Attachment 7 - Raven SR Project_Updated ISMND Response to Comments_042523.pdf

180 Grand Avenue

Suite 1050

Oakland, CA 94612

510.839.5066
phone

510.839.5825
fax

esassoc.com

M
emorandum

date

April 2
5 , 2023

Lina Velasco
, Director
,
Director of Community Development

from

Crescentia Brown
, Project Director
, ESA

Tim Sturtz
, Project Manager
, ESA

subject

RESPONSE TO COMMENTS Received on the

Updated

Raven SR Bio
energy Project In
itial
Study /
Mitigated Negative Declaration

1. 0

Background

1.1 Original IS/MND

On October 7, 2022, the City of Richmond (Lead Agency) released for public review a

Draft
Initial Study
(IS)
and Mitigated Negative Declaration (MND)
pursuant to the Californ
ia Environmental Quality Act (CEQA)
for
the proposed
Raven SR Bioenergy Project
(Project)

(SCH#

2022
01045
).

The proposed Project involves the
construction and operation of a bioenergy facility that converts food and green waste into transportation -
grade
hy
drogen for various renewable energy products (PLN21
-
282).

The
original
public review and comment period
on the
IS/
MND

was
October
7 , 20
22 through November 7, 2022, and the City extended the comm ent period to
November 22, 2022, to allow for additional oppor
tunity for public review. Approximately 19 written comments were received during this period.

Although not required by CEQA, the City responded in writing to all written comments received on the IS/MND during the public review period. The
Project

was then

presented to the City’s Planning Commission

at a
public
hearing on December 15, 2022, to consider approval of the Project

by approval of the IS/MND and Mitigation
Monitoring and Reporting Program (MMRP) and Design Review and Conditional Use Permit. After consideration of all
the
evidence before it, including public comment, both written and oral, the Planning Commission then approved the
Project
. The approval was then appealed.

1.2 Updated IS/MND

Given the comments provided during the
December 15, 2022,
h
earing and in the written appeal,
the City prepared
an
Updated

IS/MND

that contained

additional information that clarif
ied
, amplif
ied
, or otherwise more fully
explain
ed

the information in the original IS/MND.

Although
recirculation of the
Updated

IS/MND wa
s

not
required by CEQA
, the City recirculated that document to
make
the
additional clarifying information available to
the public

for review and comment. The public review and comment period on the Updated

IS/MND was
originally
March 9,
2023 through
April
7,
2023, and
was
then
re
-
noticed on March 14, 2023, and
extended

t
o
April 12,

2023.

A total of
19 written comments were received during that period.

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

2 E
ach commenter
is
listed
below in
Table 1
. Again
,
while not required by CEQA, the City has responded in
wr
iting

–

individually or by master
responses
-

to all written comments
received during the public review period
;
all comments and responses are
presented in
Section

2.0 .

TABLE 1

COMMENT LETTERS RECE

IVED ON THE IS/MND

Letter #

Entity

Author(s) of Comment
L
etter/e
-
mail

Comment Date

Page
No.

Agencies
–

Public / Quasi
-
Public

EBMUD

David J. Rehnstrom, Manager of
Water Distribution Planning

March 29, 2023

7 B

Port of Oakland

Danny Wan, Executive Director

April 12, 2023

13 C

CalRecycle

Harprit Mattu, Envir
onmental
Scientist

April 12, 2023

17 Organizations

Communities for a Better
Environment

Donnie Cho, Staff Attorney;
Tessa Wardle, Northern
California Staff Researcher;
Keala Uchoa, Richmond Youth
Organizer

A
pril 12, 2023

21 E

National Resources De
fense Council

Ann Alexander, Senior Staff
Attorney

April 12, 2023

35 F

Sierra Club, San Francisco Bay

Norman La Force, Vice
-
Chair

April 12, 2023

37 G

Energy Efficiency Finance Corp.

John C. MacLean, President

April 12, 2023

39 H

Sunflower Alliance

Shosh
ana Wechsler, Co
-
Coordinator

April 12, 2023

45 I

International Union of Elevator
Constructors

Ryan Lange, Business
Representative

April 5, 2023

47 J

Sprinkler Fitters and Apprentices

Jeffrey J. Dixon, Business
Manager / Financial Secretary

April 5, 2023

49 K

International Brotherhood of
Electrical Workers

Tom Hansen, Business
Manager

April 4, 2023

53 L

Contra Costa Building and
Construction Trade Council

Bill Whitney

April 4, 2023

55 Individuals

Griselda Rivera
-
Orochena

Richmond Community Membe
r

April 12, 2023

57 N

Ayush Dahal

Youth San Pablo Resident

April 12, 2023

61 O

Gil Friend

April 12, 2023

65 P

Lazuli Trujano

Richmond Community Member
and CBE Community Organizer

April 11, 2023

69 Q

Anna Henry

April 10, 2023

71 R

Maxim Scrogin

A
pril 5, 2023

75 S

Sunari Weaver
-
Anderson

North Richmond Community
Member & Occidental College
Student (Class of 2024)

Undated

77 Attachments

1 (
to Let
ter D
)

–

W
est

Contra Cos
ta
S
anitary Landfill (W
CCSL)
Summary Report (2021
-
2070
)

2 (
to Let
ter D
)

–

Pacific Gas and Electric Company’s (PG&E) Preliminary Engineering Study (PES) ,
2022

3 (
to
Response to

Letter

D
)
–

Raven
One
Hydrogen Ven
t
S
ound Atten
uation, 2023

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

3 2.0

Comments and Responses

Responses focus on comments that pertain to the adequacy of the analysis in the IS/MND or to other

aspects
pertinent to the pot
ential 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 acknow
ledged for the public record and will be taken into account by City decision -
makers.

2.1 Consolidated Response
:

Conditions Requiring Preparation of an
EIR

Numerous public comments received on the October 2022 IS/MND and March 2023 Updated IS/MND assert t hat
the City should reverse its approval of the IS/MND and, instead, prepare a full Environmental Impact Report (EIR). This is a

comprehensive response to address
this
recurring
topic
, and it

intended to reduce repetiti
ve
responses
in this
Comments and
Responses

section. Individual comments
to which this Co
nsolidated
R
esponse
relates are Response to Comments

D
-
1, D
-
8, H
-
1,

M
-
3, N
-
3, P
-
5, Q
-
9 and S
-

6. 2.1.1

CEQA
Guidance

CEQA

only

requires

preparation

of an EIR
“
if there is substantial evidence, in light
of the whole record before the
lead agency, that the project may have a significant effect on the environment. ”

(
Public Resources Code [PRC]
section 21080(d)
)

To assess whether an EIR is warranted, the City, as Lead Agency, conducted preparation of
an
Init
ial Study
,

reflecting its independent judgement,
to
determine

if the
Project

would

have a significant effect on
the

environment.

Pursuant to
CEQA Guidelines
, the Initial Study considered all phases of the
proposed

Project
;
relied on expert opinion supporte
d by facts,
technical

studies or other substantial evidence to document its
findings;
and
circulated the Initial Study for public review.
(CEQA Guidelines section 15063(1) through
15063(4))

As described in Section 1.0 (Background), the City prepared and ci rculated the updated Initial Study that
clarified, amplified, or otherwise more fully explained

the
Project

and certain analyses. The analysis presented in
the October 2022 IS/MND and the March 2023 Updated IS/MND showed that there was no substantial evide
nce
in the record that
the proposed
Project

may have a significant

effect on the
environment

(
CEQA Guidelines
section 15570). Mitigation measures are identified to reduce potentially significant impacts to less than significant, supported by substantial ev
idence in the Updated IS/MND and its appendices.

2.1.2 IS/MND Analysis and
Finding
s

Some c
omments suggest that a fair argument remains that significant impacts exist regarding air quality, cumulative impacts, and hazards and safety. Each is discussed bel ow.

A
ir
Q
uality

and Human Health Risk

Section 4.3,
Air Quality
, of the October 2022 IS/MND presents the air quality analysis for construction and operations of the proposed
Project

and cumulative conditions
, conducted in accordance with methodology used
b
y BAAQMD. The result of
that analysis was

that the proposed
Project

would

not exceed any applicable
thresholds of significance to result in
any
potentially significant air quality impacts.

Preparation of the
March
2023
Updated IS/MND clarified the air qual
ity analysis, which resulted in updates to criteria pollutant emissions, none of which
changed
the original less
-
than
-
significant impacts previously identified
.

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

4 The
HRA
w
as
presented as
Appendix A

to the Updated IS/MND
. The HRA involved
dispersion models o
f the
immediate

area
,
developed in accordance with methodology

used by BAAQMD and studied, with a focus on
nearby receptors as identified by the
a
ppellants

in the
a
ppeal.

Although the nearest sensitive receptor is located
f
a
rther than the 1,000
-
foot distan
ce, the analysis included a Health Risk Assessment (HRA) to quantify construction
-
related and operational emissions and associated health risks during Project construction and operation for an area within 6,000 feet of the proposed Project

footprint.

Also,

while conducting the HRA,
corrections were ma
de

to prior calculation errors involving a duplication of emissions.

The

net result of the
correction
s

was that the emissions profile of the
Project

was reduced.

The HRA determined that
,

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

would result in less
-
than
-
significant environmental impacts to the community.

The results of the HRA confirmed the October 2022 IS/MND finding of
no significant impact
s;
the
Project
’s

potential impacts during its
c
onstruction an
d
o
peration phases
were

below thresholds of

significance for impacts
on overburdened communities
. Si
milarly
, the analysis in the
Updated IS/MND
determined that
the

Project

would
not result in a significant air quality
or health risk impact
impacts to any s
ensitive

receptors.

Overall, the
s
ubstantial evidence contained in
the Updated IS/MND
and
its
Appendix
A

supports
that the
Project

would
not
result in
a
significant air quality

or
health risk impacts.

Cumulative Impacts

A r
ecurring concern

of several comm
enters

suggest that the
Project

analysis speculates about the potential and
cumulative pollution impacts resulting from two other hydrogen projects in the Richmond area. Footnote 9 on page 12 of the Updated IS/MND describes how “the proposed project is a s eparate and independent project from
other possible hydrogen
-
related projects within the City that may be proposed in the near future,” details the separate and speculative nature of the other projects, and explains that CEQA does not require analysis of s
peculative projects that have yet to be received.

Further, the Updated IS/MND explains that future hydrogen -
related projects submitted to
the

City after the Raven
Project

(or at some future date) would be required to comply with CEQA . Those CEQA analyses

would include
consideration of the Raven
Project

in either the baseline or a reasonably foreseeable project (assuming that the type of project impacts overlap for the purposes of a cumulative analysis).

For these reasons, the
cumulative
pollution impact an
alysis
in the Updated IS/MND is
appropriate and clearly d
escri
bed; no relevant information
gaps exist. Substantial evidence contained in the Updated IS/MND and its Appendix A supports that the Project

would not result in a significant cumulative impact.

S
afety

Appellants
and numerous other comments suggest that
the October 2022 IS/MND was vague in describing an
intent
for the
Project

to comply with various health, hazard, and process safety management regulations. In the IS/MND, the

Project

was described a
s being subject to various local, state, and federal programs

governing the
health and safety of workers in industry. Section 2.6
(Operations)
of the
Updated IS/MND
IS/MND also referred
to Raven SR’s intended compliance with the OSHA Process Safety

Managem
ent (29 CFR 1910.119) and the
EPA Risk Management Program (Section 112(r) of the Clean Air Act), commonly referred to as PSM/RMP.

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

5 These programs provide a process for

safety, mechanical reliability and operator involvement. PSM/RMP is mandatory for system
s

that exceed a threshold of 10,000 pounds of flammable material. The proposed
Project

will
not
exceed this threshold
,

but will voluntarily comply with the program requirements. Various other

programs administered at the state and local levels require docu mentation and reporting (with

periodic audit of
the site and updating of requisite documentation) for processes associated with

the
Project
’s operations and
maintenance.

An Individual Response
(D
-
12 to Letter D in the following section)

de
tails
the
Raven t
eam
’s

e
xperts
who were
select
ed

for their expertise
in characterizing and evaluating

best practices regarding

the
mitigation of pollutants, health risks, and plant operations

and that
have undertaken

standard, reasonable efforts
and best management practic
es to mitigate foreseeable risks and to

incorporate standard best management
practices into the
Project

design and operation. The

standards and practices for engineering, design, and operation that are and will be utilized, with

ever improving sensors and
instrumentation for process control, reasonably
demonstrate the

intent and capability of
the
Project

to minimize and mitigate risk.

For

all the reasons above, the
Updated IS/MND is clear and detailed about the
Project
’s intent regarding compliance with all

applicable health
and safety management regulations. No relevant information gaps exist.

2.1.3 Conclusion

In summary, the Updated IS/MND determined that all potentially significant environmental impacts with the Project

would be mitigated to a less
-
than
-
s
ignificant level, including the topics of concern raised in numerous comments, as discussed above. (Each impact and corresponding mitigation measure for the Project

is identified in
the
Updated Draft Mitigation Monitoring and Reporting Program

(MMRP) (Appe
ndix C to the Updated
IS/MND).

Overall, for all the reasons above, and given the substantial evidence the Updated IS/MND, its appendices, and this document, no relevant information gaps exists. Nor does

the proposed
Project

result in
significant cumulative

impacts that would trigger the need for a full EIR.

2.2 Individual Comments and Responses

The following pages present each comment letter with each individual comment bracketed with a numeric code, followed by the corresponding response.

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

6 Thi
s page is intentionally blank.

SS
W
U
U
FC

RIGHT OF WA Y
MIN 20’

APPLICANT PIPELINE

DESIGN CRITERIA

RIGHT OF WA Y EXTENDS
5’ BEYOND APPURTENCES
FC

SUBGRADE

FINISH GRADE

NO PERVIOUS PAVEMENT

NO HYDRANTS ON CURVES,

STREET CORNERS, OR
WITHIN 5' OF DRIVEWAY
24"
36"
5'min
10'min
7'min
5'min
12"min
12"min12"min12"min
SD 4'min

JOINT TRENCHES

SHALL NOT

CONFLICT WITH

THE CRITERIA IN

THE DIAGRAM
4203 • 5/21
W = WATER
24" cover to subgrade
36" cover to ﬁnal grade
7' inset from face of curb
U = UTILITY
min 12" vertical clearance
min 5' horizontal clearance
SD = STORM DRAIN
min 12" below water
min 4' horizontal clearance
SS = SANITARY SEWER
min 12" below water
min 10' horizontal clearance
FC= FACE OF CURB
March 2021
Applicant Pipeline Design Criteria
EBMUD values applicant pipeline projects and is committed to providing a thorough and efficient design.

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

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

Please contact the New Business Office representative assigned to your project if there are any questions regarding the requirements listed above. Meeting this criteria will enable the most efficient design possible.

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

12 Responses to
Letter A

EBMUD

A
-
1 The City acknowledges EBMUD’s conditions of approval for water service stated in the comment. The City would require the
Project

applicant, Raven SR, to adhere to the condi
tions of approval of such
service, including the request for a water service estimate to further determine the costs and conditions of providing water service for the proposed Project.

Specifically, as stated in
Updated
IS/MND Section

4.17,
Utilities and S
ervice Systems,
(
C
riterion “b”), EBMUD s
ervice would be granted subject to the
Project
’s “compliance with the District’s regulations governing water service and Schedule of Rates and Charges, which may include water main extensions and/or off -
site pipeline

improvements….”

A
-
2 If approved, the proposed Project would be required to adhere to all applicable permitting requirements and conditions that pertain to EBMUD's provision of water services, including rights -
of
-
way and
separation requirements as stated i
n the comment.

The IS/MND explains that current water service and
infrastructure at and near the
Project

site

are serviced and maintained by EBMUD
, as well as
comply

with
all
EBMUD design standards, which
includes

that the design not result in EBMUD having

to handle
hazardous materials.

A
-
3 No recycled water infrastructure currently exists at the Project

site. In compliance with the

Project’s

Condition of Approval (COA) #68, the
P
roject shall
make every effort to use reclaimed wastewater,
should it become
available, for daily operations;
and
Project
COA #69
(Water Conservation Measures)
directs the
Project

to incorporate water conservation measures into the construction and landscaping of the site, in compliance with all applicable City water conservation o rdinances and be consistent with East
Bay Municipal Utility District (EBMUD) policies and guidelines.

________________________

A
pril 12
, 2023
L
ydia Elias

City of Richmond

Community Development Department

450
Civic Center Plaza
, PO Box 4046
Richmond
, CA 9
4804
Re
:

Raven SR’s Conditional Use Permit App
lication

D
ear Ms. Elias
,
T
he Port of Oakland (Port)
is
writing in support of Raven SR’s Conditional Use Permit for the construction and operation of a bioenergy facility at Republic Service’s closed West Contra Costa County Sanitary Landfill.

T
he Port of Oakland is committed to a
chieving zero
-
emissions operations.

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

Projects like Raven SR’s

are needed to

ensure that there is a local
supply
of
clean hy
drogen fuel
available
for use
as a transportation fuel
at the

Oakland seaport and airport. Clean hydrogen
fuel
can also be used to generate clean
electricity
in microgrids, which will improve resilience and lessen demand on the power grid.

T
he
Port of Oakland is
eager to
support projects t
hat help
commercialize
zero
-
emissions
technologies
.

C
lean
hydrogen
fuel will contribute towards
California’s efforts to eliminate reliance on fossil fuels .

We urge
the City
of Richmond to approve Raven SR’s
Conditional U
se
P
ermit so they may begin construction this year and start production in early 2024.

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

Sincerely,

Danny Wan
Executive Director

2 Lydia
lias
City
o
f
Rich
mond

April
12,
202
3 Pg.
2 C
C:

Kr
isti McKenney,

Chief

Operating

Officer

Matthew

D
avis,

D
irector
of
Governmental Affairs

Colleen

L
iang,

A
cting

Dir
ector of

Environmental Programs
a
nd
P
lanning

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

15 Responses to
Letter B

–

Port of Oakland

B
-
1 The comment is in support of the proposed
Project

made available to the decision
makers
prior to a final dec
ision on the
IS/MND and the
proposed Project.

________________________

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

16 This page is purposefully blank.

1001 I Street, Sacramento, CA 95814 | P.O. Box 4025, Sacramento, CA 95812 www.CalRecycle.ca.gov | (916) 322-4027

California Environmental Protection Agency

Department of
Resources Recycling and Recovery
Gavin Newsom
California Governor
Yana Garcia
Secretary for Environmental Protection
Rachel Machi Wagoner
CalRecycle Director
April 12, 2023

Lydia Elias, Planner I
City of Richmond Planning Department
450 Civic Center Plaza
Richmond, CA 94804

Subject: SCH No. 2022100145 – Raven SR Bioenergy Project Mitigated Negative Declaration – Contra Costa County

Dear Lydia Elias,

Thank you for allowing the Department of Resources Recycling and Recovery (CalRecycle) staff to provide comments on the proposed project and for your agency’s consideration of these comments as part of the California Environmental Quality Act (CEQA) process.

Project Description

The City of Richmond Planning Department, acting as Lead Agency, has prepared and circulated an Updated Initial Study/Mitigated Negative Declaration (IS/MND) in order to comply with CEQA and to provide information to, and solicit consultation with, Responsible Agencies in the approval of the proposed project. The updated IS/MND document is meant to clarify, amplify, and refine the language of the draft IS/MND.

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

The project site is located at 1 Parr Boulevard, in the City of Richmond, Contra Costa County, California. It is within the West Contra Costa Sanitary Landfill (WCCSL) facility located in the northwest area of the City of Richmond, in Contra Costa County, California. For purpose of the environmental document, the project would occur within approximately 2.5 acres of the existing Bulk Materials Processing Center (BMPC) of the WCCSL. The property is located approximately 0.25 miles west of Parr Boulevard (approximately 0.25 miles west from Richmond Parkway) via an unpaved access road.

The northern boundary of the project site is the City of Richmond/Contra Costa County jurisdiction line; the project site is located wholly within the City of Richmond, except for

1001 I Street, Sacramento, CA 95814 | P.O. Box 4025, Sacramento, CA 95812 www.CalRecycle.ca.gov | (916) 322-4027

use of an existing access/egress road located within the County. The project site is located within Assessor’s Parcel Number (APN) 408-140-009.

The Raven SR Bioenergy Project (project) proposes to construct and operate a bioenergy system composed of the Raven SR multi-patented Steam/CO2 Reformation process at the project site. The non-combustion process would convert blended green waste and food waste, obtained from the existing BMPC operation adjacent to the project site, into renewable, transportation grade hydrogen that would be exported offsite for various renewable energy products. No long-term hydrogen storage would occur onsite. The project would reduce existing flaring of landfill gas (LFG) produced from the decomposition of organic solid wastes in the WCCSL facility, and would help reduce greenhouse gas emissions and produce renewable “green” hydrogen using a low-carbon process. The project would also involve the construction of a modular structure and industrial canopy.

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

Solid Waste Regulatory Oversight
Contra Costa Health Services is the Local Enforcement Agency (LEA) for Contra Costa County and responsible for providing regulatory oversight of solid waste handling activities, including inspections. Please contact Tim Kraus, the LEA, at 925.608.5549 to discuss the regulatory requirements for the proposed project.

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

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

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

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

1001 I Street, Sacramento, CA 95814 | P.O. Box 4025, Sacramento, CA 95812 www.CalRecycle.ca.gov | (916) 322-4027

Sincerely,

Harprit Mattu, Environmental Scientist
Permitting & Assistance Branch – North
Waste Permitting, Compliance & Mitigation Division
CalRecycle

cc: Eric Kiruja, Supervisor
Permitting & Assistance Branch – North

Tim Kraus, REHS, LEA
Contra Costa Health Services

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

20 Responses to
Letter
C

CalRecycle

C
-
1 The comment accurately describes characteristics of the proposed P
roject. No additio
nal comment is
made.

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

C
-
3 The comment does not raise a significant environmental issue, concerns about the environmental analyses, or information in the IS
/MND. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the proposed Project. The comment also specifies a duration of advance noticing for any hearing or decision on the proposed Pr
oject
, which is
consistent with the City’s 10
-
day advance notice issued prior to the May 16, 2023, public hearing on the appeal and
the
P
roject.

________________________

April12,2023
Viaelectronicmail([email protected])
LydiaEliasCityofRichmondCommunityDevelopmentDepartment450CivicCenterPlaza,P.O.Box4046Richmond,CA94804 Re: UpdatedIS/MNDDocumentsforRavenSRBioenergyProject
DearLydiaElias,
ThankyoufortheopportunitytocommentonarevisedInitialStudy/MitigatedNegativeDeclaration(IS/MND)fortheRavenSRBioenergyProject.WeappreciatetheaddeddetailintherevisedIS/MNDaimedataddressingthepointsweraisedinourappeal.However,afterextensiveengagementwithRichmondcommunitymembers,wecontinuetobelieveanynewdevelopmentinRichmond–especiallyNorthRichmond 1 –shouldnotriskanysustainedincreaseinairpollutionemissionsorindustrialsafetyrisks.Furthermore,undertheCaliforniaEnvironmentalQualityAct(CEQA),thereisstillafairargumentthattherearepotentiallysignificantimpactsonairquality;cumulativeimpacts;hazardsandsafety,asraisedinourappealfiledDecember19,2022. 2 Therefore, theRichmondCityCouncil shouldreversetheRichmondPlanningCommissiondecisiontoapproveanIS/MNDandundertakeafullEnvironmental Impact Reviewbeforepermit approval. 3 BeforeenumeratingouroutstandingconcernsabouttheIS/MND,webeginwithabroaderobservation.Uponreviewingtherevisedanalysis,ourcommunityhasbeendismayedtolearnoftheexcessiveflaringcurrentlytakingplaceattheWestContraCostaSanitaryLandfill(WCCSL).ContraCostaCounty,theCity,WestContraCostaSanitaryLandfill,Inc.,andRepublicServicesshouldhavepreventedthisavoidablepollutionthroughupgradestothenow-defunctbiogasengines.

RegardingtheupdatedRavenSRIS/MND,wearethankfulthattheprojectproponenthasprovidedtheCitywithadditionalmeaningfulanalysisanddetailabouttheprojectaimedataddressingthemajorityof 3 UndertheCityofRichmondCEQAGuidelinesandProcedures,Section11.2.I.1onAppealDecisions:“TheCityCouncilshallaffirm,modify,orreversetheoriginaldecision…[andwhenmodifiedorreversed]...statethespecificreasons…IfthedecisiontorequireanNDorMNDisreversed,anEIRshallbeprepared.”Availableat:https://www.ci.richmond.ca.us/DocumentCenter/View/307/CEQA-Guidelines-and-Procedures?bidId=. 2 WeincorporatebyreferenceanyunaddressedissuesfromtheappealfiledDecember19,2022. 1 OfficeofEnvironmentalHealthHazardsAssessment(OEHHA),CalEnviroScreen4.0.Availableathttps://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40. 1 ourconcernsintheappeal.However,aswewilldetailbelow,notallconcernshavebeenalleviatedandadditionalconcernsarisefromtheupdatesprovided.

Summaryof KeyOutstandingConcerns1. TheCityfailstotreatpollutingemissionsfromlandfillgasflaringconsistently.2. TheCityfailstoanalyzeandprovidesafeguardsfortheinevitabledeclineoflandfillgas.3. Thepotentialforunacceptablelevelsofdioxinformationinthehydrogenproductionprocessitselfhasnotbeenevaluatedormitigated.4. TheCitymustbeexplicitaboutwhetherhydrogenwillbeflaredorventedasasafetypractice,withproperairqualityandgreenhousegas(GHG)impactanalysisaswellasmitigation.5. TheCityshouldconsideradditionalmitigationmeasuresandcommunitybenefitsinafullEIRprocess.

1. TheCityfailstotreat pollutingemissionsfromlandfill gasflaringconsistently.

WhileweappreciatethattheanalysisoftheRavenSRprojectanticipatesadecreaseinflaringattheWCCSLbybringinginmoreefficientbiogasengines,wearesurprisedthattheprojectproponentisseekingtoclaimthesereductionsaspartoftheirprojectwithoutalsoaccountingfortheemissionscomingfromanycontinuedflaringoflandfillgasthatremains.Thereductioninlandfillgasflaringandtheremaininglandfillgasflaringareinextricablylinked,anditdoesnotmakesensetoaccountforonepartofthisequationwithouttakingintoaccounttheother.Whileweapplaudtheconservativeapproachinconsideringthescenarioofthebiogasenginesrunningon55%landfillgas,therewouldstillbelandfillgasflaringtakingplaceasapartofthisconnectedsystem.Therefore,eitherboththelandfillgasflarereductionsandthecontinuedflaringemissionsshouldbeconsidered,orneithershould.

InTable4.3-4,theIS/MNDprovidesprojectedemissionsfromprojectoperations,includingthereductionsinflaredlandfillgas.However,missingfromthesecalculationsaretheemissionsfromcontinuedflaringoftheremaininglandfillgasthatwillcontinuetooccuralongsidetheRavenSRproject.Inthistable,weobservethatwithoutthelandfillgasflaringreductions,theprojectoperationswouldexceedtheBAAQMDsignificancethresholdforNOxemissions. 4,5

2. TheCityfailstoanalyzeandprovidesafeguardsfortheinevitabledeclineof landfill gas.

WhileweappreciatetheaddedmentionintherevisedIS/MNDofwhatwouldhappenwhenthelandfillgasdeclinesandeventuallyrunsout,itisstillinsufficient.ItisimportantthattheCityexplicitlyrequireasystemwithabackstopinplacetocontrolthePressureSwingAbsorptionUnittailgasemissiononcethelandfillgasrunsout.TheCityshoulddirecttheprojectapplicanttocreateathoughtfulplanfor 5 Additionally,asstatedinourappealletter,regulatoryguidelinesarenotmeanttoinvalidatesubstantialevidenceofafairargumentthatthereisasignificantenvironmentaleffect.TheCitycanandshoulduseitsindependentresponsibilitytolookatevidencebeyondanyregulatorystandardsfromotheragenciestodecidewhetheranEIRmustbeprepared. SeeBayAreaAirQualityManagementDistrict(BAAQMD),CEQAGuidelines,Section1.1Purpose,https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa_guidelines_may2017-pdf. 4 Eitherway, anypotentiallysignificantimpactshouldtriggeranEIR,evenifaprojectmayprovidea“net”benefitinsomeareas. Seee.g., LighthouseFieldBeachRescuev. Cityof SantaCruz(2005)131Cal.App.4th1170. 2 reconfigurationunderthisinevitablefuturecondition,andtoclarifythattheprojectproponentwillneedtoreturntotheCityforapprovalofsuchareconfiguration.

3. Thereispotential forunacceptablelevelsof dioxinformationinthehydrogenproductionprocessthat hasnot beenevaluatedormitigated.

WhilewealsogreatlyappreciatetheadditionalmodeledemissionscalculationsfortoxicaircontaminantsfromthebiogasenginesintheUpdatedIS/MND 6 ,thereisstillconcernregardingdioxinformationinthehydrogenproductionprocessitself.TheprojectinRichmondwouldconstituteapilotprojectforthisspecificproprietarytechnology.Thisisstillarelativelynoveltechnologywithaspectsthatneedfurtherevaluationandmitigation,suchasthepotentialformationofdioxinsandfurans(whichcanalsobereferredtoasPolychlorinateddibenzo-p-dioxinsandfurans(PCDD/Fs). 7,8
Onestudyfound: “. . . arecentassessment of theliteratureindicatesthat [biomass]gasificationcannot alwaysreducePCDD/Fsemissionstoacceptablelevels, andthusacommonbelief onthereplacement of incinerationwithgasificationinordertoreducePCDD/Fsemissionsseemsoverlysimplistic.” 9 Inotherwords,thereisthepotentialfordioxinformationaboveacceptablelevelsinbiomassgasificationprojects.Thispotentialalsoexistsinanatmospherewithoutoxygen,asidentifiedina2021studybyKirkoketal.wheretheauthorssuggestthatonehypothesisforthisisthepresenceofoxygeninfeedstockmaterials. 10 Dioxinsarepersistentandhighlytoxiccompoundsatlowlevels,andthepotentialformationofdioxinsduringthisproject’sprocessmustbestudiedandminimized. 11 Thesestudiesprovideabasisforareasonableassumptionthatthereisevidencetosupportafairargumentofpotentialsignificantimpactonairquality.

4. TheCitymust beexplicit about whetherhydrogenproduct will beflaredorventedasasafetypractice, withproperairqualityandgreenhousegas(GHG) impact analysisaswellasmitigation. 11 U.S.EPAwebsite, Learnabout Dioxin:“Dioxinsarecalledpersistentorganicpollutants(POPs),meaningtheytakealongtimetobreakdownoncetheyareintheenvironment….Dioxinsarehighlytoxicandcancausecancer,reproductiveanddevelopmentalproblems,damagetotheimmunesystem,andcaninterferewithhormones.”Availableat:https://www.epa.gov/dioxin/learn-about-dioxin#:~:text=Dioxins%20are%20highly%20toxic%20and,the%20fatty%20tissue%20of%20animals%20. 10 Kirkoketal.,2021, Dioxinanddibenzofuranlikemolecularanaloguesfromthepyrolysisof biomassmaterials—theemergingchallengeinbio-oil production.Availableat:https://bmcchem.biomedcentral.com/articles/10.1186/s13065-020-00732-z 9 Safavietal.,2022. DioxinFormationinBiomassGasification: AReview.Availableat:https://www.mdpi.com/1996-1073/15/3/700/htm 8 Gao,2016.Dioxinsanddioxin-likecompoundsinthermochemicalconversionofbiomass.Availableat:https://www.diva-portal.org/smash/get/diva2:917094/FULLTEXT01.pdf 7 Safavietal.,2022. DioxinFormationinBiomassGasification: AReview.Availableat:https://www.mdpi.com/1996-1073/15/3/700/htm 6 UpdatedRavenSRIS/MND,MemofromRambolltoRichmondPlanningandBuildingServiceDepartment,RavenSRCEQAAirQualityandHealthRiskAssessment,Table12:ModeledEmissionRates,p.227. 3 ItiscurrentlyunclearbasedonthisIS/MNDwhetherthefacilitywillbeflaringordirectlyventinghydrogenasasafetybackup.Thischoiceshouldbeexplicitandexplained,astherevisedIS/MNDalludestobothpossibilities.

Wecautionagainstventingthehydrogenasitisagreenhousegaseffectmultiplier,particularlygiventhatpartofthisproject’spurposeistoreduceGHGemissions.Whenhydrogenisreleaseddirectlyintotheatmosphere,itworkstodecrease“thetroposphericconcentrationofhydroxylradicals(OH),themajortroposphericoxidant,andtherebyincreasetheatmosphericlifetimeofmethane”anditsglobalwarmingpotential. 12 Hydrogenhasacarbonintensityof5.8,meaningithas5.8timesmoreglobalwarmingpotentialthanCO2. 13 Iftheprojectplanstoventhydrogen,theresultingglobalwarmingpotentialmustbeincludedinthecalculationoftheproject’sUnmitigatedAnnualOperationalGreenhouseGasEmissionsestimations.Ifthisisthechosenroute,wealsocallforaclearpermitconditionlimitingthedirectventingofhydrogen.

EmittingNOxfromflaringhydrogenisalsofarfromideal,asNOxemissionscreatesmogandarelinkedwithrespiratorydiseaseincludingasthma. 14,15
Ifflaringistheproposedsafetypractice,thenweurgetheCitytorequireaspecificplanforminimizingflaring,thatcurbssafetyrisksandcapsadditionalpollutionemittedbyflaring.

Ultimatelyhowthehydrogenishandledshouldbedecidedbasedoncalculationsofclimateandcommunityimpacts,notonlytoavoidnoiseemissionsfromflaring.Inordertoavoidtheseunnecessaryemissions,theadditionofasystemtostorethehydrogenproductasabackupshouldbeconsidered.

5. TheCityshouldconsideradditional mitigationmeasuresandcommunitybenefitsinafullEIRprocess.

MembersofthefrontlineNorthRichmondcommunity,Richmond,andWestContraCostaCountymorebroadlyaredismayedtoseenovel,additionalindustrialendeavorsinanalreadydisproportionatelypollution-burdenedarea,especiallyonethatdoesnotfulfillanyofthecommunity’smanycriticalneeds.

Giventhatthereisafairargumentthatthereisstillapotentialforsignificantimpacts,afullEIRshouldbepreparedfortheCity.ToinformtheEIRprocess,ourcommunityengagementwithRichmondyouth,workingclasscommunitymembers,andRichmondresidentsmorebroadlyhasgeneratedseveralideasformitigationandcommunitybenefits. 15 Hajmohammadietal.,2022, Associationbetweenshort-termNOxexposureandasthmaexacerbationsinEastLondon: Atimeseriesregressionmodel.Availableat:https://www.sciencedirect.com/science/article/abs/pii/S2212095522000918 14 ATSDR,2002,NitrogenOxides.Availableat:https://www.atsdr.cdc.gov/toxfaqs/tfacts175.pdf 13 Derwentetal.,2006, Global environmental impactsof thehydrogeneconomy.Availableat:https://agage.mit.edu/publications/global-environmental-impacts-hydrogen-economy#:~:text=Hydrogen%20is%20therefore%20an%20indirect,a%20100%2Dyear%20time%20horizon. 12 Warwicketal.,2022, AtmosphericImplicationsof IncreasedHydrogenUse.Availableat:https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1067144/atmospheric-implications-of-increased-hydrogen-use.pdf 4 ThecurrentIS/MNDdidnotallowtheCitytoconsiderthefullscopeofwhatpotentialmitigationscouldbeaddedtothisproject.Additionalmitigationmeasurescouldincludethefollowing:● Giventhenovelnatureofthisdevelopment,theCityshouldrequireregularmonitoringofoperations,includingairmonitoringforCriteriaAirPollutantsandToxicAirContaminants.Whiletheadditionoffencelinemonitoringforvisiblefugitivedustisanexcellentplacetostart,itisinsufficientinanareaalreadydisproportionatelyoverburdenedbypollution.Thedatacollectedfromthismonitoringshouldbepubliclyavailable.● Theapplicanthasexpressedinterestinusingzeroemissionvehicles(ZEVs)fortheheavydutytrucksthatwilltransportthehydrogenandbiocarbonproduct.Thecityshouldmakeadoptingoperationalzeroemissionheavydutyfleetsarequirementandpartofthepermitconditions.ThismitigationmeasureiscriticalbecausetherevisedIS/MNDconfirmstheestimationof100additionalheavy-dutytrucktripsperday.AfullEIRwouldalsoneedtoprovideafullanalysisofthecommunityimpactsofthisincreaseandtheneedforadditionalmitigationshouldbeassessed.● Developmentofarenewableenergytransitionplanforwhenthelandfillgasrunsout.RatherthanrelyingonPG&E’senergytransition,renewableenergyinfrastructurethatRichmondresidentscanalsobenefitfromshouldbedeveloped.● TheCityshouldrequireamoretransparentandextensiveprocesssafetyandhazardprotectionsystempriortoprojectapproval.Thisprojectshouldemployarigorouswarningsystemandsafetyaccountabilityprocess,includingtimelinesforregularincidentreportswithcausalanalysesupdatestotheCityCouncilandthresholdsforrequiringoperationstocease.

Throughourcommunityengagementworkwithkeycommunitystakeholders,wehaveidentifiedadditionalcommunitybenefitsthatcouldbeappropriatetoconsiderforthisproject:● Localworkforce,prioritizingNorthRichmondresidents,withsafeworkingconditionsandfairwages.● InvestmentinpublicgoodsandservicesfortheCityofRichmondorEastBayCommunityJustTransitionFund.● InvestmentinlocalrenewableenergyandresilienceinfrastructureandprojectsinNorthRichmond.● InvestmentinhealthcareaccessandhealthyfoodaccessbecauseRichmondisahealthcaredesertaswellasafoodaccessdesert.● InvestmentingeneraloperatingexpensesforlocalpubliceducationforyoungpeopleinRichmond.

Thankyouagainfortheopportunitytocomment.

Sincerely,
ConnieCho,StaffAttorneyTessaWardle,NorthernCaliforniaStaffResearcherKealaUchôa,RichmondYouthOrganizerCommunitiesforaBetterEnvironment 5 RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

26 Responses to Letter D
–

Communities for a Better
Environment

D
-
1 T
his introductory comment
reiterate
s

prior concern
s

that despite added information in the
Updated

IS/MND a fair argument

still

remains that significant impacts exist
regarding air quality, cumulative
impacts, and hazards and safety
. The comment reiterates

t
hat warrant
s reversal of the City’s approval of
an IS/MND and
, instead,

preparation of a full Environmental Impact Report (EIR).

The Consolidated Response
regarding conditions requiring preparation of a full EIR

(starting on p. 3

of
this document)

discus
ses the
impact
findings for each of these
specific
topics relativ
e to those conditions
for preparation of an EIR
. The s
ubsequent comments in this
Letter D

elaborate on
specific aspects of the
aforementioned
topic
s
,

and full responses are presented
for

each

in
Response
s

to Comments
D
-
4 through
D
-
12 .

In summary, the Updated IS/MND findings are consistent with CEQA’s requirements that an EIR is not required as the impacts of the Project are less than significant.

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

This would be an existing condition to which the proposed P
roject could not
have contributed.

In other
words, without the proposed Project the WCCSL would still be engaged in o perations including flaring.

Moreover, CEQA does not require that the analysis of the proposed P
roject quantify or evaluate pre
-
existing activities at the
Project

location

for purposes of its environmental effects. Pursuant to CEQA, the focus of the enviro
nmental analysis is the potential effects of the proposed Project

on the existing
conditions.

The existing conditions include current WCCSL operations.

The comment does not raise a
significant environmental issue, concerns about the environmental analyses,

or information in the
IS/MND.

D
-
3 The comment
enumerates

“
key outstanding concerns
”

that are each discussed in detail in the subsequent
comments in this letter.

See Response to Comment
D
-
4 regarding the treatment of polluting emissions from landfill gas

(LFG)
flaring (Concern 1). See Response to Comment
D
-
5 regarding the
planning for the
decline of
LFG

(Concern 2). See Response to Comment
D
-
6 regarding dioxin formation (Concern 3). See Response to Comment
D
-
7 regarding
clarification of
hydrogen flaring o
r venting (Concern 4). See Response to
Comment
D
-
8 regarding additional mitigation measures
,

and
see
Response to Comment D
-
9 regarding
community benefits (Concern 5).

D
-
4 The comment asserts that the City fails to treat polluting emissions from LFG

flarin
g consistently. In
response, the proposed
Project

will have the capacity to handle all of the
LFG

currently produced by
WCCSL.

Upon
commencement
of Raven’s
operation
, there will be no remaining
LFG

flaring at WCCSL during
normal operations.

As clarified
throughout the Updated IS/MND, t
he only flaring that potentially could
occur at WCCSL
after the proposed
Project

is underway
would be during periods when Raven’s process
is shut down, such as during system maintenance
. See expanded
and clarified
discussion
s
of flare use
in
the Updated IS/MND at
Section 1.9 (Project Overview)
; Section 2.5 (Technology), under the heading
Flare System
;
throughout
Section 4.3,
Air Quality
; and Table 4.8
-
3,
Unmitigated Annual Operational
GHG Emissions
, on p. 88 of Section 4.8,
G
reenhouse Gas Emissions
. Moreover, even in the unlikely

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

27 event that flaring
was

to occur after the Raven Project is
in operation
, any flaring of
LFG

at WCCSL
represents an existing baseline condition associated with the existing landfill operations and not

as a
result of Raven’s process. The Updated IS/MND presents the proposed change in emissions and impacts from the
Project
, including emissions associated with Raven’s operations, as well as reductions from baseline conditions at
the
WCCSL.

With respect t
o the footnotes
cited
in th
e comment
, the City conducted an independent analysis of the
potential
Project

impacts and determined that all environmental impacts are less than significant or could be mitigated to a
less
-
than
-
significant
level based on its re
view of the facts and evidence in support of the
analysis.

The Updated IS/MND findings are consistent with CEQA’s requirements that an EIR is not required when the impacts of a
Project

are less than significant.

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

After release of the Updated IS/MND, Raven provided addit ional clarifying information to

the City about
the LFG and the source of power for the system once the LFG is depleted. In summar y,
Figure 1

on the
following page
shows the LFG decline over time, based on information provided in the attached report regarding the closed
WCCSL
Summary Report (2021
-
2070)

(
Attachment 1

to this document)
. As Figure
1 illustrates, the projected volume, in

cubic feet per minute, is not expected to deplete by even 50 percent of the current volume by 2055, with a roughly linear decline between now and then.

Additionally
,

Pacific Gas and Electric Company’s (PG&E) Preliminary Engineering Study (PES)

(
Attachme
nt 2

to this document)
,
shows
that 2.5 megawatts (MW) will be available to the
Raven
facility
upon commissioning
,

and up to 5.5 MW by 2025 through distribution system upgrades, as described therein. The
Raven
facility will only consume incremental electric
ity from the grid as needed to make up
for any reduction in onsite power generation due to depletion of the LFG. As shown in Figure 1, the rate of LFG decline is limited

that, as additional incremental renewable and zero
-
carbon generation is
brought onl
ine to meet the requirements of Senate Bill (SB) 100

(
as modified by SB 1020
,

Stats. 2022,
Ch. 361, Sec. 4), eligible renewable energy and zero
-
carbon resources supply 90 percent of all retails
sales to California end
-
use customers by 2035,
and
95 percent
by 2040 and 100 percent by 2045 (see Cal.

Pub. Res. Code § 454.53(a))
.

A
ny incremental electricity delivered from the grid to make up for depletion of LFG is expected to be increasingly clean, such that the carbon intensity of the produced hydrogen will re
main low and should not result in significant additional greenhouse gas emissions.

Taken together, the information above
demonstrates that the estimated decline of LFG will occur over multiple decades. Normal operation
of the
Project

will consume all LFG
and tail gas to produce power
for the
Project
.

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

28 FIGURE 1: WCCSL LFG Decline Over Time

D
-
6 The comment asserts that there is potential for unacceptable levels of dioxin formation in the hydrogen production process that has not been evaluated or mitigat ed.

The Raven SR multi
-
patented Steam/CO2 Tri
-
Reformation technology is a non
-
combustion, non
-
catalyst
process that converts blended green waste and food waste, obtained from the existing on -
site
West Contra
Costa Sanitary Landfill Organic Materials Proc
essing Facility (OMPF)

operation

(as clarified on p. 3 of
the Updated IS/MND)

adjacent to the
Project

site, into renewable, transportation grade hydrogen. This process produces syngas and is not categorized as incineration or combustion. The process operat es in an
oxygen deficient/free atmosphere at temperatures of 1,000+ degrees Celsius
. In the unlikely event that
dioxins could be produced (which they cannot where there is no exposure to free or available air in a closed system), the severe temperatures wi
thin process
would
result in their destruction.

The technical papers referenced in
the
comment do not apply to the Raven technology
;

they describe the
effects of different technologies than that used by Raven. The Kirkok et al. paper (202 1 ) focuses on
p
yrolysis of biomass (cellulose and amino acids) in a partial oxygen (6

percent
) environment at
temperature of 200
-
700 C.

The Safavi et al paper (2021) looks at thermal processes, primarily incineration, which is a combustion process with oxygen, and differ ent feedstocks (MSW, plastic waste,
sewage, etc.). Th
e Safevi et al

paper states the main ingredients for dioxin formation are an organic material, a chlorine source and a metallic catalyst. The Raven One process does not have a chlorine

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

29 source or metallic

catalyst. And in the conclusion section
,

the
Safevi et al
paper states, without the
presence of oxygen, dioxin formation is significantly reduced in reactors above 800 C. As previously stated, the Raven One process will operate above this temperature.

O
verall, the operating conditions referred to in the papers provided with
the

comment

are not similar to
the Raven One process. The proposed Project would not generate dioxins and would not result in any potential significant impacts.

The Updated IS/MND fin
dings are consistent with CEQA’s requirements
that an EIR is not required when the impacts of a
Project

are less than significant.

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

impact analysis as well
as mitigation.

Regarding the
commenter’s

question about whether hydrogen would be vented or flared, as indicated in
the
U
pdated IS/MND (
on
p. 24
, under the heading
Flare

System
), hydrogen would be vented to the
atmosphere, rather than flared, in the event no off
-
taker is available. Combustion of hydrogen produces
nitrogen oxides (
NOx
)

emissions.

Hydrogen is not identified as a criteria pollutant, and is not itself a green
house gas.
1 Thus, venting was identified as the environmentally superior approach

for the process
.

At 200 kg/hour capacity, if there is a hydrogen vent from the high pressure hydrogen compressor system, that would equate to 7.3 pounds of hydrogen/min or

0.12 pounds/second release.

As the facility’s
valuable product, Raven SR has designed the facility to minimize any potential product losses during normal operation.

Venting would occur only rarely, including during unexpected operational safety circumstanc
es or emergency shut
-
down situations.

The worst case release scenario of this kind would be
the venting of a full hydrogen tube trailer, which would be at the trailer’s relief valve, and potentially up to 1000 kg capacity, which is depended on trailer capa
city.

This type of release is separate from the
facility equipment and processes.

V
enting

is expected to produce noise should an emergency event occur.

This is due to the high pressure
of the hydrogen (potentially 8,000+ psig) going to a low -
pressure (at
mospheric).

The reference noise
level could be estimated up
estimated 114 dB at the source
–

approximately

15 -

to 20
-
feet above grade

onsite

(see
Attachm
ent 3

to this document)
. However, the noise created from emergency venting would be is less than 65 dB at the property line (64 dB) and acc ess to Republic’s main entrance parking (54 dB)
(which
is

close
st

to nearby receptors), and would be for

a duration of
approximately

ten minutes

or less
.

Project operations wou
l
d be suspended during an emergency event.

Factoring in the attenuation of this
b
rief, intermittent sound over the 0.75
-
mile distance to the nearest sensitive receptor

would

significantly

reduced

and within the ranges anticipated by Municipal Code 9.52.100 .

T
he noise
created
from venting during the emergency event
would also be
exem
pt from the Noise Ordinance (section

15.04.605.020(a)),
and would not affect the less than significant operational noise impact identified in the Updated IS/MND. Also,
Raven will consider a range of noise attenuation
features

such as baffling, etc.,
that m
ay be viable to incorporated into the
Project

to reduce this potential noise nuisance that has an
already low probability of occurring
, and is already less than significant
.

The goal would

to adhere to

1 See, e.g., T. Koch, T. Muralidharan, K. Ramirez, A. Well and T. Weiss, Rocky Mountain Insti tute, “Hydrogen Reality Check #1:

Hydrogen Is Not a Significant Warming Risk,” May 9, 2022, https://rmi.org/hydrogen
-
reality
-
check
-
1 -
hydrogen
-
is
-
not
-
a
-
signi
ficant
-
warming
-
risk
.

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

30 Project

COA #42
(
Operating Noise Limit
s)
which limits operating noise measured at the Republic
property boundary to exceed 70 dB at any time in accordance with Richmond Municipal Code 9.52.100.

Overall
, the Updated IS/MND determined based on reasonable worst case assumptions supported by subs
tantial evidence that the proposed venting would not result in a significant impact.

The findings are
consistent with CEQA’s requirements that an EIR is not required when the impacts of a Project

are less
than significant.

D
-
8 The comment states that by no
t preparing a full EIR, the City did not consider the full scope of what potential mitigations could be added to the
Project
.

The
Updated IS/MND determined that all potentially significant environmental impacts would be mitigated to a less than significa
nt level.

In addition to the topics addressed generally in the Consolidated Response

regarding conditions requiring preparation of a full EIR

(starting on p. 3

of this document), t
he
Project

does not result in significant impacts that would trigger the nee d for
the comment’s
proposed
additional measures for the reasons discussed below.

First,
many of the additional measures requested
by the comment
would not be considered mitigation
measures
for the purposes of
avoiding or substantially reducing potential
ly significant
environmental
impacts of the
Project

and
/or

exceed the scope of the proposed
Project

and its effects.

Second, the Updated IS/MND identified
mitigation measures that are designed to avoid and substantially lessen potentially significant impa
cts
of the
Project
. Each mitigation measure is identified and
discussed
in Section
4 (Environmental Checklist and Evaluation)
of the Updated IS/MND

and listed in the Updated
Draft
MMRP
, which is Appendix C to the Updated IS/MND
. The City prepared the Updat
ed IS/MND
taking into consideration the additional clarifying
Project

information from the
Project

applicant
, and
then confirmed whether or not the
Project

would result in
less
-
than
-
significant impacts

in accordance
with CEQA’s requirements.

The analysis

a
lso considered the full scope of applicable mitigation measures to a
ddress potentially significant
Project

impacts so that any
Project

impacts
were
mitig
ated to less than
significant.

Under each requested mitigation measure
, the
request

either

is not req
uired to mitigate a potentially
significant impact and

would not be
fully
feasible
,

redundant with other
mitigation
measures
already
identified in the Updated IS/MND,
is

already
included in the
Project
, or
would
exceed the scope of the
Project

and its a
ssociated impacts.

Each of the requested additional measures
is

addressed in the
following Responses to Comments D
-
9 through D
-

12. D
-
9 The comment specifies an a
dditional mitigation measure
that could be added to the
Project

and that

pertains to regular mo
nitoring of operations, including air monitoring for
c
riteria
a
ir
p
ollutants and
t
oxic
a
ir
c
ontaminants

(TACs), and the
insufficiency

of fenceline monitoring
(
in
Mitigation
Measure

AQ
-
1)
.

The
Project

applicant
clarifies that the proposed
Project

is not t
he first to
involve the conversion of
biomass to hydrogen or other forms of renewable energy.

Moreover, the suggested mitigation measure
calls for

monitoring of speculative impacts that substantial evidence in the Updated IS/MND
has
demonstrated would not
occur. Nonetheless,
the
Project

applicant

agrees to implement all dust control
measures to address fugitive dust as discussed on pages 51 and 52 of the Updated IS/MND ,

and listed in
Mitigation Measure AQ
-
1,
in order to confirm that elevated levels (if they

were to occur)
of dust
comply

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

31 with adopted standards.

The Updated IS/MND findings are consistent with CEQA’s requirements that an EIR is not required when the impacts of a
Project

are less than significant. Also, w
ritten documentation
that
the
Project

app
licant
submits to public agencies is considered to be available as a public record under the Public Records Act.

D
-
10 The comment specifies an additional mitigation measure that could be added to the Project

and that

pertains to
requiring
operational
zero
emission heavy duty fleets, but erroneously interpreting the number of
additional heavy
-
duty truck trips per day

associated with the
Project
.

First, as clarified in the Updated IS/MND in Section 2.8 ,

Transportation and Circulation
,

on page
31 , and
in Tab
le 4.15
-
1 (
Project Daily Trip Generation Summary
) on page
118
,
approximately 50

trucks would
access
/egress

the site daily

(
25 round trips)
.

Table 4.15
-
1 further clarifies that reference to “100 truck
trips per day” is the result of converting truck trips t o a
passenger car equivalent

(PCE) by
applying a
factor of 2.0 for purpose of accounting for the size and speed of trucks versus passenger cars ;
conservatively, 100 PCE truck trips were
factored into the operational emissions and energy analyses in the Upd
ated IS/MND
.

Second
, Section 4.3
,
Air Quality,

of the Updated IS/MND evaluated the air quality impacts associated with the increased trips per day generated by the projected truck s,

and concluded the impacts were less
than significant (see
p
. 54 of the U
pdated IS/MND). Similarly, Section 4.15
,
Transportation
,

of the
Updated IS/MND
discussed for informational purposes (under Criterion “a”) that traffic impacts
associated with

80 additional heavy duty truck trips
(or 100 truck PCEs) on a typical weekday wou
ld not
substantially increase the motor vehicle volumes on the nearby streets; the transportation impact
that
considered vehicle trip counts was
less than significant (see
Criterion “a” starting on
p
.

11 7

of the
Updated IS/MND).

Regarding the suggested
r
equirement

that all of the heavy
-
duty trucks entering and leaving the facility be
zero emission vehicles,
Raven will not have direct control over trucks entering and existing the site to obtain product, even in cases where Raven may hold third -
party contra
cts
, and therefore could not
mandate that the operators use zero emission vehicles
.

Additionally, electric vehicle heavy
-
duty trucks
are not currently commercially available.

Further,
the
proposed
Project

does not include Raven delivering
product off
-
site
–

in which case it would have control of its truck fleet.

Nonetheless,
the
Project

applicant
expects that truck fleets will convert over time to zero, or near zero, emissions vehicles ,

as such vehicles
would
become commercially available.

Pursuant to
Proje
ct
COA #61

(Zero Emission Vehicles)
,
the
Project

applicant will make reasonable efforts to procure zero

or near
-
zero

emission vehicles/trucks, to
the extent that such vehicle/trucks continue to be manufactured and are commercially available.

The
Project

ap
plicant
will encourage the owners of those heavy
-
duty vehicles to use them when servicing the
Raven facility.

The Updated IS/MND findings are consistent with CEQA’s requirements that an EIR is not required when the impacts of a
Project

are less than signif
icant.

D
-
11 The comment specifies an additional mitigation measure that could be added to the Project

and that

pertains to
the development of
a renewable energy transition plan for when the
LFG

runs out.

As discussed in Response to Comment D
-
5 and depict
ed in Figure 1, above,

b
ased on a WCCSL
summary report (2021
-
2070
), the expected decline of
LFG

provided is not a rapid decline and occurs
over decades. According to the summary report,
f
or the next 10 years, the estimated
LFG

decline is on

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

32 the order of 18

percent total (1.8 percent per year average). The current plan for future electrical supply for the proposed
Project

would draw additional capacity from PG&E, who will expand their renewable energy portfolio to comply with state requirements.

The propos
ed
Project

is to further

renewable energy infrastructure in Richmond. As the Updated IS/MND stated
at the top of

page 11, “
T
he purpose of Raven SR’s proposed project and its non
-
combustion Raven
SR process is to reduce pollution, help reduce greenhouse gas emissions, and produce renewable and
green hydrogen using a low
-
carbon process.”
The proposed
Project

is intended to contribute to efforts to
accelerate progress in green hydrogen production in furtherance of the transition from combustion of fossil fu
els in accordance with CARB’s 2022 Scoping Plan for Achieving Carbon Neutrality.

Statewide
and local
Richmond residents will benefit from
the proposed
Project
’s

efforts to implement the State’s
plans for a transition to renewable energy, given the proposed

Project
’s renewable energy technology
enabling the conversion of organic feedstock to hydrogen.

S
ee
specific clarifications of this topic in the
Updated IS/MND
, on the second to last paragraph on page
87 in Section 4.3,
Air Quality
(under Criterion “a”)
, and on page 125 in Section 4.17,
Utilities and
Service Systems
(under Criterion “a”).

The Updated IS/MND findings are consistent with CEQA’s
requirements that an EIR is not required when the impacts of a Project

are less than significant.

D
-
12 The commen
t specifies an additional mitigation measure that could be added to the Project

and that
pertains to
need for

a more transparent and extensive process safety and hazard protection system for the
Project

with specific reporting
and corrective thresholds for

City action.

The proposed
Project

incorporates a transparent and extensive safety plan into Project

construction and
operation as described in detail
under
Safety and Controls

on pages 26 through 30
in Section 2
.6

(
Operations
)
of the Updated IS/ MND. Rave
n
indicates that it
has assembled a team of experts in process
engineering, plant operations, civil engineering (including environmental and traffic), and chemical engineering to incorporate best practices into the design and operation of the Project
.

Its
consultants were
selected for their expertise in mitigating pollutants, assessing and mitigating health risks, and plant operations.

Raven also indicates that t
he construction arm of
its

team was chosen for their exemplary
record of on
-
the
-
job safety, cost

management, and schedule management.

R
aven

explains

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

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

Raven’s safety and hazard protection system has been built into its
Project

design as described in further
detail under the heading “Safety and Controls” in
Section 2.6 (Operations) of
the Updated IS/MND. As
discussed therein, piping and vessels will be periodically scanned with infrared equipment to identify hot

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

33 spots or gas leaks that may threaten safety. If hot spots or leaks are identified, immediate steps will be taken to correct or mediate the condition. Also, remote monitoring of the facility by Raven will provide oversight of the operation and early identif
ication of problems as they develop.

In summary
, the
Project

applicant

will comply with all applicable local, state and federal laws , as
discussed in the Consolidated Response “safety” (starting on p.4 of this document)

and that

address
s
tandards for work
places involving use, storage, handling and transport of hydrogen , including
standards
pertaining to incident reports
,

thresholds for requiring operations to cease in the event of hazardous incidents
. These laws and regulations are mandatory
.

Also,
severa
l
Project COA
s
establish the
scheduled review
and monitoring
of the Project’s
operations,
including
the assessment of
the Project
’s

compliance with
applicable federal, state, and local laws and
regulations pertaining to

safety precautions and emergency res
ponse.

These include Project COA
#17
(Compliance Objective)
;

COA
#
28 (Permit Review)
,

which includes
the
City’s
assessment of corrective
actions if needed;
COA #49 (Additional Operating Parameters Shall Include) ; and
COA #83 (Regulation
Compliance
)
.

The Up
dated IS/MND findings are consistent with CEQA’s requirements that an EIR is not required when the impacts of a
Project

are less than significant.

Also,
the
process safety and hazard protection
s
described
above
will be implemented as part of the safety sit
e operations plan referenced in
the
P
roject
’s

COAs
.

D
-
13 The comment identifies additional community benefits that it suggests could be appropriate for the City to consider for
the
Project
.

Each of the suggested community benefits
(re
-
stated and bulleted
below for
ease of review)
do not pertain to the potential environmental effects of the proposed Project

or other
topics relevant under CEQA. Each suggestion exceeds the scope of the proposed Project

and focuses on
existing conditions in the Richmond commun
ity rather than potential impacts caused by the proposed Project
.

Nonetheless, the following addresses each community benefit that CBE has identified. The responses below are acknowledged for the public record and will be taken into account by City decisio n
-
makers.



Local workforce, prioritizing North Richmond residents, with safe working conditions and fair wages.

The
Project

applicant has already signed a project labor agreement with the unions and will be offering two internships per year to trade or com
munity college students.



Investment in public goods and services for the City of Richmond or East Bay Community Just Transition Fund.

The
Project

applicant already supports local businesses, contractors and various community organizations in the City of
Richmond and Western Contra Costa County.



Investment in local renewable energy and resilience infrastructure and projects in North Richmond.

As discussed in Section 2 (Project Description) of the Updated IS/MND, the purposes of the proposed
Project

and i
ts non
-
combustion Raven SR process are to reduce pollution, help reduce greenhouse gas emissions, and produce renewable and green hydrogen using a low carbon process.

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

34 The
Project

is designed to convert blended green waste and food waste into renewable, low -
carbon,
transportation grade hydrogen. Use of low
-
carbon hydrogen as a substitute for petroleum based fuels in heavy duty vehicles and other applications would reduce criteria pollutant emissions and greenhouse gas
emissions in Richmond, thereby demonstra
ting a commitment to an investment in
local renewable energy in the community.



Investment in health care access and healthy food access because Richmond is a health care desert as well as a food access desert.

The proposed
Project

is a renewable energy p
roject, and improving access to food and health care is not within its scope.



Investment in general operating expenses for local public education for young people in Richmond.

The draft Conditional Use Permit (CUP) requires that Raven SR must contribute 1

percent of its
construction fund to the Richmond City Arts Program. That fee is approximately $500,000.

________________________

April 12, 2023

Via electronic mail ([email protected])

Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, P.O. Box 4046
Richmond, CA 94804

Re: Updated IS/MND Documents for Raven SR Bioenergy Project

Dear Lydia:

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

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

Very truly yours,

Ann Alexander
Senior Staff Attorney, National Resources Defense
Council

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

36 Responses to Letter E
–

N
ational Resources Defense Council

E
-
1 The comment
states full support of the comments su
bmitted by the Community for a Better Environment
and the communities it represents. See Response to Comments in
Letter D regarding the purported
information gaps and additional mitigation measures and community benefits .

________________________

Sierra Club
2101 Webster St #1300
Oakland, CA 94612

April 12, 2023

Via electronic mail ([email protected])

Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, P.O. Box 4046
Richmond, CA 94804

Re: Updated IS/MND Documents for Raven SR Bioenergy Project

Dear Lydia:

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

Sincerely,
Norman La Force
Vice-Chair, Sierra Club West Contra Costa County Group

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

38 Responses to Letter F
–

Sierra Club
, San Francisco Bay

F
-
1 The comment
states appreciat
ion

for the Updated IS/MND, yet states full support of the comments submitted by the Community for a Better Environment and the communities it represents. See Respons e
to Comments
in

Letter D regarding the purported information gaps and additional mitigation measures and community benefits.

________________________

Energy Efficiency Finance Corp. phone: 1-360-339-3936 Fax: 1-206-774-0411 Address: 3336 Libby Road NE, Olympia, WA USA 98506 April 12, 2023 Ms. Lydia Elias City of Richmond, Community Development Department 450 Civic Center Plaza, PO Box 4046 Richmond, CA 94804 sent by email to: [email protected]. Re: Raven SR Bioenergy Project Dear Ms. Elias: I am writing in support of the Raven SR Bioenergy Project to be located at West Contra Costa Sanitary Landfill and which will capture landfill gas (LFG) that is otherwise being flared and also convert organic waste to useful hydrogen energy. I have been introduced to this project by Libba and Gifford Pinchot. My work is in clean energy and environmental project finance and I have worked on developing and raised financing for LFG, waste-to-energy, anerobic bio-digester (selling renewable natural gas into the California LCFS market as managed by the CARB), recycling and composting facility and other environmental projects in my 35+ year career. I also served on the Board of my Windham County solid waste management district for several years while living in Brattleboro, Vermont where we operated a landfill, installed an LFG capture and energy plant and developed a materials recovery facility. I see the Raven project as a waste utilization project, making value added use of waste and LFG, and also providing significant local air quality benefits. As I learn and think about the Raven project from the public sector and public official point of view and put myself in City Council member shoes, questions I would be asking are: a) does the project generate local environmental benefits and improve air quality?, b) is the project consistent with State and local climate objectives and standards?, c) what are the financial benefits and risks to the City in the project undertaking? It seems that the answers to a) and b) are clearly yes, reflecting, for example, the “Raven SR Project Air Quality and Greenhouse Gas Assessment” prepared by Ramboll US Consulting, Inc. dated February 23, 2023 (attached for ease of reference). The Raven facility reduces local air pollution, hence local health risks even before accounting for emission reductions achieved by replacing diesel trucks with hydrogen fueled ones, and reduces greenhouse gas emissions consistent with State climate goals. Further inputs from scientists and permitting authorities on these questions a) and b) could be sought to confirm the local environmental and GHG reduction benefits from the project and inform the City’s decision. While I have not studied the project sufficiently to detail answers to question c) concerning City financial benefits and risks, my understanding is that the project will be implemented and operated on a turnkey basis by the project developer, thus managing project risks, and will generate savings and revenues for the City and landfill operation, and that the developer has a demonstrated track record and capabilities. Further assessment of this question c) in the context of completing project implementing agreements could be conducted.

I wish you all the best in conducting your analysis and supporting the City Council’s decision on this project. If I can be of any support, please contact me at 360-339-3936 or by email at [email protected]. Sincerely, John C. MacLean President Attachment Raven SR Project Air Quality and Greenhouse Gas Assessment” prepared by Ramboll US Consulting, Inc. dated February 23, 2023 cc: Gifford and Libba Pinchot

1 Lydia Elias
From: John MacLean <[email protected]>
Sent: Wednesday, April 12, 2023 3:13 PM
To: Lydia Elias
Cc: Gifford Pinchot III; Libba Pinchot
Subject: Re: Letter in support of the Raven SR Bioenergy Project Follow Up Flag: Follow up
Flag Status: Flagged
This email originated from outside of the City's email system. Do not open links or attachments from untrusted sources.

Dear Ms. Elias: One more thought to share…I understand that some environmental organizations are advocating for H2 production exclusively from electrolysis, powered by renewable energy. I have been learning about, and evaluating possible investments in the developing H2 economy, and while I also advocate for green H2 infrastructure, I think that (i) this Raven project should be evaluated on its own merits, especially the local air quality benefits, and (ii) there is definitely room within the future H2 economy for this project’s modest production volumes. Thank you for your public service. Sincerely, John MacLean

John MacLean, President
Energy Efficiency Finance Corp.
3336 Libby Road NE
Olympia, WA 98506
Cell = 360-339-3936
Fax = 206-774-0411
[email protected]

Skype handle = john.coleman.maclean

On Apr 12, 2023, at 11:53 AM, John MacLean <[email protected]> wrote:

Dear Ms. Elias: Attached please find my letter in support the Raven SR Bioenergy Project to be located at West Contra Costa Sanitary Landfill; also attached is one study shared with me by Mr. Gifford Pinchot (copied here) which assesses the local air quality and environmental benefits and greenhouse gas emissions reductions estimated to be achieved by this project. I wish you and your colleagues all the best in your review and decision process. Sincerely, John MacLean

You don't often get email from [email protected]. Learn why this is important 2 <Raven AQ GHG Memo_0227_with tables and figures.pdf>

John MacLean, President
Energy Efficiency Finance Corp.
3336 Libby Road NE
Olympia, WA 98506
Cell = 360-339-3936
Fax = 206-774-0411
[email protected]
Skype handle = john.coleman.maclean

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

43 Responses to Letter G
–

Energy Efficiency Finance Corp.

G
-
1 The comment
states its support

of the proposed
Project

and considers factors that public officials should
consider for the
Project
.

The comment does not raise a significant environmental issue, concerns about the environmental analyses, or information in the IS/MND. The comment will be

included as a part of the
record and made available to the decision makers prior to a final decision on the IS/MND and the Project
.

________________________

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

44 This page is purposefully blank.

1 Lydia Elias
From: Shoshana Wechsler <[email protected]>
Sent: Wednesday, April 12, 2023 4:38 PM
To: Lydia Elias
Subject: Raven SR Project
Follow Up Flag: Follow up
Flag Status: Flagged
This email originated from outside of the City's email system. Do not open links or attachments from untrusted sources.

Attn:

Lydia Elias
Richmond City Planner
Community Development Department
City of Richmond
450 Civic Center Plaza, P.O. Box 4046
Richmond, CA 94804

Re: Raven SR Project
Dear Ms. Elias,
I am writing on behalf of the Sunflower Alliance, an environmental and climate justice organization in the East Bay with over 4,000 supporters. Many of our active members are residents of Richmond, or residents of neighboring communities. The health and safety of Richmond and North Richmond residents has been a top priority for us in the work we’ve been doing over the last decade.

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

Very sincerely yours,
Shoshana Wechsler, Co‐Coordinator

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

46 Responses to Letter H
–

Sunflower Allianc
e

H
-
1 The comment recommends that
a full EIR be prepared for the
Project
, but cites only “the complexities of
this project” as justification. Regardless, see
the Consolidated Response
(starting on p
.3 of this document)
regarding
conditions

requiring prepar
ation of a full EIR.

________________________

April 5, 2023
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Lydia,
I am writing in support of Raven SR’s Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service’s closed West Contra Costa County Sanitary Landfill.

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

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

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

Another plus is that Raven has signed a Project Labor Agreement with the Contra Costa Building & Construction Trades Council and the I.B.E.W. Local #1245. Raven SR will be creating around 10 jobs, 2 internships, 100-150 constructions jobs and approximately 60 indirect jobs for our community.

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

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

Sincerely,
Ryan Lange
Business Representative
IUEC Local 8

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

48 Responses to Letter I
–

International Union of Elevator Constructors

I
-
1 The comment
supports

the proposed
Project

and discusses merits of the
Project
. It does not raise a
significant environmental
issue, concerns about the environmental analyses, or information in the IS/MND. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the IS/MND and the proposed Project.

_______________
_________

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

51 Responses to Letter J
–

Sprinkler

Fitters and Apprentices

J
-
1 The comment is in support of the proposed
Project

and discusses merits of the
Project
. It does not raise a
significant environmental issue, concerns about the environmental

analyses, or information in the
IS/MND. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the IS/MND and the proposed Project.

________________________

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

52 This page is pu
rposefully blank.

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

54 Responses to
Letter
K

–

International Brotherhood of Electrical Workers

K
-
1 The comment is in support of the proposed
Project

and discusses merits of the
Project
. It does not raise a
significant environmental issue, concerns ab
out the environmental analyses, or information in the
IS/MND. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the IS/MND and the proposed Project.

________________________

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

56 Responses to
Letter
L
–

Contra Costa Building and Construction Trade
Council

L
-
1 The comment is in support of the proposed
Project

and discusses merits of the
Project
. It does not raise a
significant environmental issue, concerns about the environmenta l analyses, or information in the
IS/MND. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the IS/MND and the proposed Project.

________________________

1 Lydia Elias
From: Griselda Rivera-Orochena <[email protected]>
Sent: Wednesday, April 12, 2023 4:43 PM
To: Lydia Elias
Subject: Raven SR Project
Follow Up Flag: Follow up
Flag Status: Flagged
This email originated from outside of the City's email system. Do not open links or attachments from untrusted sources.

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

I would like to raise concerns regarding Raven SR Project:

1. 2.

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

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

5. direct way.

6. 7.

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

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

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

Sincerely,
2 Griselda Rivera-Orochena
Richmond Community Member
‐‐
Griselda Rivera‐Orochena
CSU Dominguez Hills 2021
[email protected]

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

59 Responses to Let
ter M
–

Griselda

Rivera

M
-
1 The comment states that the proposed
Project

would release harmful and cancerous chemicals, such as
formaldehyde, mentions concern that hydrogen is highly volatile and explosive, and calls for preparation
of a
community safety p
lan
.

Cancerous materials, otherwise referred to as toxic air contaminants or TACs,
were

assessed as part of the HRA conducted as part of the CEQA analysis (see Consolidated
Response “Air Quality and Human Health Risk” starting on p.3 of this document).

TAC
s were tabulated
and modeled.

Tables 4.3
-
4 and 4.3
-
5 on pages 49 and 50, respectively, of the Updated IS/MND show that the
Project

would not exceed applicable BAAQMD thresholds, and the impact would be less than significant.

The modeled results of health r
isks would not exceed the
BAAQMD

thresholds and, when
combined with landfill reductions, are expected to reduce the overall health burden to the community

(see
Response to Comment N
-
1)
.

Also s
ee
the
C
onsolidated Response
(starting on p. 3 of this document
)

regarding conditions requiring
preparation of a full EIR
.

________________________

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

60 This page is purposefully blank.

1 Lydia Elias
From: Ayush Dahal <[email protected]>
Sent: Wednesday, April 12, 2023 4:50 PM
To: Lydia Elias
Subject: raven sr
Follow Up Flag: Follow up
Flag Status: Flagged
This email originated from outside of the City's email system. Do not open links or attachments from untrusted sources.

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

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

1. 2.

3. As a resident with

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

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

6. 7.

8. 9. I would really like

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

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

Sincerely,
Ayush Dahal
Youth San Pablo Resident

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

63 Responses to Letter

N
–

Ayush

Dahal

N
-
1 The commen
t

raises concerns about community health impacts from increas ed truck traffic associated
with the
Project
; s
ee Response to Comment D
-
10 and
R
esponse to Comment N
-
2 regarding truck
emissions. The comment also raises concern with explosive potential from transporting hydrogen produced on the
Project

site; see Response

to Comment D
-
12 and Consolidated Response “safety”
(starting on p. 4 of this document).

Also regarding the transport of hydrogen, the transportation of compressed gases such as hydrogen are regulated by the federal Department of Transportation, OSHA, and
other federal and State laws. These laws and regulations are mandatory

and set safety standards for
transportation and handling.

The comment raises concern about

cumulative impacts of
greenhouse gas
emissions
. As analyzed in
Criterion “a”
(starting on p
. 87)
in Section 4.8,
Greenhouse Gas
Emissions
, of the Updated IS/MND, the
Project

uses

LFG to provide power to the process
that
converts
blended green waste
into renewable,
transportation grade hydrogen.

Thus, it

reduces the amount of
greenhouse gas
emiss
ions produced at the
Project

site.

Further, the
Raven SR system does not have any free oxygen in its
process, and instead uses
steam
-
promoted processes to thermally decompose the
blended green waste

into its chemical elements.

The process does not involve
any type of combustion, and therefore does not have
greenhouse gas
emissions associated with the system operational emissions. Once Project

operations fully begin,

greenhouse gas

emissions are expected to be net negative.

Page 82 ends

ntinues that, qualitatively, t
he
Project

would satisfy the BAAQMD
Best Available Control Technology (BACT) requirements, and thus the proposed Project

is consistent
with the 2017 Climate Change Scoping Plan as well as the draft and final 2022 Scoping Plan Update in
terms of following the
greenhouse gas
reduction strategy to reach the statewide goal of climate neutrality by 2045
.

Based on the state carbon neutrality goal for 2045, the proposed Project

would contribute its
portion of what is needed to achieve

the State’s climate goals and would help to solve the cumulative climate problem.

Table 4.8
-
3 on page
83 of the Updated IS/MND shows that the
Project
’s

emissions
would

considerably less than the current BAAQMD operational emissions threshold of 10,000 metric
tons of CO2
e per year, which would be a
less
-
than
-
cumulatively
-
considerable climate impact.

The
analysis also discloses the
possibility of reaching net negative
greenhouse gas

emissions,
which supports
th
e determination
that the

Project

would have a

less than significant impact and a less
-
than
-
cumulatively
-
considerable climate impact.

N
-
2 The comment requests
the

City require the use of zero emissions heavy duty fleets as part of the COAs for the
Project
. See Response to Comment D
-

10. N
-
3 The comment

speaks to the need for transparency and community engagement in the decision -
making
process for the
Project
, and therefore requests preparation of a ful
l EIR.

The comments concern does not
raise a significant environmental issue, concerns about the enviro nmental analyses, or information in the
IS/MND. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the IS/MND and the proposed Project.

However,
Section 1
.0

of this document describe
s the CEQA process conducted for preparation, public
noticing, posting and review of the original and Updated IS/MND, all in accordance with the City’s CEQA Guidelines and other public noticing requirements. Of particular note, the City exceeded CEQA

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

64 requi
rements by recirculation the Updated IS/MND for public review and comment, as well as extended public review periods. As authorized by the City,
and as described in Raven’s letter to
the

City dated
March 21, 2023, Raven SR presented at more than 15 group m eetings in its outreach efforts to
neighborhood groups and organizations in the Richmond community, including those that raised specific
concerns about the
Project
’s potential impacts in a submitted appeal to the City’s approval of the original IS/MND and
MMRP and Design Review and Conditional Use Permit.

The comment suggest
s

that preparation of a full EIR would allow the community to be more fully informed about the
Project

and “voice in the decision
-
making process.” CEQA does requires additional
and len
gthier opportunities for public scoping, review and input than preparation of an IS/MND, however the findings of the IS/MND do not warrant preparation of a full EIR. See the
C
onsolidated Response

(p.3
of this document)
regarding
conditions

requiring prepar
ation of a full EIR.

________________________

1 Lydia Elias
From: Gil Friend, Natural Logic Inc. <[email protected]> Sent: Wednesday, April 12, 2023 4:34 PM
To: Lydia Elias
Subject: Comment regarding Raven SR’s Conditional Use Permit Follow Up Flag: Follow up
Flag Status: Flagged
This email originated from outside of the City's email system. Do not open links or attachments from untrusted sources.

Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza–2
nd Floor
Richmond CA 94804

[email protected]

April 12th, 2023

Dear Ms. Elias
Thank you for inviting comments concerning Raven SR’s Conditional Use Permit application and Updated IS/MND application for the construction and operation of a bioenergy facility at Republic Services West Contra Costa County Sanitary Landfill.

I am CEO of Natural Logic is a 33 year old consultancy (based in to your south in Berkeley CA), which advises companies, cities, leaders, and investors on “taking sustainability seriously, and taking it deep." Sierra Club, Communities for a Better Environment, and NRDC, among other appellants, signed a public letter on March 23, 2023 to Governor Newsom, Senate President pre Tempore Toni Atkins, and Speaker Anthony Rendon proposing criteria for the manufacture or use of hydrogen in California.

In the letter they state:
“As California considers the role of hydrogen in our decarbonized future, we urge you to enact measures that will:

1. Ensure that any hydrogen used or produced in California is produced via electrolysis through clean and renewable sources …”
The Raven SR project does not use electrolysis to produce hydrogen, but I question this criterion.

I have long maintained that regulations should be performance based (focused on results and impacts) rather than prescriptive (focused on the technical processes that companies use) wherever possible. There are at least two reasons for this perspective: (1) Governments will rarely have the technical expertise and resources to adequate evaluate the technologies in question; and (2) we want to encourage rather than discourage technical innovations that can better meet environmental, human, and economic needs.

You don't often get email from [email protected]. Learn why this is important 2 I have not studied the Raven SR Project in depth, so I cannot comment on its overall merits. But I encourage you not to use the “electrolysis only” argument as a factor in your decision making.

Sincerely,
Gil Friend
CEO, Natural Logic, Inc.

‐‐‐‐‐‐‐‐‐‐‐‐‐‐——————————————————————
Gil Philip Friend • Trimtab for Trimtabs™
Me—Now.

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

67 Responses to Letter O
–

Gil Friend

O
-
1 The comment shares differing perspectives regarding methods to produce hydrogen (use of electrolysis or not) and how regulations should be framed. The comment

does not raise a significant environmental
issue, concerns about the environmental analyses, or information in the IS/MND. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the IS/M
ND and the proposed Project.

________________________

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

68 This page is purposefully blank.

1 Lydia Elias
From: Lazuli Trujano <[email protected]>
Sent: Tuesday, April 11, 2023 7:09 PM
To: Lydia Elias
Subject: Raven SR Project
Follow Up Flag: Follow up
Flag Status: Flagged
This email originated from outside of the City's email system. Do not open links or attachments from untrusted sources.

4/11/2023
To Lydia Elias, Richmond City Planner,
Thank you for the opportunity to comment on the Raven SR Project. I am Lazuli Trujano, a lifelong resident of Richmond. I am also the community organizer for Communities for a Better Environment, a local community- driven environmental justice organization in Richmond.

I would like to raise some concerns regarding the Raven SR Project,

1. I believe the community of Richmond deserves a better option /project in Richmond. I believe that Republic Services, the private owner of the Richmond Landfill neglected the land and the biogas engines. They have allowed for the toxic flaring of methane to go on for far too long, without any consequences or accountability.

2. I do not believe Raven SR is a better option, they will cont inue to emit greenhouse gases, PM 2.5, cancerous chemicals such as formaldehyde, all of which are issues/chemicals that Richmond residents are constantly being exposed to through other big polluters such as Chevron. We are an already overburdened community, and we deserve better. Raven SR is not better.

3. If the Raven SR project were to be approved, I demand that R aven SR invest in EV Trucks to transport the hydrogen to mitigate truck traffic pollution, an issue that is already prominent in Richmond.

4. Lastly, if the project were to be approved, I believe that t he work to construct, electrify, and operate should be locally sourced through union workers that are in Richmond and that they are paid fair wages, with health insurance/benefits, and have a safe working environment.

In summary, I do not believe the Raven SR project should be approved without a full environmental impact report (EIR). Richmond is already an overburdened community who has been facing health issues, some of which are irreversible and lead to death at the hands of companies that pollute our community for their own benefit and increase of profits. The city of Richmond should not tolerate this and should be putting the people of this community first. Thank you for taking the time to read my comment and I hope that Richmond makes the right decision.

Sincerely,
Lazuli Trujano

[Richmond Community Member and CBE Community Organizer] You don't often get email from [email protected]. Learn why this is important

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

70 Responses to Letter P
–

Lazuli

Trujano

P
-
1 The
comment refers to flaring operations at the Richmond Landfill. See Response to Comment D -
4 P
-
2 The
comment raises concern with
several emissions
the
Project
’s emissions of
greenhouse gase
s
, in
addition to concern that the potential for the
Project

to emit other cancerous chemicals, such as
formaldehyde.

See Response to Comment M
-
1 and Response to Commen
t N
-

1. P
-
3 The comment requests that
Project

invest in EV trucks to mitigate truck traffic pollution. See Response to Comment D
-

10. P
-
4 The comment raise
s topics of union hires, fair wages and benefits, and the need for safe workplace environments.

These
topics do not pertain to the potential environmental effects of the proposed Project

or other topics relevant under CEQA.

See the second bullet under Response to Comment D
-

13. P
-
5 The comment suggests that a full EIR should be prepared for the Project
. Se
e
the Consolidated Response
(starting on p. 3

of this document)
regarding
conditions

requiring preparation of a full EIR.

________________________

1 Lydia Elias
From: Anna Henry <[email protected]>
Sent: Monday, April 10, 2023 6:59 PM
To: Lydia Elias
Subject: Raven SR Project
Follow Up Flag: Follow up
Flag Status: Flagged
This email originated from outside of the City's email system. Do not open links or attachments from untrusted sources.

Dear Lydia Elias, Richmond City Planner,
Thank you for the opportunity to comment on the Raven SR Project. I am a member of Communities for a Better Environment who cares deeply about the potential impacts of the Raven SR Project on the North Richmond community.

I would like to raise points of consideration because the City has insufficiently considered this aspect of the Raven SR Project.

1. It is my understanding this type of project will be a sort of pilot, as it is not something that has been done before. I am concerned about the risks of such a project being carried out on a population that is already overburdened with air toxicity, specifically the possibility of dioxins being released.

2. The NOx emissions of the project will exceed the BAAQMD threshold. Would the city consider a production cap to limit air pollution each day?

3. How does this project fit into a just transition framework? How can Richmond invest in renewable hydrogen projects and not hydrogen projects that produce emissions?

4. What will the hydrogen be used for? Is this city confident that it will not be used for a technology that could not be powered by electricity, such as cars?

5. What policies are in place to ensure that the increased trucking is done by a fleet of electric trucks?

6. What policies are in place to protect workers on site, and ensure job opportunities are prioritizing local residents and paying fair wages?

7. What policies are in place to ensure the hydrogen would be distributed in the local economy and not simply to large corporations like Chevron (who is a major investor in Raven)?

8. What is the plan for regular operations monitoring of air quality leaks, etc? What warning systems will be in place? Does the city have the power to require temporary suspension of operations? This Project is important to me because I live with chronic health conditions that were caused by living in a toxic environment and no human should have their lives significantly negatively impacted based on their environment.

In summary, there are still many unanswered questions and unaddressed concerns regarding the Raven SR Project. I do not support the City’s conclusion in the Initial Study that this project requires only a Mitigated Negative Declaration, instead of a full Environmental Impact Review.

Thank you for engaging with this feedback.

Sincerely,
Anna Henry

You don't often get email from [email protected]. Learn why this is important

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

72 Responses to
Letter
Q
–

Anna Henry

Q
-
1 The comment
addresses risks regarding air toxicity of the
Project
, namely associated with potential
dioxin release. See Response to Comment D
-

6. Q
-
2 The comment assumes the
Project

will exceed NOx emission threshold, and that the City should consider a production cap for the
Project
. As shown in
Updated IS/MND
Ta
ble
s 4.3
-
4 and 4.3
-
5 on pages 49 and
50, respectively
, the
Project

does

not exceed the applicable NOx emissions threshold given the reductions the
Project

will effect o
n

existing LFG.

The impact is less than significant, and no mitigation measures are requ
ired.

Project
COAs
set maximum daily limits of input the
Project

facility may receive (COA #47
,
Maximum Daily Quantities
) and maximum storage capacity at any given time (COA #48 , Maximum
Storage Capacity
), which
to some extent
frame
Project

operations and associated emission
.

Q
-
3 The comment poses questions about the City
’s investment in hydrogen projects. The comment does not raise a significant environmental issue, concerns about the environmental analyses, or information in the IS/MND. Th
e comment will be included as a part of the record and made available to the decision makers prior to a final decision on the IS/MND and the proposed Project.

Q
-
4 The comment asks what the hydrogen would be used for. As stated on page 8 of the Updated IS/ MND
under Section 2.1 (
Project

Purpose), the low
-
carbon hydrogen produced from renewable feedstock would be for off
-
site use in trucks and other heavy
-
duty applications in lieu of petroleum
-
based diesel. Further,
starting on page 11
of the Updated IS/MND,
“
…
the Raven SR’s purpose is the conversion of
organic
feedstock input

to produce renewable and green hydrogen with a lower carbon intensity than could be produced using electricity from the grid…,” and “… the project’s purpose is also to contribute to the expansion of renewable hydrogen supply needed to keep pace with the expanding fuel -
cell vehicle
population and fueling capacity.”
In its letter to the City, dated
March 21, 2023
, Raven elaborated that
“other potential uses of low
-
carbon hydrogen include re
placement for
[fossil]
-
based natural gas and
[the]

manufacturing of green electro fuels.”
Consistent with the

California Air Resources Board (CARB)
2022
Scoping Plan for Achieving Carbon Neutrality
, which “
calls for accelerating the transition from
combust
ion of fossil fuels, including by increasing the use of renewable and green hydrogen in zero -
emissions vehicles, heavy
-
duty vehicles, aviation, ocean
-
going vessels, freight and passenger rail, and
industrial applications.
”

Q
-
5 The comment asks about exist
ing policies
exists to ensure increased trucking is done by a fleet of electric trucks. As discussed in
the third paragraph of
Response to Comment D
-
10, pursuant to
Project
COA #61

(Zero Emission Vehicles)
, the
Project

applicant will make reasonable effort
s to procure zero emission
vehicles/trucks, to the extent that such vehicle/trucks continue to be manufactured and are commercially available. Also, the
Project

applicant will encourage the owners of those heavy
-
duty vehicles to use them
when servicing the

Raven facility.

Project
COA #61 aligns with
several

City policies

(
i.e.
, Climate Action
Plan [CAP] Strategy TL7
Promote Low
-
Carbon Vehicles and Fuels
,
and Policy EC2.1
Climate
-
Friendly
Vehicles and Equipment
)
.

Also see the second paragraph of Response to
Comment D
-
10, which explains
that the
Project

would

result in less
-
than
-
significant impacts emissions impacts associated with the projected increase in truck trips per day (per p. 54 of the Updated IS/MND).

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

73 Q
-
6 The comment raises topics of union hires, fa
ir wages and benefits, and the need for safe workplace
environments. These topics do not pertain to the potential environmental effects of the proposed Project

or other topics relevant under CEQA. See the second bullet under Response to Comment D -

13. Q
-
7 T
he comment addresses policies to ensure the hydrogen would be distributed in the local economy and asked about major investors in the Raven. These topics do not raise significant environmental issues, concerns about the environmental analyses, or informati on in the IS/MND. The comment will be
included as a part of the record and made available to the decision makers prior to a final decision on the IS/MND and the proposed Project.

Q
-
8 The comment
asks about operations

monitoring of air quality leaks, etc, w
arning systems, and the City’s
authorization over temporary suspension of operations.

Under the heading
Safety and Controls

on page
26 of the Updated IS/ MND

in Section 2.6 (Operations)
, “Raven would initiate inspection, monitoring
maintenance procedures t
o ensure safe facility operations…Piping and vessels would be periodically scanned with infrared equipment to identify hot spots or gas leaks that may threaten safety. If hot spots or leaks were identified, immediate steps would be taken to correct or medi ate the condition.” Also s
ee
Response to Comment
D
-
12 and Consolidated Response “safety” (starting on p. 4 of this document) ,
which further detail

the
Project
’s

incorporation of best practices and expertise, including pertaining to

mitigation

pollutants an
d monitoring,
reporting, and auditing
processes.

Project
COA

#49
b

(Additional
Operati
ng Parameters Shall Include
)
explicitly states
that

the
Project

applicant

(permittee) shall “use best
management practices as specified in the approved
Re
port of Facility Information (
RFI
)

to prevent
spontaneous combustion from occurring; or any gas leakage; or any excess heat leakage,” and several other
Project

COAs specify
conditions for which
monitoring and reporting is required and
instances when

the Ci
ty
may take action to

revoke the CUP.

Q
-
9 The comment asserts that the
Project

requires a full EIR
, since unanswered questions and concerns
remain. The prior responses to this letter address the commenters questions and concerns, which support that the
Pr
oject
’s impacts identified in the Updated IS/MND are less than significant. Also see C
onsolidated Response
(starting on p. 3

of this document)
regarding
conditions

requiring preparation of a
full EIR.

________________________

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

74 This page is purp
osefully blank.

1 Lydia Elias
From: Maxim Schrogin <[email protected]>
Sent: Wednesday, April 5, 2023 8:38 PM
To: Lydia Elias
Subject: Climate change and Raven
This email originated from outside of the City's email system. Do not open links or attachments from untrusted sources.

Dear Ms Elias:

I am writing in support of the Raven SE Bioenergy Project at the Richmond landfill.

I was invited through friends to witness the successful test in Benicia of a prototype of the plant being proposed for the Richmond landfill.

I was greatly impressed by the theory of the project: converting climate‐harmful methane gas into hydrogen fuel. I was also impressed with the teamwork involving scores of engineers, scientists, and managers in several collaborating companies to do highly technical work effectively to simply make the world a better place.

I am also aware that the project faces opposition from several environmental organizations that both Raven and I respect. My understanding of their reasoning simply leads me to reject that opposition in the case of the Raven project.

Basically, their caution is about the general precautions and standards which must be addressed in any creation and use of hydrogen. We all agree with that caution. Their reasoning goes beyond that, however: they suggest prohibiting any manufacture of hydrogen other than by electrolysis. They claim that other methods which produce hydrogen contribute to climate change due to the polluting gasses that their processes produce.

In the case of Raven, the opposite is true; not only does the Raven process not emit pollutants, it actually removes polluting methane from our air.

My impression is that the well‐meaning restrictions proposed by these groups is shortsighted and was perhaps formed even before they were aware of the work done by Raven. Such blanket limitation can inhibit the kind of innovation that Raven represents and that is badly needed on all fronts to combat human contribution to climate change. Until I am shown that the net effect of efforts such as the Bioenergy Project are detrimental to our efforts in that arena, I remain a staunch supporter. I hope that you and Richmond agree with my reasoning.

mds
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RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

76 Responses to Letter R
–

Maxim
S
chrog
in

R
-
1 The comment is in support of the proposed
Project

and notes
Project

benefits
regarding
pollutant

emissions.

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.

________________________

Re: Raven SR Project
To Lydia Elias, Richmond City Planner
I am grateful for the opportunity to comment on the proposed Raven SR Project. I study Politics and Urban and Environmental Policy at Occidental College. I am a fifth-generation Bay Area resident, with deep family roots in North Richmond. North Richmond is where my grandparents met, it is where my parents met, it is where I was raised for most of my life, it is my home. If approved, the Raven SR Project would be located less than two miles away from my family’s house.

I would like to raise concerns regarding the Raven SR Project, which has the potential to negatively impact North Richmond and surrounding communities: Despite claims that Raven SR would be a decrease in emissions compared to the methane currently emitted at the proposed site, there are still community concerns around truck traffic, potential for accidents, labor practices and the cumulative impact of persistent GHG emissions.

1. First, I would like to see the city require Raven SR to commit to zero emission trucks. In addition to the emissions of their hydrogen facility, there is also reason to be concerned about the effect of increased truck traffic on the air quality. According to a 2020 report by the California Air Resources Board, trucks are the largest single source of vehicular air pollution, “responsible for 70 percent of the smog-causing pollution and 80 percent of carcinogenic diesel soot even though they number only 2 million among the 30 million registered vehicles in the state.” 1 How many trucks is Raven SR planning to send out in a day? Truck pollution has been proved to have an outsized, detrimental impact on air quality, making a requirement of zero-emission truck transportation a necessity for the respiratory health of our community.

2. Second, I would like to see the city require Raven SR, in collaboration with community members, to put in place hydrogen fuel cell workplace safety standards that are routinely monitored. Hydrogen is notoriously flammable and can be explosive if mishandled. As noted by the U.S. Occupational Safety and Health Administration (OSHA), “hydrogen is colorless, odorless and tasteless… by the time a worker smells an odorant, the hydrogen concentrations might have already exceeded its lower flammability limit” 2 In other words, not only is hydrogen flammable, but detecting the risk of flammability is delayed due to the nature of the gas—making proper workplace standards a necessity to ensure the safety of workers and residents. OSHA has compiled standards that are applicable to workplaces where hydrogen is stored, used and/or produced; I would like to see regular monitoring of operations (to ensure that these guidelines are being followed) and a requirement of community involvement in developing these standards further in order to protect workers and residents. 3

3. Third, since this project would be located in North Richmond, are there currently plans to ensure that jobs are offered to community members? Has Raven SR made any labor practice commitments regarding wages and benefits? As a community member of North Richmond, I want to see Raven SR—with strong encouragement from the city of Richmond—commit to a local hire plan of North Richmond and Richmond residents 3 Ibid.
2 “Green Job Hazards - Hydrogen Fuel Cells: Fire and Explosion | Occupational Safety and Health Administration.” Accessed April 11, 2023. https://www.osha.gov/green-jobs/hydrogen/fire-explosion . 1 “California Takes Bold Step to Reduce Truck Pollution | California Air Resources Board.” Accessed April 11, 2023. https://ww2.arb.ca.gov/news/california-takes-bold-step-reduce-truck-pollution . more broadly. Raven has made labor agreements for construction workers, but what about employees who operate the plant? I would like to see a requirement of either union labor or paying workers prevailing wages (where non-union workers are paid union wages). The Raven SR Project not only has a responsibility to those living around the facility, but also a responsibility to the workers who operate it.

4. Lastly, while it has been suggested that the Raven SR Project would produce less emissions than the proposed site already emits, it is important to acknowledge that this hydrogen production facility is still a pollution producer. The effects of this facility's emissions will also be compounded by the presence of a nearby refinery, further negatively impacting surrounding residents. I would like to see the city require Raven SR to invest in community resources as a way of offsetting harm. If Raven SR is going to profit off of Richmond’s land, I believe that it is reasonable to require an investment in our community; the relationship between Raven SR and the city of Richmond should be reciprocal, not depleting. This could look like health care investments and STEM program funding for local high schools (like Richmond and Kennedy High). It is imperative that Raven SR acknowledges the importance of a mutually beneficial project while operating in North Richmond, by committing to community benefits agreements.

In summary, I would like to see the city require Raven SR’s commitment to zero-emission trucks, rigorous workplace health and safety standards, fair labor practices for plant operators, and community investments. At every level, community members should be invited to participate and collaborate in the development of these standards. As a community member, as someone whose loved ones live on this land and breathe this air, I would like to see the city of Richmond conduct a full Environmental Impact Review (EIR), to reckon with the full environmental and health implications of this proposed plant in order to keep residents and families like mine, safe.

Sincerely,
Sunari Weaver-Anderson
North Richmond Community Member & Occidental College Student (Class of 2024)

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

79 Responses to
Le
tter
S

–

Sunari

Weaver
-
Anderson

S
-
1 The comment
is an introductory statement regarding
ongoing community concerns around truck traffic,
potential for accidents,
labor concerns,
and cumulative impacts of
greenhouse gas

emissions.

Each topic
is addressed in
the following responses.

S
-
2 The comment
requests that

the City require the
Project

to commit to
zero

emissions trucks, and asks
about the number of trips associated with the
Project
. See Response to Comment D
-
10 ,

which addresses
both topics.

S
-
3 The comme
nt addresses the existence and regular monitoring of workplace safety

standards

and calls for
community involvement in developing such standards
. The comment also
raises

concern

about the
explosive and
flammability risk of hydrogen
. S
ee Response

to Comment D
-
12 and Consolidated
Response “safety” (starting on p. 4 of this document)

which address th
is

concern
.

S
-
4 The comment asks about a local hire plan,
Project

jobs offered to the local community (North
Richmond), labor wages and benefits, f
or
Project

workers in addition to construction workers. As stated
in the first bullet under Response to Comment D
-
13, the
Project

applicant has already signed a project
labor agreement with the unions and will be offering two internships per year to trade or community
college students. This topic does not pertain to the potential environmental effects of the proposed Project

or other topics relevant under CEQA. Nonetheless, the following addresses each community benefit that CBE has identified.

S
-
5 The com
ments requests that the City requires the
Project

applicant to invest in community resources and
providing community benefits as a way of offsetting the Project
’s emissions effects.

This topic also does
not pertain to the potential environmental effects of

the proposed
Project

or other topics relevant under
CEQA.

See Response to Comment D
-

13. S
-
6 The closing comment restates the topics of concern raised and responded to in this letter and requests preparation of a full EIR. See
the Consolidated Response
(st
arting on p. 3

of this document)

regarding
conditions

requiring preparation of a full EIR.

________________________

RESPONSE TO COMMENTS Received on the Updated Raven SR Bioenergy Project Initial Study / Mitigated

Negative Declaration

80 This page is purposefully blank.

ATTACHMENT

1 (
to
Comment D
-
5 )

–

W
est Contra Costa Sanitary
Landfill (WCCSL)
Summary Report (202
1 -
2070
)

This page is purposefully b
lank.

WCCSL_landgem-v302_SCS_7-20-21 Draft 7/20/2021
Summary Report
Landfill Name or Identifier: West Contra Costa Sanitary LF (Class II) Date:

First-Order Decomposition Rate Equation:

Where,
QCH4 = annual methane generation in the year of the calculation (m 3 /year ) i = 1-year time increment Mi = mass of waste accepted in the ith year (Mg ) n = (year of the calculation) - (initial year of waste acceptance) j = 0.1-year time increment
k = methane generation rate (year -1 )
Lo = potential methane generation capacity (m 3 /Mg )
tij = age of the jth section of waste mass Mi accepted in the ith year (decimal years , e.g., 3.2 years)
LandGEM is considered a screening tool — the better the input data, the better the estimates. Often, there are limitations with the available data regarding waste quantity and composition, variation in design and operating practices over time, and changes occurring over time that impact the emissions potential. Changes to landfill operation, such as operating under wet conditions through leachate recirculation or other liquid additions, will result in generating more gas at a faster rate. Defaults for estimating emissions for this type of operation are being developed to include in LandGEM along with defaults for convential landfills (no leachate or liquid additions) for developing emission inventories and determining CAA applicability. Refer to the Web site identified above for future updates.

Tuesday, July 20, 2021
LandGEM is based on a first-order decomposition rate equation for quantifying emissions from the decomposition of landfilled waste in municipal solid waste (MSW) landfills. The software provides a relatively simple approach to estimating landfill gas emissions. Model defaults are based on empirical data from U.S. landfills. Field test data can also be used in place of model defaults when available. Further guidance on EPA test methods, Clean Air Act (CAA) regulations, and other guidance regarding landfill gas emissions and control technology requirements can be found at http://www.epa.gov/ttnatw01/landfill/landflpg.html.

Description/Comments:

About LandGEM:

REPORT - 1
WCCSL_landgem-v302_SCS_7-20-21 Draft 7/20/2021
Input Review

LANDFILL CHARACTERISTICS
Landfill Open Year 1955
Landfill Closure Year (with 80-year limit) 2006
Actual Closure Year (without limit) 2006
Have Model Calculate Closure Year? No
Waste Design Capacity short tons

MODEL PARAMETERS
Methane Generation Rate, k 0.020 year -1
Potential Methane Generation Capacity, Lo 100 m 3 /Mg
NMOC Concentration 600 ppmv as hexane
Methane Content 50 % by volume

GASES / POLLUTANTS SELECTED
Gas / Pollutant #1: Total landfill gas
Gas / Pollutant #2: Methane
Gas / Pollutant #3: Carbon dioxide
Gas / Pollutant #4: NMOC

WASTE ACCEPTANCE RATES
(Mg/year) (short tons/year) (Mg) (short tons)
1955 104,727 115,200 0 0
1956 107,869 118,656 104,727 115,200
1957 111,105 122,216 212,596 233,856
1958 114,438 125,882 323,702 356,072
1959 117,872 129,659 438,140 481,954
1960 121,407 133,548 556,012 611,613
1961 125,050 137,555 677,419 745,161
1962 128,801 141,681 802,469 882,716
1963 132,665 145,932 931,270 1,024,397
1964 136,645 150,310 1,063,935 1,170,329
1965 140,745 154,819 1,200,581 1,320,639
1966 144,967 159,464 1,341,325 1,475,458
1967 149,316 164,248 1,486,293 1,634,922
1968 153,795 169,175 1,635,609 1,799,170
1969 158,409 174,250 1,789,405 1,968,345
1970 163,162 179,478 1,947,814 2,142,595
1971 168,056 184,862 2,110,975 2,322,073
1972 173,098 190,408 2,279,032 2,506,935
1973 178,291 196,120 2,452,130 2,697,343
1974 183,640 202,004 2,630,421 2,893,463
1975 189,149 208,064 2,814,061 3,095,467
1976 194,824 214,306 3,003,210 3,303,531
1977 200,668 220,735 3,198,034 3,517,837
1978 206,688 227,357 3,398,702 3,738,572
1979 212,889 234,178 3,605,390 3,965,929
1980 219,275 241,203 3,818,279 4,200,107
1981 225,854 248,439 4,037,555 4,441,310
1982 231,388 254,527 4,263,408 4,689,749
1983 238,909 262,800 4,494,796 4,944,276
1984 366,000 402,600 4,733,705 5,207,076
1985 283,818 312,200 5,099,705 5,609,676
1986 305,153 335,668 5,383,524 5,921,876
1987 303,868 334,255 5,688,676 6,257,544
1988 312,636 343,900 5,992,545 6,591,799
1989 312,955 344,250 6,305,181 6,935,699
1990 292,767 322,044 6,618,135 7,279,949
1991 240,245 264,270 6,910,903 7,601,993
1992 205,272 225,799 7,151,148 7,866,263
1993 228,399 251,239 7,356,420 8,092,062
1994 256,097 281,707 7,584,819 8,343,301
Year Waste Accepted Waste-In-Place
REPORT - 2
WCCSL_landgem-v302_SCS_7-20-21 Draft 7/20/2021
WASTE ACCEPTANCE RATES (Continued)
(Mg/year) (short tons/year) (Mg) (short tons)
1995 327,766 360,543 7,840,916 8,625,008
1996 281,256 309,382 8,168,683 8,985,551
1997 225,492 248,041 8,449,939 9,294,933
1998 249,703 274,673 8,675,431 9,542,974
1999 255,903 281,493 8,925,134 9,817,647
2000 255,393 280,932 9,181,036 10,099,140
2001 300,380 330,418 9,436,429 10,380,072
2002 278,266 306,093 9,736,809 10,710,490
2003 264,623 291,085 10,015,075 11,016,583
2004 275,420 302,962 10,279,698 11,307,668
2005 376,676 414,344 10,555,118 11,610,630
2006 277,647 305,412 10,931,795 12,024,974
2007 0 0 11,209,442 12,330,386
2008 0 0 11,209,442 12,330,386
2009 0 0 11,209,442 12,330,386
2010 0 0 11,209,442 12,330,386
2011 0 0 11,209,442 12,330,386
2012 0 0 11,209,442 12,330,386
2013 0 0 11,209,442 12,330,386
2014 0 0 11,209,442 12,330,386
2015 0 0 11,209,442 12,330,386
2016 0 0 11,209,442 12,330,386
2017 0 0 11,209,442 12,330,386
2018 0 0 11,209,442 12,330,386
2019 0 0 11,209,442 12,330,386
2020 0 0 11,209,442 12,330,386
2021 0 0 11,209,442 12,330,386
2022 0 0 11,209,442 12,330,386
2023 0 0 11,209,442 12,330,386
2024 0 0 11,209,442 12,330,386
2025 0 0 11,209,442 12,330,386
2026 0 0 11,209,442 12,330,386
2027 0 0 11,209,442 12,330,386
2028 0 0 11,209,442 12,330,386
2029 0 0 11,209,442 12,330,386
2030 0 0 11,209,442 12,330,386
2031 0 0 11,209,442 12,330,386
2032 0 0 11,209,442 12,330,386
2033 0 0 11,209,442 12,330,386
2034 0 0 11,209,442 12,330,386
Year Waste Accepted Waste-In-Place
REPORT - 3
WCCSL_landgem-v302_SCS_7-20-21 Draft 7/20/2021
Pollutant Parameters
Concentration Concentration
Compound (ppmv ) Molecular Weight (ppmv ) Molecular Weight Total landfill gas 0.00
Methane 16.04
Carbon dioxide 44.01
NMOC 4,000 86.18
1,1,1-Trichloroethane
(methyl chloroform) -
HAP 0.48 133.41
1,1,2,2-
Tetrachloroethane -
HAP/VOC 1.1 167.85
1,1-Dichloroethane
(ethylidene dichloride) -
HAP/VOC 2.4 98.97
1,1-Dichloroethene
(vinylidene chloride) -
HAP/VOC 0.20 96.94
1,2-Dichloroethane
(ethylene dichloride) -
HAP/VOC 0.41 98.96
1,2-Dichloropropane
(propylene dichloride) -
HAP/VOC 0.18 112.99
2-Propanol (isopropyl
alcohol) - VOC 50 60.11
Acetone 7.0 58.08
Acrylonitrile - HAP/VOC 6.3 53.06
Benzene - No or
Unknown Co-disposal -
HAP/VOC 1.9 78.11
Benzene - Co-disposal -
HAP/VOC 11 78.11
Bromodichloromethane -
VOC 3.1 163.83
Butane - VOC 5.0 58.12
Carbon disulfide -
HAP/VOC 0.58 76.13
Carbon monoxide 140 28.01
Carbon tetrachloride -
HAP/VOC 4.0E-03 153.84
Carbonyl sulfide -
HAP/VOC 0.49 60.07
Chlorobenzene -
HAP/VOC 0.25 112.56
Chlorodifluoromethane 1.3 86.47
Chloroethane (ethyl
chloride) - HAP/VOC 1.3 64.52
Chloroform - HAP/VOC 0.03 119.39
Chloromethane - VOC 1.2 50.49
Dichlorobenzene - (HAP
for para isomer/VOC) 0.21 147
Dichlorodifluoromethane 16 120.91
Dichlorofluoromethane -
VOC 2.6 102.92
Dichloromethane
(methylene chloride) -
HAP 14 84.94
Dimethyl sulfide (methyl
sulfide) - VOC 7.8 62.13
Ethane 890 30.07
Ethanol - VOC 27 46.08
Gas / Pollutant Default Parameters:

Pollutants
User-specified Pollutant Parameters:

Gases
REPORT - 4
WCCSL_landgem-v302_SCS_7-20-21 Draft 7/20/2021
Pollutant Parameters (Continued)
Concentration Concentration
Compound (ppmv ) Molecular Weight (ppmv ) Molecular Weight Ethyl mercaptan
(ethanethiol) - VOC 2.3 62.13
Ethylbenzene -
HAP/VOC 4.6 106.16
Ethylene dibromide -
HAP/VOC 1.0E-03 187.88
Fluorotrichloromethane -
VOC 0.76 137.38
Hexane - HAP/VOC 6.6 86.18
Hydrogen sulfide 36 34.08
Mercury (total) - HAP 2.9E-04 200.61
Methyl ethyl ketone -
HAP/VOC 7.1 72.11
Methyl isobutyl ketone -
HAP/VOC 1.9 100.16
Methyl mercaptan - VOC 2.5 48.11
Pentane - VOC 3.3 72.15
Perchloroethylene
(tetrachloroethylene) -
HAP 3.7 165.83
Propane - VOC 11 44.09
t-1,2-Dichloroethene -
VOC 2.8 96.94
Toluene - No or
Unknown Co-disposal -
HAP/VOC 39 92.13
Toluene - Co-disposal -
HAP/VOC 170 92.13
Trichloroethylene
(trichloroethene) -
HAP/VOC 2.8 131.40
Vinyl chloride -
HAP/VOC 7.3 62.50
Xylenes - HAP/VOC 12 106.16
User-specified Pollutant Parameters:Gas / Pollutant Default Parameters:

Pollutants
REPORT - 5
WCCSL_landgem-v302_SCS_7-20-21 Draft 7/20/2021
REPORT - 6
WCCSL_landgem-v302_SCS_7-20-21 Draft 7/20/2021
Graphs

0.000E+00

5.000E+03

1.000E+04

1.500E+04

2.000E+04

2.500E+04

3.000E+04

3.500E+04

4.000E+04
Emissions
Year
Megagrams Per Year
Total landfill gas Methane Carbon dioxide NMOC

0.000E+00

5.000E+06

1.000E+07

1.500E+07

2.000E+07

2.500E+07

3.000E+07

3.500E+07
Emissions
Year
Cubic Meters Per Year
Total landfill gas Methane Carbon dioxide NMOC

0.000E+00

5.000E+02

1.000E+03

1.500E+03

2.000E+03

2.500E+03
Emissions
Year
User-specified Unit (units shown in legend below)
Total landfill gas (av ft^3/min) Methane (av ft^3/min)
Carbon dioxide (av ft^3/min) NMOC (av ft^3/min)
REPORT - 7
WCCSL_landgem-v302_SCS_7-20-21 Draft 7/20/2021
Results
(Mg/year) (m 3 /year) (av ft^3/min) (Mg/year) (m 3 /year) (av ft^3/min) 1955 0 00000
1956 5.185E+02 4.152E+05 2.789E+01 1.385E+02 2.076E+05 1.395E+01 1957 1.042E+03 8.346E+05 5.607E+01 2.784E+02 4.173E+05 2.804E+01 1958 1.572E+03 1.258E+06 8.456E+01 4.198E+02 6.292E+05 4.228E+01 1959 2.107E+03 1.687E+06 1.134E+02 5.628E+02 8.436E+05 5.668E+01 1960 2.649E+03 2.121E+06 1.425E+02 7.075E+02 1.061E+06 7.126E+01 1961 3.197E+03 2.560E+06 1.720E+02 8.541E+02 1.280E+06 8.602E+01 1962 3.753E+03 3.005E+06 2.019E+02 1.003E+03 1.503E+06 1.010E+02 1963 4.317E+03 3.456E+06 2.322E+02 1.153E+03 1.728E+06 1.161E+02 1964 4.888E+03 3.914E+06 2.630E+02 1.306E+03 1.957E+06 1.315E+02 1965 5.468E+03 4.378E+06 2.942E+02 1.460E+03 2.189E+06 1.471E+02 1966 6.056E+03 4.849E+06 3.258E+02 1.618E+03 2.425E+06 1.629E+02 1967 6.654E+03 5.328E+06 3.580E+02 1.777E+03 2.664E+06 1.790E+02 1968 7.261E+03 5.814E+06 3.907E+02 1.940E+03 2.907E+06 1.953E+02 1969 7.879E+03 6.309E+06 4.239E+02 2.105E+03 3.155E+06 2.120E+02 1970 8.507E+03 6.812E+06 4.577E+02 2.272E+03 3.406E+06 2.289E+02 1971 9.146E+03 7.324E+06 4.921E+02 2.443E+03 3.662E+06 2.460E+02 1972 9.797E+03 7.845E+06 5.271E+02 2.617E+03 3.923E+06 2.636E+02 1973 1.046E+04 8.376E+06 5.628E+02 2.794E+03 4.188E+06 2.814E+02 1974 1.114E+04 8.917E+06 5.991E+02 2.974E+03 4.458E+06 2.996E+02 1975 1.182E+04 9.468E+06 6.362E+02 3.158E+03 4.734E+06 3.181E+02 1976 1.253E+04 1.003E+07 6.740E+02 3.346E+03 5.015E+06 3.370E+02 1977 1.324E+04 1.060E+07 7.125E+02 3.537E+03 5.302E+06 3.563E+02 1978 1.397E+04 1.119E+07 7.519E+02 3.733E+03 5.595E+06 3.759E+02 1979 1.472E+04 1.179E+07 7.920E+02 3.932E+03 5.894E+06 3.960E+02 1980 1.548E+04 1.240E+07 8.330E+02 4.136E+03 6.199E+06 4.165E+02 1981 1.626E+04 1.302E+07 8.749E+02 4.344E+03 6.511E+06 4.375E+02 1982 1.706E+04 1.366E+07 9.178E+02 4.556E+03 6.830E+06 4.589E+02 1983 1.787E+04 1.431E+07 9.612E+02 4.772E+03 7.153E+06 4.806E+02 1984 1.870E+04 1.497E+07 1.006E+03 4.994E+03 7.485E+06 5.029E+02 1985 2.014E+04 1.612E+07 1.083E+03 5.379E+03 8.062E+06 5.417E+02 1986 2.114E+04 1.693E+07 1.138E+03 5.648E+03 8.465E+06 5.688E+02 1987 2.224E+04 1.780E+07 1.196E+03 5.939E+03 8.902E+06 5.982E+02 1988 2.330E+04 1.866E+07 1.254E+03 6.223E+03 9.328E+06 6.268E+02 1989 2.439E+04 1.953E+07 1.312E+03 6.514E+03 9.763E+06 6.560E+02 1990 2.545E+04 2.038E+07 1.369E+03 6.799E+03 1.019E+07 6.847E+02 1991 2.640E+04 2.114E+07 1.420E+03 7.051E+03 1.057E+07 7.101E+02 1992 2.706E+04 2.167E+07 1.456E+03 7.229E+03 1.084E+07 7.281E+02 1993 2.754E+04 2.206E+07 1.482E+03 7.357E+03 1.103E+07 7.410E+02 1994 2.813E+04 2.252E+07 1.513E+03 7.514E+03 1.126E+07 7.567E+02 1995 2.884E+04 2.309E+07 1.552E+03 7.704E+03 1.155E+07 7.758E+02 1996 2.989E+04 2.394E+07 1.608E+03 7.985E+03 1.197E+07 8.041E+02 1997 3.069E+04 2.458E+07 1.651E+03 8.198E+03 1.229E+07 8.257E+02 1998 3.120E+04 2.498E+07 1.679E+03 8.334E+03 1.249E+07 8.394E+02 1999 3.182E+04 2.548E+07 1.712E+03 8.499E+03 1.274E+07 8.560E+02 2000 3.246E+04 2.599E+07 1.746E+03 8.669E+03 1.299E+07 8.731E+02 2001 3.308E+04 2.649E+07 1.780E+03 8.835E+03 1.324E+07 8.898E+02 2002 3.391E+04 2.715E+07 1.824E+03 9.058E+03 1.358E+07 9.122E+02 2003 3.462E+04 2.772E+07 1.862E+03 9.246E+03 1.386E+07 9.312E+02 2004 3.524E+04 2.822E+07 1.896E+03 9.413E+03 1.411E+07 9.480E+02 Year Total landfill gas Methane
REPORT - 8
WCCSL_landgem-v302_SCS_7-20-21 Draft 7/20/2021
Results (Continued)
(Mg/year) (m 3 /year) (av ft^3/min) (Mg/year) (m 3 /year) (av ft^3/min) 2005 3.591E+04 2.875E+07 1.932E+03 9.591E+03 1.438E+07 9.659E+02 2006 3.706E+04 2.968E+07 1.994E+03 9.899E+03 1.484E+07 9.970E+02 2007 3.770E+04 3.019E+07 2.028E+03 1.007E+04 1.509E+07 1.014E+03 2008 3.695E+04 2.959E+07 1.988E+03 9.871E+03 1.480E+07 9.941E+02 2009 3.622E+04 2.901E+07 1.949E+03 9.675E+03 1.450E+07 9.744E+02 2010 3.551E+04 2.843E+07 1.910E+03 9.484E+03 1.422E+07 9.551E+02 2011 3.480E+04 2.787E+07 1.872E+03 9.296E+03 1.393E+07 9.362E+02 2012 3.411E+04 2.732E+07 1.835E+03 9.112E+03 1.366E+07 9.177E+02 2013 3.344E+04 2.678E+07 1.799E+03 8.932E+03 1.339E+07 8.995E+02 2014 3.278E+04 2.625E+07 1.763E+03 8.755E+03 1.312E+07 8.817E+02 2015 3.213E+04 2.573E+07 1.728E+03 8.581E+03 1.286E+07 8.642E+02 2016 3.149E+04 2.522E+07 1.694E+03 8.411E+03 1.261E+07 8.471E+02 2017 3.087E+04 2.472E+07 1.661E+03 8.245E+03 1.236E+07 8.304E+02 2018 3.026E+04 2.423E+07 1.628E+03 8.082E+03 1.211E+07 8.139E+02 2019 2.966E+04 2.375E+07 1.596E+03 7.922E+03 1.187E+07 7.978E+02 2020 2.907E+04 2.328E+07 1.564E+03 7.765E+03 1.164E+07 7.820E+02 2021 2.849E+04 2.282E+07 1.533E+03 7.611E+03 1.141E+07 7.665E+02 2022 2.793E+04 2.236E+07 1.503E+03 7.460E+03 1.118E+07 7.513E+02 2023 2.738E+04 2.192E+07 1.473E+03 7.313E+03 1.096E+07 7.365E+02 2024 2.683E+04 2.149E+07 1.444E+03 7.168E+03 1.074E+07 7.219E+02 2025 2.630E+04 2.106E+07 1.415E+03 7.026E+03 1.053E+07 7.076E+02 2026 2.578E+04 2.065E+07 1.387E+03 6.887E+03 1.032E+07 6.936E+02 2027 2.527E+04 2.024E+07 1.360E+03 6.750E+03 1.012E+07 6.798E+02 2028 2.477E+04 1.984E+07 1.333E+03 6.617E+03 9.918E+06 6.664E+02 2029 2.428E+04 1.944E+07 1.306E+03 6.486E+03 9.721E+06 6.532E+02 2030 2.380E+04 1.906E+07 1.281E+03 6.357E+03 9.529E+06 6.403E+02 2031 2.333E+04 1.868E+07 1.255E+03 6.231E+03 9.340E+06 6.276E+02 2032 2.287E+04 1.831E+07 1.230E+03 6.108E+03 9.155E+06 6.151E+02 2033 2.241E+04 1.795E+07 1.206E+03 5.987E+03 8.974E+06 6.030E+02 2034 2.197E+04 1.759E+07 1.182E+03 5.868E+03 8.796E+06 5.910E+02 2035 2.154E+04 1.724E+07 1.159E+03 5.752E+03 8.622E+06 5.793E+02 2036 2.111E+04 1.690E+07 1.136E+03 5.638E+03 8.451E+06 5.679E+02 2037 2.069E+04 1.657E+07 1.113E+03 5.527E+03 8.284E+06 5.566E+02 2038 2.028E+04 1.624E+07 1.091E+03 5.417E+03 8.120E+06 5.456E+02 2039 1.988E+04 1.592E+07 1.070E+03 5.310E+03 7.959E+06 5.348E+02 2040 1.949E+04 1.560E+07 1.048E+03 5.205E+03 7.802E+06 5.242E+02 2041 1.910E+04 1.529E+07 1.028E+03 5.102E+03 7.647E+06 5.138E+02 2042 1.872E+04 1.499E+07 1.007E+03 5.001E+03 7.496E+06 5.036E+02 2043 1.835E+04 1.469E+07 9.873E+02 4.902E+03 7.347E+06 4.937E+02 2044 1.799E+04 1.440E+07 9.678E+02 4.805E+03 7.202E+06 4.839E+02 2045 1.763E+04 1.412E+07 9.486E+02 4.710E+03 7.059E+06 4.743E+02 2046 1.728E+04 1.384E+07 9.298E+02 4.616E+03 6.919E+06 4.649E+02 2047 1.694E+04 1.356E+07 9.114E+02 4.525E+03 6.782E+06 4.557E+02 2048 1.660E+04 1.330E+07 8.934E+02 4.435E+03 6.648E+06 4.467E+02 2049 1.628E+04 1.303E+07 8.757E+02 4.347E+03 6.516E+06 4.378E+02 2050 1.595E+04 1.277E+07 8.583E+02 4.261E+03 6.387E+06 4.292E+02 2051 1.564E+04 1.252E+07 8.413E+02 4.177E+03 6.261E+06 4.207E+02 2052 1.533E+04 1.227E+07 8.247E+02 4.094E+03 6.137E+06 4.123E+02 2053 1.502E+04 1.203E+07 8.084E+02 4.013E+03 6.015E+06 4.042E+02 2054 1.473E+04 1.179E+07 7.924E+02 3.934E+03 5.896E+06 3.962E+02 2055 1.444E+04 1.156E+07 7.767E+02 3.856E+03 5.780E+06 3.883E+02 Total landfill gasYear Methane
REPORT - 9
WCCSL_landgem-v302_SCS_7-20-21 Draft 7/20/2021
Results (Continued)
(Mg/year) (m 3 /year) (av ft^3/min) (Mg/year) (m 3 /year) (av ft^3/min) 2056 1.415E+04 1.133E+07 7.613E+02 3.780E+03 5.665E+06 3.806E+02 2057 1.387E+04 1.111E+07 7.462E+02 3.705E+03 5.553E+06 3.731E+02 2058 1.359E+04 1.089E+07 7.314E+02 3.631E+03 5.443E+06 3.657E+02 2059 1.333E+04 1.067E+07 7.170E+02 3.559E+03 5.335E+06 3.585E+02 2060 1.306E+04 1.046E+07 7.028E+02 3.489E+03 5.230E+06 3.514E+02 2061 1.280E+04 1.025E+07 6.888E+02 3.420E+03 5.126E+06 3.444E+02 2062 1.255E+04 1.005E+07 6.752E+02 3.352E+03 5.025E+06 3.376E+02 2063 1.230E+04 9.850E+06 6.618E+02 3.286E+03 4.925E+06 3.309E+02 2064 1.206E+04 9.655E+06 6.487E+02 3.221E+03 4.828E+06 3.244E+02 2065 1.182E+04 9.464E+06 6.359E+02 3.157E+03 4.732E+06 3.179E+02 2066 1.158E+04 9.276E+06 6.233E+02 3.094E+03 4.638E+06 3.116E+02 2067 1.136E+04 9.093E+06 6.109E+02 3.033E+03 4.546E+06 3.055E+02 2068 1.113E+04 8.913E+06 5.988E+02 2.973E+03 4.456E+06 2.994E+02 2069 1.091E+04 8.736E+06 5.870E+02 2.914E+03 4.368E+06 2.935E+02 2070 1.069E+04 8.563E+06 5.754E+02 2.856E+03 4.282E+06 2.877E+02 2071 1.048E+04 8.394E+06 5.640E+02 2.800E+03 4.197E+06 2.820E+02 2072 1.027E+04 8.228E+06 5.528E+02 2.744E+03 4.114E+06 2.764E+02 2073 1.007E+04 8.065E+06 5.419E+02 2.690E+03 4.032E+06 2.709E+02 2074 9.872E+03 7.905E+06 5.311E+02 2.637E+03 3.952E+06 2.656E+02 2075 9.676E+03 7.748E+06 5.206E+02 2.585E+03 3.874E+06 2.603E+02 2076 9.485E+03 7.595E+06 5.103E+02 2.533E+03 3.797E+06 2.552E+02 2077 9.297E+03 7.445E+06 5.002E+02 2.483E+03 3.722E+06 2.501E+02 2078 9.113E+03 7.297E+06 4.903E+02 2.434E+03 3.649E+06 2.451E+02 2079 8.932E+03 7.153E+06 4.806E+02 2.386E+03 3.576E+06 2.403E+02 2080 8.756E+03 7.011E+06 4.711E+02 2.339E+03 3.506E+06 2.355E+02 2081 8.582E+03 6.872E+06 4.617E+02 2.292E+03 3.436E+06 2.309E+02 2082 8.412E+03 6.736E+06 4.526E+02 2.247E+03 3.368E+06 2.263E+02 2083 8.246E+03 6.603E+06 4.436E+02 2.203E+03 3.301E+06 2.218E+02 2084 8.082E+03 6.472E+06 4.349E+02 2.159E+03 3.236E+06 2.174E+02 2085 7.922E+03 6.344E+06 4.262E+02 2.116E+03 3.172E+06 2.131E+02 2086 7.765E+03 6.218E+06 4.178E+02 2.074E+03 3.109E+06 2.089E+02 2087 7.612E+03 6.095E+06 4.095E+02 2.033E+03 3.048E+06 2.048E+02 2088 7.461E+03 5.974E+06 4.014E+02 1.993E+03 2.987E+06 2.007E+02 2089 7.313E+03 5.856E+06 3.935E+02 1.953E+03 2.928E+06 1.967E+02 2090 7.168E+03 5.740E+06 3.857E+02 1.915E+03 2.870E+06 1.928E+02 2091 7.026E+03 5.626E+06 3.780E+02 1.877E+03 2.813E+06 1.890E+02 2092 6.887E+03 5.515E+06 3.706E+02 1.840E+03 2.758E+06 1.853E+02 2093 6.751E+03 5.406E+06 3.632E+02 1.803E+03 2.703E+06 1.816E+02 2094 6.617E+03 5.299E+06 3.560E+02 1.768E+03 2.649E+06 1.780E+02 2095 6.486E+03 5.194E+06 3.490E+02 1.733E+03 2.597E+06 1.745E+02 Year Total landfill gas Methane
REPORT - 10
WCCSL_landgem-v302_SCS_7-20-21 Draft 7/20/2021
Results (Continued)
Year
(Mg/year) (m 3 /year) (av ft^3/min) (Mg/year) (m 3 /year) (av ft^3/min) 1955 0 00000
1956 3.800E+02 2.076E+05 1.395E+01 8.929E-01 2.491E+02 1.674E-02 1957 7.638E+02 4.173E+05 2.804E+01 1.795E+00 5.007E+02 3.364E-02 1958 1.152E+03 6.292E+05 4.228E+01 2.707E+00 7.551E+02 5.073E-02 1959 1.544E+03 8.436E+05 5.668E+01 3.629E+00 1.012E+03 6.802E-02 1960 1.941E+03 1.061E+06 7.126E+01 4.562E+00 1.273E+03 8.551E-02 1961 2.343E+03 1.280E+06 8.602E+01 5.507E+00 1.536E+03 1.032E-01 1962 2.751E+03 1.503E+06 1.010E+02 6.464E+00 1.803E+03 1.212E-01 1963 3.164E+03 1.728E+06 1.161E+02 7.434E+00 2.074E+03 1.393E-01 1964 3.582E+03 1.957E+06 1.315E+02 8.418E+00 2.348E+03 1.578E-01 1965 4.007E+03 2.189E+06 1.471E+02 9.416E+00 2.627E+03 1.765E-01 1966 4.438E+03 2.425E+06 1.629E+02 1.043E+01 2.910E+03 1.955E-01 1967 4.876E+03 2.664E+06 1.790E+02 1.146E+01 3.197E+03 2.148E-01 1968 5.322E+03 2.907E+06 1.953E+02 1.251E+01 3.489E+03 2.344E-01 1969 5.774E+03 3.155E+06 2.120E+02 1.357E+01 3.785E+03 2.543E-01 1970 6.235E+03 3.406E+06 2.289E+02 1.465E+01 4.087E+03 2.746E-01 1971 6.703E+03 3.662E+06 2.460E+02 1.575E+01 4.394E+03 2.953E-01 1972 7.180E+03 3.923E+06 2.636E+02 1.687E+01 4.707E+03 3.163E-01 1973 7.666E+03 4.188E+06 2.814E+02 1.801E+01 5.026E+03 3.377E-01 1974 8.161E+03 4.458E+06 2.996E+02 1.918E+01 5.350E+03 3.595E-01 1975 8.666E+03 4.734E+06 3.181E+02 2.036E+01 5.681E+03 3.817E-01 1976 9.181E+03 5.015E+06 3.370E+02 2.157E+01 6.018E+03 4.044E-01 1977 9.706E+03 5.302E+06 3.563E+02 2.281E+01 6.363E+03 4.275E-01 1978 1.024E+04 5.595E+06 3.759E+02 2.407E+01 6.714E+03 4.511E-01 1979 1.079E+04 5.894E+06 3.960E+02 2.535E+01 7.073E+03 4.752E-01 1980 1.135E+04 6.199E+06 4.165E+02 2.666E+01 7.439E+03 4.998E-01 1981 1.192E+04 6.511E+06 4.375E+02 2.801E+01 7.813E+03 5.250E-01 1982 1.250E+04 6.830E+06 4.589E+02 2.938E+01 8.196E+03 5.507E-01 1983 1.309E+04 7.153E+06 4.806E+02 3.077E+01 8.584E+03 5.767E-01 1984 1.370E+04 7.485E+06 5.029E+02 3.220E+01 8.982E+03 6.035E-01 1985 1.476E+04 8.062E+06 5.417E+02 3.468E+01 9.675E+03 6.500E-01 1986 1.550E+04 8.465E+06 5.688E+02 3.641E+01 1.016E+04 6.825E-01 1987 1.630E+04 8.902E+06 5.982E+02 3.829E+01 1.068E+04 7.178E-01 1988 1.708E+04 9.328E+06 6.268E+02 4.013E+01 1.119E+04 7.521E-01 1989 1.787E+04 9.763E+06 6.560E+02 4.200E+01 1.172E+04 7.872E-01 1990 1.865E+04 1.019E+07 6.847E+02 4.383E+01 1.223E+04 8.216E-01 1991 1.935E+04 1.057E+07 7.101E+02 4.546E+01 1.268E+04 8.521E-01 1992 1.983E+04 1.084E+07 7.281E+02 4.661E+01 1.300E+04 8.737E-01 1993 2.019E+04 1.103E+07 7.410E+02 4.744E+01 1.323E+04 8.892E-01 1994 2.062E+04 1.126E+07 7.567E+02 4.844E+01 1.351E+04 9.081E-01 1995 2.114E+04 1.155E+07 7.758E+02 4.967E+01 1.386E+04 9.310E-01 1996 2.191E+04 1.197E+07 8.041E+02 5.148E+01 1.436E+04 9.650E-01 1997 2.249E+04 1.229E+07 8.257E+02 5.286E+01 1.475E+04 9.908E-01 1998 2.287E+04 1.249E+07 8.394E+02 5.373E+01 1.499E+04 1.007E+00 1999 2.332E+04 1.274E+07 8.560E+02 5.480E+01 1.529E+04 1.027E+00 2000 2.379E+04 1.299E+07 8.731E+02 5.590E+01 1.559E+04 1.048E+00 2001 2.424E+04 1.324E+07 8.898E+02 5.697E+01 1.589E+04 1.068E+00 2002 2.485E+04 1.358E+07 9.122E+02 5.840E+01 1.629E+04 1.095E+00 2003 2.537E+04 1.386E+07 9.312E+02 5.961E+01 1.663E+04 1.117E+00 2004 2.583E+04 1.411E+07 9.480E+02 6.069E+01 1.693E+04 1.138E+00 Carbon dioxide NMOC
REPORT - 11
WCCSL_landgem-v302_SCS_7-20-21 Draft 7/20/2021
Results (Continued)
(Mg/year) (m 3 /year) (av ft^3/min) (Mg/year) (m 3 /year) (av ft^3/min) 2005 2.632E+04 1.438E+07 9.659E+02 6.184E+01 1.725E+04 1.159E+00 2006 2.716E+04 1.484E+07 9.970E+02 6.382E+01 1.781E+04 1.196E+00 2007 2.763E+04 1.509E+07 1.014E+03 6.493E+01 1.811E+04 1.217E+00 2008 2.708E+04 1.480E+07 9.941E+02 6.364E+01 1.775E+04 1.193E+00 2009 2.655E+04 1.450E+07 9.744E+02 6.238E+01 1.740E+04 1.169E+00 2010 2.602E+04 1.422E+07 9.551E+02 6.115E+01 1.706E+04 1.146E+00 2011 2.551E+04 1.393E+07 9.362E+02 5.994E+01 1.672E+04 1.123E+00 2012 2.500E+04 1.366E+07 9.177E+02 5.875E+01 1.639E+04 1.101E+00 2013 2.451E+04 1.339E+07 8.995E+02 5.759E+01 1.607E+04 1.079E+00 2014 2.402E+04 1.312E+07 8.817E+02 5.645E+01 1.575E+04 1.058E+00 2015 2.355E+04 1.286E+07 8.642E+02 5.533E+01 1.544E+04 1.037E+00 2016 2.308E+04 1.261E+07 8.471E+02 5.423E+01 1.513E+04 1.017E+00 2017 2.262E+04 1.236E+07 8.304E+02 5.316E+01 1.483E+04 9.964E-01 2018 2.217E+04 1.211E+07 8.139E+02 5.211E+01 1.454E+04 9.767E-01 2019 2.174E+04 1.187E+07 7.978E+02 5.107E+01 1.425E+04 9.574E-01 2020 2.130E+04 1.164E+07 7.820E+02 5.006E+01 1.397E+04 9.384E-01 2021 2.088E+04 1.141E+07 7.665E+02 4.907E+01 1.369E+04 9.198E-01 2022 2.047E+04 1.118E+07 7.513E+02 4.810E+01 1.342E+04 9.016E-01 2023 2.006E+04 1.096E+07 7.365E+02 4.715E+01 1.315E+04 8.838E-01 2024 1.967E+04 1.074E+07 7.219E+02 4.621E+01 1.289E+04 8.663E-01 2025 1.928E+04 1.053E+07 7.076E+02 4.530E+01 1.264E+04 8.491E-01 2026 1.890E+04 1.032E+07 6.936E+02 4.440E+01 1.239E+04 8.323E-01 2027 1.852E+04 1.012E+07 6.798E+02 4.352E+01 1.214E+04 8.158E-01 2028 1.815E+04 9.918E+06 6.664E+02 4.266E+01 1.190E+04 7.997E-01 2029 1.780E+04 9.721E+06 6.532E+02 4.182E+01 1.167E+04 7.838E-01 2030 1.744E+04 9.529E+06 6.403E+02 4.099E+01 1.143E+04 7.683E-01 2031 1.710E+04 9.340E+06 6.276E+02 4.018E+01 1.121E+04 7.531E-01 2032 1.676E+04 9.155E+06 6.151E+02 3.938E+01 1.099E+04 7.382E-01 2033 1.643E+04 8.974E+06 6.030E+02 3.860E+01 1.077E+04 7.236E-01 2034 1.610E+04 8.796E+06 5.910E+02 3.784E+01 1.056E+04 7.092E-01 2035 1.578E+04 8.622E+06 5.793E+02 3.709E+01 1.035E+04 6.952E-01 2036 1.547E+04 8.451E+06 5.679E+02 3.635E+01 1.014E+04 6.814E-01 2037 1.516E+04 8.284E+06 5.566E+02 3.563E+01 9.941E+03 6.679E-01 2038 1.486E+04 8.120E+06 5.456E+02 3.493E+01 9.744E+03 6.547E-01 2039 1.457E+04 7.959E+06 5.348E+02 3.424E+01 9.551E+03 6.417E-01 2040 1.428E+04 7.802E+06 5.242E+02 3.356E+01 9.362E+03 6.290E-01 2041 1.400E+04 7.647E+06 5.138E+02 3.289E+01 9.177E+03 6.166E-01 2042 1.372E+04 7.496E+06 5.036E+02 3.224E+01 8.995E+03 6.044E-01 2043 1.345E+04 7.347E+06 4.937E+02 3.160E+01 8.817E+03 5.924E-01 2044 1.318E+04 7.202E+06 4.839E+02 3.098E+01 8.642E+03 5.807E-01 2045 1.292E+04 7.059E+06 4.743E+02 3.036E+01 8.471E+03 5.692E-01 2046 1.267E+04 6.919E+06 4.649E+02 2.976E+01 8.303E+03 5.579E-01 2047 1.242E+04 6.782E+06 4.557E+02 2.917E+01 8.139E+03 5.469E-01 2048 1.217E+04 6.648E+06 4.467E+02 2.860E+01 7.978E+03 5.360E-01 2049 1.193E+04 6.516E+06 4.378E+02 2.803E+01 7.820E+03 5.254E-01 2050 1.169E+04 6.387E+06 4.292E+02 2.747E+01 7.665E+03 5.150E-01 2051 1.146E+04 6.261E+06 4.207E+02 2.693E+01 7.513E+03 5.048E-01 2052 1.123E+04 6.137E+06 4.123E+02 2.640E+01 7.364E+03 4.948E-01 2053 1.101E+04 6.015E+06 4.042E+02 2.587E+01 7.219E+03 4.850E-01 2054 1.079E+04 5.896E+06 3.962E+02 2.536E+01 7.076E+03 4.754E-01 2055 1.058E+04 5.780E+06 3.883E+02 2.486E+01 6.936E+03 4.660E-01 NMOCCarbon dioxideYear
REPORT - 12
WCCSL_landgem-v302_SCS_7-20-21 Draft 7/20/2021
Results (Continued)
(Mg/year) (m 3 /year) (av ft^3/min) (Mg/year) (m 3 /year) (av ft^3/min) 2056 1.037E+04 5.665E+06 3.806E+02 2.437E+01 6.798E+03 4.568E-01 2057 1.016E+04 5.553E+06 3.731E+02 2.389E+01 6.664E+03 4.477E-01 2058 9.963E+03 5.443E+06 3.657E+02 2.341E+01 6.532E+03 4.389E-01 2059 9.766E+03 5.335E+06 3.585E+02 2.295E+01 6.402E+03 4.302E-01 2060 9.573E+03 5.230E+06 3.514E+02 2.249E+01 6.276E+03 4.217E-01 2061 9.383E+03 5.126E+06 3.444E+02 2.205E+01 6.151E+03 4.133E-01 2062 9.197E+03 5.025E+06 3.376E+02 2.161E+01 6.029E+03 4.051E-01 2063 9.015E+03 4.925E+06 3.309E+02 2.118E+01 5.910E+03 3.971E-01 2064 8.837E+03 4.828E+06 3.244E+02 2.076E+01 5.793E+03 3.892E-01 2065 8.662E+03 4.732E+06 3.179E+02 2.035E+01 5.678E+03 3.815E-01 2066 8.490E+03 4.638E+06 3.116E+02 1.995E+01 5.566E+03 3.740E-01 2067 8.322E+03 4.546E+06 3.055E+02 1.956E+01 5.456E+03 3.666E-01 2068 8.157E+03 4.456E+06 2.994E+02 1.917E+01 5.348E+03 3.593E-01 2069 7.996E+03 4.368E+06 2.935E+02 1.879E+01 5.242E+03 3.522E-01 2070 7.838E+03 4.282E+06 2.877E+02 1.842E+01 5.138E+03 3.452E-01 2071 7.682E+03 4.197E+06 2.820E+02 1.805E+01 5.036E+03 3.384E-01 2072 7.530E+03 4.114E+06 2.764E+02 1.769E+01 4.937E+03 3.317E-01 2073 7.381E+03 4.032E+06 2.709E+02 1.734E+01 4.839E+03 3.251E-01 2074 7.235E+03 3.952E+06 2.656E+02 1.700E+01 4.743E+03 3.187E-01 2075 7.092E+03 3.874E+06 2.603E+02 1.666E+01 4.649E+03 3.124E-01 2076 6.951E+03 3.797E+06 2.552E+02 1.633E+01 4.557E+03 3.062E-01 2077 6.814E+03 3.722E+06 2.501E+02 1.601E+01 4.467E+03 3.001E-01 2078 6.679E+03 3.649E+06 2.451E+02 1.569E+01 4.378E+03 2.942E-01 2079 6.546E+03 3.576E+06 2.403E+02 1.538E+01 4.292E+03 2.884E-01 2080 6.417E+03 3.506E+06 2.355E+02 1.508E+01 4.207E+03 2.826E-01 2081 6.290E+03 3.436E+06 2.309E+02 1.478E+01 4.123E+03 2.770E-01 2082 6.165E+03 3.368E+06 2.263E+02 1.449E+01 4.042E+03 2.716E-01 2083 6.043E+03 3.301E+06 2.218E+02 1.420E+01 3.962E+03 2.662E-01 2084 5.923E+03 3.236E+06 2.174E+02 1.392E+01 3.883E+03 2.609E-01 2085 5.806E+03 3.172E+06 2.131E+02 1.364E+01 3.806E+03 2.557E-01 2086 5.691E+03 3.109E+06 2.089E+02 1.337E+01 3.731E+03 2.507E-01 2087 5.579E+03 3.048E+06 2.048E+02 1.311E+01 3.657E+03 2.457E-01 2088 5.468E+03 2.987E+06 2.007E+02 1.285E+01 3.585E+03 2.409E-01 2089 5.360E+03 2.928E+06 1.967E+02 1.259E+01 3.514E+03 2.361E-01 2090 5.254E+03 2.870E+06 1.928E+02 1.235E+01 3.444E+03 2.314E-01 2091 5.150E+03 2.813E+06 1.890E+02 1.210E+01 3.376E+03 2.268E-01 2092 5.048E+03 2.758E+06 1.853E+02 1.186E+01 3.309E+03 2.223E-01 2093 4.948E+03 2.703E+06 1.816E+02 1.163E+01 3.244E+03 2.179E-01 2094 4.850E+03 2.649E+06 1.780E+02 1.140E+01 3.179E+03 2.136E-01 2095 4.754E+03 2.597E+06 1.745E+02 1.117E+01 3.116E+03 2.094E-01 NMOCYear Carbon dioxide
REPORT - 13
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ATTACHMENT 2

(to
Comment

D
-
5 )

–

Pacific Gas and Electric
Company’s (PG&E) Preliminary Engineering Study
(PES)
, 2022

This page is purposefully b
lank.

Internal
Preliminary Engineering
Study Report
Load Interconnection
Raven SR, LLC
1 PARR BLVD., RICHMOND

April 26, 2022
Doc ID: c2fc0f35a713b25357ddb6a880227edb5bfcc74a
Internal
Table of Contents

1. Introduction ..................................................................................................................... 1

2. Project and Interconnection Information ......................................................................... 1

3. Study Assumptions ......................................................................................................... 4

4. Evaluation of Distribution Interconnection ...................................................................... 5

5. Study Schedules ............................................................................................................. 9

Doc ID: c2fc0f35a713b25357ddb6a880227edb5bfcc74a
1 PARR BLVD.

RAVEN SR – PRELIMINARY ENGINEERING STUDY REPORT

INTERNAL
1 1. Introduction
Raven SR, LLC has submitted a request for electric service to Pacific Gas & Electric Co. for its new commercial use development located on 1 Parr Blvd in Richmond.

The maximum net three phase electrical load demand is estimated to be 5.5MW.

The proposed Commercial Operation Date (COD) of the Project is March 1st, 2023.

In response to Raven SR, LLC’s request, PG&E performed a Preliminary Engineering Study (PES) as defined by the study plan. The PES will provide the following:

1. Infrastructure Scope: Identify any adverse impacts on PG&E's system and identify methods for addressing such adverse impacts.

The PES Plan forms the basis for the Preliminary Engineering Study Agreement by defining the scope, content, assumptions, and terms of reference for the PES.

The proposed Commercial Operation Date (COD) is March 1st, 2023.

The PES assumes no additional generation, renewable or otherwise, will be installed at the site. Should Raven SR LLC wish to install generation, battery bank, renewable or otherwise, at the site at a later date, an application is required.

2. Project and Interconnection Information Schedule
Table 1 below lists the general information about the Project as provided by the Customer.

Table 1: Project General Information

Project Location

1 Parr Blvd
PG&E Planning Area East Bay
Maximum Load 5.5 MW
Connection Voltage 12kV
Primary Service Entrance PG&E approved Phase and Ground protection

Doc ID: c2fc0f35a713b25357ddb6a880227edb5bfcc74a
1 PARR BLVD.

RAVEN SR – PRELIMINARY ENGINEERING STUDY REPORT

INTERNAL
2 Figure 1: Location Map of the Facility

Doc ID: c2fc0f35a713b25357ddb6a880227edb5bfcc74a
1 PARR BLVD.

RAVEN SR – PRELIMINARY ENGINEERING STUDY REPORT

INTERNAL
3 Figure 2: 1 Parr Blvd loads as provided by the customer

Doc ID: c2fc0f35a713b25357ddb6a880227edb5bfcc74a
1 PARR BLVD.

RAVEN SR – PRELIMINARY ENGINEERING STUDY REPORT

INTERNAL
4 3. Study Assumptions
The infrastructure evaluation will identify any new PG&E substation facilities or existing facility upgrades necessary to interconnect the facility using the following assumptions:

PG&E will conduct a PES using the following assumptions:
1) The maximum net electrical demand of 5.5 MW to be served from an available primary distribution voltage.
2) The expected ramp up schedule of 45% in 1Q’ 2023 and 55% in 2025. 3) The expected Commercial Operation Date is March 1st, 2023. 4) The customer will engineer, procure, construct, own, and maintain its project facilities up to the point of common coupling.

Table 2: 1 Parr Blvd, Richmond – Ramp Up Schedule

PG&E has estimated a study fee of $25,000 for performing the PES based upon the scope of this study plan. The final cost to complete the PES will be based on actual cost.

PG&E will provide Raven SR LLC a record of actual costs for performing this PES roughly two months after the PES is completed. PG&E will bill Raven SR LLC the remaining balance if the actual cost is higher than the estimated $25,000. If the actual cost is less than the estimated study fee, PG&E will return the balance to the Raven SR LLC within thirty (30) days of such determination.

Raven SR LLC has paid a total of $25,000 for the Preliminary Engineering Study Plan as of December 27, 2021.

Year Load Type Demand
2023 1Q’ 2023 Demand 2.5 MW
2025 2025 Demand 5.5 MW
Doc ID: c2fc0f35a713b25357ddb6a880227edb5bfcc74a
1 PARR BLVD.

RAVEN SR – PRELIMINARY ENGINEERING STUDY REPORT

INTERNAL
5 4. Evaluation of Distribution Interconnection
PG&E’s Distribution Planning Department evaluated the capability of the existing distribution system to serve requested demand at the new Raven SR LLC’s facility.

Infrastructure Scope and Feasibility: There will be one primary service provided from a PG&E 12kV feeder to 1 Parr Blvd, Richmond based on the requested demand of 5.5 MW and voltage class 12kV. The services will be fed from Richmond R 1129.

System reinforcement details are as follows:

Part I (March 2023)
• Reconductor approximately 1,400 feet of 6Cu conductor to 397 Al conductor • Install approximately 1,800 feet of 397 Al conductor
• Install two OH 900A Switch
• Install 1 cap bank
• Install one voltage regulator

Part II (2025)
• Reconductor approximately 3,500 feet of 6cu and 4/0Al conductor to 715Al conductor • Trench and install approximately 280 feet of 1100Al underground cable • Reconductor approximately 200 feet of 4/0 Al to 715Al conductor • Install one Viper Recloser
• Project Lead Time: 18 – 24 months

Doc ID: c2fc0f35a713b25357ddb6a880227edb5bfcc74a
1 PARR BLVD.

RAVEN SR – PRELIMINARY ENGINEERING STUDY REPORT

INTERNAL
6 Table 3. Cost break-down
Reinforcement $ Cost
Reconductor approximately 1,400 feet of
6Cu conductor to 397 Al conductor
Install approximately 1,800 feet of 397 Al
conductor
Install two OH 900A Switch
Install 1 cap bank
Install one Voltage Regulator
Reconductor approximately 3,500 feet of
6cu and 4/0Al conductor to 715Al
conductor
Trench and install approximately 280 feet
of 1100Al underground cable
Reconductor approximately 300 feet of
4/0Al conductor to 715Al conductor
Install one Viper Recloser
Install two OH 900A Switch
308,000

396,000

60,000

33,000

150,000

770,000

114,800

66,000

80,000

60,000
Estimated Cost 2,037,800
Contingency (AACE Class 5:
-50%/+100%)
-1,018,900/+2,037,800
TOTAL COST with Contingency
(x$1,000)
$ 1,019 - $4,076

Doc ID: c2fc0f35a713b25357ddb6a880227edb5bfcc74a
1 PARR BLVD.

RAVEN SR – PRELIMINARY ENGINEERING STUDY REPORT

INTERNAL
7 Figure 3: Work required to serve Raven SR (part I)

Doc ID: c2fc0f35a713b25357ddb6a880227edb5bfcc74a
1 PARR BLVD.

RAVEN SR – PRELIMINARY ENGINEERING STUDY REPORT

INTERNAL
8 Figure 4: Work required to serve Raven SR (part II)

Figure 5: Work required to serve Raven SR (part II)
Doc ID: c2fc0f35a713b25357ddb6a880227edb5bfcc74a
1 PARR BLVD.

RAVEN SR – PRELIMINARY ENGINEERING STUDY REPORT

INTERNAL
9 5. Study Schedules
Table 4: PG&E study schedule for the Raven SR project at 1 Parr Blvd, Richmond

Task Milestone Description Target Date
1 Raven SR submits deposit Dec 2021
1 Draft Preliminary Engineering Study (PES) Study Plan
Agreement to Raven SR Jan 2022

2 Raven SR submit comments to the Draft PES Study
Plan
Feb 2022
3 Raven SR signs Study Agreement Feb 2022
4 PG&E finalizes PES Study Plan Mar 2022
5 PG&E submits Draft PES Report April 2022
6 Raven SR submits comments on Draft PES Report April 2022 7 PG&E finalizes PES Report May 2022

6. Detailed Interconnection Study Scope
The specific studies to be conducted are outlined below:

7.1 PG&E electric planning will perform a study to identify system reinforcements required to serve 5.5 MW demand at 1 Parr Blvd. in Richmond per PG&E’s assessment.

7.2 Land Evaluation
For the PES, PG&E’s Land Department will not perform an evaluation to determine if any new land rights are necessary to upgrade PG&E facilities.

Doc ID: c2fc0f35a713b25357ddb6a880227edb5bfcc74a
1 PARR BLVD.

RAVEN SR – PRELIMINARY ENGINEERING STUDY REPORT

INTERNAL
10 Pacific Gas and Electric Company
WE DELIVER ENERGY.

Preliminary Engineering Study Agreement

Raven SR, LLC has reviewed the Preliminary Engineering Study for the request for service at 1 Parr Blvd, Richmond, CA served by PG&E’s electric distribution system and agrees with the proposed Preliminary Engineering Study.

The Raven SR, LLC has paid a total of $25,000 in study fees as of December 27, 2021.

Dated this _________day of ______ , 2022

Raven SR, LLC:

BY: _______________________________________
(Signature)

___________________________________________
(Type or Print Name)

MAILING ADDRESS:

___________________________________________

9th June
Matt W. Murdock
PO Box 1360
Pinedale, WY 82941
Doc ID: c2fc0f35a713b25357ddb6a880227edb5bfcc74a
Audit Trail
Title
File Name
Document ID
Audit Trail Date Format
Status
1 Parr Blvd_PES Report
1 Parr Blvd_PES Report.pdf
c2fc0f35a713b25357ddb6a880227edb5bfcc74a

MM / DD / YYYY
Signed
06 / 09 / 2022
17:19:22 UTC
Sent for signature to Matt W. Murdock
([email protected]) from [email protected]
IP: 138.88.140.76
06 / 09 / 2022
20:48:28 UTC
Viewed by Matt W. Murdock ([email protected])
IP: 13.37.228.178
06 / 09 / 2022
20:48:43 UTC
Signed by Matt W. Murdock ([email protected])
IP: 13.37.228.178
The document has been completed.
06 / 09 / 2022
20:48:43 UTC
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ATTACHMENT

3 (
to Response to
Comment D
-
7 )

–

Raven One
Hydrogen Vent Sound Attenuation, 2023

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lank.

POWER ENGINEERS, INC.
2041 SOUTH COBALT POINT WAY
MERIDIAN, ID 83642 USA

PHONE
FAX
208-288-6100
208-288-6199

MEMORANDUM
BOI 179068 / 174550 (2023-04-21) SH

DATE: April 21, 2023
TO: Raven Mike Fatigati, Alicia Guerra
C: TSS Fred Tornatore
FROM: Howard Skidmore, Raven One CTS Discipline Lead
SUBJECT: 179068 / 174550 Raven One Hydrogen Vent Sound Attenuation

MESSAGE

For the Raven One facility, during upset/emergency situations, high pressure hydrogen is vented for safety. From an evaluation by the equipment supplier, the max sound from an event is estimated at 114 dB at the hydrogen compressors.

During a discussion with the City of Richmond, 4/20/23, noise level estimates at the Republic boundary were requested to understand the magnitude of sound and if it becomes a nuisance for residents. This is for information purposes only, as there is an exemption for the noise ordinance during emergency situations.

Distance attenuation calculations were performed for two locations. The first is the Republic fence line boundary, which is estimate at 325+ feet away, and at the Main Entrance Parking area, estimated at 950+ feet away from the hydrogen compressors. These locations are pictured in Appendix 1.

Estimated sound levels at distance from the hydrogen compressors.

Location Distance
(ft)
Estimated Sound level
(dB)

1. Raven Hydrogen Compressors 1 114

2. Republic Fence line 325 64

3. Republic Main Entrance Parking 950 54

See appendix 2 for the distance attenuation calculations.

MEMORANDUM POWER ENGINEERS, INC.

BOI 179068 / 174550 (2023-04-21) SH PAGE 2 OF 3

Appendix 1: Distance map from the Raven One hydrogen compressors

MEMORANDUM POWER ENGINEERS, INC.

BOI 179068 / 174550 (2023-04-21) SH PAGE 3 OF 3

Appendix 2: Distance Attenuation Calculations

The sound attenuation formula is based on the distance from a sound source and is stated as:

𝑑𝐵2 = 𝑑𝐵1 + 20 log 𝑑1
𝑑2

Where:
dB1 = initial sound level (dB)
dB2 = sound (dB) at distance 2
d1 = distance 1 (ft)
d2 = distance 2 (ft)

Calculation Example for the fence line.
• dB1 = 114 dB
• d1 = 1 ft
• d2 = 325 ft

𝑑𝐵2 = 114 𝑑𝐵 + 20 log 1
325 = 114 − 20.2 = 64 𝑑𝐵

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Richmond City CouncilMay 16, 2023

Richmond City Council
May 16, 2023