0 .0024

Flare

0 .0
92 0.16

0 .00
98 0
.000
2 0
.00
86 0
.00
86 Fire pump engine

0 .0
55 0.04

0 .00
22 0
.0000
9 0
.003
3 0
.003
3 Total

50. 84

7.39 8.72

6.64 5.1
6 5.1
4 SOURCE:

Ramboll Permit Application (Raven
,

2022
a
)

T
ABLE

4 .3
-
3 C
AL
EEM
OD
A
VERAGE
A
NNUAL

O

PERATIONAL
-
R
ELATED

C

RITERIA
P

OLLUTANT
E
MI
SSIONS

(

TONS PER YEAR
)

Project
Operations

Emissions
by
Category

ROG

NO
x

Exhaust PM
10 Exhaust PM

2.5 Area

0.1 8

0 0

0 Energy

<0.01

0.05 <0.01

<0.01

Mobile

0.14 0.
1 6

<0.01

<0.01

Offroad

0.1 5

1.4 5

0.05 0.04

Waste

N/A

N/A

0 0

Water

N/A

N/A

0 0

Total

0. 47

1. 66

0.0 5

0.05 SOURCE: ESA (
Appendix A

to this checklist
)

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T
ABLE
4 .3
-
4 A
VERAGE
A
NNUAL
O

PERATIONAL
-

RELATED

C

RITERIA
P

OLLUTANT
E
MI
SSIONS

(

TONS PER YEAR
)

Project
Op
erations

Emissions

NO
x

VOC/ROG

Exhaust
PM
10 Exhaust
PM

2.5 Air Permit

7.39 8.72

5.1 6

5.1 4

CalEEMod

1. 66

0. 47

0.0 5

0.05 Overall Total

9.05 9.
1 9

5. 2
1 5.1
9 BAAQMD Threshold for Significant
Operational

Impacts

10 10

15 10

Potential Significant Impact?

N
o

No

No

No

Source
: ESA (Appendix A

to this checklist
) and Ramboll Permit Application (Raven
,

2022
a
)

These tables show that on a project
-
level
assessment, emissions do not exceed significant
thresholds determined by BAAQMD for criteria pollutants emitted

during operations, and
therefore are less than significant.

Construction Air Emissions

Less than Significant Impact
.

Construction activities would result in emissions of
the
following non
-
attainment
pollutants
: r
eactive organic gases (ROG) and nitrogen o
xides
(NOx)
, which are ozone precursors, and

particulate matter (PM
10 and PM

2.5 ).

These
pollutant

emissions would be generated
in the form of fugitive dust
(PM
10 and PM

2.5 )

and in
the form of exhaust
by construction equipment, on
-
road vehicle trips of haul

trucks for
delivering construction material, water trucks for site dust control, and construction worker commutes to and from the project site.

Construction Dust

Less than Significant Impact
, after

Mitigation
.

Activities that generate dust include
excava
tion and equipment movement across unpaved construction sites. Dust can be an irritant causing watering eyes or irritation to the lungs, nose, and throat.

E
xcavation,
grading, and other construction activities can cause wind -
blown dust that adds PM
10 and
P
M

2.5 to the local atmosphere. The BAAQMD has taken a qualitative approach to addressing fugitive dust emissions during construction, such that any project that implements the BAAQMD Basic Construction Mitigation Measures Recommended for All Projects (Best
Management Practices)
would not result in a significant impact with
respect to fugitive dust

(BAAQMD 2017b)
.

Mitigation Measure AQ
-
1: Best Management
Practices
, provided below, spe
cifies BAAQMD recommended measures and would apply
to all individual project
s to address construction dust
.

In conclusion, while air emissions
from construction equipment are all below the BAAQMD CEQA thresholds construction dust emissions are always considered significant within the SFBAAB unless the mitigation measures below are

applied.

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Mitigation Measure
s

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 lev
el:

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 mater ial 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 sh
all 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 ei
ther 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 prope r
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 numbe r shall
also be visible to ensure compliance with applicable regulations.

Operational Air Emissions

Less than Significant Impact.

Based on the operational emissions modelled and

summarized

in

Table

4.3 -
4 above,

activities

related

to

operating

the

bioenerg
y

system
would all be below significance thresholds.

c)

Expose sensitive receptors to substantial pollutant concentrations?

Construction

Less than Significant Impact
.

Construction equipment and associated heavy
-
duty truck
traffic generate diesel exhaus
t, which is a known TAC. Construction exhaust emissions may pose health risks for sensitive receptors.

However, there are no sensitive receptors

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nearby the project site, which is zoned for
open space

us
es
.

The nearest sensitive
receptor
s are

0. 75

miles sou
theast
, or more than 1
,
000 feet, which is the distance
considered in the BAAQMD CEQA
G
uidelines
.

Therefore, any concentrations of
diesel
particular matter (
DPM
)

generated during construction would be less than significant.

Operations

Less than Significan
t Impact
.

The proposed project would introduce a new source of
DPM and PM

2.5 emissions due to the installation of an emergency diesel generator at the centralized treatment facility

that
would

use
California Air Resources Board (CARB)
-

certified diesel fue
l. Emergency generators would be subject to BAAQMD permit

requirements, which would ensure that operation of these generators would not significantly impact nearby receptors
.

These activities would result in minimal TAC
emissions for emergency operations o
nly (typically less than 50 hours per year), and
therefore have negligible associated health risks to existing sensitive receptors in the area ,
the nearest being 0.
75 miles from the project site
.

Other annual TAC concentrations from
non
-
emergency operation
s
of the generator
were
estimated
in an annual emissions
summary for operations at the
project

site (Raven
,

2022
a
).

A
n HRA was not conducted
due to there not being any sensitive receptors within 1 ,
000 feet of the project site and
trigger levels not applyin
g to the
p
roject.

There would also be a rubber
-
tired loader
associated with operations that would run 24 hours a day 7 days a week. Emissions from the loader were calculated using CalEEMod and included in the operational emissions, shown in
Table 4.3
-
4 .

d
)

Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?

Less than Significant Impact
.

Existing uses on and near the WCCSL include operations
that are among t
ypical odor sources of concern
. These

incl
ude wastewater treatment
plants, sanitary landfills, transfer stations, composting facilities, petroleum refineries, chemical manufacturing facilities,
and
auto body shops. As a hydrogen production
facility, the
p
roject
would

include organic feedstock proc
essed during operations at the
WCCSL
, which is

known to
create odors.

WCCSL
implement
s

various
control

measures

to minimize odors

associated with operation of the mixed waste processing.

The nearest sensitive receptors to the project site are residences a
t generally West
Gertrude Avenue/Malcolm Drive, approximately 0.75 miles southeast .

This is closer than
the 1.0
-
mile odor screening distance for greenwaste handling established in the BAAQMD’s CEQA Guidelines
.

Also, an elementary school and a health clinic

exist
approximately 1.1 and 1.2 miles, respectively, from the project site

-

slightly beyond the
screening distance
.

Uses
between the project site and these
the nearest sensitive receptors
to the southeast
include the
West
County Wastewater

District Treat
ment Plant,
EBMUD’s North Richmond Water Reclamation Plan
t
, the Richmond Sanitary District,
and other refuse services, automobile repair and towing businesses, an
d

lawn services,
etc.

Topography in the area is relative flat, and no substantial areas of veg etation exist.

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

N
uisance odor
from Raven
is unlikely
since

feedstock material
would

only be on the
feedstock management area floor for relatively short periods of time .

Nor would
the
sy
stem’s
tail gas
or the as
-
needed
flare

generate noticeable odor
.

Also, other than the
input of organic feedstock within the
system
, the
process

would not involve the storage

or
processing

of
other
potentially odor
ous
materials

nor contribute to odor from n
earby
existing WCCSL activities
.

Regardless, a
s described in Section 2,
Project Description¸
the project
would

involve

o
dor control
mechanisms to minimize
possible
additional
odors

from its operation. T
he proposed industrial metal canopy would be placed ov
er the
feedstock floor and infeed equipment to prevent stormwater contact.

The project may
incorporate control measures similar to those current employed by WCCSL, such as ensuring the input of feedstock into the system within a designated period of time f rom
receiving it from
WCCSL’s
o
nsite
organic material processing facility

to prevent
potential odor buildup; routine cleaning of floors, walls, and

equipment; use of odor
suppressants as

deemed necessary.

O
dor control
w
ould be added to the management area
if objectionable odors
occur.

The
Raven
facility could also store topical treatment
solutions (non
-
toxic and biodegradable) onsite, which would be applied to neutralize odors if an immediate need arises.

To the extent that any new sources of odor is
attrib
utable to the proposed project, the project applicant shall promptly log and respond to any complaints and remediated.

Therefore,

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

The impact would
be less than significant.

References

BAAQMD, 2017a
.

Clean Air Plan, Spare the Air, Cool the Climate
. April

19, 2017. Available at
https://www.baaqmd.gov/~/media/files/planning
-
and
-
research/plans/2017
-
clean
-
air
-
plan/attachment
-
a_
-
proposed
-
final
-
cap
-
vol
-
1 -
pdf.pdf?la=en
. Accessed December 2020.

BAAQMD, 2017b
.

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

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

RAVEN
,
2022
a

Air Permit Application
-
Bioenergy Facilit
y
. Prepared by Ramboll US Consulting,
Inc.
,

(Ramboll) for Raven SR, April 2022.

4. Environmental Checklist and
Evaluation

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42 ESA

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Blank Page

4. Environmental Checklist and Evaluation

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4.4 Biological

Resources

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Biological
Resources

Would

the

project:

a)

Have

a
substantial

adverse

effect, either

directly or

through habitat

modifications,

on any

species

identified
as
a

candidate,

sensitive,

or

special
-
status

spe
cies in

local

or

regional

plans,

policies,

or

regulations,

or

by
the

California

Department of

Fish

and

Wildlife

or

United States

Fish

and
Wildlife

Service?

b)

Have

a
substantial

adverse

effect

on

any riparian

habitat or

other

sensitive

natura
l

community

identified

in

local

or

regional

plans, policies,
and

regulations

or

by
the

California

Department of

Fish

and

Wildlife

or

United
States

Fish

and Wildlife

Service?

c)

Have

a
substantial

adverse

effect

on
State

or

federally protected

wetlands

(including,
but

not

limited

to,

marsh,

vernal

pool,

coastal,

etc.)

through

direct

removal,

filling, hydrological

interruption,

or

other

means?

d)

Interfere

substantially

with the

movement

of

any

native

resident or

migratory

fish

or

wildlife

species

or

with

established native

resident

or

migratory

wildlife

corridors,

or

impede the

use of

wildlife

nursery

sites?

e)

Conflict

with

any

local

policies or

ordinances

protecting biological

resources,

such

as

a
tree

preservation

policy

or

ordinance?

f)

Conflict

with

the

provisions

of

an

adopted

Habitat

Conservation

Plan, Natural

Community Conservation

Plan,

or

other

approved local,

regional,

or

State

habitat
conservation

plan?

Setting

The project site is locat
ed
in the upland area of the

approximately 340
-
acre WCCSL,
within the
context of expansive
grasslands and hills. The WCCSL borders

San Pablo Bay

and
tidal
marshland of
naturalized portions of
San Pablo
and Wildcat creeks
.

The

broader

surrounding area
of th
e WCCSL property
is a low density
industrial and open space area.

The local context in Figure
1 -
2 shows the project site located approximately 0.25
-
mile east of the
San Pablo Bay shoreline, mudflats
,

and open water. The tidal marshland of San Pablo Creek
i
s

approximately 0.3 miles north/northeast of the project site, bordering the WCCSL north boundary which is an elevated levee. As shown in Figure 2
-
0, the marshlands of Wildcat Creek sit

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approximately 280 feet south/southeast of the project site, bordering the WCCSL south boundary
,

which is also an elevated levee.

A

closed Class I landfill

is immediately north of the project site
and the main access road supports a cover of non
-
native grassland and ruderal
vegetation
species.

No trees exist on the project si
te. Several landscape trees
occur at

the Golden Bear Waste
Recycling Facility, located approximately 300 feet southwest of the project site.

Biological resources were
characterized

through the review and compilation of existing
information

and a biological

reconnaissance survey conducted by ESA biologists on June 29, 2022
.

T
he
study area included

the
project construction area

plus a 250
-
foot buffer
, to account for
potential indirect impacts to special
-
status species
. The
study area

for special
-
status plant

s
pecies

includes the
project construction area
, plus a 10
-
foot buffer due to the lack of potential for
indirect impacts to
plants.

No detailed surveys were conducted
for special
-
status plants or wildlife
or are
deemed

necessary based on the
developed and m
anipulated
conditions of the
project
site

and surroundings
, the scope of the proposed project’s construction and operations, and the
proposed standard methods to minimize disturbance to sensitive resources in the vicinity.

Species / Habitats

The uplands
of

the WCCSL are either
devoid of vegetation from on
-
going landfill operations and
roadways, or are dominated by nonnative grasses and forbs. Plant species observed in the grassland at the periphery of the project site
are dominated by non
-
native species suc
h as

Italian
rye

grass

(
Festuca perennis
), wild oats (
Avena
spp.), storksbill (
Erodium cicutarium
), bristly ox
-
tongue (
Helminthotheca echioides
), and ribwort (
Plantago lanceolata
). Several weedy species are
also present

along the margins of the site
, including fennel

(
Foeniculum vulgare
)
, wild radish

(
Raphanus

spp.)
,
black
mustard

(
Brassica nigra
)
,
curly dock (
Rumex crispus
), prickly lettuce
(
Lactuca serriola
), and iceplant (
Carpo
brotus edulis
)
. Clumps of native coyote brush
(
Baccharis
pilularis
)

are scattered through grasslands, road margins, and upper edge of the marshlands and levees.

While the highly disturbed project site provides little habitat that is suitable for special -
st
atus
plants and wildlife, the surrounding grasslands and wetlands provide habitat for a variety of wildlife and plant species. Wildlife observed in the surrounding study area during the site reconnaissance survey include
American crow (
Corvus brachyrhyncho
s
), red
-
tailed hawk (
Buteo
jamaicensis
), western bluebird (
S
i
alia mexicana
), barn swallow (
Hirundo rustica
), common raven
(
Corvus corax
), Canada goose (
Branta canadensis
), wild turkey (
Meleagris gallopavo
), black
-
necked
stilt

(
Himantopus mexicanus
), turkey

vulture (
Cathartes aura
), mallards (
Anas
platyrhynchos
), killdeer (
Charadrius vociferus
), and several gull species (
Larus

spp.)
.

Sensitive aquatic habitats occur outside of the project boundary, and include wetlands ,
sloughs,
creek channel
s
, and
the San
Pablo B
ay shoreline.

San Pablo Creek is located approximately 600
feet east/northeast of the project site and is separated from WCCSL

developed areas by a levee.

San Pablo Creek is tidally influenced and flows into the San Francisco Bay after flowing throu gh
San Pablo Creek Marsh. Emergent salt marsh vegetation occurs approximately 280 feet south/southwest of the project site within Wildcat Marsh,

0.3 miles north/northeast

of the project
site. Numerous s
horebirds, waterfowl, and other wildlife use the marsh

and mudflats for foraging
and

resting
; however, the marsh is beyond the 250
-
foot project study area
.

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A number of special
-
status animal species have been reported from
nearby
creek
s

and
marshes,
including
the
s
tate and federally
-
endangered salt marsh harv
est mouse (
Reithrodontomys
raviventris
)

and
California
Ridgway’s

rail

(
Rallus longirostris obsoletus
)
,
state
-
threatened
California black rail

(
Laterallus jamaicensis coturniculus
)
, and
several

other species considered
to be California
Species of
Special Co
ncern
and Fully Protected by the State.

Appendix B

present
s

the special
-
status species considered in the analysis, including each species’ legal or protective status, habitat requirements, and blooming period (for plants), and the potential for occurrence
within
study areas.

Higher elevations of the marsh typically provide important refuge for small

mammals and birds during storms and high tides. However, due to
the extent of
developed and otherwise disturbed habitat on the project site , the narrow band of
cover along the
lev
ee slope
, and the intensity

of human activity
,

the project site is not expected to provide
upland
retreat habitat
for wildlife species, including species associated with salt marsh and other wetland habitats
.

Several special
-
status plant

species are known from the uplands and coastal salt marsh

habitats

along the shoreline of San Francisco and San Pablo Bays, but none have been reported

from the

vicinity of the WCCSL. A single occurrence of fragrant fritillary ( Fritillaria liliacea
)

was
r
eported from the Point Richmond area in 1900, but this occurrence is believed to have been

extirpated by development, and suitable habitat is absent on the site. Other special -
status plant

species known from marshland habitat along the shoreline of San Pab lo Bay include: the State

rare soft
-
haired bird’s beak
(
Chloropyron molle

ssp.
molle
), M
ason’s lilaeopsis (
Lilaeopsis

masonii
), and San Francisco gumplant (
Grindelia hirsutula
var.
maritima
).

T
hese

California Rare
Plant Rank
1B
species
are considered rare
under

Section 13580 of the California Environmental
Quality Act (CEQA) Guidelines. None have

been reported from the WCCSL, and suitable habitat
is absent on portions of the site proposed

for improvements.

Wetlands

No wetlands or other aquatic resources occ
ur within the project site.

Jurisdictional wetlands and
unvegetated

waters extend over the northern

coastal salt
marsh,

open water habitat, and San Pablo

Creek
channel.

The sloughs,
creek channel, and bay shoreline

which border the WCCSL property
are all u
nder

tidal
influence.

The upland
portions

of the WCCSL property do

not support
wetlands, and the
engineered

basins designed for
runoff

control and leachate

treatment,

including
basins located to the south and west of the project site, are exempt

from

state

and federal wetland
jurisdiction
.

Evaluation

a)

Have a substantial adverse effect, either directly or through habitat modifications, on any
species identified as a candidate, sensitive, or special -
status species in local or
regional plans, policies, or r
egulations, or by the California Department of Fish and Wildlife or United States Fish and Wildlife Service?

A list of special
-
status species that occur in the project region was identified based upon review of existing information
, including
q
ueries of th
e California Natural

Diversity
Database (CNDDB), U.S. Fish and Wildlife Service (USFWS) Official Species List, and

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

described above

(
Appendix B
)
.

Plants

No special
-
status plant species are
expected

to occur on the
disturbed

project site. Site
preparati
on for the project would involve minimal grading for the erection of the modular building and
the
replacement of existing compacted soil, ruderal groundcover and partial
ly

pav
ed

areas

where special
-
status plants are not expected to occur
.

Hence, no
impacts

would occur to special
-
status plants.

Wildlife

The project site exists within
a
previously disturbed upland portion of the WCCSL that
do
es

not provide habitat for special
-
status
wildlife
species.

Due

to the extent of past
development,
no

special
-
status
wi
ldlife

spec
ies are expected to occur within

the project
site
. Additionally, basins and runoff control ponds located to the south and west of the project site do not provide suitable habitat for special -
status species.

Beyond the site boundaries, surroundi
ng wetland and annual grassland habitat may
provide habitat for special
-
status wildlife species. The following species are considered to have the potential to occur within these areas: short
-
eared owl (
Asio flammeus
), western
burrowing owl (
Athene cunicula
ria hypugaea
), northern harrier (
Circus hudsonius
),
loggerhead shrike (
Lanius ludovicianus
), California black rail (
Laterallus jamaicensis
coturniculus
), and California Ridgway’s rail (
Rallus longirostris obsoletus
)
.

Short
-
eared
owl, western burrowing owl,

northern harrier, and loggerhead shrike
are California
Species of Special Concern.

Uplands and wetlands outside of the project site provide potential foraging habitat for these species. Upland grassland and ruderal habitats provide potential nesting habit
at. Short
-
eared owl and northern harrier are ground nesting species, while loggerhead shrikes nest in shrubs and occasionally items such as brush piles, generally between two and four feet off the ground. Western burrowing owls nest underground in burrows
dug by mammals such as California ground squirrels
(
Otospermophilus beecheyi
)
.

California Ridgway’s
is listed as endangered under both
the Federal Endangered Species
Act (
FESA
)

and
the California Endangered Species Act (
CESA
)
, and is a state fully
-
protect
ed species. Ridgway’s rails are found in tidal and brackish marshes where they typically construct nests in or under dense marsh vegetation, such as marsh gumplant and pickleweed at an elevation high enough to avoid inundation during high tides.

California

black rail

is listed as threatened under
CESA

and is a

state

f
ully
-
p
rotect
ed s
pecies.

This
species nests and forages in tidal
emergent wetland.

Suitable marsh habitat

for both of
these species

is present within
500 feet of the project site

and multiple oc
currences are
known from marshes adjacent to or nearby the project
site
.

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In addition to the aforementioned special
-
status species, common r
aptors and other bird
species may forage
in uplands and marshes on the edges of the study area.

While no trees
exist

on the project site, trees approximately 300 feet southwest of the
project

site
at the
Golden Bear Waste Recycling Facility

have potential to
support raptor
nest
ing
. Current
activity on the project site involves large truck traffic, human activity, operat ion of
machinery and elevated noise levels.

Regardless, some bird species, such as killdeer
(
Charadrius vociferus
) and American crow (
Corvus brachyrhynchos
), tend to be highly
tolerant of human disturbance and may still nest in areas with relatively high l evels of
human activity
.

Construction

Less than Significant Impact
, after Mitigation
.

Bird species listed under FESA and
CESA, as well as non
-
ESA
-
listed birds, are afforded conservation protections. Breeding birds are protected under California Fish and

Game Code

(FGC)

Section 3503 and
raptors are protected under Section 3503.5. In addition, FGC
Section 3513 and the
Federal MBTA (16 USC, Sec. 703 Supp. I, 1989) prohibit the killing, possession, or trading of migratory birds. Finally,
FGC
Section 3800 pro
hibits the taking of non
-
game
birds, which are defined as birds occurring naturally in California that are not game birds or fully protected species.

Impacts during the non
-
breeding season are not considered
significant, primarily due to the birds’ mobilit
y and ability to access other high
-
quality
foraging habitat in the region.

Also, the project site is disturbed and provides poor habitat for nesting birds.

However, equipment staging and project construction could render the site
and adjacent areas
tempora
rily unsuitable for breeding birds due to the noise,
vibration, and increased activity levels associated with grubbing, earth moving, heavy equipment operation, and increased human presence even when the nest itself is unaffected. These activities could ca
use birds that have established a nest prior to the start of construction to change their behavior or even abandon an active nest, putting eggs and nestlings at risk for mortality. This would be considered a significant impact.

Implementation of Mitigatio
n Measure BIO
-
1: Avoid and Minimize Impacts to Nesting
Birds,
Except

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

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

To th
e 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
. I
f these activities must be

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p
erformed 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 calend ar 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 ar
eas 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 zon
es 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 adjuste
d 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 moni
tor 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 abandon
ed.

If active burrowing owl dens are found within the survey area, the P
roject
A
pplicant shall implement measures at least equal to the 2012 (or subsequent applicable) CDFW Staff Report

(CDFG, 2012),

as determined by the qualified biologist.

Mitigation Mea
sure 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 a
reas
(within 500 feet

[150 meters]

or a distance determined in coordination with
U.S. Fish
and Wildlife (
USFWS
)

or
the California Department of Fish and Wildlife (
CDFW)
),

shall

be avoided during the breeding season from February 1 through August 31.

If ar
eas 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.

T
he surveys will focus on potential habitat that
could

be
indire
ctly
disturbed by construction activities during the breeding season to ensure that rails are not
breeding

within 500 feet of project activities
.

Survey methods for rail
s

will follow
the
Site
-
Specific Protocol for Monitoring Marsh
Birds
, which was develop
ed 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 t
arget 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

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adopted by Invasive Spartina Project (ISP) and
Point Blue Conservation Science to
survey
Ridgway
’s rails at sites throughout San Francisco Bay

Estuary
.

The

survey
protocol for Ridgway’s rail
is
summarized below.

Previously used survey locations (points) should be used when available to maintain consis
tency with past survey results. Adjacent points

should be
at least
200
meters apart along transects in or adjacent to areas

representative of the
marsh
.

Point
s 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 s
urveys initiated between January 15 and February
6, the second round
performed February 7 to February 28, and the third round March 1 to March 25 .

Surveys s
hould 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, fo
llowed 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 5
00 feet (150 meters)
, then
p
roject 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 f
ollowing measures would apply to project activities

conducted duri
ng
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 visu
al 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 sea son.

Operations

Less than Significant Impact
.

Current activity on the project site involves large truck traffic, human activity, operation of machinery and elevated noise levels

associated with
the
Republic Services

BMPC property and the existing landfill

power plant.

The
proposed Raven SR operation

is not expected to significantly change the level of activity that is currently conducted within the project area and, therefore, long -
term operation of
the Raven SR operation is not expected to result in signi ficant impacts to biological
resources within the project area.

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There is also existing permanent lighting associated with the current 24 -
hour activities
of
the BMPC and the project site
. The proposed
project would not substantially

increase
existing
night
time
lighting

to result in an
adverse impact

to
existing bird species.

The
project propos
es LED

lighting
mounted
on 30
-
foot
-
tall poles. Similar to existing
conditions, the project

lighting would be focused and shaded, incorporating directional shading
(dow
n
-
shot reflectors) to limit light pollution during

night operation
s
.

The
project would place nine single
-
light fixtures at throughout the site and three double
-
light
fixtures in the truck loading area in the south portion of the site.

No
part of the propo
sed facility would exceed 31 feet in height, which is the height of the industrial feed
material handler. Other elements of height and size include the nitrogen
tank (30 feet tall)
; the
cooling tower

and the fire water tank (both 25.5 feet tall); and the
i
nd
ustrial metal canopy

over the feed/unload storage area
, the adjacent steam reformer
structure, and the nitrogen tank (each
26 feet tall
)
.

Therefore, no part of the project would

exceed

45 feet

in height, in which case the project would comply with the Ci
ty of
Richmond’s Bird
-
Safe Buildings Municipal Ordinance.

Overall, the proposed project also would not alter any of the area’s natural resources or native vegetation in a way that could adversely impact biological resources. The impact would be less than
significant.

b)

Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of Fish and Wildlife or United States Fish and W ildlife
Service?

No
I
mpact
.

The project site does not contain any riparian habitat or other sensitive natural communities. The nearest sensitive habitat is well -
preserved coastal salt marsh
occur along the San Pablo Bay shoreline
, Wildcat Marsh,

and along
the upper banks of
San Pablo Creek.

T
he project site is located 0.25 miles east of the shoreline ,

approximately 0.3 miles south of San Pablo Creek’s upper banks , and within 300 feet
of
Wildcat Marsh, which is separated from the project site by the Bay Trai l levee.

The
proposed project does not involve any activity that would affect these areas. Therefore ,

the proposed project would have no impact.

c)

Have a substantial adverse effect on State or federally protected wetlands (including, but not limited to, m
arsh, vernal pool, coastal, etc.) through direct
removal, filling, hydrological interruption, or other means?

No

Impact
.

The

project

site

does

not

contain

any

State

or

federally

protected

wetlands
.

T
he

proposed development

would not

impact

any waterbodies
i
n

any

way

and
th
erefore

would

have

no

impact

on protected wetlands
.

d)

Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede th
e use of wildlife nursery sites?

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Less than Significant Impact
.

The
project

site

is

not in a

natural condition and contains
development and current truck and other operations of the BMPC.

Due to the existing
developed nature of the site, the project site do
es not provide suitable habitat to be
considered a wildlife nursery site. Additionally, wildlife movement within the project site is restricted by existing privacy fencing that surrounds the project area. While the surrounding uplands and wetlands provide
habitat for the movement of native resident and
migratory wildlife, activities associated with the project are not expected to directly impact these areas or impede wildlife movement
. Therefore, this impact would be less than
significant.

e)

Conflict with

any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?

Less than Significant Impact
.

Construction or operation of the proposed project
would

not conflict with any local policies or ordinances pro
tecting biological resources.

There are
no existing trees on the project site, nor are any proposed

d
ue to limited space and
potential safety hazards
. However, a
s part of the proposed project
,
off
-
site landscaping
improvements
are proposed
to the Wildcat M
arsh Trail and trail head parking located
approximately 1,000 feet east of the project
site.

Eleven drought
-
tolerant trees would be
planted: either six large Coast Live Oak (
Quercus agrifolia
) or Big Leaf Maple (
Acer
macrophyllum
), and five small Californi
a Buckeye (
Aesculus californica
). Both species
are on City’s approved list of trees. Tree size planted would be associated with 1 5
-
gallon
containers
.

The

project is subject

to and
would

adhere

to the City’s local tree protection
policies and regulations.

A
lso, a
s addressed under
Section

4.12,
Noise and Vibration
,
of
this checklist,
the project
would

adhere to the City of Richmond Noise Ordinance
regarding noise levels during temporary construction activity, as well as the operational noise levels.

Therefore
, this impact would be less than significant.

f)

Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan?

No

Impact
.

The project site
does not lie within the boundaries of any an adopted Habitat Conservation Plan (HCP) or Natural Community Conservation Plan (NCCP) or any other approved local, regional, or State habitat conservation plan.

References

California Department of Fish and Gam
e

(CDFG)
. 2012. Staff Report on Burrowing Owl
Mitigation. Dated March 7, 2012.

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

Accessed
June 14, 2022
.

4. Environmental Checklist and
Evaluation

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ial Study

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CDFW. California Natural Diversity Database (CNDDB) for 7.5 -
minute topographic quadrangles
Richmond, Briones Valley, San Francisco North, Oakland West, Oakland

East, Petaluma
Point, Mare Island, Benicia, San Quentin
, Commercial Version.

Accessed
June 14, 2022
.

CDFW.

Natural Diversity Database.
2022
.

Special Animals List. Periodic publication.

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

Accessed

2022
.

California Native Plant Socie
ty (CNPS)
. Inventory of Rare and Endangered Plants (online
edition,
v9
-
01 1.
5 ),

California Native Plant Society, Sacramento, CA. Available at:
www.rareplants.cnps.org. Accessed

June 14
, 2022
.

City of Richmond, 2012.

Ric
hmond General Plan 2030: Conservation, Natural Resources and Open Space Element.

Adopted April 25, 2012.

Contra Costa County 2004.

Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions ,

SCH. 2002102057
.

June
2004
.

Contra Costa County 2009.

Addendum to the

Final

EIR

for the WCCSL BMPC and Related
Actions
,
SCH. 2002102057
. 2009
.

United States Fish and Wildlife Service (USFWS)
.

20 22
. List of threatened and endangered
species that may occur

in your proposed project location, and/or may be affected by the
Raven SR Bioenergy Project
. Consultation Code:
2022
-
0054185
.

June 14, 2022.

Wood, J.K., Nur, N., Salas, L. and O.M.W. Richmond. 2017.

Site
-
specific Protocol for
Monitoring Marsh Birds: Don E
dwards San Francisco Bay and San Pablo Bay National
Wildlife Refuges
. Prepared for the U.S. Fish and Wildlife Service, Pacific Southwest Region Refuge Inventory and Monitoring Initiative. Point Blue Conservation Science.

Petaluma, CA.

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4.5 Cultural

Resources

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Cultural

Resources

Would

the

project:

a)

Cause

a
substantial

adverse change

in
the

s
ignificance

of
a
historical

resource
as
pursuant

to

Section

15064.5?

b)

Cause

a
substantial

adverse change

in
the

significance

of
an
archaeological

resource

pursuant

to
Section 15064.5?

c)

Disturb

any human

remains, including th
ose interred

outside

of formal

cemeteries?

Setting

To determine the cultural resources sensitivity of the project site, ESA completed a records search and background research, including a review of historic maps, aerial imagery, and geologic/soils da
ta.

ESA
staff
conducted a records search at the Northwest Information Center (NWIC) of the California Historical Resources Information System on
March 23, 2022

(File No.

21 -
1575
). The
purpose of the records search was to (1) determine whether known cultura l resources have been
recorded
in the vicinity of the

project site
; (2) assess the likelihood for unrecorded cultural
resources to be present based on historical references and the distribution of nearby sites; and (3) develop a context for the identificat
ion and preliminary evaluation of cultural resources. The records search consisted of an examination of the following documents:

NWIC digitized base maps (USGS
San Quentin
, CA 7.5
-
minute topographic map), to identify
recorded archaeological sites and studi
es within a 0.
5 -
mile radius of the
project site
.

NWIC digitized base maps (USGS
San Quentin
, CA 7.5
-
minute topographic map), to identify
recorded historic
-
era resources of the built environment (building, structures, and objects) within
and adjacent to

th
e
project site
.

Resource Inventories:

California Inventory of Historical Resources, California Historical Landmarks, Built Environment Resource Directory

(BERD) (through March 2020) and
Archaeological Determinations of Eligibility
(as of April 2012) for
C
ontra Costa

County.

No
cultural resources

have been previously recorded in the vicinity of the
project site

and there
are no historic
-
age architectural resources in or adjacent to the project site .

The nearest cultural
resources are a series of pre
-
contact

archaeological sites nearly 1 mile to the east that contribute to the Lower San Pablo Creek Archaeological District. These resources would not be impacted by the proposed project.

The underlying geology of the
project site

consists of
artificial fill over

Holocene Bay Mud deposits
.

The historic shoreline is approximately 0.4 miles (2,000 feet) east of the project site; pre
-
contact and historic
-
era archaeological sites in this environment would be
located at or very near to the historic shoreline.

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Therefor
e, this analysis concludes that the sensitivity for pre -
contact
and
historic
-
era
archaeological resources is low

and the potential to uncover archaeological resources during project implementation is also low
.

Evaluation

a)

Cause a substantial adverse chan
ge in the significance of a historical resource as
pursuant to Section 15064.5?

No Impact
.

CEQA Guidelines Section 15064.5 requires the lead agency to consider the effects of a project on historical resources. A historical resource is defined as any buildi
ng, structure, site, or object listed in or determined to be eligible for listing in the California Register

of Historical Resources (California Register)
, or determined by a lead
agency to be significant in the
architectural, engineering, scientific, econ
omic, agricultural,
educational, social, political,
or
cultural annals of California. The following discussion focuses on architectural and structural resources. Archaeological resources, including those that are potentially
historical resources according
to CEQA Guidelines Section 15064.5,
are addressed below under
question

b).

As a result of the records searc
h and

background research, it was
determined
that there are
no
architectural or structural resources
in or adjacent to

the
project site

that

potentia
lly

qualify as historical resources,
as defined in CEQA Guidelines Section 15064.5. As
such, there are no historical resources present within the project site

and there would be
no impact

on
historical resources.

b)

Cause a substantial adverse change in th
e significance of an archaeological resource
pursuant to Section 15064.5?

Less than Significant
Impact, after

Mitigation
.

This section discusses archaeological
resources, both as historical resources according to CEQA Guidelines Section 15064.5, as well as

unique archaeological resources, as defined in California Public Resources (PRC) (CEQA) Section 21083.2(g). A significant impact would occur if the project would cause a substantial adverse change to an archaeological resource through physical demolition,

destruction, relocation, or alteration of the resource.

Based on the results of the background research and environmental context, the potential for encountering archaeological resources during project implementation is low. However, in the unlikely event

that a previously unrecorded archaeological resource is identified during project ground
-
disturbing activities and found to qualify as a historical resource or a unique archaeological resource, any impacts on the resource resulting from the project could
be potentially significant.

Implementation of Mitigation Measure CUL
-
1a: Cultural Resources Awareness
Training
and

Mitigation Measure CUL
-
1b:

Inadvertent Discovery of Cultural Materials or Tribal Cultural Resources would reduce potentially significant imp
acts to
less than significant.

In the
event of an inadvertent

discovery of
any cultural materials

or tribal cultural resource,

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these

mitigation
measures
would ensure that
all personnel complete a cultural resources
awareness training prior to any ground
-
di
sturbing activity and
that work
halts

in the
vicinity until a qualified archaeologist can make an
assessment and provide additional
recommendations if necessary, including contacting Native American tribes.

Mitigation Measure CUL
-
1a: Cultural Resources Awa
reness 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
o
n site disturbance. On
-
site personnel
shall
attend a mandatory pre
-
p
roject training that outline
s

the general
archaeological
sensitivity of the
vicinity

and the procedures to follow in the event an
archaeological res
ource 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
p
roject
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
assessmen
t. 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; sto
ne 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, gl
ass, 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 archaeologi
cal 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 cons
truction 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 archaeologis
t
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 in
clude 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 integr
ity of the resource (according to PRC Section

21084.3).

c)

Disturb any human remains, including those interred

outside of formal
cemeteries?

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Less than Significant Impact
, after Mitigation.

The records search and background
research
conducted for the projec
t
determined that no human remains are known to exist
within the
project site
. Therefore, the
project

is not anticipated to impact human remains,
including those interred outside of formal cemeteries.

While unlikely, if any previously
unknown human remains

were encountered during ground
-
disturbing activities, impacts
on the human remains resulting from the
project

could be
potentially significant
.

Implementation of Mitigation Measure CUL
-
2: Inadvertent Discovery of Human
Remains
,

would

reduce potentially si
gnificant impacts to
less than significant
. This
measure shall comply with applicable state laws, including Section 7050.5 of the Health and Safety Code. This would require work halt in the vicinity of a find and the immediate notification of the County
C
o
roner. If the
C
oroner determines that the human remains are
Native American, they
would

notify the California Native American Heritage
Commission, who shall appoint a Most Likely Descendant (PRC Section 5097.98).

Mitigation Measure CUL
-
2: Inadvertent Disco
very of Human Remains.

If human remains are encountered during
project

implementation,
t
he
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

de
termine 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
sha
ll then identify the person or
p
ersons it believes to be the Most Likely Descendant from the deceased Native American, who in turn would make recommendations for the appropriate means of treating the human remains and any grave goods.

References

Northwest Information Center (NWIC), Recor
ds Search File No. File No.

21 -
1575
. On file,
ESA, March 23, 2022.

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4.6 Energy

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Energy

Would

the

project:

a)

Result

in potentially

significant

environmental

impact
due

to

wasteful,

inefficient, or

unnecessary

consumption of

energy

resources,

during

project

construction or

operation?

b)

Conflict

with

or

obstruct

a

State

or

local

plan

for

renewable

energy

or

energy efficiency?

Setting

In 2020, more than 35 percent of the electricity PG&E delivered to its customers came from eligible renewable resources including solar, wind, bioenergy, geothermal and small hydropower and is o
n target to meet the 2045 goal (PG&E, 2021).

As intro
duced in Section 2,
Project
Description,
the Raven SR project

would consume electricity
to operate
, the
majority of the
power would come from
updated
onsite power generation
, and the

fuel to be used is t
he existing
LFG
combined with
tail gas from the
project operation. An

existing PG&E power drop
is
available to the project site.

Evaluation

a)

Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption
of energy resources, during project construction or
operation?

Less than Significant Impact
.

Both construction and operation of the
project

would
involve expenditure of energy.

Below are discussions of the energy resources that would be consumed during con
struction and operation of the project.

Construction

During construction, energy use would be both direct and indirect. Direct energy use would include the consumption of fuel (typically gasoline and diesel fuel) for the operation of construction equipment

and vehicles. Energy in the form of electricity may
also be consumed by some pieces of construction equipment, such as welding machines, power tools, lighting, etc.; however, the amount of consumed electricity would be relatively minimal. Indirect energy
use would include the energy required to make the
materials and components used in construction. This includes energy used for extraction of raw materials, manufacturing, and transportation associated with manufacturing.

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CEQA focuses on the efficient use
of energy rather than
comparisons of

estimated

energy
amounts to be
consumed

to
quantitative significance thresholds. Construction activities at the project site would occur over a period of approximately 8 months. Construction activities would include use

of heavy
-
duty construction equipment

and offsite vehicles to
transport equipment, materials, and workers to the project component sites.

Energy use requirements in the form of diesel fuel
that would be
consumed by off
-
road
construction equipment
at the pr
oject site
have been estimated based on the GHG
emissions estimates
obtained from

the CalEEMod modeling conducted for the Air
Quality and GHG analysis

in Sections 4.3 and 4.8, respectively, of this checklist . GHG
emissions from CalEEMod were used in conjun
ction with
The Climate Registry’s 2021
default factors for
calculating
c
arbon dioxide (
CO
2 )
emissions

from diesel fuel (TCR,
2021)
. The

analysis
assumes that all off
-
road construction equipment would be fueled by
diesel.

T
he analysis assumes that light
-
du
ty automobiles and trucks used by commuting
construction
workers would be fueled by gasoline, and that vendor vehicles and trucks that would
haul demolition debris, soil, and other materials would use diesel fuel . This
analysis assumes that no electric on
-
road vehicles would be used during
project

construction.

GHG emissions associated with commuting workers and vendor and haul trips were estimated using information provided by the
City

for estimated trip counts and
CalEEMod default trip lengths
.

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

area.

It is estimated that over the e
ntire construction period of the
project
, off
-
road equipment
and on
-
road
vender and haul trucks

would consume approximately

25,0
61 g
allons

of
diesel

fuel
,

and
commuting

worker vehicles would consume approximately
146

gallons
of gasoline.

Due to the relati
vely small scope of the
project
, as well as the limited duration of
construction activities, the consumption of fuel energy during construction would be temporary, localized, and would amount to a very small fraction of the 47 million gallons
of diesel and

336 million
gallons of
gasoline sold in Contra Costa County (California
Energy Commission [CEC], 2020).

Vehicles used for
project

construction and operation
would be required to comply with all federal and state efficiency standards. Additionally, there a
re no
project

characteristics or features that would be inefficient or that would result in the use of equipment and vehicles in a manner that would be less energy efficient than similar construction projects.

Therefore,
project

construction would not res
ult in wasteful, inefficient, or unnecessary
use of energy, and would result in a less
-
than
-
significant impact associated with energy
consumption.

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Operation

Once operational, the majority of the
project
’s power requirements would come from
electricity gen
erated onsite. The electricity would be generated using equipment such as

newly installed
Jenbacher
generator sets. The fuel that would be used for the generation is
LFG

from the Republic Services landfill,
blended
with the tail gas from a pressure
swing a
dsorption
(PSA)
unit to purify the hydrogen product. Republic Services would offtake approximately 0.5 MW from the power generation for its onsite operation al

needs
and the rest
of the generated energy
would be used to power the hydrogen plant. The
plant w
ould consume approximately

6.0+

MWe to operate and produce 200 kg of
hydrogen per hour. Any additional electricity needed to operate the facility would be sourced from an existing PG&E power drop to the site and no new distribution power line would be requ
ired for the
project
.

Operation and maintenance of the new facility
would require 3

to
4 employees per shift, for a total of 9

to
12 new employees

per day

to
cover all shifts and provide necessary support of the facility; energy use from employee trips woul
d therefore be minimal.

Energy would be consumed by new truck trips to the
site, with is also relatively minimal at up to approximate 100 truck trips per week.

T
he
facility

would not

involve customers onsite
.

Since the majority of the required power would

be generated onsite
,

and the power would
be used to produce hydrogen fuel at the plant, the

energy use associated with the
project

would
be net positive (i.e. more power would be generated than consumed) and not be
considered inefficient
or

wasteful and h
ence, this impact would be considered less than
significant.

b
)

Conflict with or obstruct a State or local plan for renewable energy or energy efficiency?

No

Impact
.

As discussed above,
project

construction would require the use of off
-
road
construction eq
uipment and on
-
road trucks. Construction activities would comply with
state and local requirements designed to minimize idling and associated emissions, which would also minimize the use of fuel. Specifically, pursuant to 13 CCR Sections 2485 and 2449, idl
ing of commercial vehicles over 10,000 pounds and off
-
road equipment over 25
horsepower would be limited to a maximum of five minutes. Fuel use for project

construction would be consistent with typical construction and manufacturing practices, and energy s
tandards such as the Energy Policy Acts of 1975 and 2005, which promote strategic planning and building standards that reduce consumption of fossil fuels, increase use of renewable resources, and enhance energy efficiency.

Once operational, the
project
’s
primary
energy use would be
electricity generated onsite
using a fuel that would consist of
LF
G combined with tail
gas
.

Energy

used for
operational vehicle trips would be negligible. Any additional electricity would be provided by PG&E
,

which would be subj
ect to SB 100 under California’s Renewable
Portfolio Standard (RPS) Program. Signed into law by Governor Brown, SB 100 increased California’s RPS target to 60 percent of total electric retail sales by 2030, and requires 100 percent of electric retail sales

to come from eligible renewable or carbon
-

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free resources by 2045. PG&E, as the utility provider
,

is subject to these requirements.

T
here are no aspects of the proposed
project

that would conflict with or obstruct a state or
local plan for renewable energy

or energy efficiency
, so there would be no impact
.

References

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

Accessed April 26
, 2022.

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

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

Available: https://www.theclimateregistry.org/wp
-
content/uploads/2021/05/2021
-
Defau
lt
-
Emission
-
Factor
-
Document.pdf?mc_cid=4b45d12237&mc_eid=5f138d1baa. Accessed March 29, 2022.

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4.7 Geology, Soils and Mineral Resources

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Geology

and

Soils

Would

the

project:

a)

Directly or

indirectly cause potential

substantial

adverse

effects,

including

the
risk

of loss, injury,

or

death

involving:

i)

Rupture

of

a

known

earthquake

fault,

as

delineated on

the
most

recent Alquist
-
Priolo

Earthquake

Fault

Zoning Map

issued
by

the

State
Geologist

for

the

area or

based on

other

substantial

evidence

of
a
known

fault? Refer

to

Division

of

Mines
and

Geology

Special

Publication 42.

ii)

Stro
ng

seismic ground

shaking?

iii)

Seismic
-
related

ground

failure,

including

liquefaction?

iv)

Landslides?

b)

Result

in substantial

soil

erosion

or

the

loss

of

topsoil?

c)

Be
located

on
a
geologic unit o
r

soil

that

is

unstable,

or

that

would

become unstable

as a
result of

the

project,

and potentially

result

in

on
-

or

off
-
site

landslide,

lateral

spreading, subsidence, liquefaction

or

collapse?

d)

Be
located

on expansive

soil,
as

defined

in Ta
ble

18 -

1 -
B

of
the

Uniform Building

Code

(1994), creating

substantial direct

or

indirect

risks

to
life

or

property?

e)

Have

soils

incapable

of adequately

supporting

the

use

of

septic tanks

or

alternative

wastewater

disposal

systems where

sewe
rs

are

not available

for

the
disposal

of wastewater?

f)

Directly or

indirectly destroy

a
unique

paleontological

resource

or site

or

unique geologic

feature?

Mineral Resources

Would the project:

a) Result in the loss of availability
of a known mineral

resource that would be of value to the region and the
residents of the State?

b) Result in the loss of availability of a locally important

mineral resource recovery site delineated on a local
general plan, specific plan or othe
r land use plan?

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Setting

There are several known active faults in the vicinity of the project site. The location lies within a geologic province of the San Francisco Bay named the “Richmond Basin," bounded by the San Pablo and Hayward faults. The act
ive fault in the region that are capable of producing the most significant ground shaking at the project site is the Hayward Fault, located approximately

3.7 miles
southwest of the project site.

(Rockridge, 2022)

A Geotechnical Investigation report was pr
epared for the proposed project (Rockridge, 2022).

T
he
project site
is blanketed by about 12 to 18 feet of heterogeneous fill, the upper five feet of which in the areas studied generally appears to be relatively well compacted. The fill is underlain
by you
ng bay sediments known locally as

Bay Mud
,

which extends to depths of approximately
110 to 117 feet
below ground surface (
bgs
)
.

Bay Mud layer is generally soft to depths of
approximately 50 to 60 feet bgs, but can be more stiff below, depending on the degr ee of
over
consolidation
.

The Bay Mud is underlain by alluvium consisting of dense to very dense sand/silty sand that

extends to the maximum depth explored (120 feet bgs).

This analysis considers information
from the geotechnical investigation as well as
f
rom numerous
studies conducted for the WCCSL

property
.

Evaluation

Geological Resources and Soils

a)

Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving (
i
) Rupture of a known earthquake

fault, as

delineated on the most recent Alquist
-
Priolo Earthquake Fault Zoning Map issued
by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42. ( ii
)
Stro
ng seismic ground shaking? (
iii
) Seismic
-
related ground failure, including

liquefaction? (
iv
) Landslides?

Less than Significant Impact
.

Intense ground shaking during a large earthquake would
be expected at the project site, particularly given its close pro ximity of the nearest active
fault.

The project
would

adhere to standard industry practices, code requirements, and any geotechnical recommendations or design parameters
identified

in the geotechnical
study prepared for the project (Rockridge, 2022). (
for
the proposed earthwork, foundation
slabs, and any surrounding related improvements, utilities, or paved areas associated with the project, would reduce the potential impacts associated with ground shaking during a major seismic event; seismically
-
related g
round failure, including liquefaction

for which
the

project

area is susceptible (
Richmond
, 2012)
. T
he project
would

also adhere to all
requirements in the applicable versions of the California Building Code, which would generally reduce known seismic hazar
ds to minimize
potential adverse effects
.

The
project
would
introduce an industrial operation and modular structures on the project site ,
involving up to three to four employees onsite at any particular time , and no customers
.

The impact
would
be less than

significant.

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b)

Result in substantial soil erosion or the loss of

topsoil?

Less than Significant Impact
.

The project, which relatively flat and partially paved and partially compacted soil and ruderal groundcover, would develop and implement an Erosion Co
ntrol Plan and
applicable

best management practices
as part of the
National
Pollutant Discharge Elimination System (NPDES)
Construction General Permit
,

would
reduce
potential
impacts associated with erosion to a less than significant level.

c)

Be located
on a geologic unit or soil that is unstable,

or that would become unstable
as a result of the project, and potentially result in on -

or off
-
site landslide, lateral
spreading, subsidence, liquefaction or collapse?

Less than Significant Impact
.

As mentioned
in criterion “a”

above,

t
he project
would

adhere to standard industry practices, code requirements, and any geotechnical recommendations or design parameters
that would
reduce the likelihood
of landslide
,
lateral spreading, subsidence, liquefaction or coll
apse

due to
unstable geologic units or
soil
.

Based on the results of previous analyses, most of the

sand layers present at the site
(primarily within the Bay Mud) are sufficiently dense, have

sufficient clay content,
and/or are overlain by a sufficient thi
ckness of Bay Mud, such that

the potential for
liquefaction is low

although the site is in a liquefaction hazard zone (see “a”) . The
greatest potential for liquefaction is
approximately

0.3 miles northward,
adjacent

to
San
Pablo Creek.

The project site is
not located on areas of landfill, which also sits upon Bay Mud and is susceptible to risks of settlement

over time. The impact would be less than
significant.

d)

Be located on expansive soil, as defined in Table 18
-

1 -
B of the Uniform Building
Code (1994)
, creating substantial direct or indirect risks to life or property?

No Impact
.

Expansive soil is not known to exist at the
WCCSL
site

(County, 2004)
.

No
impact would occur.

e)

Have soils incapable of adequately supporting the

use of septic tanks or alter
native
wastewater disposal systems where sewers are not available for the disposal of wastewater?

No Impact
.

The project does not proposed installation or use of septic tanks

or alternative
wastewater disposal systems
; the site is currently served by
West
County Wastewater
District

sanitary sewer
service and facilities which
would

continue with the proposed
project
.

f)

Directly or indirectly destroy a unique

paleontological resource or site or unique
geologic feature?

Less than Significant

Impact, after
Mi
tigation
.

Based on the evaluation in

Section 4.5,
Cultural Resources,

in this checklist, the
potential for encountering
paleontological or
unique geologic features on the project site during
ground
-
disturbing activities

for the

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proposed project is unlikely
.

However,
the implementation of
Mitigation Measure CUL
-
1a: Cultural Resources Awareness Training
,

Mitigation Measure CUL
-
1b:

Inadvertent Discovery of Cultural Materials or Tribal Cultural Resources , and

Mitigation Measure CUL
-
2: Inadvertent Discovery of H
uman Remains
,
all
identified

above

in
Section

4.5 ,
Cultural Resources
,

also apply to
reduce
the potential and unlikely
event

paleontological resources
are discovered.

Mineral Resources

a, b)

Result in the loss of availability of a known mineral

resource t
hat would be of
value to the region and the residents of the State? Result in the loss of availability of a locally important

mineral resource recovery site delineated on a local general plan, specific plan or other land use plan?

No Impact
.

The
proposed

p
roject
would

not require the use of vast amounts of natural
resources or
mineral

resources for construction or operation.

Input to the operation is
existing organic feedstock from the project site. No impact would occur.

References

City of Richmond, 2012.

Richmond General Plan
Update Environmental Impact Report.

SCH.
2008022018.
2012.

City of Richmond, 2012.

Richmond General Plan

2030:

Public Safety and Noise E
lement.

Table

3.7 -
4,
Liquefaction
.
2012.

Contra Costa County 2004.

Environmental Impact Report on

the West Contra County Sanitary
Landfill Bulk Materials Processing Center and Related Actions ,
SCH. 2002102057
.

June
2004
.

Contra Costa County 2009.

Addendum to the

Final

EIR

for the WCCSL BMPC and Related
Actions
,
SCH. 2002102057
. 2009
.

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4.8 Greenhouse Ga
s Emissions

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Greenhouse Gas

Emissions

Would

the

project:

a)

Generate greenhouse
gas

em
issions,

either

directly

or

indirectly, that

may

have
a
significant

impact on

the
environment?

b)

Conflict

with

any

applicable plan, policy or

regulation

adopted

for

the

purpose

of reducing
the

emissions

of

greenhouse gases?

Setting

St
ate

and Regional

The California Global Warming Solutions Act (Assembly Bill [AB] 32, 2006), as amended, sets statewide greenhouse gas (GHG) emissions caps. The California Air Resources Board (CARB) established the Climate Change Scoping Plan, which outline d a framework for achieving the
emission reduction goals set in the California Global Warming Solutions Act. In 2016, SB 32 and its companion bill AB

197 established a new climate pollution reduction target of 40 percent below 1990 levels by 2030 and inclu
ded provisions to ensure the benefits of State climate policies reach into disadvantaged communities.

Senate Bill (SB) 375 requires CARB to develop regional GHG reduction goals for the automobile and light truck sectors. The
Plan Bay Area 2040
is a plan t
o achieve regional GHG reduction
goals by improving transportation access, maintaining the region’s infrastructure, and enhancing resilience to climate change through strategies such as fostering open space. There are a number of other laws in California i
ntended to reduce GHG emissions through the regulation of construction standards, growth, and municipal operations.

Governor Brown signed Executive Order B
-
55 -
18 in September 2018 to establish a statewide
goal to achieve carbon neutrality as soon as possi
ble, and no later than 2045, and to achieve and
maintain net negative emissions thereafter.

In response to this Executive Order, CARB’s Draft
2022 Scoping Plan Update (May 10, 2022) presents several scenarios for achieving carbon neutrality statewide no la
ter than 2045.

Significance Threshold

Greenhouse gas impacts are, by their nature, cumulative impacts because one project by itself cannot cause global climate change. As such, GHG emissions are evaluated under CEQA as a cumulative impact. To evaluate cum
ulative impacts, a lead agency must assess (1) whether the overall cumulative impact
would

be significant and, (2) if the overall impact is significant,

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whether the incremental contribution that the individual project under review would

add to the
overall
cumulative problem
would

be cumulatively considerable.

A conservative threshold of significance for determining the cumulative impact of a project’s GHG emissions is “net zero” emissions. This concept is supported by the BAAQMD in its Justification Report
:

CEQA Thresholds for Evaluating the Significance of Climate Impacts f
rom
Land Use Projects and Plans

(BAAQMD, 2022), which states: “If a land use project incorporates all of the design elements necessary for it to be carbon neutral by 2045, then it will c ontribute its
portion of what is needed to achieve the State’s climate goals and will help to solve the cumulative problem. It can therefore be found to make a less -
than
-
cumulatively
-
considerable
climate impact” (BAAQMD 2022).

Further,
the State’s Office o
f Planning and Research’s (
OPR
)

Final Statement of Reasons

for
Senate Bill 97 revisions to the CEQA Guidelines

state that, “AB32, and regulations
implementing

that statute, will require reductions in emissions

from certain sectors in the economy, but do no
t
preclude new emissions. Moreover, as explained

in the Initial Statement of Reasons, the proposed
amendments do not establish a zero emissions

threshold

of significance because

there

is no

‘one
molecule

rule’

in CEQA”

(CNRA,

2009).

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

The new BAAQMD thresholds are focused on land development pro jects,
and

the legacy
stationary source threshold for operational GHG emissions is 10,000 MTCO 2 e. This threshold is
not being currently updated in the BAAQMD, as staff are focusing on creating land use project and plan thresholds (BAAQMD 2022).

This

analys
is
focuses

on net zero emissions and the new
draft thresholds, while also taking into account the existing BAAQMD threshold.

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T
ABLE

4.8 -
1 BAAQMD

GHG

T

HRESHOLDS OF
S

IGNIFICANCE

(M
UST
I
NCLUDE
A

OR
B

FOR
O
PTION
S
CHEME
)

Existing and Draft Air District Thr
esholds

Legacy Stationary Source
Threshold

10,000 MTCO
2 e

Option

A

Projects must include, at a minimum, the following project design elements:

1)

Buildings

a
.

No natural gas (residential and non
-
residential)

2)

Transportation

a
.

Achieve complian
ce with EV requirements in the most recently adopted version of CALGreen
1 Tier

2 b
.

Achieve SB 743 target of 15% reduction in VMT per capita below regional average

Option B

Be consistent with a local GHG Reduction Strategy that meets the criteria under the CEQA
Guidelines Section

15183.5(b)

1 Part 11 of the Title 24 Building Energy Efficiency Standards is referred to as the California Green Building Standards (CALGr een) Code

SOURCES:

BAAQMD 2022.

Justification Report: CEQA Thresholds for Evaluating
the Significance of Climate Impacts from Land Use
Projects and Plans
, April.

Evaluation

a)

Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?

Less than Significant Impact
.

GHG emission
s would be generated during both
construction and operational phases of the
project
.

Construction

The combustion of diesel fuel to provide power for the operation of various construction

equipment
results in the generation of

GHGs. Construction emission
s associated with the
project were

estimated using project
-
specific information provided by the Project
Applicant
, such as

construction schedule and phasing; types, number, and horsepower rating of construction

equipment

to be

used,

their

daily

usage in te
rms

of hours per day,

and

the

number

of

days

each piece of equipment is used over the construction period; and information on

construction vehicle trips for worker commute, equipment and material transport and

hauling trips. Appendix A to this checklist co
ntains the data and
assumptions used to

estimate the construction
-
phase GHG emissions that would be

associated with

the

project.

Carbon Dioxide (
CO
2 )
,
methane (CH
4 ) and nitrous oxide (N
2 O)
emissions from off
-
road
construction equipment and construction veh
icle trips were derived from the CalEEMod
run to estimate criteria air pollutant emissions. N
2 O and CH
4 emissions were multiplied

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by their respective Global Warming Potentials GWPs (25 and 298) and added to the CO 2 emissions to obtain CO
2 e emissions.

Const
ruction of the proposed project is anticipated to occur over a period of

approximately eight months. It is

estimated that
p
roject construction would generate a
total of approximately
258.
9 MTCO
2 e over

an 8
-
month

construction period
, as shown in
Table 4.8
-
2 . BAAQMD does not have adopted significance thresholds for construction -
related GHG emissions in its 2017 CEQA Guidelines (BAAQMD, 2017). However, it recommends that the Lead Agency (i.e., the City of Richmond) quantify and disclose construction GHG emissi
ons and incorporate best management practices to reduce GHG emissions during construction, as applicable.

T
ABLE

4.8 -
2 A
NNUAL

C

ONSTRUCTION
-
R
ELATED

G

REENHOUSE

G
AS

E

MISSIONS

Year

GHG

(MTCO
2 e)

2022

17 8
.
3 2023

80.6 Total

258.
9 Amortized

8.6 3

NOTES:

MTCO
2 e

=

metric

tons

of

carbon

dioxide

equivalent

Construction
-
related GHG emissions were amortized over 30 years, which is a

commonly accepted method for including construction emissions as part of the

proposed

project
’s

average

annual

emissions.

SOURCE:

Data

c
ompiled

by

Environmental

Science

Associates

in

2022

(Appendix

A

to

this

checklist)

In addition, the GHG thresholds proposed by the BAAQMD in response to SB 32’s GHG reduction goals also do not contain significance thresholds for construction (BAAQMD, 20 22). GHG emissions from the construction phase of a project represent a very small portion of emissions over the project’s lifetime, which for the projects such as the proposed
project

would be at least 30 years.

The BAAQMD’s proposed thresholds are inste
ad designed to address operational GHG
emissions from land use development projects which represent the majority of a project GHG emissions. The primary source of GHG emissions from construction is diesel -
powered construction equipment. Large reductions in

construction emissions are difficult
to realize because there are currently no economical alternatives to diesel fuel for powering most construction equipment. Improvements in statewide regulations governing construction equipment and fuel standards drive
n by SB 32 and other initiatives will also
contribute to reduced emissions from construction activities. Therefore, GHG emissions associated with
p
roject construction would be considered less than significant.

Though not required as mitigation to reduce a

significant impact,
implementation of

Mitigation Measure AQ
-
1: Best Management Practices
, identified above in Section

4.3,
Air Quality,

will help reduce GHG emissions in addition to providing air quality

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benefits.

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

Appendix A contains

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

Operational

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

The existing legacy stationary source thresh
old is 10,000 MTCO
2 e annually.

The proposed system takes up
to

99.9 wet
-
tons per day (WTPD) of blended green waste
(GW), food waste (FW),
using

landfill gas (LFG)
to provide power to the process
and
converts
the feed
into renewable, transportation grade hy
drogen.

This waste would
otherwise be put into the landfill where it would produce GHG emissions in the form of methane gas. The landfill gas would also otherwise be creating GHG emissions if not for the bioenergy facility taking it and converting it into hydrogen. By redirecting this waste
into the Raven SR, it reduces the amount of GHG emissions produced at the project site.

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

The system does not have any free

oxygen in its process, and instead uses steam
promoted

processes to
thermally decompose the feed

into its chemical elements. This
process does not involve any t
ype of combustion, and therefore does not have an GHG
emissions associated with the system operational emissions.

Once project operations fully
begin,

GHG

emissions are expected to be

net negative.

Table 4.8
-
3 shows
operational emissions calculated using C
alEEMod (version 2020.4.0)
added to the amortized

construction emissions to get the total annual project GHG emissions. BAAQMD does not currently have a quantitative threshold for GHG emissions. The current qualitative significant thresholds are found in T
able

4.8 -
1 .

The
project
would

satisfy the BAAQMD Best Available Control Technology (BACT) requirements, and thus
t
he proposed project is consistent with the 2017 Climate Change Scoping Plan as well as the draft 2022 Scoping Plan Update in terms of followin g the
GHG reduction strategy to reach the statewide goal of climate neutrality by 2045.

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T
ABLE

4.8 -
3 U

NMITIGATED
A
NNUAL
O

PERATIONAL
G

REENHOUSE
G
AS
E

MISSIONS

Source

GHG (
MTCO
2 e
)

Area

<1

Energy

80.5 Mobile

2 62.6

Off
-
road

303.2

Waste

96.7 Water

17. 0

Amortized Construction Emissions

8.6 3

Total
Project GHG
Emissions

697.17

NOTES:

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

MTCO
2 e = metric tons of carbon dioxide equivalent

SOURC
E:

Data compiled by Environmental Science Associates. See Appendix A to
this checklist.

Based

on

the

state carbon neutrality goal for 2045, the proposed project would

contribute
its portion of what is needed to achieve the State’s climate goals and wou
ld

help to solve
the cumulative climate problem. It can therefore be found to make a less -
than
-
cumulatively
-
considerable climate impact. The project emission calculations, along with the supporting data from the life cycle analysis, shows that the project would be below
both the new draft significant thresholds and the legacy stationary source threshold, with the possibility of reaching net negative GHG emissions, contributing to the determination of the project having a less than significant impact and a l ess
-
than
-
cumulatively
-
considerable climate impact. Therefore, operation of the proposed project

would

have
a
less than significant impact.

b
)

Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenh
ouse gases?

Less than Significant Impact
.

In response to AB 32 GHG reduction goals, CARB
adopted the Climate Change Scoping Plan, which outlined a framework for achieving the emission reduction goals set in the California Global Warming Solutions Act. The Scoping Plan was most recently updated in 2017 (2017 Scoping Plan; CARB, 2017) to address California’s 2030 GHG target and identifies how the State can reach the 2030 climate target established by SB 32 while making substantial advancements toward the 2050

climate goal established by Executive Order (EO) S
-
3 -
05 (2005).

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

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The
project

would generate GHG emissions primarily from
operational
activities and
would
most likely

result in net negative emissi
ons on an annual basis. As such, the
project

would help the City achieve its long
-
term GHG emissions goal. Neither the 2017
Scoping Plan Update or the City’s existing CAP contain any actions or measures that address GHG emissions from construction. The maj
ority of electricity supplied to the
project

would

come from an onsite power generator, fueled by LFG from the Republic Services
WCCSL
.

Any additional power required
would

be supplied from an on
-
site
PG&E power drop; PG&E is required to comply with SB 100 and the RPS.

SB 100
requires that the proportion of electricity from renewable sources be 60 percent by 2030 and 100 percent renewable power by 2045.

Therefore, the
project

would be consistent
with all applicable plans, policies and regulations adopted for

the purpose of reducing
GHG emissions. This impact would be less than significant.

References

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

Available online:

Microsoft Word
-

FINAL CEQA Thresholds Report for Climate Impacts
03_30_22 revisions with tracked changes (baaqmd.gov)
.

Accessed on May 11, 2022.

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

The City of Richmond, 2016. Climate Action Plan 2
016. Available online:
https://www.ci.richmond.ca.us/DocumentCenter/View/40636/CAP -
combined
. Accessed
May 11, 2022.

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

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

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

Raven SR Republic Service Summary, 2021.

Carbon Life Cycle Analysis, Life Cycle
Associates, LLC.

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4.9 Hazards

and Hazardous Materials

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Hazards

and Hazardous
Materials

Would

the

project:

a)

Create

a
significant hazard

to
the
public or

the

environ
ment

through

the

routine

transport,

use,

or

disposal

of hazardous

materials?

b)

Create

a
significant hazard

to
the
public or

the

environment

through

reasonably

foreseeable

upset

and

accident conditions

involving

the

release

of

hazardous

mater
ials

into

the

environment?

c)

Emit

hazardous emissions or

handle hazardous or

acutely

hazardous

materials, substances, or

waste

within

one
-
quarter

mile

of

an

existing or

proposed

school?

d)

Be
located

on
a
site

which

is

included

on

a

list

of

hazardous

materials

sites compiled

pursuant

to

Government

Code

Section 65962.5 and,

as

a

result,

would

it create
a
significant hazard

to

the

public

or

the
environment?

e)

For

a

project

located within

an
airport land use

plan

or,

where

such
a
plan

has

not been adopted,

within

two

miles

of

a

public airport or

public

use airport,

would

the

project

result in

a

safety hazard

or

excessive

noise

for

people

residing

or

working

in

the

project area?

f)

Impair

implementation
of

or

physically

interfere

with

an
adopted

emergency

response

plan

or

emergency

evacuation

plan?

g)

Expose people or

structures, either

directly or

indirectly
to a

significant

risk of

loss,

injury or

death

involving

wildland fires?

Sett
ing

The project site sits within the existing WCCSL which does not accept hazardous wastes; u nder
State and federal laws, the

landfill is permitted to accept non
-
hazardous wastes only.

Although

the municipal solid

waste stream does contain small quantities

of hazardous wastes that result
from disposal of

household waste and waste from small quantity generators, such as auto repair, auto dealers, and

gas stations
, the proposed project only involves
a

variety of organic waste
feedstock
.

As discussed below

and

in Section 2.5 (
Non
-
Combustion
)
, the Raven SR process
incorporates internal safety functions an
d

would

adhere to numerous

applicable
state and federa
l

regulations, plans and
procedures

that apply specifically to its
production of
hydrogen gas

from

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organic

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

A Phase I Environmental Site Assessment has been prepared for the project (CEC, 2022).

The
Phase I

reports r
elevant site conditions observed include the storage of various commonly used hazardous materials, such as used oil, lubricants, anti -
freeze, HDPE pipe sealant, pipe glue
solvent, spray paint, and household cleaning supplies. All observed materia ls were properly
stored and maintained.

The Phase I
also
reports n
umerous above
-
ground storage tanks (ASTs)
containing petroleum products

located within and near the existing

landfill power plant and
maintenance buildings

near

the project site.

As previou
sly described, the project is contiguous to a closed hazardous waste landfill portion of the WCCSL operation.

Also,

the project site was formerly occupied by three leachate evaporation ponds. Groundwater contamination on
the

WCCSL site was confirmed in a J
anuary 2021
Corrective Action Groundwater Monitoring Program Report. 12 Groundwater at the WCCSL also
has reported PFAS chemicals detected in groundwater. This is considered a recognized
environmental condition (
REC
)
, but regularly monitored and the results
are submitted to the State
regulatory agency. Additionally, the groundwater impact is not expected to pose a risk of unacceptable

exposure to workers at the
project

site.

(CEC, 2022
)

Evaluation

a, b)

Create a significant hazard to the public or the enviro nment through the routine
transport, use, or disposal of hazardous materials? Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the en vironment?

Less than Significant Impact
.

The
proposed
operation

of

transforming blended green
waste and food
waste

into transportation
-
grade hydrogen
-
rich

synthesis
gas
(syngas)
and
charcoal

(biochar)

could result in an adverse effect thr
o
u
gh

the exposure
to or spill of
chemicals. The green waste and food waste feedstock would not be considered a hazardous material.

Also, in 1993, DTSC determined that the Raven SR process for the production of syngas from organic solids was not categorized as either inciner ation or
combustion and was therefore a suitable technology for use in California. 13 The conversion method uses a non
-
combustion (i.e., anoxic, indirect external heating),
low pressure process. The only chemicals added would be carbon dioxide (CO2), calcium

12 CEC, 2022.

Operation of a groundwater monitoring system and a groundwater extraction system is required under the West County La
ndfill (WCL) corrective action groundwater monitoring program (CAGMP), in accordance with

Corrective Action Enforcement Order, Docket Number 20061079 dated September 26, 2007.

13 According to the definitions listed in Section 260.10, Title 40, Code of Feder al Regulations (40 CFR) and Section
66260.10, Title 22, California Code
of Regulations (22 CCR). Also, s
ince 2017, a Raven pilot engineering unit,
sized at 100 wet pounds per day of feedstock, has been operating at the UC Berkeley’s Richmond Field Station and
is permitted for operation by the Bay Area Air Quality Management District (BAAQMD) under permit Nos. 23993 and 23320.

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carbonate

(lime
stone
), and steam (i.e., water heated into a
vapor
state). No hazardous
materials would be used in the process. The conversion occurs in sealed rotating drums that drop out solid matter from the green and food waste feedstock, which would c onsist
largely of biocarbon, along with dirt, glass, grit, rocks, and inorganic salts. The biocarbon materials are inert to the process (i.e., not gasified) and drop out in the first stage. The process also drops out excess water. Neither the biocarbon nor

the water would be
considered a hazardous material.

There would be no long
-
term hydrogen storage onsite; the material would be fed directly into the tube trucks and transported offsite.

For

transportation, the United States
Department of Transportation (
USDOT) classifies hydrogen gas as a Division 2.1
Flammable Gas. Vehicles transporting flammable gas are mandated to display USDOT flammable gas placards.

The

proposed
project

would pump the

hydrogen gas into
standard pressurized hydrogen gas trucks, called

tube trailers. The gaseous hydrogen is
compressed to pressures of
380 gas

(about
5,500

pounds per square inch [psig]) or higher
into long cylinders that are stacked on a trailer that the truck hauls. This gives the appearance of long tubes, hence the name

tube trailer.

To support development of the hydrogen economy, development of t ube trailers
capable
of storing hydrogen at pressure of about 500 bar
are
approved for use on public
throughways use
by
US
DOT regulations (Federal Motor Carrier Safety Administ
ration,
49 CFR Part 393). Such tube trailers are routinely used to transport hydrogen gas, as well as other gases such as natural gas and propane. Regulations regarding the design of tube trailers that transport hydrogen gas is in OSHA 1910.103, Subpart H,

Hydrogen, which
includes requirements for the containers, pressure relief valves, piping, tubing, fittings, and labeling.

On
-
road transport of hydrogen gas must comply with applicable USDOT regulations, which include equipment requirements and driver safe ty training. In
California, a specific driver’s license is required, a commercial driver’s license with a Hazard Materials endorsement.

A

new 250,000
-
gallon integrated fire water tank and diesel engine is proposed in the northeast corner of the site for

em
ergency use
, as required by fire department regulations

(see Figures 2
-
1 through 2
-
4).

Diesel fuel is classified as a hazardous material,
and

therefore the above ground tanks
would

require compliance with
containment
requirements in
a

Spill Prevention, Con
trol, and Countermeasure (SPCC) Plan

pursuant
to federal requirements
.

Propane
for the continuous flare pilot would
be supplied from a
standard 1000
-
gallon propane tank

installed on
-
site. A local propane supplier w
ould
service and fill
the
tank as

needed.

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

Specifically
, the facility’s controls would be distributed through the various process islands
, taking their direction from a central Human
-
Machine Interface in the control
room with centralized data collection. Process setpoints would

be bounded by high/low
alarm limitations to draw the operator’s attention to the specific problem. The control

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

Because the process itself is oxygen
-
free, there would be no opportunity within the
process for explosion.

As previously descr
ibed (
Section 2.5
), p
iping and vessels would be
periodically scanned with infrared equipment to identify hot spots or gas leaks that may threaten safety. If hot spots or leaks were identified, immediate steps would

be taken to
correct or mediate the condit
ion. Also, remote monitoring of the facility by Raven SR corporate provides oversight of the operation and early identification of problems as they development.

The project would comply with applicable Environmental Protection Agency (EPA) risk management

plan (RMP) and Occupational Safety and Health Administration (OSHA) process safety management (PSM) guidelines, as may be applied to the facility to ensure the safety of its operations staff and the surroundings

A maintenance program of regular
and preven
tative maintenance would be developed to maintain equipment in a reliable manner.

The project’s adherence to all regulatory requirements mentioned in this section,
combined with
the Raven RS process, materials and operations
, the impact would be less
than
significant.

c)

Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one
-
quarter mile of an existing or proposed school?

No

impact
.

As discussed above, the proposed project would not emit hazardous emissi
ons or handle hazardous materials or waste. Moreover, t he

project site
is

located
approximately

1. 1

miles from
Verde
Elementary School

at 2000 Giaramita Street
.

Therefore,

no impact would occur
.

d)

Be located on a site which is included on a list of hazard ous materials sites compiled
pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?

No impact
.

An inactive waste disposal area

that is a
Class I Hazardous Waste
Management Facili
ty (HWMF) is located within the WCCSL and
directly north

of the
BMPC
and project
site

(see Figure 1
-
3 in Chapter 1, and Figure 2
-
0 in Chapter 2)
. The
facility was closed pursuant to State and f
ederal regulations
, and final cap construction
was completed pr
ior to 2003
. It is a totally enclosed facility with required environmental control systems.

The proposed project site is not within the
previous

HWMF area;
therefore, no impact would occur.

e)

For a project located within an airport land use plan or, where

such a plan has not
been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?

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No impact
.

The

proposed project
is

not located

within

an

airport
land

use plan, and the
closest

airport to the project site
is

the
San Rafael
Airport located approximately

8.3 miles southeast
. Therefore, the proposed project would
not

be located within
two

miles

of

an

airport, and no impact would occu
r.

f)

Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?

Less than Significant Impact
.

In
the

event
of

a

large
-
scale disaster, emergency response
to the site would
be

coordinated by
WCCSL
facility,
City and County

fire
responders
,
and in adherence to the WCCSL Emergency Response and Evaluation Plan and local agency protocols. Emergency fire control procedures are also

included in the composting
and wood waste recycling operations plans. The

WCCSL facility and project site are
accessed from and exit to Parr Boulevard, and a serious of roadways

and paths
throughout the 340
-
acre WCCSL
provide sufficient
width

for emergency access.

The
proposed project would be developed within

part of the

exist
ing BMPC property and
would not create new or interfere with existing access or egress roads.

Therefore, there is
no potential for the project to impair implementation
of

emergency evacuation
or

an
adopted

emergency response plan.

g)

Expose people or struc
tures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?

Less than Significant Impact
.

The

project site
is

flat and
surrounded
by the
WCCSL
facility
, which is composed of
grass
-
covered disposal areas

of

the landfill mounds
, runoff
control ponds and lagoons, and composting areas
, and
tidal marshlands of San Pablo and
Wildcat Creek
.

Open water of San Pablo Bay is approximately 0.25 miles westward from the project site.

Wildfire hazard maps show the site as

not being within a high wildfire
hazard zone (CPUC, 2018).

Further, as discussed in criteria “a and b”, the project would
include

a
new 250,000
-
gallon integrated fire water tank and diesel engine is proposed for
emergency use
, as required by fire departme
nt regulations
.

References

California Public Utilities Commission. Fire
-
Threat Map
–

State of California. January 19, 2018.

CEC, 2022
.

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

June 30,
2022.

Contra Costa County 2004.

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

June 2004
.

Contra Costa Coun
ty 2009.

Addendum to the

Final

EIR

for the WCCSL BMPC and Related
Actions
,
SCH. 2002102057
. 2009.

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4.10 Hydrology and Water Quality

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

tha
n

Significant

Impact

No

Impact

Hydrology

and
Water

Quality

Would

the

project:

a)

Violate

any

water

quality

standards

or

waste

discharge

requirements

or

otherwise substantially

degrade

surface

or

groundwater

quality?

b)

Substantia
lly decrease groundwater

supplies

or

interfere

substantially

with groundwater

recharge

such
that

the

project

may

impede

sustainable

groundwater
management of

the

basin?

c)

Substantially alter

the

existing drainage pattern

of

the
site

or area,

including

through

the

alteration

of

the

course

of
a

stream or

river

or

through

the

addition of

impervious

surfaces,

in
a
manner

which

would:

(i)

result

in

substantial

erosion or

siltation

on
-

or

off
-
site;

(
i
i)

substantially in
crease the rate or amount of surface
runoff in a manner wh
i
ch would result in flooding on
-

or off
-
site;

(iii)

create

or

contribute

runoff water

which

would

exceed
the

capacity of

existing

or

planned

stormwater

drainage

systems

or

provide

subst
antial

additional

sources

of

polluted

runoff;

or

(iv)

impede

or

redirect

flood

flows?

d)

In

flood hazard,

tsunami,

or

seiche

zones, risk

release

of

pollutants

due

to

project inundation?

e)

Conflict

with

or

obstruct

implementation of
a
water

quality control

plan or

sustainable groundwater

management plan?

Setting

No surface water bodies exist on the project site.

As
previously

described
throughout other
sections of
this

analysis, the
following surface water bodi
es
exist
within
the WCCSL property
and
directly south/southwest of the

project site: runoff ponds or lagoons delineated as “Area B” and tidal waters delineated as “Area C” (shown in Figure 3 -
1,
Vicinity Map
, of the 2004 EIR)
.

San Pablo Creek

is
approximat
ely

0.3 miles north of the project site, and
Wildcat Creek

is
approximately

280 feet
south/southeast of the project site, bordering the WCCSL south boundary which is an elevated levee (see Figure 2
-
0 and Figure 2
-
1 in Chapter 2

of this

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document
).

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

Open water of San Pablo Bay is approximately 0.25 miles west of the project

site
.

The

leve
es
around the WCCSL have

been designed and
maintained

to exceed flood levels and the
upland
portions

are located outside

wetlands under U.S. Army Corps of Engineers (Corps)
jurisdiction.

Depth to groundwater at specific areas of the project site can range

from 5 to 7 feet or up to 10
-
1/2 feet below the ground surface. The depth to groundwater varies

seasonally. Groundwater
contamination on the WCCSL site was confirmed in a Phase I Environmental Site Assessment prepared for the project (CEC, 2022). This rec
ognized environmental condition (REC) is
regularly monitored and the results are submitted to the State regulatory agency.

T
here

are no
anticipated plans for use

of existing groundwater

by the Project
.

Evaluation

a, b
)

Violate any water quality standards
or waste

discharge requirements or otherwise
substantially degrade surface or groundwater quality?

Substantially decrease
groundwater supplies or

interfere substantially with groundwater recharge such
that the project may impede sustainable groundwater man agement of the basin?

Less than Significant Impact
.

WCCSL implements a
Storm Water Pollution Prevention
Plan (SWPPP)

under the
NPDES

permit, as amended.

The drainage plan for the
WCCSL,
which
currently
encompasses the project site,
accommodate
s

the 100
-
yea
r storm
event
.

T
he WCCSL is managed to prevent the infiltration of surface water into the waste materials and to maximize and control the amount of surface water th at runs off via
overland flow with
berms, bench drains, down drains
, which would manage runo
ff from
the project. Area 1 runoff

is

diverted

to

the

siltation

control

basin

located

behind

(east

of) the Golden Bear
Waste

Recycling Center
.

As introduced in
Section 2.8,
Construction, Site Coverage and Drainage
, t
he project
would adhere to all applicab
le regulatory stormwater runoff controls and will pursue its own NPDES permit. The project’s SWPPP
would
be developed prior to construction and
operation of the facility and flows would be integrated into the existing WCCSL system and ensure drainage from
the proposed project site
would

drain towards existing
stormwater runoff control ponds (or bioretention facility) to which the rest of the WCCSL property currently drains. The drainage control systems would be

designed such
that the two systems are segrega
ted and independent of one another. This
would

minimize the creation of contact water (water that has come into contact with organic
feedstock)
as well as protecting
the
site
from

various health and safety hazards.

The receiving and handling area
would

be

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

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Any excess contact water that may be generated inside the canopy receiving area will either be reabsorbed into in
coming feedstock or collected via floor drains and diverted to the
facilit
y’s

sanitary sewer
.

The SWPPP also requires site inspections and a preventive storm water control maintenance program, with triggers for evaluation monitoring and corrective action as
needed under RWQCB review and oversight pursuant to State regulations.

Also, neither
construction nor operation of the project
would

involve use of groundwater
.

Taken
together, the proposed stormwater program and project development would not impair wat
er quality or decrease groundwater.

The impact is less than significant.

c)

Substantially alter the existing drainage pattern of

the site or area, including
through the alteration of the course of a stream or river or through the addition of impervious sur
faces, in a manner which would:

(i)

result in substantial erosion or siltation on
-

or

off
-
site;

(
ii)

substantially increase the rate or amount of surface runoff in a manner which would result in flooding on
-

or off
-
site;

(iii)

create or contribute runof
f water which would

exceed the capacity of
existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or

(iv)

impede or redirect flood flows?

Less than Significant
Impact
.

The proposed project
would

invo
lve minimal grading as
needed to prepare the site for new paving and foundations for the proposed modular buildings. The site is current flat and
would

remain so
, except for slight
grading

around
the proposed modular structure to prevent contact water . As
descri
b
ed in Section 2.8,
Construction
,

Site Coverage

and Drainage
, in Chapter 2, t
he proposed project would
add

a
pproximately

1.21 acres of

new impervious surface area
(including modular structures)
to the existing 0.76 acres of impervious area that would

be repaved. This would result in
approximately 78 percent of the project site (2.5 acres) being impervious. Approximately

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

Although the
amount
of
im
pervious area on the project site would nearly double
compared to the existing conditions, the proposed dr
ainage

management

would

effectively manage increased flows to the existing system and not exceed the

capacity of
the system.

A draft Stormwater Contro
l Plan has been prepared for the project (Power,
2022). It delineates two nearly
equally
-
sized drainage management areas (DMA 1 and
DMA 2) across the
project

site. DMA 1
is the northern part of the site where the modular
building and
facilities

are propose
d and its flows
would drain to an existing pump
that is
part of the
existing

stormwater
system. DMA 2
is generally the south and southwest part
of the project site

where
existing development and paved areas
exist for
truck traffic

and

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circulation;
its flow
s
would

integrate
directly
into the existing stormwater system.

The
DMA’s are delineated to effectively capture and direct runoff to not exceed the existing system.

Based on the 24
-
hour, 100
-
year storm, pre
-
development flow is estimated at

11.89 cubic feet

per second (cfs). Post
-
development is estimated at 12.47 cfs, which is
less than 5 percent

potential change.

Also, permanent source controls would
be implemented to
address potential runoff
flows,
including.

Examples include use of
equipment closures

and

regular inspection of
potential pollutant sources for debris or blockages that may interfere with intended stormwater flows.

Adherence

to the
SWPPP

under the
NPDES

permit

(see criterion “a
and b”)
would also minimize erosion as well as polluted runoff.

Ov
erall, the proposed site alterations would not result in changes in stormwater flows that could exceed

the capacity

of the existing
stormwater

control
system

to which the project
site would flow. The impact is less than significant.

d)

In flood hazard, tsu
nami, or seiche zones, risk release of pollutants due to project inundation?

Less than Significant Impact
.

The California Geological Survey has mapped tsunami
inundation areas along the Richmond shoreline
, and the project

site
is located within the
hazard

zon
e (CGS, 2021)
.

Seiche risk at areas along Richmond’s shoreline are minimal because there are no large confined bodies of water with depths that would cause this hazard (City of Richmond, 2011)
.

As discussed in the above
Setting,
the

100
-
year flood
flow
s in San Pablo Creek
adjacent to the project site and
would be t
otally contained in the
channel, also t
he

levees around the WCCSL have

been designed and
maintained

to
exceed flood levels.

Therefore
, risk of inundation at the site is low, particularly due t o
risk of
a
seich
e

or flooding on the project site.

The i
mpacts would be less than significant.

e)

Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?

Less than Significant Impact
.

As discuss
ed in criterion “a”, the proposed project would

not conflict with implementation of the existing water quality plan nor release pollutants

from

its

construction or operation.

References

State of California, 2021, Tsunami Hazard Area Map,

Contra Costa

Count
y; produced by the
California Geological Survey, the California Governor's Office of Emergency Services, and AECOM; dated

2021. Accessed and printed September 13, 2022
.

Contra Costa County 2004.

Environmental Impact Report on the West Contra County Sanita ry
Landfill Bulk Materials Processing Center and Related Actions ,
SCH. 2002102057
.

June
2004
.

4. Environmental Checklist and Evaluation

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Contra Costa County 2009.

Addendum to the

Final

EIR

for the WCCSL BMPC and Related
Actions
,
SCH. 2002102057
. 2009
.

City of Richmond, 2012.

Richmond General Plan
Update Environmental Impact Report.

SCH.
2008022018.
2012.

Power, 2022
.

Draft S
tormwater Control Plan for Raven One
, July 22, 2022.

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4.11 Land Use and Planning

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Miti
gation

Incorporated

Less

than

Significant

Impact

No

Impact

Land Use

and Planning

Would

the

project:

a)

Physically divide

an
established

community?

b)

Cause

a
significant environmental

impact due

to

a

conflict with

any

land use
plan, policy,

or

regulation

adopted

for

the

purpose

of avoiding

or

mitigating

an

environmental

effect?

Setting

The proposed project area is the existing approximately 340 -
acre WCCSL, a self
-
contained area
and operation within the broader area of indu
strial and open space land uses
, including the Bay
Trail / Wildcat Creek Marsh Trail
. Other nearby use
s

include

the West
County Wastewater

District Treatment Plant, EBMUD’s North Richmond Water Reclamation Plan, the Richmond Sanitary District, and other re
fuse services, automobile repair and towing businesses, and
lawn
services, etc.

The Richmond Parkway is a major roadway through the area and spurs the Parr Boulevard approach to the WCCSL and adjacent
uses
.

The next nearest
established
community
is the res
idential development at generally West Gertrude Avenue/Malcolm Drive, approximately 0.75 miles southeast.

Evaluation

a)

Physically divide an established community?

No Impact
.

The proposed operation is consistent with current BMPC activities on the site.

T
he
refore, the

project could not divide any established community. The project would have no impact.

b)

Cause a significant environmental impact due to a

conflict with any land use plan,
policy, or regulation adopted for the purpose of avoiding or mitigatin g an
environmental effect?

Less than Significant Impact
.

The proposed
facility and operation
to convert
blended

green waste and food waste obtained from the existing BMPC operation adjacent to the project site into renewable, transportation grade hydrogen

would not conflict with any
existing land use plan, policy or regulation intended to mitigat e

environmental effects.

As
proposed, the project does not require approval of an amendment to any aspect of the General Plan or the City’s Zoning Ordinance or Map.

CEQA does not require
the project
to be
consisten
t

with all policies in the General Plan, nor
does it require
an assessment of

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compliance with every applicable General Plan policy.

Overall, the project advances
Policy EC2.2

Climate
-
Friendly Fuel Support p
roduction and distribution of climate
-
friendlier fuels (when and if any are identified) and identify appropriate locations for fuel storage and distribution (
Energy and Climate Change Element
).

This impact would be
less than significant.

References

City of

Richmond, 2012.

Richmond General Plan
Update Environmental Impact Report.

SCH.
2008022018.
2012.

City of Richmond, 2012.

Richmond General Plan

2030:

Public Safety and Noise E
lement.

Table

3.7 -
4,
Liquefaction
.
2012.

City of Richmond, 2012.

Richmond General

Plan

2030:

Conservation, Natural

Resources and
Open Space Element
.
2012.

City of Richmond, 2012.

Richmond General Plan

2030

Historic Resources Element
.
2012.

City of Richmond, 2012.

Richmond General Plan

2030:

Energy and Climate Change Element
.
2012.

Cont
ra Costa County 2004.

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

June
2004
.

Contra Costa County 2009.

Addendum to the

Final

EIR

for the WCCSL BMPC and Rela
ted
Actions
,
SCH. 2002102057
. 2009
.

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4.12 Noise

and Vibration

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Noise

Would

the

project

result in:

a)

Generation

of
a
substantial

temporary

or

permanent

increase

in ambient noise

levels

in

the
vicinity

of
the

project
in

excess

of

standards

established in
the
local

general

plan
or

noise

ordinance,

or applicable

standards

of

other

agencies?

b)

Generation

of excessive

groundborne

vibration

or

groundborne noise

levels?

c)

For

a

project

located within the

vicinity

of
a

private

airstrip

or

an

airport

land use plan or,

where

such

a

plan
has
not

been

adopted,

within

two

mile
s

of

a

public airport
or

public

use airport,

would

the

project expose people
residing

or

working

in
the

project area

to excessive

noise

levels?

Setting

The
proposed p
roject is located entirely within the
City of Richmond.

The
West
County
Wastewater

D
istrict Treatment Plant and other industrial uses exist east of the property. The nearest residential receptors are 0.75 miles (approximately 3,949 feet) southeast from the project site.

Approximately 7
-

to 8
-
foot
-
high sound walls were installed at these r
esidences when
Richmond Parkway was constructed to lower noise levels (WCCSL BMPC, 2003).

The primary noise sources in the vicinity of the
p
roject
site

include vehicles on adjacent
and
nearby
roadways: Richmond Parkway and Parr Boulevard. The existing ambi ent noise
environment in the
project
vicinity may be characterized by traffic noise modeling conducted for a previous EIR (City of Richmond, 2011) for primary roadways. Results of this traffic modeling are presented in
Table

4.12 -
1 and are representative o
f transportation noise levels generated by
roadways.

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T
ABLE

4.12 -
1 L

OCALIZED
R
OADWAY
T
RAFFIC
N
OISE

1 Roadway

Segment Description

Predicted, Ldn
2 , dB at 50 feet

Background

Richmond Parkway

Gertrude Street and Parr Boulevard

75.9 Richmond Parkway

Parr

Boulevard and San Pablo Avenue

74.7 NOTES:

1 Analytical Environmental Services. 2011.

Point Molate Mixed
-
Use Tribal Destination Resort and Casino Project
. Available
online:
https://www.ci.richmond.ca.us/DocumentCenter/View/7685/Section_4p11?bidId =

2 L
dn

is t
he energy average of the A
-
weighted sound levels occurring during a 24
-
hour period, and which accounts for the greater
sensitivity of most people to nighttime noise b
y weighting noise levels at night (“penalizing” nighttime noises).

SOURCE: Brown and Buntin Associates, 2008.

Evaluation

a)

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

Less than Significant Impact
.

Noise would be generated during both construction and
operational phases of the
p
roject
.

Construction

Construction of
the
proposed p
roject would occur over a period of approximately
eight
months
, starting
Fourth

Q
uarter

of
2022
, and
start
-
up of the plant is projected to begin in
the Second to Third Quarter of 2023.
.

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

City of Richmond Noise Ordinance, Section 15.04.605.060, regulates construction noise by allowing construction work that generates noise to occur weekdays between the hours 7:00

a.m. and
6 :00 p.m.,
except outside of t
hese hours or on Sundays and federal holidays
unless a temporary waiver is granted by the Building Official or his or her authorized representative (City of Richmond, 20
18 )
.

T
he
proposed project would adhere to the
City’s construction work hours. The City’
s
construction noise level limitation of
75 dBA is

used to assess whether daytime L
eq

construction
-
related noise levels would cause a substantial temporary or periodic increase in ambient noise levels at sensitive receptor locations.

City of
Richmond Noise

Ordinance,

9.52.110 Temporary construction activity
, limits
noise levels

measured at

SFR
-
1, SFR
-
2, SFR
-
3 Zoning Districts

(Single
-
Family

Residential)

to 75 dBA between
the hours of
7:00 a.m. to 7:00 p.m
. on weekdays.

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The operation of each piece of equipm
ent would not be constant throughout the day, as
equipment would be turned off when not in use. Over a
typical workday, the equipment
would be operated at different locations and all the equipment would not operate concurrently at the same location
within
the
p
roject site

or roadways to and from the
site
. Construction noise levels have been estimated using typical equipment source noise levels suggested in the Federal Highway Administration’s (FHWA) Roadway Construction Noise Model (RCNM) and based on the t
ype of construction equipment
that are proposed to be used. To
quantify construction
-
related noise exposure that would
occur at the nearest sensitive receptors, it was assumed that the two loudest pieces of construction equipment would operate concurrently

at
the
location

within

the
p
roject site
and
construction vehicle paths

to the nearest sensitive receptor locations.

The estimated L
max

and L
eq

for each of the two loudest pieces of equipment that would be used to construct the
project

components, and the

combined L
eq

noise level associated
with the two loudest pieces of construction equipment at the closest sensitive receptor locations for each
p
roject component are identified in
Table

4.12 -
2 . The combined L
eq

construction noise levels would not exceed th
e City’s construction noise level limitation
of 75 dBA described in Table

4.12 -
2 . This modest noise contribution would not increase
the existing ambient noise level at the nearest receptor .

T
ABLE

4.12 -
2 C

ONSTRUCTION
E

QUIPMENT
N
OISE
L
EVELS

Type of
Equipmen
t

Distance to Closest
Sensitive Receptor
(feet)

Equipment
L
max
, dBA

Equipment Hourly
L
eq
, dBA/Usage%

Combined Leq at
Sensitive
Receptor, dBA

Demolition

Crushing/Proc.

Equipment

3 ,
949 (Residences)

52.3 45.3/20%

46.2 Excavators

42.8 38.8/40%

Site Prepa
ration

Tractors

3 ,
949 (Residences)

46.0 42.1/40%

45.6 Rough Terrain
Forklifts

47.0 43.1/40%

Grading

Excavators

3 ,
949 (Residences)

42.8 38.8/40%

43.7 Tractors

46.0 42.1/40%

Building Construction

Rough Terrain
Forklifts

3 ,
949 (Residences)

45.4 41.
5/40%

46.0 Other Construction
Equipment

47.0 44.0/50%

NOTES:

L
max

= maximum instantaneous noise level; L
eq

= the equivalent sound level used to describe noise over a specified period of time, in terms of a single numerical value
; L
max

= the instantaneo
us maximum noise level measured during the
measurement period of interest.

SOURCE
:

Federal Highway Administration, 2008.

FHWA Roadway Construction Noise Model, Version 1.1
, December 2008.

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In addition to on
-
site construction equipment, the
p
roject would a
lso result in short
-
term
increases in local daytime traffic volumes. The
p
roject components would each add up to
approximately 84 one
-
way daily construction
-
related vehicle trips to area roadways,
including 72 one
-
way daily hauling trips, 4 one
-
way daily v
endor trips, and 8 one
-
way
daily worker trips
.

The
p
roject truck trips would access the
nearest
freeway
(Interstate
580)
via Parr Boulevard and Richmond Parkway and would not utilize roadways with noise
-
sensitive land uses. Therefore,
the
associated increa
se in short
-
term construction
vehicular noise levels would not be expected to increase noise levels in the vicinity of existing sensitive receptors beyond the levels described in Table

4.12 -

2. Operation

The Raven SR system
would

run
up to
24 hours per day,

7 days per week,
although
an
average of

1.5 days per month are planned down times
.

The primary source of noise
during
p
roject operation would be mechanical equipment associated with the Steam/CO 2 Reformation system, including heating systems, HVAC equipme nt.

Also, feedstock
would be physically
deposited in the receiving area

via self
-
unloading transfer trucks or
other suitable vehicles
.

The hydrogen compressors are industrial pieces that could generat
e

noise up to as much as 85 dBa at 1
.0

meter.

Additional
ly, trucks used to
distribute fuels generated on the site would be maneuvering within the parking lot of the proposed facility.

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

(City o
f

Richmond,
2012). The 65 dBA L
eq
measured at any boundary of a residential zone is used here to assess whether operational noise levels would cause a substantial permanent increase in ambient noise levels.

I
t is not possib
le to provide specific noise levels at individual receptor locations that would result from operation of stationary sources. However, the nearest noise -
sensitive
receptor would be
approximately 0.75 miles

from the project site property line.

Table

4.12 -
3 p
resents reference noise levels for many of the

stationary

sources for
informational purposes. Given the data in Table

4.12 -
3 and the
known distance to the
nearest noise
receptors, the operational noise levels would be
substantially
below the 65
dBA standar
d of the City of

Richmond Noise Ordinance and the operational noise impact would be
less than significant
.

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T
ABLE

4.12 -
3 R

EFERENCE
N
OISE
L

EVELS FOR
S

TATIONARY
N
OISE
S
OURCES
A

SSOCIATED WITH THE
P

ROPOSED
P
ROJECT

Stationary

Noise Source

Documented Sound

Leve
ls (dBA)

Noise Level at
Nearest
Receptor

Source

HVAC Equipment

72 –
78 dBA at 30

feet without
acoustical treatments

19 -
25 dBA

Trane,
Sound Data and Application
Guide
, 2002

Standby

Diesel

Generator

75 –
90 dBA at 23

feet

(size dependent) without acoustical
en
closure

19 -
34 dBA

Cummins Power Generation,
Sound Attenuated and Weather
Protective Enclosures
, 2008

Loading Dock

77 dBA at 20

feet

20 dBA

Urban Crossroads,
Moreno Valley
Walmart Noise Impact Analysis
,
2015

NOTES:

dBA = A
-
weighted decibels; ESA = Environ
mental Science Associates; HVAC = heating, ventilation and air conditioning

SOURCE: Data compiled by Environmental Science Associates in 2022. (Additional sources noted above.)

b)

Generation of excessive groundborne vibration or groundborne noise levels ?

Less than Significant Impact
.

Operations and maintenance of the
project facility

would
not include any sources of vibration that would be considered excessive. Groundborne vibration and noise associated with some construction activities, including the us e of pile
drivers, blasting, and vibratory rollers
,

can cause excessive vibration. The
project

would not
include any such activities. Groundborne vibration and noise levels generated by the types of equipment required to
prepare the site and
construct the
proposed facility
would be
minimal and would not cause human annoyance or structure damage at a distance of 25

feet
or beyond from the source (FTA, 2018). No existing historic structures that would be potentially vulnerable to vibration are located in the
immediate vicinity of the
p
roject site
such that any damage related to groundborne vibration from construction activities would occur. This impact would be
less than significant

and mitigation measures are not
warranted
.

c)

For a project located within the

vicinity of a private airstrip or an airport land use
plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise l
evels?

No Impact
.

The
p
roject is located approximately 8.3 miles southeast of the San Rafael Airport and is not located within the 55 dBA L
dn

noise contours for the San Rafael
Airport (City of San Rafael, 2021
)
. The
proposed p
roject would not involve the
d
evelopment of noise
-
sensitive land uses that would be exposed to excessive aircraft noise. Therefore, there would be no impact.

References

California Department of Transportation (Caltrans), 2013.

Technical Noise Supplement (TeNS)
.

September 2013.

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

April 25, 2012.

City of Richmond, 2022. Richmond Municipal Code, Article 15.04.605

-

Noise. March 16, 2022.

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

Federal Highway Administration (FHWA), 2008. FHWA Roadway Construction Noise Model, Version 1.1, December 2008.

Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment

Manua
l. September 2018. Available:
https://www.transit.dot.gov/sites/fta.dot.gov/fil
es/docs/research
-
innovation/118131/transit
-
noise
-
and
-
vibration
-
impact
-
assessment
-
manual
-
fta
-
report
-
no
-
0123_0.pdf
. Accessed March
31, 2022.

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4.13 Population

and Housing

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

w
ith

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Population

and

Housing

Would

the

project:

a)

Induce

substantial unplanned

population

growth

in

an
area,

either

directly

(for

example,

by proposing

new

homes

and

businesses) o
r

indirectly

(for

example,

through extension

of

roads

or other

infrastructure)?

b)

Displace

substantial

numbers

of

existing

people

or

housing, necessitating

the construction

of

replacement housing elsewhere?

Setting

As previously discus
sed in Section 4.11,
Land

Use and Planning,
in this section, the project area
entails open space and a range of

industrial
and commercial uses. No housing exists within 0.75
miles of the area, and the proposed project would be developed within existing BMP C facilities
and operations.

Evaluation

a)

Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?

No

Impact
.

The proposed project does not entail new housing, roads or other infrastructure that would induce substantial growth; the new business would involve 3 to 4 new
employees per shift, for a total of 9 to12 new employees per day, which would not consti
tute substantial population growth.

There would be no impact.

b)

Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?

No Impact
.

No housing or people exist on the project site. The pro ject would have no
impact.

References

None.

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4.14 Public Services

and Recreation

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Public

Services

Would

the

project

result in

substantial

adverse

physical

impacts

associated

with

the provision

of

new

or

physically
altered

governmental

facilities,

need

for

new

or

physically

altered

governmental

facilities,

the

construction

of which

could cause significa
nt

environmental

impacts, in order

to

maintain

acceptable

service

ratios, response times
or
other

performance objectives

for

any

of

the

public services:

a)

Fire

protection?

b)

Police

protection?

c)

Schools?

d)

Parks?

e)

Other

public

facilities?

Recreation

a) Would the project increase the use of existing

neighborhood
and regional parks or other recreational facilities such that substantial physical deterioration of the facility
would occur or
be accelerated?

b) Does the project include recreational facilities or

require the
construction or expansion of recreational facilities, which might have an adverse physical effect on the environment?

Setting

The project area i
s currently serviced by the

Richmond

Fire Department (RFD), which also
manages the
West

County Fire District, which also serves San Pablo, El Sobrante, and unincorporated areas of
Western

Contra Costa County, including North
Richmond.

The nearest
fire stat
ion is RFD Station 62 at 1065 7th Street, Richmond.

Evaluation

Public Services

a)

Fire Protection

and Emergency Medical

Less than Significant Impact
.

The project site
would

be
served

by the same fire and
emergency services that currently serve the
WCCSL.

The
project
would

also install a

new
2 50
,000
-
gallon
fire water tank and
diesel engine
in the northeast corner of the site

for emergency use
, as required by fire department regulations

The fire water tank would
be up to 25.5 feet tall and include two pump
s, a small jockey pump for normal
circulation, and

the diesel
-
powered fire pump
(shown in Figures 2
-
1 through 2
-

4.) A
ll

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construction
-
related mitigation measures identified in this analysis would apply to that development

onsite
.

The proposed operation
wou
ld

involve up to
3 to 4
new
employees per shift

and would
not involve customers onsite
.

Also, t
he Raven SR system itself is not a combust
ion

process and would incorporate several safety measures, including continuous monitoring
systems
,
automatic
plant ope
rations
shut down without human intervention
,
compliance
with
applicable
EPA

RMP and OSHA PSM guidelines
, including
applicable USDOT
regulations

for the on
-
road transport of hydrogen gas
.

Overall, the project would not
result in noticeable increased demand

for service that would
require

new fire or
eme
rgency medical facilities. The
impact would be less than significant
.

b,c
)

Police Protection
,
Schools, Parks, Other

No Impact
.

The project
would

not involve changes
that

would increase the demand for
policy pr
otection on the project site.

Th
ere would be
no impact. Also, t
he project
would

not involve changes
that

would increase the demand for
schools, parks or other public
services.

Th
ere would be
no impact
.

Recreation

a)

Would the project increase the use of e
xisting neighborhood and regional parks or
other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?

No Impact
.

The project
would

not
introduce new
people

onsite that would increase the
use of

recreational facilities or parks. New population would consist of up to
3 to 4
new
employees
per shift; no
customers would be onsite
.

There would be no impact

b)

Does the project include recreational facilities or require the construction or expansion of
recreational facilities, which might have an adverse physical effect on the environment?

No Impact
.

The project
would

include

new or expanded

recreational facilities or parks.

There would be no impact
.

References

City of Richmond, 2011.

General Plan 2030

–

Map 12.6 Police and Fire Services
. August
2011
.

City of Richmond, 2012.

Richmond General Plan
Update Environmental Impact Report.

SCH.
2008022018.
2012.

Google Earth Pro, Richmond Fire Stations, June 2022.

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4.15 Transportation

Environmental

Issues

Po
tentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Transportation

Would

the

project:

a)

Conflict

with

a

program

plan,

ordinance

or policy

of

the

circulation system,

i
ncluding

transit,

roadway,

bicycle

and pedestrian

facilities?

b)

Would
the

project conflict

or

be
inconsistent

with

CEQA Guidelines

Section 15064.3,

subdivision

(b)?

c)

Substantially

increase hazards

due

to a

geometric

design fe
ature

(e.g., sharp curves

or

dangerous

intersections) or

incompatible

uses

(e.g., farm

equipment)?

d)

Result

in inadequate emergency

access?

Setting

The Richmond Parkway is a major roadway in the area that extends from

Interstate 580 ne
ar the
east approach to the Richmond
-
San Rafael Bridge northeasterly to

Interstate 80 near Hilltop
Drive.

Parr Boulevard from Richmond Parkway is the main approach to the project site within
the
WCCSL and other nearby uses
.

Evaluation

a)

Conflict with a p
rogram, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities?

Less than Significan
t Impac
t.

Table

4.15 -
1 summarizes the daily vehicle trip ge
neration
for the
p
roject based on the expected number of employees and truck activity at the site.

Since trucks are larger and operate slower than passenger vehicles, a

passenger

car
equivalent (PCE) ratio of 2.0 is used to convert the truck trips

to passe
nger vehicle trips
(each truck is counted as two passenger vehicles). Accounting for PCE trips, the p
roject
is estimated to generate about
130
net new PCE trips on a typical weekday.

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T
ABLE

4.15 -
1 P
ROJECT
D
AILY
T
RIP
G

ENERATION
S
U
MMARY

Use

Amount

Daily Trip Rate

Passenger Car
Equivalent (PCE)
a

Daily Trips

Employees

12 b

2.5 c

1.0 30

Trucks

25 d

2.0 e

2.0 100

Total trips (PCE)

130

NOTES:

a

A PCE of 2.0 is used for trucks because they are lager and operate slower than passenger

vehicles

b

Per the Project Applicant and described in Chapter 2,
Project Description

c

One inbound and one outbound trip per employee per day plus 0.5 trips per employee per day for other trips such as deliveries ,
running errands, etc.

d

Per the Project
Applicant and as described in Chapter 2,
Project Description
,
125

trucks would serve the site during a typical week.

This estimate assumes they
would

be evenly distributed on five weekdays

e

One inbound and one outbound trip per truck

SOURCE: Fehr & Peers
, 2022

The addition of
130
new trips on a typical weekday would not substantially increase the motor vehicle volumes on the nearby streets, including Parr Boulevard and Richmond Parkway. In addition, considering that both streets currently have high tru ck volumes
because they serve primarily industrial areas, the additional trips generated by the p
roject
would not conflict with existing and proposed
transit, roadway, bicycle
,

and pedestrian
facilities

in the
p
roject vicinity. The
p
roject would also not m
odify any
transit, roadway,
bicycle
,

or
pedestrian facilities

and would not conflict with existing or proposed facilities in the
p
roject vicinity.

The
p
roject would be consistent
with

programs, plans, ordinances, and policies
addressing the circulation sys
tem, including transit, roadway, bicycle, and pedestrian facilities
. The impact is

less than significant
.

b)

Would the Project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?

Less than Significant

Impact
.

CEQA Guidelines
Section 15064.3, added in December
2018 and consistent with the requirements of SB 743, states that vehicle miles traveled (VMT) is the most appropriate metric to assess the environmental impacts of a project on transportation.

T
he City of Richmond adopte
d VMT
analysis
guidelines,
methodology
, and thresholds of
significance on April 6, 2021, consistent with the Contra Costa Transportation Authority (CCTA)’s adopted VMT guidelines
, which are also consistent with the State’s Office of
Planning and Research’s

(OPR)
Technical Advisory on Evaluating Transportation
Impacts in CEQA
(December 2018)
.

The City of Richmond guidelines includes
screening
criteria for development projects that meet certain criteria that can readily lead to the conclusion that they would
not cause a significant impact on VMT. The screening
criterion applicable to the
p
roject is the Small Projects criterion, which states that projects

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generating less than 836 VMT per day can be presumed to cause a less than significant impact on VMT.

Error! Not a valid bookmark self
-
reference.

summarizes the estimated VM
T generated by
the
p
roject on

a typical weekday. Since the City of Richmond’s adopted guidelines, which are based on the CCTA Guidelines and consistent with CEQA Guidelines section

15064.3, subdivision (a) state that the VMT analysis for transportation impact purposes
can focus solely on VMT generated by
passenger vehicles

and light
-
duty trucks and not
include the VMT generated by heavy trucks
, the
p
roject VMT summarized in
Error! Not
a valid bookmark self
-
reference.

does not include

the VMT generated by trucks for the
p
roject. As shown in
Error! Not a valid boo
kmark self
-
reference.
, the

p
roject is
estimated to
generate 174
VMT per day, which is below the screening

criterion of 836
VMT per day. Therefore, the
p
roject can be presumed to have a less than significant
impact on VMT and is consistent with CEQA Guidelines section 15064.3, subdivision

(b)

and the impact is less than significant.

T
ABLE

4.15 -
2 P
ROJECT
VMT

S
UMMARY

Use

Amount

Daily VMT Rate

Total VMT

Employees

12 a

14.5 b

174

Total

174

Threshold

836

Below Threshold?

Yes

NOTES:

a

Per the Project Applicant and described in Chapter 2,
Project Description

b

Daily commute VMT per
worker in 2020 based on the CCTA Travel Demand Model for TAZ 10347, where the project

is located

c

Per the Project Applicant and as described in Chapter 2, Project Description
,
125

trucks would serve the site during a typical week. This estimate assumes th
ey
would

be evenly distributed on five weekdays

d

Per the Project Applicant and described in Chapter 2,
Project Description
, average truck trip would be 40 miles; assuming two trips (one inbound and one outbound) per truck.

SOURCE: Fehr & Peers, 2022

c
)

Substantially increase hazards due to a geometric design feature, (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?

Less than Significant

Impact
.

The
p
roject would not modify the access point to the
existing
WC
CSL
facility
, the internal circulation within WCCSL, or the public right -
of
-
way.

Passenger vehicles and trucks would continue to access the p
roject site
through
Parr
Boulevard

and Richmond Parkway
.

T
he
p
roject

is
located
in an industrial area
with high
vol
ume of
large trucks
already present on
surrounding roadways
,

including
Parr
Boulevard

and Richmond Parkway
.

The additional trucks added by the
p
roject
would not
result in incompatible uses or increase hazards.

Thus, the impact on
hazards due to a
geometric

design feature

or incompatible uses

is less

than

significant.

d)

Result in inadequate emergency access?

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Less than Significant

Impact
.

As
discussed

above, the
p
roject would
not
modify the
access point to the
existing
WCCSL
facility
,

the internal circulati
on within
WCCSL
,
or
the public right
-
of
-
way. Emergency vehicles would continue to access t
he
p
roject site
on
Parr Boulevard
.

The
p
roject
would

be designed and constructed according to the applicable fire and safety standards at the time of construction.

T
herefore, t
he
WCCSL
site would
continue to
be
accessible by fire and emergency vehicles through public streets and the internal
roadways within the WCCSL
.

Thus, the impact on emergency access is less

than

significant.

References

California State’s Office o
f Planning and Research’s (OPR)
Technical Advisory on Evaluating
Transportation Impacts in CEQA
(December 2018)
.

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4.16 Tribal Cultural Resources

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporate
d

Less

than

Significant

Impact

No

Impact

Tribal

Cultural

Resources

Would

the

project
:

a
)

Cause a substantial adverse change in the significance
of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site,
feature, place,
cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:

i
)

Listed

or

eligible

for

listing

in

the

California Register

of

Historical

Resources, or

in
a
local

register

of

historical

resources

as

defined

in

Public Resources

Code Section

5020.1(k),

or

ii
)

A resource determined by the lead agency, in its

discretion and

supported by substa
ntial evidence, to
be significant

pursuant to criteria set forth in
subdivision (c)

of Public Resources Code Section

5024.1. In applying the criteria set forth in subdivision (c)

of Public Resource Code Section 5024.1, the lead
agency shall

consider the si
gnificance of the
resource to a California

Native American tribe.

Setting

ESA contacted the California State Native American Heritage Commission (NAHC) on October 20,
2021
, to request a search of the NAHC’s Sacred Lands File and a list of Native Amer ican
representatives who may have knowledge of tribal cultural resources in the project vicinity or interest in the proposed project. The NAHC replied to ESA by email on November 19, 2021
,

noting that the Sacred Lands File has no record of any sacred sites

within the project site. The
NAHC response included a list of 15 Native American representatives from 13 tribal groups who may have knowledge of tribal cultural resources in the vicinity of the project site.

On May 4, 2022, the City received a response fo
r consultation from Chairwoman Corrina Gould
of the Confederated Villages of Lisjan. On May 18, 2022, the City held a virtual meeting with tribal members, Chairwoman Gould, Deja, and Cheyenne, to discuss the project and any potential impacts to cultural re
sources. Based on the discussion, the tribe has no concerns with the project as it relates to impacts to tribal cultural resources and cultural resources, and is comfortable with the proposed mitigation measures. See
Section
4 .5,

Cultural Resources
,
of thi
s checklist

for a
summary of ESA’s NWIC records search and cultural resources sensitivity assessment.

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Evaluation

a.i
,

a.
ii)

Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as

defined in Public Resources Code Section
5020.1(k), or significance of the resource to a California Native American tribe .

Less than Significant
Impact, after

Mitigation
.

CEQA requires the lead agency to
consider the effects of a project on tribal cultura
l resources. As defined in PRC Section
21074, tribal cultura
l resources are sites, features, places,
cultural

landscapes, sacred
places, and objects with cultural value to a California Native American tribe that are listed, or determined to be eligible for

listing, on the national, state, or local register of
historical resources.

Based on the NWIC records search and the NAHC SLF negative search results, there are no known tribal cultural resources listed or determined eligible for listing in the Californi
a

Register of Historical Resources or included in a local register of historical resources as defined in PRC Section 5020.1(k), pursuant to PRC Section 21074(a)(1), would be affected by the project. No tribal cultural resources have been identified by Nati ve
American representatives, and background research did not identify any tribal cultural resources. In addition, the City did not determine any resource that could potentially be affected by the project to be a significant tribal cultural resource pursuan t to criteria set
forth in PRC Section 5024.1(c).

In the event that cultural materials are identified during project construction activities

that
are determined to be tribal cultural resources,
implementation of
Mitigation Measure
CUL
-
1a: Cultural Resourc
es Awareness Training
,

Mitigation Measure CUL
-
1b:

Inadvertent Discovery of Cultural Materials or Tribal Cultural Resources , and

Mitigation Measure CUL
-
2: Inadvertent Discovery of Human Remains
, all
identified

above

in
Section

4.5 ,
Cultural Resources
, would

reduce potentially significant
impacts

to
less than significant.

These

mitigation
measures
would ensure that
all personnel complete
a cultural resources awareness training prior to any ground -
disturbing activity and that
work
halt
in

the vicinity of a fin
d until a qualified archaeologist
and a Native American
representative
can make an assessment and pro
vide additional recommendations
.

References

Northwest Information Center (NWIC), Records Search File No. File No.

21 -
1575
. On file, ESA,
March 23, 2022.

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4.17 Utilities and Service Systems

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Utilities

and

Service
Systems

Would

the

project:

a)

Require or

result

in

the relocation

or construction of

new or

expanded

water, wastewater

treatment

or

stormwater

drainage,

electric power, natural

gas,

or

telecommunications

facilities,

the

construction

or

relocation

of

which could cause

significant

enviro
nmental

effects?

b)

Have

sufficient water

supplies

available

to
serve

the

project and

reasonably foreseeable

future

development

during

normal, dry and

multiple

dry

years?

c)

Result

in
a

determination

by
the
wastewater

treatment
provider

which serves

or

may

serve

the

project that

it
has
adequate capacity

to

serve

the

project’s

projected demand

in

addition
to
the

provider’s

existing commitments?

d)

Generate

solid waste

in

excess

of

State

or

local

standards,

or

in

exce
ss

of
the

capacity

of local

infrastructure,

or

otherwise

impair

the

attainment

of

solid

waste

reduction goals?

e)

Comply

with federal,

State,

and

local

management

and
reduction

statutes

and regulations

related

to

solid

waste?

Setting

Th
e
project

site, within the WCCSL BMPC, is currently served by all public utilities, including water and wastewater treatment by EBMUD and West
County Wastewater

District, respectively,
as well as the reuse of runoff water, and PG&E provides electric power,

natural gas.

Evaluation

a)

Require or result in the relocation or construction of

new or expanded water,
wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which co uld cause
significant environmental effects?

Less than Significant Impact
.

The
existing WCCSL
would

use offtake approximately

0.5 MW from the power generation for
Republic’s

onsite operation needs and the rest
would be used to power the proposed project. A
ny additional electrical power required
beyond that generated onsite would come from an existing PG&E power drop to the site.

The project
would

also involve a new
250
,000
-
gallon
integrated
fire water tank and
diesel
engine
for emergency use,
per fire regul
ations, but
would
continue to be served by RFD

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and

the West County Fire District.

As previously discussed in 4.14,
Public Services and
Recreation,
all construction
-
related mitigation measures identified in this analysis would apply to that development

onsi
te, which
would

ensure any environmental effects from the
project would be less than significant.

b
)

Have sufficient water supplies available

to serve the

project and reasonably
foreseeable future development during normal, dry and multiple dry years?

Les
s than Significant Impact
.

Steam is injected into the process to promote the thermal decomposition of the feedstock.

Estimated water flow required for boiler feedwater and
for cooling tower make
-
up
is about 70 percent of the total required and
is on the or
der of
60 gallons per minute
(gpm)

(81,500 gallons per day [gpd]). A
dding in required water
flow for overall processes and wash water for cleaning, the total

water flow required for
the project is estimated
to be
81 gpm

(116,200 gpd)
(Raven, 2022b)
.

Potab
le water is available for both domestic and fire protection to the subject property from existing major facilities (e.g., reservoirs, pumping plants), which are serviced and maintained by EBMUD. Service
would

be granted subject to compliance with the
Distr
ict’s regulations governing water service and Schedule of Rates and Charges, which may include water main extensions and/or off
-
site pipeline improvements

(Raven SR,
2022c)
. For this analysis, it is not anticipated that t
he proposed project would require n
ew
water supplies for its operation to the extent that it would make future water supplies insufficient. The impact would be less than significant.

c)

Result in a determination by the wastewater

treatment provider which serves or
may serve the project tha
t it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?

Less than Significant Impact
.

Wastewater generated by the process is mainly cooling
tower blowdown, RO system blowdown, and boiler syste
m blowdown, along with a
small flow from the syngas wash columns. Intermittent flow is from potable sources (restrooms, sinks, etc.) and area wash down water. Wastewater would be generated from
the syngas wash columns, which can potentially contain low con cen
trations of organic
compounds.

Wastewater
would
be treated before it is discharged to the sewer systems through sump and grease/oil
where the organic content
would
be removed for
capture/reclaim/disposal, and the water portion sent to the wastewater sew er.

Total
wastewater
discharge from all project processes

(or waste streams) is estimated to
be 50,200 gallons per day
, and the West County Wastewater District
would

permit this
additional use upon its determination that the discharge may be covered by the

Districts’
Pretreatment and/or Pollution Prevention programs

(Raven, 2022b)
.

Discussions are occurring
between the project applicant and the

West County Wastewater
District and
are in the permitting process.

At this time, there are no anticipated capacit
y
issues expected.

Given the small scale of the proposed project, the lack of notable new population

onsite, it is
reasonable

that the West County Wastewater District, as

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wastewater treatment provide
r
,
would

maintain adequate
capacity

to meet its demands
w
ith the addition of the proposed project. The impact
would

be less than significant.

d,e)

Generate solid waste in excess of State or local

standards, or in excess of the
capacity of local infrastructure, or otherwise impair the attainment of solid waste r
eduction goals?

Comply with federal, State, and local management

and reduction
statutes and regulations related to solid waste?

Less than Significant Impact
. The project
would

not generate
substantial
solid waste but
would convert existing organic waste in
to a reusable fuel product. Therefore, the
project

would not
conflict

with existing local or other laws or policies regarding the reduction,
reuse

and management of solid waste. The impact
would

be less than
significant
.

References

City of Richmond, 2012.

Richmond General Plan
Update Environmental Impact Report.

SCH.
2008022018.
2012.

Contra Costa County 2004.

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

June
2 004
.

Contra Costa County 2009.

Addendum to the

Final

EIR

for the WCCSL BMPC and Related
Actions
,
SCH. 2002102057
. 2009
.

RAVEN SR, 2022b. West County Wastewater District Wastewater Discharge Permit Application. October 2022.

RAVEN SR, 2022c. Correspondence

from Tracy Barrow, East Bay Municipal Utilities District, to Mike Fatigati, Raven SR. September 2022.

______________________________

4. Environmental Checklist and
Evaluation

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4.18 Wildfire

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorpo
rated

Less

than

Significant

Impact

No

Impact

Wildfire

If

located in
or

near

State

Responsibility Areas

or
lands classified

as

very

high

fire hazard

severity

zones,

would

the
project:

a)

Substantially

impair

an

adopted

emergency

response

plan

or

emergency

evacuation

plan?

b)

Due
to

slope,

prevailing

winds,

and

other

factors,

exacerbate wildfire

risks,

and thereby

expose

project

occupants

to, pollutant concentrations

from
a

wildfire

or

the

uncontrolled

spread

of

a
wildfire?

c)

Require
the

installation

or

maintenance of

associated

infrastructure

(such

as
roads,

fuel

breaks,

emergency

water

sources,

power

lines

or

other

utilities)

that

may

exacerbate

fire

risk

or

that

may

result

in

temporary

or

ongoing

impacts

to
the

en
vironment?

d)

Expose people or

structures

to

significant

risks,

including downslope

or

downstream

flooding

or

landslides,

as

a

result

of

runoff,

post
-
fire

slope

instability, or

drainage changes?

Setting

The
p
roject site borders
e
xpansi
ve

non
-
native grassland and ruderal species

in

open and that can
get very dry during

summer months. Factors that contribute to the risk of fire include dense and fire
-
prone vegetation,

poor access to fire
-
fighting equipment because of slopes or inadequate
roads, lack of adequate

water pressure and service in fire
-
prone locations, and seasonal
atmospheric conditions that result

in warm, dry fire seasons with strong afternoon winds. Wildfire hazard maps show the site as
not
being within
a high wildfire hazard

zone

(
CPUC
,
2018
).

Evaluation

a)

Substantially impair an adopted emergency

response plan or emergency evacuation
plan?

Less than Significant Impact
. As discussed under Section 4.15,
Transportation
, the
p
roject would not modify the access point to the
exi
sting
WCCSL
facility
, the internal
circulation within WCCSL, or the public right
-
of
-
way.

Therefore, the project would not
impair any existing plans for emergency response or evaluation. The impact would be less than significant.

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b)

Due to slope, prevailing

winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?

Less than Significant Impact.

Certain project characteristics
could have the p
otential to
exacerbate wildfire risks
, such as diesel fuel storage for the
fire water take
.

However, no
hazardous materials would be used in the
conversion
process. The

biocarbon

materials

produced
are

inert

to

the

process

(i.e.,

not

gasified)
. Also, t
he c
onversion process also
derives electricity

from

fuel

cells

or

turbines and/or

internal combustion engine

generator

sets.

The project
site
is relatively flat, within the context of marshlands and Bay shoreline, and would also include a new fire water tank
and
diesel engine
per fire regulations onsite
. The
tank would be used for emergency use, although the project site would still being served
by the RFD and the West County Fire District. The impact would be less than significant.

c)

Require the installation

or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?

No

Impact.

The project s
ite is fully served by existing infrastructure that currently service the WCCSL. It would not require the installation or maintenance of additional infrastructure
that may exacerbate fire risk. The
re would be no

impact.

d)

Expose people or structures to si
gnificant risks, including downslope or downstream
flooding or landslides, as a result of runoff, post
-
fire slope instability, or drainage
changes

Less than Significant Impact
. The project would not introduce new people on the site, other than up to three

to four employees per shift. As previously mentioned, the site is relatively flat, not located within downstream flood or landslide areas.

The proposed
project is not located in a
high wildfire hazard zone (CPUC, 2018).

The impact would be
less than signi
ficant.

References

California Public Utilities Commission. Fire
-
Threat Map
–

State of California.

January 19, 2018
.

City of Richmond, 2011.

General Plan 2030
–

Map 12.6 Police and Fire Services
. August 2011.

City of Richmond, 2012.

Richmond General Plan Up
date Environmental Impact Report.

SCH.
2008022018. 2012.

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4.19 Mandatory Findings of Significance

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Mandatory Findings

of

Significance

a)

Does

the

project

have

the

potential

to
substantially

degrade

the

quality

of
the

environment,

substantially
reduce

the

habitat

of
a
fish

or

wildlife

species, cause

a
fish

or

wildlife

population to

drop

below

s
elf
-
sustaining

levels,
threaten
to
eliminate

a

plant

or animal

community,
substantially

reduce
the

number

or

restrict

the

range of

a
rare or

endangered

plant

or animal,

or

eliminate

important
examples of

the
major

periods

of

California

history or

prehistor
y?

b)

Does

the

project

have

impacts

that

are

individually

limited,

but

cumulatively

considerable?

(“Cumulatively
considerable” means

that

the

incremental

effects

of
a

project

are considerable

when

viewed

in

connection

with

the

effects

of

past

projects,

the

effects

of other

current
projects,

and

the
effects

of probable future

projects)?

c)

Does

the

project

have

environmental

effects,

which

will cause

substantial

adverse

effects

on human

beings, either

directly or

indirectly?

Findings

a)

Does the project have the potential to substantially

degrade the quality of the
environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self
-
sustaining levels, threaten
to eliminate
a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory?

Less than
S
ignificant
I
mpact
,

after Mitigation
.

The proposed project may result in
potential
construction
-
related impacts to nesting special
-
status birds
and to
California
Black Rail and
California
Ridgway’s Rail
.

The potential impacts are reduced to

less than
significant
by requiring

surveys and
avoidance of construction
-
related work during
specific times of year:

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

Mitigation Measure BIO
-
2: Avoid and Minimize Impacts to California
Black Rail and Califo
rnia Ridgway’s Rail

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The proposed project may result
in

potential impacts to C
ultural
R
esources
,
Paleontological Resources (Geology and Soils),

and Tribal Cultural Resources
,

unless the
following mitigation measures are implemented, which would reduce the potential
impacts to less than significant:

Mitigation Measure CUL
-
1a: Cultural Resources Awareness
Training

Mitigation Measure CUL
-
1b:

Inadvertent Discovery of Cultural Materials
or
Tribal Cultural Resources

Mitigation Measure CUL
-
2: Inadvertent Discove
ry of Human Remains
.

b)

Does the project have impacts that are individually

limited, but cumulatively
considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects,
the effects of other current projects, and the effects of probable future projects)?

Less than Significant Impact
, after Mitigation
.

The project does not result in a
cumulative
consideration impact for any environmental factors. One commo n exception,
this evaluation does identify
the BAAQMD Basic Construction Mitigation Measures
Recommended for All Projects (Best Management Practices) to address fugitive dust
during construction, which applies even though the project’s construction air emi ssions
are all below the BAAQMD CEQA thresholds of significance. The BMPs also apply to all individual projects and ensure that a significant impact with respect to fugitive dust is less than significant.

Mitigation
Measure

AQ
-
1: Best

Management Practices
.

Given
the

relatively

small
scope
of

the pr
oposed pr
oject
,
its
limited
potential
impacts,

as
well as the mitigation measures
identified
in this Draft IS/MND
and listed below,
the
incremental effects
of

th
e project are
not

cumulatively
considerable
when c
onsidered
with the potential
effects
of

past, current, and probable future projects.

The
project
does

not have
any

significant cumulative
impacts
. Impacts would
be

less than significant.

c)

Does the project have environmental effects, which

will cause s
ubstantial adverse
effects on human beings, either directly or indirectly?

Less than Significant Impact
, after Mitigation
.

All

impacts identified
in

this Draft
IS/MND are either less than significant after
implementation of identified mitigation
measures (
all listed above),
or

less than significant
without the need for

mitigation.

Of
those impacts, only the potential

impact of

PM
10 and PM

2.5 (fugitive dust) being added
to
the local atmosphere

during construction
has the pot
ential
to adversely
affect

human
b
eings, directly or indirectly.

As discussed under finding “b” above,
the project’s
implementation of
Mitigation Measure AQ
-
1: Best Management Practices
,

would
reduce the impact
to
less

than significant.

5 . Document Preparers

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5. Document
Preparers

5.1 CEQA Consultant

ESA

180 Grand A
venue
–

Suite 1050

Oakland, CA 94612

Phone 510.839.5066

Project Director

Crescentia Brown

Project Manager

Tim Sturtz

Air Quality/GHG

Chris Easter,

Director

Air Quality
/
GHG

Tim Sturtz, Principal

Madison Castelazo, Analyst

Energy

Bailey Setzler,
Planner

Noise/Vibration

Chris Sanchez, Senior Technical Associate

Hazardous Materials

Michael Burns, Environmental Scientist

Biologi
cal Resources

Sharon, Dulava, Biologist

Cultural Resources

Heidi Koenig, RPA

Tribal Consultation

Heidi Koenig, RPA

Se
nior Review / Other Topics

Crescentia Brown

Graphics

Ron Teitel

5.2 Technical Subconsultant

Fehr & Peers Transportation

2201 Broadway
–

Suite
602

Oakland, CA 9461
2 Phone

510.835.1943

Transportation

Sam Tabibnia, Senior Associate

Raven SR Bioenergy Project

A
-
1 ESA

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October 7,
2022

APPENDIX

A

Emissions Data, Assumptions and Modeling Files

Blank

This page is intentionally blank.

RAVEN
Contra Costa County, Annual
Project Characteristics -
Land Use - Project specific info
Construction Phase - Project specific information
Off-road Equipment - Project specific information
Off-road Equipment - Project specific information
Off-road Equipment - Project specific information
Off-road Equipment - Project specific information
Trips and VMT - Client provided information
Grading - Project specific information
Vehicle Trips - Project specific information
Area Coating - Project specific information

1.1 Land Usage
Land Uses
Size
Metric
Lot Acreage
Floor Surface Area
Population
General Light Industry

40.00 1000sqft

1.30 40,000.00
0 1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
5 Wind Speed (m/s)
Precipitation Freq (Days)

2.2 58

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company
Pacific Gas and Electric Company
2023
Operational Year
CO2 Intensity
(lb/MWhr)
203.98

0.033
CH4 Intensity
(lb/MWhr)

0.004
N2O Intensity
(lb/MWhr)
CalEEMod Version: CalEEMod.2020.4.0
Date: 8/11/2022 11:05 AM

Page 1 of 28 ends
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