180 Grand Avenue
Suite 1050
Oakland, CA 94612
510.839.5066
phone
510.839.5825
fax
esassoc.com
M
emorandum
date
November 30, 2022
to
Lydia
Elias
, Planner I
Lina Velasco
, Director
from
Crescentia Brown
, Project Director
Tim Sturtz
, Project Manager
subject
RESPONSE TO
COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
Background
On October 7, 2022, the City of Richmond (Lead Agency) released for public review a
Draft
Initial Study
(IS)
and Mitigated Negative Declarati
on (MND)
pursuant to the California Environmental Quality Act (CEQA) for
the proposed
Raven SR Bioenergy Project
(Project)
(SCH#
2022
01045
). The
original
public review and comment
period on the
IS/
MND
was
October
7 , 20
22 through November 7, 2022, and the C
ity extended the comment
period to November 22, 2022.
Although not required by CEQA, this document includes the comments received on the IS/MND
(see
Table 1
)
and responses to each comment.
TABLE 1
COMMENT LETTERS RECE
IVED ON THE IS/MND
Letter #
Entity
Author(s) of Comment Letter/e
-
mail
Comment Date
Agencies
–
Public / Quasi
-
Public
1 Contra Costa Environmental
Health
Nicole Soto
, REHS
November 22, 2022
2 Berkeley Lab
Vi H. Rapp, PhD
, Deputy for Building and Industrial
Applications Department
November
21, 2022
3 CalRecycle
Harprit Mattu, Environmental Scientist
November 7, 2022
4 Department of Toxic
Substances Control
Rebecca De Pont, Supervising Environmental
Planner
November 4, 2022
5 California State Senate
Nancy Skinner, State Senator District
9 October 21, 2022
6 MCE
Dawn Weisz, CEO
October 20, 2022
7 Bay Area Air Quality
Management District
Kelly Malinowski, MPA | Senior Environmental
Planner
October 19, 2022
8 Republic Services
Ken Lewis, P.E., General Manager
October 13, 2022
continued
RESPONSE TO COMMENTS Received on
the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
2 TABLE 1 (CONTINUED)
COMMENT LETTERS RECE
IVED ON THE IS/MND
Letter #
Entity
Author(s) of Comment Letter/e
-
mail
Comment Date
Organizations
/ Individual
9 Environmental Justice Groups
November 22, 2022
Communities for a
Better Environment
Connie Cho, Attorney / Tessa Wardle, Staff
Researcher
Sierra Club
Teresa Cheng, Senior Campaign Representative
Asian Pacific
Environmental Network
Faraz Rizvi, Campaign and Policy Manager
Richmond Our Power
Coalition
Katt Ramos, Managing
Director
-
Richmond Our
Power Coalition
Urban Tilth
Kiara Pereira, Just Transition Organizer / Rafael
Castro, Just Transition Organizer
Natural Resources
Defense Council
Ann Alexander, Senior Attorney
10 Shell Hydrogen
Humberto Orantes
, Acting
Commercial Head, North
America
November 7, 2022
11 Powers Engineers
James P. Hays
, Business Unit Director
November 7, 2022
12 Trails for Richmond Action
Committee (TRAC)
Bruce Beyaert
, TRAC Chair
October 27, 2022
13 Benicia Fabrication & Machine
Carmelo
Santiago
, CEO & President
October 20, 2022
14 Contra Costa Construction and
Building Trades Council
William Whitney
October 17, 2022
15 Watlow
Ashish Bhatnagar
, Chief Technology Officer
October 14, 2022
16 Iron Workers Local 378
Jason Gallia
, Business
Manager, Financial
Manager/Treasurer
October 13, 2022
17 Local Union
No
. 302
International Brotherhood of
Electrical Workers
Tom Hansen
, Business Manager, Financial
Secretary
October 13, 2022
18 Green Hydrogen Coalition
Nicholas Connell
, Policy Director
October 10, 2022
19 Not Identified
Christina Strawbridge
October 10, 2022
No “substantial revisions” that would require recirculation of the IS/MND are warranted. Specifically, (1)
no
new, avoidable significant effect is identified and mitigation measures or project revisions must be added in order to reduce the effect to insignificance, or
(2)
The lead agency determines that the proposed mitigation measures or project revisions wil
l not reduce potential effects to less than significance and new measures or revisions must be required (CEQA
Guidelines
Section
15073.5).
Although
a
m
itigation measure
(
AQ
-
1: Best Management
Practices
) is expanded
with equal or more effective measures pur
suant to Section 15074.1, recirculation of the
MND is not required.
The updated
Mitigation
Measure Monit
oring and Reporting Pro
gram (MMRP
) with the
expanded
miti
gation measure
is included as
Attachment A
to
this memo.
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
3 Comments
and Responses
Responses focus on comments that pertain to the adequacy of the analysis in the IS/MND or to other aspects pertinent to the potential effects of the proposed Project
on the environment pursuant to CEQA. Comments that
address topics beyond the purview of the IS/MND or CEQA or that state opinions about the overall merit of the proposed Project are acknowledged for the public record and will be taken into account by City
decision
-
makers.
The following pages present each comment letter
with each
individual comment bracketed
with a
numeric code,
followed by the
corresponding
response to each
individual
comment.
RESPONSE TO COMMENTS Received on
the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
6 Response
s to
Letter 1
-
Contra Costa Environmental Health
1 -
1 The comment specifies that the
project
must obtain a
permit from
Contra Costa Environmental Health
(
CCEH
)
for any well or soil boring prior to commencing drilling activities.
The project applicant
acknowled
ges this requirement and shall comply
.
1 -
2 The comment
recommend
s
that the project be served by public sewer and public water.
As specified in
Section 4.17,
Utilities and Service Systems
, of the IS/MND, the proposed project will continue to be served by
EBMUD and West County Wastewater District, which already serves the site.
1 -
3 The comment specifies application information that the project applicant/operator must obtain from C
CEH
as the Local Enforcement Agency (LEA)
relevant to the proposed project facility and operation.
The project applicant/operator will submit and obtain all required permitting applications for the proposed
Transfer/Processing Facility.
1 -
4 The comment requests clarification of the duration of tim e for
the
project’s
feedstock to remain on the
management area floor
, and
what the o
dor control measures consist of
.
The project applicant has clarified
that
all incoming organic feedstock material shall be received and stored under roof in designated area s
and
shall be processed within 48 hours
of receipt.
The project will incorporate control mechanisms to
minimize possible additional odors from its operation. Odor control would be both preventative and performance based, triggered “if objectionable odors
occur”, such as the immediate application of odor
neutralizing solutions onsite as needed. Also, as previously mentioned in Response to Comment 1 -
4, the
site shall be cleaned daily to remove loose material and litter. Boxes, bins, and containers shall be c leaned
on a regular basis. The site and receiving area shall be swept regularly. Specifically, these will include preparation, implementation, and monitoring and annual evaluation of, and adherence to, the operational Odor Prevention and Management Plan (O
PMP) detailed in project Condition No. 19.3 regarding odors and that is consistent with Contra Costa County requirements prior to commissioning and operation of the facility.
Condition No. 19.3
-
Odor Containment.
During the construction phase of the Proj
ect, the
operational Odor Prevention and Management Plan (OPMP) shall be developed and implemented upon commissioning of the renewable fuels processes, intended to become an integrated part of daily operations at the Facility and other sites, so as to prev ent any
objectionable offsite odors and effect diligent identification and remediation of any potential objectionable odors generated by the facility and associated sites. The plan shall outline equipment that is in place and procedures that facility perso nnel shall use to address odor
issues, facility wide. The OPMP shall include continuous evaluation of the overall system performance, identification of trends to provide an opportunity for improvements to the plan, and updating the odor prevention and mana
gement strategies, as necessary. This plan shall be
retained at the facility for City or any other government agency inspection upon request. The following practices shall be included in the OPMP to reduce the potential of objectionable odors from the stor
age of renewable feedstocks, operation of the Facility, and any other odor generating activity:
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
7 •
Develop operating procedures to inspect and evaluate the effectiveness of odor control equipment and operation of the wastewater treatment plant.
•
The OPMP shal
l include guidance for the proactive identification and documentation of odors through routine employee observations, routine operational inspections, and odor compliant investigations.
•
Inspections to be conducted on a semi
-
annual basis.
•
If there are fewer
than an average of five confirmed complaints per year during the first 3 years of operation, then the inspection frequency can be reduced to an annual basis.
•
If there are more than five confirmed complaints in any single year, then the application shall d
evelop additional mitigation strategies in consultation with the BAAQMD.
•
All odor complaints received by the facility shall be investigated as soon as is practical within the confines of proper safety protocols and site logistics. The goal of the investiga tion
will be to determine if an odor originates from the facility and, if so, to determine the specific source and cause of the odor, and then to remediate the odor.
•
Prepare an annual evaluation report of the overall system performance, identifying any tre
nds to provide an opportunity for improvements to the plan, and updates to the odor management and control strategies, as necessary. The report shall be provided to the City for review and approval.
Also see Response to Comment 9
-
5 regarding the related e
nvironmental impacts of odor.
1 -
5 In response to the comments statement regarding
medical waste as one of the types of organic feedstocks ,
the project applicant has clarified, as limited by project Condition No. 8.1 regarding eligible feedstocks, that the
project shall be prohibited from intentionally accepting industrial or medical waste in the eligible feedstock. The IS/MND is updated as shown below.
2.4 Technology (p. 17)
Organic feedstocks include biomass, municipal solid waste, bio -
solids, industrial
waste,
sewage,
medical waste,
or a combination of these, obtained from the existing WCCSL.
1 -
6 The comment seeks to
ensure the project is compliant with the Post Closure Maintenance Plans of the landfills.
Project Condition No. 4.5 specifically requires that the project operations shall be consistent with, and shall not conflict with, the Closure/Post Closure Maintenance Plan required by CalRecycle, the SFRWQCB, and the LEA for the existing WCCSL.
1 -
7 The c
omment addresses the treatment of h
azardous construction and demolition materials
, t
he required
management of d
ebris from construction or demolition
activity
, and states that
n
on
-
source
-
separated
waste materials must not be brought back to the contractor's
yard unless the facility has the appropriate
solid waste permit or EA Notification.
Each of these requirements are part of standard local, State and federal regulatory requirements
and project conditions
pertaining to solid waste, water
/
stormwater
resour
ces
,
and hazardous site conditions
. The project applicant acknowledges this requirement and shall comply.
________________________
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
9 Response
s to
Letter 2
–
Berkeley Lab
2 -
1 The comment is in support of the proposed Project and notes that the proposed Proje ct will help the City
further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment also opines that the proposed Project’s non -
combustion
system would reduce methan
e and short
-
lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this commen t, however, it is
noted and will be made available to City decision
-
makers as they consider the Project and whether or not
to approve it.
________________________
1001 I Street, Sacramento, CA 95814 | P.O. Box 4025, Sacramento, CA 95812 www.CalRecycle.ca.gov | (916) 322-4027
California Environmental Protection Agency
Department of
Resources Recycling and Recovery
Gavin Newsom
California Governor
Amelia Yana Garcia Gonzalez
Secretary for Environmental Protection
Rachel Machi Wagoner
CalRecycle Director
November 7, 2022
Lydia Elias, Planner I
City of Richmond Planning and Building Services Department 450 Civic Center Plaza
Richmond, CA 94804
[email protected]
Subject: SCH No. 2022100145 – Raven SR Bioenergy Project Mitigated Negative Declaration – Contra Costa County
Dear Lydia Elias,
Thank you for allowing the Department of Resources Recycling and Recovery (CalRecycle) staff to provide comments on the proposed project and for your agency’s consideration of these comments as part of the California Environmental Quality Act (CEQA) process.
Project Description
The City of Richmond Planning Department, acting as Lead Agency, has prepared and circulated a Notice of Completion (NOC) of a Draft Initial Study/Mitigated Negative Declaration (Draft IS/MND) in order to comply with CEQA and to provide information to, and solicit consultation with, Responsible Agencies in the approval of the proposed project.
The proposed Raven SR Project is located at 1 Parr Boulevard, Richmond, California. The location is within the West Contra Costa Sanitary Landfill (WCCSL) facility located in the northwest area of the City of Richmond, in Contra Costa County, California. For purpose of this environmental document, the project would occur within approximately 2.5 acres of the existing Republic Services Bulk Materials Processing Center (BMPC) within “Area A” of the WCCSL. The property is located approximately
0.25 miles west of Parr Boulevard (approximately 0.25 miles west from Richmond Parkway) via an unpaved access road. The northern boundary of the project site is the City of Richmond / Contra Costa County jurisdiction line; the project site is located wholly within the City of Richmond, except for use of an existing access/egress road located within the County. The project site is located within Assessor’s Parcel Number (APN) 408-140-009.
The proposed project would add a bioenergy system at the site. The non-combustion process would convert blended green waste and food waste, obtained from the existing
1001 I Street, Sacramento, CA 95814 | P.O. Box 4025, Sacramento, CA 95812 www.CalRecycle.ca.gov | (916) 322-4027
BMPC operation adjacent to the project site, into renewable, transportation grade hydrogen that would be exported offsite for various renewable energy products. No long-term hydrogen storage would occur onsite. The project would involve the erection of a modular structure and industrial canopy.
The conversion method uses a non-combustion (i.e., anoxic, indirect external heating), low pressure process. The only chemicals added would be carbon dioxide (CO2), calcium carbonate (limestone), and steam (i.e., water heated into a vapor state). No hazardous materials would be used in the process. The conversion occurs in sealed rotating drums that drop out solid matter from the green and food waste feedstock, which would consist largely of biocarbon, along with dirt, glass, grit, rocks, and inorganic salts. The biocarbon materials are inert to the process (i.e., not gasified) and drop out in the first stage. The process also drops out excess water. Neither the biocarbon nor the water would be considered a hazardous material.
Prior to being received at the site, the material will be ground and screened at the WCCSL compost site. Maximum daily tonnage is estimated to be 99.9 wet tons per day of blended green waste and food waste. The Raven SR system may run up to 24 hours per day, seven days per week.
The operation would involve up to approximately 12 hydrogen tube trucks and up to approximately 15 biocarbon trucks (total 37 trucks) per week, each with an average trip of 40 miles after leaving the site. Considering this with other trucks and employees coming to and leaving the project site daily, the project is estimated to generate about 130 vehicle trips on a typical weekday.
Comments
CalRecycle staff’s comments on the proposed project are listed below. Where a specific location in the document is noted for the comment, please ensure the comment is addressed throughout all sections of the Draft IS/MND, in addition to the specific location noted.
Comments for the Draft IS/MND are summarized below:
1. Project Description, Daily Quantities and Operations, PDF Page 22 – “The Raven facility would receive up to 99.9 wet tons per day of blended green waste and food waste feedstock…” Receipt of this volume of solid waste for further processing will require a Transfer/Processing Facility Solid Waste Facility Permit. As a reminder, per PRC 40191 a solid waste facility cannot receive hazardous, radioactive, or medical wastes.
2. Project Description, Odor Control, PDF Page 23 – “Nuisance odor from Raven is unlikely since feedstock material would only be on the feedstock management area floor for relatively short periods of time.” The applicant should clarify how long the material will be stored in the storage bunkers or other designated material storage areas prior to being placed in the Raven SR’s Reformation Technology system? Given the putrescible nature of the incoming feedstock, what methods will the applicant utilize to control or prevent the propagation, 1001 I Street, Sacramento, CA 95814 | P.O. Box 4025, Sacramento, CA 95812 www.CalRecycle.ca.gov | (916) 322-4027
harborage and attraction of flies, rodents, or other vectors, and animals, and to minimize bird attraction.? Per Title 14 CCR Section 17410.1(a)(2) “facilities shall remove solid waste accepted at the site within 48 hours from the time of receipt.”
Solid Waste Regulatory Oversight
Contra Costa Health Services is the Local Enforcement Agency (LEA) for Contra Costa County and responsible for providing regulatory oversight of solid waste handling activities, including inspections. Please contact Tim Kraus, the LEA, at 925.608.5549 to discuss the regulatory requirements for the proposed project.
Conclusion
CalRecycle staff thanks the Lead Agency for the opportunity to review and comment on the environmental document and hopes that this comment letter will be useful to the Lead Agency preparing the MND and in carrying out their responsibilities in the CEQA process.
CalRecycle staff requests copies of any subsequent environmental documents, copies of public notices and any Notices of Determination for this proposed project.
If the environmental document is adopted during a public hearing, CalRecycle staff requests 10 days advance notice of this hearing. If the document is adopted without a public hearing, CalRecycle staff requests 10 days advance notification of the date of the adoption and proposed project approval by the decision making body.
If you have any questions regarding these comments, please contact me at 916.341.6119 or by e-mail at [email protected].
Sincerely,
Harprit Mattu, Environmental Scientist
Permitting & Assistance Branch – North
Waste Permitting, Compliance & Mitigation Division
CalRecycle
cc: Eric Kiruja, Supervisor
Permitting & Assistance Branch – North
Tim Kraus, REHS, LEA
Contra Costa Health Services
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
13 Response
s to
Letter 3
-
CalRecycle
3 -
1 The comment states that per PRC
40191 and given the proposed daily volume of a solid waste the proposed facility could receive, receipt of hazardous, radioactive, or medical wastes is not permitted.
See
Response to Comment 1
-
5 above regarding
eligible feedstock.
3 -
2 The comment requests clarification of how long the feedstock material will be stored in the storage
bunkers or other designated material storage areas prior to being placed in the Raven SR’s Reformation Technology system
.
See
Response
s
to Comment
s
1 -
4 and
9 -
5 regarding potential odor
control measures
and
impacts.
3 -
3 The comment specifies contact information
for the project applicant and City to discuss t
he regulatory
requirements for the proposed project.
The project a
pplicant acknowledges this requirement and shall
comply.
3 -
4 The comment requests copies of any subsequent environmental documents, copies of public notices and any Notices of Determination for this proposed project, and specifies noticing timeframes. The
Lead
Agency will conduct all CEQA
-
related noticing and distribution of associated documents pursuant to CEQA Guidelines for an MND and City standards. Access to all project notices, documents and City actions on the project are available to the public at
https://www.ci.richmond.ca.us/4365/Raven
-
SR
-
Bioenergy
-
Project
.
Printed on Recycled Paper
November 4, 2022
Lydia Elias, Planner 1
(Sent electronically to [email protected])
City of Richmond Planning Division
450 Civic Center Plaza-2nd Floor
Richmond, CA 94804
Phone: (510) 620-5558
Subject: Raven SR Bioenergy Project Draft Initial Study/Mitigated Negative Declaration (SCH 2022100145)
Dear Ms. Elias,
Thank you for the opportunity to review and comment on the draft Mitigated Negative Declaration for the Raven SR Bioenergy Project (SCH 2022100145). The Department of Toxic Substances Control (DTSC) has identified that your project may affect, and in turn be affected by, the West County Landfill Inc. Post-Closure Permit project (CAD041844002). The Post-Closure Project area is surrounded by the Class II portion of the West Contra Costa County Sanitary Landfill. Initial wastes received included demolition debris, municipal solid waste, and industrial waste. In later years, the site was designated to receive hazardous waste. The Project area has operated a corrective action groundwater monitoring program for the Hazardous Waste Management Facility (HWMF) since March 1996. This program consists of measuring leachate and groundwater levels to evaluate inward hydraulic gradients across the HWMF and E‐22R slurry walls, and the semiannual sampling and analysis of groundwater from 33 wells to monitor groundwater quality in the surficial, shallow, and medium water‐bearing zones (WBZs) beneath the Project area.
Additional information about the permit and groundwater contamination at the site is available here.
DTSC has the following comments on the draft Mitigated Negative Declaration and Initial Study for the Raven SR Bioenergy Project:
1. The proposed Raven SR Bioenergy Project’s construction may destabilize the contamination at the West County Landfill Inc. Post-Closure Permit beyond its existing containment system. This may result in, the potential contamination of additional groundwater.
2. The groundwater monitoring system funnels leachate to a treatment area near the proposed Raven SR Bioenergy Project that may be damaged during construction.
3. DTSC believes that City of Richmond must address these concerns to avoid any significant impacts under CEQA that may occur and ensure that the West County Landfill Inc. Post-Closure care is operational during and after construction of the SR Bioenergy Project.
Thank you for your assistance in protecting California’s people and environment from the harmful effects of toxic substances. If you have any questions or would like any clarification on DTSC’s comments, please contact Rebecca De Pont, Supervising Environmental Planner at (916) 255-3638 or [email protected].
Sincerely,
Rebecca De Pont
Supervising Environmental Planner, Permitting Division
Department of Toxic Substances Control
RESPONSE TO COMMENTS Received on
the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
16 Response
s to
Letter 4
-
Department of Toxic Substances Control
4 -
1 The comment claims that the
project’
s
construction may destabilize the contamination at the West County Landfill Inc. Post
-
Closure Permit beyond its existing containment system,
and that
the existing
groundwater monitoring system may be damaged during construction, resulting in potential
con
tamination of additional groundwater and
significant impacts under CEQA.
The analysis understands
that the existing systems directs leachate from the landfill to the treatment area located near the proposed project site (IS/MND, Section 2.2
Surrounding Use
s and Conditions
). The
Geotechnical Investigation
report prepared for the proposed project (Rockridge, 2022)
involved investigation to depths of
approximately 150 feet on and around the site. The investigation confirmed that the maximum depth of disturbanc
e required for the project, specifically the foundation pads necessary to support the proposed project (up to approximately 30 to 33 feet) would not disturb existing groundwater or monitoring stations of leachate flows or migration. Thus the proposed proj ect would not
destabilize the existing
containment system or groundwater condition during construction. Further, as indicated in Response
to Comment 1
-
6,
the project shall be compliant with the Post Closure Maintenance Plans of the landfills, in accordance
with project Condition No. 4.5, the Closure/Post Closure Maintenance Plan required by CalRecycle, the San Francisco Regional Water Quality Control Board (SFRWQCB), and the LEA for the existing WCCSL.
________________________
October 21, 2022
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
RE: Support for Raven SR’s Conditional Use Permit for Clean Hydrogen Facility
Dear Ms. Elias,
I am writing in support of Raven SR’s Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a clean hydrogen/bioenergy facility at Republic Service’s West Contra Costa County Sanitary Landfill.
As the author of statewide legislation to jumpstart California’s use of hydrogen made from renewable sources, I am pleased that Raven is proposing to showcase a new clean hydrogen production technology in Richmond, using a waste-to-hydrogen process. In addition, Raven’s innovative project will help the city divert more waste from landfills to meet California’s goal of reducing organic waste disposal by 75% from 2014 levels by 2025.
I am also pleased that Raven has signed a Project Labor Agreement with the Contra Costa Building & Construction Trades Council and the I.B.E.W. Local #1245.
California has taken a leadership role in launching a clean hydrogen economy, and Richmond has the opportunity with Raven to advance clean fuels production and emissions reductions, and help our fight against climate change.
As such, I respectfully urge you approve Raven SR’s CUP application and the CEQA MND so they may begin construction this year and start production in early 2023.
Sincerely,
Nancy Skinner
State Senator, District 9
RESPONSE TO COMMENTS Received on
the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
18 Response
s to
Letter 5
-
California State Senate
5 -
1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The commen
t also opines that the proposed Project’s non
-
combustion
system would reduce methane and short
-
lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis con
tained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision
-
makers as they consider the Project and whether or not
to approve it.
________________________
CONCORD OFFICE: 2300 Clayton Road, Suite 1150, Concord, CA 94520 SAN RAFAEL OFFICE: 1125 Tamalpais Avenue, San Rafael, CA 94901 mceCleanEnergy.org
Lydia Elias October 20, 2022
City of Richmond’s Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Ms. Elias,
Over the years, we have seen the incredible projects that have come to fruition in the City of Richmond. Keeping in tradition with this innovative, entrepreneurial spirit, we are pleased to watch the development of the Raven SR bioenergy facility at Republic Service’s West Contra Costa County Sanitary Landfill.
MCE’s mission is to confront the climate crisis by eliminating fossil fuel greenhouse gas emissions, producing renewable energy, and creating equitable community benefits. We understand the incredible impact that clean, green hydrogen offers California as we transition away from fossil fuels and decarbonize our economy. Raven SR’s proposed hydrogen production is expected to not only produce a consistent high-value multi-use hydrogen supply, but also reduce our community waste streams without incineration. This would help us meet our organic waste diversion goals (Senate Bill 1383) while minimizing existing methane and greenhouse gas emissions, and would avoid contributions to localized criteria air pollutants. We understand Raven SR has a PLA with the Contra Costa Building & Construction Trades Council and IBEW Local 1245, helping to ensure the quality of jobs produced at this site.
We are excited about this proposed technology, and the engagement with strong partners. In addition, we’re encouraged to see the project take root in Richmond as its first location.
In October, we attended an Alliance for Renewable Clean Hydrogen Energy Systems (ARCHES) event to discuss the possibilities that hydrogen offers California and how stakeholders must coordinate to obtain funds from the Department of Energy to create a regional Hydrogen Hub. It is likely that there could soon be strong demand for a limited supply of commercially available hydrogen. Raven’s production is poised to take advantage of this growing demand to meet decarbonization goals. Using hydrogen for transportation fuel is especially important to displace the diesel emissions of long-haul vehicles which disproportionally pollute lower-income and communities of color adjacent to transportation corridors.
Thank you for your consideration. We are supportive of these efforts and look forward to this project becoming a key part of California’s Northern California Hydrogen Hub in the future.
Sincerely,
Dawn Weisz, CEO
RESPONSE TO COMMENTS Received on
the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
20 Response
s to
Letter 6
-
MCE
6 -
1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (Californ
ia’s SB 1383). The comment also opines that the proposed Project’s non -
combustion
system would reduce methane and short
-
lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the ade quacy of the analysis
contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision
-
makers as they consider the Project and whether or not
to approve it.
________
________________
From: Kelly Malinowski
To: Lydia Elias
Cc: Samuel Garcia; Lily MacIver; Wendy Goodfriend; Alison Kirk Subject: Raven SR Bioenergy Project
Date: Wednesday, October 19, 2022 2:44:33 PM
You don't often get email from [email protected]. Learn why this is important This email originated from outside of the City's email system. Do not open links or attachments from untrusted sources.
Hi Lydia,
We have reviewed the IS/MND for the Raven SR Bioenergy Project. We will not be sending a formal CEQA comment letter, but we did want to provide some additional dust mitigation measures that you could consider for the Construction Dust, related to AQ-1 Best Management Practices, below:
BMP #6: All excavation, grading, and/or demolition activities shall be suspended when average wind speeds exceed 20 mph.
BMP #7: All trucks and equipment, including their tires, shall be washed off prior to leaving the site.
BMP #8: Unpaved roads providing access to sites located 100 feet or further from a paved road shall be treated with a 6- to 12-inch layer of compacted layer of wood chips, mulch, or gravel.
Additional BMP: Limit the simultaneous occurrence of excavation, grading, and ground- disturbing construction activities.
Additional BMP: Install wind breaks (e.g., trees, fences) on the windward side(s) of actively disturbed areas of construction. Wind breaks should have at maximum 50 percent air porosity.
Additional BMP: Plant vegetative ground cover (e.g., fast-germinating native grass seed) in disturbed areas as soon as possible and watered appropriately until vegetation is established Additional BMP: Install sandbags or other erosion control measures to prevent silt runoff to public roadways from sites with a slope greater than one percent.
Additional BMP: Minimize the amount of excavated material or waste materials stored at the site.
Additional BMP: Hydroseed or apply non-toxic soil stabilizers to construction areas, including previously graded areas, that are inactive for at least 10 calendar days.
Require zero visible fugitive dust and use fence line air monitoring to demonstrate compliance with this requirement.
Set requirements for when dust generating operations have to be shut down due to dust crossing the property boundary or if dust is contained within the property boundary but not controlled after a specified number of minutes.
Prohibiting grading on days when a Spare the Air is in effect (https://www.sparetheair.org/) Prohibiting grading on days with an Air Quality Index forecast of greater than 100 for particulates for the project area
Please let us know if you have any questions, or would like to discuss! Best,
Kelly
Kelly Malinowski, MPA | Senior Environmental Planner
Planning and Climate Protection Division
Bay Area Air Quality Management District
Office: 415-749-8673
Pronouns: she/her
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
23 Response
s to
Letter 7
-
Bay Area Air Quality Management District
7 -
1 The comment
provides
additional dust mitigation measures for consideration, which the City and the
project applicant
has elected to in
corporate in to Mitigatio
n Measure AQ
-
1 , as
shown below
.
Section 4.3, Air Quality, Criterion “b” (p. 39):
Mitigation Measures
AQ
-
1: Best Management Practices.
All subsequent projects, regardless of size, shall implement the following best management practices to reduce construction impacts, particularly fugitive dust, to a less -
than
-
significant
level:
All exposed surfaces (e.g., parking areas, staging areas, so il piles, graded areas, and
unpaved access roads) shall be watered two times per day, except when not required for dust control.
All haul trucks transporting soil, sand, or other loose material off -
site shall be covered.
All visible mud or dirt track
-
out
onto adjacent public roads shall be removed using wet
power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.
All vehicle speeds on unpaved roads shall be limited to 15 mph.
All roadways, driveways, and sidewalks
to be paved shall be completed as soon as
possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.
Idling times shall be minimized either by shutting equipment off when not in use or reducing the ma
ximum idling time to 5 minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations [CCR]).
Clear signage shall be provided for construction workers at all access points.
All construction
equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation.
Post a publicly visible sign wit
h the telephone number and person to contact at the Lead Agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s phone number shall also be visible to ensure compliance with applicable regu
lations.
BMP #6: All excavation, grading, and/or demolition activities shall be suspended when
average wind speeds exceed 20
mph.
BMP #7: All trucks and equipment, including their tires, shall be washed off prior to leaving the site.
BMP #8: Unpaved roads
providing access to sites located 100 feet or further from a paved road shall be treated with a 6
-
to 12
-
inch layer of compacted layer of wood chips,
mulch, or gravel.
RESPONSE TO COMMENTS Received on
the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
24
Additional BMP: Limit the simultaneous occurrence of excavation, g rading, and ground
-
di
sturbing
construction activities.
Additional BMP: Install wind breaks (e.g., trees, fences) on the windward side(s) of actively disturbed areas of construction. Wind breaks should have at maximum 50 percent air porosity.
Additional BMP: Plant vegetative g
round cover (e.g., fast
-
germinating native grass seed)
in disturbed areas as soon as possible and watered appropriately until vegetation is
established.
Additional BMP: Install sandbags or other erosion control measures to prevent silt runoff to public roa
dways from sites
with a slope greater than one
percent.
Additional BMP: Minimize the amount of excavated material or waste materials stored at the site.
Additional BMP: Hydroseed or apply non
-
toxic soil stabilizers to construction areas,
including previous
ly graded areas, that are inactive for at least 10 calendar days.
Require zero visible fugitive dust and use fence line air monitoring to demonstrate compliance with this requirement.
Set requirements for when dust generating operations have to be shut d own due to dust
crossing the property boundary or if dust is contained within the property boundary but not controlled after a specified number of minutes.
Prohibiting grading on days when a Spare the Air is in effect (
https://www.sparetheair.org/
) Prohibiting grading on days with an Air Quality Index forecast of greater than 100 for
particulates for the project area
.
These modifications do not change the adequacy of the analysis or impacts identified in the IS/MND, and no further analysis is warranted, pursuant to the findings enumerated in Section 1 of this memo.
_________________
_______
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
27 Response
s to
Letter 8
-
Republic Services
8 -
1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste d isposal for target
year 2025 (California’s SB 1383). The comment also opines that the proposed Project’s non -
combustion
system would reduce methane and short
-
lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission
. The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision
-
makers as they consider the Project and wh
ether or not
to approve it.
________________________
November 22, 2022
Lydia Elias, Planner 1City of Richmond Planning Division450 Civic Center Plaza—2nd FloorRichmond, CA 94804510-620-5558 Submitted electronically via [email protected] Re: Comment on Draft Initial Study/Mitigated Negative Declaration (IS/MND) for RavenSR Bioenergy Project (PLN21-282) Dear Ms. Elias,
Please accept these comments from the undersigned organizations concerning the DraftInitial Study and Mitigated Negative Declaration (IS/MND) for the Raven SR Bioenergy Project,Project No. PLN21-282 (Project). We are thankful for the opportunity to share our concernsduring this extended comment period. For the reasons described below, we do not believe theanalysis supporting the IS/MND is sufficient, and therefore request that you produce a fullEnvironmental Impact Report (EIR).
Raven SR Inc. (Applicant) proposes the construction of a novel technology for creatinghydrogen that has no real precedent, making the need to do a thorough environmental impactanalysis even more important. We would like to work collaboratively with the City PlanningDivision to ensure that the already overburdened community in North Richmond does not faceany unexpected cumulative impacts from this new project. While the project is being touted asgreen, such claims should not influence the need for thorough in-depth analysis of Projectimpacts under the California Environmental Quality Act (CEQA). We believe the City should beasking many more questions, and providing the public with transparent answers about the scopeof the Project; and answering them in a full EIR.
I. Outstanding air permit items must be resolved and disclosed in order to properlyassess the Project’s potential environmental impact On May 11, 2022, the Bay Area Air Quality Management District (BAAQMD)determined that the Air Permit Application to construct the Raven SR Bioenergy Project(Application #31700) was incomplete. BAAQMD, as a responsible agency, needs completeinformation to weigh in on the review; and accordingly, the City needs such information to fullyevaluate the Project’s air quality impacts. The Air Permit Application remains a live application under review and the City’s IS/MND does not include a disclosure or assessment of essentialinformation requested by BAAQMD in its letter.
Specifically, BAAQMD flagged a staggering 57 missing or incomplete items that stillneed to be disclosed and analyzed, including important information needed to assess communityhealth impacts—such as missing Health Risk Assessment (HRA) forms for specific emissionsources, missed potential sources of emissions (i.e. lime stored onsite and biochar if storedonsite), confirmation that formaldehyde would not be released from the bioengines, and clearenforceable limits on flare use. Until and unless all 57 concerns are addressed, the City shouldnot move forward with a MND. Full information regarding air pollutant loads and impact is allthe more important because the Project would be located in an already overburdened community.
II. Exceedances of chronic and acute thresholds for toxic chemicals trigger the need fora Health Risk Assessment (HRA) Based on the current version of the BAAQMD Air Permit Application, emissions fromthe biogas engines powered by landfill gas (LFG) exceed chronic and acute thresholds thattrigger the need for a Health Risk Assessment (HRA) under Rule 2-5 for eight different toxicchemicals. Acute HRA limits are exceeded for formaldehyde, while chronic limits are exceededfor 1,3-butadiene, acetaldehyde, acrolein, ammonia, benzene, diesel particulate matter (PM),formaldehyde, and naphthalene.
We also request that the City be conservative in determining the scope of an HRA forthese chemicals. According to the Initial Study, an HRA was not conducted for the impacts ofdiesel PM from construction because sensitive receptors are not within 1,000 ft of the site anddue to “trigger levels not applying to the project”. However, there are sensitive receptors(residences) within 0.75 miles, an elementary school within 1.1 mile and a health clinic within1.2 miles, which is still close enough to warrant full analysis. In reviewing Rule 2-5, it is unclearwhy HRA trigger levels would not apply to this project. Further, while emissions of criteriapollutants NOx and VOCs are estimated to be below the BAAQMD threshold for significantimpact, they are extraordinarily close to the threshold. NOx emissions are estimated at 9.05 tonsper year (tpy) and VOCs at 9.19 tpy, both with a threshold of 10 tpy.
III. Cumulative pollution impacts should be considered more fully Increased emissions from this project adds to the cumulative pollution impacts of themany projects currently in operation and primed for development in North Richmond andadjacent Richmond areas—which is one of the most pollution burdened areas of the state. 1 Full
1 OEHHA, CalEnviroScreen 4.0. Available at https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40. and robust cumulative impacts analysis, as required under CEQA, is thus particularly criticalhere.
Two cumulative impacts stand out with particular importance. First, there will beincreased truck traffic as a result of this project, which is expected to add 100 trips per day ofheavy duty trucks. The Initial Study minimizes the importance of this increase as ‘notsignificant’ because the area already has high truck volumes. However, this reasoning is exactlybackwards: the existing high truck volumespointsto the needto carefully assess potentialcumulative impacts from even more heavy duty trucks. This is particularly so given, as describedabove, how close NOx and VOC pollutant emissions will potentially come to the BAAQMDthreshold for significant impacts.
Second, there are two other hydrogen-related projects being evaluated by and/or withinthe City that are not recognized in this IS/MND:
2,3
Chevron has proposed to expand itsproduction of hydrogen for retail sale and Chevron has also proposed an almost certainly relatedapplication to construct a hydrogen fueling station. Chevron’s production expansion will result inincreased air pollutant emissions; and it is very possible, in the absence of information to thecontrary, that the hydrogen produced at the Project would be marketed via,inter alia, theproposed filling station. Yet these two other projects were not even mentioned in the MND.
All three projects should have been addressed in the IS/MND for a cumulative impactsanalysis. Pollution increases from the Chevron production project should have been consideredcumulatively with pollutant emissions from this Project. To the extent it remains unclear whetherthe hydrogen produced by the Raven project will be marketed at the proposed Chevron fillingstation, the City should have asked that question of Chevron and Raven, and adjusted its analysisaccordingly - possibly even considering the two projects in one EIR, but at the very leastconsidering their impacts cumulatively. Richmond is overall being driven toward a hydrogeneconomy that has the potential to be highly polluting, risking the health and safety of residents 4,5
;and it behooved the City to consider that direction as a whole before simply signing off on onlyone corner of it. 5 Raven SR, Renewable fuels company Raven SR announcesstrategic investment from Chevron, ITOCHU, HyzonMotors and Ascent Hydrogen Fund. Available athttps://ravensr.com/investment-from-chevron-itochu-hyzon-motors-and-ascent-hydrogen-fund/. 4 Chevron U.S.A. Inc., Chevron, Iwatani Announce Agreement to Build 30 Hydrogen Fueling Stations in California.Available athttps://www.chevron.com/newsroom/2022/q1/chevron-iwatani-announce-agreement-to-build-30-hydrogen-fueling-stations-in-california. 3 Raven SR, Renewable fuels company Raven SR announcesstrategic investment from Chevron, ITOCHU, HyzonMotors and Ascent Hydrogen Fund. Available athttps://ravensr.com/investment-from-chevron-itochu-hyzon-motors-and-ascent-hydrogen-fund/. 2 Chevron U.S.A. Inc., Chevron, Iwatani Announce Agreement to Build 30 Hydrogen Fueling Stations in California.Available athttps://www.chevron.com/newsroom/2022/q1/chevron-iwatani-announce-agreement-to-build-30-hydrogen-fueling-stations-in-california.
IV. The biogas engines using landfill gas involves combustion, and the air pollutionimpacts of this combustion should be analyzed in more detail Landfill gas is primarily methane and CO2
, but italso contains many toxic chemicalsfrom the landfill contents. Based on past studies, biogas engines have potential to emit multipletoxic chemicals that are associated with the landfill contents. 6 The Project includes the use ofbiogas engines to power the hydrogen extraction and purification process, and results inemissions of both criteria air pollutants and toxic air contaminants. While the Initial Studymentions the existing biogas engines already onsite and a lower emission profile from the newengines, it does not appear that the likely increased volume of landfill gas processed by thebiogas engines was taken into account. A thorough multi-criteria lifecycle assessment isimportant to understanding the relevant air quality impact of the new biogas engines.
V. The odor mitigation plan is inadequate
The proposed odor mitigation measures are insufficient. The Initial Study states that themethod of odor control would be to employ “control measures similar as those currentlyemployed by WCCSL [West Contra Costa Sanitary Landfill].” However, those measures havealready proven insufficient, as local residents are currently complaining of odors from WCCSL.
Moreover, possible solutions are framed as a form of deferred mitigation, a proposal toaddress an odor problem only if it arises later rather than a plan to address it from the start.CEQA requires concrete and immediate mitigation plans, not promises to develop mitigation inthe future.
And it is fairly clear that odor is going to be a problem. The site of this facility thatwould have piles of putrescible green waste is approximately 158 feet closer to residences thanthe existing composting facility. The IS claims that “nuisance odor from Raven is unlikely sincefeedstock material would only be on the feedstock management area floor for relatively shortperiods of time.” However, the air permit lists the duration of feedstock onsite as 12 hours. Sincethe facility is running 24/7, it seems unavoidable that there would be compost and green wasteonsite at all times.
VII. Potential to convert and create other fuels
Finally, the Raven SR patented technology covers other fuel products that have greaterclimate implications than hydrogen. We question whether the intended use of the facility is fully 6 Konkol et al, 2022.Biogas Pollution and Mineral Deposits Formed on the Elements of Landfill GasEngines. Materials.Available athttps://www.ncbi.nlm.nih.gov/pmc/articles/PMC8999940/ disclosed, and whether there is any potential that the facility could be used down the line to makeliquid fuels such as alternative aviation fuel. The Initial Study should have explored thatpossibility.
VI. Conclusion
We appreciate the opportunity to comment on this project and are especially grateful forthe extension of the comment period. We hope to work collaboratively with the City to ensurethe full consideration of impacts to the community of North Richmond.
Sincerely,
Connie Cho, CBE AttorneyTessa Wardle, CBE Staff ResearcherCommunities for a Better Environment Teresa Cheng, Senior Campaign RepresentativeSierra Club Faraz Rizvi, Campaign and Policy ManagerAsian Pacific Environmental Network Katt Ramos, Managing DirectorRichmond Our Power Coalition Kiara Pereira, Just Transition OrganizerRafael Castro, Just Transition OrganizerUrban Tilth Ann Alexander, Senior AttorneyNatural Resources Defense Council
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
33 Response
s to
Letter 9
-
Environmental Justice Groups
9 -
1 The comment asserts that the o
utstanding air permit items
for the
proposed
project
must be resolved
and
disclosed in order to properly
assess the
p
roject’s potential environmental impact
.
The CEQA and
permitting processes are separat
e and distinct. T
he pendency of the air permit should not impact the
CEQA process
, rather the
air permit will be constraine
d by CEQA
.
The project applicant is working closely with the BAAQMD to
acquire an air permit for the p
roject. The
information provided in the IS/MND reflects the best air emissions data available from the applicant at the time of publication for determini
ng significance of the project. The
final
IS/MND include updates to
the emission totals that are associated with updates to the permit application materials due to the applicant’s discussions with the air district. The emissions presented in the IS/MND are
not anticipated to
undergo any considerable changes prior to the issuance of an air permit. As such, the IS/MND is reflective of the best available information for assessing potential impacts to the atmospheric environment under BAAQMD guidance.
No furthe
r analysis is warranted
.
9 -
2 The comment asserts that exceedances of chronic and acute thresholds for toxic chemicals trigger the need for a Health Risk Assessment (HRA).
The emissions of toxic air contaminants do exceed trigger thresholds for an HRA unde
r air permitting rules and a HRA will be produced as part of the air permitting process.
For permitting, a
HRA is triggered by the project exceeding emission limits, irrespective of its location and proximity to sensitive receptors. However, under CEQA, we
use HRA as a tool to answer
checklist question 3
-
whether the project would expose sensitive receptors to substantial pollutant concentrations. The BAAQMD recommends methodology and thresholds that can be used in this CEQA
analysis. Since the checklist question specifically talks about exposure of sensitive receptors (and not emissions levels), using the BAAQMD's recommended zone of influence of 1000 feet is a reasonable way to screen for impacts and determine
a less than si
gnificant
impact if there are no receptors within that
distance
For the proposed project and u
nder the BAAQMD CEQA guidance, an HRA must be conducted for sensitive receptors identified within 1,000 feet of the project facility property line. However, no se nsitive
receptors
exist
within that buffer distance, nor within a distance of 2,000 feet of the property line. Given that the project does not have sensitive receptors within the distances indicated by the BAAQMD, an HRA was not developed as part with e CE
QA IS/MND, but an HRA will be produced as part of the air permitting process.
No further analysis is warranted
.
9 -
3 The comment asserts that cumulative pollution impacts should be considered more fully in the IS/MND analysis.
Similar to
Response to Commen
t 9
-
2 regarding
developing a HRA
,
the BAAQMD guidance
indicates that a cumulative health risk analysis should be conducted for all sources within 1,000 feet of the project property line, but no the BAAQMD screening tool indicates that no additional sources
exists
within that distance. Additionally, no sensitive receptors are within 1,000 feet of the project property line, thereby negating the need for an HRA. A cumulative risk analysis is not provided as part of the IS/MND.
No further analysis is warranted
.
9 -
4 The comment claims that the biogas engi
nes using landfill gas involve
combustion, and the air pollution
impacts of this combustion should be analyzed in more detail than presented in the IS/MND analysis.
The
air permitting process being conducted by
the applicant to acquire a permit from the BAAQMD will
RESPONSE TO COMMENTS Received on
the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
34 provided the additional detail that is being requested. As noted in Response to Comment
9 -
1, the most up
to date estimates of air emissions from operation of the facility have been provided in the IS/M ND and
compared against the BAAQMD’s thresholds for significance . No further analysis is warranted
.
9 -
5 The comment opines that the odor mitigation plan is inadequate due to the efficacy of the existing WCCSL odor control measures, the
operational
storage
characteristics of the feedstock materials. The
comment also cites that the project operation would be
approximately
158 feet closer
than the existing
WCCLS
to existing residents
; that distance is
currently
1,750 feet
from the WCCSL.
The IS/MND st
ates that “nuisance odor from Raven is unlikely since feedstock material would only be on the feedstock management area floor for relatively short
periods of time.” The
project
applicant and
operator
, in coordination with City and BAAQMD staff, have furthe r detailed the
draft
conditions of
approval
to fully address Raven operations
specifically
.
As stated in Response to Comment
1 -
4 ,
all
incoming organic feedstock material shall be received and stored under roof in designated areas and shall be processed wit
hin 48 hours of receipt
.
Response to Comment 1
-
4 f
urther detail
s the requirements of
Condition No. 19.3 that is consistent with Contra Costa County requirements prior to commissioning and operation of the facility.
As with all
c
onditions
of approval, the p
roposed project’s adherence is presumed
as part of the project, even though full text of conditions may not be stated in the environmental document.
The environmental impact under CEQA remains less than significant according to the applicable CEQA significance criteria, as analyzed
in IS/MND Section 4.3,
Air Quality
(criterion “d”)
, which assumes
adherence to Condition
19.3 . No mitigation measure is re
quired.
For clarity
and update
, the following
update is made to the IS/MND:
Section 4.3, Air Quality, Criterion “d” (p.
41 ):
Nuisance odor from Raven is unlikely since
feedstock material would only be on the feedstock management area floor for relatively
short
periods of time
; all incoming organic feedstock material shall be received and stored under roof in designated areas and shall be processed within 48 hours of receipt , pursuant to project
Condition No. 19.3
,
which is incorporated as part of the prop
osed project
…
…
The project
may
will
incorporate control measures similar to those current employed by WCCSL,
but expanded and tailored per project Condition No. 19.3, such as ensuring the
input of feedstock into the system within a designated period of ti me from receiving it from
WCCSL’s onsite organic material processing facility to prevent potential odor buildup; routine cleaning of floors, walls, and equipment; use of odor suppressants as deemed necessary.
Also pursuant to Condition No. 19.3, o
O
dor cont
rol would be added to the
management area if objectionable odors occur. The Raven facility could
would
also store
topical treatment solutions (non
-
toxic and biodegradable) onsite, which would be applied to neutralize odors if an immediate need arises.
___
_____________________
November 7
th, 2022
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Lydia,
I am writing in support of Raven SR’s Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service’s West Contra Costa County Sanitary Landfill.
Raven’s Waste to Renewable Hydrogen Project will provide important progress enabled by innovations in California policy and the hydrogen industry. Raven SR is providing the City of Richmond the opportunity to showcase a new hydrogen production technology that will revolutionize waste-to-hydrogen production. The focus in California policy on renewable content and carbon intensity enables the diversity of hydrogen production methods to make the best use of renewable feedstocks in California. Innovations improving the gaseous hydrogen approach by companies like Shell Hydrogen – including high-pressure high-capacity tube trailers that triple capacity while halving cost and refueling stations that enable up to 95% usable fraction – enable a market for distributed hydrogen production with significant benefits for the safety, environment, and economy in California. Please consider:
• New hydrogen production facilities can be built by a wide range of innovative companies, deploying technologies and production pathways that make the very best use of renewable resources in California.
• New hydrogen production facilities can be built in California, close to market, making use of local renewable resources and creating local employment and economic development.
• Hydrogen supply for mobility can become reliable and resilient most quickly, with rapid increase in the number and diversity of production facilities and in the aggregate hydrogen storage capacity in the system.
• Distributed gaseous hydrogen supply for mobility can be safer, lower cost and lower carbon intensity than centralized liquid hydrogen by avoiding the capital cost and energy requirements for liquefaction; minimizing the road transport distances,
costs, and emissions; and enabling storage without product loss to boil-off.
In closing, Shell is committed to a low carbon energy future, with more and cleaner energy, and is working to become a net-zero energy business by 2050 or sooner in step with society. Shell already offers customers a range of decarbonized renewable power, fuels, and energy products, including hydrogen dispensed as a transportation fuel. Thank you for your consideration and I respectfully ask that you approve Raven SR’s CUP application and the CEQA MND so they may begin construction this year and start production in early 2023.
Sincerely,
Humberto Orantes
Acting Commercial Head, North America
Shell Hydrogen
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
37 Response
s to
Letter 10
-
Shell Hydrogen
1 0
-
1 The comment is in support of the proposed Project and does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to thi s comment, however, it is
noted and will be made available to City decision
-
makers as they consider the Project and whether or not
to approve it.
________________________
POWER ENGINEERS, INC.
2041 SOUTH COBALT POINT WAY
MERIDIAN, ID 83642 USA
PHONE
FAX
208-288-6100
208-288-6199
BOI (2022 -11 -07) JPH
Lydia Elias November 7, 2022 City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Subject: Raven SR Conditional Use Permit (CUP)
Dear Lydia,
I am writing to provide my support of Raven SR’s Co nditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the c onstruction and operation of a bioenergy facility at Republic Service’s West Contra Costa County Sanitary Landfill.
Raven SR has developed a new hydrogen production te chnology for waste-to-hydrogen production. Richmond will be their first location, and the community has a significant opportunity to receive attention in the current pro-hydrogen focus by the State of California and Department of Energy. In addition to providing clean hydrogen fue l for the Bay area, Raven will also help Richmond further divert waste from landfills to mee t California’s SB 1383’s goal of reducing organic waste disposal by 75% from 2014 levels (up to 27 M tons of organic waste) by 2025.
The development of the Raven systems will generate jobs not only in Richmond, but also ancillary jobs through the fabrication, fuels providers, engi neering, waste management and so many other areas. Raven has signed a Project Labor Agreement w ith the Contra Costa Building & Construction Trades Council and the I.B.E.W. Local #1245.
Because Raven’s system is non-combustion with minim al emissions, they will actually be reducing methane and short-lived climate pollutants from the landfill, and there will be a positive reduction in greenhouse gases. This is such a posit ive aspect to improving the air around the Richmond area.
California has taken a leadership role in the natio n for launching the hydrogen economy, and Richmond has the opportunity with Raven SR to lead the advancement of clean fuels production, emissions reduction, and reversing climate change in the East Bay region.
Thank you for your consideration and we respectfull y request you approve Raven SR’s CUP application and the CEQA MND so they may begin construction this year.
Respectfully Submitted,
James P. Hays, PE
Business Unit Director, POWER Engineers
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
39 Response
s to
Letter 11
-
Powers Engineers
11 -
1 The comment is in support of the
proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment also opines that the proposed P roject’s non
-
combustion
system would reduce methane and short
-
lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis contained in the IS/MND. No addition
al analysis or response is required to this comment, however, it is noted and will be made available to City decision
-
makers as they consider the Project and whether or not
to approve it.
________________________
Trails for Richmond Action Committee
TRAC
73 Belvedere Avenue
Richmond, CA 94801
Phone/Fax 510-235-2835
[email protected]
October 27, 2022
VIA Email:
Ms. Lydia Elias, Planner I
City of Richmond Planning Division
Dear Ms, Elias:
TRAC, the Trails for Richmond Action Committee, would like to comment on the Octo- ber 7 Draft IS/MND for the Raven SR Bioenergy Project (PLN21-282).
The project site is very close to the Landfill Loop Trail, which is part of the regional San Francisco Bay Trail as shown on the attached Bay Trail map for Richmond. However, the draft IS/MND in many locations erroneously refers to the Wildcat Marsh Trail, e.g. in Sections 1.10, 2.9 & 4.1a and on Figure 4.1-1. The Wildcat Marsh Trail is located on West County Wastewater District property, whereas the Landfill Loop Trail is located on the Republic Services site of the Raven SR facility as shown by the attached orientation map posted at the Landfill Loop trailhead staging area.
Section 4.12 Noise and Vibration: The nearest noise-sensitive receptors would be those walking, bicycling and bird watching on the Landfill Loop Trail. Noise impacts on trail users should be assessed and mitigated as appropriate.
TRAC hopes that these comments will prove helpful in finalizing the IS/MND.
Sincerely,
Bruce Beyaert, TRAC Chair
Attachments:
Richmond Bay Trail Map
Wildcat Marsh & Landfill Loop Trail orientation map
14.6” x 17.3” — G arrard Blvd.
Atlas Rd
San Pablo
80 580
Point San Pablo
Yacht Harbor
Point Molate Beach Park
Point Pinole
Regional
Shoreline
Point San Pablo
Point
Wilson
Winehaven
Historic District
Shimada
Park
Miller-Knox
Regional
Shoreline
Point Isabel
Regional
Shoreline
Jay &
Barbara
Vincent
Park
Richmond-
San Francisco
Ferry Terminal
Lucretia
Edwards
Park
Rosie the Riveter/
WWII Home Front
NHP Visitor Center
SS
Red Oak
Victory
Marina
Bay
Park
Richmond
BART Station
El Cerrito
Plaza
BART
Station
El Cerrito del Norte
BART Station
Cutting Blvd
Marina
Bay
Gertrude Ave
Castr
o St
He
nsley St
Richmond
El Cerrito
Richmond
y
W anira
M
Keller
Beach
Ferry
Point
Point
Molate
Brooks Island
Point
Potrero
Hall
Wright
Nevin Ave
Barrett Ave
Pennsylvania Ave
Ohio Ave
To Point Isabel
Regional Shoreline
Richmond Greenway
Landfi ll
Loop Trail
Boat
Ramp St
Richmond
Museum of History
West Macdonald
Point
Richmond
23rd St
Kaiser
Shipyard 3
Richmond
Goodrick Ave
51st St
Wildcat Creek Trail
Canal Blvd
Harbour W
ay Soutn
Ho
man
Trail Open — Pilot Project
Richmond-San Rafael Bridge
Garrard Blvd
Regatta Blvd
Dorna
n Dr
Brickyard Cove
Pkwy
Marina Bay
Open
Fall
2019
Ohlone Greenway
Wildcat
Marsh
Trail
Richmond
Wellness
Trail
Richm
ond Pkwy
Parkway
San Pablo Ave
Pin
Trail
Stenm
ark Dr
Welcome to
Richmond
August 2022
Over 36 miles of Bay Trail
linking a necklace of
12 shoreline parks
0 MILES
10.50.25 0.75
Bay Trail
Complete
Incomplete
Connector Trail
Complete
Incomplete
Parks/Open Space
Water Trail site
Water Trail site
(planned)
Water Bodies
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
43 Response
s to
Letter
12 -
Trails for Richmond Action Committee (TRAC)
12 -
1 The comment distinguishes the existing Landfill Loop Trail from the Wildcat Marsh Trail, both of which are part of the regional San Francisco Bay Trail. In the following
instances, the IS/MND is updated
to
specify the two facilities that exist near to the proposed Project site.
Section
1.10 , p. 6:
Figure 1
-
3 shows the closest structure and development is the Golden Bear Waste Recycling Facility approximately 300 feet southwest of the proposed project l
ocation, and the West County Wastewater District Treatment Plant and the Landfill
Loop
Wildcat Marsh
Trail and trail head parking exist approximately 1,000 feet east of the project location.
Section
2.9 , p. 22:
As part of the proposed project, off
-
site la
ndscaping improvements to the
Landfill Loop
Wildcat Marsh
Trail and trail head parking located approximately 1,000 feet east of the project location. Due to limited space and potential safety hazards, no new plants or vegetation will be installed within the
Raven project site. Instead, new trees will be added
to the public parking area near the trailhead.
Section 4.1a and Figure 1
-
1:
Figure 4.1
-
1,
Landfill Loop
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.
These modifications do not change the adequacy of the analysis or impacts identified in the IS/MND, and no further analysis is warranted, pursuant to the findings enumerated in Section 1 of this memo.
1 2
-
2 The comment asserts that
trail users should be
considered the
nearest noise
-
sensitive receptors
to the
proposed Project and factored into the noise analysis. This consideration would not be consistent with the City’s established approach to noise analy
ses in other CEQA documents for project located adjacent to public trails. Moreover, users of the trail would be electing their activity in the noise environment and would be a temporary, relatively short
-
term recreational users, unlike residences, schools
and medical
facilities or wildlife species. No additional analysis is warranted in response to the comment.
________________________
101 East Channel Rd
BeniCta Benicia,CA 94510
Fabrication phone (70T> 745-8i1 {
&Machine" Fa"(707)J45:810L
www.beniciafab.com
10/20/2022
Lydia Ellas
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Lydia,
I am writing to provide our company's support of Raven SR's Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation ofabioenergy facility at Republic Service's West Contra Costa County Sanitary Landfill.
Raven SR has developed a new hydrogen production technology that will revolutionize waste-to-hydrogen production, and as Richmond will be their first location, the community has a significant the opportunity to receive attention m the current pro-hydrogen focus by the State of California and Department of Energy. In addition to providing clean hydrogen fuel for the Bay area, Raven will also help Richmond further divert waste from landfills to meet California's SB 13 83's goal of reducing organic waste disposal by 75% from 2014 levels (up to 27 M tons of organic waste) by 2025.
The development of the Raven systems will generate jobs not only in Richmond, but also ancillary jobs through the fabrication, fuels providers, engineering, waste management and so many other areas. Raven has signed a Project Labor Agreement with the Contra Costa Building & Construction Trades Council and the I.B.E.W. Local #1245.
Because Raven's system is non-combustion with minimal emissions, they will actually be reducing methane and short-lived climate pollutants from the landfill, and there will be a positive reduction in greenhouse gases. This is such a positive aspect to improving the air around the Richmond area.
California has taken a leadership role in the nation for launching the hydrogen economy, and Richmond has the opportunity with Raven SR to lead the advancement of clean fuels production, emissions reduction, and reversing climate change in the East Bay region.
Thank you for your consideration and we respectfully request you approve Raven SR's CUP application and the CEQA MND so they may begin construction this year and start production in early 2023. /Carmeld Santiago
CEO & President
Benicia Fabrication & Machine, Inc.
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
45 Response
s to
Letter 13
-
Benicia Fabrication & Machine
13 -
1 The comment is in support of the proposed Project and notes
that the proposed Project will help the City
further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment also opines that the proposed Project’s non -
combustion
sy
stem would reduce methane and short
-
lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is
required to this comment, however, it is
noted and will be made available to City decision
-
makers as they consider the Project and whether or not
to approve it.
________________________
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
47 Response
s to
Letter 14
-
Contra Costa Construction and Building Trad
es
Council
14 -
1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1
383). The comment also opines that the proposed Project’s non -
combustion
system would reduce methane and short
-
lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis
contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision
-
makers as they consider the Project and whether or not
to approve it.
__________________
______
^WATLOW
October 14, 2022
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Lydia,
I am writing to provide Watlow's support of Raven SR's Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service's West Contra Costa County Sanitary Landfill.
Raven SR has developed a new hydrogen production technology that will revolutionize waste-to-hydrogen production, and Watlow has been a proud technology partner providing our thermal expertise, engineering assistance and partnership towards this exciting and promising new technology.
We commend Richmond's vision and leadership becoming the first location to implement Raven's SR2 Reformer, representing the opportunity to receive both recognition and attention by the State of California and Department of Energy related to theu- desire to promote the hydrogen economy.
Watlow remains committed to Raven's efforts and we share a passion for providing leading products and solutions contributing to the advancement of clean fuels production, emissions reduction and energy transition.
Thank you for your consideration and we respectfully request that you approve Raven SR's CUP application and the CEQA MND so they may begin construction this year and start production in early 2023.
Please let me know if Watlow can be of any further assistance to you on your decision process.
Sincerely,
^ybL St^i•i^z^^C^-<-^
Dr. Ashish Bhatnagar
Chief Technology Officer
Watlow
12001 Lackland Road • St. Louis, Missouri 63146 USA
Phone: 314-878-4600 * www.watlow.com
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
49 Response
s to
Letter 15
-
Watlow
15 -
1 The comment is in support of the proposed Project and does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted a
nd will be made available to City decision
-
makers as they consider the Project and whether or not
to approve it.
________________________
IRON WORKERS LOCAL 378
UNION OFFICE OF BRIDGE, STRUCTURAL, ORNAMENTAL AND REINFORCING 3120 Bayshore Road, Benicia CA 94510 | www.ironworkers378.org P. (707) 746-6100 | F. (707) 746-0979
Jason
October 13, 2022
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Mrs. Elias,
On behalf of the Iron Workers Local 378, we are writing in support of Raven SR’s Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service’s West Contra Costa County Sanitary Landfill.
Raven SR is poised to place the City of Richmond front and center in the production of clean hydrogen fuels not only in the Bay Area, but in the State of California. We have the opportunity to showcase a new hydrogen production technology that will revolutionize waste - to-hydrogen production. No longer will we be dependent on our hydrogen being shipped in from out of state, and we will ensure energy security for the owners of commercial and passenger hydrogen vehicles. It may even generate additional drivers coming to our community to fuel their cars, increasing our retail and gas revenues.
In addition to providing clean hydrogen fuel to our community, Raven will also help the City further divert waste from landfills to meet California’s SB 1383’s goal of reducing organic waste disposal by 75% from 2014 levels (up to 27 M tons of organic waste) by 2025. In an era when disadvantage communities are pleading for improvements, Raven SR is providing us solutions. Because Raven’s system is non-combustion with minimal emissions, the company will actually be reducing methane and short-lived climate pollutants from the landfill, and we will see a positive reduction in greenhouse gases in our community. It is a win-win all the way around! California has taken a leadership role in the nation for launching the hydrogen economy, and Richmond has the opportunity with Raven SR to take our place in the advancement of clean fuels production, emissions reduction, and reversing climate change.
Thank you for your consideration and we respectfully request that you approve Raven SR’s CUP application and the CEQA MND so they may begin construction this year, creating jobs for our Union Iron Workers, and start production of clean hydrogen in early 2023.
Best Regards,
Jason Gallia
Business Manager
Financial Secretary/Treasurer
JG:ym
opeiu-29/afl-cio
Jason Gallia
Business
Manager/Financial
Secretary-Treasurer
Jason Lindsey
President/Business
Agent
James Ashcroft
Business Agent
Ken Miller
Business Agent/
Organizer
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
51 Response
s to
Letter 16
-
Iron Workers Local 378
16 -
1 The comment is in support of the proposed Project and notes that
the proposed Project will help the City
further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment also opines that the proposed Project’s non -
combustion
system
would reduce methane and short
-
lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is requ ired to this comment, however, it is
noted and will be made available to City decision
-
makers as they consider the Project and whether or not
to approve it.
________________________
Local Union No. 302
INTERNATIONAL BROTHERHOOD ©OF ELECTRICAL TOKERS
REGULAR MEETING 4T^, '/.'EDS EACH MONTH °-T:'~; EXECUTIVE BOARD MEETS 3RD WEDS EACH MONTH 1875 ARNOLD DRIVE • MARTINEZ, CALIFORNIA 94553-4239
TELEPHONE (925) 228-2302 • FAX (925) 228-0764
October 13, 2022
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Ms. Etias,
On behalf of the Members of IBEW Local 302 we are writing in support of Raven SR's Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service's West Contra Costa County Sanitary Landfill.
Raven SR is poised to place the City of Richmond front and center in the production of clean hydrogen fuels not only in the Bay Area, but in the State of California. We have the opportunity to showcase a new hydrogen production technology that will revolutionize waste-to-hydrogen production. No longer will we be dependent on our hydrogen being shipped in from out of state, and we will ensure energy security for the owners of commercial and passenger hydrogen vehicles.
In addition to providing clean hydrogen fuel to our community, Raven will also help the City further divert waste from landfills to meet California's SB 1383's goal of reducing organic waste disposal by 75% from 2014 levels (up to 27 M tons of organic waste) by 2025.
Because Raven's system is non-combustion with minimal emissions, the company will actually be reducing methane and short-lived climate pollutants from the landfill, and we will see a positive reduction in greenhouse gases in our community. Clearly this project advances the production of clean fuels, as well as reducing emissions, and a crucial step in reversing climate change.
This project will be built with a PLA which means middle class, skilled and trained Union jobs. Local hire, apprenticeship training, and a veteran hire program are additional community benefits of the PLA.
We respectfully request that you approve Raven SR's CUP application and the CEQA MND so they may begin construction this year, which creates jobs for our Union workers, and starts the production of clean hydrogen as early as 2023.
Y^vw
Tom Hansen
Business Manager
Financial Secretary
TH:nlp
OPEIU#29:afl-cio
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
53 Response
s to
Letter 17
-
Local Union No. 302 International Brotherhood
of
Electrical Workers
17 -
1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (Califor
nia’s SB 1383). The comment also opines that the proposed Project’s non -
combustion
system would reduce methane and short
-
lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the ad equacy of the analysis
contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision
-
makers as they consider the Project and whether or not
to approve it.
________
________________
October 10, 2022
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Lydia,
I am writing in support of Raven SR’s Conditional U se Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service’s West Contra Costa County Sanitary Landfill.
Raven SR is providing the City of Richmond the oppo rtunity to showcase a new hydrogen production technology that will revolutionize waste -to-hydrogen production. In addition to providing clean hydrogen fuel to the Richmond commu nity, Raven will also help the City of Richmond further divert waste from landfills to mee t California’s SB 1383’s goal of reducing organic waste disposal by 75% from 2014 levels (up to 27 M tons of organic waste) by 2025.
Another plus is that Raven has signed a Project Labor Agreement with the Contra Costa Building & Construction Trades Council and the I.B.E.W. Loca l #1245. The jobs that Raven SR will be generating for the Richmond community, in addition to the construction jobs to build the plant, are to be commended.
California has taken a leadership role in the natio n for launching the hydrogen economy, and Richmond has the opportunity with Raven SR to support the advancement of clean fuel production, emissions reduction, and reversing climate change.
Thank you for your consideration, and I respectfull y ask that you approve Raven SR’s CUP application and the CEQA MND so they may begin construction this year and start production in early 2023.
Sincerely,
/s/ Nicholas Connell
Nicholas Connell
Policy Director
Green Hydrogen Coalition
Tel: 949-558-1305
Email:
[email protected]
RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
55 Response
s to
Letter 18
-
Green Hydrogen Coalition
18 -
1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organi c waste disposal for target
year 2025 (California’s SB 1383). The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available
to City decision
-
makers as they consider the Project and whether or not to approve it.
________________________
October 10, 2022
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Lydia,
I am writing in support of Raven SR’s Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service’s West Contra Costa County Sanitary Landfill.
Raven SR is providing the City of Richmond the opportunity to showcase a new hydrogen production technology that will revolutionize waste‐to‐hydrogen production. In addition to providing clean hydrogen fuel to our community, Raven will also help the City further divert waste from landfills to meet California’s SB 1383’s goal of reducing organic waste disposal by 75% from 2014 levels (up to 27 M tons of organic waste) by 2025.
I believe that because Raven’s system is non‐combustion with minimal emissions, the company will actually be reducing methane and short‐lived climate pollutants from the landfill, and we will see a positive reduction in greenhouse gases in our community. For once, a company that is trying to improve our environment!
Another plus is that Raven has signed a Project Labor Agreement with the Contra Costa Building & Construction Trades Council and theI.B.E.W. Local #1245. The jobs that Raven SR will be generating for our community, in addition to the construction jobs to build the plant, are to be commended. Jobs in Benicia will also be impacted with Benicia Fabrication, a subsidiary company, that is building the reforming units for the project. Benicia Fabrication is located in the Industrial Park of Benicia and founded in 1983. It specializes in the repair, maintenance and new construction of pressure vessels, heat exchangers and miscellaneous industrial equipment.
California has taken a leadership role in the nation for launching the hydrogen economy, and Richmond has the opportunity with Raven SR to take our place in the advancement of clean fuels production, emissions reduction, and reversing climate change.
Thank you for your consideration and I respectfully ask that you approve Raven SR’s CUPapplication and the CEQAMNDso they may begin construction this year and start production in early 2023.
Sincerely,
Christina Strawbridge
RESPONSE TO COMMENTS Received on
the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration
58 Response
s to
Letter 19
-
Christina Strawbridge
19 -
1 The comment is in support of the proposed Project and notes that the proposed
Project will help the City
further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment does not address the adequacy of the analysis contained in the IS/MND. No a
dditional analysis or response is required to this comment, however, it is noted and will be made available to City decision
-
makers as they consider the Project and whether or not to approve it.
________________________
Blank
This page is intentionally blank.
A
PP
-
A
ATTACHMENT A
Final
Mitigation Monitoring and Reporting
Program (MMRP)
(Update to IS/MND Appendix C)
Blank
This page is intentionally blank.
Raven SR Bioenergy Project
A
-
1 ESA
/ D202100382
November
30, 2022
FINA
L UPDATED
MITIGATION MONITORIN
G AND REPORTING PROG
RAM
Project Mitigation Measures
Implement
ed
By
Monitored By
Monitoring and Reporting
Action
Monitoring
Schedule
Verification of
Compliance
4.1 Aesthetics
–
None Required
4.2 Agriculture and Forestry Resources
–
None Required
4.3 Air Quality
(
Expanded
)
Mitigation Measure AQ
-
1: Best Management
Practices.
All subsequent projects, regardless of size, shall
implement the following best management practices to
reduce construction impacts, particularly fugitive dust, to a less
-
than
-
significant level:
All exposed surfaces (e.g., parking areas, staging areas, so
il piles, graded areas, and unpaved access roads) shall be watered two times per day
, except when not required
for dust control
.
All haul trucks transporting soil, sand, or other loose material off
-
site shall be covered.
All visible mud or dirt track
-
out
onto adjacent public roads
shall be removed using wet power vacuum street
sweepers at least once per day. The use of dry power
sweeping is prohibited.
All vehicle speeds on unpaved roads shall be limited to 15 mph.
All roadways, driveways, and sidewalks
to be paved shall
be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.
Idling times shall be minimized either by shutting
equipment off when not in use or reducing the ma
ximum
idling time to 5 minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations [CCR]). Clear signage shall be provided for construction workers at all access points.
All construction
equipment shall be maintained and
properly tuned in accordance with manufacturer’s
specifications. All equipment shall be checked by a
certified mechanic and determined to be running in proper condition prior to operation.
P
roject Applicant /
Construction
Contractor
Richmond
Building Division
and Engineering
Services
Department
Richmond
Engineering Services
Department to verify inclusion of
BAAQMD BMPs in applicable
construction plans
and specifications.
City of Richmond Building Division to
inspect site during construc
tion to
ensure compliance with P
roject
construction plans.
Prior to issuance of
building
permit.
Field inspections
during construction.
Verified by:
Date:
Fin
al
U
pdated
M
itigation Monitoring and Reporting Program
Raven SR Bioenergy Project
A
-
2 ESA
/ D202100382
N
ovember
30, 2022
Project Mitigation Measures
Implement
ed
By
Monitored By
Monitoring and Reporting
Action
Monitoring
Schedule
Verification of
Compliance
Post a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust
complaints. This person shall respond and take corrective action within 48 hours. The Air District’s phone number shall also be visible to ensure
compliance with applicable
regulations.
BMP #6: All excavation, grading, and/or demolition
activities shall be suspended when
average wind speeds
exceed 20
mph.
BMP #7: All trucks and equipment, including their tires, shall be washed off prior to leavin
g the site.
BMP #8: Unpaved roads providing access to sites located 100 feet or further from a paved road shall be treated with a 6
-
to 12
-
inch layer of compacted layer of wood chips,
mulch, or gravel.
Additional BMP: Limit the simultaneous occurrence of
e
xcavation, g
rading, and ground
-
disturbing
construction
activities.
Additional BMP: Install wind breaks (e.g., trees, fences) on the windward side(s) of actively disturbed areas of
construction. Wind breaks should have at maximum 50
percent air porosity.
Additional BMP: Plant vegetative ground cover (e.g., fast -
germinating native grass seed) in disturbed areas as soon as possible and watered appropriately
until vegetation is
established.
Additional BMP: Install sandbags or other erosion control measures to
prevent silt runoff to public roadways from
sites
with a slope greater than one
percent.
Additional BMP: Minimize the amount of excavated
material or waste materials stored at the site.
Additional BMP: Hydroseed or apply non
-
toxic soil
stabilizers to cons
truction areas, including previously
graded areas, that are inactive for at least 10 calendar days.
Require zero visible fugitive dust and use fence line air monitoring to demonstrate compliance with this
requirement.
Set requirements for when dust gener
ating operations
have to be shut down due to dust crossing the property
Final
Updated
Mitigation
Monitoring and Reporting Program
Raven SR Bioenergy Project
A
-
3 ESA
/ D202100382
N
ovember
30, 2022
Project Mitigation Measures
Implement
ed
By
Monitored By
Monitoring and Reporting
Action
Monitoring
Schedule
Verification of
Compliance
boundary or if dust is contained within the property
boundary but not controlled after a specified number of minutes.
Prohibiting grading on days when a Spare the Air is in
effect (
https://www.sparetheair.org/
) Prohibiting grading on
days with an Air Quality Index forecast of greater than 100 for
particulates for the project area
.
4.4 Biological Resources
Mitigation Measure BIO
-
1: Avoid and Minimize Impacts to
Nesting Birds, Except Rails.
To the extent practicable, project construction
activities requiring
heavy equipment, or
any
tree trimming
,
shall be performed outside of
the bird nesting season (February 1st through August 31st) to avoid impacts to nesting birds
.
Project Applicant
/ Construction
Contractor
Qualified Biologist
Richmond
Building Division
and
Planning
Division
City of Richmond
Building Division to
ensure construction activities are
performed between February 1st and
August 31st.
Prior to
any site
alterations or
issuance of building
permit.
Field inspections
during construction.
Verified by:
Date:
I
f these activities must be
performed during the nesting bird season,
a qualified biologist shall be retained to conduct a pre -
construction
survey in the project construction and staging areas for nesting birds and verify the presence or absence of nesting birds no more than 14 cale
ndar days prior to construction activities or after any construction breaks of 14 calendar days or more. Surveys shall be performed for the project construction and staging areas and suitable habitat within 250
feet of the project construction and staging
areas in order to
locate any active passerine (perching bird) nests and within 500 feet of the project construction and staging areas to locate any active raptor (birds of prey) nest
, including potential burrowing owl burrows
.
If nesting birds and raptors
do not occur within 250 and 500
feet of
the Project area, respectively, then no further action is required if construction begins within 14 calendar days.
If active nests are located during the pre
-
construction bird nesting
surveys, no
-
disturbance buffer z
ones 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 adjus
ted 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
mo
nitor 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 aband
oned. If active
burrowing owl dens are found within the survey area, the project applicant shall implement measures at least equal to the 2012 (or Project Appl
icant
/ Construction
Contractor
Qualified Biologist
Richmond
Building Division
City of Richmond Building Division to
confirm
surveys are conducted
pursuant to specified measures, and if
warranted, that buffer zone distances
are indicated in project plans and
adhered to during construction
activities.
City of Richmond Planning Division to
receive and confirm survey report.
Fiel
d inspections
during construction.
Upon completion of
surveys.
Verified by:
Date:
Fin
al
U
pdated
M
itigation Monitoring and Reporting Program
Raven SR Bioenergy Project
A
-
4 ESA
/ D202100382
N
ovember
30, 2022
Project Mitigation Measures
Implement
ed
By
Monitored By
Monitoring and Reporting
Action
Monitoring
Schedule
Verification of
Compliance
subsequent applicable) CDFW Staff Report (CDFG, 2012), as determined by the qualified biologist.
Mitigation Measure BIO
-
2: Avoid and Minimize Impacts to
California Black Rail and California Ridgway’s Rail
To minimize or avoid the loss of individual California black rail and Ridgway’s rail, construction activities requiring heavy equipment, adjacent to tidal marsh areas (within 500 feet [150 meters] or a distance determined in coordination with U.S.
Fish and
Wildlife (USFWS) or the California Department of
Fish and Wildlife (CDFW)), shall be avoided during the
breeding season from February 1 through August 31.
Project Applicant
/ Construction
Contractor
Qualified Biologist
Richmond
Building Division
and
Planning
Division
City of Richmond Building Division to
ensure construction activities are
performed between February 1st and
August 31st.
Field inspections
during construction.
Verified by:
Date:
If areas within 500 feet of rail habitat cannot be avoided during the breeding season (February 1 through August 31),
protocol
-
level surveys shall be conducted to determine rail
nesting locations. The surveys will focus on potential habitat that could be i
ndirectly 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 de
veloped for use by
USFWS and partners
(Wood et al.
2017). Surveys are
concentrated during the approximate period of peak
detectability, January 15 to March 25 and are structured to efficiently sample an area in three rounds of surveys by broadcasting calls
of target species during specific periods of
each survey round. Call broadcast increase the probability of detection compared to passive surveys when no call
broadcasting is employed. This protocol
has since been
adopted by Invasive Spartina Project (ISP)
and Point Blue
Conservation Science to survey
Ridgway
’s rails at sites
throughout San Francisco Bay
Estuary
.
The
survey protocol
for Ridgway’s rail
is
summarized below.
Previously used survey locations (points) should be used when available to maintain c
onsistency with past survey
results. Adjacent points should be at least 200 meters
apart along transects in or adjacent to areas
representative of the marsh. Points should be located to minimize disturbances to marsh vegetation. Up to 8
points can be locat
ed on a transect
.
At each transect, three surveys (rounds) are to be
conducted, with the first round of surveys initiated
between January 15 and February 6, the second round
performed February 7 to February 28, and the third round Project Applicant
/ Construction
Contractor
Qualified Biologist
Richmond
Building Division
City of Richmond Building Division to
confirm
surveys are conducted
pursuant to
specified measures.
City of Richmond Planning Division to
receive and confirm survey report.
Field inspections
during construction.
Upon completion of
surveys.
Verified by:
Date:
Final
Updated
Mitigation
Monitoring and Reporting Program
Raven SR Bioenergy Project
A
-
5 ESA
/ D202100382
N
ovember
30, 2022
Project Mitigation Measures
Implement
ed
By
Monitored By
Monitoring and Reporting
Action
Monitoring
Schedule
Verification of
Compliance
March 1 to March 25. Surv
eys should be spaced at least
one week apart and the period between March 25 to April 15 can be used to complete surveys delayed by logistical or weather issues. A Federal Endangered Species Act
Section 10(a)(1)(A) permit is required to conduct active surv
eys.
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 vocalization
s, followed by 30 seconds of
silence, followed by a 30
-
second recording of California
black rail, followed by 3.5 minutes of silence.
If no breeding Ridgway’s rails or black rails are detected during surveys, or if their breeding territories can be avoided
by 500 feet (150 meters), then project activities may proceed at that location.
If protocol surveys determine that breeding Ridgway’s rails or black rails
are present in the project area, the following
measures would apply to project activities conducted during their breeding season (February 1
-
August 31):
The applicant shall coordinate with the USFWS
-
and
CDFW, as appropriate depending upon species, to
determine if project activities can continue during the nesting season based on nest location, natural visual
barriers (e.g., levees) between the project and
marshlands, and the distance between proposed
activities and identified activity centers. If impac
t cannot
be avoided during the rail nesting season, activities
would be delayed until after the nesting season.
Project Applicant
/ Construction
Contractor
Qualified Biologist
Richmond
Building Division
City of Richmond Building Division to
ensure
construction activities are
performed between February 1st and
August 31st
, based on agency
coordination
per this measure
.
City of Richmond Planning Division to
verify agency coordination and
outcome.
Field inspections
during construction.
Upon completio
n of
surveys.
Verified by:
Date:
4.5 Cultural Resources
Mitigation Measure CUL
-
1a: Cultural Resources Awareness
Training.
Prior to authorization to proceed, the City shall engage a qualified archaeologist, defined as an archaeologist meeting the U.S.
Secretary of the Interior’s Professional Qualification Standards for Archeology, to conduct a training program for all construction workers involved on site disturbance. On
-
site personnel shall attend
a mandatory pre
-
project training that outlines the gene
ral
archaeological sensitivity of the vicinity and the procedures to follow Project Applicant /
Construction
Contractor
Qualified
Archaeologist
Richmond
Building D
ivision
City of Richmond
Building Division
to
review and confirm documentation of
training, required personnel attending,
and scope of training.
Prior to
commencement of
any ground
-
disturbing
activities.
Verified by:
Date:
Fin
al
U
pdated
M
itigation Monitoring and Reporting Program
Raven SR Bioenergy Project
A
-
6 ESA
/ D202100382
N
ovember
30, 2022
Project Mitigation Measures
Implement
ed
By
Monitored By
Monitoring and Reporting
Action
Monitoring
Schedule
Verification of
Compliance
in the event an archaeological resource and/or human remains are inadvertently discovered.
Mitigation Measure CUL
-
1b:
Inadvertent Discovery of Cultural
Materials or Tribal Cultural Resources.
If pre
-
contact or historic
-
era cultural materials are encountered
during project implementation, all construction activities within 100
feet of the find shall halt and the contracto
r shall notify the City.
The City shall notify a qualified archaeologist who will inspect the find within 24
hours of discovery and provide the City of an initial
assessment. Pre
-
contact cultural materials might include obsidian
and chert flaked
-
stone tool
s (e.g., projectile points, knives, scrapers)
or toolmaking debris; culturally darkened soil (“midden”) containing heat
-
affected rocks, artifacts, or shellfish remains; stone milling equipment (e.g., mortars, pestles, handstones, or milling slabs); and bat
tered stone tools, such as hammerstones and pitted stones.
Historic
-
era cultural materials might include building or structure footings and walls, and deposits of metal, glass, and/or ceramic refuse.
If the City determines, based on recommendations from a
qualified
archaeologist and a Native American representative (if the resource is pre
-
contact), that the resource may qualify as a historical resource or unique archaeological resource (as defined in CEQA Guidelines Section 15064.5) or a tribal cultural re
source (as defined in PRC
Section 21080.3), the resource shall be avoided if feasible.
Consistent with Section 15126.4(b)(3), this may be accomplished through planning construction to avoid the resource, incorporating the resource within open space, cappin
g and covering the resource,
or deeding the site into a permanent conservation easement.
If avoidance is not feasible, the City shall consult with a qualified archaeologist and a Native American representative (if the resource is pre
-
contact) to determine
treatment measures to avoid, minimize,
or mitigate any potential impacts to the resource pursuant to PRC Section
21083.2 and CEQA Guidelines Section
15126.4. This shall
include documentation of the resource and may include data recovery (according to PRC
Section
21083.2), if deemed
appropriate, or other actions such as treating the resource with culturally appropriate dignity and protecting the cultural character and integrity of the resource (according to PRC Section
21084.3).
Project Applicant /
Construction
Contractor
Qualified
Archaeologist
If applicable,
Native American
representative
Richmond
Building Division to review
and approve of archaeologist, of
cultural resources monitoring plan and
of the construction plan that includes
archaeologic
al mitigation.
If resources are encountered,
Contractor to verify work is suspended
as required, review and approve
qualified archaeologist and
recommendations.
If resources encountered are found to
be qualifying as described in the
measure, the City to en
sure
preservation measures are
implemented or that the ARDTP is
completed and submitted to NWIC.
City to inspect site during construction
to ensure compliance with project
construction plans.
Prior to issuance of
building permit for, or
commencement of,
a
ny ground
-
disturbing
activities.
Field inspections
during construction.
Verified by:
Date:
Final
Updated
Mitigation
Monitoring and Reporting Program
Raven SR Bioenergy Project
A
-
7 ESA
/ D202100382
N
ovember
30, 2022
Project Mitigation Measures
Implement
ed
By
Monitored By
Monitoring and Reporting
Action
Monitoring
Schedule
Verification of
Compliance
Mitigation Measure CUL
-
2: Inadvertent Discovery of Human
Remains.
If human remains are encountered during project implementation, the contractor shall halt all
construction activities within 100
feet of
the find and notify the City. The City shall contact the Contra Costa County Coroner who will determine that no investigation of the cause of death is required. If it is determined that the remains are Native Amer
ican, the Coroner shall contact the Native American Heritage Commission within 24 hours. The Commission shall then identify the person or persons it believes to be the Most Likely Descendant from the deceased Native American, who in turn would make
recomme
ndations for the appropriate means of treating the human remains and any grave goods.
Project Applicant /
Construction
Contractor
Qualified
Archaeologist
Richmond Building Division verify
mitigation measure on construction
plans.
Inspect site during
construction to
ensure compliance with project
construction plans.
If needed, engage County Coroner
and ensure NAHC contact.
Prior to issuance of a
building permit for, or
commencement of,
any ground
-
disturbing
activities.
Field inspections
during const
ruction
.
Verified by:
Date:
4.6 Energy
–
None Required
4.7 Geology, Soils, and Mineral Resources
-
MM CUL
-
1a, CUL
-
1b, CUL
-
2 (see 4.5, Cultural Resources)
4.8 Greenhouse Gas Emissions
–
None Required
4.9 Hazards and Hazardous Materials
–
None Required
4.10 Hydrology and Water Quality
–
None Required
4.11 Land Use and Planning
–
None Required
4.12 Noise / Vibration
–
None Required
4.13 Population and Housing
–
None Required
4.14 Public Services and Recreation
–
None Required
4.15 Transportation
–
None Required
4.16 Tribal Cultural Resources
-
MM CUL
-
1a, CUL
-
1b, CUL
-
2 (see 4.5, Cultural Resources)
4.17 Utilities and Service Systems
–
None Required
4.18 Wildfire
–
None Required
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