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Planning & Design Meetings 2/16/2010 - MinutesGunn High School Master Plan 1 ESA / 209002 Initial Study September 2009 GUNN HIGH SCHOOL MASTER PLAN Initial Study and Environmental Checklist Form California Environmental Quality Act (CEQA) 1. Project Title: Gunn High School Master Plan 2. Lead Agency Name and Address: Palo Alto Unified School District 25 Churchill Avenue, Building D Palo Alto, CA 94306 3. Contact Person and Phone Number: Tom Hodges, Program Director Telephone: (650) 329-3972 E-Mail: thodges@pausd.org 4. Project Location: 780 Arastradero Road Palo Alto, CA 94306 5. Santa Clara County Assessor’s Parcel Number: 142-17-032 6. Project Sponsor’s Name and Address: Palo Alto Unified School District 25 Churchill Avenue Building D Palo Alto, CA 94306 7. General Plan Designation: School District Lands 8. Zoning: PF – Public Facilities 9. Description of Project: The proposed project includes construction of new buildings, renovation of existing structures, and other site improvements as part of the Master Plan for the Gunn High School. See Project Description, below, for details of the Master Plan. 10. Surrounding Land Uses and Setting: The project site is within an urban area in the City of Palo Alto. Existing adjacent land uses include residential areas on the north and east, Alta Mesa Cemetery on the south, and the Veterans Affairs (VA) Palo Alto Health Care Systems campus on the west. 11. Other public agencies whose approval is required (e.g., permits, financing approval, or participation agreement): During the Site Improvements, the project may require an encroachment permit from the City of Palo Alto for construction within Arastradero Road. A permit will also be required from the Bay Area Air Quality Management District (BAAQMD) for demolition of existing structures. Initial Study Gunn High School Master Plan 3 ESA / 209002 Initial Study September 2009 Project Description Background The Palo Alto Unified School District (PAUSD or District) was founded in 1893. The District includes the City of Palo Alto, Stanford University, and areas of Los Altos Hills, Palo Alto Hills, and Portola Valley within its attendance area. See Figure 1 for attendance boundaries. The PAUSD consists of twelve elementary schools (grades K-5), three middle schools (6-8), and two high schools (9-12). In addition, the District operates a pre-school, Young Fives program, a self- supporting Adult School, the Hospital School at Stanford’s Lucille Packard Children’s Hospital, and summer school. The total District enrollment for the 2008/2009 school year was approximately 11,430 students. Gunn High School is located at 780 Arastradero Rd in Palo Alto and has an existing student capacity of 1,950. Enrollment at Gunn has steadily increased over the last ten years from 1,508 students in the 1998/1999 school year to 1,917 for the current (2008/2009) school year. The school employs approximately 135 certified staff and administrative staff. The projected capacity of Gunn High School at completion of the proposed improvements in 2018 would be 2,300 students, an increase of approximately 18 percent. Long Range Facilities Master Plan / Measure A In January 2006, PAUSD staff presented to the Board of Education a School Site Status Report that provided an assessment of the improvements made to District facilities during the Building for Excellence Program and outlined the future needs of the PAUSD.1 The Board authorized staff to prepare a 20-year facilities master plan that would identify facilities needs that were not funded by the Building for Excellence Program and outline a growth strategy to accommodate projected increases in enrollment. The Long Range Facilities Master Plan (LRFMP) is a conceptual document that was presented to the Board in April 2007. The LRFMP includes and implementation plan for capital improvements, planned maintenance, and equipment and furnishing needs over the next twenty years. This document also incorporates current codes and principles from the Collaborative for High Performance Schools (CHPS).2 These standards incorporate the latest green building practices to reduce operating costs through sustainable and energy efficient design, reduce environmental impact, and increase building life, while creating schools that are healthy and comfortable for students and staff. 1 “Building for Excellence” was a 1995 tax measure that funds upgrading school facilities and some technology items, such as computers. 2 The Collaborative for High Performance Schools (CHPS) is the United States’ first green building rating program especially designed for K-12 schools. CHPS provides information and resources to schools in order to facilitate the construction and operation of high performance institutions. 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REGENT PL KENT PL SOMERSET PL WINDSORCT SAMUELLN PENACT CORINA CT RINCONCIR DARLINGTONCTWILKIECTCORONADOAVE CROSBYCT LEGHORN ST FERNECT NTOLMANLN AMESCT TRA CYCT BARCLAYCTALVARADOCTGARYCTDYMONDCT MARIRAPL ELSINORECT MADELINECT JULIECT ANACAPACT GROVELN NEWELLPL TIMLOTTLN HEMLOCKCT GAILENLN MARTINSENCTWELLSBURYCT SUZANNECTPALOALTOSQ DULUTH CIR MEADOWCREEKCT NATHANCTSTELLINGCT YALE CT GREENMANOR LOSPALOSCIR LORABELLELN WHITCLEMCT GROVECT LUMASVERDESAVE FRENCHMANSRD PARADISECT FELTLAKEHigh School Attendance Areas Palo Alto Unified School District I280 Lapkoff & Gobalet Demographic Research, Inc. 6/2007www.Demographers.com HAMILTONAVE Richard W. LymanGraduate Residencesplus Santa Teresa Lanehomes assigned to Palo Alto HS Gunn High School Master Plan . 209002 Figure 1 High School Attendance Boundaries, Palo Alto Unified School District SOURCE: Lapkoff & Gobalet Demographic Research, Inc. Initial Study Gunn High School Master Plan 5 ESA / 209002 Initial Study September 2009 On June 3, 2008, voters in the District approved a $378 million bond issue, Measure A (Palo Alto School Modernization and Expansion Bond of 2008), that would provide funding to implement the LRFMP. The proposed project, the Gunn High School Master Plan (Master Plan) is a component of the LRFMP. PAUSD, serving as Lead Agency under the California Environmental Quality Act (CEQA), is completing the required environmental review of the Master Plan pursuant to CEQA, prior to approval of the plan. In accordance with the CEQA Guidelines, PAUSD has prepared an Initial Study to determine the potential environmental consequences of adoption and implementation of the proposed Master Plan. This Initial Study provides the necessary information to inform PAUSD, other responsible agencies, and the public of the nature of the project and its potential effect on the environment. Project Location and Existing Site Characteristics Gunn High School was constructed in 1964 on an approximately 48-acre site (the project site) northeast of the intersection of Arastradero Road and Foothill Expressway (see Figure 2). Adjacent land uses include residential areas to the north and east, Alta Mesa Cemetery to the south across Arastradero Road, and a Veterans Affairs hospital complex to the west. The school is composed of 17 permanent buildings clustered on the southern portion of the campus. These include the following: Administrative Building, Student Activities Building, cluster of four buildings for language and social studies instruction, cluster of four buildings for math and science instruction, Resource Materials Building, Music Building, Art Building, Spangenberg Auditorium, Business Education and Home Economics Building, Industrial Arts Building, and Gymnasium. The original buildings were constructed in 1964, with a new Library Building and Science facility added in 2003. The architectural style features single-story structures (with the exception of the Gym and Spangenberg Auditorium) with exterior wood siding, small window openings, and attached covered walkways supported by concrete columns and mansard roofs. Most of the southern portion of the campus is paved with trees and other landscaping interspersed between the buildings. All buildings, with the exception of the interiors to the Gym, Spangenberg Auditorium, Administration, and the old Library Building were, fully renovated under the Building for Excellence Program. The campus also includes approximately 26 relocatable classrooms. Recreational facilities are located primarily on the northern section of the campus and include a gym, pool, football field, baseball and softball diamonds, athletic field, outdoor track, seven tennis courts, and five basketball courts. The main parking lot is located on the southeast portion of the site, with vehicular access off Arastradero Road. The campus overall contains approximately 461 parking spaces. The campus has several public easements including the Hetch-Hetchy water easement running diagonally across the site in the east-west direction, as well as PG&E and sewer easements. In addition, a Santa Clara Valley Water District retention basin is located north of the relocatable classroom buildings. 280 82 PAGE MILL RDARASTRADERO RDEL C A M I N O R E A L FOOTH I L L EXPY SAN ANTONIO RDPAGE MILL RDCHAR L E S T O N R D ALM A S T PALO ALTO LOS ALTOSLOS ALTOS HILLS MOUNTAIN VIEW MOUNTAIN VIEW Stanford PROJECT LOCATION Gunn High School Master Plan . 209002 Figure 2 Project Location SOURCE: ESA 01 Mile Pacific Ocean NOVATO SANRAFAEL MOUNTAINVIEW SAN JOSE FREMONT HAYWARD SANRAMON WALNUT CREEK CONCORD SANTA ROSA NAPA FAIRFIELD ALAMEDASANFRANCISCO DALYCITY BERKELEY VALLEJO VACAVILLE REDWOOD CITY PALO ALTO SANMATEO OAKLAND PROJECT SITE RICHMOND Initial Study Gunn High School Master Plan 7 ESA / 209002 Initial Study September 2009 Proposed Improvements The proposed project features construction of new buildings and other structures; renovation of some existing buildings; utility and infrastructure improvements; open space and landscaping enhancements; entry and courtyard upgrades; and pedestrian/bicycle/vehicular circulation improvements. Specific components of the proposed Master Plan improvements are summarized in Table 1, below. Construction of individual projects on the campus would occur in groups or phases over the time period of the Master Plan, with buildout targeted for 2017. Specific projects within each project group would be constructed over the same general time period, but not necessarily simultaneously. Locations of proposed projects are indicated on Figures 3 through 7. Construction of a new Aquatics Center and renovation of the existing Industrial Arts building are currently underway with completion anticipated during the summer and fall of 2009, respectively. Renovations of existing buildings may include, but are not limited to, upgrades to electrical, communication, water and wastewater systems; replacement or modification of heating and cooling systems; lighting improvements; replacement of roofs; upgrade or addition of restrooms; improvements to comply with the Americans with Disabilities Act (ADA) and California Title 24 requirements; and exterior improvements to walls, doors, and windows. Group 1 Projects under the first group include construction of two new classroom buildings and a second gymnasium. The new gym would be located just east of the pool, which would require modifications to the tennis and basketball courts in this area. At buildout, Gunn would have eight tennis and three basketball courts. The existing gym would be modernized with new equipment, refinished floors, and other interior improvements. Proposed Classroom Building A would include 28 classrooms, offices, conference room, and restrooms. This two-story building is intended to replace the 28 relocatable classrooms currently located at this site (known as Titan Village) and those located near the Miranda Street entrance to the campus. These relocatable classrooms would be temporarily moved to the parking area adjacent to the tennis and basketball courts. Classroom Building B would be a single-story structure with five classrooms for world languages and program support as well as textbook storage. This phase would include an interim improvement to the parking and drop-off areas that are designed to provide greater separation between these two zones and provide easier access to the school during drop-off during construction and while the relocatables are placed on the parking lot. Group 2 Group 2 includes construction of a new Performing Arts Center to replace existing inadequate facilities in Building M. This new building would be located adjacent to the existing Spangenberg Theater in order to provide protected connection to the backstage access, greenrooms, and other theater facilities. Spangenberg would be updated as well with new lighting, finishes, and other interior improvements. Other projects during this phase would include modernization of the existing math wing building to accommodate the Special Education program, which is currently Initial Study Gunn High School Master Plan 8 ESA / 209002 Initial Study September 2009 located in the Resource Center building. Two general laboratory classrooms and a connector to the prep area Initial Study Gunn High School Master Plan 9 ESA / 209002 Initial Study September 2009 TABLE 1 MASTER PLAN PROJECT LIST Phase Project Description Schedule/Timeline Group 1 1a: Classroom Building A New two-story, 28-classroom building 2011 – 2012 1b: Classroom Building B New one-story, 6-classroom building 1c: Gymnasium New second gymnasium 1d: Existing Gymnasium Renovation of existing gymnasium 1e: Parking & Drop-Off Reconfiguration of parking and student drop-off areas 1f: Utility & Infrastructure Miscellaneous utility and infrastructure improvements Group 2 2a: Performing Arts Building New performing arts complex 2012 – 2014 2b: Campus Entry Entry and entry court improvements and reconfiguration 2c: Spangenberg Theater Renovation of existing theater 2d: Special Education Center Renovation of existing building 2e: Science Lab Two new classrooms 2f: Parking & Drop-Off Reconfiguration of parking and student drop-off areas Group 3 3a: Spangenberg Theater Renovation of lobby and other areas TBD 3b: Amphitheater Improvements to existing amphitheater Group 4 4a: Student Activities / Media Arts / Conference New two-story multiple-use building TBD 4b: Classroom Building Renovation of L-wings for existing building 4c: Art Building Additional classrooms and renovation to A-wing 4d: West Access Road & Parking Reconfiguration of access and parking area Group 5 5a: Guidance & Counseling Center Renovation of existing building TBD 5b: Administration Building Addition and renovation of existing building 5c: Quad Landscaping and other improvements to expanded quad 5d: Field Structure New athletics storage and snack bar facility 5e: Site Improvements Miscellaneous landscaping and pedestrian improvements 5f: RC Building Demolition of existing building to accommodate quad expansion SOURCE: PAUSD, 2009 Gunn High School Master Plan . 209002Figure 3Gunn High School Master Plan, Group 1 ProjectsSOURCE: Deems Lewis McKinley Gunn High School Master Plan . 209002Figure 4Gunn High School Master Plan, Group 2 ProjectsSOURCE: Deems Lewis McKinley Gunn High School Master Plan . 209002Figure 5Gunn High School Master Plan, Group 3 ProjectsSOURCE: Deems Lewis McKinley Gunn High School Master Plan . 209002Figure 6Gunn High School Master Plan, Group 4 ProjectsSOURCE: Deems Lewis McKinley Gunn High School Master Plan . 209002Figure 7Gunn High School Master Plan, Group 5 ProjectsSOURCE: Deems Lewis McKinley Initial Study Gunn High School Master Plan 15 ESA / 209002 Initial Study September 2009 and office would be added to the Science Lab. A redesigned entry area and entry courtyard would be constructed to form a coherent gateway to the campus from the parking area adjacent to Spangenberg Theater and the new Performing Arts complex. The existing Music Building would be demolished in order to create this new entryway. Finally, the parking area would be reconfigured again after the relocatable classrooms are removed from the campus. Group 3 (Unfunded)3 Spangenberg Theater would be renovated under this phase with the addition of a focal lobby area to be used for performances and other activities. A connector to the new Performing Arts Center constructed during Group 2 would also be added. The outdoor amphitheater adjacent to Spangenberg on the north would be updated with a new stage and landscaping. Group 4 (Unfunded) Group 4 includes a new two-story, centrally-located building to serve as a Student Activities Center. It would also include the media arts program, additional social studies classrooms, and a conference center. An existing classroom building would be demolished to make room for the new Student Center. Other existing buildings would be renovated during this phase. The three L-wing classroom buildings would be utilized for the expanded social studies and world languages departments. The Art Building would feature upgraded classrooms and additional classrooms would be added to the existing A-wing. Access to the campus via the west access road off Miranda Avenue would be reconfigured to provide a turn-around, parking, and pedestrian/bicycle paths. Group 5 (Unfunded) The existing Administration Building-AD2 would be modernized and converted into a guidance and counseling center during this phase. The staff lounge and patio would be relocated to the south side of the building as part of the renovation. Administration Building-AD1 would be renovated to accommodate administrative functions previously located in AD2, and the cafeteria would be upgraded. This phase would also include major changes to the Quad. The existing Resource Center building would be demolished to allow for an expanded Quad with new landscape/hardscape, furnishings, and other pedestrian improvements. In addition, a new Field Structure would be constructed just north of the football field. This building would feature snack bar facilities as well as storage space for soccer, track and field, lacrosse, and physical education programs. Sources California Department of Education, DataQuest, http://dq.cde.ca.gov/dataquest, accessed June 24, 2009. Palo Alto Unified School District (PAUSD), www.pausd.org, accessed June 2009. PAUSD, Gunn High School Master Plan, 2009. 3 Design of specific projects listed in Groups 3, 4 and 5 is currently unfunded. Initial Study Gunn High School Master Plan 16 ESA / 209002 Initial Study September 2009 Environmental Impacts Issues (and Supporting Information Sources): Potentially Significant Impact Less Than Significant with Mitigation Incorporation Less Than Significant Impact No Impact 1. Aesthetics Would the project: a) Have a substantial adverse effect on a scenic vista? b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? c) Substantially degrade the existing visual character or quality of the site and its surroundings? d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? Discussion a, b) No Impact. Gunn High School is located on a trapezoidal shaped block that is located off of Arastradero Road near Foothill Expressway in a southwestern portion of Palo Alto. There are no roadways near Gunn High School that have been designated as or are considered eligible to be a state scenic highway, nor is the project site visible from a state scenic highway (Caltrans, 2009). In addition, there are no scenic resources, including trees, rock outcroppings, and historic resources, in the vicinity of the campus. Therefore, the proposed project would not result in impacts related to scenic resources within a state scenic highway. The City of Palo Alto considers Arastradero Road west of Foothill Expressway and Foothill Expressway to be scenic routes (City of Palo Alto, 2007). While the segment of Arastradero Road that is in front of the high school is not considered to be a scenic route, a small portion of the high school campus is visible from the intersection of Foothill Expressway and Arastradero Road (see Figure 8). Arastradero Road is generally the only roadway that provides views of Gunn’s campus (intermittent views of the sports facilities are available from Miranda Road). Other public views of the campus are provided by the publicly accessible pathways that line both the eastern and western edges of the campus. Gunn High School consists of a collection of classroom buildings that are concentrated in the southwestern portion of the campus. Parking lots and internal roadways comprise the southeastern portion and the remainder of campus consists of sports facilities, including tennis courts, a baseball stadium, football stadium, and an aquatic center. The buildings on Gunn’s campus maintain a uniform style throughout and are characterized by square or rectangular massing, mansard roofs and colonnades (see Figures 9 and 10). In addition to maintaining a consistent style, the buildings also include a common color scheme with brown siding, white columns, and brown roofs. While the majority of the buildings are one story, there are a few two-story (in height) buildings on campus, including the library, theater and the gymnasium. Gunn High School Master Plan . 209002 Figure 8 Existing Views of Gunn High School Campus SOURCE: ESA View of campus near Foothill Expressway and Arastradero Road View of campus near Foothill Expressway and Arastradero Road Gunn High School Master Plan . 209002 Figure 9 Existing Views of Gunn High School Campus SOURCE: ESA View of campus from Arastradero Road looking east View of campus from Arastradero Road looking west Gunn High School Master Plan . 209002 Figure 10 Existing Views of Gunn High School Campus SOURCE: ESA View of campus buildings View of campus buildings Initial Study Gunn High School Master Plan 20 ESA / 209002 Initial Study September 2009 Buildout of the Master Plan would not affect views from the intersection of Arastradero Road and Foothill Expressway. Currently, views of the campus from the intersection of Arastradero Road and Foothill Expressway consist of the roof and some of the columns of the building located on the southwestern-most corner. Under the proposed project, one small classroom building would be constructed along the Arastradero Road frontage of campus. View of this new classroom building from the intersection of Foothill Expressway and Arastradero Road would be blocked by the existing classroom building and views from that intersection would not change. Therefore, the proposed project would not affect views from those scenic routes and impacts related to scenic vistas would be less than significant. c) Less Than Significant. Buildout of the Master Plan would result in the construction of new buildings and renovations to existing buildings throughout the campus. Very few of these improvements would even be visible from the publicly accessible viewpoints. As noted above, one relatively small classroom building would be constructed along the Arastradero Road frontage of campus. This building would be set back approximately 100 feet from the roadway. In addition, the elevation of the campus slopes down from the edge of the roadway, which slightly diminishes the presence of the buildings along the roadway. All new construction and renovations would be designed to be compatible with the existing style of buildings on campus in terms of height, massing and color scheme. In addition, the development pattern of the campus would be maintained with all classroom buildings being concentrated in the southwestern portion of campus, parking lots would be reconfigured but not be relocated, and the sports facilities would remain intact in their current locations with only minor upgrades. Generally, the Master Plan would result in better utilization of the space on campus, but would not affect the overall character of the site and its surrounding. Therefore, the proposed project would result in less than significant impacts on the character of the site and its surroundings. d) Less Than Significant. New buildings developed under the Master Plan would include fixed exterior lighting in order to promote safety. Gunn High School is located in a suburban environment that has some existing sources of light and glare associated with nearby land uses. Nearby homes and businesses cast light from windows or from outdoor security lighting and parking lots. Arastradero Road and Foothill Expressway provide street lighting and are also additional sources of light and glare. Ambient light generated by new buildings that could be developed or improved under the plan would be minimized and partially screened by trees and surrounding buildings. Therefore, the proposed project would not result in adverse light or glare impacts at their specific sites or in the surrounding areas. Sources City of Palo Alto, 2007. Palo Alto Comprehensive Plan, Land Use Element, adopted July 17, 2007. California Department of Transportation (Caltrans), 2009. California Scenic Highway Mapping System website, http://www.dot.ca.gov/hq/LandArch/scenic_highways/index.htm, accessed July 21, 2009. Initial Study Gunn High School Master Plan 21 ESA / 209002 Initial Study September 2009 Issues (and Supporting Information Sources): Potentially Significant Impact Less Than Significant with Mitigation Incorporation Less Than Significant Impact No Impact 2. Agriculture Resources In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. Would the project: a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? c) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use? Discussion a–c) No Impact. The project site is not located on or near any agricultural land, nor is the site zoned for agricultural uses. The project site, as with the majority of developed land in the City of Palo Alto, is designated as Urban and Built-Up Land by the California Department of Conservation (Department of Conservation, 2007). Therefore, the proposed project would not convert farmland to non-agricultural use and would have no effect on farmland or any property subject to a Williamson Act contract. Sources California Department of Conservation, Santa Clara County Important Farmland Map 2006, August 2007. Initial Study Gunn High School Master Plan 22 ESA / 209002 Initial Study September 2009 Issues (and Supporting Information Sources): Potentially Significant Impact Less Than Significant with Mitigation Incorporation Less Than Significant Impact No Impact 3. Air Quality Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project: a) Conflict with or obstruct implementation of the applicable air quality plan? b) Violate any air quality standard or contribute substantially to an existing or projected air quality violation? c) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)? d) Expose sensitive receptors to substantial pollutant concentrations? e) Frequently create objectionable odors affecting a substantial number of people? f) Conflict with the state goal of reducing greenhouse gas emissions in California to 1990 levels by 2020, as set forth by the timetable established in AB 32, California Global Warming Solutions Act of 2006? Discussion a) Less than Significant. The project site is located in the City of Palo Alto, within the San Francisco Bay Area Air Basin (Bay Area). The Bay Area experiences occasional violations of ozone and particulate matter (PM-10 and PM-2.5) standards. Air Quality standards and regulations are enforced in the Bay Area Air Basin by the Bay Area Air Quality Management District (BAAQMD). When a project is proposed in a city with a general plan that is consistent with the most recently adopted Clean Air Plan and if the project is consistent with the land use designation of the general plan, then the project is considered consistent with applicable air quality plans and policies. As discussed in Checklist Item 9, Land Use and Planning, of this Initial Study, the campus improvements and educational uses proposed as part of the project would not substantially conflict with the goals and policies in the City of Palo Alto Comprehensive Plan. Moreover, although not bound by local land use ordinances, project components proposed by the PAUSD would nonetheless be consistent with the land use designation and zoning for the campus. The applicable Clean Air Plan (CAP) is the Bay Area 2005 Ozone Strategy. The City’s General Plan is consistent with the CAP because data and projections from the General Plan are incorporated into the CAP. The project, therefore, is consistent with the plan. This Initial Study Gunn High School Master Plan 23 ESA / 209002 Initial Study September 2009 is a less-than-significant impact because the project would not conflict with the region’s air quality management plan. b, c) Less Than Significant with Mitigation. Construction Emissions This analysis evaluates the effect of the site grading and the construction of Master Plan improvements on the local and regional air quality. Development of this project could affect local pollutant concentrations in two ways. First, during construction, the project would affect local particulate concentrations by generating dust. Over the long-term, the project might result in a slight increase in emissions due to new motor vehicle trips associated with accommodation of a larger student population. Activities such as grading and excavation would generate substantial amounts of dust (including PM-10) from “fugitive” sources, such as proposed earthmoving activities to improve athletic fields and to excavate foundations and vehicle travel over unpaved surfaces, and lesser amounts of other criteria pollutants from the operation of heavy equipment construction machinery (primarily diesel operated) and construction worker automobile trips (primarily gasoline operated). Construction-related dust emissions would vary from day to day, depending on the level and type of activity, silt content of the soil, and the weather. Construction activities may result in significant quantities of dust, and as a result, local visibility and PM-10 concentrations may be adversely affected on a temporary basis during the construction period. In addition, larger dust particles would settle out of the air close to the construction site resulting in a potential soiling nuisance for adjacent uses. For the evaluation of construction-phase impacts, BAAQMD does not require a detailed quantification of construction emissions. Instead, it recommends that evaluation of the significance of impacts be based on a consideration of the control measures to be implemented (BAAQMD, 1999). Generally, if appropriate measures are implemented to reduce fugitive dust, then the residual impact can be presumed to be less than significant. Without these measures, the impact is generally considered to be significant, particularly if sensitive land uses (e.g., residential or scholastic) are located in the project vicinity. The Master Plan improvements that would require the greatest degree of grading and earthwork would be new building excavations for classrooms, the new gymnasium, the new performing arts center, and the new student activities and media arts buildings. Other project elements would disturb much smaller areas of earth and have fewer construction impacts to localized PM-10 and PM-2.5 concentrations. All individual construction areas would be less than one acre. Because construction grading would generate localized increased concentrations of PM-10 and PM-2.5 in an area designated as non-attainment for these pollutants, without appropriate dust mitigation, the impact would be significant. Mitigation Measure AIR-1: During future construction, PAUSD shall require the construction contractor to implement BAAQMD’s “basic” dust control procedures which are required for all construction sites of less than four acres and which would mitigate the potential impact to a less than significant level. Initial Study Gunn High School Master Plan 24 ESA / 209002 Initial Study September 2009 Elements of the “basic” dust control program for project components that disturb more than four acres shall include, but not necessarily be limited to the following: Basic Control Measures • Water all active construction areas at least twice daily. Watering should be sufficient to prevent airborne dust from leaving the site. Increased watering frequency may be necessary whenever wind speeds exceed 15 miles per hour. Reclaimed water should be used whenever possible. • Cover all trucks hauling soil, sand, and other loose materials or require all trucks to maintain at least two feet of freeboard (i.e., the minimum required space between the top of the load and the top of the trailer). • Pave, apply water three times daily, or apply (non-toxic) soil stabilizers on all unpaved access roads, parking areas and staging areas at construction sites. • Sweep streets (with water sweepers using reclaimed water if possible) at the end of each day if visible soil material is carried onto adjacent paved roads. • Sweep streets daily (with water sweepers) if visible soil material is carried onto adjacent public streets. With implementation of these measures, project construction would not be expected to violate any air quality standard or contribute to an existing or projected air quality violation in the project vicinity. Construction activities would also result in the emission of other criteria pollutants from equipment exhaust, construction-related vehicular activity and construction worker automobile trips. Emission levels for construction activities would vary depending on the number and type of equipment, duration of use, operation schedules, and the number of construction workers. Criteria pollutant emissions of ROG and NOx from these emission sources would incrementally add to the regional atmospheric loading of ozone precursors during project construction. BAAQMD CEQA Guidelines recognize that construction equipment emit ozone precursors, but indicate that such emissions are included in the emission inventory that is the basis for regional air quality plans. Therefore, construction emissions would not be expected to impede attainment or maintenance of ozone standards in the Bay Area (BAAQMD, 1999). The impact would therefore be less than significant. Operational Emissions The project would result in a net increase in emissions of criteria pollutants (ROG, NOx and PM-10) primarily because of a resultant increase in average daily vehicle trips. Based on the traffic analysis, the proposed change in land use would result in an increase of approximately 532 net new daily vehicle trips. Increased vehicle trips would lead to a small increase in ROG (approximately 2.7 pounds per day), NOx (approximately 2.2 pounds per day) and PM-10 (approximately 6.9 pounds per day) due to vehicle exhaust. Increases in emissions from stationary sources at the site (such as natural gas combustion for space and water heating, landscaping, use of consumer products, etc.) would also be minimal Initial Study Gunn High School Master Plan 25 ESA / 209002 Initial Study September 2009 (approximately 0.72 pounds per day of ROG and 1.06 pounds per day of NOx). Together, operational emissions increases resulting from the project would represent approximately ten percent or less of the quantities BAAQMD identifies as significant (80 pounds per day of either ROG, NOx, or PM-10, individually). Therefore, once operational, the development under the Master Plan would not significantly contribute to a violation of any air quality standard in the area. Cumulative Air Quality Impact In combination with other future projects in the project vicinity, the construction and operations of the proposed project would likely result in a small cumulative contribution to increases in pollutant emissions, but these would have less than significant impacts to air quality. Furthermore, with the implementation of mitigation measures, these impacts would be reduced to less than significant levels. d) Less than Significant with Mitigation. Construction activities could expose sensitive receptors (students and residences located adjacent to the project site) to substantial pollutant concentrations, principally PM-10, from fugitive dust sources. However, with implementation of the dust abatement program described above in Mitigation Measure AIR-1, impacts from construction-related PM-10 emissions would be less than significant. The proposed project would locate additional students, considered a sensitive receptor, in an area established with existing school land use and adjacent residential land uses. There are no major freeways or land uses that would be considered major (i.e., permitted) stationary sources of air pollution located within the project vicinity (1,000 feet). The only BAAQMD-identified source facilities of toxic air contaminant emissions within one-half mile of the project site is Alta Mesa Improvement Company at 695 Arastradero Road which would not be expected to represent a threat to the existing scholastic land use, as their only inventoried emissions are less than one gram of hexavalent chromium per year (BAAQMD, 2007). e) No Impact. As a general matter, the types of land use development that pose potential odor problems include wastewater treatment plants, refineries, landfills, composting facilities and transfer stations. No such uses would occupy the project site. Therefore, the project would not create objectionable odors that would affect a substantial number of people. In addition, there are no existing odor sources in the vicinity of the project site to which future occupants of the project site would be subjected. f) Less than Significant with Mitigation. Gases that trap heat in the atmosphere are called greenhouse gases. The major concern is that increases in greenhouse gases are causing global climate change. Global climate change is a change in the average weather on earth that can be measured by wind patterns, storms, precipitation and temperature. Although there is disagreement as to the speed of global warming and the extent of the impacts attributable to human activities, most agree that there is a direct link between increased emission of greenhouse gases and long-term global temperature. What greenhouse gases have in common is that they allow sunlight to enter the atmosphere, but trap a portion of Initial Study Gunn High School Master Plan 26 ESA / 209002 Initial Study September 2009 the outward-bound infrared radiation and warm up the air. The process is similar to the effect greenhouses have in raising the internal temperature, hence the name greenhouse gases. Both natural processes and human activities emit greenhouse gases. The accumulation of greenhouse gases in the atmosphere regulates the earth’s temperature; however, emissions from human activities such as electricity generation and motor vehicle operations have elevated the concentration of greenhouse gases in the atmosphere. This accumulation of greenhouse gases has contributed to an increase in the temperature of the earth’s atmosphere and contributed to global climate change. The principal greenhouse gases are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), sulfur hexafluoride (SF6), perfluorocarbons (PFCs), hydrofluorocarbons (HFCs), and water vapor (H2O). Carbon dioxide is the reference gas for climate change because it is the predominant greenhouse gas emitted. To account for the varying warming potential of different greenhouse gases, greenhouse gas emissions are often quantified and reported as CO2 equivalents (CO2e). Executive Order S-3-05 In 2005, Governor Schwarzenegger established Executive Order S-3-05, which sets forth a series of target dates by which statewide emission of greenhouse gases (GHG) would be progressively reduced, as follows: • By 2010, reduce GHG emissions to 2000 levels; • By 2020, reduce GHG emissions to 1990 levels; and • By 2050, reduce GHG emissions to 80 percent below 1990 levels. Assembly Bill 32 (California Global Warming Solutions Act of 2006) In 2006, California passed the California Global Warming Solutions Act of (Assembly Bill No. 32; California Health and Safety Code Division 25.5, Sections 38500, et seq., or AB 32), which requires the California Air Resources Board (CARB) to design and implement emission limits, regulations, and other measures, such that feasible and cost- effective statewide GHG emissions are reduced to 1990 levels by 2020 (representing an approximate 25 percent reduction in emissions). Under AB 32, the CARB must adopt regulations by January 1, 2011 to achieve reductions in GHGs to meet the 1990 emission cap by 2020. CARB Climate Change Scoping Plan In December 2008, CARB adopted the Climate Change Scoping Plan (AB 32 Scoping Plan) outlining the State’s strategy to achieve the 2020 greenhouse gas emissions limit. The AB 32 Scoping Plan, developed by CARB in coordination with the Climate Action Team (CAT), proposes a comprehensive set of recommended actions designed to reduce overall GHG emissions in California. The measures in the AB 32 Scoping Plan approved by the Board will be developed over the next two years and be in place by 2012. Initial Study Gunn High School Master Plan 27 ESA / 209002 Initial Study September 2009 OPR on CEQA and Climate Change The Governor’s Office of Planning and Research (OPR) June 2008 Technical Advisory (OPR, 2008) provides informal guidance for public agencies as they address the issue of climate change in their CEQA documents. The June 2008 Technical Advisory offers recommendations for identifying GHG emissions, determining significance under CEQA, and mitigating impacts. The June 2008 OPR Advisory states that lead agencies under CEQA should develop their own approach to performing a climate change analysis for projects that generate GHG emissions. The approach should be consistent for analyzing all such projects, and analyses should be performed based on the best available information. If a lead agency determines that GHGs may be generated by a proposed project, the agency is responsible for quantifying estimated GHG emissions by type and source. The June 2008 OPR Advisory also states that the lead agency must assess whether project emissions are individually or cumulatively significant and implement strategies to avoid, reduce, or otherwise mitigate the impacts of those emissions when impacts are potentially significant. Regional agencies can attempt to reduce GHG emissions through their planning processes, according to the June 2008 OPR Advisory. Regional transportation planning agencies can adopt plans and programs that address congestion relief and reduce vehicle miles traveled (VMT), for example. Subsequent to the release of the 2008 Technical Advisory, OPR has developed proposed guidelines for the mitigation of GHG emissions or the effects of GHG emissions under CEQA, following Senate Bill 97. On April 13, 2009, OPR submitted additions and amendments to the CEQA Guidelines to the Secretary for Natural Resources for certification and adoption by January 1, 2010. CARB Preliminary Draft Staff Proposal, October 2008 In its Staff Proposal, CARB is taking the first step toward developing recommended statewide interim thresholds of significance for GHGs that may be adopted by local agencies for their own use. The proposal does not attempt to address every type of project that may be subject to CEQA, but instead focuses on common project types that, collectively, are responsible for substantial GHG emissions – specifically, industrial, residential, and commercial projects. CARB is developing these thresholds in these sectors to advance climate objectives, streamline project review, and encourage consistency and uniformity in the CEQA analysis of GHG emissions throughout the State. CARB staff’s objective in this proposal is to develop a threshold of significance that will result in the vast majority (approximately 90 percent statewide) of GHG emissions from new industrial projects being subject to CEQA’s requirement to impose feasible mitigation. CARB believes this can be accomplished with a threshold that allows small projects to be considered insignificant. CARB staff used existing data for the industrial sector to derive a proposed hybrid threshold. The threshold consists of a quantitative threshold of 7,000 metric tons of CO2 equivalent per year (MT CO2e/year) for operational emissions Initial Study Gunn High School Master Plan 28 ESA / 209002 Initial Study September 2009 (excluding transportation), and performance standards for construction and transportation emissions. These performance standards have not yet been developed. To date, CARB has only developed preliminary interim threshold concepts for industrial projects. No proposed thresholds for non-industrial project have been developed. As with other individual and relatively small projects (i.e., projects that are not cement plants, oil refineries, electric generating facilities/providers, co-generation facilities, or hydrogen plants or other stationary combustion sources that emit more than 25,000 metric tons (MMT) CO2e/yr), the project specific emissions from the proposed project would not be expected to individually have an impact on global climate change (AEP, 2007) and the primary concern would be whether the project would be in conflict with the state goals for reducing greenhouse gas emissions. Three types of analyses are used to determine whether the project could be in conflict with the state goals for reducing greenhouse gas emissions. The analyses are reviews of: • Assessment A: The potential conflicts with the CARB 39 recommended actions of the Climate Change Scoping Plan; • Assessment B: The relative size of the project in comparison to the estimated greenhouse reduction goal of 174 MMTCO2E by 2020 and in comparison to the size of major facilities that are required to report greenhouse gas emissions (25,000 metric tons of CO2E/yr)4 and proposed thresholds of CARB; and • Assessment C: The basic parameters of a project to determine whether its design is inherently energy efficient, will lead to wasteful energy use, or is neutral with regard to future energy use. With regard to Assessment A, the project does not pose any apparent conflict with the most recent list of the CARB early action strategies as these are aimed at industry, water use and new land use development. With regard to Assessment B, project construction GHG emissions were estimated with the URBEMIS2007 computer model. CO2 emissions from construction assumed peak annual GHG emissions would most likely occur during Group 1 and 2 classroom improvements. An overall project construction area of 2.5 acres was assumed based on 110,000 square feet of improvements. Per the Project Description this work would occur over a nine moth period in 2011 and 2012. GHG emissions from this activity were calculated using the URBEMIS2007 model of the CARB. Equipment exhaust also contains small amounts of methane and nitric oxides which are also GHGs. Non-CO2 GHG emissions represent approximately a three percent increase in CO2-equivalent emissions from diesel equipment exhaust. For purposes of analysis, it was assumed that non-CO2 GHG emissions from 4 The State of California has not adopted guidance as to quantitative significance thresholds for assessing the impact of greenhouse gas emissions on climate change and global warming concerns. Initial Study Gunn High School Master Plan 29 ESA / 209002 Initial Study September 2009 construction equipment would be negligible. The peak annual activity would generate 245 “short” or 222 metric tons (MT) per year of CO2. The proposed improvements to Gunn High school under the Master Plan would result in an increase in daily operational CO2 emissions from project-related traffic and area source emissions for space and water heating as well as electricity demand. Operational emissions of CO2 from vehicle traffic as calculated by URBEMIS2007 would be 665 “short” tons per year or 603 MT per year. URBEMIS also calculates natural gas combustion emissions based on square footage of improvements. CO2 emissions from natural gas emissions are calculated to be 233 “short” tons per year or 211 MT per year. Electricity demand based on square footage of improvements and California specific emission factors of the California Climate Action Registry and high school-specific electrical demand estimates would result in an additional 430 MT per year of GHGs emitted indirectly as a result of the project. Consequently the total operational CO2 emission rate resulting from implementation of the proposed Master Plan is estimated to be 1,244 MT per year. When compared to the state facility reporting requirement for GHG emissions of 25,000 MT per year CO2e, the maximum GHG emissions for the project (222 MT per year CO2e during construction; and 1,244 MT per year during operations are not significant enough to require reporting to the CARB relative to the requirements of AB32. Additionally, although not yet adopted nor applicable to the proposed Master Plan, project GHG emissions would be less than the proposed 7,000 MT per year Preliminary Staff Proposal threshold for industrial projects under consideration by CARB. With regard to Assessment C, in the absence of any definitive thresholds of significance, the GHG emphasis on a project-specific level is to incorporate project design features that reduce energy consumption and reduce vehicular travel as much as is feasible once such measures are adopted in the Climate Change Scoping Plan of CARB. Unless there is a greater shift to clean energy such as solar, hydroelectric, wind, nuclear, etc., no substantial reduction in GHG is likely attainable by conventional methods except through energy conservation. GHG reduction options on a project-level basis are similar to those measures designed to reduce criteria air pollutants (those with ambient air quality standards). Mitigation Measure TRAN-2 (See Checklist Item 15, Transportation) would reduce trip generation thus optimize the transportation efficiency of the land use and measures that promote energy conservation within a development would reduce GHG emissions. Because the proposed project consists of improvements under a Master Plan, there are no specific building details at this level of project development. Consequently, mitigation measures are recommended to ensure that development under the proposed Master Plan would be inherently energy efficient and commensurate with achieving the goals of GHG reductions under AB32. Initial Study Gunn High School Master Plan 30 ESA / 209002 Initial Study September 2009 Mitigation Measure AIR-2: Building development plans resulting from the Master Plan shall include “green building” features to reduce energy consumption to the extent practicable. These measures may include: • Building design consistent with the Collaborative for High Performance Schools (CHPS). CHPS is a third party program that oversees the nation’s first green building rating program especially designed for K-12 schools. CHPS has published design guidelines and performance criteria specific to California schools. • Install efficient lighting and lighting control systems. Site and design buildings to take advantage of daylight. • Plant trees and vegetation near structures to shade buildings and reduce energy requirements for heating/cooling. • Preserve or replace onsite trees consistent with Mitigation Measure BIO-4 (that are removed due to development) as a means of providing carbon storage. • Install light-colored “cool” roofs and cool pavements. • Install energy efficient heating and cooling systems, appliances and equipment and control systems. • Install light emitting diodes (LEDs) for traffic, street and other outdoor lighting. • Install water efficient fixtures and appliances. Implementation of the above mitigation measures would reduce the impact to less than significant levels. Sources Bay Area Air Quality Management District (BAAQMD), BAAQMD CEQA Guidelines: Assessing the Air Quality Impacts of Projects and Plans, December 1999. BAAQMD, Toxic Air Contaminant 2003 Annual Report, published 2007. BAAQMD, Rules & Regulations, www.baaqmd.gov/dst/regulations/index.htm, accessed May 10, 2007. California Air Resources Board, Air Quality and Land Use Handbook: A Community Health Perspective, April 2005. Initial Study Gunn High School Master Plan 31 ESA / 209002 Initial Study September 2009 Issues (and Supporting Information Sources): Potentially Significant Impact Less Than Significant with Mitigation Incorporation Less Than Significant Impact No Impact 4. Biological Resources Would the project: a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? c) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) or state-protected wetlands, through direct removal, filling, hydrological interruption, or other means? d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? f) Fundamentally conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? Discussion a) Less than Significant with Mitigation. ESA conducted a reconnaissance-level field survey of the project area on July 9, 2009 to verify existing biological conditions, assess vegetation and wildlife habitats, and identify potential for special-status wildlife species to occur onsite (ESA, 2009).5 Palo Alto and surrounding cities on the San Francisco peninsula have been extensively developed in the last century, and areas directly surrounding Gunn High School are primarily single-family homes and commercial business parks. Most of the Gunn campus is landscaped, and common trees on campus include coast live oak (Quercus agrifolia), valley oak (Quercus lobata), and elm (Elmus spp.). Several small, less landscaped areas contain coyote brush (Baccharis pilularis) growing underneath oak trees. 5 The term “special-status” species includes those species that are listed and receive specific protection defined in federal or state endangered species legislation, as well as species not formally listed as Threatened or Endangered, but designated as “Rare” or “Sensitive” on the basis of adopted policies and expertise of state resource agencies or organizations, or local agencies such as counties, cities, and special districts. A principle source for this designation is the California “Special Animals List” (CDFG, 2009B). Initial Study Gunn High School Master Plan 32 ESA / 209002 Initial Study September 2009 Birds identified on campus were species typically accustomed to disturbance, including scrub jay (Aphelocoma californica), common raven (Corvus corax), black phoebe (Sayornis nigricans), and American robin (Turdus migratorius). Most open areas on campus are either paved parking lots, walkways, or grass playing fields. In the northernmost corner of the campus, there is an approximately four-acre annual grassland habitat. The area is gently sloped and had been recently mowed prior to a site visit (ESA, 2009). Several California ground squirrel (Spermophilus beecheyi) burrows were observed. Typical vegetation in this area includes wild oats (Avena barbata), ripgut brome (Bromus hordaceous), and several oaks along the perimeter of the area. This habitat could potentially support burrowing owl (Athene cunicularia), but construction would not occur close enough to impact owls and any pairs present would be accustomed to residential noise and disturbance. The Barron Creek Debris Basin and an upstream wetland area are located directly west of the Gunn campus. When ESA conducted a site visit, the basin was holding water but the wetland area was dry (ESA, 2009). The basin likely holds water year-round and effectively functions as a pond, and the wetland area becomes seasonally ponded but dries out in arid months of the year. This habitat is described in more detail in c) below. The California Natural Diversity Database (CNDDB) documents 43 special-status species within the Palo Alto and Mountain View U.S. Geological Survey (USGS) quadrangles that include the project area (CDFG, 2009). Potential for the project area to support special- status species was assessed using the CNDDB (CDFG, 2009). No suitable habitat for special-status plant species was found on or directly adjacent to the project area. Special- status wildlife species that could potentially be impacted by the project include California red-legged frog (Rana dratonyii), western pond turtle (Actinemys marmorata), pallid bat (Antrozous pallidus) and hoary bat (Lasiurus cinereus). Construction activities and tree removal may adversely impact nesting birds as well. These impacts are discussed below. California red-legged frog The California red-legged frog (CRLF) is a federally-threatened and California species of special concern that can be found in man-made or natural ponds with little shade and some aquatic vegetation, streams, and in moist upland areas near water bodies. Aquatic habitats that seasonally dry up are preferred because they are less likely to contain predators like bullfrogs (Lithobates catesbeianus) and non-native fish. CRLF, especially juveniles, can disperse into poor quality habitats more than one mile from breeding ponds (Rathbun, pers. comm.). The nearest CRLF occurrences are in Matadero and Deer Creeks, less than 0.75 miles away (CDFG, 2009), and potential dispersal and breeding habitat does exist in the basin and upstream wetlands. Construction of a two-story classroom building within 100 feet of the debris basin is scheduled in Phase 1 of the Master Plan, which could result in impacts on CRLF. Although unlikely, transient frogs could move from nearby wetland areas to the Gunn campus and be impacted by project construction activities. Additionally, sediment or hazardous materials from project activities could be carried into wetlands, Initial Study Gunn High School Master Plan 33 ESA / 209002 Initial Study September 2009 especially during rain events. Both these potential impacts will be mitigated to less-than- significant levels through Mitigation Measure BIO-1. Mitigation Measure BIO-1: PAUSD shall require its contractor(s) to install silt fence along the chain-link fence bordering the debris basin and wetland area on the west side of the campus. This would prevent any sensitive wildlife from entering active construction zones on the project site and will keep disturbed material, sediment, or hazardous materials from travelling into these waters. The fence shall be constructed of geotextile fabric with a minimum 3.5-inch overlap between panels. Fence panels shall be attached to the chain-link fence or to wooden fence posts, and sunken to a minimum of 6 inches below grade. Western Pond Turtle Western pond turtle is a California species of special concern that occupies permanent bodies of water including ponds, streams and wetlands. They are found basking on logs, rocks, or floating vegetation and submerge quickly when disturbed. Females need sandy beaches or dry upland habitats to lay eggs, and have been recorded moving as far as 100 feet from aquatic habitats to lay eggs (Zeiner, 1990). The debris basin is potential habitat for the western pond turtle year-round, and the wetlands upstream contain pond turtle habitat when seasonally inundated. The nearest CNDDB occurrences for the western pond turtle are along San Francisquito Creek and Lake Lagunita, both of which are on Stanford University land approximately 2.5 miles away from the project area. While no occurrences of western pond turtle have been documented at the debris basin, it does contain suitable western pond turtle habitat. Discharge of sediment or hazardous materials during construction would be a significant impact to western pond turtles. This potential impact would be reduced to less-than-significant levels by Mitigation Measure BIO-1. Special-Status Bats The pallid bat, hoary bat, and Townsend’s big-eared bat could be present in trees or buildings at Gunn High School. The pallid bat is a California species of concern present in most low elevations in California. Preferred habitats for the pallid bat include rocky outcrops with crevices and access to open areas, but they can be found in a variety of other habitats as well. Day roosts can be found in crevices, caves, mines, and occasionally buildings and hollow trees, while night roosts can be in more open areas such as open buildings or porches (Zeiner et al, 1990). Pallid bats are nocturnal and present year-round in most areas of California. Local CNDDB occurrences include Stanford University, and within the cities of Menlo Park, Woodside, and Los Altos (CNDDB, 2009). The hoary bat is a California species of concern and can be found at nearly any location in California. Maternity roosts of this species are typically found in woodlands with medium to large trees and dense foliage cover (Zeiner et al, 1990). Hoary bats migrate between summer and winter ranges but can be found year-round in the San Francisco Bay Area. While not common behavior, hoary bats may roost or be present on buildings or in building attics. Several historical CNDDB occurrences from nearby Stanford University and the Los Altos area exist for this species (CNDDB, 2009). Townsend’s big-eared bat is a California species of special concern also found in most of California. Roosting habitat includes Initial Study Gunn High School Master Plan 34 ESA / 209002 Initial Study September 2009 caves, mines, tunnels, buildings, or other human-made structures (Zeiner, 1990), and maternity roosts for the Townsend’s big-eared bat are warm, while hibernation roosts can be cold. This species is especially sensitive to disturbance, and a single visit by humans may result in roost abandonment. Removal of any trees or demolition of buildings containing special-status bat species in the project area would be a significant impact. This impact can be reduced to less-than- significant levels through implementation of Mitigation Measure BIO-2: Mitigation Measure BIO-2: PAUSD shall require its contractor(s) to implement the following measures: • Prior to construction or demolition activities within 250 feet of trees/structures with at least a moderate potential to support special-status bats, a qualified biologist (i.e., a biologist holding a CDFG collection permit and a Memorandum of Understanding with the CDFG allowing the biologist to handle and collect bats) shall survey for bats. If no evidence of bats (i.e., visual or acoustic detection, guano, staining, strong odors) is present, no further mitigation is required. • If bats raising pups (also called a maternity colony) are identified within 250 feet of the project area during preconstruction surveys or project construction (typically April 15 through August 15), the PAUSD will create a no-disturbance buffer acceptable in size to the CDFG around the bat roosts. Bat roosts initiated within 250 feet of the project area after construction has already begun are presumed to be unaffected by project-related disturbance, and no buffer would be necessary. However, the “take” of individuals (e.g., direct mortality of individuals, or destruction of roosts while bats are present) is prohibited. • Trees or buildings with evidence of bat activity shall be removed during the time that is least likely to affect bats as determined by a qualified bat biologist (in general, roosts should not be removed if maternity bat roosts are present, typically April 15 – August 15, and roosts should not be removed if present bats are in torpor, typically when temperatures are less than 40 degrees Fahrenheit). Non-maternity bat roosts shall be removed by a qualified biologist, by either making the roost unsuitable for bats by opening the roost area to allow airflow through the cavity, or excluding the bats using one-way doors, funnels, or flaps. • All special-status bat roosts that are destroyed shall be replaced at a 1:1 ratio with a roost suitable for the displaced species. The roost shall be modified as necessary to provide a suitable roosting environment for the target bat species. Nesting Birds Trees and buildings in and around the project area provide suitable habitats for breeding birds. Most native, breeding birds are protected under Section 3503 of the CDFG Code (Code), and raptors are protected under Section 3503.5 of the Code. In addition, both Section 3513 of the Code and the Federal Migratory Bird Treaty Act (16 U.S. Code, Sec. 703 Supp. I, 1989) prohibit the killing, possession, or trading of migratory birds. Finally, Section 3800 of the Code prohibits the taking of non-game birds, which are defined Initial Study Gunn High School Master Plan 35 ESA / 209002 Initial Study September 2009 as birds occurring naturally in California that are neither game birds nor fully protected species. To the degree feasible, construction activities would be scheduled to avoid the nesting season between February 1 and August 31. In the event construction or vegetation removal must be performed during the nesting season, potential impacts to breeding or nesting birds could be significant and would be minimized to less-than-significant levels with the implementation of Mitigation Measure BIO-3. Mitigation Measure BIO-3: If construction or vegetation removal must be performed in the bird nesting season (February 1 through August 31), a qualified biologist shall be retained to survey the project area for nesting raptors and other birds and verify the presence or absence of nesting birds or raptors no more than 14 days prior to construction activities. If active nests are observed, buffer zones shall be established around trees/shrubs with nests, with a buffer size established by the qualified biologist through consultation with the appropriate regulatory agency (e.g., CDFG). Buffered zones shall be avoided during construction activities until young have fledged or the nest is otherwise abandoned. b) Less than Significant with Mitigation. Riparian habitat exists less than 150 feet from construction areas on the western side of the Gunn campus. This habitat consists of large California buckeye (Aesculus californica), coast live oak, and willow (Salix spp.) trees lining the western side of a wetland area within the Barron Creek channel, with coyote brush and blackberry (Rubus spp.) growing inside the channel as well. The riparian area is fairly narrow and limited by a paved bike path to the east of Barron Creek and a commercial business park to the west of Barron Creek. This habitat would not be directly impacted by construction activities, and any water quality or nesting bird impacts would be mitigated to less-than-significant levels by Mitigation Measures BIO-1 and BIO-3. Other nearby riparian areas include San Francisquito Creek, Matadero Creek, and Lake Lagunita, but these are all greater than 0.5 miles from the project site and would not be impacted by project activities. Potential impacts to wetlands in the Barron Creek channel are addressed in c) below. c) Less than Significant with Mitigation. Wetlands are a subset of “waters of the United States,” which are defined in the Code of Federal Regulations (CFR) (33 CFR 328.3[a]; 40 CFR 230.3[s]) as rivers, streams, mud flats, sand flats, wetlands, sloughs, prairie potholes, wet meadows, playa lakes, or natural ponds, the use, degradation, or destruction of which could affect interstate or foreign commerce including any such waters. These waters and their associated riparian corridors (discussed under b) above) fall under the jurisdiction of the U.S. Army Corps of Engineers (Corps), San Francisco Bay Regional Water Quality Control Board, and the California Department of Fish and Game. The Barron Creek Debris Basin is less than 100 feet away from existing portable buildings on the west side of campus, and consists of a 250-foot wide pond lined with concrete. This habitat is classified by the Corps as open water, under other waters of the U.S., another subset of waters of the U.S. Ponded and open stream waters are still jurisdictional, much like wetland areas discussed above. The basin was constructed directly in the channel of Barron Creek to prevent seasonal flooding of the surrounding businesses and Initial Study Gunn High School Master Plan 36 ESA / 209002 Initial Study September 2009 neighborhoods, and is designed to catch debris that previously hindered creek flow during large storm events. No emergent vegetation is present in the pond, but dense aquatic vegetation grows along its perimeter. The wetland area slightly upstream of the debris basin contains dense areas of emergent wetland vegetation including cattails (Typha spp.), curly dock (Rumex crispus), and sedges (Cyperace spp.), but was dry when ESA conducted a site visit (ESA, 2009). Aerial photos show inundation of much of the wetland (NAIP, 2005), and it is presumed that standing water seasonally ponds there. Barron Creek is culverted for much of its extent downstream of the debris basin, but it does discharge into San Francisco Bay at the Palo Alto Baylands Park. Discharge of sediment and hazardous materials from construction work could enter these waters, and would result in significant impacts on jurisdictional waters. These impacts would be mitigated to less than significant levels through Mitigation Measure BIO-1. d) No Impact. Areas around Gunn are heavily developed, and any historically present terrestrial wildlife corridors have already been disrupted. Riparian corridors discussed in b) and extensive areas of oak savanna west of Gunn provide connected habitats suitable for migration of various wildlife species. Most developed areas of Palo Alto provide habitat for urban wildlife in landscaped environments, but little native habitat exists to provide significant wildlife movement corridors around the project area. Additionally, large roads with moderate to high traffic volume restrict movement of many terrestrial wildlife species through the project area. No impacts on wildlife corridors are anticipated by project activities. e) Less than Significant with Mitigation. Many large trees grow within the project area, and proposed construction of new facilities may necessitate tree removal. Under the City of Palo Alto Tree Preservation and Management Regulations (Municipal Code Section 8.10) and the Tree Technical Memo (City of Palo Alto, 2001), trees designated as protected trees or street trees are subject to several conditions before removal. A protected tree is: • A coast live oak (Quercus agrifolia) or valley oak (Quercus lobata) tree greater than 11.5 inches diameter at breast height (DBH)6; • A redwood (Sequioa sempervirens) tree greater than 18 inches DBH; or • Any tree designated a heritage tree by the Palo Alto city council. • A street tree is any tree that grows within the publicly-owned street right-of-way. Removal of any protected or street trees in the project area would be considered a significant impact. These impacts can be mitigated to less-than-significant levels through Mitigation Measure BIO-4. Mitigation Measure BIO-4: PAUSD shall require its contractor(s) to implement the following measures: 6 Diameter at breast height (DBH) is the diameter of the trunk of a tree 4.5 feet above natural grade. Initial Study Gunn High School Master Plan 37 ESA / 209002 Initial Study September 2009 • Fulfill pre-construction requirements consistent with Section 2.15 of the City of Palo Alto Tree Technical Memo, including establishment of a tree protection and preservation plan; verification of tree protection; a pre- construction meeting with the City Arborist, community representative, and District Arborist to coordinate a tree replacement plan and protective fencing for retained protected or street trees; establishment of tree protection zones for retained trees; and trimming of any retained trees. • Obtain a tree removal permit for removal of any street trees in the project area by submitting the following to the City of Palo Alto: 1) Protected Tree Removal Application; 2) Application fees; and 3) Letter report from a certified arborist including tree species, location, size (DBH, height and crown spread), condition, and life expectancy and prognosis. • Obtain a permit from the City of Palo Alto Department of Public works for any construction activities occurring within the dripline7 of a street tree. • Remove no more than 25 percent of a protected tree’s canopy during pruning activities of retained trees, and remove no more than 25 percent of a protected tree’s root mass during construction activities. • Replace all removed street trees as specified by the City of Palo Alto’s Director of Planning and Community Environment and in conjunction with standards described in section 3.15-C in the City of Palo Alto Tree Technical Manual. f) No Impact. The proposed project would not conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. Mitigation Measures BIO-1, BIO-2, BIO-3, and BIO-4 are designed to reduce cumulative impacts to special-status species and wetlands, and avoid conflicts with any other local plans or ordinances. Sources California Department of Fish and Game (CDFG), California Natural Diversity Database for 7.5 minute topographic quadrangles of Mountain View, Palo Alto, Commercial Version, accessed July, 2009. CDFG, California Natural Diversity Database. Special Animals (901 Taxa), www.dfg.ca.gov/biogeodata/cnddb/pdfs/SPAnimals.pdf, accessed May 18, 2009. City of Palo Alto, Department of Planning and Community Environment, Tree Technical Manual, 2001. City of Palo Alto Municipal Code, Section 8.10, www.cityofpaloalto.org/depts/clk/municipal_code.asp, accessed July 15, 2009. ESA. 2009. Site reconnaissance, July 9, 2009. 7 Dripline area, as defined in the Tree Technical Manual, is the circular area underneath a tree with a radius equal to ten times the tree’s trunk diameter. Initial Study Gunn High School Master Plan 38 ESA / 209002 Initial Study September 2009 NAIP (National Agriculture Imagery Program), U.S. Department of Agriculture Farm Service Agency, 2005. Rathbun, G., and Scott, N., Personal communication: biology and management of the California red-legged frog (Rana draytonii). Workshop sponsored by Alameda County Conservation Partnership, 2009. Zeiner, D.C., Laudenslayer, W.F., Mayer, W.E., and White, M., ed., California’s Wildlife, Volume III, Mammals, California Department of Fish and Game, Sacramento, CA, 1990. Initial Study Gunn High School Master Plan 39 ESA / 209002 Initial Study September 2009 Issues (and Supporting Information Sources): Potentially Significant Impact Less Than Significant with Mitigation Incorporation Less Than Significant Impact No Impact 5. Cultural Resources Would the project: a) Cause a substantial adverse change in the significance of a historical resource as defined in §15064.5? b) Cause a substantial adverse change in the significance of a unique archaeological resource pursuant to §15064.5? c) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? d) Disturb any human remains, including those interred outside of formal cemeteries? Discussion a) No Impact. CEQA Guidelines Section 15064.5 requires the lead agency to consider the effects of a project on historical resources. A historical resource is defined as any building, structure, site, or object listed in or determined to be eligible for listing in the California Register of Historical Resources (CRHR), or determined by a lead agency to be significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, or cultural annals of California. The following discussion will focus on architectural/structural resources. Archaeological resources, including archaeological resources that are potentially historical resources according to Section 15064.5, are addressed in b), below. The Palo Alto Unified School District (PAUSD or District) was founded in 1893. The District includes the City of Palo Alto, Stanford University, and areas of Los Altos Hills, Palo Alto Hills, and Portola Valley within its attendance area. Gunn High School was constructed in 1964 on an approximately 48-acre site northeast of the intersection of Arastradero Road and Foothill Expressway. The school is comprised of 17 permanent buildings clustered on the southern portion of the campus. These include the following: Administrative Building, Student Activities Building, cluster of four buildings for language and social studies instruction, cluster of four buildings for math and science instruction, Resource Materials Building, Music Building, Art Building, Spangenberg Auditorium, Business Education and Home Economics Building, Industrial Arts Building, and Gymnasium. The original buildings were constructed in 1964, as described above, with a new Library Building and Science facility added in 2003. The modern architectural style of the campus buildings features single-story structures (with the exception of the Gym and Spangenberg Auditorium) with exterior wood siding, small window openings, and attached covered walkways supported by concrete columns and mansard roofs. Most of the southern portion of the campus is paved with trees and other landscaping interspersed between the buildings. All buildings with the exception of the interiors to the Gym, Spangenberg Auditorium, Administration, and the old Library Building were fully renovated under the Initial Study Gunn High School Master Plan 40 ESA / 209002 Initial Study September 2009 Building for Excellence Program. The campus also includes approximately 26 relocatable classrooms. Archival research revealed that none of the buildings on the Gunn campus are listed in the federal, state, or local listings of historical resources. While the campus has not been systematically surveyed or evaluated for any potential historical or architectural significance, given the age of the campus, it would not meet the minimum threshold for consideration for listing, which is generally 50 years of age or older. In addition, research revealed no significant associations with important historical events, important persons, or buildings with a high degree of architectural merit. Due to their relatively recent age and general lack of historical and architectural merit, none of the buildings on the Gunn campus appear eligible for listing in the federal, state, or local listings of historical resources. While the proposed project would make a number of physical changes to the campus, no direct or indirect impacts to historic architectural resources (either on or off-campus) as defined by CEQA Section 15064.5 are anticipated. No mitigation measures would be necessary. b) Less Than Significant with Mitigation. This section discusses archaeological resources, both as historical resources according to Section 15064.5 as well as unique archaeological resources as defined in Section 21083.2 (g). A records search was conducted at the Northwest Information Center of the California Historical Resources Information System (NWIC) at Sonoma State University on June 29, 2009 (File No. 08-1672) to: (1) determine whether known archaeological resources had been recorded within a 0.5 mile radius of the project site; (2) assess the likelihood for unrecorded archaeological resources to be present based on historical references and the distribution of nearby archaeological sites; and (3) develop a context for the identification and preliminary evaluation of cultural resources. During the records search, the following sources for information on historical resources were reviewed: the California Inventory of Historical Resources (OHP, 1976), California Historical Landmarks (DPR, 1996), California Points of Historical Interest (DPR, 1992), and Historic Properties Directory Listing (OHP, 2009). The Historic Properties Directory includes listings of the National Register of Historic Places and the California Register of Historical Resources, and the most recent listings of California Historical Landmarks and California Points of Historical Interest. Historic topographic maps were also reviewed. The project site is situated within the territory of the Costanoan—also referred to as Ohlone—language groups. Eight Costanoan languages were spoken in an area extending from the southern edge of the Carquinez Strait to portions of the Sur and Salinas Rivers south of Monterey Bay (Levy, 1978). At the time of Euro-American contact, Ramaytush speakers occupied the San Francisco Peninsula. Levy’s 1978 summary of Costanoan lifeways describes territories as comprised of one or more land-holding groups, which anthropologists named tribelets. The tribelet, or village community, was a nearly universal characteristic throughout Native California, consisting of a principal village that was occupied year-round and a series of smaller hamlets occupied intermittently or seasonally (Kroeber, 1925). Tribelet territories were generally defined on the basis of physiographic Initial Study Gunn High School Master Plan 41 ESA / 209002 Initial Study September 2009 features (e.g., river drainage systems) and stretched between 8 and 12 miles across. Population densities within tribelets ranged from 50 to 500 people and were largely determined by the carrying capacity of a tribelet’s territory. San Francisquito Creek, located approximately 3.5 miles northwest of the project site, was one of the most densely occupied watersheds along the San Francisco Peninsula during the prehistoric period. At the time of Euroamerican contact, two or more Ohlone tribelets may have occupied this watershed at the villages of puyšon and Ssiputca. No archaeological resources have been recorded in the immediate project site. Two archaeological sites have been recorded north of the project site along the south bank of Matadero Creek (Bocek and Rutherford, 1985; Bocek, 1987). Both archaeological sites are extensive shell middens with artifacts and human remains, likely related to a major prehistoric occupation area along Matadero Creek. An ESA Registered Professional Archaeologist surveyed the project site on August 22, 2009. The project site was walked in transects spaced 10–20-meters apart. Visibility was moderate in the undeveloped area nearest to the recorded archaeological sites. Exposed ground surface and rodent holes were inspected for cultural materials. No cultural materials were located. The project site is in an area mapped as bedrock. This geologic landform does not have the potential to contain deeply-buried soils or paleosols that would have once been available for human use and occupation. The project site does not appear to contain archaeological materials; however the possibility cannot be entirely discounted. The following mitigation measure would reduce potential impacts to the inadvertent discovery of archaeological resources to a less-than- significant level. Mitigation Measure CUL-1: If previously unidentified cultural materials are unearthed during construction, work shall halt in that area until a qualified archaeologist can assess the significance of the find. Additional archaeological survey will be needed if project limits are extended beyond the present study limits. Prehistoric materials might include obsidian and chert flaked-stone tools (e.g., projectile points, knives, scrapers) or toolmaking debris; culturally darkened soil (“midden”) containing heat-affected rocks, artifacts, or shellfish remains; and stone milling equipment (e.g., mortars, pestles, handstones, or milling slabs); and battered stone tools, such as hammerstones and pitted stones. Historic-era materials might include stone, concrete, or adobe footings and walls; filled wells or privies; and deposits of metal, glass, and/or ceramic refuse. If any find is determined to be significant, the project proponent and the archaeologist will meet to determine the appropriate avoidance measures. If the resources cannot be avoided they must be evaluated for their eligibility to the California Register of Historical Resources. c) Less Than Significant with Mitigation. Paleontological resources are the fossilized remains of plants and animals, including vertebrates (animals with backbones), invertebrates (e.g., starfish, clams, ammonites, and marine coral), and fossils of microscopic plants and animals (microfossils). The age and abundance of fossils depend on the location, topographic setting, and particular geologic formation in which they are found. Initial Study Gunn High School Master Plan 42 ESA / 209002 Initial Study September 2009 Subsurface excavations into undisturbed soils and rock beneath the high school could potentially disturb or destroy paleontological resources. Gunn High School is underlain by the Santa Clara Formation, which is a sedimentary rock unit that is approximately 3.5 to 11 million years old and has yielded fossilized plants and animals in other locations in the Bay Area. The University California Museum of Paleontology contains five records of vertebrate fossils that originated in the Santa Clara Formation, including teeth and bone fragments from several extinct species of hoofed mammals (UCMP, 2009). The closest of these finds is on the Stanford Campus, approximately 2.5 miles northwest of the site. Plant fossils found within the unit include petrified wood fragments as large as 60 cm in diameter at Coal Mine Ridge in the Santa Cruz Mountains and a suite of plant fossils along Scott Creek, approximately 8.5 miles southwest of the site (UCMP, 2009; USGS, 2000). Fossil discoveries of this kind provide scientific value because they help establish a historical record of past plant and animal life and can assist geologists in dating rock formations. Because the Santa Clara Formation beneath Gunn High School has yielded vertebrate fossils, it qualifies under the Society of Vertebrate Paleontology guidelines as a unit of high paleontological potential8 (SVP, 2006). While no information exists to refute or confirm the presence of fossils beneath the high school, disturbance or destruction of a paleontological resource is a potentially significant impact if excavations for the project disturb the Santa Clara Formation. Mitigation Measure CUL-2 would reduce this impact to a less than significant level by informing earth moving crews on the appearance of fossils, procedures to follow if any are discovered, and ensuring that a paleontologist assess the significance of any fossil find, and recovers it, if appropriate. Mitigation Measure CUL-2: Prior to the start of any subsurface excavations, all construction forepersons and field supervisors shall receive training by a qualified professional paleontologist, as defined by the SVP (1995), who is experienced in teaching non-specialists, to ensure they can recognize fossil materials and will follow proper notification procedures in the event any are uncovered during construction. Procedures to be conveyed to workers include halting construction within 50 feet of any potential fossil find and notifying a qualified paleontologist, who will evaluate its significance. Training on paleontological resources will also be provided to all other construction workers, but may involve using a videotape of the initial training and/or written materials rather than in-person training by a paleontologist. If a fossil is determined to be significant and avoidance is not feasible, the paleontologist will develop and implement an excavation and salvage plan in accordance with SVP standards (SVP, 1995; SVP, 1996). d) Less than Significant with Mitigation. Based upon the records search, no human remains are known to exist within the project site. The proposed project would involve ground- disturbing activities; therefore the possibility that such actions could unearth, expose, or disturb buried human remains cannot be entirely discounted. The following mitigation measure would reduce potential impacts attributable to the inadvertent discovery of human remains to a less-than-significant level. 8 Paleontological potential refers to the probability that a rock unit will yield a unique or significant paleontological resource. Initial Study Gunn High School Master Plan 43 ESA / 209002 Initial Study September 2009 Mitigation Measure CUL-3: If human remains are encountered unexpectedly during construction excavation and grading activities, State Health and Safety Code Section 7050.5 requires that no further disturbance shall occur until the County Coroner has made the necessary findings as to origin and disposition pursuant to PRC Section 5097.98. If the remains are determined to be of Native American descent, the coroner has 48 hours to notify the Native American Heritage Commission (NAHC). The NAHC will then identify the person(s) thought to be the Most Likely Descendent of the deceased Native American, who will then help determine what course of action should be taken in dealing with the remains. Sources Bocek, Barbara, Archaeological Site Record for CA-SCL-616. On file, Northwest Information Center of the California Historical Resources Information System, Sonoma State University, Rohnert Park, California, 1987. Bocek, Barbara, and James Rutherford, Archaeological Site Record for CA-SCL-585. On file, Northwest Information Center of the California Historical Resources Information System, Sonoma State University, Rohnert Park, California, 1985. California Department of Parks and Recreation (DPR), California Points of Historical Interest, Office of Historic Preservation, Sacramento, California, 1992. California Department of Parks & Recreation (DPR), California Historical Landmarks, Sacramento: State of California, Resources Agency, 1996. Kroeber, Alfred L., Handbook of the Indians of California. Bureau of American Ethnology Bulletin 78. Smithsonian Institution, Washington, D.C., Reprinted 1976 by Dover, New York, 1925. Levy, Richard, Costanoan In California. Handbook of North American Indians, vol. 8, William C. Sturtevant, general editor. 1978. Society of Vertebrate Paleontology (SVP), Assessment and mitigation of adverse impacts to nonrenewable paleontologic resources: standard guidelines, Society of Vertebrate Paleontology News Bulletin, Vol. 163, pp. 22–27, 1995. Society of Vertebrate Paleontology (SVP), Conditions of Receivership for Paleontologic Salvage Collections, Society of Vertebrate Paleontology News Bulletin, Vol. 166, pp. 31–323, February 1996. United States Geological Society (USGS), Geologic map and map database of the Palo Alto 30’ X 60’ quadrangle, California, Prepared by Brabb E.E., Graymer R.W., and Jones D.L., USGS Miscellaneous Field Studies, Map MF-2332, Version 1.0, 2000. University of California Museum of Paleontology (UCMP), Collections Database. Accessed Online August 20, 2009 at: http://www.ucmp.berkeley.edu/science/collections.php. Initial Study Gunn High School Master Plan 44 ESA / 209002 Initial Study September 2009 Issues (and Supporting Information Sources): Potentially Significant Impact Less Than Significant with Mitigation Incorporation Less Than Significant Impact No Impact 6. Geology and Soils Would the project: a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42. ii) Strong seismic ground shaking? iii) Seismic-related ground failure, including liquefaction? iv) Landslides? b) Result in substantial soil erosion or the loss of topsoil? c) Be located on geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse? d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994, as it may be revised), creating substantial risks to life or property? e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater? Setting The City of Palo Alto is located along the southern portion of the San Francisco Peninsula. The landscape is typical of much of the California Coast Ranges, characterized mainly by northwest trending ridges and valleys of moderate topographic relief. The area is also characterized by numerous active and potentially active faults, and frequent earthquakes. The San Andreas fault, a major tectonic and structural feature of the Coast Range, that bisects the City’s foothill area, forms the boundary between the North American and Pacific plates. The greatest hazards associated with earthquakes are fault rupture and groundshaking, although liquefaction hazards are significant east of U.S. Highway 101 due to the porous nature and relatively shallow groundwater table. Other geologic hazards in Palo Alto may or may not include landslides, expansive soils, settlement, and erosion. Landsliding may result from heavy rain, erosion, removal of vegetation, or human activities. Settlement and subsidence due to groundwater withdrawal has historically been a problem in south and east Palo Alto but has been largely halted by groundwater recharge efforts and reduced pumping from local groundwater resources. Seismically-induced flooding is a hazard due to the possibility of dam failure at Felt Initial Study Gunn High School Master Plan 45 ESA / 209002 Initial Study September 2009 Lake, Searsville Lake, and Lagunita Reservoir, as well as from the potential for levee failure near the San Francisco Bay. Discussion a.i) Less than Significant with Mitigation. Surface fault rupture is most commonly seen along traces of active faults during major earthquakes and results in observable offsets on the ground surface. On faults that generate horizontal movement (referred to as strike-slip faults) this displacement along a fault trace can cause considerable damage to a structure, even collapse. Non-structural damage from fault rupture includes distorted asphalt, severe utility damage, distressed foundations and extensive service disruption for transportation facilities. Surface fault rupture presents a substantial potential risk to people and property, especially in the San Francisco Bay Area where there are several active faults. The State of California, through the Alquist-Priolo Earthquake Fault Zoning Act (Alquist- Priolo Act), prohibits the development of structures for human occupancy across active fault traces9. Under the Alquist-Priolo Act, the California Geological Survey (CGS) must establish zones on either side of the active fault that delimit areas most susceptible to surface fault rupture. These zones are referred to as fault rupture hazard zones and are shown on official maps published by the CGS. The project site is located approximately five miles from the San Andreas fault. The project site is not located in an Alquist-Priolo Earthquake Fault Zone, as defined by the CGS. However, the project site is located in the immediate vicinity of the Stanford fault zone, which is part of the front-range fault system. The location and levels of risk associated with individual faults of the front-range fault system are not well defined and there is no known displacement within the last 10,000 years. The location of the probable rupture area within the Stanford fault zone is poorly defined; therefore, the level of risk associated with rupture of the Stanford fault zone is essentially undefined (City of Palo Alto DEIR, 1996). From a planning standpoint, the Stanford fault zone should be considered as potentially active with associated zones of possible surface rupture. The ability to produce an earthquake large enough to rupture the earth’s surface is significantly less certain along the Stanford fault zone than that of the San Andreas fault because there is no documented historic record of ground rupture. The project site is located between two concealed fault traces of the Pulgas fault within the frontal Stanford fault zone, a series of high angle thrust faults generally located along the base of the low hills lying immediately west of the campus. The nearest mapped traces of 9 An active fault is defined by the State of California as a fault that has had surface displacement within Holocene time (approximately the last 10,000 years). A potentially active fault is defined as a fault that has shown evidence of surface displacement during the Quaternary (last 1.6 million years), unless direct geologic evidence demonstrates inactivity for all of the Holocene or longer. This definition does not, of course, mean that faults lacking evidence of surface displacement are necessarily inactive. Sufficiently active is also used to describe a fault if there is some evidence that Holocene displacement occurred on one or more of its segments or branches (Hart, 1997). Initial Study Gunn High School Master Plan 46 ESA / 209002 Initial Study September 2009 the Pulgas fault are located approximately 200 feet to the southwest and 400 feet to the northwest of the site. According to the geotechnical report prepared for Gunn (Cleary, 2009), the evidence for Holocene activity on the Stanford fault zone, and specifically the Pulgas fault, is inconclusive and thus a “very low likelihood” that proposed improvements would be affected due to surface displacement on the fault. Implementation of Mitigation Measure GEO-1 would ensure that impacts related to surface rupture would be less than significant. Mitigation Measure GEO-1: The proposed construction shall comply with site specific recommendations made in design level geotechnical investigations by the District’s geotechnical engineers. These recommendations shall be designed to mitigate geologic hazards and shall become part of the project. The final seismic considerations shall be submitted to and approved of by the Division of the State Architect (DSA), prior to project commencement, to ensure compliance with the most current California seismic building codes. a.ii) Less than Significant with Mitigation. Seismic ground shaking is a significant hazard within Palo Alto because of its close proximity to the San Andreas fault, the Hayward fault, the front-range fault system, and several other faults within the Bay Area that have the capability of producing a large magnitude earthquake. The level of shaking is influenced by various factors including distance to the epicenter, underlying soil or bedrock conditions, and the magnitude of the event. In April 2008, a new earthquake forecast called the Uniform California Earthquake Rupture Forecast (UCERF) was released that updated the earthquake forecast for the Bay Area. Produced by the U.S. Geological Survey 2007 Working Group on California Earthquake Probabilities (WG07), the UCERF evaluated the likelihood of one or more earthquakes of moment magnitude 6.7 or higher occurring in the San Francisco Bay Area.10 The result of the evaluation indicated a 63 percent likelihood that such an earthquake event will occur in the Bay Area before 2037. Within this 63 percent probability, the Hayward-Rodgers Creek and San Andreas Fault systems are the two most likely fault systems to cause the event (UCERF, 2008). Therefore, the proposed project would likely experience at least one major earthquake (greater than moment magnitude 6.7) before 2037. 10 Moment magnitude is related to the physical size of a fault rupture and movement across a fault. The Richter magnitude scale reflects the maximum amplitude of a particular type of seismic wave. Moment magnitude provides a physically meaningful measure of the size of a faulting event (CGS, 1997). Initial Study Gunn High School Master Plan 47 ESA / 209002 Initial Study September 2009 According to the CGS Probabilistic Seismic Hazard Assessment (PSHA), peak ground acceleration at the project site could reach or exceed 0.6 g (CGS, 2009).11 The PSHA identifies the hazard from earthquakes that geologists and seismologists agree could occur. It is “probabilistic” in the sense that the analysis takes into consideration the uncertainties in the size and location of earthquakes and the resulting ground motions that can affect a particular site. In addition, the Association of Bay Area Governments (ABAG) determined that ground shaking at the project site would most likely be felt as very strong if a moment magnitude 7.2 earthquake were to occur on the San Andreas Fault Zone (ABAG, 2009). Ground shaking from a moderate to strong earthquake could generate ground accelerations at the proposed project site that could cause damage to structures, utilities, and/or unsecured equipment and objects. Specifically, the proposed school buildings and underground utilities could sustain structural damage, potentially causing injury to anyone present during an earthquake event. Damage from ground shaking could include cracking in walls and pavement and damage to exterior building elements. Although some structural damage is typically not avoidable during an earthquake, current building codes and construction ordinances have been established to protect against building collapse and major injury during a seismic event. Implementation of Mitigation Measure GEO-1 would ensure that the level of risk from ground shaking would be less than significant. a.iii) Less than Significant. Liquefaction is the sudden temporary loss of shear strength in saturated, loose to medium dense, granular sediments subjected to ground shaking. It generally occurs when seismically induced ground shaking causes pore water pressure to increase to a point equal to the overburden pressure. Liquefaction can cause foundation failure of buildings and other facilities due to the reduction of foundation bearing strength. The State of California, through the Seismic Hazard Zonation Program, produces Seismic Hazard Zone maps that identify areas of liquefaction and landsliding, as required by the Seismic Hazards Mapping Act. These maps depict “areas where historical occurrence of liquefaction, or local geological, geotechnical and ground water conditions indicate a potential for permanent ground displacement such that mitigation as defined in Public Resources Code Section 2693(c) would be required.” Mitigation is defined as “those measures that are consistent with established practice and that will reduce seismic risk to acceptable levels.”[PRC 2693(c)] The CGS Seismic Hazard Zone map for the Palo Alto Quadrangle (CGS, 2006) shows a narrow band of liquefaction running across the campus along the undergrounded Barron Creek. This area begins at the Santa Clara Valley Water District detention basin on the 11 g is equivalent to the acceleration due to gravity, or 980 centimeters per second squared. Acceleration is scaled against acceleration due to gravity or the acceleration with which a ball falls if released at rest in a vacuum (1.0 g). Acceleration of 1.0 g is equivalent to a car traveling 100 meters (328 feet) from rest in 4.5 seconds. Initial Study Gunn High School Master Plan 48 ESA / 209002 Initial Study September 2009 western boundary of the campus, runs between the existing gymnasium and football field, and exits the campus near Los Robles Avenue. The geotechnical investigation (Cleary, 2009) determined that proposed new building sites are generally underlain by firm to very stiff sandy clay and medium dense to very dense clayey sand, silty gravelly clayey sand and sandy clay gravel from the surface to the maximum depth explored of 45 feet. Based on these conditions, the likelihood of soil liquefaction during strong ground shaking is very low; however, the sand and clay layers encountered in borings below the assumed high groundwater table (estimated to be at 25 feet) were conservatively analyzed for liquefaction-induced settlement. The analysis calculated the theoretical liquefaction-induced settlements as less than an inch a proposed building sites. Because the computed settlements would occur below a depth of 25 feet, the likelihood of significant surface manifestation from settlement at such depth is low. The proposed second gymnasium, as well as the relocated tennis and basketball courts, are located in proximity to this liquefaction zone. Construction of these proposed facilities in this area may lead to foundation failure during a seismic event. With implementation of Mitigation Measure GEO-1, the potential impact associated with liquefaction would be reduced to a less than significant level. a.iv) Less than Significant. Slope failures, including landslides, include many phenomena that involve the down-slope displacement and movement of material, either triggered by static (i.e. gravity) or dynamic (i.e. earthquake) forces. Slope failure is dependent on degree of incline, subsurface materials, precipitation, excavation, and seismicity. The type of failure can include deep-seated massive slope movements or shallow slump type movements. The project site is generally level and it is not located within an “earthquake-induced landslide” zone according to the Seismic Hazard Zone map for the Palo Alto Quadrangle (CGS, 2006). Therefore, the potential impact of slope failure would be considered less than significant. b) Less than Significant with Mitigation. Construction activities associated with the proposed project would require earthmoving, grading, and compaction. These activities may expose areas of soil that have previously been covered with asphalt, concrete, or landscaping. This temporary loss of erosion control would expose bare soil, which would be subjected to erosion by wind and storm water runoff. Concentrated water erosion, if not managed or controlled, can eventually result in substantial soil loss and/or discharging of sediment into utilities, adjacent lots, or nearby creeks and drainages. Excessive soil loss can cause a potential threat to the structural integrity of structural foundations, earthen berms, or engineered fills. Stormwater discharges from construction activities that disturb one acre or more are regulated by the local Regional Water Quality Control Board (RWQCB) and are subject to Initial Study Gunn High School Master Plan 49 ESA / 209002 Initial Study September 2009 the permitting requirements of the National Pollutant Discharge Elimination System (NPDES) General Permit for Discharges of Stormwater Runoff Associated with Construction Activity (General Construction Permit). The General Construction Permit requires the preparation and implementation of a Storm Water Pollution Prevention Plan (SWPPP) for construction activities. As fully described in Checklist Item 8, Hydrology and Water Quality, Mitigation Measure HYD-1, the PAUSD would be required to develop and implement a SWPPP in order to minimize potential erosion and subsequent sedimentation of storm water runoff. This SWPPP would include Best Management Practices (BMPs) to control erosion associated with grading, trenching, and other ground surface-disturbing activities. Since BMPs have been recognized as methods to effectively prevent or minimize the erosion, and the PAUSD will adhere to erosion control measures outlined in the SWPPP, the potential for erosion impacts during the various projects would be less than significant. c) Less than Significant with Mitigation. The upper soils at the project site were found to be of variable density and strength, and are considered unsuitable for support of proposed building foundations and slabs if left in place (Cleary, 2009). However, over-excavation and replacement with engineered fill in compliance with the standards described in the preliminary foundation recommendations would mitigate the potential for unstable soils to affect the building foundations (Cleary, 2009). The potential landslide hazard for the proposed project is discussed above in Section 6.a.iv. With implementation of preliminary foundation recommendations and Mitigation Measure GEO-1, above, the potential hazard from unstable soils would be considered less than significant. Due to the generally high relative densities associated with the subsurface soils, soil lurching and lateral spreadings are considered unlikely (Cleary, 2009) d) Less than Significant with Mitigation. Preliminary foundation recommendations indicated that upper sandy clay at the project site is considered to be moderately to highly expansive based on its plasticity characteristics and laboratory test results (Cleary, 2009). The effects of expansive soils could damage foundations and aboveground structures, paved parking areas, and concrete slabs. Surface structures with foundations constructed in expansive soils could experience expansion and contraction depending on the season and the amount of surface water infiltration. The expansion and contraction due to the behavior of expansive soils could exert enough pressure on the structures to result in cracking, settlement, and uplift. Cleary indicates that the potential detrimental effects of expansive soils may be largely eliminated through the proposed grading plan and replacement of well- compacted engineered fill. Interior and exterior slabs should be supported on a cushion of imported aggregate base to minimized expansive soil movements. Recommendations given in the geotechnical reports require design and construction of the proposed projects to follow engineering design criteria needed to improve and/or eliminate settlement from expansive soils conditions. Initial Study Gunn High School Master Plan 50 ESA / 209002 Initial Study September 2009 The design and construction of the proposed project in accordance with the engineering recommendations of the preliminary foundation recommendation by Cleary, and implementation of Mitigation Measure GEO-1, would ensure that the level of risk from expansive soils would be less than significant. e) No Impact. Implementation of the proposed project would not involve the use of septic tanks or alternative wastewater treatment disposal systems to handle wastewater generation. Therefore, no impact would result from project implementation. Sources Association of Bay Area Governments (ABAG), Earthquake Hazard Map for Palo Alto/Stanford, Peninsula Segment of the San Andreas Fault System, www.abag.ca.gov/cgi- bin/pickmapx.pl, accessed July 20, 2009. California Geological Survey (CGS), Probabilistic Seismic Hazards Mapping Ground Motion Page, http://redirect.conservation.ca.gov/cgs/rghm/psha/pshamap.asp, accessed July 10, 2009. CGS, Seismic Hazard Zones, Palo Alto Quadrangle Official Map, October 18, 2006. CGS, Special Studies Zones, Palo Alto Quadrangle Official Map, July 1, 1974. California Public Resources Code, Division 2, Geology, Mines and Mining, Chapter 7.8, Seismic Hazards Mapping, Section 2693(c). City of Palo Alto, Comprehensive Plan Update, 1996. City of Palo Alto, Draft and Final Environmental Impact Report, Comprehensive Plan Update, 1996. Cleary Consultants, Inc., Geotechnical Investigation, Campus Improvements-Group 1, Gunn High School, July 31, 2009. Initial Study Gunn High School Master Plan 51 ESA / 209002 Initial Study September 2009 Issues (and Supporting Information Sources): Potentially Significant Impact Less Than Significant with Mitigation Incorporation Less Than Significant Impact No Impact 7. Hazards and Hazardous Materials Would the project: a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? f) For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area? g) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? h) Expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands? Setting Hazardous materials are handled and stored on a number of properties in Palo Alto, primarily in the East Bayshore and San Antonia Road/Bayshore corridor, University Avenue/Downtown, the South of Forest Area, and at the Stanford Research Park. Contamination has resulted from leaking underground storage tanks, disposal of hazardous materials, and various industrial practices. Fuel leak sites are concentrated in the areas of University Avenue/Downtown, South of Forest, the Stanford Research Park, and along San Antonia Road, Alma Street, and El Camino Real. The California Environmental Protection Agency, Department of Toxic Substances Control (DTSC) is authorized by the United States Environmental Protection Agency (EPA) to enforce and implement federal hazardous materials laws and regulations, including disposal and transportation of hazardous materials. Initial Study Gunn High School Master Plan 52 ESA / 209002 Initial Study September 2009 Discussion a, b) Less than Significant with Mitigation. The Department of Toxic Substances Control (DTSC) EnviroStor database listed one site at or in the vicinity of the school as having had a past release to soil and/or groundwater (DTSC, 2009). The former Fairchild Semiconductor site at 4001 Miranda Avenue is currently undergoing remediation. A land use covenant was recorded in 2003 that prohibits the use of groundwater at the site as a source of drinking water until groundwater cleanup standards have been achieved (SCCR, 2003). Water supply to the City of Palo Alto, and the project site, is provided by the San Francisco Public Utilities Commission’s Hetch Hetchy water supply system, which is not sourced from local groundwater supplies. Therefore, this contamination would not be considered a hazard to development of the proposed project. The proposed project includes re-grading in areas prior to new construction. Construction would require the use of certain hazardous materials such as fuels, oils, solvents, and glues. Inadvertent release of large quantities of these materials into the environment could adversely impact soil, surface waters, or groundwater quality. However, implementation of Mitigation Measure HAZ-1 would reduce the risk associated with hazardous materials used during construction to a less than significant level. Mitigation Measure HAZ-1: The PAUSD shall require its contractor(s) to use construction best management practices typically implemented as part of its construction activities to minimize the potential adverse effect of the project to groundwater and soils from construction activities. These shall include the following: • Follow manufacturer’s recommendations on the use, storage, and disposal of chemical products used in construction; • Avoid overtopping construction equipment fuel tanks; • During routine maintenance of construction equipment, properly contain and remove grease and oils; and • Properly dispose of discarded containers of fuels and other chemicals. c) Less than Significant with Mitigation. The project site consists of an existing high school. As under existing conditions, proposed development on the campus, including new classrooms, lounges, recreational facilities, and other associated educational facilities, would involve storage and use of limited quantities of hazardous materials such as cleaners, toners, correction fluid, paints, lubricants, kitchen and restroom cleaners, pesticides and other maintenance materials, but not to the extent of causing a significant impact. Construction and renovation of the various Master Plan projects would be completed in phases over a period of several years with some of the work scheduled for the summer months. Considering the types and quantities of hazardous materials used and stored, and implementation of Mitigation Measure HAZ-1, the proposed project would not emit or use acutely hazardous materials during either construction or operation that would significantly impact the schools or immediate area. Initial Study Gunn High School Master Plan 53 ESA / 209002 Initial Study September 2009 d) No Impact. The project site is not included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5; therefore, no impact would result (DTSC, 2009). e, f) No Impact. The project site is not located within the boundaries of the Comprehensive Land Use Plan (CLUP) for the Palo Alto Airport or within the vicinity of a private airstrip. No element of the proposed project would result in a safety hazard related to air traffic. g) Less than Significant. The proposed project would not impair implementation of, or physically interfere with, an adopted emergency response plan or emergency evacuation plan. Please also refer to Checklist Item 15, Traffic and Transportation for additional discussion of emergency access. h) No Impact. The project site is located in an urbanized area and is not intermixed with or adjacent to wildlands. There are no elements of the proposed project that would increase the potential for wildfires in the project vicinity. All new buildings would be required to comply with all applicable fire code and fire suppression systems, and be approved by the Division of State Architect for fire and life-safety compliance. Therefore, the proposed project would not expose people or structures to significant risks associated with wildland fires. Sources California Department of Toxic Substances Control (DTSC), EnviroStor Database, www.envirostor.dtsc.ca.gov, accessed July 21, 2009. City of Palo Alto, Comprehensive Plan Update, 1996. City of Palo Alto, Draft and Final Environmental Impact Report, Comprehensive Plan Update, 1996. County of Santa Clara, Comprehensive Airport Land Use Plan, Palo Alto Airport, adopted November 19, 2008. County of Santa Clara, Wildland Urban Interface Fire Area Map, February 24, 2009. Santa Clara County Recorder (SCCR), Covenant and Environmental Restriction on Property, 4001 Miranda Avenue, Palo Alto, Document No. 17136705, June 25, 2003. Initial Study Gunn High School Master Plan 54 ESA / 209002 Initial Study September 2009 Issues (and Supporting Information Sources): Potentially Significant Impact Less Than Significant with Mitigation Incorporation Less Than Significant Impact No Impact 8. Hydrology and Water Quality Would the project: a) Violate any water quality standards or waste discharge requirements? b) Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted)? c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion of siltation on- or off-site? d) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site? e) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? f) Otherwise substantially degrade water quality? g) Place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map? h) Place within a 100-year flood hazard area structures which would impede or redirect flood flows? i) Expose people or structures to a significant risk of loss, injury or death involving flooding, including flooding as a result of the failure of a levee or dam? j) Inundation of seiche, tsunami, or mudflow? Setting The City of Palo Alto is located in the watersheds of several creeks and drainageways, including Adobe, Barron, Matadero, and San Francisquito Creeks. The Santa Clara Valley Water District regulates creekside development and provides flood control services in the City of Palo Alto. Barron Creek begins in the foothills of Los Alto Hills and flows northwest through Palo Alto until it joins Adobe Creek just west U.S. Highway 101. Barron Creek is in a relatively natural state southwest of the project site. A flood control project was completed in 1996 that diverts excess flows from the creek into Matadero Creek during large storm events. Barron Creek flows in an underground culvert across the project site beginning at a Santa Clara Valley Water District retention basin on the western boundary of the campus. Most of the urban core of Palo Alto is located within the Federal Emergency Management Agency (FEMA) Flood Zone X. These areas are outside the 100-year flood zone, but within the Initial Study Gunn High School Master Plan 55 ESA / 209002 Initial Study September 2009 500-year flood zone. Some areas are located within Special Flood Hazard Areas, which are subject to flooding in the event of a 100-year flood. Groundwater in Palo Alto is contained in both shallow and deep aquifers formed in the alluvial deposits of streams running from the foothills to the San Francisco Bay. Historical saltwater intrusion in the shallow aquifers along the bay has largely been reversed as alternative sources of water have been secured for irrigation and other purposes. Surface water bodies in and around the City include Felt, Searsville, Boronda, and Arastradero RoadLakes and the Lagunita Reservoir. Discussion a) Less than Significant with Mitigation. The proposed project could result in potential water quality impacts during construction phases. Construction activities involving soil disturbance, excavation, cutting/filling, stockpiling, and grading activities could result in increased erosion and sedimentation to surface waters, which could produce contaminated stormwater runoff, a major contributor to the degradation of water quality. Project construction would also involve use of motorized heavy equipment, including trucks and other construction vehicles that require fuel, lubricating grease, and other fluids. Accidental chemical release or spill from a vehicle or equipment could affect surface water. Such spills could also wash into nearby storm drains or infiltrate into soil affecting groundwater quality. However, the volume of material would not be significant; therefore runoff and groundwater pollution resulting from use of construction vehicles is considered minimal. Furthermore, implementation of standard construction procedures and precautions as discussed under Section 7, Hazards and Hazardous Materials, would ensure that impacts related to construction vehicle pollutants would be less than significant. The NPDES permit program under the Federal Clean Water Act controls water pollution by regulating point and nonpoint sources that discharge pollutants into “waters of the U.S.” Authority for NPDES permitting has been delegated by the federal government to the California State Water Resources Control Board (SWRCB), which has nine regional boards; the San Francisco Bay Regional Water Quality Control Board (RWQCB) regulates water quality in the project area. The Santa Clara Valley Urban Runoff Pollution Prevention Program (SCVURPPP) is an association of thirteen cities and towns in the Santa Clara Valley (including Palo Alto), together with Santa Clara County and the Santa Clara Valley Water District. Program participants share a common permit to discharge stormwater to South San Francisco Bay. The RWQCB issued the SCVURPPP its first NPDES permit in 1990, and reissued the permit in 1995. In 2001, the SCVURPPP was reissued its third NPDES permit and provision C.3 of the permit was also revised to address post-construction and some construction phase impacts of new and redevelopment projects on stormwater quality. Provision C.3 calls for enhancement of the existing performance standard to increase the effectiveness of existing implementation, primarily by: 1) setting volume and flow based hydraulic sizing criteria for stormwater treatment measures; 2) setting minimum sizes of Initial Study Gunn High School Master Plan 56 ESA / 209002 Initial Study September 2009 new development and redevelopment projects which must employ the treatment measures; 3) creation of a program to assure the adequate operation and maintenance of treatment measures occurs; 4) creation of standards for source control measures and site design measures which can lead to reduced impervious surface for a given equivalent land use; and 5) development of a process and criteria to limit changes in the runoff hydrograph for new and redevelopment, where those changes could have a harmful effect on downstream beneficial uses by excessive erosion of the bed and bank of downstream watercourses. Stormwater discharges from construction activities on one acre or more are regulated by the RWQCB and are subject to the permitting requirements of the NPDES General Permit for Discharges of Stormwater Runoff Associated with Construction Activity (General Construction Permit). The General Construction Permit requires the preparation and implementation of a SWPPP for construction activities. As described in Checklist Item 6, Geology and Soils, above, the SWPPP must be prepared before the construction begins, and in certain cases, before demolition begins. The SWPPP must include specifications for BMPs that would need to be implemented during project construction. BMPs are measures that are undertaken to control degradation of surface water by preventing soil erosion or the discharge of pollutants from the construction area. The SWPPP must describe measures to prevent or control runoff after construction is complete and identify procedures for inspecting and maintaining facilities or other project elements. The proposed project would disturb approximately 2.4 acres (DLM, 2009), exceeding the NPDES one-acre threshold; therefore, the PAUSD would be required to apply to the RWQCB for the General Construction Permit and comply with the SCVURPPP NPDES requirements that apply to “significant redevelopment” projects. Implementation of a SWPPP as required by Mitigation Measure HYD-1 would ensure that the proposed project would not violate any water quality standards or waste discharge requirements and reduce potential impacts to a less than significant level. Mitigation Measure HYD-1: The PAUSD shall apply for coverage under the State General Construction Permit to comply with federal NPDES regulations. The NPDES and State General Construction Permit require a project applicant to develop and implement a Storm Water Pollution Prevention Plan (SWPPP) that identifies appropriate construction BMPs in order to minimize potential sedimentation or contamination of storm water runoff generated from the project site. BMPs could include, without limitation, silt fences, gravel or sand bag berms, storm drain inlet protection, soil stockpile protection, preservation of existing vegetation, use of straw mulch, dust control, and others. The SWPPP shall also include any additional measures identified in the Santa Clara Valley Urban Runoff Pollution Prevention Program, as required. The District shall adhere to the identified BMPs as well as the waste discharge and stormwater requirements outlined in the permit. b) Less than Significant. Preliminary geotechnical investigation of the project site indicated that the uppers soils are considered unsuitable for proposed building foundations and slabs and would require excavation and replacement with engineered fill to a depth of at least 3.0 feet below the ground surface (see Section 6, Geology and Soils). The water level was Initial Study Gunn High School Master Plan 57 ESA / 209002 Initial Study September 2009 encountered in borings at depths of 25 to 30 feet. Therefore, the potential for intercepting groundwater and depleting groundwater supplies or recharge through excavation or subsurface foundations is considered to be low. Water supply to the City of Palo Alto is provided by the City Utilities Department through purchases from the San Francisco Public Utilities Commission’s Hetch Hetchy water supply system. The proposed project would not involve depletion of groundwater supplies; however, it would increase the amount of impervious surface area and thereby reduce the potential amount of groundwater recharge. As mentioned above, the proposed project would have to comply with the C.3 requirements which include measures for reducing the amount of flow from offsite and using biofiltration improvements to the extent possible. Adherence to these requirements would reduce the amount of offsite runoff volumes and create a less than significant impact to groundwater supplies. c, d) Less than Significant with Mitigation. Proposed new structures and other improvements on the project site would not alter existing drainage patterns, nor would there be any alteration to the existing Santa Clara Valley Water District retention basin located on the western boundary of the campus. Although soil erosion could occur due to project construction, the resulting operational surface runoff rates would not significantly increase due to the generally flat topography of the project site and the relatively small net increase in impervious surface areas occurring during each individual phase of the Master Plan. The potential for accelerated runoff flow rates or flooding would be low. The use of BMPs and adherence to SWPPP and NPDES permit requirements as described in Mitigation Measure HYD-1, above, would reduce potential erosion and flooding impacts to a less than significant level. e) Less than Significant with Mitigation. As discussed above, the surface runoff rates resulting from operation of individual phases of the Master Plan would not significantly increase due to the generally flat topography of the project site and the relatively small net increase in impervious surface area. Stormwater runoff would flow from the project site into the City of Palo Alto’s stormwater drainage system, which would be adequate to handle any increase in flows resulting from the proposed project. In addition, stormwater treatment measures required as part of the NPDES permit described in Mitigation Measure HYD-1, including, but not limited to, vegetated swales, detention basins, and landscape infiltration systems, must be hydraulically sized to treat a specified amount of runoff, and they must include provisions to meet ongoing maintenance needs. Therefore, the project’s impact on the stormwater drainage system would be less than significant. f) Less than Significant with Mitigation. As discussed in a) and c) above, construction is the only phase of the proposed project that could affect water quality. Stormwater runoff would be controlled on-site using standard engineering practices and as required by Mitigation Measure HYD-1. Therefore, substantial degradation of water quality would not be expected and the proposed project’s impact would be less than significant. g, h) Less than Significant. According to the FEMA Flood Insurance Rate Map covering the project area, a narrow band designated as Zone A runs across the project site above Barron Initial Study Gunn High School Master Plan 58 ESA / 209002 Initial Study September 2009 Creek, which is undergrounded in a culvert (FEMA, 2009). This area begins at the Santa Clara Valley Water District retention basin on the western boundary of the campus, runs between the gymnasium and football field, and exits the campus near Los Robles Avenue. Zone A areas are subject to flooding by the one percent annual chance flood, which is a flood event that has a one percent chance of occurring in any given year (also known as the 100-year flood). No base flood elevations have been determined for Zone A areas. The proposed project would include construction of new basketball and tennis courts that may be located within small sections of this zone. These improvements are not anticipated to significantly impede or redirect flood flows on the project site; therefore the impact would be considered less than significant. i) No Impact. The project site is not located within any dam failure inundation area; therefore, no impact would occur. j) No Impact. Although tsunamis could occur and cause tidal surges in San Francisco Bay, these events are extremely rare and the project site is located sufficiently far enough away from the Bay shoreline that tsunamis would not impact the project site. No water bodies large enough to cause a seiche are located in the vicinity of the project site. The potential for mudflows or landslides is discussed under Section 6, Geology and Soils. No impact would occur due to inundation of seiche or tsunami. Sources City of Palo Alto, Comprehensive Plan Update, 1996. City of Palo Alto, Draft and Final Environmental Impact Report, Comprehensive Plan Update, 1996. Deems Lewis McKinley, Gunn High School, Site Perviousness, 2009. Federal Emergency Management Agency (FEMA), Flood Insurance Rate Map (FIRM), Santa Clara County, Map Number 06085C0019H, May 18, 2009. Santa Clara Valley Urban Runoff Pollution Prevention Program, www.scvurppp-wk2.com, accessed July 14, 2009. Initial Study Gunn High School Master Plan 59 ESA / 209002 Initial Study September 2009 Issues (and Supporting Information Sources): Potentially Significant Impact Less Than Significant with Mitigation Incorporation Less Than Significant Impact No Impact 9. Land Use and Planning Would the project: a) Physically divide an established community? b) Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? c) Conflict with any applicable habitat conservation plan or natural community conservation plan? Setting Gunn High School is located on an approximately 48-acre site northeast of the intersection of Arastradero Road and Foothill Expressway. The campus includes 17 permanent buildings clustered on the southern portion of the campus. Adjacent land uses include residential areas on the north and east, Alta Mesa Cemetery on the south, and the Veterans Affairs (VA) Palo Alto Health Care Systems campus on the west. Local Plans and Policies The following policies from the Land Use and Community Design Element and the Community Services and Facilities Element of the City of Palo Alto Comprehensive Plan are relevant to the proposed project: Policy L-5: Maintain the scale and character of the City. Avoid land uses that are overwhelming and unacceptable due to their size and scale. Policy L-7: Evaluate changes in land use in the context of regional needs, overall City welfare and objectives, as well as the desires of surrounding neighborhoods. Policy L-48: Promote high quality, creative design and site planning that is compatible with surrounding development and public spaces. Policy L-61: Promote the use of community and cultural centers, libraries, local schools, parks, and other community facilities as gathering places. Ensure that they are inviting and safe places that can deliver a variety of community services during both daytime and evening hours. Policy L-71: Strengthen the identity of important community gateways, including entrances to the City at…Embarcadero Road at El Camino Real. Policy C-4: Maintain a close, collaborative relationship with the PAUSD to maximize the use of school services and facilities for public benefit, particularly for young people, families, and seniors. Policy C-5: Recognize the importance of schools to the social and economic vitality of the City. Initial Study Gunn High School Master Plan 60 ESA / 209002 Initial Study September 2009 Policy C-6: Continue and enhance City efforts to assist PAUSD in anticipating and addressing land development-related school enrollment impacts. The General Plan designates the project site as School District Lands. This land use designation applies to properties owned or leased by public school districts and used for educational, recreational, or other non-commercial, non-industrial purposes. Floor area ratio may not exceed 1.0. The campus is zoned PF-Public Facilities, which is designed to accommodate governmental, public utility, educational, and community service or recreational facilities. The California Constitution (Article 9, Section 6), prohibits the PAUSD, as a component of the state’s public school system, from being placed under the jurisdiction of a local government. Therefore, the PAUSD is exempt from the requirement to comply with local land use controls, including local general plans and zoning ordinances, within the District’s boundaries. However, the PAUSD attempts to ensure its Master Plan is compatible with the goals and policies of the City of Palo Alto to the extent feasible. Goals of the Master Plan are listed below: • Give organization and structure to the campus • Create a hierarchy of open space • Utilize in-between spaces—preserve open space • Create edges to open space and buildings • Define and articulate building entries • Provide growth strategies—consolidate departmental functions Discussion a, b) Less Than Significant. The land uses proposed as part of the Master Plan would represent a continuation of established public education land uses that have existed on the project site for several decades. The project therefore would not deviate from established development patterns on the project site or in the vicinity. New development would be designed in keeping with the predominant styles of the existing campus architecture. As such, the new uses proposed as part of the project would be consistent with, and would represent an enhancement of, existing educational uses on the Gunn campus. While the proposed Master Plan would represent changes and improvements to the existing campus, the proposed project would not cause a significant adverse land use impact. Furthermore, all potential physical environmental effects of the proposed project on adjacent land uses during construction (including traffic, noise, air quality) are addressed and mitigated where required to the extent feasible throughout this environmental document. The campus improvements and educational uses proposed as part of the project would not substantially conflict with the goals and policies in the City of Palo Alto Comprehensive Plan. Moreover, although not bound by local land use ordinances, project components proposed by the PAUSD would nonetheless be consistent with the land use designation and zoning for the campus. The project would also require review and approval by Board of Education and would be required to meet design criteria established by the Department of Initial Study Gunn High School Master Plan 61 ESA / 209002 Initial Study September 2009 General Services, Division of the State Architect, which is responsible for review of the architectural plans and construction documents. In conclusion, the proposed project would not disrupt or divide the physical arrangements of existing uses and activities that surround them, nor would the proposed physical changes displace any businesses, residences, or other uses. Therefore, land use impacts are considered less than significant and no mitigation is required. c) No Impact. As discussed in Section 4, Biological Resources, no Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan exist within the project boundaries. Sources City of Palo Alto, Comprehensive Plan Update, 1996. Initial Study Gunn High School Master Plan 62 ESA / 209002 Initial Study September 2009 Issues (and Supporting Information Sources): Potentially Significant Impact Less Than Significant with Mitigation Incorporation Less Than Significant Impact No Impact 10. Mineral Resources Would the project: a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state? b) Result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? Discussion a, b) No Impact. According to the Santa Clara County General Plan, the project site does not contain any known mineral resources. No impact would result. Sources Santa Clara County, General Plan 1995-2010, adopted December 20, 1994. Initial Study Gunn High School Master Plan 63 ESA / 209002 Initial Study September 2009 Issues (and Supporting Information Sources): Potentially Significant Impact Less Than Significant with Mitigation Incorporation Less Than Significant Impact No Impact 11. Noise Would the project result in: a) Expose persons to or generate noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? b) Exposure of persons to or generation of excessive groundborne vibration or groundborne vibration levels? c) A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project? d) A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project? e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? f) For a project within the vicinity of a private airstrip, would the project expose people residing or working in the project area to excessive noise levels? Discussion a) Less Than Significant with Mitigation. The California Department of Education (CDE) requires all school districts to select school sites that provide safety and support learning.12 Because the CDE recognizes that unwanted sound can be distracting and can present an obstacle to learning, the CDE requires school districts to consider noise in the site selection process.13 The School Site Selection and Approval Guide document recommends that this be accomplished with an assessment of noise from major roadways and railroads during environmental review of school construction.14 If PAUSD considers a potential school site near a freeway or other source of noise, CDE recommends hiring an acoustical engineer to determine the level of sound that the location is subjected to and to assist in designing the school. The American Speech Language-Hearing Association (ASLHA) guidelines recommend that in classrooms sounds dissipate in 0.4 seconds or less (and not reverberate) and that background noise not rise above 30 dBA.15 While PAUSD has not adopted any specific interior noise standard for its classrooms, other districts, such as Los Angeles Unified have adopted an interior standard of 45 dBA. 12 California Department of Education (CDE), Regulations (CCR Tit. 5, Div. 1, Ch. 13 Subchapter 1, Article 2 §14010 “Standards for School Site Selection”) 13 CDE Regulations (CCR Tit. 5, Div. 1, Ch. 13 §14010(q)) 14 CDE, School Facilities Planning Division. 2001. School Site Selection and Approval Guide. March. 15 Ibid. Initial Study Gunn High School Master Plan 64 ESA / 209002 Initial Study September 2009 Long-term (24-hour) noise monitoring was conducted at two locations on the Gunn campus to determine the existing noise environment of proposed locations of new classrooms. The first location monitored was the location of the proposed Group 1, six-classroom building. Noise sources in this area are dominated by vehicle traffic on Arastradero Road which is approximately 100 feet from the southern building façade. Daytime hourly average noise levels at this location ranged from 63 to 67 dBA with a (logarithmic) average of 64 dBA. The second location monitored was the location of the proposed Group 1, 2-story, 28- classroom building. Noise sources in this area are dominated by students as there are no roadways within several hundred feet of this location. Daytime hourly average noise levels at this location ranged from 49 to 58 dBA with a (logarithmic) average of 53 dBA. Standard building construction methods typically result in an exterior to interior noise reduction of 15 to 20 dBA (HUD, 2004), which would be insufficient to meet the recommended goals of the ASLHA. The location of the 28-classroom building could achieve the generally accepted 45 dBA standard for interior residential spaces without special insulation considerations. Consequently, classroom buildings will need to be designed to incorporate sound insulation sufficient to maintain interior noise levels appropriate for a classroom. Mitigation Measure NOI-1: The PAUSD shall collaborate with a certified acoustical engineer to assist in design and verification of noise insulation measures for the classrooms proposed under the Master Plan. b) Less than Significant with Mitigation. In discussing whether the project would expose people to severe noise via airborne or ground-borne vibrations, this analysis examines the impact of construction activities associated with the project on the existing sensitive receptors in the vicinity of the site. Ground-borne vibration from activities that involve “impact tools,” especially pile driving could produce significant vibration. It is unknown, at the Master Plan level, whether pile driving would be required for two-story classroom buildings to meet seismic code. Pile driving can result in typical peak particle velocities (PPV) of 0.64 inches per second at a distance of 25 feet, which would exceed the criteria published by the U.S. Department of Transportation (DOT) of 0.2 inches per second for the protection of non-engineered timber and masonry buildings and 0.3 inches per second for concrete and masonry buildings with no plaster. Distances of 55 and 42 feet are required for the attenuation of pile driving vibrations to below these respective building protection thresholds. The nearest existing buildings to the proposed building locations are adjacent language classrooms, approximately 30 feet away. The nearest residences would be located over 300 feet away from any proposed building locations and would not be susceptible to building damage from pile driving activity. Consequently, the potential for adjacent building damage would Initial Study Gunn High School Master Plan 65 ESA / 209002 Initial Study September 2009 be a concern at the nearest adjacent classrooms if installation of piles were a necessary construction method and mitigation measures are recommended. Vibration levels can also result in interference or annoyance impacts to residences or other land uses where people sleep, such as hotels and hospitals. Vibration annoyance impact criteria published by U.S. DOT relative to daytime residential land uses (the most applicable use listed to a classroom) are established in terms of vibration decibels (VdB). VdB’s are generally used when evaluating human response to vibrations, as opposed to structural damage, where PPV is the more commonly used descriptor. Vibration decibels are established relative to a reference quantity, typically 1 x 10-6 inches per second.16 The criterion for vibration annoyance established by U.S. DOT for daytime residential uses (again, the most applicable use listed to a classroom) is 78 VdB. Pile driving can result in typical vibrations of 104 Vdb at a distance of 25 feet. The nearest residence to the proposed two-story classrooms would be located approximately 300 feet away at which distance vibrations from pile driving activities would be reduced to 72 Vdb. This would be a less than significant vibration impact to the nearest residences. However, annoyance impacts would be a concern at the nearest adjacent classrooms if installation of piles were a necessary construction method and therefore, mitigation measures are recommended. Mitigation Measure NOI-2: To reduce potential structural damage impacts from pile driving (if necessary), PAUSD shall employ the following measures: • Verify the construction method of adjacent buildings of concern. If buildings are constructed of reinforced concrete, steel or timber without plaster, these structures can withstand vibrations of up to 0.5 PPV without structural damage. If located at a distance of at least 30 feet from pile locations potential structural impacts would be considered less than significant. • Use alternative driving methods. If adjacent buildings are non-engineered timber and masonry buildings or concrete and masonry buildings with no plaster then alternative driving methods may be employed to reduce vibration impacts to a less than significant level. Use of a sonic (or vibratory) pile driver can result in typical vibration levels being reduced from 0.644 feet per second to 0.170 feet per second (U.S. DOT, 2006). Alternatively pile holes may be pre-drilled to reduce vibrations. Mitigation Measure NOI-3: To reduce the potential for annoyance impacts from pile driving (if necessary) at occupied adjacent classrooms, PAUSD shall have the contractor schedule any pile driving activities during the summer or winter breaks or other times when classrooms within a 150-foot radius are unoccupied. Additionally, any required pile driving should be restricted to daytime hours. c) Less than Significant. Future development of the site could generate noise from motor vehicle trips as well as from stationary sources (i.e., HVAC equipment etc.) that could adversely affect nearby noise-sensitive land uses. 16 Ibid. Initial Study Gunn High School Master Plan 66 ESA / 209002 Initial Study September 2009 Noise from air handling equipment would be located more than 300 feet away from the nearest sensitive receptor and would be no different than the existing equipment located on campus buildings. Given the presence of other noise sources between the site and the nearest residential receptors, noise from air handling equipment would not represent a significant noise impact. Noise level projections from roadway traffic increases were made using traffic data and the TNM version 2.5 Lookup Noise Prediction Model of the Federal Highway Administration (FHWA) for those road segments that would experience the greatest increase in traffic volumes and/or that would pass nearest to residential areas. The model is based on the TNM reference noise factors for automobiles, medium trucks, heavy trucks, and buses with consideration given to vehicle volume, speed, roadway configuration, and distance to the receiver. The results of the modeling are presented in Table 2 for existing and existing plus project scenarios. The traffic analysis indicates that the proposed project would generate approximately 532 total daily vehicle trips. This traffic would be distributed over the local street network and would affect roadside noise levels. For the modeling effort, a.m. peak hour traffic volumes during weekdays were used as a worst-case analysis because the proposed project would contribute more traffic to the a.m. peak hour than to the a.m. peak hour. Modeled existing noise levels shown in Table 2 correspond to a distance of 50 feet from the centerline of applicable roadway segments. As presented in Table 2, roadway traffic noise increases resulting from the proposed project would be less than 1 dBA. Generally, even in a laboratory environment, increases of less than 1 dBA are too small to be detected by the human ear (Caltrans, 1998). Consequently, increases in roadway noise resulting from the proposed project would be less than significant. TABLE 2 TRAFFIC NOISE INCREASES IN ROADSIDE LEQ Road Segment Existing Existing + Project Contribution of Proposed Project 1. Arastradero Road (between Foothill Expressway and Old Trace Road) 63.4 63.4 0.0 2. Arastradero Road (between Gunn Driveway and Donald Drive) 65.3 65.4 0.1 3. Foothill Expressway (between Arastradero Road and Edith Avenue) 68.3 68.3 0.0 a These listed values represent the modeled existing noise levels from mobile sources along specified roadways and are based on traffic data. Road center to receptor distance is assumed to be 50 feet. The speed limit for these segments is assumed to be 25 miles per hour except for Arastradero Road 45 miles per hour for Foothill Expressway. SOURCE: ESA, 2009. Initial Study Gunn High School Master Plan 67 ESA / 209002 Initial Study September 2009 d) Less than Significant with Mitigation. Noise standards are typically addressed in Title 24, local General Plan policies and local noise ordinance standards. The City of Palo Alto Noise Ordinance (Section 9.10.060 of the Municipal Code) establishes construction noise regulations in the City. The noise ordinance restricts the allowable hours for construction to between 8:00 a.m. and 6:00 p.m. on weekdays. Construction may occur on weekends between 9:00 a.m. and 5:00 p.m. on Saturdays. Construction activities are prohibited on Sundays and holidays. In addition, no individual pieces of construction equipment are allowed to exceed 110 dBA at a distance of 25 feet. Construction of future buildings would involve demolition of some existing structures at the site and the construction of one and two-story classrooms and renovations of existing buildings. Various types of equipment would be used for demolition and construction purposes. Some of this equipment would generate relatively steady-state noise levels, such as the noise from diesel engines, and other equipment would generate impulse or impact noise. Construction noise levels at and near locations on the project site would fluctuate depending on the particular type, number, and duration of use of various types of construction equipment. The effect of construction noise depends upon how much noise would be generated by construction, the distance between construction activities and the nearest noise-sensitive uses, and the existing noise levels at those uses. Table 3 presents typical noise levels generated by construction equipment. As shown in Table 3, the noisiest phases of (non-pile driving) construction would generate approximately 88 Leq at 50 feet. Pile driving, if necessary, would generate noise levels of approximately 101 dBA at 50 feet. All of these construction equipment noise levels would be consistent with the restriction of the City’s municipal code. The receptors nearest to the proposed construction activities would be adjacent classrooms. The nearest residences to proposed construction activities would be located 300 feet from the proposed gymnasium. TABLE 3 TYPICAL CONSTRUCTION EQUIPMENT NOISE EMISSION LEVELS Equipment Noise Level (Leq)a Shovel (Excavator) 82 Back Hoe 80 Concrete pumps 82 Jack Hammer 88 Pneumatic tools 85 Truck 88 Pile Driving 101 a Estimates correspond to a distance of 50 feet from the piece of equipment. SOURCE: U.S. Department of Transportation, Transit Noise and Vibration Impact Assessment, May 2006. Initial Study Gunn High School Master Plan 68 ESA / 209002 Initial Study September 2009 While construction-related noise would be within the limits established by the City’s noise ordinance, construction noise could be a nuisance to the nearest sensitive receptors. Consequently, mitigation measures are recommended to reduce noise impacts of project construction on adjacent sensitive receptors. Mitigation Measure NOI-4: Construction contractors shall be required to follow appropriate time restrictions consistent with the City’s Municipal Code. Specifically, it is recommended that contractors be required to limit noisy construction activities, including related on-road truck use in the immediate project vicinity, to the hours of 8:00 a.m. to 6:00 p.m. on weekdays. No construction shall be allowed on Sundays and legal holidays. In addition, although not required, it is recommended that the use of impact tools (e.g., hoe-ram, jackhammers, pile driver) be limited to the hours of 8:00 a.m. to 5:00 p.m. Construction Related Noise Attenuation Measures • Notify adjacent residents of any planned pile-driving activities, as well as any particularly noisy activity that would affect them for a given short period of time so they can plan their activities accordingly. • Ensure that all diesel equipment is equipped with effective mufflers, in accordance with the manufacturer’s specifications, and that the mufflers are in good repair. • Use temporary noise barriers along the perimeter of the sites, to the maximum extent feasible during demolition and grading activities. • Locate stationary noise-generating equipment such as generators and compressors as far as possible from the nearest residential property line. • Locate any construction trailers or offices as far from the adjacent residential uses as possible. Implementation of the above mitigation measures would reduce the impact to less than significant levels. e, f) No Impact. There are no public use airports or private air strips within a two mile radius of the project site. Consequently, there are no noise or vibration impacts associated with these uses that would occur on the project site. Sources Caltrans, Technical Noise Supplement, 1998. U.S. Department of Transportation, Federal Traffic Administration (FTA), Transit Noise and Vibration Impact Assessment, May 2006. U.S. Department of Housing and Urban Development, Office of Community Planning and Development, The Noise Guidebook, updated, August, 2004. Initial Study Gunn High School Master Plan 69 ESA / 209002 Initial Study September 2009 Issues (and Supporting Information Sources): Potentially Significant Impact Less Than Significant with Mitigation Incorporation Less Than Significant Impact No Impact 12. Population and Housing Would the project: a) Induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? b) Displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere? c) Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere? Discussion a) Less than Significant. As described in the Project Description, the purpose of the proposed project is to renovate existing aging facilities, and to provide additional building capacity, as well as various infrastructure and site access/circulation/landscaping upgrades consistent with the Master Plan. Student enrollment is anticipated to incrementally increase within the PAUSD over the time period of the Master Plan buildout in 2017. However, the proposed project would not, in itself, induce student growth within the PAUSD, but rather, better accommodate existing and planned student enrollment within the PAUSD. Furthermore, utility infrastructure improvements are intended to improve utility service at the project site, and would not be oversized to potentially serve additional growth within the area. b, c) Less than Significant. The proposed project would not displace any existing housing or generate a demand for housing elsewhere. Furthermore, the project would not result in a displacement of people from the project site. No impact would result. Sources PAUSD, Gunn High School Master Plan, 2009. Lapkoff & Gobalet Demographic Research, Inc., Enrollment Forecasts for PAUSD Middle and High Schools, January 12, 2009. Initial Study Gunn High School Master Plan 70 ESA / 209002 Initial Study September 2009 Issues (and Supporting Information Sources): Potentially Significant Impact Less Than Significant with Mitigation Incorporation Less Than Significant Impact No Impact 13. Public Services Would the project: a) Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services: i) Fire protection? ii) Police protection? iii) Schools? iv) Parks? v) Other public facilities? Setting Fire Protection Services Fire protection services to the project site are provided by the City of Palo Alto Fire Department. The Fire Department has approximately 122 employees and staffs seven full time stations located throughout the City and on the Stanford University campus. To provide coverage in the sparsely developed hillside areas, an additional fire station in the foothills is operated during summer months when fire danger is high. Service areas for the Fire Department include the Stanford University campus, the Stanford Linear Accelerator Center (SLAC), and unincorporated areas of Santa Clara County. The nearest fire station to the Gunn campus is Fire Station No. 5 at 600 Arastradero Road, which is approximately one-mile from the campus. The City also has mutual aid agreements with Menlo Park, Mountain View, Los Altos, and Woodside. In fiscal year 2007-08, the Fire Department responded to an average of 21 calls per day. The average response time for fire calls was 6 minutes 48 seconds, and the average response time for medical/rescue calls was 5 minutes 24 seconds. There were more than 4,500 medical/rescue incidents and 192 fire incidents (including 43 residential structure fires) in 2007-2008. The Fire Department also performed 1,277 fire inspections and 406 hazardous materials inspections. Police Protection Services Law enforcement services to the project site are provided by the Palo Alto Police Department. The Police Department has 169 personnel; it shares Special Weapons and Tactical (SWAT) Teams with Los Altos and Mountain View and provides dispatching to the Stanford University Police through the City’s Communications Center. Initial Study Gunn High School Master Plan 71 ESA / 209002 Initial Study September 2009 The Police Department handled more than 58,700 calls for service in fiscal year 2007-08, or about 161 calls per day. The average response time for emergency calls is 4 minutes 32 seconds. Police Department statistics show 127 reported crimes per 1,000 residents, with 87 reported crimes per officer last year. The Police Department is located at 275 Forest Avenue, approximately four miles from the Gunn campus. Public Schools The PAUSD attendance area includes the City of Palo Alto, Stanford University, and areas of Los Altos Hills, Palo Alto Hills, and Portola Valley. The PAUSD consists of twelve elementary schools (grades K-5), three middle schools (6-8), and two high schools (9-12). In addition, the District operates a pre-school, Young Fives program, a self-supporting Adult School, the Hospital School at Stanford’s Lucille Packard Children’s Hospital, and summer school. The total District enrollment for the 2008/2009 school year is 11,431. Discussion a.i-ii) Less than Significant. The proposed project would result in construction of new buildings and other site improvements to accommodate anticipated enrollment increases through buildout of the Master Plan in 2017. While no off-site access improvements are proposed, parking and drop-off areas would be reconfigured as part of the project to improve vehicular, pedestrian, and bicycle circulation and safety on the campus. The proposed project would be required to comply with all applicable requirements of the California Fire Code, and be consistent with the California Building Code regarding life safety issues, including emergency vehicle access. In addition, during the construction document phase, all plans would be subject to review and approval by the Division of State Architect for a fire and life-safety compliance review. In consideration of these factors, the proposed project would not adversely affect the ability of the Palo Alto Fire and Police Departments to maintain adequate fire and police protection services, or result in the need for expanded public services that would result in the need for new or expanded facilities. a.iii) No Impact. There are no elements of the proposed project that would adversely affect public schools. Consequently, no impact is anticipated. a.iv) Less than Significant. Refer to Section 14, Recreation, for a discussion of the need for additional park and recreational facilities, and the potential environmental impacts associated with the provision of new facilities. a.v) Less than Significant. The proposed project would not adversely affect any other public services in the City of Palo Alto. Sources City of Palo Alto, City Auditor, Annual Report on City Government Performance, Service Efforts and Accomplishments Report FY 2007-2008, Summary, January 2009. City of Palo Alto, Comprehensive Plan Update, 1996. Initial Study Gunn High School Master Plan 72 ESA / 209002 Initial Study September 2009 City of Palo Alto, Draft and Final Environmental Impact Report, Comprehensive Plan Update, 1996. City of Palo Alto, Fire Department, www.cityofpaloalto.org/depts/fir/news, accessed July 22, 2009. City of Palo Alto, Police Department, www.cityofpaloalto.org/depts/pol/news, accessed July 22, 2009. Initial Study Gunn High School Master Plan 73 ESA / 209002 Initial Study September 2009 Issues (and Supporting Information Sources): Potentially Significant Impact Less Than Significant with Mitigation Incorporation Less Than Significant Impact No Impact 14. Recreation Would the project: a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? Setting The City of Palo Alto owns and operates 28 neighborhood and district parks totaling approximately 190 acres. They range in size from one-half to two-acre mini-parks to “district” parks that serve the entire community and feature playing fields, picnic grounds, and community centers. Many parks feature specialized facilities such as tennis courts, basketball courts, skate bowls, community gardens, dog exercise areas, and par courses. The City also owns and operates several large open space preserves such as Foothills Park. The Recreation Division provides numerous programs, classes, and special events. Recreation facilities include community centers, pools (including the new Gunn High School Aquatic Center), and a teen center. The City also maintains PAUSD athletic fields and tennis courts at all elementary and middle school sites and manages public use of those facilities. The City of Palo Alto brokers all city athletic fields, tennis courts and Palo Alto Unified School District school fields. Park Services also maintains school athletic fields and tennis courts at all elementary and middle school sites. Parks in the vicinity of Gunn High School include Bol, Briones, and Terman Parks. Discussion a, b) Less than Significant. Implementation of the proposed project over buildout of the Master Plan in 2017 and associated incremental increase in student population at the project site would not substantially increase the use of existing neighborhood or regional parks in the vicinity or cause substantial physical deterioration of those facilities. Construction of the new gymnasium is proposed to occur in the area currently occupied by tennis and basketball courts. Some or all of these facilities would be temporarily disrupted during construction of the new gym. Approximately 45 other tennis courts located at other schools and parks throughout the City of Palo Alto (including four at nearby Terman Park) would be available for use by the public during the closure of Gunn’s courts. New tennis and basketball courts would be constructed in areas adjacent to the new gym. Any potential environmental effects associated with the construction and operation of these recreational facilities are discussed in this environmental document and mitigated to a less than significant level. Initial Study Gunn High School Master Plan 74 ESA / 209002 Initial Study September 2009 Sources City of Palo Alto, Community Services Department, www.cityofpaloalto.org/depts/csd, accessed July 22, 2009. City of Palo Alto, Comprehensive Plan Update, 1996. City of Palo Alto, Draft and Final Environmental Impact Report, Comprehensive Plan Update, 1996. Initial Study Gunn High School Master Plan 75 ESA / 209002 Initial Study September 2009 Issues (and Supporting Information Sources): Potentially Significant Impact Less Than Significant with Mitigation Incorporation Less Than Significant Impact No Impact 15. Transportation/Traffic Would the project: a) Cause an increase in traffic which is substantial in relation to the existing traffic load and capacity of the street system (i.e., result in a substantial increase in either the number of vehicle trips, the volume-to- capacity ratio on roads, or congestion at intersections)? b) Exceed, either individually or cumulatively, a level of service standard established by the county congestion management agency for designated roads or highways? c) Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks? d) Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? e) Result in inadequate emergency access? f) Result in inadequate parking capacity? g) Conflict with adopted policies, plans, or programs supporting alternative transportation (e.g., bus turnouts, bicycle racks)? Setting Gunn High School is located on Arastradero Road immediately east of Foothill Expressway. The school has one primary entrance from Arastradero Road at the southeastern corner of the campus. The driveway includes two lanes in each direction and is signalized. A secondary driveway is on Miranda Avenue. Existing Traffic Volumes and Intersection Lane Configurations Four study intersections that would be most affected by project traffic were selected for analysis: 1. Arastradero Road and Foothill Expressway 2. Arastradero Road and Miranda Avenue 3. Arastradero Road and School Driveway 4. Arastradero Road and Donald/Terman Road The study intersections were analyzed during weekday a.m. peak-hour traffic conditions. Peak traffic conditions, which would coincide with school traffic, typically occur during the morning commute periods (between 7:00 a.m. and 9:00 a.m.). Intersection operations were evaluated for the one hour during the morning peak period for which the highest traffic volumes were measured. Initial Study Gunn High School Master Plan 76 ESA / 209002 Initial Study September 2009 Vehicle counts at the driveway were conducted at the start and end of the school day on a Friday in March (March 16, 2009). The counts included inbound and outbound vehicles, as well as count of parked cars by location. Morning drop-offs and afternoon pick-ups are part of the student commute. Under existing conditions, over 550 vehicles are inbound (includes both drop-offs and parking) to the site in 30 minutes and over 700 in less than 90 minutes as illustrated in Figure 11. Inbound traffic from the east on Arastradero Road is backed-up out of the right turn lane into the right or curb lane for several blocks. The backup lasted for approximately 15- to 20-minutes and peaked just before the first class. During observations, vehicles were primarily dropping-off and picking-up at the front of the school as illustrated at Location B in Figure 11. Drives followed the entrance road north, turned left into the drop-off area and then exited back on to Arastradero Road. The entrance includes two northbound lanes to the beginning of the drop-off lane. At that point, one lane turns left into the drop-off area while the other continues northerly to student and staff overflow parking areas. Vehicles leaving the rear parking areas are routed through the drop-off area to Arastradero Road. Parking at the high school is currently concentrated in three locations as show in Figure 11. The school has a total of 461 parking spaces. Lots D, E, F, and G, with a total of 147 parking spaces are reserved for staff and visitors (part of lot G). Lot I with 17 spaces on the west side of the campus is reserved for staff. Lots A, B, and C with the majority of the parking (294 spaces) are located toward the rear of the site and are used for staff overflow and students. Parking demand at the high school fluctuates very little over the course of the day, but generally, the lots in close proximity to the campus buildings (Lots D, E, and G) can exceed capacity periodically as people arrive and depart during the day, The student lots, particularly Lot A, generally has 60 to 80 spaces available throughout the day. As a whole, the school had a peak parking demand for approximately 440 parking spaces (95 percent). Existing Intersection Operations The operations of roadway facilities are described with the term Level of Service. Level of Service (LOS) is a qualitative description of traffic flow based on such factors as speed, travel time, delay, and freedom to maneuver. Six levels are defined from LOS A, as the best operating conditions, to LOS F, or the worst operating conditions. LOS E represents “at-capacity” operations. When volumes exceed capacity, stop-and-go conditions result, and operations are designated as LOS F. Level of Service Calculation Method. The level of service calculation methodology for intersections is dependent on the type of traffic control device, traffic signals or stop signs. The level of service methodology used in this analysis bases a signalized intersection’s operation on the average control delay calculated using methods described in Chapter 16 of the 2000 Highway Capacity Manual (Transportation Research Board, 2000). The average delay for signalized intersections was calculated using Synchro analysis software and is correlated to a LOS designation as shown in Table 4. The level of service standard (i.e., minimum acceptable operations) for the City of Palo Alto is LOS D. Gunn High School Master Plan . 209002 Figure 11 AM and PM Peak Hour Intersection Volumes and Parking Count Summaries SOURCE: Wilson (2009). Merci. LL Initial Study Gunn High School Master Plan 78 ESA / 209002 Initial Study September 2009 TABLE 4 SIGNALIZED INTERSECTION LEVEL OF SERVICE DEFINITIONS Level of Service Average Control Delay Per Vehicle (Seconds) Description A ≤ 10.0 Operations with very low delay occurring with favorable progression and/or short cycle length. B 10.1 to 20.0 Operations with low delay occurring with good progression and/or short cycle lengths. C 20.1 to 35.0 Operations with average delays resulting from fair progression and/or longer cycle lengths. Individual cycle failures begin to appear. D 35.1 to 55.0 Operations with longer delays due to a combination of unfavorable progression, long cycle lengths, and high V/C ratios. Many vehicles stop and individual cycle failures are noticeable. E 55.1 to 80.0 Operations with high delay values indicating poor progression, long cycle lengths, and high V/C ratios. Individual cycle failures are frequent occurrences. F > 80.0 Operations with delays unacceptable to most drivers occurring due to over-saturation, poor progression, or very long cycle lengths. SOURCE: Transportation Research Board, 2000 Highway Capacity Manual. Existing Intersection Levels of Service. The existing lane configurations, signal phasing, and peak-hour turning movement volumes were used to calculate the level of service for the study intersections. The results of the level of service analysis are presented in Table 5. Two of the study intersections are currently operating at acceptable LOS D: Arastradero Road intersections with Foothill Expressway and at Donald Road under a.m. peak hour conditions. The intersections of Arastradero Road at Miranda Avenue and the Gunn High School Driveway, however, are operating at unacceptable LOS F under existing conditions. TABLE 5 EXISTING INTERSECTION AM PEAK-HOUR LEVELS OF SERVICE (LOS) ANDAVERAGE VEHICLE DELAY (seconds/vehicle)a Existing Intersection Delay LOS Arastradero Road and Foothill Expressway 42.7 D Arastradero Road and Miranda Avenue >120 F Arastradero Road and School Driveway >120 F Arastradero Road and Donald/Terman Road 42.4 D a LOS calculations performed for using SYNCHRO and the 2000 Highway Capacity Manual operations analysis methodology. SOURCE: Wilson (2009). Initial Study Gunn High School Master Plan 79 ESA / 209002 Initial Study September 2009 Pedestrian and Bicycle Facilities Pedestrian facilities include sidewalks, crosswalks, and pedestrian signals. The existing school site currently contains pedestrian facilities. School route crosswalks exist on Arastradero Road at its intersections with Miranda Avenue, the Gunn High School Driveway, and Donald Drive. There is a crosswalk with a pedestrian signal phase across the driveway and across Arastradero Road on the west side. The pedestrian phase across the driveway runs concurrent with the westbound through and right-turn vehicle movements on Arastradero Road. This puts all pedestrian traffic across the driveway at conflict with inbound right-turns in the morning commute period. Similarly pedestrian and bicycle traffic crossing Arastradero Road using the eastbound crosswalk is in conflict with vehicles making right-turns out of the driveway. Bicycle facilities include bike paths, bike lanes, and bike routes. Bike paths are paved trails that are separated from the roadways. Bike lanes are lanes on roadways that are designated for use by bicycles by striping, pavement legends, and signs. Bike routes are roadways that are designated for bicycle use with signs, but no separate lane width. Within the vicinity of the project site, there are bike lanes on Miranda Avenue and Arastradero Road. Bike paths are present along the property boundary with the Veterans Hospital and between Los Altos Road and Arastradero Road. Bicycle counts were conducted at the start and end of the school day on a Monday in March (March 16, 2009). The counts included both inbound and outbound bicycles by location, as well as count of parked bicycles by location.17 Bicycle counts, illustrated in Figure 12, reveal that approximately 400 students bicycle to school. Approximately 73 percent (285 students) entered from the rear of the school property at Los Robales/Gerogia/McGregor. At the main entrance, 11 percent (44 students) approached from the east on Arastradero Road and 6 percent (23 students) approached from the west. The remaining 10 percent (37 students) entered from Miranda Road or the bike trail on the western edge of the campus. Outbound bicycle traffic in the afternoon is much less focused in that departures occur over a much longer period as student leave the campus over a more extended period. Directions are generally reversed from morning arrivals. By comparison, counts conducted by the Parent Teacher Association (PTA) on a warmer day, have documented upwards of 600 students bicycling to school, roughly 50 percent more than was counted in March. Bike cages are generally located at three points in the central area of the campus, including near the library, near the science building, and near the student center. 17 It should be noted that both vehicle and bicycle counts represent a worst-case scenario as the weather was cold in March. Mode-shift would occur as weather improves (i.e., more bicycling and walking would occur on a warm day). Gunn High School Master Plan . 209002 Figure 12 Bicycles and AM/PM Peak Period Pickup/Dropoff Volumes SOURCE: Wilson (2009) Initial Study Gunn High School Master Plan 81 ESA / 209002 Initial Study September 2009 Transit Facilities Bus service in Santa Clara County is operated by the Santa Clara Valley Transportation Authority (VTA). Route 88 is a local bus route that provides service between the Palo Alto Veterans Hospital and Colorado/Middlefield Roads. It operates with additional service when school is in service to accommodate students. Route 88 stop is directly in front of Gunn High School on Arastradero Road. In addition, the PAUSD makes unused seats on its Bus Routes J, Y, and Z buses available to high school students for a fee. Discussion a, b) Less than Significant with Mitigation. Implementation of the proposed project over buildout of the Master Plan in 2017 and associated incremental increase in student population at the project site would increase trips to the high school. The vehicle trip generation for the proposed project is presented in Table 6. Vehicle trip generation for the proposed improvements was estimated based on trip generation rates published in the Institute of Transportation Engineers Trip Generation (8th edition). The proposed high school expansion is estimated to generate approximately 82 net new morning vehicle trips (57 inbound and 25 outbound) at the school driveway. TABLE 6 AM PEAK HOUR TRIP FORECAST Existing Student Population Forecast 2018 Student Population Net Increase in Tripsa Net Inbound/Outbound Trips 1,948 2,259 82 57/25 a Trip generation was based on the trip generation rates published in ITE Trip Generation, 8th edition. SOURCE: Wilson (2009), ITE (2008) The vehicle trip distribution pattern for the proposed project was estimated based on the existing travel patterns of students and faculty from the traffic counts conducted in March 2009. Project Conditions Project conditions are defined as existing conditions plus traffic added by the proposed project. Project impacts are then identified by comparing the LOS results under project conditions to those under existing conditions. The results of the LOS analysis for project conditions are summarized in Table 7; turning movement counts and LOS calculations are presented on-file at the District. With the addition of project-generated traffic, the study intersections would continue to operate at Initial Study Gunn High School Master Plan 82 ESA / 209002 Initial Study September 2009 TABLE 7 EXISTING AND PROJECT LEVELS OF SERVICE (LOS)a Intersection Existing Project Delay LOS Delay LOS AM Peak Hour Arastradero Road and Foothill Expressway 42.7 D 42.7 D Arastradero Road and Miranda Avenue >120 F >120 F Arastradero Road and School Driveway >120 F >120 F Arastradero Road and Donald/Terman Road 42.4 D 44.2 D a LOS calculations performed for using SYNCHRO and the 2000 Highway Capacity Manual operations analysis methodology. SOURCE: Wilson (2009) the same acceptable levels of service during the a.m. peak hour as they do under existing conditions. Two of the study intersections are currently operating at acceptable LOS D: Arastradero Road intersections with Foothill Expressway and at Donald Road under a.m. peak hour conditions. The intersections of Arastradero Road at Miranda Avenue and the Gunn High School Driveway, however, are operating at unacceptable LOS F under existing conditions. Under Existing Plus Project Conditions, the delay would increase at the study intersections, and the project would contribute to these unacceptable levels during the a.m. peak hour. Cumulative Conditions The Arastradero Road corridor is effectively at capacity now and further increases in demand would expand the peak in terms of length of time but not peak volumes. The Arastradero Road corridor is at capacity and traffic is metered into and out of it at both ends (El Camino Real and Foothill Expressway) during the morning and evening commute periods. Under Cumulative Conditions, the delay would increase at the study intersections, and the project would contribute to these unacceptable levels during the a.m. peak hour. Implementation of Mitigation Measures TRAN-1 and TRAN-2 would reduce the project’s contribution to vehicle delays on Arastradero Road by moving students to alternative modes of transportation by including additional measures in their comprehensive Traffic Demand Management (TDM) Program. The goal of the TDM program is to not increase traffic volumes to the high school as the student body increases. Mitigation Measure TRAN-1: PAUSD shall require Gunn High School to set up a carpool matching program for students. The program should be well advertised at the beginning of the school year and the service should remain available throughout the school year. Ideally a match person/scheduler would be available at all time to react to changing driver schedules (vacation, sickness etc.) as needed. Initial Study Gunn High School Master Plan 83 ESA / 209002 Initial Study September 2009 Mitigation Measure TRAN-2: PAUSD shall require Gunn High School to continue the existing TDM program. The TDM program shall include the following: • No net increase in the number of onsite parking spaces relative to 2009 (461 parking spaces); • No increase in student parking permits relative to 2009; • Direct bicycle access via Georgia and Los Robles versus Arastradero Road to remove bicycle traffic from the main driveway to improve existing intersection level of service; • Locate bicycle racks in convenient areas to facilitate ease of queues, safety, and accessibility; • Provide maps at the start of the school year illustrating preferred bicycle access routes; • Extend arrivals over a longer period of time by getting students to school before the peak rush. Consider providing study areas or breakfast incentives or similar to encourage student to arrive a little before school starts. Construction Period Construction of the proposed modifications to the school is anticipated to commence in summer 2010, and would be conducted in phases. Construction activities that would generate offsite traffic would include the initial delivery of construction vehicles and equipment to the project site, the daily arrival and departure of construction workers, and the delivery of materials throughout the construction period, and removal of construction debris. Deliveries would include shipments of concrete, lumber, and other building materials for onsite structures, utilities (e.g., irrigation and plumbing equipment, electrical supplies) and paving and landscaping materials. Construction-generated traffic would be temporary, and therefore, would not result in any long-term degradation in operating conditions on any project roadways. The impact of construction-related traffic would be a temporary and intermittent lessening of the capacities of project area streets because of the slower movements and larger turning radii of construction trucks compared to passenger vehicles. However, given the proximity of the project site on and near major arterials (Arastradero Road, Foothill Expressway) and to El Camino Real, construction trucks would have relatively easy and direct routes. Most construction traffic would be dispersed throughout the day. Thus, the temporary increase would not significantly disrupt daily traffic flow on any of the study area roadways. Although the impact would be less than significant, truck traffic could have some adverse effect on traffic flow in the study area. As such, the transport of construction materials and equipment should be limited to off-peak traffic periods. This measure should be incorporated by the school district into the contract specifications documents to ensure implementation by the construction contractor(s). Initial Study Gunn High School Master Plan 84 ESA / 209002 Initial Study September 2009 c) No Impact. The proposed school would not change air traffic patterns, increase air traffic levels or result in a change in location that would result in substantial safety risks. There would be no project effect. d) Less than Significant with Mitigation. The project would result in an increase in vehicle trips, as well as an increase in pedestrian traffic within the project site and on local roadways, and correspondingly, would increase the potential for interaction between these travel modes. Sidewalks currently exist on roadways adjacent to the project site. To further improve pedestrian circulation, pedestrian walkways would be enhanced from the sidewalk and all passenger loading/unloading zones to the main entrance to the campus site. Bicycle access to the high school would increase as student population increases. Assuming the same rate of bicycle use as observed in the March 2009 counts, the projected number of cyclists at buildout of the Master Plan would be approximately 485. The high school would continue to encourage bicycling to campus as part of their Transportation Demand Management program and further through Mitigation Measure TRAN-2, and thus would provide adequate and secure bicycle parking, in the form of bicycle cages, at convenient and commute entrances. Circulation and parking aisles at the high school would continue to serve both one-way and two-way traffic and provide both angled and perpendicular parking spaces. The aisles would be designed to be wide enough for maneuvering all types of passenger vehicles. Morning drop-offs observed approximately 365 vehicles dropping off students on campus. Assuming the percentage of drop-offs remains constant as the enrollment increases, a future student population is forecasted to result in approximately 450 drop-offs during the morning commute period. A queue of approximately 1,100 feet (in two lanes) would be required to accommodate the projected drop-offs. Based on the residential distribution of existing students and transit routes, the school would generate pedestrian traffic through the neighborhood and along roadways that front the school property. The existing sidewalks on all street frontages would accommodate the pedestrian traffic. Implementation of Mitigation Measures TRAN-3 and TRAN-4 would reduce onsite circulation impacts to less-than-significant levels. Mitigation Measure TRAN-3: PAUSD shall incorporate the following measures into the project site’s final internal circulation design: • The drop-off lane shall be designed to accommodate queuing onsite during the morning commute period without blocking driveways or the Arastradero Road entrance; Initial Study Gunn High School Master Plan 85 ESA / 209002 Initial Study September 2009 • Internal driveway approaches shall be painted red to prohibit stopping and maintain sight-distance; • Internal roadway curbs shall be painted red to prohibit stopping; • Internal circulation would use a curbside drop-off zone, which shall be painted white and striped with a lane to allow vehicles to pass on the left-side of loading/unloading vehicles; • The loading zone shall be marked with signs/pavement markings that make vehicles aware of pedestrian and loading activities; • Signs and pavement markings (i.e., painted arrows) shall designate directional flow through the parking lot. Mitigation Measure TRAN-4: PAUSD shall integrate the following measures to reduce potential queuing impacts: • Circulate informational flyers to parents and students that discuss onsite circulation patterns and designated parking areas; • Encourage drivers with disabled passengers that would require longer dwell times (i.e., wheelchair users) to use ADA parking spaces for loading/unload; • Use staff to monitor and direct onsite traffic during peak drop-off/pick-up times both before and after school (i.e. 7:45 a.m. to 8:00 a.m.). With implementation of the above mitigation measures, there would be no apparent circulation design features that would create a traffic safety hazard or significantly increase the potential for conflicts between vehicles, pedestrians and bicycles. e) Less than Significant. The proposed Master Plan would not alter the ingress, egress to the high school. The driveway as designed in the site plan would provide adequate emergency access. There would be no blockage of access or traffic pattern disturbance that would significantly affect emergency access. Red curb will be used along interior roadways and driveways to provide sufficient response time for emergency vehicles. The fire lane must be a minimum of 18 feet in width and must be kept clear at all times. The project’s effect would be less than significant. f) Less than Significant with Mitigation. The City of Palo Alto requires one parking space for every five students, plus one space for each four teaching stations. The proposed daily population for the high school is approximately 2,300 students and 92 teachers (1 for every 25 students), thus requiring 483 parking spaces. Using the current parking demand of approximately 440 spaces on a typical weekday, the future demand rate with buildout of the Master Plan would be approximately 533 spaces, however, with implementation of Mitigation Measure TRAN-2, the future parking demand would be reduced through TDM measures; therefore, the project’s effect would be less than significant. Initial Study Gunn High School Master Plan 86 ESA / 209002 Initial Study September 2009 The high school has an existing parking demand management program which limits student driving to campus though permits. The program is enforced through cooperation with the City police, which uses parking enforcement (tickets) to ensure adherence to the program. g) Less than Significant with Mitigation. The project is located in an established urban area, and buildout of the Master Plan would not conflict with adopted policies, plans, or programs supporting alternative transportation. The increase in students and employees could increase the use of alternative transportation modes. The high school has, and will continue to implement, a Transportation Demand Management (TDM) program that shifts students to alternative modes of travel through implementation of Mitigation Measure TRAN-2. Decreasing the volume of vehicular traffic to the school through the promotion of alternative modes of travel, including carpooling, biking, or use of public transit, is fundamental to any TDM program. The project’s effect would be less than significant with mitigation. Sources Institute of Transportation Engineers Trip Generation (8th edition), 2008. Santa Clara Valley Transportation Authority (VTA), Transit and Rail Map, http://www.vta.org/schedules/pdf/bus_rail_map_a.pdf. Accessed August 18, 2009. Santa Clara Valley Transportation Authority (VTA), Bike Map, http://www.vta.org/schedules/pdf/vta_bike_map_a.pdf. Accessed August 18, 2009. Transportation Research Board, Highway Capacity Manual, 2000. Wilson Engineering. On-Site Traffic Study for Gunn High School. Prepared for the Palo Alto Unified School District. May 2009. Wilson Engineering. An Assessment of Gunn and Play High Schools Trip Generation, Traffic Assignment and LOS Assessment Associated with Measure B. Prepared for the Palo Alto Unified School District. August 7, 2009. Initial Study Gunn High School Master Plan 87 ESA / 209002 Initial Study September 2009 Issues (and Supporting Information Sources): Potentially Significant Impact Less Than Significant with Mitigation Incorporation Less Than Significant Impact No Impact 16. Utilities and Service Systems Would the project: a) Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board? b) Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? c) Require or result in the construction of new storm water drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? d) Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed? e) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? f) Be served by a landfill with sufficient permitted capacity to accommodate the project’s solid waste disposal needs? g) Comply with federal, state, and local statutes and regulations related to solid waste? Setting Water supply to the City of Palo Alto is provided by the City Utilities Department through purchases from the San Francisco Public Utilities Commission’s Hetch Hetchy water supply system. On average, 85 percent of this water is derived from snow melt flowing into the Hetch Hetchy Reservoir in Yosemite National Park, and the balance is from runoff stored in San Francisco Bay Area reservoirs on the Peninsula and in the East Bay. There are five wells in Palo Alto that are maintained as an emergency source of supply. Palo Alto also uses recycled water from the Regional Water Quality Control Plant (RWQCP) to irrigate the municipal golf course, Greer Park, and landscaping around the RWQCP. The City owns and operates an approximate 200-mile wastewater collection system and operates the Regional Water Quality Control Plant (RWQCP). The RWQCP also serves Mountain View, Los Altos, Los Altos Hills, East Palo Alto, and Stanford University. Approximately 26 million gallons of wastewater are processed on a daily basis at the RWQCP and 9.5 billion gallons annually (3.3 billion gallons from Palo Alto). The City also provides weekly waste, yard waste and recycling collection service to all homes and businesses in the City. Yard waste is currently composted at the Palo Alto Landfill. Waste collected at the curbside goes to the Sunnyvale Materials Recovery and Transfer Station or to another facility for additional sorting. The processed waste is ultimately placed in a landfill at the Initial Study Gunn High School Master Plan 88 ESA / 209002 Initial Study September 2009 Kirby Canyon Landfill in San Jose. The Palo Alto Landfill, which is scheduled to close in 2011, currently accepts waste from self-haul and City vehicles. The City is required by State law to divert 50 percent of its waste stream from landfills. In 2006, the City diverted 62 percent of its waste stream. Discussion a, e) Less than Significant. Minimal growth in student and staff populations would occur over the duration of the Master Plan. As discussed in the Project Description, the proposed Master Plan identifies an increase in the student enrollment at the high school through 2017. The student capacity over the eight-year period of the Master Plan would increase by approximately 350 students, or about 44 students per year. This increase would not result in substantial increases in wastewater generation over existing conditions at the project site such that the wastewater treatment requirements would be exceeded. Furthermore, the City of Palo Alto’s General Plan EIR found that overall population growth that would occur in the City (of which future PAUSD students and staff would be a part) would not create significant amounts of wastewater that would exceed the RWQCP treatment capacity or require expansion of the treatment plant. Therefore, the proposed project would result in a less than significant impact regarding wastewater treatment requirements. b, d) Less than Significant. The proposed project would result in the development of a combined maximum total of approximately 124,000-square feet of new educational uses on the project site. These new uses (e.g., new classrooms, gymnasium, labs, etc.), and the minor increases in student and staff population they would accommodate over the Master Plan’s eight-year planning period would incrementally increase local water demand and wastewater generation at the project site, as discussed above. As noted in the General Plan EIR, the City would have access to adequate water supplies and wastewater treatment capacity to serve anticipated population growth. Therefore, the proposed project would not require new or expanded water or wastewater facilities and effects to water treatment facilities would be less than significant. c) Less than Significant. New buildings and other structures proposed under the Master Plan would require connection to the existing on-site stormwater drainage system. Stormwater runoff from the project site would be routed to the municipal stormwater collection system. As discussed in Section 8, Hydrology and Water Quality, and as required by Mitigation Measure HYD-1, the PAUSD would be required to develop a Storm Water Pollution Prevention Plan that would identify Best Management Practices to ensure that construction of new on-site stormwater infrastructure would not result in adverse impacts to water quality. f, g) Less than Significant. Gunn High School student and staff population growth would be relatively stable over the eight-year Master Plan horizon. The Kirby Canyon Landfill has Initial Study Gunn High School Master Plan 89 ESA / 209002 Initial Study September 2009 adequate capacity until 2022, and as such, the General Plan’s regional growth, including minor increases in local student and staff populations at the project site, would not adversely affect capacity at the Kirby Canyon Landfill; therefore, impacts to solid waste would be less than significant. Additionally, in conformance with Mitigation Measure HAZ-1, the proposed project would not affect compliance with solid waste statutes and regulations. Sources California Integrated Waste Management Board (CIWMB), Active Landfills Profile for Kirby Canyon Recycling and Disposal Facility, www.ciwmb.ca.gov/profiles/facility/landfill, accessed July 23, 2009. CIWMB, Jurisdiction Profile for City of Palo Alto, www.ciwmb.ca.gov/profiles/Juris, accessed July 23, 2009. City of Palo Alto, All About Your Utilities: Palo Alto’s Homegrown Asset, April 10, 2007. City of Palo Alto, Comprehensive Plan Update, 1996. City of Palo Alto, Draft and Final Environmental Impact Report, Comprehensive Plan Update, 1996. Initial Study Gunn High School Master Plan 90 ESA / 209002 Initial Study September 2009 Issues (and Supporting Information Sources): Potentially Significant Impact Less Than Significant with Mitigation Incorporation Less Than Significant Impact No Impact 17. Mandatory Findings of Significance Would the project: a) Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? b) Does the project have impacts that are individually limited, but cumulative considerable? (“Cumulative considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)? c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly? Discussion a) Less than Significant. Based upon background research, site reconnaissance, and the project description, the project does not have the potential to substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self- sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory. Any potential short-term increases in potential effects to the environment during construction are mitigated to a less than significant level, as described throughout the Initial Study. b) Less than Significant with Mitigation. In accordance with CEQA Guidelines Section 15183, the environmental analysis in this Initial Study was conducted to determine if there were any project-specific effects that are peculiar to the project or its site. No project- specific significant effects peculiar to the project or its site were identified that could not be mitigated to a less than significant level. The proposed project would contribute to environmental effects in the areas of biological resources (e.g., loss of trees), temporary increases in construction-generated dust and noise, temporary increase in sedimentation and water quality effects during construction, and operational traffic and circulation impacts. Mitigation measures incorporated herein mitigate any potential contribution to cumulative impacts associated with these environmental issues. Therefore, the proposed project does not have impacts that are individually limited, but cumulatively considerable. c) Less than Significant. The project may have significant adverse effects on human beings in the areas of air quality, noise and traffic during construction, and with geologic/seismic considerations with new development. Mitigation measures identified in the relevant sections of this Initial Study would reduce the effects to a less than significant level. 350 Frank H. Ogawa Plaza Suite 300 Oakland, CA 94612 510.839.5066 phone 510.839.5825 fax www.esassoc.com memorandum date February 5, 2010 to Palo Alto Unified School District from Lesley Lowe, AICP - ESA Project Manager Cory Barringhaus, AICP – ESA Senior Associate John Wilson, P.E., - Wilson Engineering subject Gunn High School: Response to Questions/Comments on the Draft Initial Study (ESA No. 209002) On October 6, 2009 the Palo Alto Unified School District (Lead Agency) released for public review a Draft Mitigated Negative Declaration for the Gunn High School Master Plan (SCH# 2009102024). The 30-day public review and comment period began on October 6, 2009 and closed at 5:00 p.m. on November 4, 2009. Further, a public hearing on the project was held on October 27, 2009, at a regularly scheduled School Board Meeting. This memorandum summarizes and responds generally to the comments and questions on the Draft Mitigated Negative Declaration for the Gunn High School Master Plan. Following circulation of the Draft Mitigated Negative Declaration, minor changes were made in response to comments to clarify the project description and add specifics to mitigation measures presented in the document. Comments have been organized by general concern and further categorized by a subtopic. The subtopic is summarized and a response provided. Comment letters received during the public review period are attached as Attachment A. The minutes from the October 27, 2009 School Board Meeting are attached as Attachment B. Responses to Comments Transportation and Circulation Trip Generation Comment states the trip generation rate from ITE underestimates the forecast of new auto trips based on the proposed increase in student population; e.g., no school buses are used. Response: The traffic analysis prepared for the draft Initial Study utilized Institute of Transportation Engineers (ITE) Standard Trip Generation Rates when estimating increases in traffic which could be associated with potential increases in student population over the next nine years. The ITE rates are based on studies of over 20 sites throughout the US and are generally considered the best available on an overall basis. However, the rates are qualified to the extent that more research is needed relative to use of school busing and transit and whether the schools were private or public. A breakdown of means of commute 2 information was not provided in the ITE manual other than to state the percentage of students transported by transit and/or bus varied considerably. At both Palo Alto High Schools, with limited transit and essentially no busing, there is a different sort of variation which occurs. At both Palo Alto and Gunn High Schools a high percentage of students (as much as a third of the student body) bicycle. During clear weather in the Fall, as many as 600 plus students or a third or more students regularly commute by bike to Gunn. Surveys of existing travel modes conducted last year at the two high schools were completed on brisk March days when the bicycle commute was significantly reduced (by 200 plus). This reduction results in a proportional increase in auto commuting, typically in the form of drop-offs. Parking at the schools is controlled with permits and students cannot simply drive themselves on a cold or rainy day. As such, the survey of drop-offs (inbound and outbound trips) showed a significantly increased number relative to what regularly occurs on a sunny day and should be interpreted as more of a worst case estimate. In response to the comment, the following table summarizes trip generation estimates utilizing the more conservative or worst case results from the March surveys. The numbers are based upon a simple pro rata increase of survey results (driveway counts) relative to the potential increase in student population at Gunn. The student population is forecast to increase from a level of 1,948 for the 2008/2009 year to 2,259 in 2018 or by 15.96 percent. Table 6 of the Initial Study is revised to reflect the alternative trip generation methodology. With this methodology the increase in students at Gunn would generate approximately 147 addition vehicle trips. TABLE 6 AM PEAK HOUR TRIP FORECAST Existing Student Population Forecast 2018 Student Population Net Increase in Auto Trips Net Inbound/ Outbound Trips 1948 2,259 147 98/49 SOURCE: Wilson, 2009 Intersection Levels of Service Comment states that study intersections are not quantified in terms of additional delay attributable to the increased traffic relative to a pro rata increase of trips surveyed versus estimates utilizing ITE trip generation forecasts. Commenter also states there is no comparison between cumulative with project and cumulative without project. Response: Table 6.5 below presents the results of a revised LOS analysis which assumes the revised trips generation rates discussed in the response to the Trip Generation comment above. The table presents the project’s contribution to delay and changes in traffic volumes at the study intersection under the Existing plus Project scenario (under Project) in seconds of delay and changes in volume to capacity ratio (V/C) per standard traffic engineering practices. The quantified increase in delay and v/c ratio at the study intersections attributable to project related traffic can be represented by subtracting the “Existing” delay from the “Existing Plus Project” delay. These are the two metrics the City uses to quantify impacts when an intersection is already operating at an LOS F prior to the addition of project traffic. However, in terms 3 of the actual LOS calculations/ modeling process, it must be noted that results at impacted intersections can quickly exceed the capability of the modeling process. Once traffic volumes exceed intersection capacity and an intersection is forecast to operate at an LOS F, further estimates of delay and v/c ratios become increasingly erroneous as volumes are increased. At LOS F the theoretical capacity of the facility is exceeded. As noted in the Initial Study discussion, two of the study intersections are currently operating at a low level of service even assuming completion of the City’s proposed re-striping of Arastradero Road. The intersections of Miranda Avenue and the Gunn driveway entrance with Arastradero Drive are currently operating at an LOS F during the morning peak hour and will continue to do so with the city’s proposed re-striping plan of Arastradero Road assuming the “Preferred” or Hybrid Alternative. TABLE 6.5 EXISTING AND FUTURE LEVELS OF SERVICE (LOS) AND AVERAGE VEHICLE DELAY (seconds/vehicles)a Intersection Control Existing w/City’s Hybrid Alternative a Existing w/City’s Hybrid Alternative + Project Typeb Delay b V/C LOS Delay b V/C LOS AM Peak Hour Arastradero / Foothill Signal 42.7 0.66 D 43.2 0.68 D Arastradero / Miranda Signal >120c 1.18 F >120c 1.21 F Arastradero / Gunn HS Entrance Signal >120c 2.45c F >120c 2.79c F Arastradero / Donald / Terman Signal 43.4 0.88 D 45.4 0.88 D a The Hybrid Alternative assumes restriping of Arastradero Road with essentially one lane in the eastbound direction east of the cemetery b Represents average vehicle delay in seconds for overall intersection at signalized intersections. c Delay and V/C calculations at this location exceed the capability of the traffic model process. SOURCE: Wilson (2009) Table 6.5 presents, as noted in the Initial Study, two of the studied intersections are forecast to operate at unacceptable levels assuming completion of the City’s proposed re-striping of Arastradero Road and are forecast to continue to do so with completion of the proposed project. The intersections of the school driveway and Miranda Avenue with Arastradero Road currently operate at an LOS F during the morning peak commute period, and are forecast to continue to do so when the City’s re-striping of Arastradero Road takes place assuming the preferred “Hybrid Alternative”. In addition, both intersections forecast to experience an increase in v/c ratios in excess of 0.01 or the City’s threshold for a significant impact, if the project is completed and the student body grows as forecast. Again, in terms of the actual LOS calculations/ modeling process, results for the intersection of the Gunn driveway and Arastradero Road far exceed the capability of the modeling process. Once traffic volumes exceed intersection capacity and an intersection is forecast to operate at an LOS F, further estimates of delay and v/c ratios become increasingly erroneous. 4 Traffic Demand Management Policies and Implementation Comment states the current and proposed TDM plan is inadequate for the following reasons: • Many of the proposed mitigations are already being implemented through the TDM and by other means • Transportation mode shift from auto to other modes is not quantified • Proposed carpool matching program lacks goals and specific implementation information • Additional bike parking is not quantified Response: Mitigation Measure TRANS-2, which addresses onsite circulation, includes the following revisions which further identify when the TDM policies would be implemented and outlines additional policies that would be added to the current program: The City’s criteria for determining an impact or when mitigation is needed when an intersection is already operating at a LOS F is when forecast increases in traffic are estimated to increase delay by more than four seconds or the v/c ratio by more than 0.01 or one percent. The critical intersection in determining impacts and the potential need for mitigation is the intersection of the Gunn entrance driveway and Arastradero Road during the morning peak commute. As discussed above, the delay related calculations exceed the capability of the traffic model given the current level of traffic demand in the area. Therefore, the following assessment of levels of significance relative to this project is based on anticipated increases in volume to capacity or v/c ratio relative to a one percent or more increase. The assessment focuses on the intersection of Gunn with Arastradero where the largest increase in v/c ratio is forecast to occur. Measures sufficient to reduce trip increases at this location to acceptable levels would be sufficient to mitigate potential impacts at the intersection of Miranda Avenue and Arastradero. A.M. peak hour traffic counts at the intersection of Gunn and Arastradero completed in March of 2009 showed a total volume of 2,363 vehicles entering the intersection in a one hour period. An increase of one percent would be an additional 24 vehicles. Again, using the results of the Gunn surveys completed in March of 2009, this would be equivalent to an increase of 50.78 or 51 new students. At this point, the City’ level of significance criteria relative to an increase in v/c ratio would be exceeded and traffic related mitigation is warranted. In terms of monitoring the success of proposed measures, traffic counts would be completed at the entrance to the school on an annual basis during a pre-selected time interval. The results of the counts would then be compared to baseline counts and if increases exceed 24 vehicle trips during the morning peak hour, additional mitigation measures would have to be implemented. The timing of the counts does not matter relative to time of school year as long as school is in full session (no holidays, winter break, special testing, etc.), the weather is dry, and the counts are conducted the same time every year. To that end, the District would conduct a week long hose count of the Gunn driveway entrance (both inbound and outbound) in the early spring (middle of April when weather could be expected to be dry) to establish the baseline monitoring number. The counts would then be repeated on an annual basis beginning when the student population increases beyond the population at the time of the baseline count by more than 51 or the impact threshold as described above. The baseline will be established this spring before mitigation measures begin to be implemented to allow identification of the degree of success of measures. The monitoring of driveway volumes would then continue as long as the student population exceeded baseline plus 51 conditions. 5 The following measures are being proposed by the District as the first level of mitigation which will need to be implemented when the student population increases by more than 51 people. At that point, the school will need to monitor and determine the degree of success of the measures in diverting students to alternate modes, those being increased use of VTA and increased carpooling as described above. Whenever the counts show an increase of more than 24 trips during the morning peak hour, additional measures will have to be implemented. • Provide VTA Passes to students free of charge. Coordinate a voluntary ride-sharing program. • Increase the number of bike racks in campus to encourage less driving. • Evaluate alternative means of class scheduling with the goal of expanding the peak arrival times to the campus. When the number of number of new students minus the number of additional students diverted to transit with the implementation of VTA Eco Passes or voluntary ride-sharing programs exceeds the critical 51 new student level (increase of 24 auto trips), a second tier of measures will need to be implemented to retain compliance with the City’s impact criteria. At that point, the administration will need to implement additional measures to reduce school related traffic. These could include the following or similar types of measures: • Implement alternative means of class scheduling with the goal of expanding the peak arrival times to the campus. In addition, the following TDM efforts are included as part of the Master Plan: • An increase or bike racks • Parking re-striping plan with a target increase of parking spaces. With the implementation of the TDM program, the proposed project would have a less than significant impact on local roadways. These mitigations will be monitor in the Mitigation Monitoring and Reporting program. Access and Circulation Comment states that using staff to monitor and direct traffic during peak drop-off/pick-up times lacks specific implementation information and has been unsuccessful in the past. Comment states that the drop-off queue on Arastradero Road is shared with students entering the school site to park, which increases backups, and is not analyzed in the traffic study. Response: The project is attempting to improve student drop-offs and on-site circulation through the re- design of the onsite circulation system, parking lot layout, bicycle access, etc. Goals of the redesign include minimizing conflicts, facilitating bike access and maximizing the smooth and efficient flow of 6 traffic onto and off of the site. The District will also be implementing measures to limit site trip generation as discussed above. Transit Ridership Comment states that bus ridership was not quantified in the traffic study. Response: As discussed in Section 15, Transportation, of the Initial Study, bus service in Santa Clara County is operated by the Santa Clara Valley Transportation Authority (VTA). Commuter rail service (Caltrain) is provided from San Francisco to Gilroy by the Peninsula Joint Powers Board. Route 88, 88L, and 88M, currently provide service in the vicinity of the project. Under existing conditions, these buses generally operate with excess capacity during peak commute periods. The proposed project, which could result in as much as a 15.96 percent increase in student population, could increase ridership on these lines. This would be particularly true if free VTA Eco passes are provided as discussed above. However, the lines have sufficient capacity in accommodate new patrons related to the proposed project. Parking Demand Comment states that mitigation limiting onsite parking spaces and permits would shift parking to adjacent neighborhoods, which should be addressed. Response: As necessary, the District would work in conjunction with the City of Palo Alto to offer a permit only parking if the proposed project resulted in students parking in the adjacent neighborhoods. Intersection Levels of Service Comment states that LOS F intersections at school entrances on Arastradero Road (main entrance and Miranda Avenue) are not quantified in terms of additional delay attributable to the increased traffic. Response: Please see response to earlier comments regarding LOS. Drop-off at Miranda Avenue Comment states that drop-offs at Miranda Avenue are currently almost as large as those occurring at the Arastradero Road entrance (44%) and operates at LOS F. Mitigations envisioned in the funded phases of the Master Plan only address the Arastradero entrance; therefore, the Miranda entrance would be inadequate for both drop-off s and emergency vehicle access. Item 4.d of the Master Plan should be moved into the current work plan. Comment states that the Santa Clara Sheriff’s Office is currently ticketing vehicles dropping off students at the Miranda VTA bus stop. Therefore, use of this drop-off location may not be available for the foreseeable future and the traffic study should be revised to reflect this condition. Response: The Facilities Steering Committee will evaluate the Parking and Drop-Off project with the option to include a parking and drop-off area at the Miranda entrance. 7 Bell Schedule/Start Times, etc. Comment disagrees with mitigation regarding earlier school start times. Additional commenters state a staggered bell schedule would be effective mitigation. Other mitigation proposed by the comment includes: 1) online learning, 2) independent study options, 3) late afternoon/evening courses, 4) extension of school day by adding 0 and 8th periods, and 5) off-campus course work. Response: As described in the project description of the Initial Study, the Gunn High School Master Plan is a planning level document and as such specific details such as bell schedules have not been developed at this stage in the planning process. Potential impacts related to Traffic Demand Management Polices and Implementation would be mitigated to a less than significant level by Mitigation Measures TRANS-1 and TRANS-2. The District will evaluate alternative class scheduling options as necessary to stagger arrival times to the campus. Hydrology Mitigations Details Comment notes lack of detail regarding stormwater runoff design and compliance with the Regional Water Quality Control Board’s C.3 requirements. Response: As described in the project description of the Initial Study, the Gunn High School Master Plan is a planning level document and as such specific details of the stormwater drainage system have not been developed at this stage in the planning process. Potential impacts regarding stormwater runoff would be mitigated to a less than significant level by Mitigation Measure HYD-1, which requires compliance with provisions of the NPDES regulations, including the C.3 provisions. Municipal Stormwater Permit Comment notes that the project will have to comply with the new regional municipal stormwater permit, which also requires use of low impact development techniques under C.3. Response: The PAUSD acknowledges the comment and will fully comply with the regulatory requirements of the NPDES through implementation of Mitigation Measure HYD-1. Greenhouse Gases Greenhouse Gases and Noise Comment notes that the greenhouse gas and noise analysis use traffic numbers that may need to be updated depending on the use of the ITE trip generation rate. 8 Response: The trip generation estimates were revised to address public comments and the net new morning vehicle trips were increased by approximately 16 percent. Pages 24 and 29 of the Initial Study, is updated as follows to reflect the increase in vehicle trips: Operational Emissions The project would result in a net increase in emissions of criteria pollutants (ROG, NOx and PM- 10) primarily because of a resultant increase in average daily vehicle trips. Based on the traffic analysis, the proposed change in land use would result in an increase of approximately 532 617 net new daily vehicle trips. Increased vehicle trips would lead to a small increase in ROG (approximately 2.7 3.0 pounds per day), NOx (approximately 2.2 2.6 pounds per day) and PM-10 (approximately 6.9 8.0 pounds per day) due to vehicle exhaust. Increases in emissions from stationary sources at the site (such as natural gas combustion for space and water heating, landscaping, use of consumer products, etc.) would also be minimal (approximately 0.72 pounds per day of ROG and 1.06 pounds per day of NOx). Together, operational emissions increases resulting from the project would represent approximately ten percent or less of the quantities BAAQMD currently identifies as significant (80 pounds per day of either ROG, NOx, or PM-10, individually). Therefore, once operational, the development under the Master Plan would not significantly contribute to a violation of any air quality standard in the area. Project emissions would also be below new CEQA thresholds proposed by BAAQMD of 54 pounds per day of ROG, NOx and PM-2.5 and 82 pounds per day of PM-10. Changes to GHG on page 29 of the IS: The proposed improvements to Gunn High school under the Master Plan would result in an increase in daily operational CO2 emissions from project-related traffic and area source emissions for space and water heating as well as electricity demand. Operational emissions of CO2 from vehicle traffic as calculated by URBEMIS2007 would be 665 772 “short” tons per year or 603 700 MT per year. URBEMIS also calculates natural gas combustion emissions based on square footage of improvements. CO2 emissions from natural gas emissions are calculated to be 233 “short” tons per year or 211 MT per year. Electricity demand based on square footage of improvements and California specific emission factors of the California Climate Action Registry and high school-specific electrical demand estimates would result in an additional 430 MT per year of GHGs emitted indirectly as a result of the project. Consequently the total operational CO2 emission rate resulting from implementation of the proposed Master Plan is estimated to be 1,244 1,341 MT per year. When compared to the state facility reporting requirement for GHG emissions of 25,000 MT per year CO2e, the maximum GHG emissions for the project (222 MT per year CO2e during construction; and 1,244 1,341 MT per year during operations are not significant enough to require reporting to the CARB relative to the requirements of AB32. Additionally, although not yet adopted nor applicable to the proposed Master Plan, project GHG emissions would be less than the proposed 7,000 MT per year Preliminary Staff Proposal threshold for industrial projects under consideration by CARB. 9 BAAQMD has recently proposed a GHG significance threshold of 1,100 MT/year for development projects. While this threshold has not yet been adopted, the proposed project GHG emissions would exceed this proposed threshold by 22 percent. Consequently, mitigation measures to reduce GHG emissions are recommended. The modified trip generation would not increase noise due to the projected increase in vehicle traffic, as volumes on Arastradero are high volume roadways and the project contributions are relatively small. Land Use and Community Design Element Comment notes minor edits in reference to the City of Palo Alto Comprehensive Plan. Response: The PAUSD acknowledges the comments and page 20 of the Initial Study is revised as follows: City of Palo Alto, Palo Alto Comprehensive Plan 1998-2010, Land Use and Community Design Element, adopted July 20 17, 1998 2007. All references in the Initial Study to the “Palo Alto Comprehensive Plan Update 1996” are revised to read “Palo Alto Comprehensive Plan 1998-2010.” Attachment A Lesley Lowe From: Aimee Lopez [alopez@ocmi.com] Sent: Monday, November 02, 2009 9:14 AM To: Lesley Lowe; Cory Barringhaus Subject: FW: Public comment, Public Hearing, Gunn CEQA documents and westside traffic Page 1 of 3 1/29/2010 Additional comment for CEQA Aimée From: Robert Golton [mailto:rgolton@pausd.org] Sent: Friday, October 30, 2009 11:54 PM To: Tom Hodges; Aimee Lopez; elee@dlm.com; Ron Smith Subject: FW: Public comment, Public Hearing, Gunn CEQA documents and westside traffic please add this to your CEQA comments. Robert Golton, Chief Business Official Palo Alto Unified School District 3 Please consider the environment before printing this e-mail. From: Kathleen Ruegsegger Sent: Friday, October 30, 2009 4:09 PM To: Robert Golton; Kevin Skelly Subject: FW: Public comment, Public Hearing, Gunn CEQA documents and westside traffic FYI. This went to the Board and me. Kathleen Ruegsegger Administrative Assistant to the Superintendent Palo Alto Unified School District 25 Churchill Ave., Palo Alto, CA 94306 650.329.3737 (w) 650.321.3810 (fax) www.pausd.org From: Duncan MacMillan [mailto:dmcmllan@pacbell.net] Sent: Friday, October 30, 2009 3:35 PM To: Melissa Caswell; Barbara Klausner; Barbara Mitchell; Dana Tom; Camille Townsend Cc: Kathleen Ruegsegger Subject: Fw: Public comment, Public Hearing, Gunn CEQA documents and westside traffic Fyi since I added a few comments, shown in italics, since the Board meeting. The net of it all is that: Without addressing Miranda (>44% of the drop-off + emergency access issues), the mitigation measure proposed in the current CEQA document (TRAN-3) will be defective and a MITIGATED NEGATIVE DECLARATION should not, therefore, be awarded. Regards, Duncan --- On Wed, 10/28/09, Duncan MacMillan <dmcmllan@pacbell.net> wrote: From: Duncan MacMillan <dmcmllan@pacbell.net> Subject: Public comment, Public Hearing, Gunn CEQA documents and westside traffic To: "Tom Hodges" <thodges@pausd.org> Cc: "Dr. Robert Golton" <rgolton@pausd.org> Date: Wednesday, October 28, 2009, 3:15 PM Hi, Tom: As you suggested, here is a restatement of my remarks made at public hearing during the PAUSD Board meeting last night. Without a 3-minute limit, I also took the liberty of providing additional comments, which are shown in italics.... "My name is Duncan MacMillan, from Los Altos Hills. "I was happy to receive the nearly 100-page CEQA report on Gunn and especially the inclusion of the Wilson Engineering traffic data. "That report clearly confirms that Arastradero is currently at capacity at both the Main Entrance and Miranda intersections. It also provides a grading of the Level of Service at several points. The two intersections mentioned received a LOS of "F", certainly a failing grade ("Operatons with delays unacceptable to most drivers occurring due to over-saturation, poor progression, or very long cycle lengths"). "Most important, on page 80 of the CEQA report, collected traffic data (by Wilson Engineering) shows that the drop-offs at Miranda are currently almost as large as those that occur via the Main Entrance - more than 44% of Gunn drop-offs occur along Miranda at the present time. "The mitigations envisioned in the funded phases of the plan only address the Main Entrance. Without a change in priorities, Miranda can not be addressed for many years, until yet another bond issue. "Miranda is inadequade for both current drop-off traffic and for emergency access to the west side of campus. An improved west-side access would enhance the ability of emergency vehicles getting to the most campus buildings and to some of the more likely buildings to have problems - the science building, for instance. "The Board should move the current Item 4.d into the current work plan, which could then address the issues of improved drop-off and emergency access traffic at Miranda. That work has been estimated at a little over $1 million, against the current work plan of more than $76 million. Page 2 of 3 1/29/2010 "If the Board does not act, the dual safety issues of an adequate drop-off and emergency access for the Gunn campus will not be addressed for many, many years. An unacceptable situation. "Thank you." Duncan MacMillan Los Altos Hills --------- additonal comments ---------- Special attention should be drawn to the current Mitigation Measure TRAN-3 in the CEQA document, which cites a number of physical enhancements to address the Main Entrance traffic issues. Unfortunately, the Main Entrance carries only slightly more than half of the current drop-off load (161 at Miranda versus 204 via the Main Entrance for at total of 365 drop-offs for the campus; a shift of only 20 drop-offs would make the loads equal). TRAN-3 needs to expanded to address Miranda or the Gunn site can not be expected to grow to its projected level of enrollment without Arastradero deteriorating even further, below its current F LOS rating, "the worst operating conditions" as enumerated in the CEQA report. In addition, there may be a "paint and pylon" opportunity next fall and winter to experiment with an internal drop-off via the west entry along Miranda. The T-transportable classrooms will have vacated the area during the summer of 2010. Construction will not begin (A/B Buildings+) until the spring of 2011. Once the classrooms are removed, the Miranda access road and previous parking areas will be exposed and the judicious use of paint and pylons (as was done on the Main Entrance this past year) could test a drop-off/turnaround scheme. Please move this project forward both in its detailed planning and possible experimentation, as well as implementation during the currently-funded work plan. Without addressing Miranda drop-off safety and emergency access issues, the CEQA mitigation effort will be barely 50% complete and a MITIGATED NEGATIVE DECLARATION should not, therefore, be awarded. #### Page 3 of 3 1/29/2010 Lesley Lowe From: Aimee Lopez [alopez@ocmi.com] Sent: Tuesday, November 03, 2009 4:36 PM To: Lesley Lowe; Cory Barringhaus Subject: FW: no to earlier arrival times Page 1 of 1 1/29/2010 Another CEQA Comment Aimée M. Lopez | Project Manager O'Connor Construction Management, Inc. Palo Alto Unified School District 25 Churchill Ave., Bldg. D, Palo Alto, CA94306 650.329.3968 | Fax 650.327.3588 | Cell 925.580.2714 e-mail: ailopez@pausd.org From: Tom Hodges Sent: Tuesday, November 03, 2009 3:44 PM To: Aimee Lopez Subject: Fw: no to earlier arrival times From: Beatriz Magaloni <magaloni@stanford.edu> To: thodges@pausd.org <thodges@pausd.org> Sent: Tue Nov 03 18:18:43 2009 Subject: no to earlier arrival times Dear Tom, I am a mother of three kids, one going to middle school next year and the other two in K and 2. I am very concerned about Gunn High School's intention to get kids to arrive earlier to school. With what is going on in the community among kids that age, and especially at Gunn, I think it is extremely inadequate to demand earlier arrival from kids. Studies amply show that high-school kids need MORE sleep -- even 30 minutes can have a huge impact on both physical and emotional health. I support kids arriving LATER to high-school, not earlier, and I know I am among a large group of parents supporting later arrivals. Beatriz Magaloni Department of Political Science Stanford University 616 Serra St Stanford, CA 94305 (650) 723-1806 magaloni@stanford.edu Palo Alto Council of PTAs 25 Churchill Ave Palo Alto CA, 94306 650-326-0702 November 18, 2009 Attn: Tom Hodges Palo Alto Unified School District 25 Churchill, Building D Palo Alto, CA 94306 The Palo Alto Council of PTAs Traffic Safety Committee respectfully submits the following comments on the Transportation /Traffic sections of the Gunn and Paly Draft Mitigated Negative Declarations. Trip Generation Projection--The report uses standard figures for increases in trips based on the land use category from the ITE. While this may satisfy a California Environmental Quality Act (CEQA) requirement, it does not necessarily predict the situation at Gunn High School or Paly today. For example, the present number of morning peak hour auto trips at Gunn is 922. The ITE formula is for every 3.79 students we add one car trip. Based on the ITE model there currently should be 514 auto trips in the peak hour. So, readers of this report should be cautioned that the ITE formula underestimates the forecast of new auto trips with the increase in student population. The increase in trips very likely will be significantly greater than the ITE forecast of 82 trips, possibly as much as 75% higher when we extrapolate from today’s 2.11 students per car trip. A difference of this scale will likely have a significant impact but it is not modeled in this analysis. Traffic is one of the top concerns cited by participants at Gunn planning meetings. TDM Plan Lacks Specific Goals & Critical Program Details The Gunn and Paly reports rely on Transportation Demand Management (TDM) plans for mitigations. However, the proposed mitigation plan doesn’t define performance criteria. Transportation mode shift, that is the percentage of students shifting from autos to other modes of transportation, which would be needed to provide adequate mitigation, is never quantified. Without that data, it is impossible to evaluate whether or not the reports’ conclusions that adequate mitigation is achievable is correct or incorrect. What is the mode shift goal of these mitigations? How many car trips need to be shifted to other modes in order to mitigate the transportation impacts of this expansion? Precisely how will that goal be achieved? Further, elements that could determine the success or failure of a TDM plan are not adequately specified, making it unenforceable. Typically, well written TDM plans have very specific participation and mode shift goals that should be attributed to each element of the plan. There is none of that in this plan. For example, a carpool matching program is cited as a required mitigation measure, yet the program has no goals attached to it in terms of participation. No specifics about organization of the matching program are outlined. Who will be responsible for organizing and managing the carpool matching program? Staff? PTA volunteers? Have they agreed to do this? What funding source will be used for this? This is time intensive work. What resources will PAUSD be required to apply to the carpool matching program? Carpool matching programs are most successful when students are matched at the very beginning of the school year before commute patterns are established. Will PAUSD release information to make it possible to create a carpool matching database or maps in time to meet this critical deadline? Even with this commitment, we don’t yet have a carpool matching model that we know really works for this school district. The PTA Traffic Safety Committee has experimented at Escondido and Ohlone with several carpool matching models yielding limited success. (Our best performance to date has been this year’s report from Ohlone, increasing from 26 carpoolers last year to 45 carpoolers this year.) The district has not allowed us to create an on-line matching program so we have not been able to explore that as an option. Another example is the bike parking facilities mitigation in the Gunn report: Mitigation Measure TRAN-2 states that bike racks should be located in convenient areas to facilitate ease of queues, safety, and accessibility. This is a good idea; however, the number of additional bike parking spaces required for adequate mitigation should be quantified in the Gunn and Paly reports. Further, the mitigation measure should specify that these additional spaces will be made available during the construction period as staff has agreed to do in recent meetings. A plan that depends on encouraging alternative modes as a primary mitigation should carefully spell out facilities capacity needs for those alternative modes. We suggest, at minimum, that enough bike parking spaces should be provided to meet current peak demand. That would require a minimum of 633 bike parking spaces at Gunn and 582 at Paly. Since the goal is to increase the number of bikes, we should plan for even greater numbers based on mode shift need for mitigation. Bike counts for both high schools for the last ten years were provided to staff at the beginning of the planning process to help them project probable future growth rates. The CEQA document should project probable bike count increases and specify a bike parking space number requirement in the mitigations. Further, the driveway and circulation design for both sites is still underway. It will be critically important to address the comfort and safety of bicyclists and pedestrians if we are to achieve successful mode shift. Usually, the parking/circulation plan for all modes would be included in the mitigations list as it must be part of the mitigation in a TDM plan in order to make it work. Gunn Mitigation Measure TRAN-4 requires staff to monitor and direct onsite traffic during peak drop-off/pick-up times. This is something Gunn staff has not been able to do consistently in the past. Is there funding for additional staff time? Has anyone asked Gunn staff how they will be able to implement this mitigation in the future? (Traffic Direction is not something PTA volunteers can do. The PTA insurance policy explicitly excludes this activity. If staff cannot do it, it won’t get done.) The same is true at Paly. Most of the other mitigations proposed for Gunn already have been implemented. Gunn PTA Traffic Safety Team already directs bike access away from the main Gunn campus driveway. We already provide maps and circulation instructions on the school web site and information about alternative modes of transportation (including buses, pedestrian and bike route maps, etc.) at the beginning of the year. Gunn already limits the number of parking permits. Paly provides some information re: Transportation on their web site as well. Please direct staff to specify that this is already being done in their final document. We can’t realistically expect a significant incremental mode shift from activities we are already doing. To reiterate the primary point: Most of the mitigations proposed in this document are already in place. We have a good idea how much mode shift we can achieve with these measures because we are already doing them. What we cannot tell from these documents is what additional mode shift is required to adequately mitigate the additional vehicle impacts of this project. That goal is not quantified anywhere in the document; therefore, it is impossible to evaluate whether or not the goal is achievable as the report claims it is. That reporting failure should be corrected. Without it the Mitigated Negative Declaration is inadequate. Bus ridership The Gunn report doesn’t quantify am/pm VTA bus ridership. The same is true of City of Palo Alto Shuttle use at Paly. Was bus use studied? Intersection Level of Service On page 78 (Gunn report) the report notes that Arastradero intersections at Miranda and the Gunn driveway already are at LOS F. Additional intersection delays are not specifically quantified because the intersection operations already are operating at an unacceptable level. However, though there isn’t a worse LOS “grade” than F, it is possible for real world road users to experience greater delay than they currently do. Further degradation of these intersections will impact the performance of Arastradero Road as a whole. The report only reports this as >120 seconds in these cases, and it does not specifically quantify the delay. Delays at the Gunn driveway at morning bell time are a key factor driving peak hour performance of the Arastradero street system. Currently, no other single facility on Arastradero has a more negative impact on operational efficiency of the road than Gunn HS. We need to make sure the district has gotten this right. The likely effect of further LOS degradation would be “peak spreading”—the peak period during which the intersection operates at LOS F will become longer with road users choosing to travel earlier and earlier to avoid delays. Under most circumstances, traffic would also spread later, but that cannot happen at school sites where peak periods are driven by bell times. Peak spreading will make the Gunn Mitigation Measure TRAN-2 that provides early morning study areas or breakfast incentives necessary. A mitigation to address LOS degradation was suggested in the original traffic study for this project by Wilson Engineering. That was staggering Gunn bell times. This would spread out arrivals, eliminating peak loads that precede current bell times. This same mitigation was independently proposed by City of Palo Alto Consulting Engineer Gary Kruger to improve LOS at impacted Arastradero corridor intersections. The district rejected this mitigation, citing logistical difficulty of implementation. If the engineers’ recommended mitigation is rejected, then a substantive alternative is required that will adequately mitigate the LOS impacts. The current proposed mitigations do not include such an alternative mitigation. The LOS problem remains and increased enrollment will worsen the situation at multiple Arastradero intersections, including: Gunn driveway, Foothill, Donald/Terman. If the district opts not to shift bell times, an adequate alternative mitigation must be identified. Gunn PTSA has suggested opening the library earlier and adding many more zero period classes. Zero period classes might help, depending on the number of classes. If this is to be required as an alternate mitigation, the number of zero period classes needed to provide adequate mitigation should be studied. The requirement should be very specific as to the number of zero period classes needed to insure adequate split of the auto surge to mitigate LOS impacts. Further, a traffic engineer should check to make sure that the timing of the zero period arrival time will not add traffic to affected Arastradero intersections during the Terman morning bell time surge. Bike Facilities—p. 79 should note the bike path that connects the rear of campus to Georgia. Parking demand—Gunn has 461 total existing spaces with current demand at 440 (or 95 percent). As parking mitigations require no increase in parking spaces or permits, how will PAUSD deal with probable shift of auto parking to nearby neighborhoods? Has this probable outcome been studied and/or discussed with the City of Palo Alto? This will be less of a problem at Paly where parking capacity is closer to projected demand, but it is a likely problem for both sites. Because projected trip generation is underestimated (see below), it is likely the parking problem will be much greater than the CEQA document indicates. The purpose of an environmental review is to insure that information is gathered to inform the planning process for proper mitigation. It is an important responsibility to the community to get this right. We appreciate this opportunity to comment on the Draft Mitigated Negative Declarations for Gunn and Palo Alto High Schools and we thank you for giving these comments your usual thoughtful consideration. Sincerely, Penny Ellson, 2009-10 Chair and Middle School Schools Representative Palo Alto Council of PTAs Traffic Safety Committee Christine Fawcett, High Schools Representative Palo Alto Council of PTAs Traffic Safety Committee George Pierce, Elementary Schools Representative Palo Alto Council of PTAs Traffic Safety Committee 1 Comments on the Initial Study and Environmental Checklist for California Environmental Quality Act for the Gunn High School Master Plan dated September 2009 Arthur M. Keller, Gunn Facilities Planning Committee, PTSA Public Transit Coordinator, Palo Alto Planning and Transportation Commission member, Gunn parent 1. The reference on page 20 to the Land Use Element of the Palo Alto Comprehensive Plan is erroneous. The chapter is called the Land Use and Community Design element, and it was part of the Palo Alto Comprehensive Plan for 1998-2010 adopted well before 2007. 2. The greenhouse gas analysis on page 24 and noise analysis on page 66 each assume in increase in daily trips of 532, which may be an underestimate. 3. The various references to the Palo Alto Comprehensive Plan Update 1996 should instead refer to the Palo Alto Comprehensive Plan 1998-2010. 4. Table 7 on page 82 states that the AM peak hour delays will remain at LOS F for both Arastradero Road / Miranda Avenue and Arastradero Road / School Driveway. However, no specific measure of critical delay was made other than the vague “> 120”; however the City of Palo Alto’s traffic significance thresholds states, “A significant impact results if the existing LOS is already D or worse at the intersections not included in ‘a’ above and the addition of project traffic causes an increase of one second or more of critical movement delay.”1 It is likely that the expected increase in traffic will increase the critical movement delay by more than one second, and the mitigations proposed are unlikely to reduce this increase to no more than one second. Furthermore, the increase in critical movement delay of 1.8 seconds exceeds the threshold of significance as determined by Palo Alto standards for the Arastradero Road and Donald/Terman intersection (see Table 7, page 82), even though the report implies that this increase is less than significant with mitigations. It is not demonstrated how the increase in critical movement delay would be reduced by mitigations to below one second. 5. Mitigation TRAN-1 regarding setting up a carpool-matching program for students is not realistic. The primary mechanism for such a matching program is through the student directory, which is not released to the students until November and does not geocode the student addresses. There is no quantification for the amount of carpooling currently occurring nor are there quantified goals for the increase in carpooling. No reference is made as to the apportionment of the increase of carpooling between students in carpools driving to Gunn High School versus parents dropping off and picking up carpools. 6. Mitigation TRAN-2 contains measures that are already in practice, and it is unclear the extent to which these measures will “not increase traffic volumes to the high school as the student body increases.” (page 82) 7. Spillover traffic and parking at the adjacent Barron Park neighborhood may be a consequence of the lack of increase in onsite parking spaces. No mitigation measures to address that consequential effect is provided. For example, there may be an increase in student dropoffs by parents on Georgia to avoid the Gunn High Driveway delay. 1 See “TRANSPORTATION SIGNIFICANCE THRESHOLDS—STUDY SESSION AND NEW INTERIM STANDARDS (CONTINUED FROM SEPTEMBER 19, 2002),” dated October 9, 2002, http://www.cityofpaloalto.org/civica/filebank/blobdload.asp?BlobID=7475 2 8. Will the price of student parking permits be increased if demand exceeds supply of permits, as proposed to be limited relative to 2009. In particular, as the number of teachers will be increased with student enrollment, more of the proposed-to-be-fixed parking spaces will have to be allocated to staff, with fewer students parking on campus. Replacing students driving with being dropped off by parents means replacing one-way trips with round trips. More morning round trips means long cycle times for cars exiting Gunn High School, adding to the critical movement delays at the Arastradero Road / Gunn High School intersection. While doing so may be beneficial from a land-use perspective, it is not an effective measure to reduce traffic impacts. 9. Maps are currently provided at the start of the school year illustrating preferred bicycle routes, which includes directing students to access the campus via Georgia and Los Robles rather than Arastradero Road. The data on Figure 12 indicates that this is successful and it is clear what greater success is intended by these measures. 10. The proposal to get students to arrive at Gunn High School before the peak rush through breakfast or by providing study areas is particularly unrealistic. High school students are chronically sleep deprived.2 11. The PTSA bicycle count has exceeded 600 on a warmer day (page 84), a suggested mitigation is to ensure that there is sufficient bike parking. As the enrollment is projected to increase by 21% over current levels, a proportionate increase would mean at least 750 secured bicycle parking spaces. Increased incentives (such as even more than a proportionate increase in bicycle parking) to bicycling would help to “not increase traffic volumes to the high school as the student body increases.” (page 82) 12. Measures have already been taken to increase student use of the VTA 88 bus routes. Another transportation mitigation measure that should be considered is to provide free VTA Eco Passes to all students at Gunn High School as a sticker on their student body card. The cost per student might be less if students at both Gunn High School and Palo Alto High School were included in the program. As demand for VTA bus service increases, PAUSD should provide support for working with the VTA to increase the number of buses provided before and after school and perhaps increase the number of distinct routes from the current three. 13. Another transportation mitigation measure to consider is to increase PAUSD bus service to accommodate demand by the approximately 160 Gunn students from Los Altos Hills and approximately 100 Gunn students from Stanford. 14. The queue of dropoffs (1100 feet in two lanes) is shared with the queue of students parking. This combination queue increases backups, and is not considered in the report. 15. Which staff members are proposed to monitor and direct traffic during peak dropoff/pickup times and how are they to be funded? 16. Another potential traffic mitigation is to have a right turn arrow from Arastradero Road into the Gunn High School driveway, so that inexperienced drivers do not stop when they have a “free” right turn and there are no pedestrians wanting to cross. Including signalized pedestrian crosswalk across the “free” right turn would handle the pedestrian/vehicle conflict. 2 See Laura Brown, “Early start time deprives teenagers of crucial sleep,” the Paly Voice, December 17, 2004, http://voice.paly.net/view_story.php?id=2431 3 17. The increase in AM peak hour trip forecast of 57 more inbound trips and 25 more outbound trips (Table 6, page 81) is contradicted by data elsewhere in the report. On page 84, it states that the number of vehicles dropping off students is expected to increase from 365 to 450, an increase in 85. Thus, one would expect an increase of 85 more inbound and outbound trips just from student dropoffs alone. Considering the limitation in parking, this number is likely to increase as noted in Item 8 above. 18. Current 11th day enrollment for Gunn High School is 1,898 and was 1,907 last year. 3 Table 6 (page 81) cites an existing student population of 1,948 with forecast of 2,259. However, page 5 cites an enrollment (last year) of 1,917. The increased enrollment based on Table 6 is less than 16%, while the actual increase from current levels to 2,300 is over 21%. Such a discrepancy calls into question the remaining figures in the analysis of the Initial Study. 19. The parking requirement stated is “one [parking] space for each four teaching stations.” (page 85). The report computes 92 teachers, but Gunn has 120 classrooms4 and likely even more “teaching stations.” 20. We observe that only increases in the numbers of students walking, bicycling, or riding buses to school, or increases in carpooling decreases traffic. The Initial Study states, “The goal of the TDM program is to not increase traffic volumes to the high school as the student body increases.” Thus, the TDM (Transportation Demand Management Program) must be sufficient with measureable quantified goals so that an additional 400 students must arrive at Gunn High School through alternative means. The number of students walking to school is limited by geography and is unlikely to increase. Specific and measureable mitigations are required to increase bicycling, bus use, and carpooling totaling 400 students. We believe that the report is inadequate because it fails to quantify the amount of critical movement delay in the intersections studied that are at LOS F, fails to consider the significant increase in critical movement delay at Arastradero Road and Donald/Terman that is at LOS D, and fails to identify specific, measurable and effective mitigations that increase bicycling, bus riding, and carpooling along with quantified goals, and fails to analyze whether the proposed mitigations will reduce the increase in critical movement delays to a less than significant level. 3 http://www.paloaltoonline.com/news/show_story.php?id=13854 4 http://www.trulia.com/schools/CA-Palo_Alto/Henry_M_Gunn_High_School/ DRAFT Dear Honorable Board of Education Members, I am submitting for your review my draft comments on the Trasnportation /Traffic sections of the Gunn and Paly Draft Mitigated Negative Declarations. The transportation elements of the Paly and Gunn environmental documents are remarkably short for projects of this scale. It makes reading them quick, but thoughtful review difficult. Some basic information is missing. TDM Plan Lacks Specific Goals & Critical Program Details The Gunn report relies on Transportation Demand Management (TDM) plans for mitigations. However, the proposed mitigation plan doesn’t define performance criteria. Transportation mode shift, that is the percentage of students shifting from autos to other modes of transportation, which would be needed to provide adequate mitigation, is never quantified. Without that data, it is impossible to evaluate whether or not the report‘s conclusion that adequate mitigation is achievable is correct or incorrect. What is the mode shift goal of these mitigations? How many car trips need to be shifted to other modes in order to mitigate the transportation impacts of this expansion? Precisely how will that goal be achieved? Further, elements that could determine the success or failure of a TDM plan are not adequately specified, making it unenforceable. Typically, well written TDM plans have very specific participation and mode shift goals that should be attributed to each element of the plan. There is none of that in this plan. For example, a carpool matching program is cited as a required mitigation measure, yet the program has no goals attached to it in terms of participation. No specifics about organization of the matching program are outlined. Who will be responsible for organizing and managing the carpool matching program? Staff? PTA volunteers? Have they agreed to do this? What funding source will be used for this? This is time intensive work. What resources will PAUSD be required to apply to the carpool matching program? Carpool matching programs are most successful when students are matched at the very beginning of the school year before commute patterns are established. Will PAUSD release information to make it possible to create a carpool matching database or maps in time to meet this critical deadline? Even with this commitment, we don’t yet have a carpool matching model that we know really works for this school district. The PTA Traffic Safety Committee has experimented at Escondido and Ohlone with several carpool matching models yielding limited success. (Our best performance to date has been this year’s report from Ohlone, increasing from 26 carpoolers last year to 45 carpoolers this year.) The district has not allowed us to create an on-line matching program so we have not been able to explore that as an option. Another example is the bike parking facilities mitigation in the Gunn report: Mitigation Measure TRAN-2 states that bike racks should be located in convenient areas to facilitate ease of queues, safety, and accessibility. This is a good idea; however, the number of additional bike parking spaces needed should be quantified in the Gunn and Paly reports. Further, the mitigation measure should specify that these additional spaces will be made available during the construction period as staff has agreed to do in recent meetings. A plan that depends on encouraging alternative modes as a primary mitigation should carefully spell out facilities capacity needs for those alternative modes. I suggest, at minimum, that enough bike parking spaces should be provided to meet current peak demand. That would require a minimum of 633 bike parking spaces at Gunn and 582 at Paly. Since the goal is to increase the number of bikes, we should plan for even greater numbers based on mode shift need. Please direct staff to make these corrections in the final draft. Further, the driveway and circulation design for both sites is still underway. It will be critically important to address the comfort and safety of bicyclists and pedestrians if we are to achieve successful mode shift. Usually, the parking/circulation plan for all modes would be included in the mitigations list as it must be part of the mitigation in a TDM plan in order to make it work. Gunn Mitigation Measure TRAN-4 requires staff to monitor and direct onsite traffic during peak drop-off/pick-up times. This is something Gunn staff has not been able to do consistently in the past. Is there funding for additional staff time? Has anyone asked Gunn staff how they will be able to implement this mitigation in the future? (Traffic Direction is not something PTA volunteers can do. The PTA insurance policy explicitly excludes this activity. If staff cannot do it, it won’t get done.) Most of the other mitigations proposed for Gunn already have been implemented. Gunn PTA Traffic Safety Team already directs bike access away from the main Gunn campus driveway. We already provide maps and circulation instructions on the school web site and information about alternative modes of transportation (including buses, pedestrian and bike route maps, etc.) at the beginning of the year. Gunn already limits the number of parking permits. Please direct staff to specify that this is already being done in their final document. We can’t realistically expect a significant incremental mode shift from activities we are already doing. To reiterate the primary point: Most of the mitigations proposed in this document are already in place. We have a good idea how much mode shift we can achieve with these measures because we are already doing them. What we cannot tell from these documents is what additional mode shift is required to adequately mitigate the additional vehicle impacts of this project. That goal is not quantified anywhere in the document; therefore, it is impossible to evaluate whether or not the goal is achievable as the report claims it is. That reporting failure should be corrected. Bus ridership The Gunn report doesn’t quantify am/pm VTA bus ridership. Was bus use studied? Intersection Level of Service On page 78 (Gunn report) the report notes that Arastradero intersections at Miranda and the Gunn driveway already are at LOS F. Additional intersection delays are not specifically quantified because the intersection operations already are operating at an unacceptable level. However, though there isn’t a worse LOS “grade” than F, it is possible for real world road users to experience greater delay than they currently do. Further degradation of these intersections will impact the performance of Arastradero Road as a whole. The report only reports this as >120 seconds in these cases, and it does not specifically quantify the delay. Delays at the Gunn driveway at morning bell time are a key factor driving peak hour performance of the Arastradero street system. Currently, no other single facility on Arastradero has a more negative impact on operational efficiency of the road than Gunn HS. We need to make sure the district has gotten this right. The likely effect of further LOS degradation would be “peak spreading”—the peak period during which the intersection operates at LOS F will become longer with road users choosing to travel earlier and earlier to avoid delays. Under most circumstances, traffic would also spread later, but that cannot happen at school sites where peak periods are driven by bell times. Peak spreading will make the Gunn Mitigation Measure TRAN- 2 that provides early morning study areas or breakfast incentives necessary. An alternate mitigation that might be considered (suggested in the original traffic study by Wilson Engineering) would be staggering Gunn bell times. This would spread out arrivals, eliminating peak loads that precede current bell times. There would be schedule complications, but this would immediately reduce the bell time surge of auto traffic. This is critically important because at Gunn there is only one driveway. The current bell time surge at that driveway is the equivalent of over 1,200 autos entering per hour in the twenty minute period 7:40-8:00am. This problem certainly will be exacerbated by a campus expansion and could be most effectively addressed by staggering bell times. However, when this was previously discussed it was dismissed as impractical by the district. Site expansion creates enough additional delay that this is an option worth revisiting. Bike Facilities—p. 79 should note the bike path that connects the rear of campus to Georgia. Parking demand—Gunn has 461 total existing spaces with current demand at 440 (or 95 percent). As parking mitigations require no increase in parking spaces or permits, how will PAUSD deal with probable shift of auto parking to nearby neighborhoods? Has this probable outcome been studied and/or discussed with the City of Palo Alto? This will be less of a problem at Paly where parking capacity is closer to projected demand, but it is a likely problem for both sites. Because projected trip generation is underestimated (see below), it is likely the parking problem will be much greater than the CEQA document indicates. Trip Generation Projection--The report uses standard figures for increases in trips based on the land use category from the ITE. While this may satisfy a California Environmental Quality Act (CEQA) requirement, it does not necessarily predict the situation at Gunn High School or Paly today. For example, the present number of morning peak hour auto trips at Gunn is 922. The ITE formula is for every 3.79 students we add one car trip. Based on the ITE model there currently should be 514 auto trips in the peak hour. So, readers of this report should be cautioned that the ITE formula underestimates the forecast of new auto trips with the increase in student population. The increase in trips very likely will be significantly greater than the ITE forecast of 82 trips, possibly as much as 75% higher when we extrapolate from today’s 2.11 students per car trip. A difference of this scale will likely have a significant impact but it is not modeled in this analysis. The purpose of an environmental review is to insure that information is gathered that can inform the planning process for proper mitigation. It is an important responsibility to the community to get this right. Thank you for giving these comments your usual thoughtful consideration. Sincerely, Penny Ellson To: Tom Hodges, Program Director Palo Alto Unified School District 25 Churchill Ave., Palo Alto, CA 94306 From: Joan Jacobus 3833 La Donna Ave, Palo Alto, CA 94306 Subject: Gunn High School Master Plan dated September 2009 CEQA Initial Study and Environmental Checklist in support of proposed Mitigated Negative Declaration – TRAFFIC, pages 75-86 Date: November 17, 2009 In light of the Sheriff’s Office changing their policy regarding drop offs at the Miranda VTA bus stop, the Wilson Engineering Reports, on which the traffic mitigation measures are based, will need to be revised. Even if the Sheriff’s Office reverses their current decision, at any point in the future they could again prevent drop offs at the bus stop. Presently 161 cars (44%) use Miranda for morning drop off, compared to 204 cars that use the Gunn driveway, so this is a significant issue. Those 161 cars cannot be redirected to the Gunn driveway which is already overcapacity (LOS F). Identifying another drop off location on the Los Altos Hills side of campus is critical. Given the low level of service (LOS D&F) already present at the four study intersections, additional traffic mitigation measures must be considered. Several educational options were identified by the High School Task Force, which met during 2007 and published its report to the PAUSD Board of Education on 12/18/07, that could be considered for traffic mitigation. They are: a. Online learning b. Independent study options c. Late afternoon/evening courses d. Extension of the school day by adding 0 and 8th periods e. Staggered start times for students f. Off-campus course work What these educational options have in common is that they allow students to arrive at campus as needed, but not necessarily at the morning bell, thus may be helpful in mitigating the morning traffic peak. Now is the time for PAUSD and Gunn staff to begin investigation of one or several of these options to meet the needs of the growing Gunn population and its growing traffic demands. For more information, please refer to the PAUSD BOE packet, Discussion Item 1, Recommendations from the High School Task Force, 12/18/07, page3-4. Given the shortcomings in the CEQA document concerning traffic mitigation proposals, the Mitigated Negative Declaration should not be adopted by PAUSD without additional traffic mitigation measures. Thank you for the opportunity to submit comments. If you have any questions, please contact me at 650-856-7480. TRANSPORTATION DIVISION Memorandum Date: November 16, 2009 To: Tom Hodges, Program Director, Palo Alto Unified School District From: Rafael Rius, P.E., Transportation Project Engineer, City of Palo Alto Subject: Palo Alto Unified School District – Transportation Comments on the Gunn High School and Palo Alto High School Master Plan, Initial Studies The following are the City’s comments on the Transportation/Traffic sections (Chapters 15) of the Initial Studies for the Draft Mitigated Negative Declarations (MND) prepared for the Gunn High School and Palo Alto High School Master Plans, dated October 2, 2009 and October 3, 2009, respectively. Impact Analysis: Trip Generation provided is based on the Institute of Transportation Engineers – Trip Generation Manual. Per the ITE, for unique instances or where more detailed information is available, actual count data should be applied. Part of the reason is that the school district does not provide any bus services, and the local public transit is limited to approximately 3 routes during each of the peak periods. Re: Palo Alto HS - PAUSD conducted a traffic analysis in May 2009 which included detailed data collection and projections of traffic. Per the May 2009 study, approximately 134 additional vehicles would drive and park on the campus and 148 additional vehicular drop-offs would occur. Combined, this would result in approximately 430 additional AM peak hour vehicle trips, which is substantially greater than the 138 additional trips presented in Table 7 of the MND. Re: Gunn HS - PAUSD conducted a traffic analysis in May 2009 which included detailed data collection. Per the May 2009 study, approximately 93 additional vehicles would drive and park on the campus and 85 additional drop-offs would occur. Combined, this would result in approximately 263 additional AM peak hour vehicle trips, which is substantially greater than the 82 additional trips presented in Table 6 of the MND. The City of Palo Alto has significance criteria for intersections that already operate at LOS E or F. The impact analysis for the deficient intersections was not quantified using the City’s thresholds of significance, and should be conducted to determine if a November 16, 2009 Page 2 of 3 significant impact would occur. Instead the impact analysis qualitatively states that the proposed project would increase vehicular traffic. By quantifying the level of impact, appropriate levels of mitigation can be identified. Attached are the City’s significance criteria for traffic impact analysis which should be used in evaluating the traffic impacts generated by the project on Palo Alto streets. Proposed Mitigation Measures: Because the estimated increase in traffic is underestimated, the proposed mitigation most likely will need to include more stringent measures aside from incentives or voluntary ride-share programs. Comprehensive carpooling programs at other schools in the area have shown minimal success. Mitigation measures should be identified subsequent to preparation of an updated traffic analysis using the City’s significance criteria. By restricting the amount of parking permits, the measures should include any proposals to minimize the amount of parking on neighborhood streets. A staggered bell schedule for Gunn High School was previously recommended by the PAUSD consulting traffic engineers, as well as City of Palo Alto staff. This should be included as a potential mitigation alternative, since it would be one of the more effective measures. Attachments: City of Palo Alto Significance Criteria for Transportation Impacts ENVIRONMENTAL CRITERIA (SIGNIFICANCE THRESHOLDS) USED BY THE CITY OF PALO ALTO Transportation A traffic impact is considered significant if the project will: • Cause a local (City of Palo Alto) intersection to deteriorate below Level of Service (LOS) D; or • Cause a local intersection already operating at LOS E or F to deteriorate in the average control delay for the critical movements by four seconds or more, and the critical volume/capacity ratio (V/C) value to increase by 0.01 or more; or • Cause a regional intersection to deteriorate from an LOS E or better to LOS F; or • Cause a regional intersection already operating at LOS F to deteriorate in the average control delay for the critical movements to increase by four seconds or more, and the critical V/C value to increase by 0.01 or more; or • Cause queuing impacts based on a comparative analysis between the design queue length and the available queue storage capacity. Queuing impacts include, but are not limited to, spillback queues at project access locations; queues at turn lanes at intersections that block through traffic; queues at lane drops; queues at one intersection that extend back to impact other intersections, and spillback queues on ramps; or • Cause a freeway segment (for each direction of traffic) to operate at LOS F or contribute traffic in excess of 1% of segment capacity to a freeway segment already operating at LOS F; or • Impede the development or function of planned pedestrian or bicycle facilities; or • Impede the operation of a transit system as a result of congestion; or • Create an operational safety hazard; or • Cause any change in traffic that would increase the Traffic Infusion on Residential Environment (TIRE) index by 0.1 or more on a local or collector residential street; or • Result in inadequate on-site parking capacity; or • Result in inadequate emergency access. 1 Lesley Lowe From:Aimee Lopez [alopez@ocmi.com] Sent:Monday, November 02, 2009 9:59 AM To:Lesley Lowe; Cory Barringhaus Subject:FW: Comments on Draft Mitigated Negative Declaration for Gunn HighSchool Master Plan I believe you may have these already. Following are additional comments. Thanks, Aimée -----Original Message----- From: Tom Hodges Sent: Monday, November 02, 2009 8:23 AM To: Aimee Lopez Subject: FW: Comments on Draft Mitigated Negative Declaration for Gunn High School Master Plan To ESA please. T ________________________________________ From: Sue Ma [SMa@waterboards.ca.gov] Sent: Friday, October 30, 2009 3:16 PM To: rsmith@pausd.org; thodges@pausd.org Cc: Joe Teresi; Ken Torke; Phil Bobel; Brian Wines; Dale Bowyer Subject: Comments on Draft Mitigated Negative Declaration for Gunn High School Master Plan Greetings: Water Board staff has reviewed the Draft Mitigated Negative Declaration for the Gunn High School Master Plan project located at 780 Arastradero Road, northeast of the intersection of Arastradero Road and Foothill Expressway in the city of Palo Alto. The proposed project features construction of new buildings and other structures, including two new classroom buildings, a new gymnasium, and a new Performing Arts Center. The subject document identifies water quality as an issue and acknowledges that the project is subject to the New and Redevelopment Requirements (Provision C.3.) in the City of Palo Alto's municipal stormwater permit. Provision C.3. requires that new and redevelopment projects treat stormwater runoff to remove pollutants to the maximum extent practicable and consider/limit changes in the runoff hydrograph. The subject document mentions vegetated swales, detention basins, and landscape infiltration systems as methods to comply with C.3. but does not provide any specific details on the proposed methods being considered for this particular project. These issues need to be identified and addressed early in the planning and design process; stormwater treatment should not be an afterthought once the project is built. Therefore, the subject document should be revised to provide enough detail on the proposed mitigation alternatives so that we can adequately assess the project's compliance with Provision C.3. You should also be aware that a new regional municipal stormwater permit (Water Board Order No. R2-2009-0074) was issued on October 14, 2009, to all municipalities and local agencies in Alameda, Contra Costa, San Mateo, and Santa Clara counties, and the cities of Fairfield, Suisun City, and Vallejo. Provision C.3. of the new permit specifically requires that stormwater treatment be addressed using Low Impact Development techniques, such as infiltration, harvesting and reuse, evapotranspiration, and biotreatment. Please call or email me if you have any questions. Sue Ma Water Resources Control Engineer 2 1515 Clay Street, Suite 1400 Oakland, CA 94612 510-622-2386 FAX 510-622-2460 SMa@waterboards.ca.gov November 19, 2009 FROM: Penny Ellson Attn: Tom Hodges Palo Alto Unified School District 25 Churchill, Building D Palo Alto, CA 94306 The CEQA document points to a higher volume of drop-offs on Miranda (161) than previous years. It is not clear what the reasons for an increase in volume at that location might be. In addition, the County Sheriff, in response to recent traffic safety complaints from VTA, began ticketing people for dropping off students at that location last week. This activity has begun pushing autos from Miranda to the Arastradero entrance. We can’t assume that additional volume can be accommodated elsewhere on the public streets. We request that the CEQA document be revised to include the effects of any resulting diversion of drop-off traffic from Miranda. These revisions should be included in the existing conditions so that mitigations might be studied to address this issue, considering motor vehicle, pedestrian and bicycle safety. At today’s City School Traffic Safety Committee meeting, CPA Transportation Engineer Rafael Rius stated that the city would be open to discussing possible safety improvements to the Miranda area with PAUSD. 1 Comments on the Initial Study and Environmental Checklist for California Environmental Quality Act for the Gunn High School Master Plan dated September 2009 Arthur M. Keller, Gunn Facilities Planning Committee, PTSA Public Transit Coordinator, Gunn parent 1. The reference on page 20 to the Land Use Element of the Palo Alto Comprehensive Plan is erroneous. The chapter is called the Land Use and Community Design element, and it was part of the Palo Alto Comprehensive Plan for 1998-2010 adopted well before 2007. 2. The greenhouse gas analysis on page 24 and noise analysis on page 66 each assume in increase in daily trips of 532, which may be an underestimate. 3. The various references to the Palo Alto Comprehensive Plan Update 1996 should instead refer to the Palo Alto Comprehensive Plan 1998-2010. 4. Table 7 on page 82 states that the AM peak hour delays will remain at LOS F for both Arastradero Road / Miranda Avenue and Arastradero Road / School Driveway. However, no specific measure of critical delay was made other than the vague “> 120”; however the City of Palo Alto’s traffic significance thresholds states, “A significant impact results if the existing LOS is already D or worse at the intersections not included in ‘a’ above and the addition of project traffic causes an increase of one second or more of critical movement delay.”1 It is likely that the expected increase in traffic will increase the critical movement delay by more than one second, and the mitigations proposed are unlikely to reduce this increase to no more than one second. Furthermore, the increase in critical movement delay of 1.8 seconds exceeds the threshold of significance as determined by Palo Alto standards for the Arastradero Road and Donald/Terman intersection (see Table 7, page 82), even though the report implies that this increase is less than significant with mitigations. It is not demonstrated how the increase in critical movement delay would be reduced by mitigations to below one second. 5. Mitigation TRAN-1 regarding setting up a carpool-matching program for students is not realistic. The primary mechanism for such a matching program is through the student directory, which is not released to the students until November and does not geocode the student addresses. There is no quantification for the amount of carpooling currently occurring nor are there quantified goals for the increase in carpooling. No reference is made as to the apportionment of the increase of carpooling between students in carpools driving to Gunn High School versus parents dropping off and picking up carpools. 6. Mitigation TRAN-2 contains measures that are already in practice, and it is unclear the extent to which these measures will “not increase traffic volumes to the high school as the student body increases.” (page 82) 7. Spillover traffic and parking at the adjacent Barron Park neighborhood may be a consequence of the lack of increase in onsite parking spaces. No mitigation measures to address that consequential effect is provided. For example, there may be an increase in student dropoffs by parents on Georgia to avoid the Gunn High Driveway delay. 1 See “TRANSPORTATION SIGNIFICANCE THRESHOLDS—STUDY SESSION AND NEW INTERIM STANDARDS (CONTINUED FROM SEPTEMBER 19, 2002),” dated October 9, 2002, http://www.cityofpaloalto.org/civica/filebank/blobdload.asp?BlobID=7475 2 8. Will the price of student parking permits be increased if demand exceeds supply of permits, as proposed to be limited relative to 2009. In particular, as the number of teachers will be increased with student enrollment, more of the proposed-to-be-fixed parking spaces will have to be allocated to staff, with fewer students parking on campus. Replacing students driving with being dropped off by parents means replacing one-way trips with round trips. More morning round trips means long cycle times for cars exiting Gunn High School, adding to the critical movement delays at the Arastradero Road / Gunn High School intersection. While doing so may be beneficial from a land-use perspective, it is not an effective measure to reduce traffic impacts. 9. Maps are currently provided at the start of the school year illustrating preferred bicycle routes, which includes directing students to access the campus via Georgia and Los Robles rather than Arastradero Road. The data on Figure 12 indicates that this is successful and it is clear what greater success is intended by these measures. 10. The proposal to get students to arrive at Gunn High School before the peak rush through breakfast or by providing study areas is particularly unrealistic. High school students are chronically sleep deprived.2 11. The PTSA bicycle count has exceeded 600 on a warmer day (page 84), a suggested mitigation is to ensure that there is sufficient bike parking. As the enrollment is projected to increase by 21% over current levels, a proportionate increase would mean at least 750 secured bicycle parking spaces. Increased incentives (such as even more than a proportionate increase in bicycle parking) to bicycling would help to “not increase traffic volumes to the high school as the student body increases.” (page 82) 12. Measures have already been taken to increase student use of the VTA 88 bus routes. Another transportation mitigation measure that should be considered is to provide free VTA Eco Passes to all students at Gunn High School as a sticker on their student body card. The cost per student might be less if students at both Gunn High School and Palo Alto High School were included in the program. As demand for VTA bus service increases, PAUSD should provide support for working with the VTA to increase the number of buses provided before and after school and perhaps increase the number of distinct routes from the current three. 13. Another transportation mitigation measure to consider is to increase PAUSD bus service to accommodate demand by the approximately 160 Gunn students from Los Altos Hills and approximately 100 Gunn students from Stanford. 14. The queue of dropoffs (1100 feet in two lanes) is shared with the queue of students parking. This combination queue increases backups, and is not considered in the report. 15. Which staff members are proposed to monitor and direct traffic during peak dropoff/pickup times and how are they to be funded? 16. Another potential traffic mitigation is to have a right turn arrow from Arastradero Road into the Gunn High School driveway, so that inexperienced drivers do not stop when they have a “free” right turn and there are no pedestrians wanting to cross. Including signalized pedestrian crosswalk across the “free” right turn would handle the pedestrian/vehicle conflict. 2 See Laura Brown, “Early start time deprives teenagers of crucial sleep,” the Paly Voice, December 17, 2004, http://voice.paly.net/view_story.php?id=2431 3 17. The increase in AM peak hour trip forecast of 57 more inbound trips and 25 more outbound trips (Table 6, page 81) is contradicted by data elsewhere in the report. On page 84, it states that the number of vehicles dropping off students is expected to increase from 365 to 450, an increase in 85. Thus, one would expect an increase of 85 more inbound and outbound trips just from student dropoffs alone. Considering the limitation in parking, this number is likely to increase as noted in Item 8 above. 18. Current 11th day enrollment for Gunn High School is 1,898 and was 1,907 last year. 3 Table 6 (page 81) cites an existing student population of 1,948 with forecast of 2,259. However, page 5 cites an enrollment (last year) of 1,917. The increased enrollment based on Table 6 is less than 16%, while the actual increase from current levels to 2,300 is over 21%. Such a discrepancy calls into question the remaining figures in the analysis of the Initial Study. 19. The parking requirement stated is “one [parking] space for each four teaching stations.” (page 85). The report computes 92 teachers, but Gunn has 120 classrooms4 and likely even more “teaching stations.” 20. We observe that only increases in the numbers of students walking, bicycling, or riding buses to school, or increases in carpooling decreases traffic. The Initial Study states, “The goal of the TDM program is to not increase traffic volumes to the high school as the student body increases.” Thus, the TDM (Transportation Demand Management Program) must be sufficient with measureable quantified goals so that an additional 400 students must arrive at Gunn High School through alternative means. The number of students walking to school is limited by geography and is unlikely to increase. Specific and measureable mitigations are required to increase bicycling, bus use, and carpooling totaling 400 students. We believe that the report is inadequate because it fails to quantify the amount of critical movement delay in the intersections studied that are at LOS F, fails to consider the significant increase in critical movement delay at Arastradero Road and Donald/Terman that is at LOS D, and fails to identify specific, measurable and effective mitigations that increase bicycling, bus riding, and carpooling along with quantified goals, and fails to analyze whether the proposed mitigations will reduce the increase in critical movement delays to a less than significant level. 3 http://www.paloaltoonline.com/news/show_story.php?id=13854 4 http://www.trulia.com/schools/CA-Palo_Alto/Henry_M_Gunn_High_School/ Correspondence sent via email • These November 18, 2009 TO: Tom Hodges <thodges@pausd.org>, CC: Bart Carey <bcarey@careyvision.com>, Tom Jacoubowsky <tjacoubowsky@pausd.org>, Noreen Likins <nlikins@pausd.org>, Duncan MacMillan <dmcmllan@pacbell.net>, Tracey Stewart <tstewart@folsom.net>, Dear Mr. Hodges: I am writing to forward the statement of the Los Altos Hills Education Committee (EC) and the Los Altos Hills City Council as public comment against the adoption of a Mitigated Negative Declaration under the California Environmental Quality Act (CEQA) for the projects at Henry M. Gunn High School (Gunn), located at 780 Arastradero Road, Palo Alto. This position has been reviewed and approved by the Los Altos Hills City Council. The Committee wishes to raise its concern that the CEQA document is inadequate concerning proposed traffic mitigations at Gunn, specifically that the report ignores approximately 44% of student drop-offs that now occur along Miranda Avenue from its proposed mitigation, TRAN-3. In addition, it appears to the Committee that the situation along Miranda has seriously worsened over the past weeks with the Santa Clara County Sheriff's Department ticketing parents along Miranda for what were previously thought to be permissible drop-offs. It also appears from a meeting between a subcommittee of the EC and the principal and assistant principal of Gunn that sufficient resources do not exist internally at Gunn to proactively deal with the short-term traffic issues along Miranda. We are additionally concerned that any west-side entry mitigations would need to wait until another bond issue if they are not addressed now. There should be an agreement now to task the traffic engineer and architect to propose mitigation recommendations along Miranda, including a possible campus entry point for drop-off purposes. For these reasons, the Los Altos Hills Education Committee and the Los Altos Hills City Council feel the CEQA document is inadequate, should be rejected as defective, and that a Mitigated Negative Declaration should not be adopted until and unless Miranda Avenue traffic issues are addressed as part of the initially-funded phases of improvements at Gunn. Sincerely, Bart Carey Chair, Los Altos Hills Education Committee 26379 Fremont Road Los Altos Hills California 94022 650 / 941-7222 Fax: 650/941-3160 Lesley Lowe From: Aimee Lopez [alopez@ocmi.com] Sent: Thursday, November 19, 2009 4:57 PM To: Cory Barringhaus; Lesley Lowe Cc: 'John Wilson' Subject: FW: Gunn expansion needs a new bell schedule, not earlier start times Page 1 of 2 1/29/2010 Aimée M. Lopez | Project Manager O'Connor Construction Management, Inc. Palo Alto Unified School District 25 Churchill Ave., Bldg. D, Palo Alto, CA94306 650.329.3968 | Fax 650.327.3588 | Cell 925.580.2714 e-mail: ailopez@pausd.org From: Tom Hodges Sent: Wednesday, November 04, 2009 9:40 AM To: Aimee Lopez Subject: FW: Gunn expansion needs a new bell schedule, not earlier start times For ESA Thomas Hodges - Sr. Vice President O’Connor Construction Management, Inc. 7041 Koll Center Parkway, Suite 135 | Pleasanton, CA 94566 925.426.1578 | 925.426.1587 FAX | 650.296.8087 CELL From: Meri Gruber [mailto:meri.gruber@gmail.com] Sent: Monday, November 02, 2009 10:55 PM To: thodges@pausd.org Subject: Gunn expansion needs a new bell schedule, not earlier start times Dear Mr Hodges, I am writing to send you my comments to the Gunn High School Master Plan, Initial Study and Environmental Checklist Form California Environmental Quality Act (CEQA) The traffic mitigation plan on p. 83 suggest getting students to school earlier. This is counter to the well documented research regarding teens and sleep. The teen internal clock shifts and earlier start times forces chronic sleep loss. We continue to operate with the assumption that teens are like adults, that sleep loss is tiring but manageable. However the well researched and documented reality is that the magnitude of the effect of sleep loss on teens is exponentially damaging. Also, the document significantly under estimates the increased traffic. The use of a standard trip rate doesn't reflect local conditions (i.e. no school buses). For example, the present number of morning peak hour auto trips at Gunn is 922. Using the standard trip rate the number would be 514. This is a great opportunity for a staggered bell schedule, not earlier arrival times. Best regards, Meri Gruber -- Meri Gruber cell: 650-269-3570 Page 2 of 2 1/29/2010 Attachment B Approved: November 17, 2009 Regular Meeting October 27, 2009 Page 1 BOARD OF EDUCATION Attachment Consent 4 PALO ALTO UNIFIED SCHOOL DISTRICT Date: November 17, 2009 Complete tape recordings of most Board Meetings are available at 25 Churchill Avenue. Meetings are also available on demand at http://www.communitymediacenter.net/watch/pausd_webcast/PAUSDondemand.html MINUTES FOR REGULAR MEETING OF OCTOBER 27, 2009 Call to Order The Board of Education of Palo Alto Unified School District held a Regular Meeting in the Board Room at 25 Churchill Avenue, Palo Alto, California. Barb Mitchell, President, called the meeting to order at 5:30 p.m. Members present: Ms. Barb Mitchell, President Ms. Barbara Klausner, Vice President Ms. Melissa Baten Caswell Mr. Dana Tom Ms. Camille Townsend Mr. Steve Zhou, Student Board Rep, Gunn High School Mr. Jason Willick, Student Board Rep, Palo Alto High School Staff present: Dr. Kevin Skelly, Superintendent Dr. Linda Common, Assistant Superintendent Mrs. Ginni Davis, Assistant Superintendent Dr. Scott Bowers, Assistant Superintendent Dr. Robert Golton, Co Chief Business Official Mrs. Cathy Mak, Co Chief Business Official Dr. William Garrison, Director Adjourn to Closed Session The Board adjourned to closed session pursuant to Government Code 54957 for Employee Evaluation regarding the Superintendent; pursuant to Government Code 54961 for Liability Claims – Ng vs PAUSD; Flusberg vs PAUSD; Miao vs PAUSD; pursuant to Government Code 54957.6 for Conference with Labor Negotiator Dr. Scott Bowers, regarding PAEA, CSEA, and Non-represented groups; pursuant to Government Code 54957 regarding Employee Discipline / Dismissal / Release; and for Student Discipline in Two Cases. Reconvene in Open Session The Board reconvened in open session at 6:32 p.m. Mitchell announced the board took action, as follows, on three liability claims. MOTION: It was moved by Townsend, seconded by Baten Caswell, and motion carried 5-0 to issue payment in the amount of $436.41 in Ng vs PAUSD. MOTION: It was moved by Townsend, seconded by Baten Caswell, and motion carried 5-0 to issue payment in the amount of $787.09 in Flusberg vs PAUSD. MOTION: It was moved by Townsend, seconded by Baten Caswell, and motion carried 5-0 to reject the claim in Miao vs PAUSD. Approval of Agenda Order MOTION: It was moved by Baten Caswell; seconded by Townsend; and motion carried 5-0 to approve the agenda order. Student Board Representatives Willick, of Palo Alto High School, reported homecoming week is ongoing; a rally was held during advisory and showcased a new Paly fight song; the quarter ended last week; there is online reporting by teachers; and he commented on the impact at Paly from the recent suicide. Zhou, of Gunn High School, reported on girls’ water polo; homecoming was the previous week and students worked around the weather; student government was reviewing issues from the event; discussed the recent suicide and student-led promotion of communication among students and adults Staff and Student Successes Skelly noted the 120 commended high school students for the National Merit Scholarship included in the packet. He also commented on violin performances of Alexi Kenney. Skelly commented on the continuing work on the issue of suicide, impressed with how students at Gunn are working with staff. Staff is attending meetings on the state budget, working on reductions with the leadership team remaining faithful to the values, have reached tentative agreements with the bargaining units and hope to bring agreements to the Board on Approved: November 17, 2009 Regular Meeting October 27, 2009 Page 2 MINUTES FOR REGULAR MEETING OF OCTOBER 27, 2009 November 10, 2009, action for on November 17; are pleased to work with Triona Gogarty (PAEA) and Jeremy Sakakihara (CSEA). Skelly spoke of his cycling to “Scaremeadow” and other schools with Townsend and Klausner. Staff is researching the achievement gap question raised at the previous meeting and will be providing information on November 10, 2009. Skelly then introduced Ann Durkin, new director of technology, who comes to the district from HP. Durkin noted she was thrilled to be part of the district and that she is looking forward to meeting everyone. Golton showed phots from walk/cycle day at the various schools, the Terman science fair, and Nixon tree planting. The construction update included the Citizens’ Oversight Committee meeting, the El Camino fields at Paly, the Gunn pool and dedication, and the Gunn industrial arts building. Consent Calendar MOTION: It was moved by Tom, seconded by Townsend, and motion carried 5-0 to approve the consent calendar including certificated and classified personnel actions, warrants of September 2009, the Uniform Complaint (Williams Settlement and Valenzuela/CAHSEE Lawsuit Settlement) Quarterly Report for July 1-September 30, 2009, Addendums No. 3, 4, and 5 with Gelfand Partners, and the renewal of Student Teaching/Intern Agreements. The minutes for October 13, 2009, were pulled for separate discussion. Klausner requested the minutes be changed to pull the phrase “in the not yet proficient category” from the eighth bullet on page two, feeling the term is confusing. MOTION: It was moved by Klausner; seconded by Townsend, and motion carried 5-0 to approve the revised minutes with the correction as noted above. Public Hearing Notice of Intent to Adopt a Mitigated Negative and Declaration Draft Initial Study/Mitigated Negative Declaration for 780 Arastradero Road, Palo Alto, CA (Gunn High School) Mitchell opened the public hearing. Duncan MacMillan spoke about the traffic data presented in the report, referring to page 80, noting it only addresses half the traffic issues. He felt miranda needs to be addressed now or it won’t be done for years. He asked for this priority move up on the list. Penny Ellson spoke about mitigations and the need to address car trips, noting we can’t expect load shift by continuing what is already being done. She would like to look at other trip reductions. Bike parking spaces are needed; car parking is probably underestimated as well. She referred the Board and staff to the document she sent. Mitchell closed the public hearing. Public Hearing Notice of Intent to Adopt a Mitigated Negative and Declaration Draft Initial Study/Mitigated Negative Declaration for 50 Embarcadero Road, Palo Alto, CA (Palo Alto High School) Mitchell opened the public hearing. Penny Ellson indicated the same issues apply to Paly. The left turn pocket into the school needs to be reconsidered, same issues for bike parking, car parking, and supervision. Mitchell closed the public hearing. Information Strategic Plan Goals and Accountability Results Skelly indicated this is the second of two reports. Common thanked Garrison for gathering the data on high schools. The PowerPoint presentation reviewed: • Purpose of the report • Strategic Plan Goals 1 and 2 • The UC/CSU a-g course requirements • Comparisons of Selected CA High Schools – percentage of students completing the a-g courses • Number of students and percentage of those meeting a-g requirements for 2008 and 2009 • Number of African American and Hispanics students and percentage meeting a-g requirements for 2008 and 2009 • Number of students and percentage of those missing 1 or 2 a-g course requirements • College Board SAT Exam mean scores and participation rates for 2006, 2007, 2008, and 2009 for Critical Reading, Math, and Writing • SAT comparison for class of 2009 vs California and national for Critical Reading, Math, and Writing • 2008 SAT Rankings: 10 Top CA High Schools for Critical Reading, Math, and Writing (including class of 2009 for Gunn and Paly) • National Merit Students commended or semifinalists for Gunn and Paly 2008, 2009, and 2010 • AP Exams Taken, May 2009 Results for both high schools • AP Exam Scores from May 2007, 2008, and 2009 • 2008 AP Rankings comparisons for selected California High Schools • California Standards Tests proficient and advanced for science (biology, chemistry, physics) for 2007, 2008, and 2009 • California Standards Tests proficient and advanced for history/social science (social science, world history, and US history) for 2007, 2008, and 2009 Approved: November 17, 2009 Regular Meeting October 27, 2009 Page 3 MINUTES FOR REGULAR MEETING OF OCTOBER 27, 2009 • California Standards Tests proficient and advanced for mathematics (algebra I, geometry, algebra II) for 2007, 2008, 2009) • CAHSEE – students fulfilling all requirements for graduation except the CAHSEE: 2006 – 0; 2007 – 1 (who has since graduated); 2008 – 0; and 2009 – 1 Mitchell congratulated students, parents, and teachers for these accomplishments. Board member comments included appreciation for progress on a-g requirements; noted the difficulty of the comparisons in light of the recent suicide; noted test scores are one piece of the puzzle and perhaps have an outsized significance; asked about classification of ethnicity and the recent change; asked about percent of students taking at least one AP test; inquired whether students are encouraged to take AP classes; asked if trends for AP score percentages are the same for individual classes; noted scores are different depending on the class, asked if AP classes taken are outside of PAUSD; asked what can be done to monitor a-g requirements for African American and Hispanic students; asked what is being done to scaffold these students so they can do better; noted the numbers are phenomenal, students need to realize how above average they are; would like a visual for students so they can understand how they look compared to the state and nation; asked how well the District is doing with data management; would like to extrapolate how many are taking at least one AP class; noted students are incredibly accomplished; commented on the complex issue of overstretching and balance while still encouraging students to take AP classes—need to address individual students; asked if student’s AP scores have been correlated with student’s grades in the classroom; asked if the data is broken out for gender; student reps asked what is being done to help the students not passing CAHSEE; asked about Newsweek’s poll; asked about students not meeting a-g requirements and whether teacher advisors could help keep them on track; would like to ask principals about course offerings and what input is coming from students; and asked about students taking a-g courses through outside sources. Information Update on Project to Install Bleachers at Palo Alto High School Skelly indicated this item was discussed at the October 13, 2009, regular meeting. Golton said staff is going back to the drawing board based on that discussion and further discussion with site staff. Future meetings have been scheduled and will be publicized for the public. This will include the landscaping plan for the Paly campus. The bleacher plans have been pulled from review by DSA. The plan is for replacement in summer 2011. The visitors’ bleachers will be addressed this summer. Public Comment Catherine Martineau from Canopy offered help in care and enhancement of trees. She spoke of her conversations with staff in regard to the bleacher project. Canopy did not approve the approach presented. Sharon Kelly, also from Canopy, explained her role in recent advice offered to the District. This had a positive effect at Gunn. She would like to provide more input for the El Camino fields and bleacher projects at Paly. Board members comments included ongoing community membership; asked for clarification of which items will be discussed by the landscape committee; thanked staff for listening to the concerns and for looking for a compromise to address everyone’s needs; asked for clarification of visiting bleacher timeline; and asked for 3D renderings of proposals. Skelly thanked Jacqueline McEvoy, principal, and noted staff will look more comprehensively at the plan. Open Forum Public Comment No one asked to address the Board. Action Springboard to Kindergarten This item was discussed at the October 13, 2009, regular meetings. Board comments included the value of networking; appreciated the generosity of the donors; noted it represents a leveling up for kindergartners and assessment of results; and noted this is multi prong approach to the achievement gap. Motion: It was moved by Tom; seconded by Baten Caswell; and motion carried 5-0 to approve the Springboard to Kindergarten three-year pilot program. Discussion Summary of the 2009 Summer School Program and Proposal for the 2010 Program Davis commented on what the summer school programs provide for students. Staff would like to expand the secondary program for the high school so students can work on a-g courses. Barbara Lancon, coordinator, thanked all who worked so hard over the summer on these classes. She outlined the sites, dates, and tuition. She noted the state continues to cut funding, so an increase is being requested as well as a sliding scale fees for intervention programs. Pat Dawson, professional development, spoke about the 2009 literacy program and progress of students. Melissa Hauer spoke about the math program. Board member comments included asking about the intervention program and how parents will be informed about financial aid; asked if financial aid in the budget; asked about varying numbers from report to budget; asked about matched scores being tracked in the data systems; noted this would show the lasting impact and how we are doing in achieving the strategic plan goals; asked about math pre and post-tests; asked if the Barron Park college bound program being used in intervention; support tracking the long term results; asked about state restrictions and how they are being addressed; asked if intervention programs would be the same; noted it was good to see high school courses, being addressed; asked if there will be financial aid requests; asked for the dates for longer high school classes; asked if principals see a difference in their Approved: November 17, 2009 Regular Meeting October 27, 2009 Page 4 MINUTES FOR REGULAR MEETING OF OCTOBER 27, 2009 students in the fall and how it is discussed; would like to see principals be able to discuss that data; asked if expenses came in under the budgeted amount; expressed comfort with the proposal to charge a fee, but offer assistance; noted the significance of tying in CST scores into the assessment picture; asked if other assessments can be developed through summer school; would like to hear how CST data can be used starting with this past summer and perhaps the prior year’s summer school testing data; suggested summer school might need to be longer; looked forward to supporting the proposal at the next meeting; appreciated the role the program plays; supported the comments about using the data to understand the impact in attaining goals; would like to see whether it could be expanded; and noted principals spoke well of these resources. Discussion Notice of Intent to Adopt a Mitigated Negative and Declaration Draft Initial Study/Mitigated Negative Declaration for 780 Arastradero Road, Palo Alto, CA (Gunn High School) Golton noted there is an item for each high school to meet the California Environmental Quality Act (CEQA). The items will not return to the board until later in the year after input has been received. Hodges noted this is time for the Board to add their comments. All comments received will be compiled and possible amendments will be considered. Corey Barringhouse, ESA Associates, noted they looked at both of the master plans and the impact of their implementation to find impacts and how best to mitigate them to make them less than significant. He noted the 30-day public review is in progress. All comments will be responded to. Mitigation measures will be monitored. Board members comments included having the Sustainable Schools Committee review the information; noted the high speed rail could impact the plan and asked how does the District will react; asked about eminent domain; asked whether staff have Ms. Ellson’s letter; noted support for requests of Canopy; asked if oral comments are included; and asked whether there will be cost information about mitigation costs in the final report. Discussion Notice of Intent to Adopt a Mitigated Negative and Declaration Draft Initial Study/Mitigated Negative Declaration for 50 Embarcadero Road, Palo Alto, CA (Palo Alto High School) Public Comment Kirsten Essenmacher felt there was insufficient information about the public hearing and asked for two additional weeks for comments. She expressed concern about the footprint of buildings vs landscapes. Board members comments included a question about noticing practices and looking for multiple ways to send the information outbound; and suggested the extension be advertised. Discussion Award of Bid for the Purchase of Smartboards Mak noted that an excess of $76,700 in orders for Smartboards have been received. Bid results produced one bidder. The bid is consistent with past work done by this vendor. Board member comments included asking why there was only one bidder. It was agreed to bring the item back on consent. Action Memorandum of Understanding (MOU) Among Basic Aid School Districts in San Mateo and Santa Clara Counties Skelly noted the Board received information on costs. Board member comments included asking about those costs; would like numbers included in future requests to reconsider if the costs go higher; noted this was not an annual MOU, but can be canceled on 30 days notice. MOTION: It was moved by Klausner, seconded by Townsend, and motion carried 5-0 to approve the Memorandum of Understanding Among Basic Aid School Districts in San Mateo and Santa Clara Counties. Action Stipulated Expulsions (Two Cases) MOTION: It was moved by Baten Caswell; seconded by Tom, and motion carried 5-0 to ratify the recommendation for stipulated suspended expulsion for the remainder of the 2009-10 school year for student 01-0910, and that the Terms of Expulsion be fully implemented MOTION: It was moved by Baten Caswell; seconded by Tom, and motion carried 5-0 to ratify the recommendation for stipulated suspended expulsion for the remainder of the 2009-10 school year for student 02-0910, and that the Terms of Expulsion be fully implemented. Board Members’ Reports Townsend noted the City-School Liaison meeting would cover student mental health, the library bond, and technology at City and District libraries. Baten Caswell commended students and staff at Terman for their recent science fair. Closed Session The Board adjourned to closed session at 9:55 p.m. to complete business from earlier in the evening as noted above. Adjournment The Board reconvened in open session at 11:30 p.m. Mitchell announced the Board took no action. The meeting was adjourned at 11:30 p.m. ________________________________ Secretary to the Board