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Planning & Design Meetings CEQA Mitigated Negative Declaration 2/16/2010 - MinutesPalo Alto High School Master Plan 1 ESA / 209002 Initial Study September 2009 PALO ALTO HIGH SCHOOL MASTER PLAN Initial Study and Environmental Checklist Form California Environmental Quality Act (CEQA) 1. Project Title: Palo Alto 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: 50 Embarcadero Road Palo Alto, CA 94301 5. Santa Clara County Assessor’s Parcel Numbers: 008-02-034 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 Palo Alto 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 east and southeast, Stanford University on the west, and a commercial/retail shopping center on the north. 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 California Department of Transportation (Caltrans) for utilities tie-in to El Camino Real (State Route 82) and Initial Study Palo Alto High School Master Plan 3 ESA / 209002 Initial Study September 2009 Project Description Background 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. 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 District enrollment for the 2008/2009 school year was approximately 11,430 students. Palo Alto High School (Paly), located at 50 Embarcadero Road in Palo Alto, has an existing student capacity of 1,950. Enrollment at Paly has steadily increased over the last ten years from 1,489 students in the 1998/1999 school year to 1,772 for the current (2008/2009) school year. The school employs approximately 116 certified faculty and administrative staff. The projected capacity of Paly at completion of proposed improvements in 2018 is 2,300 students, an increase of approximately 23 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 to 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 an 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 impacts, 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. A high performance school is energy and resource efficient as well as healthy, comfortable, well lit, and containing the amenities for a quality education. ; ; ; ; ; ;; ; ; ; ; ; ; ; ; ; ;Palo Alto HS Gunn HS ARASTRADERORD ALPINERDFOOTHILLEXPY USHIGH WAY101 JUNIPEROSERRABLVDSANDHILLRD PAGEMILL RDMIDDLEFIELDRD ALMAST SAN ANTONIORD EL CAMINO REAL EMBARCADERORD LOUISRD EMEADOWDR COWPERST ECHARLESTONRD OR EGON EXPY COLORADO AVE LOMAVERDEAVEUNIVERSITYAVEWILLOW RDOhlone Hoover Terman MS JLS MS Barron Park Nixon Hays Palo Verde Briones Duveneck Escondido El Carmelo Addison I280 OAKCREEKDR HANOVERST LACRESTADRALTARD MIRANDAAVE JEEPTRL EMEADOWCIR FABIAN WAYWELCHRDWALTERHAYSDR COYOTEHILLRD ESPERANZADR EBAYSHORERD HILLVIEW AVE USHIGHWAY101 WBAYSHORERD PORTERDR COUNTRYWAY KENNETHDR LASUENMAL ALPINERD PETERCOUTTSRD ALEXISDR ELENARD PETERCOUTTSCIR CHIMALUSDR JUNIPEROSERRABLVD ARASTRADERORD LOSTRANCOSWOODSRD MOONLN DEERCREEKRD ROBLELADERARD HANSENWAY SANDHILLRD EDGERTONRD LAURELGLENDR VIA VEN TANA 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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 Palo Alto High School Master Plan . 209002 Figure 1 High School Attendance Boundaries, Palo Alto Unified School District SOURCE: Lapkoff & Gobalet Demographic Research, Inc. Initial Study Palo Alto 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 Palo Alto 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 Paly was originally constructed in 1918 on an approximately 44-acre site (the project site) southeast of the intersection of State Route 82 and Embarcadero Road (see Figure 2). The campus is owned and occupied by the PAUSD, but the site has a reversionary clause to Stanford University on 26 acres. Adjacent land uses include residential areas to the east and southeast, Stanford University to the west, and the Town and Country Village shopping center to the north. The Paly campus consists of 17 buildings constructed between 1918 and 2004. The original construction in 1918 included the Administration and Classroom Building and the Auditorium Building (also known as the “Haymarket Theater”). Much of the original administration/classroom building was demolished in 1972, leaving the two-story portion referred to as the “Tower Building.” In 1928, the original Boys’ Gymnasium was constructed; it was expanded in 1946 to provide locker and shower facilities and staff offices. The construction of the Industrial Arts Building was completed in 1945 and expanded to include an electronics classroom in 1955. In 1960, the Science Classroom Building was constructed. The addition of the Girls’ Gymnasium and the swimming pool were completed in 1969. In 1968, the Administration Building, Auditorium, and the Boys’ Gymnasium were extensively renovated as part of seismic retrofitting. The majority of the other buildings on campus were constructed in the early 1970s. These include the following structures: Fine and Performing Arts Building, English Building, Lecture Center, Social Studies Building, Foreign Language Building, Math and Science Technology Building, and Resource Materials Center. These are single-story rectangular or square buildings with hipped tiled roofs and wood siding. The roof structure of these buildings extends over a walkway, which surrounds the buildings allowing covered exterior access to most of the classrooms, or exterior access to the interior classrooms. During the Building for Excellence program the majority of these buildings were modernized with the exception of the Library Building and the Fine Arts Building. 82 PAGE MILL RDARASTRADERO RDEL C A M I N O R E A L FOO TH IL L SAN ANTOPAGE MILL RDCHAR L E S T O N R D MI D D L E F I E L D RD AL M A S T EMBARCA D E R O R DUNIVERSITY AVWILLOW RDPALO ALTO MOU VI MOU VI EAST PALO ALTO Stanford SAN FRANCISCO BAY PROJECT LOCATION 101 Palo Alto 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 Palo Alto High School Master Plan 7 ESA / 209002 Initial Study September 2009 Other additions to the campus include a Student Activities Center and Woodshop in 1975 and a new Science Building in 2004. In 1998, following the Loma Prieta Earthquake, the Campanile of the Tower Building was separated from the structure and strengthened. The campus also includes approximately 17 relocatable classrooms. Recreational facilities are located primarily on the southern portion of the campus and include a football field and track, baseball and softball diamonds, swimming pool, athletic field, seven tennis courts, and four basketball courts. The PAUSD Administrative Office and Corporation Yard are also located on the project site. The Corporation Yard is located just north of the football field and the District Office occupies the southwestern corner of the campus. The District Office is a single- story structure, built in 1955 and expanded in 1960, and has its own parking area that is separate from the high school. Parking areas surround the school buildings on the northern perimeter of campus off of Embarcadero Road. Additional parking is located on the south-central area of the campus between the football field and baseball/softball diamonds with access via Churchill Avenue. Approximately 555 parking spaces are available, not including 100 spaces at the District Office. The campus is served by three access points: Embarcadero Road on the north, El Camino Real on the west, and Churchill Avenue on the south. The Caltrain railroad track is located on the east side of campus, which prevents access to the campus from this direction. 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; 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 8. Improvements to the athletic field adjacent to El Camino Real (a non-Measure A project) is underway and scheduled to be completed in January 2010. 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; improvement to comply with the Americans with Disabilities Act Initial Study Palo Alto High School Master Plan 8 ESA / 209002 Initial Study September 2009 (ADA) and California Title 24 requirements; and exterior improvements to walls, doors, and windows. Initial Study Palo Alto 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: Football Stadium Bleachers Replace existing bleachers Summer 2010 1b: Multi-Use Fields Replace existing baseball and softball fields and facilities May 2010 – Feb 2011 Group 2 2a: Classroom Building New two-story, 27-classroom building 2011 – 2012 2b: Media Arts Center New building for media arts 2c: Utility & Infrastructure Miscellaneous utility improvements, including drainage and Central Plant Group 3 3a: Theater New 600-seat theater 2012 – 2014 3b: Theater Parking Reconfiguration of parking area 3c: Library Renovation of existing library 3d: Lecture Hall (Building 300A) Conversion of building into 150-seat lecture hall 3e: Weight Room / Fitness Center New building to connect existing gym to future 2nd gym Group 4 4a: Career Tech Building New classroom building to replace Building 900 2014 – 2016 4b: Buildings 100, 300 & 700 Renovation of existing buildings 4c: Tower Admin. Bldg- Phase 1 Renovation of existing building, including accessibility 4d: Science Building Convert existing office space into science lab Group 5 5a: Tower Admin. Bldg- Phase 2 Renovation of existing building To be determined 5b: Haymarket Theater Renovation of existing building 5c: Gymnasium New gymnasium to replace existing small gym 5d: Gymnasium (Existing) Renovation of existing large gym Group 6 6a: Student Center Renovation of existing building To be determined 6b: Quad Upgrade and enhance existing quad 6c: Utility & Infrastructure Miscellaneous building interior improvements 6d: Embarcadero / El Camino Access & Parking Reconfiguration of access and parking areas 6e: Churchill Ave. Access & Parking Reconfiguration of access and parking areas 6f: Site Improvements Miscellaneous landscaping and pedestrian improvements SOURCE: PAUSD, 2009 Palo Alto High School Master Plan . 209002Figure 3Palo Alto High School Master Plan, Group 1 ProjectsSOURCE: Deems Lewis McKinley Palo Alto High School Master Plan . 209002Figure 4Palo Alto High School Master Plan, Group 2 ProjectsSOURCE: Deems Lewis McKinley Palo Alto High School Master Plan . 209002Figure 5Palo Alto High School Master Plan, Group 3 ProjectsSOURCE: Deems Lewis McKinley Palo Alto High School Master Plan . 209002Figure 6Palo Alto High School Master Plan, Group 4 ProjectsSOURCE: Deems Lewis McKinley Palo Alto High School Master Plan . 209002Figure 7Palo Alto High School Master Plan, Group 5 ProjectsSOURCE: Deems Lewis McKinley Palo Alto High School Master Plan . 209002Figure 8Palo Alto High School Master Plan, Group 6 ProjectsSOURCE: Deems Lewis McKinley Initial Study Palo Alto High School Master Plan 16 ESA / 209002 Initial Study September 2009 Group 1 Group 1 projects focus on improvements to athletic fields on the southern portion of the campus. Bleachers on the home side (west) of the football stadium would be replaced with a new approximately 1,400-seat bleacher section. A new handicapped lift and press box would also be included in this project. The multi-use field adjacent to the District Office would be redesigned and upgraded with new baseball/softball dugouts, batting cages, and scoreboards. Group 2 Two new buildings would be constructed during this phase: a two-story, 27-room Classroom Building and a two-story Media Arts Center. The Classroom Building would include additional space for offices, conference rooms, and restrooms. Nine relocatable classrooms would be moved to the Quad and also adjacent to the pool to make room for the new Classroom Building. Other relocatables currently located where the Media Arts Center is proposed would be removed upon completion of the Classroom Building. The remaining relocatables would be removed at buildout of this phase. Other improvements during Group 2 would involve various infrastructure and utilities upgrades such as drainage and central plant facilities. Group 3 A new 600-seat theater with support facilities is proposed under Group 3; the theater would be located just north of Building 100 and adjacent to Embarcadero Road. This site is currently used for parking; therefore, construction of the theater would necessitate alterations to the parking lot and a new alignment from Embarcadero Road. Other improvements scheduled during this phase include renovation of the existing Library with a new front entrance and interior upgrades and conversion of the existing Building 300A into a 150-seat lecture hall. Another new building, a Weight Room/Fitness Center would be constructed during Group 3. This structure would connect the existing Gymnasium to a proposed future gym (proposed under Group 5). Group 4 (Unfunded)3 The existing Building 900 would be demolished as part of Group 4 projects. This building would be replaced with a new Career Tech Building featuring high bay flexible space, home economics, robotics, auto shop, classrooms, and will centralize custodial space. Three existing buildings would be renovated under this phase (Buildings 100, 300, and 700) to accommodate special education, world languages, and English. Renovations to the Tower Building would also occur, and would likely include installation of an elevator, upgraded restrooms, new windows, and repair of the building’s heating system. In addition, office space in the existing Science Building would be converted into a new science lab. 3 Design of specific projects listed in Groups 4, 5 and 6 is currently unfunded. Initial Study Palo Alto High School Master Plan 17 ESA / 209002 Initial Study September 2009 Group 5 (Unfunded) Additional improvements to the Tower Building would continue during this phase. Proposed upgrades include seismic retrofit as well as new space for offices and conference rooms. The Haymarket Theater would also be renovated as a part of Group 5 improvements, and would include seismic retrofitting and accessibility improvements. One new building is proposed for construction, consisting of a new gymnasium to replace the existing small gym. This new gym would become Paly’s primary competition facility with a bleacher capacity of approximately 1,800 to 2,000; the new gymnasium would also include offices and team rooms. The existing gym would be upgraded with accessibility improvements and would also be used as a secondary competition facility. Group 6 (Unfunded) The last phase would feature expansion of the Student Center and would include a stage for large gatherings and other events. The adjacent Quad would be enhanced to create an improved pedestrian environment with new landscaping, furnishings, and other features. Access to the campus from both Embarcadero Road and Churchill Avenue would be improved as a part of Group 6 improvements. Improvements would reconfigure parking areas to maximize available space and redesign bicycle and pedestrian pathways. Additional changes under Group 6 would include other landscape upgrades and modernization of existing buildings that were not improved during other phases of the Master Plan. 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, Palo Alto High School Master Plan, 2009. Initial Study Palo Alto High School Master Plan 18 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-c) Less than Significant. Paly is located on the block bounded by Embarcadero Road to the north, El Camino Real to the west, Churchill Avenue to the south, and Alma Street / Caltrain railroad tracks to the east. None of these roadways 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). However, Embarcadero Road is considered to be a scenic route by the City of Palo Alto and the entire length of El Camino Real between San Diego and San Francisco, including the portion through Palo Alto, is considered a State Historic Landmark (City of Palo Alto, 2007). In addition, while not formally designated as historic resources, the Tower Building (administrative offices) and the Haymarket Theater are considered historic buildings for the purpose of this CEQA analysis (see Checklist Item 5, Cultural Resources). The perimeter of Palo Alto High School’s campus is heavily lined by mature trees. School buildings are mostly concentrated toward the middle of the site while ball fields and parking lots dominate the periphery. Like most academic campuses, buildings on Paly’s campus vary in style, massing, and height—generally ranging from between one and two stories—but they are united by a common color scheme that links most of the buildings and consists of beige stucco siding and red tile roofs. However, due to the number of trees that line the campus along El Camino Real and Embarcadero Road and substantial building setbacks from the surrounding roadways, views of the buildings on campus are intermittent or obscured. Currently, the closest buildings to Embarcadero Road on the campus are set back approximately 185 feet from the roadway. The buildings along the Embarcadero frontage consist of relocatable classrooms and permanent classroom buildings. The relocatable classrooms are small mobile units with flat roofs and brown exteriors (see Figures 9 through 11 for existing views of the campus). These buildings are Initial Study Palo Alto High School Master Plan 19 ESA / 209002 Initial Study September 2009 not prominently visible from Embarcadero given the minimal massing and muted color of the structures and due to Palo Alto High School Master Plan . 209002 Figure 9 Existing Views of Palo Alto High School Campus SOURCE: ESA Relocatable and permanent classroom buildings along Embarcadero Road View of Tower Building and Haymarket Theater from Embarcadero looking south Palo Alto High School Master Plan . 209002 Figure 10 Existing Views of Palo Alto High School Campus SOURCE: ESA View of campus from Churchill Avenue and El Camino Real looking north View of Tower Building from El Camino Real looking east Palo Alto High School Master Plan . 209002 Figure 11 Existing Views of Palo Alto High School Campus SOURCE: ESA View of campus from corner of Embarcadero Road and El Camino Real looking southeast View of campus from corner of Embarcadero Road and El Camino Real looking east Initial Study Palo Alto High School Master Plan 23 ESA / 209002 Initial Study September 2009 the trees that are located between the structures and the road. The permanent classroom buildings consist of one-story structures with reddish-brown hipped gable roofs. These buildings are also painted brown and are surrounded by colonnades with off-white columns. While two of these permanent classroom buildings are visible from Embarcadero Road, they also maintain a relatively low profile due to modest massing and use of the muted color scheme. The Tower Building and Haymarket Theater are the most prominent visual features of the campus. The two-story Tower Building and Haymarket Theater exteriors are of the Spanish Colonial Revival style with red-tiled gabled roofs and beige stucco siding. The buildings contain various architectural embellishments including rounded-arched doorways and windows, and terra cotta arches on the facades. The bell tower on the Tower Building is visible from multiple viewpoints surrounding the campus. The buildings are set back considerably from the roadways. Haymarket Theater faces Embarcadero, but is setback approximately 400 feet. Views of Haymarket Theater from Embarcadero are intermittent due to this setback and the intervening trees. The Theater is not visible from El Camino Real because it sits behind the Tower Building. However, the Tower Building, which faces El Camino Real and is setback approximately 185 feet from the road, is highly visible from both El Camino Real and Embarcadero and serves as a defining feature of the campus. Other components of the campus that front El Camino Real include a multi-use field (El Camino Field, which is currently under construction and scheduled for completion by November 2010), tennis courts, and the district offices. The district office building is located at the corner of El Camino Real and Churchill Avenue. These buildings are fairly nondescript, single-story structures with flat roofs and beige stucco siding. They are only intermittently visible from the adjacent roadways due to the trees along the perimeter of the campus. Views of the campus from Churchill Avenue are dominated by sports fields in the foreground with one- and two-story buildings in the background. Under the proposed Master Plan, there would be several new buildings constructed on Paly’s campus. In keeping with the existing development pattern, new buildings would be concentrated toward the center of the campus with deep setbacks from the roadways. Specifically, a two-story Media Arts Center and a 600-seat theater would be constructed that would likely be visible from Embarcadero Road. The Media Arts Center would replace the group of single-story, small-scale relocatable classrooms that are located in the northern portion of the campus with a two-story structure. The theater would introduce a new two-story structure on a portion of the site that is currently undeveloped (see Figures 3 through 8 in the Project Description). Both of these buildings would be setback from Embarcadero by at least 70 feet and would be designed in a manner that would be compatible with the current architectural styles of the campus. Initial Study Palo Alto High School Master Plan 24 ESA / 209002 Initial Study September 2009 In addition, the student center would include a one-story addition, and an existing girls’ gymnasium would be replaced by a new gymnasium that could potentially be visible from El Camino Real. However, the student center addition would sit behind El Camino Field and would be set back approximately 285 feet from El Camino Real. The new gymnasium, which would be a two-story structure, would be located behind the tennis courts and would be set back approximately 245 feet from El Camino Real. Again, these buildings would be constructed in a style that would complement the rest of the buildings on campus. The remaining improvements that would occur under the Master Plan would be minimally visible from public viewpoints. Except for the replacement of the bleachers at the football field, there would be no new development on campus near Churchill Avenue. Landscaping changes, including the removal of some of the trees located on campus, would occur under the Master Plan and could result in visual changes to the campus (see Section 4, Biological Resources). However, the trees lining the campus would remain largely intact and views of the high school would continue to be partially obscured by the mature perimeter trees. Overall, the improvements that would occur under the Master Plan would result in minimal visual change along El Camino Real or Embarcadero Road. In addition, views of the campus from viewpoints along El Camino Real or Embarcadero would not be adversely affected. Views of the Tower Building from El Camino Real or of the Tower Building or Haymarket Theater from Embarcadero would not be blocked by any new development and would not be affected by changes that would occur under the Master Plan. As noted above, new development would be designed in compatible styles with the existing campus architecture. Thus, impacts of the Master Plan related to scenic resources (including scenic highways) or the visual character of the site and its surrounding would be less than significant. d) Less than Significant. New buildings developed under the Master Plan would include fixed exterior lighting attached to the building in order to promote safety. The campus is located in an urban environment that has existing sources of light and glare associated with nearby land uses. Adjacent homes to the south of the campus cast light from windows or from outdoor security lighting. Commercial uses to the north cast light from signage, parking lots and buildings. Stanford University, which is west of Paly, occasionally casts light from the ball fields that are located along El Camino Real. In addition, local roadways surrounding the high school provide street lighting and are also sources of light and glare. Ambient light generated by buildings that could be developed or improved under the Master Plan would be minimized on surrounding uses due to screening nature of the trees. Lighting on proposed buildings would be focused so as to illuminate a specific area and avoid spillover onto adjacent properties, particularly residential uses, to the extent possible. Overall, the project would result in less than significant light or glare impacts. Initial Study Palo Alto High School Master Plan 25 ESA / 209002 Initial Study September 2009 Sources City of Palo Alto, Palo Alto Comprehensive Plan, Land Use Element, adopted July 17, 2007. California Department of Transportation (Caltrans), California Scenic Highway Mapping System website, http://www.dot.ca.gov/hq/LandArch/scenic_highways/index.htm, accessed July 21, 2009. Initial Study Palo Alto High School Master Plan 26 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 Palo Alto High School Master Plan 27 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, in 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 Initial Study Palo Alto High School Master Plan 28 ESA / 209002 Initial Study September 2009 with the plan. This 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 the Group 1 improvements to the athletic fields on the southern portion of the campus. Other project elements would disturb much smaller areas of earth and have fewer construction impacts to localized PM-10 and PM-2.5 concentrations. The multi-use field at the southern end of campus is approximately 4.8 acres. Because construction grading would generate localized increased concentrations of PM-10 and PM-2.5 in an area designated as non-attainment for Initial Study Palo Alto High School Master Plan 29 ESA / 209002 Initial Study September 2009 these pollutants, without appropriate dust mitigation, the impact would be significant. Mitigation Measure AIR-1: During future construction, PAUSD shall require the construction contractor(s) to implement BAAQMD’s “basic” and “enhanced” dust control procedures required for the multi-use field at the southern end of campus which is greater than four acres in area. These procedures would be required in addition to the “basic” dust control program, which is required for all construction sites and which would mitigate the potential impact to a less than significant level. Elements of the “basic” and “enhanced” 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. Enhanced Control Measures • Hydroseed or apply (non-toxic) soil stabilizers to inactive construction areas (previously graded areas inactive for ten days or more). • Enclose, cover, water twice daily or apply (non-toxic) soil binders to exposed stockpiles (dirt, sand, etc.). • Limit traffic speeds on unpaved roads to 15 miles per hour (mph). • Replant vegetation in disturbed areas as quickly as possible. Initial Study Palo Alto High School Master Plan 30 ESA / 209002 Initial Study September 2009 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. Operational Emissions 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 emits ozone precursors, but indicate that such emissions are included in the emissions 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. 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 886 net daily vehicle trips. Increased vehicle trips would lead to a small increase in ROG (approximately 3.9 pounds per day), NOx (approximately 3.7 pounds per day) and PM-10 (approximately 11.5 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 0.08 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 Measure AIR-1, 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. Initial Study Palo Alto High School Master Plan 31 ESA / 209002 Initial Study September 2009 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 sensitive receptors, in an area established with existing scholastic uses 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 sources facilities of toxic air contaminant emissions within one-half mile of the project site is Town & County Cleaners which would not be expected to represent a threat to the existing school land use or additional students under the Master Plan as they have changed to their processes to avoid the use of perchlorethylene solvents since publication of the last BAAQMD toxic report (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 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). Initial Study Palo Alto High School Master Plan 32 ESA / 209002 Initial Study September 2009 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 gasses (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, 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 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. 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 Initial Study Palo Alto High School Master Plan 33 ESA / 209002 Initial Study September 2009 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 (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. Initial Study Palo Alto High School Master Plan 34 ESA / 209002 Initial Study September 2009 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 SCAQMD; 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 improvements to the athletic field and would be the result of heavy-duty construction equipment fine grading an area of approximately 4.8 acres. Per the Project Description, this work would occur over a nine moth period in 2010 and 2011. 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 construction equipment would be negligible. The peak annual activity would generate 410 “short” or 372 metric tons (MT) per year of CO2. The proposed improvements to Paly 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 1,108 “short” tons per year or 1,005 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 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 Palo Alto High School Master Plan 35 ESA / 209002 Initial Study September 2009 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 CO2 emission rate resulting from implementation of the proposed Master Plan is estimated to be 1,646 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 (372 MT per year CO2e during construction; and 1,646 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). Measures that reduce trip generation or trip lengths, measures that optimize the transportation efficiency of a region, and measures that promote energy conservation within a development will 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. 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. Initial Study Palo Alto High School Master Plan 36 ESA / 209002 Initial Study September 2009 • Plant trees and vegetation near structures to shade buildings and reduce energy requirements for heating/cooling. • Preserve or replace on-site trees consistent with Mitigation Measure BIO-3 (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, 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 Palo Alto High School Master Plan 37 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-status5 wildlife species to occur on-site (ESA, 2009). Palo Alto and surrounding cities on the San Francisco peninsula have been extensively developed in the last century, and while large tracts of open space exist on Stanford University property approximately 1.5 miles west of the project area, residential areas and high-traffic roads surround the Paly campus. The project site contains native and non-native trees including coast live oak (Quercus agrifolia), sycamore (Platanus racemosa), spruce (Picea sp.), redwood (Sequoia sempervirens), eucalyptus (Eucalyptus gobulus), magnolia (Magnolia grandiflora), and Monterey cypress 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 Palo Alto High School Master Plan 38 ESA / 209002 Initial Study September 2009 (Cupressus macrocarpa). Birds identified on campus were species accustomed to disturbance, including black phoebe (Sayornis nigricans), common raven (Corvus corax), dark-eyed junco (Junco hyemnalis), European starling (Sturnus vulgaris), rock dove (Columbia livia), and scrub jay (Aphelocoma californica). Open spaces without many planted trees are either paved or landscaped grass lawns. Small areas of ruderal grassland with ripgut brome (Bromus diandrus) and slender wild oats (Avena barbata) are present within the parking lot and in isolated areas on campus. The California Natural Diversity Database (CNDDB) documents 43 special-status species within the Palo Alto and Santa Clara U.S. Geological Survey (USGS) quadrangles that include the project area (CDFG, 2009). No suitable habitat for special-status plant species was found on or directly adjacent to the project area, and it is anticipated that project activities will have no negative effects on special- status wildlife species except for the pallid bat (Antrozous pallidus), hoary bat (Lasiurus cinereus), and Townsend’s big-eared bat (Plecotus townsendii). Construction activities and tree removal may adversely impact nesting birds as well. These impacts are discussed below. Special-Status Bats The pallid bat, hoary bat, and Townsend’s big eared bat could be present in trees or buildings at Paly. 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 hollow buildings and 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 and Woodside (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 are present year-round in the San Francisco Bay Area. Hoary bats roost in tree foliage, and less commonly in buildings. Several historical CNDDB occurrences from nearby Stanford University 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 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 Initial Study Palo Alto High School Master Plan 39 ESA / 209002 Initial Study September 2009 reduced to less-than-significant levels through implementation of Mitigation Measure BIO-1: Mitigation Measure BIO-1: 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 will 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 will 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 will be replaced at a 1:1 ratio with a roost suitable for the displaced species. The roost will be modified as necessary to provide a suitable roosting environment for the target bat species. Nesting Birds Trees 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 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 Initial Study Palo Alto High School Master Plan 40 ESA / 209002 Initial Study September 2009 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-2. Mitigation Measure BIO-2: 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 would 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 would be avoided during construction activities until young have fledged or the nest is otherwise abandoned. b) No Impact. No riparian habitats or other sensitive natural communities exist within the Paly campus. The nearest sensitive natural communities are the riparian corridors of San Francisquito Creek, Matadero Creek, and Lake Lagunita, all of which are more than one mile away from the project area. These riparian corridors are not close enough to the project area to be directly or indirectly impacted by project activities. c) No Impact. 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 fall under the jurisdiction of the U.S. Army Corps of Engineers, San Francisco Bay Regional Water Quality Control Board, and the California Department of Fish and Game. The project will not be constructed within or near any jurisdictional wetland areas, and no impacts on jurisdictional wetlands by project activities are anticipated. d) No Impact. Areas around Paly 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 Paly 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 high traffic volumes such as El Camino Real and Embarcadero Road restrict movement of many terrestrial wildlife species through the project area. No impacts on wildlife corridors are anticipated by project activities. Initial Study Palo Alto High School Master Plan 41 ESA / 209002 Initial Study September 2009 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-3. Mitigation Measure BIO-3: PAUSD shall require its contractor(s) to implement the following measures: • 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. 6 Diameter at breast height (DBH) is the diameter of the trunk of a tree 4.5 feet above natural grade. 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 Palo Alto High School Master Plan 42 ESA / 209002 Initial Study September 2009 • 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, and BIO-3 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 July 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, Site reconnaissance, July 9, 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 Palo Alto High School Master Plan 43 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) Less Than Significant with Mitigation. 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. The Paly High School campus consists of 17 buildings constructed between 1918 and 2004. The original construction in 1918 included the Administration and Classroom Building and the Auditorium Building (also known as the “Haymarket Theater”). Much of the original administration/classroom structure was demolished in 1972, leaving the two- story portion referred to as the “Tower Building.” In 1928, the original Boys’ Gymnasium was constructed. The construction of the Industrial Arts Building was completed in 1945 and expanded to include an electronics classroom in 1955. The Boys’ Gymnasium was expanded in 1946 to provide locker and shower facilities and staff offices. In 1960, the Science Classroom Building was constructed. The addition of the Girls’ Gymnasium and the swimming pool was completed in 1969. In 1968, the Administration Building, Auditorium, and the Boys’ Gymnasium were extensively renovated as part of seismic retrofitting. The majority of the other buildings on campus were constructed in the early 1970s. Initial Study Palo Alto High School Master Plan 44 ESA / 209002 Initial Study September 2009 Palo Alto High School’s Haymarket Theater and Tower Building are the last remaining connections to the original campus construction. Completed in 1918 and designed by the Los Angeles architecture firm of Allison and Allison in a Spanish Colonial Revival style of architecture, these highly visible buildings are a long- established presence in the community as a whole. The Tower Building in particular is seen as an icon and a defining image for the campus. While neither building is listed on the state or federal registers of historic resources, the City of Palo Alto does include these buildings on its Historic Resources Inventory. The Inventory identifies the Tower Building and the Theater as Category 2 buildings, defined as “any building or group of buildings of major regional importance, meritorious works of the best architects, or an outstanding example of an architectural style or the stylistic development of architecture of the state or region. A major building may have some exterior modifications, but the original character is retained.” Because these buildings are listed in the Palo Alto Historic Resources Inventory as Category 2 structures, the Palo Alto High School’s Haymarket Theater and Tower Building are considered historical resources under CEQA Guidelines Section 15064.5. Provided below is a description of the exterior and interior features of each building, as well as an evaluation of the potential effects of the proposed project on these historic resources. Haymarket Theater Much of the Theater building’s historic and architectural character resides in the main entry façade. A rooftop cupola and the arcade that connects the Theater Building to the Tower Building are also features that retain the historic and architectural qualities of the original campus. The roof tile, shared with the Tower Building, is another aspect of the original construction of the campus that carries historical import. The main entry facade has experienced some significant deterioration over the years; ornamentation such as the owls on top of the columns have been removed, the spiral, terra cotta columns are cracked in a number of places, original lighting has been removed, original doors have been removed and replaced, and years of wear and tear have generated the need to repair or replace windows, etc. A structural upgrade in 1934 removed a number of features from the building including high windows along each side of the auditorium. The interior of the auditorium was stripped almost entirely of its original character. Originally open to the roof structure above, the auditorium had a ceiling and structural bracing installed, which obscured the original structure from view. High windows were also filled in at this time, and a continuous ceiling and wall finish of striated plaster was installed. New light fixtures were added in the 1930s remodel. These alterations have an Art Deco style to them, which diverge from the Spanish Colonial Revival exterior of the building. The 1930s alterations, which occurred relatively early in the building’s history, may have achieved significance in their own right, however, and may help to convey the evolution of the building over time, including Initial Study Palo Alto High School Master Plan 45 ESA / 209002 Initial Study September 2009 improvements in seismic strengthening technology between 1918 and the mid- 1930s.8 As such, it is possible that the interior of the building also retains some degree of architectural merit. The Haymarket Theater would be renovated under Group 5 of the proposed project. The proposed project would “modernize the existing building with limited building modifications to address accessibility issues.” Such activities would include new Americans with Disabilities (ADA) accessible entrances, ADA compliant stairs and handrails, ADA compliant restrooms, an accessible drinking fountain, exterior and interior ramps, and installation of an assistive listening system. Although the majority of the renovations would occur in the interior of the building, which was altered early in the building’s history, it is possible that the new proposed improvements such as the ADA entrances and ramps could also alter the building’s exterior character defining features. As no systematic evaluation of the building’s exterior or interior character-defining features have been prepared, nor have final project plans been completed, the proposed project could have an adverse impact on the historic significance of the Haymarket Theater if they were not completed in a manner consistent with the Secretary of the Interior’s Standards for Rehabilitation, which would be considered a significant impact on the environment under CEQA. CEQA Section 15064.5(b)(3) states that, “Generally, a project that follows the Secretary of the Interior’s Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings (Weeks and Grimmer, 1995) shall be considered mitigated to a level of les than a significant impact on the historical resource.” As both the full extent of the building’s interior and exterior character-defining features are unknown, and given the lack of specificity of the proposed renovation efforts, it is conservatively concluded that the proposed project could have a significant impact on the historic significance of this building. Mitigation measures proposed to reduce the potential impact to a less-than-significant level are provided below Tower Building The Tower Building’s historic character is expressed on all exterior facades and is highlighted by the original bell tower or campanile. The Spanish tile roof and arcade also reflect the character of the original campus. Elaborate terracotta ornamentation at the main entry is in relatively good condition. At the side (parking lot) entrance, the terracotta trim is somewhat deteriorated, portions are missing, and columns have been obscured by paint. Terracotta trim at the arcade is covered with layers of paint. The tall wood casement windows, a defining feature of the Tower Building, are in poor repair. Doors are generally neither original nor appropriate to 8 These structural improvements were likely made to the Haymarket Theater in compliance with more stringent seismic building requirements for all schools in California as a result of the devastating 1933 Long Beach Earthquake, which destroyed numerous civic and academic buildings throughout Southern California. Initial Study Palo Alto High School Master Plan 46 ESA / 209002 Initial Study September 2009 the building style and many are not weather tight. Modern exterior lighting has been added that is out of character with the original building. The interior layout/plan of the building is substantially intact, though historic light fixtures and finishes have been replaced with elements not in keeping with the building’s historic character. The building’s showpiece, the original library, is a grand vaulted space with its original wood structure exposed at the ceiling and is flooded with light from the very tall windows wrapping three sides. This room is currently divided by interior partial-height partitions that house the school’s Guidance and Counseling Offices. The ceiling is still visible, however, above these partitions. Interior finishes are showing obvious signs of age and wear. Floor finishes at the corridors are in poor condition, and glued-on ceiling tiles are loose in many locations. The Tower Building would be renovated in two phases under Group 4c and Group 5a of the proposed project, respectively. Under Group 4a, the proposed project would complete “minimum upgrades required for safety, building integrity, and code compliance,” including the following: 1) upgrading the existing structural system to meet FEMA guidelines; 2) replacing windows in original Library for safety; 3) replacing/repairing select other windows that are damaged; and 4) numerous ADA upgrades, including elevator access to the second floor by inserting an elevator into the existing tower (requires shoring and deepening of tower foundations) or by appending a new elevator structure, which would provide accessible student and staff toilets on both floors, create accessible entrances, including ramps, at major entry points, modifying existing stairs where needed for accessibility code compliance, and replacing existing doors, frames, and hardware. Group 4c of the project improvements would also include: 5) mechanical upgrades, including changes to floor, wall, and ceiling finishes, and retrofit of existing stair tread heights. Finally, Group 4c work would also include: 7) replacing existing lighting where disturbed by work; and 8) upgrading fire protection measures to meet current standards. Under Group 5a, the proposed project would include all of the above work under Group 4c, plus “upgrade building systems to meet campus standards, and modify existing layout,” including the following activities: 1) reconfiguring spaces/relocate users of existing spaces, including removing existing non-shear walls and reconfigure spaces for improved utility; replace existing bearing walls with beams/columns as required, remodel original library space to serve a more-public function, (e.g., lecture hall/meeting room/gallery); 2) replacing additional windows as required by new wall locations; 3) replacing all windows with new double- paned, Low-E windows for increased energy efficiency and thermal comfort; 4) ADA upgrades (see discussion above under Group 4c); 5) additional mechanical upgrades; and 6) additional electrical upgrades. Initial Study Palo Alto High School Master Plan 47 ESA / 209002 Initial Study September 2009 As no systematic evaluation of the building’s exterior or inter character-defining features have been prepared, nor have final project plans been completed, the proposed project could have a significant adverse impact on the historic significance of the Tower Building if they were not completed in a manner consistent with the Secretary of the Interior’s Standards for Rehabilitation, which would be considered a significant impact on the environment under CEQA. CEQA Section 15064.5(b)(3) states that, “Generally, a project that follows the Secretary of the Interior’s Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings (Weeks and Grimmer, 1995) shall be considered mitigated to a level of les than a significant impact on the historical resource.” As both the full extent of the building’s interior and exterior character-defining features are unknown, and given the lack of specificity of the proposed renovation efforts, it is conservatively concluded that the proposed project could have a potentially significant impact on the historic significance of this building. Mitigation measures proposed to reduce the potential impact to a less-than-significant level are provided below. Aside from potential direct effects to the Haymarket Theater and Tower Building described above, no other direct or indirect impacts to historic resources either on or off campus are anticipated as a result of the proposed project. The addition to the Student Center under Group 6a of the proposed project, however, would be constructed approximately 30 feet to the east of the Tower Building. This proposed addition would have no significant indirect effects to the historic setting of the Tower Building, given the sufficient distance between these buildings, which would allow the Tower Building to continue to “read” as a separate structure. The proposed addition would also be subordinate to the Tower Building, and while its design of this new building has not been finalized, it is intended to be architecturally compatible not only with the Tower Building, but other buildings on the Paly campus. As such, the proposed addition to the Student Center would have no direct or indirect effects to historic architectural resources on the Paly campus. Other proposed structures on the campus, such as the future theater and gym, would be located approximately 200 feet and 430 feet from both the Haymarket Theater and the Tower Building, respectively. Given these relatively wide separations between the historic resources and the proposed new buildings, there would be no indirect effects on the setting of historic resources at the Paly campus as a result of these new structures. Public views of the Tower Building, in particular, would continue to be available from El Camino Real, and its campanile would remain a visible icon for both the campus and the immediate neighborhood. Mitigation Measure CUL-1. The PAUSD shall hire a qualified consulting architectural historian to review the architectural plans for renovations to both the Haymarket Theater and Tower Building for compliance with the Secretary of the Interior’s Standards for Rehabilitation. A description of the Standards is provided in Appendix A. Given that the Standards for Rehabilitation allow Initial Study Palo Alto High School Master Plan 48 ESA / 209002 Initial Study September 2009 a fair degree of flexibility and latitude in alterations to historic resources for code compliance while attempting to retain the majority of the building’s character-defining features, it appears possible that the proposed renovation efforts could meet the Standards. The consulting architectural historian shall provide the District with an assessment of compliance with the Standards in the form of a brief technical memorandum, including recommended design changes for a more complete compliance with the Standards, if necessary. During final plan check review, the District shall evaluate whether the recommended design changes by the consulting architectural historian, if proposed, are reflected on the final designs for the renovation of the Haymarket Theater and Tower Building. Implementation of this mitigation measure would reduce the project’s potentially significant impact to historic resources to a less-than-significant level. 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 Initial Study Palo Alto High School Master Plan 49 ESA / 209002 Initial Study September 2009 and a series of smaller hamlets occupied intermittently or seasonally (Kroeber, 1925). Tribelet territories were generally defined on the basis of physiographic 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 one-mile 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 project site or within a 0.5 mile radius of the project site. The project site is located in an area mapped as late Pleistocene or early Holocene alluvium. This geologic landform has a low potential to contain deeply-buried soils or paleosols that would have once been available for human use and occupation. The project site has a low potential to contain archaeological materials, however the possibility cannot be entirely discounted. The following mitigation measure will to reduce potential impact to the inadvertent discovery of archaeological resources to a less-than-significant level. Mitigation Measure CUL-2: If previously unidentified cultural materials are unearthed during construction, work should 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. Fossil discoveries provide scientific value because they help establish a historical record of past plant and animal life and can assist geologists in dating rock formations. Initial Study Palo Alto High School Master Plan 50 ESA / 209002 Initial Study September 2009 Subsurface excavations into undisturbed soils and rock beneath the high school could potentially disturb or destroy paleontological resources. Paly is underlain by Pleistocene-age (10,000 to 1.8 million years ago) alluvial fan and fluvial deposits, which are characterized by sequences of sand, silt and gravel that form gently sloping surfaces. These deposits originated from modern stream courses, which now deposit their sediment loads closer to the bay and in narrow stream valleys. Thus, these “stabilized” alluvial fan deposits are old enough to have stiffened and preserved the remains of Pleistocene organisms. In fact, Pleistocene alluvium in California is well known for yielding fossils of extinct vertebrate mammals. Geologic mapping indicated that the unit locally contains fresh-water mollusks and extinct late Pleistocene vertebrate fossils (USGS, 2000). In addition, the University of California Museum of Paleontology database records show that similar deposits have yielded vertebrate fossils at eight different locations in San Mateo County (UCMP, 2009). These include fossils from a bison, mammoth, camel, horse, sloth and moose, as well as one bird species. The fossils were found in locations along the Pacific coast as well as along Skyline Drive in South San Francisco and along Middlefield Road in San Mateo County. The database did not have specific information on the location of the non-coastal fossils. Because the Pleistocene alluvial fan and fluvial deposits beneath Paly have yielded vertebrate fossils, it qualifies under the Society of Vertebrate Paleontology guidelines as a unit of high paleontological potential9 (SVP, 2006). While no information exists to refute or confirm the presence of fossils beneath the high school, and because the unit has a high paleontological potential, subsurface excavations beyond previously disturbed soils could disturb or destroy paleontological resources, which would be potentially significant impact. Mitigation Measure CUL-3 would reduce this impact to a less than significant level by educating 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-3: 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 9 Paleontological potential refers to the probability that a rock unit will yield a unique or significant paleontological resource. Initial Study Palo Alto High School Master Plan 51 ESA / 209002 Initial Study September 2009 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 will 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. Mitigation Measure CUL-4: 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 California Department of Parks and Recreation (DPR), Historic Resources Inventory Form, Palo Alto Senior High School. Prepared by the City of Palo Alto. Historic Resource Board. 1978, 1981. 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. HMC Architects, Palo Alto Unified School District, Planning Study for Palo Alto High School Theater and Tower Buildings, June 2006. 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, 1995. Initial Study Palo Alto High School Master Plan 52 ESA / 209002 Initial Study September 2009 Society of Vertebrate Paleontology (SVP), Conditions of Receivership for Paleontologic Salvage Collections, Society of Vertebrate Paleontology News Bulletin, Vol. 166, February 1996. University of California Museum of Paleontology (UCMP), Collections Database, www.ucmp.berkeley.edu/science/collections.php, accessed August 20, 2009. 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. Initial Study Palo Alto High School Master Plan 53 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: 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. Strong seismic ground shaking? Seismic-related ground failure, including liquefaction? 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 (U.S. 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 Lake, Searsville Initial Study Palo Alto High School Master Plan 54 ESA / 209002 Initial Study September 2009 Lake, and Lagunita Reservoir, as well as from the potential for levee failure near San Francisco Bay. Discussion a.i) Less than Significant. 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 project site is located approximately 5.3 miles from the San Andreas Fault and 3.4 miles from the potentially active Monte-Vista-Shannon fault. 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 traces,10 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 not located in an Alquist-Priolo Earthquake Fault Zone, as defined by CGS. The geotechnical investigation (Cleary, 2009) concluded that there are no known active or potentially active faults crossing the proposed building sites. Therefore, the hazard resulting from surface fault rupture at the project site is considered low and the impact is considered less than significant. 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 10 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 Palo Alto High School Master Plan 55 ESA / 209002 Initial Study September 2009 of one or more earthquakes of moment magnitude 6.7 or higher occurring in the San Francisco Bay Area.11 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. According to the CGS Probabilistic Seismic Hazard Assessment (PSHA), peak ground acceleration at the project site could reach or exceed 0.5 g (CGS, 2009).12 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 impacts related to seismic ground shaking 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 11 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). 12 “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 Palo Alto High School Master Plan 56 ESA / 209002 Initial Study September 2009 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.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.” The CGS Seismic Hazard Zone map for the Palo Alto Quadrangle (CGS, 2006) does not indicate any liquefaction areas on the project site. The geotechnical investigation (Cleary, 2009) concluded that the likelihood of soil liquefaction during strong ground shaking to be very low; however, the sand and clay layers encountered in borings below the theoretically high groundwater table (estimated at 25 feet) were conservatively analyzed for liquefaction-induced settlement. Based on the results of the analysis, theoretical liquefaction-induced settlements of up to 1.54 inches could occur. However, because the computed settlement occurs below a depth of 25 feet, the likelihood of significant surface manifestation from settlement at such depth is low. Therefore, the potential for liquefaction would be considered a less than significant impact. 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 dependant 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, Initial Study Palo Alto High School Master Plan 57 ESA / 209002 Initial Study September 2009 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 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 soils at the project site in the upper five to 17-foot layer consist predominantly of stiff to very stiff sandy clay overlying medium dense to dense clayey gravelly sand, silty gravelly sand, and poorly graded sands and gravels to the maximum depth explored of 45 feet (Cleary, 2009). The potential landslide hazard for the proposed project is discussed above in Section IV.a.iv. Due to the absence of a free face in the vicinity of the relatively level site, and the generally high relative densities associated with the subsurface soils, soil lurching and lateral spreadings are considered unlikely (Cleary, 2009). With implementation of preliminary foundation recommendations and Mitigation Measure GEO-1, above, the potential hazard from unstable soils would be considered less than significant. d) Less than Significant with Mitigation. Preliminary foundation recommendations indicated that the upper sandy clay at the project site is considered to be low to moderately 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 Initial Study Palo Alto High School Master Plan 58 ESA / 209002 Initial Study September 2009 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. Recommendations given in geotechnical reports require design and construction of proposed projects to follow engineering design criteria needed to improve and/or eliminate settlement from expansive soils conditions. The design and construction of the proposed project in accordance with 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 24, 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 Investigations, Campus Improvements-Group 2, Palo Alto High School, July 30, 2009. Initial Study Palo Alto 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 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 Palo Alto High School Master Plan 60 ESA / 209002 Initial Study September 2009 Discussion a, b) Less than Significant with Mitigation. The Department of Toxic Substances Control (DTSC) EnviroStor database did not list any existing hazardous materials sites at or in the immediate vicinity of the school (DTSC, 2009). Three leaking underground fuel tank sites nearby have all been remediated and the cases have been closed. 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 the use of 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 Palo Alto High School Master Plan 61 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. Initial Study Palo Alto 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 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. 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. Initial Study Palo Alto High School Master Plan 63 ESA / 209002 Initial Study September 2009 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 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 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 Lakes 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 Initial Study Palo Alto High School Master Plan 64 ESA / 209002 Initial Study September 2009 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 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 Section 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 1.6 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 Initial Study Palo Alto High School Master Plan 65 ESA / 209002 Initial Study September 2009 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 project sponsor 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 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 off-site and using biofiltration improvements to the extent possible. Adherence to these requirements would reduce the amount of off-site 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 of 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 Initial Study Palo Alto High School Master Plan 66 ESA / 209002 Initial Study September 2009 NPDES permit described above 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 Maps covering the project area, the Paly campus is located within Flood Zone X. This area is outside the 100-year flood zone; therefore, the impact would be considered less than significant. i) Less Than Significant. The 2003 Flood Inundation Maps prepared by the Santa Clara Valley Water District indicated that the project site would not be subject to inundation in the event of a failure of the Stevens Creek Dam, Lexington Dam, Anderson Dam, Coyote Percolation Dam, Riconada T. W. Reservoir, or the Vasona Dam (Cleary, 2009). Therefore, the risk of inundation through failure of a levee or a dam would be less than significant at the project site. 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. The project site is outside of the runup zone resulting from a seismically generated tsumani with a 20-foot runup at the Golden Gate (Cleary, 2009).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. Cleary Consultants, Inc., Geotechnical Investigations, Campus Improvements-Group 2, Palo Alto High School, July 30, 2009. Deems Lewis McKinley, Palo Alto High School, Site Perviousness, 2009. Federal Emergency Management Agency (FEMA), Flood Insurance Rate Map (FIRM), Santa Clara County, Map Numbers 06085C0010H, 06085C0016H, and 06085C0017H, May 18, 2009. Initial Study Palo Alto High School Master Plan 67 ESA / 209002 Initial Study September 2009 Santa Clara Valley Urban Runoff Pollution Prevention Program, www.scvurppp- wk2.com, accessed July 14, 2009. Initial Study Palo Alto High School Master Plan 68 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 The Paly campus is located on an approximately 44-acre site southeast of the El Camino Real and Embarcadero Road intersection. The campus is owned and occupied by the PAUSD, but the site has a reversionary clause to Stanford University on 26 acres. Original construction began in 1918 and approximately 17 buildings currently exist on the campus. Adjacent land uses include residential areas to the east and southeast, Stanford University to the west, and the Town and Country Village shopping center to the north. 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. Initial Study Palo Alto High School Master Plan 69 ESA / 209002 Initial Study September 2009 Policy C-5: Recognize the importance of schools to the social and economic vitality of the City. 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, 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 their 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 Paly campus. While the proposed Master Plan would represent changes 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. Initial Study Palo Alto High School Master Plan 70 ESA / 209002 Initial Study September 2009 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. Moreover, the project would require review and approval by Board of Education and would be required to meet design criteria established by the Department of 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 Palo Alto High School Master Plan 71 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 Palo Alto High School Master Plan 72 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.13 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.14 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.15 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.16 While PAUSD has not adopted any specific interior noise standard for its 13 California Department of Education (CDE), Regulations (CCR Tit. 5, Div. 1, Ch. 13 Subchapter 1, Article 2 §14010 “Standards for School Site Selection”) 14 CDE Regulations (CCR Tit. 5, Div. 1, Ch. 13 §14010(q)). 15 CDE, School Facilities Planning Division, School Site Selection and Approval Guide, March, 2001. 16 Ibid. Initial Study Palo Alto High School Master Plan 73 ESA / 209002 Initial Study September 2009 classrooms, other districts, such as Los Angeles Unified have adopted an interior standard of 45 dBA. Long-term (24-hour) noise monitoring was conducted at two locations on the Paly campus to determine the existing noise environment of proposed locations of new classrooms. The first location monitored was the location of the proposed Group 2, two-story 27-room classroom building. Noise sources in this area are dominated by vehicle traffic on Alma Street, which is approximately 200 feet from the eastern building façade and intermittent train pass-by events on the Caltrain tracks that are approximately 130 feet from the eastern building façade. Daytime hourly average noise levels at this location ranged from 60 to 67 dBA with a (logarithmic) average of 64 dBA. Maximum (instantaneous) noise levels during train pass-by events ranged from 80 to 88 dBA, depending on the direction of the train. The second location monitored was the location of the proposed Group 2, Media Arts Center. Noise sources in this area are dominated by vehicle traffic on Embarcadero Road, which is approximately 110 feet from the northern building façade and intermittent train pass-by events on the Caltrain tracks that are approximately 260 feet from the eastern building façade. Daytime hourly average noise levels at this location ranged from 60 to 64 dBA with a (logarithmic) average of 61 dBA. Maximum (instantaneous) noise levels during train pass-by events ranged from 75 to 80 dBA, depending on the direction of the train. Standard building construction methods typically result in a exterior to interior noise reduction of 15 to 20 dBA (HUD, 2004), which would be insufficient to meet the recommended goals of the ASLHA or the generally accepted 45 dBA standard for interior residential spaces. Consequently, these two classroom buildings would 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 and operational activities associated with the project on the existing sensitive receptors in the vicinity of the site as well as the impact of the existing vibration environment on the future occupants of project classrooms. Ground-borne vibration from activities that involve “impact tools,” especially pile driving could produce significant vibration. It is unknown, at the Master Plan level, Initial Study Palo Alto High School Master Plan 74 ESA / 209002 Initial Study September 2009 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 200 feet away from the proposed building locations and would not be susceptible to building damage from pile driving activity. Consequently, the potential for adjacent building damage would 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). VdBs 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.17 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 residence nearest to the proposed two-story classrooms would be located approximately 20 feet away at which distance vibrations from pile driving activities would be reduced to 77 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 mitigation measures are recommended. Operational Vibration Impacts from Caltrain The proposed two-story 27-room classroom building and the proposed Media Arts Center would be located 130 feet and 260 feet, respectively, from active railroad tracks operated by Caltrain. Based on the published Caltrain schedule (dated March 2, 2009), 98 Caltrain passenger train pass the site each weekday. Survey of monitored vibration levels adjacent to the Caltrain tracks undertaken for the City of San Carlos in 2006 indicates that peak vibration levels monitored at a distance of 65 feet from the southbound track and 80 feet from the northbound track were recorded to be 72 Vdb (Illingworth and Rodkin, 2006). This would be a less than 17 Ibid. Initial Study Palo Alto High School Master Plan 75 ESA / 209002 Initial Study September 2009 significant vibration annoyance impact to the nearest classrooms, which are located twice this distance from the tracks. Consequently, annoyance impacts to students at the propose classrooms nearest the Caltrain tracks would be less than significant. To reduce potential structural damage impacts from pile driving (if necessary) on nearby existing and/or future buildings, PAUSD shall implement Mitigation Measures NOI-2 and NOI-3: Mitigation Measure NOI-2: • 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. Noise from air handling equipment would be located more than 200 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 (Caltrain and Alma Street), 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 Initial Study Palo Alto High School Master Plan 76 ESA / 209002 Initial Study September 2009 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 shown in Table 2 for existing, existing plus project and 2018 plus project scenarios. The traffic analysis indicates that the proposed project would generate approximately 886 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. TABLE 2 TRAFFIC NOISE INCREASES IN ROADSIDE LEQ Road Segment Existing Existing + Project Contribution of Proposed Project Modeled Cumulative Year 2018 with Proposed Project Modeled Cumulative Incremental Increase 2009 vs 2018 with Proposed Project) 1. Embarcadero Road (between Kingsley Avenue and Paly Driveway) 62.9 63.1 0.2 64.2 1.3 2. El Camino Real (between Churchill Avenue and Embarcadero Road) 69.3 69.3 0.0 70.1 0.8 3. Churchill Avenue (between Paly Driveway and El Camino Real) 59.8 59.9 0.1 60.0 0.2 4. Churchill Avenue (between Emerson Street and Alma Street) 57.1 57.2 0.1 59.4 1.3 5 Alma Street (between Kellogg Avenue and Churchill Avenue) 68.7 68.7 0.0 67.5 - 1.2b 6. Alma Street (between Coleridge Avenue and Churchill Avenue) 69.4 69.4 0.0 68.7 - 0.7b 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 foe El Camino Real and Alma Streets for which the assumed speed was 35 miles per hour. b A decrease in noise is predicted at these segments because traffic projections predict a decrease in northbound roadway volumes by 2018. SOURCE: ESA, 2009. Initial Study Palo Alto High School Master Plan 77 ESA / 209002 Initial Study September 2009 As can be seen from the data 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. 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, renovations of existing buildings and improvements to athletic fields involving earthwork. 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 shows 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 200 feet from the proposed two-story classroom, across Alma Street and residences across Churchill Avenue, approximately 120 feet from proposed earthwork for renovation of the baseball and softball fields. Initial Study Palo Alto High School Master Plan 78 ESA / 209002 Initial Study September 2009 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. 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. Initial Study Palo Alto High School Master Plan 79 ESA / 209002 Initial Study September 2009 • 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 Illingworth and Rodkin, San Carlos Train Depot Site, Noise and Vibration Assessment San Carlos, California, August 8, 2006. 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 Palo Alto High School Master Plan 80 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, Palo Alto High School Master Plan, 2009. Lapkoff & Gobalet Demographic Research, Inc., Enrollment Forecasts for PAUSD Middle and High Schools, January 12, 2009. Initial Study Palo Alto High School Master Plan 81 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: Fire protection? Police protection? Schools? Parks? – See Section 14 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 Paly campus is Fire Station No. 1 at 301 Alma Street, 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 Palo Alto High School Master Plan 82 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 one-mile from the Paly 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 a 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. Initial Study Palo Alto High School Master Plan 83 ESA / 209002 Initial Study September 2009 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. 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 Palo Alto High School Master Plan 84 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 Initial Study Palo Alto High School Master Plan 85 ESA / 209002 Initial Study September 2009 discussed in this environmental document and mitigated to a less than significant level. 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 Palo Alto High School Master Plan 86 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 Palo Alto High School is located on the southeast corner of the intersection of El Camino Real (State Route (SR) 82) and Embarcadero Road. The school has three primary entrances/exits, one from El Camino Real, one from Embarcadero road, and one from Churchill Avenue. The three entrances are currently controlled with stops signs on the driveway approaches.18 The driveway from Embarcadero Road includes left- and right-turn (eastbound and westbound) ingress from Embarcadero Road, but only right-turn egress to eastbound Embarcadero Road. This would change with signalization of the driveway, which as planned, includes left- and right-turn access to and from Embarcadero Road. Pedestrian and bicycle access from Embarcadero Road is provided with a signal controlled crosswalk approximately 200 feet easterly of the school driveway. The crosswalk effectively links the school with the shopping center and areas to the northeast, and currently accommodates a large volume of both pedestrian and bicycle traffic. Vehicle traffic currently backs up on Churchill Avenue during the morning peak hour, particularly in the westbound direction behind the traffic light at El Camino Real. The 18 The driveway at Embarcadero Road, which aligns with the Town and Country Shopping Center, is schedule to be signalized with the next year as part of the new Trader Joe’s project. Initial Study Palo Alto High School Master Plan 87 ESA / 209002 Initial Study September 2009 driveway to Embarcadero Road is congested during student arrival and departure periods. Vehicle use of the El Camino Real driveway is limited to right-turns in and out. Existing Traffic Volumes and Intersection Lane Configurations Five study intersections that would be most affected by project traffic were selected for analysis: 1. El Camino Real and Embarcadero Road 2. Embarcadero Road and School Driveway 3. El Camino Real and Churchill Avenue 4. Churchill Avenue and Alma Street 5. Churchill Avenue and School Driveway 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. Vehicle counts at the driveways were conducted at the start and end of the school day on a Friday in March (March 13, 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. A total of 467 drop-offs occurred during the count period. Of these approximately 49 percent (228 drop- offs) were in front of the Haymarket Theatre, 17 percent (80 drop-offs) were in front of the tower building, and 34 percent (159 drop-offs) occurred at the end of the driveway from Churchill Avenue.19 The primary issue during drop-offs in the morning is the number of vehicles attempting to leave the site during the 20-minute morning peak through the Embarcadero Road driveway, as there are limited queuing and stacking lanes. Parking at the high school is currently concentrated in three locations as shown in Figure 12. The school has a total of 555 parking spaces. Lots A, B, C, D, and E, with a total of 295 parking spaces are located in the northwest corner of the school site. Lot F (a combination of two smaller lots) with 57 parking spaces is located in the northeast corner. Lots G, H, I, and K, with a total of 203 parking spaces, are located in the southern portion of the school property with access from Churchill Avenue. 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 A, C, E, F, G, and H) operate close to capacity, and the more remote lots (lots B, D, I, and K) typically have parking spaces available. Lot D can have upwards of 100 empty spaces during the day, while Lot I, near Churchill Avenue, can have 20 to 40 empty parking spaces. As a whole, 19 This does not include students dropped off on side streets or in the Town and Country Shopping Center. Initial Study Palo Alto High School Master Plan 88 ESA / 209002 Initial Study September 2009 the high school has a peak parking demand of approximately 416 parking spaces (75 percent). Palo Alto High School Master Plan . 209002 Figure 12 AM and PM Peak Hour Intersection Volumes and Parking Count Summaries SOURCE: Wilson (2009). Merci. LL Initial Study Palo Alto High School Master Plan 90 ESA / 209002 Initial Study September 2009 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 LOS calculation methodology for intersections is dependent on the type of traffic control device, traffic signals or stop signs. The LOS 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 TRAFFIX analysis software and is correlated to a LOS designation as shown in Table 4. The LOS standard (i.e., minimum acceptable operations) for the City of Palo Alto is LOS D. 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. Intersection LOS calculations were conducted at the unsignalized intersection using the methodologies for two-way stop-controlled (TWSC) intersections contained in Chapter 17 of the 2000 Highway Capacity Manual (HCM). The LOS rating is based on the control delay for the stop-controlled movement expressed in seconds per vehicle. Control delay includes initial deceleration delay, queue move-up time, stopped delay, and final acceleration delay. Table 5 presents the range of average control delay that corresponds Initial Study Palo Alto High School Master Plan 91 ESA / 209002 Initial Study September 2009 to each LOS designation. The control delay was calculated using the TRAFFIX analysis software. TABLE 5 LEVEL OF SERVICE CRITERIA FOR UNSIGNALIZED INTERSECTIONS Level of Service Average Control Delay Per Vehicle (Seconds) Description A ≤ 10.0 Little or no delay B 10.1 to 15.0 Short Traffic delays C 15.1 to 25.0 Average traffic delays D 25.1 to 35.0 Long traffic delays E 35.1 to 50.0 Very long traffic delays F > 50.0 Extreme traffic delays with intersection capacity exceeded 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 LOS for the study intersections. The results of the LOS analysis are presented in Table 6. All of the study intersections are currently operating at acceptable levels. TABLE 6 EXISTING INTERSECTION AM PEAK-HOUR LEVELS OF SERVICE (LOS) ANDAVERAGE VEHICLE DELAY (SECONDS/VEHICLE)a Existing Intersection Control Typeb Delayc LOS El Camino Real and Embarcadero Road Signal 43.9 D Embarcadero Road and School Driveway Signal 9.4 A El Camino Real and Churchill Avenue Signal 22.8 C Churchill Avenue and Alma Street Signal 35.0 C Churchill Avenue and School Driveway TWSC 22.1 C a LOS calculations performed for using TRAFFIX and the 2000 Highway Capacity Manual operations analysis methodology. b TWSC = Two-way stop (sign) controlled c Represents overall intersection delay for signalized intersections, worst-case controlled movement delay for minor street stop intersection. SOURCE: Wilson (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 Embarcadero Road north of the driveway and at the intersection of Churchill and Castilleja Avenues. Initial Study Palo Alto High School Master Plan 92 ESA / 209002 Initial Study September 2009 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 Churchill Avenue between Bryant Street and El Camino Real. In addition, bicycles are allowed in paved path within the Caltrain right-of-way. Bicycle counts were conducted at the start and end of the school day on a Friday in March (March 13, 2009). The counts included both inbound and outbound bicycles by location, as well as count of parked bicycles by location.20 Bicycle counts, illustrated in Figure 13, reveal that approximately 410 students bicycle to school. Approximately 39 percent (161 students) entered from Churchill and Castilleja Avenues, 32 percent (129 students) from the signalized crossing at Embarcadero Road, 12 percent (50 students) from the intersection of El Camino Real and Embarcadero Road, and 17 percent (71 students from the northeast corner of the campus at the Caltrain tracks above Embarcadero Road. Outbound bicycle traffic in the afternoon is more dispersed over time, as students depart over an extended time period; however, the direction of departures is more or less the reverse from the morning arrivals. By comparison, counts conducted by the Parent Teacher Association (PTA) on a warmer day, have documented upwards of 520 students bicycling to school, roughly 27 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 gym, near the science building, and near the student center. Transit Facilities 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 22 is a local bus route that provides service between the Eastridge neighborhood in San Jose and Palo Alto/Menlo Park 24 hours a day, seven days a week. It operates on El Camino Real along the project frontage. The Embarcadero Shuttle is a free service that operates Monday through Friday. The shuttle runs every 15 minutes during commute hours and is coordinated with the Caltrain schedule. It serves employers in the Embarcadero/Baylands area, residents in the Embarcadero Road corridor and students at Palo Alto High School. It operates on Embarcadero Road along the project frontage. 20 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). Palo Alto High School Master Plan . 209002 Figure 13 Bicycles and AM/PM Peak Period Pickup/Dropoff Volumes SOURCE: Wilson (2009). Merci. LL Initial Study Palo Alto High School Master Plan 94 ESA / 209002 Initial Study September 2009 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 increase trips to the high school. The vehicle trip generation for the proposed project is presented in Table 7. 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 138 net new morning vehicle trips (95 inbound and 43 outbound) at the school driveways. TABLE 7 AM PEAK HOUR TRIP FORECAST Existing Student Population Forecast 2018 Student Population Net Increase in Tripsa Net Inbound/ Outbound Trips 1,773 2,291 138 95/43 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 8; turning movement counts and LOS calculations are on-file at the District offices. With the addition of project-generated traffic, the study intersections would continue to operate at acceptable levels of service during the a.m. peak hour. Therefore, it is considered a less than significant impact. Cumulative Conditions Cumulative Conditions includes estimated volumes based on forecasts of the Year 2018 baseline traffic volumes. The Year 2018 baseline conditions were developed using the City of Palo Alto’s traffic forecasts for the years 2010, 2013, and 2015 with a pro rata increase to 2018. Initial Study Palo Alto High School Master Plan 95 ESA / 209002 Initial Study September 2009 TABLE 8 EXISTING AND FUTURE LEVELS OF SERVICE (LOS) AND AVERAGE VEHICLE DEALY (seconds/vehicles)a Control Existing Project Cumulative w/Project Intersection Typeb Delayc LOS Delayc LOS Delayc LOS AM Peak Hour El Camino Real and Embarcadero Road Signal 43.9 D 43.9 D 48.4 D Embarcadero Road and School Driveway Signal 9.4 A 9.7 A 10.5 B El Camino Real and Churchill Avenue Signal 22.8 C 22.9 C 22.8 C Churchill Avenue and Alma Street Signal 35.0 C 35.9 D 43.0 D Churchill Avenue and School Driveway TWSC 22.1 C 24.9 C 30.9 D a LOS calculations performed for using TRAFFIX and the 2000 Highway Capacity Manual operations analysis methodology. b TWSC = Two-way stop (sign) controlled c Represents overall intersection delay for signalized intersections, worst-case controlled movement delay for minor street stop intersection. SOURCE: Wilson (2009) Peak-hour levels of service at the study intersections for Cumulative Conditions are summarized in Table 8. Under Cumulative Conditions, the delay will increase at the study intersection, but will continue to operate at acceptable levels during the a.m. peak hour. Therefore, the project’s impact to Cumulative Conditions would be less than significant. 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 off-site 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 on-site 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 to major arterials (Embarcadero Road, Churchill Avenue) and to El Camino Real, construction trucks would have relatively easy and direct routes. Most construction traffic would be dispersed Initial Study Palo Alto High School Master Plan 96 ESA / 209002 Initial Study September 2009 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). 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 540. The high school would continue to encourage bicycling to campus as part of their Transportation Demand Management program, 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. 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-1 and TRAN-2 would reduce on- site circulation impacts to less-than-significant levels. Initial Study Palo Alto High School Master Plan 97 ESA / 209002 Initial Study September 2009 Mitigation Measure TRAN-1: PAUSD shall incorporate the following measures into the project site’s final internal circulation design: • 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-2: PAUSD shall integrate the following measures to reduce potential queuing impacts: • Circulate informational flyers to parents and students that discuss on-site 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 on-site 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 project is located at the intersection of major roadways (El Camino Real and Embarcadero Road). The driveways 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. 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 416 spaces on a typical weekday, the future demand rate Initial Study Palo Alto High School Master Plan 98 ESA / 209002 Initial Study September 2009 with buildout of the Master Plan would be approximately 550 spaces. The proposed on-site parking supply for the school is proposed to remain at 555 spaces; the project’s effect would be less than significant. 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. 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. 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. 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 Palo Alto High School Master Plan 99 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 Initial Study Palo Alto High School Master Plan 100 ESA / 209002 Initial Study September 2009 ultimately placed in a landfill at the 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 110,000-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 Initial Study Palo Alto High School Master Plan 101 ESA / 209002 Initial Study September 2009 ensure that construction of new on-site stormwater infrastructure would not result in adverse impacts to water quality. f, g) Less than Significant. Palo Alto High School student and staff population growth would be relatively stable over the eight-year Master Plan horizon. The Kirby Canyon Landfill has 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 Palo Alto High School Master Plan 102 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 with Mitigation. 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, or reduce the number or restrict the range of a rare or endangered plant or animal. The proposed project could have an adverse impact on the historic significance of the Haymarket Theater or Tower Building. However, Mitigation Measure CUL-1 would reduce impacts to less than significant levels. 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. Initial Study Palo Alto High School Master Plan 103 ESA / 209002 Initial Study September 2009 c) Less Than Significant with Mitigation. 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 AIR-1 and 2; GEO-1; NOI-1 through 4; and TRANS-1 and 2 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 January 29, 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 Palo Alto 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 Palo Alto High School Master Plan (SCH# 2009102023). 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 Palo Alto 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 to best available on an overall basis. However, the rates are qualified to the extent that more research is needed relative to us of school 2 busing, transit and whether the schools were private or public. This information was not recorded in ITE manual other than to state the percentage of students transported by transit and/or bus varied considerably. At the Palo Alto High School sites there is different sort of variation which occurs. At both Paly and Gunn a high percentage of students 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 bicycle commute was reduced by 200 plus. This phenomenon results in proportional increase in auto commuting, typically in the form of drop-offs as a result of parking at the schools being controlled with permits. Students cannot simply drive themselves on a rainy day. As such, the survey of drop-offs (and inbound and outbound trip) showed a significantly increased number relative to what regularly occurs on a sunny day should be interpreted as more of a worst case estimate. 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 Paly. The student population is forecast to increase from a level of 1,773 for the 2008/2009 year to 2,291 in 2018 or by 29.22% Using this worst case type estimate which assumes Building D with District offices together with all other district uses having access from the Churchill driveway remain yields a total of approximately 260 new trips when bicycle commuting is at its lowest point. As such Table 7 of the Initial Study as been revised as follows: TABLE 7 AM PEAK HOUR TRIP FORECAST Existing Student Population Forecast 2018 Student Population Net Increase in Tripsa Net Inbound/ Outbound Trips 1,773 2,291 260 155/105 a 29.29%increase relative to existing driveway vehicle counts. SOURCE: Wilson, 2009, 2010; Intersection Levels of Service Comment states that study intersections are not quantified in terms of additional delay attributable to the increased traffic. Commenter also states there is no comparison between cumulative with project and cumulative without project. Response: Table 8 of the Initial Study presents the project’s contribution to delay at the study intersection under the Existing plus Project scenario (under Project) in seconds of delay at the intersection per standard traffic engineering practices. This is directly applicable to Existing Conditions only but can serve as a broad estimate of the project related increases in delay at the study intersections under cumulative conditions. The key issue is all intersections are forecast to continue to operate acceptably under Cumulative Conditions regardless of any increase in delay. 3 As noted in the Initial Study discussion, with the addition of project-generated traffic, the study intersections would continue to operate at acceptable levels of service during the a.m. peak hour, and therefore, the project would have a less than significant impact on intersection delay. Likewise, intersection delay analysis under cumulative conditions, found that with project related trips, the intersections would operate at acceptable levels of service, also, having a less than significant impact. However, because the trip generation analysis was revised per public comments intersection level of service has also been revised. As such Table 8 of the Initial Study as been revised as follows: TABLE 8 EXISTING AND FUTURE LEVELS OF SERVICE (LOS) AND AVERAGE VEHICLE DELAY (seconds/vehicles)a Control Existing Existing + Project Cumulative w/Project Intersection Typeb Delayc LOS Delayc LOS Delayc LOS AM Peak Hour El Camino Real and Embarcadero Road Signal 43.9 D 44.2 D 48.6 D Embarcadero Road and School Driveway Signal 9.4 A 10.0 B+ 10.7 B+ El Camino Real and Churchill Avenue Signal 22.8 C+ 23.5 C 23.8 C Churchill Avenue and Alma Street Signal 35.0 C- 35.6 D+ 42.9 D Churchill Avenue and School Driveway TWSC a LOS calculations performed for using TRAFFIX and the 2000 Highway Capacity Manual operations analysis methodology. b Type of control, Signalized or TWSC = Two-way stop (sign) controlled c Represents overall intersection delay of intersections SOURCE: Wilson (2009) As noted in the Initial Study, all studied intersections are currently operating at acceptable levels. With the addition of the project generated traffic, the Cumulative Conditions, the delay would increase at the studied intersections, but would continue to operate at an acceptable level during the a.m peak hour. Therefore, the project’s impact to Cumulative Conditions would be less than significant. Traffic Demand Management (TDM) Policies and Implementation Comment states the current and proposed TDM plans are 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 Response: No specific traffic related impacts requiring mitigation were identified at this school site. Mitigation Measure TRANS-2, which addresses onsite circulation, includes the following revisions which identify TDM policies which would be implemented by the school as part of an overall traffic reduction program. These could be implemented, and monitored, when the Level of Services becomes a LOS F: 4 • Investigate and provide additional Embarcadero Shuttles to Palo Alto High School during the morning peak hour. • Provide 250 VTA Eco Passes to students free of charge. This is an estimated charge of $9,000 to the districts per year. • Coordinate a voluntary ride-sharing program. • Increase the number of bike racks in campus to encourage less driving. In addition, the following TDM efforts would be included as part of the Master Plan • Increase of bike racks. This also includes additional bike racks near the Media Arts Center, close to the Cal-Train entrance. • Parking re-stripping plan 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. Response: Mitigation Measure TRANS-2, which addresses onsite circulation, includes the following revisions which identify when the TDM policies would be implemented and outlines additional policies that would be added to the current program: • Provide additional staff at the Churchill and School Driveway entrance. 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 22 and the Embarcadero Shuttle, currently provide service in the vicinity of the project. Review of current operations of Route 22 with VTA Staff indicates there is excess capacity available. The buses are articulated with a seating capacity of 55 max and standing capacity of about 80 and run on 12 minute headways during peak periods. Since the school is close to the end of the line in Palo Alto, the passenger load in that area is not very high (as compared to downtown San Jose, for example). Approximately 7 to 10 students currently use Route 22. The proposed project which would increase student population by 29.22 percent would increase ridership on these two lines. Both lines have sufficient capacity in accommodate new patrons related to the proposed project. Further, as noted under the TDM response above and under revised Mitigation Measure TRANS-2, the PAUSD would provide 250 VTA Eco Passes to student free of charge. These additional trips can be accommodated under the existing capacity of the transit service. 5 Mode Conflicts Comment indicates intersections with potential conflicts between vehicles and bicycles/pedestrians were not discussed: Churchill Avenue/Casteilleja Avenue and Embarcadero Road/school entrance. Response: Intersections selected for analysis were chosen as those adjacent to the school site and most affected by potential project trip generation and trip distribution. Intersections selected for analysis represent those with the potential to have significant operational impacts due to the increase in the student population at the site. However, as presented in Table 8, as revised in this memorandum, the project is forecast to have a less than significant impact on study intersections. The following intersections were analyzed in the Initial Study: • El Camino Real and Embarcadero Road • Embarcadero Road and School Driveway • El Camino Real and Churchill Avenue • Churchill Avenue and Alma Street • Churchill Avenue and School Driveway Relative to Embarcadero Road and the school entrance, the city is signalizing the intersection which will further reduce conflicts. In addition, currently there is a separate signalized pedestrian crossing which will remain. Bicycle and pedestrian access to the campus was discussed under Section 15, Transportation, checklist item d. As noted in the discussion, the increase in students, and thus pedestrians and cyclists to the campus would use existing facilities and although there would be an increase in the potential for interaction between vehicles and these travel modes, there are no apparent safety concerns between the increase in students and the existing facilities. In addition, the traffic and circulation project, as part of the Master Plan, will address: • Bike path improvements • Embarcadero Road and School Entrance circulation • Churchill Avenue and School Driveway circulation • Bike access improvements at the Churchill entrance High Speed Rail Comment mentions impact of possible high speed rail adjacent to high school campus. Response: At this time it is difficult to determine what the impact of the proposed high-speed rail would be as there is no current program or design. As this is an existing school campus, and the proposed project would increase student population in campus core, the high speed-rail would have similar impacts to that of the existing Caltrain service. The impacts of a high speed rail line related to noise would be similar to the conditions outlined in the Initial Study in Section 11, Noise. It should be noted that PAUSD is following the proposed project, and will assure that potential safety, noise, and visual impacts related to the rail line would be fully mitigated along the school boundary. 6 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 Palo Alto 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. Drainage and Stormwater Comment notes existing drainage problems have not been addressed and that a landscape architect has not yet generated a proposal to keep stormwater on the campus; requests more specific details. Response: As described in the project description of the Initial Study, the Palo Alto 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. Aesthetics Landscape Master Plan. Comment states that the visual impact of the proposed theater on the Haymarket and Tower buildings is not adequately addressed, and requests that renderings of the new theater should be made available. Response: As described in the project description of the Initial Study, the Palo Alto High School Master Plan is a planning level document and as such no renderings, massing studies, or landscaping plans have been prepared. A landscape master plan is currently in programming for conceptual design. 7 Greenhouse Gases Greenhouse Gases and Land Use Comment states the greenhouse gas analysis does not link with the land use discussion. Response: Potential impacts regarding the emissions of greenhouse gases are discussed at length in Section 3, Air Quality of the Initial Study. The proposed project, the Palo Alto High School Master Plan, would not result in any significant impacts due to emissions of greenhouse gases through implementation of Mitigation Measure AIR-2, which identifies several measures designed to reduce the impact to a less than significant level. 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. Response: The trip generation estimates were revised to address public comments and the net new morning vehicle trips were increased by approximately 29 percent. Page 34 of the Initial Study, is updated as follows to reflect the increase in vehicle trips: 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 886 1,143 net daily vehicle trips. Increased vehicle trips would lead to a small increase in ROG (approximately 3.9 4.8 pounds per day), NOx (approximately 3.7 4.7 pounds per day) and PM-10 (approximately 11.5 14.8 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 0.08 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. The modified trip generation would also increase noise, but as noted in Table 2 of Section 11, Noise of the Initial Study, 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, the increased trip generation rates would not increase roadway noise that would result in a significant impact. Table 2 of the Initial Study is updated to reflect the increase vehicle trips as follows: 8 TABLE 2 TRAFFIC NOISE INCREASES IN ROADSIDE LEQ Road Segment Existing Existing + Project Contribution of Proposed Project Modeled Cumulative Year 2018 with Proposed Project Modeled Cumulative Incremental Increase 2009 vs 2018 with Proposed Project) 1. Embarcadero Road (between Kingsley Avenue and Paly Driveway) 62.9 63.4 0.5 64.5 1.6 2. El Camino Real (between Churchill Avenue and Embarcadero Road) 69.3 69.5 0.2 70.2 0.9 3. Churchill Avenue (between Paly Driveway and El Camino Real) 59.8 60.2 0.4 60.3 0.5 4. Churchill Avenue (between Emerson Street and Alma Street) 57.1 57.4 0.3 59.6 2.5 5 Alma Street (between Kellogg Avenue and Churchill Avenue) 68.7 68.9 0.2 67.6 - 1.1b 6. Alma Street (between Coleridge Avenue and Churchill Avenue) 69.4 69.6 0.2 68.8 - 0.6b 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 foe El Camino Real and Alma Streets for which the assumed speed was 35 miles per hour. b A decrease in noise is predicted at these segments because traffic projections predict a decrease in northbound roadway volumes by 2018. SOURCE: ESA, 2010. Land Use 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 24 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 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 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:Friday, October 30, 2009 2:39 PM To:Lesley Lowe; Cory Barringhaus Subject:FW: Comments on Draft Mitigated Negative Declaration for Palo AltoHigh School Master Plan For your review as well, Aimee 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 -----Original Message----- From: Ron Smith [mailto:rsmith@pausd.org] Sent: Friday, October 30, 2009 2:38 PM To: Aimee Lopez Subject: FW: Comments on Draft Mitigated Negative Declaration for Palo Alto High School Master Plan Mo stuff for you! Happy Friday R -----Original Message----- From: Sue Ma [mailto:SMa@waterboards.ca.gov] Sent: Friday, October 30, 2009 2:24 PM To: Ron Smith; Tom Hodges Cc: Joe Teresi; Ken Torke; Phil Bobel; Brian Wines; Dale Bowyer Subject: Comments on Draft Mitigated Negative Declaration for Palo Alto High School Master Plan Greetings: Water Board staff has reviewed the Draft Mitigated Negative Declaration for the Palo Alto High School Master Plan project located at 50 Embarcadero Road, southeast of the intersection of Embarcadero Road and El Camino Real in the city of Palo Alto. The proposed project features construction of new buildings and other structures, including a new two-story, 27-room classroom building and a two-story media 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. 2 Please call or email me if you have any questions. Sue Ma Water Resources Control Engineer 1515 Clay Street, Suite 1400 Oakland, CA 94612 510-622-2386 FAX 510-622-2460 SMa@waterboards.ca.gov 1524 Channing Ave. Palo Alto, CA 94303 November 17, 2009 Tom Hodges PAUSD 25 Churchill Ave., Building D Palo Alto, CA 94306 Dear Mr. Hodges, I would like to comment on several sections of the Draft Initial Study/Mitigated Negative Declaration that was prepared for 50 Embarcadero Rd, Palo Alto High School, pursuant to the California Environmental Quality Act (CEQA). Aesthetics. This section does not adequately address the visual impact of the proposed theater on the historic Haymarket and Tower Buildings and the large open expanse of trees (arboretum) that now exists at the Embarcadero entrance. Based on the orientation of the Tower Building, Paly’s main entrance may appear to be on El Camino Real. However, the official address of the school is 50 Embarcadero Rd. In addition, a far greater number of visitors and students enter the campus through the Embarcadero driveway and/or crosswalk entrances than through the El Camino entrance. The Haymarket Theater and the Tower Building have always been and should remain the central feature of Paly’s main entrance. Traditionally, these buildings have been nestled within an attractive landscape that includes trees, plants and lawn, or in other words, a tranquil setting that accentuates the buildings’ architectural beauty. A landscaping firm has now been hired (as of October 2009) by the Palo Alto Unified School to create a landscape master plan, a central focus of which will be to further beautify and enhance the school’s entrance, and in particular, these buildings and the nature that surrounds them. The conclusions of the reviewer are based on incomplete information and therefore cannot be considered conclusive. Two major pieces of information are lacking. First of all, the landscape architect has not yet adequately studied and created designs for the main entrance. Landscape designs of the main entrance that include and do not include the proposed theater have yet to be presented to the public. It is essential that the public and the reviewer be given both types of designs to be able to adequately evaluate the true aesthetic and environmental impact of the proposed new theater on the historic buildings and the character of the main entrance. In conjunction with the landscape designs of the main entrance, the public and the reviewer needs to be able to see and evaluate one or more potential architectural renderings of the new theater. The reviewer claims that the new theater will not significantly impact the Haymarket or Tower Building, because it will lie 200 ft. from the theater. Merely citing a particular distance, in this case 200 ft, is not enough conclude that there will be no visual impact on the historic structures. Again, the true style, orientation, and size of the theater need to be understood by both the public and reviewer before an adequate statement can be made regarding their environmental impact. On a separate but related topic, the visual impact of the proposed new theater on the student, staff, and visitor experiences of entering or leaving the campus via the driveway and crosswalk entrances were not discussed in this report. Currently students are treated to a wide-open vista of trees, which extends as far as the Stanford arboretum, when they enter the campus via the crosswalk entrance. This vista will be significantly diminished if the proposed new theater is constructed. Similarly the wide vista of treetops that includes trees near the railroad tracks and across to Town and Country village, will be significantly diminished by visitors, staff and students entering the campus through the driveway entrance. If the new theater is built, the main entrance will forevermore have the feel of a more constricted and confined space. The arboretum, the entire collection of trees at the entrance that is a learning space and tranquil area for students to walk through and relax, will be diminished by the construction of a theater in the currently proposed location. This arboretum has space for at least 200 trees. Currently, 25 different species of trees grow in this part of campus. At its present size, future generations of students and staff will have room to create native plant gardens and ecological laboratories. There is space for sculptures and other student art. In reducing this large expanse of open space and trees, which is one of the largest and most beautiful urban parking areas in the City of Palo Alto, both the community at large and the student body will lose a valuable resource. Hydrology. The report does not adequately discuss the difficult problems with drainage on the Paly campus and the limits of the City of Palo Alto’s storm sewer system. A serious problem with the on-going construction at Paly is the net increase in impervious or nearly impervious surface due to all of the proposed and completed projects. Here is a list of these projects with their approximate dates of completion: a) 2004- Science building completed as a large ONE-story building on the west side of the quad. This building could have been built as two-story building with a much smaller footprint. b) Summer 2007 - quarter acre at the El Camino/Embarcadero entrance paved over for (rarely used) parking c) About 2008 - Football field covered with synthetic (nearly impermeable) turf d) Summer 2009 - Three large palm trees and row of mature healthy Eucalyptus trees were removed between Tower building and El Camino field. Replaced by about 6-7 large black poles that will hold a giant net. e) Expansion of the Embarcadero entrance - loss of a mature sycamore. f) Fall 2009 - El Camino field covered with synthetic turf. g) 2011- Classroom building will replace portables that were on land that was once a large beautiful lawn h) 2011-Media-Arts building will replace portables on space that was once a natural area i) 2012- New Theater will replace land that holds or could hold 15 mature trees and many plants. j) 2013- A new Fitness Center will be built and cover a significant portion of open space between the old gym and the new gym. k) After 2018- The Student Center will be expanded covering more open space between the current student center and the El Camino Field. Because Palo Alto’s storm sewer has limited capacity, it is essential that stormwater be retained on campus. However, the landscape architect has not generated a proposal for how to keep stormwater on campus. Before stating that the projects will have a less than significant impact on stormwater runoff, the reviewer and the public need to know more specifics of how this retention will be achieved. Mandatory Findings of Significance. The land losses listed above affect more than simply hydrology. They result in less nature for students to enjoy during the course of their days on campus. Future generations will have less (if any) open space on which to build. There will be less room for outdoor educational activities such as a native plant garden, compost pile, an organic garden, or various outdoor classrooms. These environmental impacts are given short shrift or not mentioned at all in the report. But they do have a substantial effect on the quality of life for students and staff on the campus. They also give the community less flexibility to deal with further growth in its student population. Climate change impacts. Climate change is discussed under air quality in the report. However, this is not tied into the land use section of the report. To reduce the impact of any project on climate change, an essential first step is to study how best to use the land. How can the buildings and land be best used to make the lowest impact on greenhouse gas emissions? This was niether discussed in the report nor has it been adequately explored or addressed by the district in a transparent manner during their planning process. There are alternative designs for the master plan that would have less of an impact on greenhouse gas emissions. The district has failed to prepare and present these plans to the community for evaluation and comparison to the current plan. Thank you for taking the time to prepare the report and to read these comments. Please keep me apprised as the CEQA process moves forward. Best regards, Kirsten Essenmacher Lesley Lowe From: Aimee Lopez [alopez@ocmi.com] Sent: Thursday, November 19, 2009 8:50 AM To: Lesley Lowe; Cory Barringhaus Cc: 'John Wilson' Subject: FW: CEQA Comments Page 1 of 3 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: Thursday, November 19, 2009 6:38 AM To: Aimee Lopez Subject: Fw: CEQA Comments From: candersonb@aol.com <candersonb@aol.com> To: thodges@pausd.org <thodges@pausd.org> Cc: jberkson@pausd.org <jberkson@pausd.org>; rgolton@pausd.org <rgolton@pausd.org>; cycampen@pacbell.net <cycampen@pacbell.net> Sent: Wed Nov 18 23:12:29 2009 Subject: CEQA Comments Good Evening, I would like to submit the following comments in regards to the Palo Alto High School Master Plan, CEQA specifically related to the Transportation/Traffic section. TRANSPORTATION/TRAFFIC Bike cages are generally located at three points in the central area of the campus, including near the gym, near the science building, and near the student center. There is currently one bike cage near the gym, bike racks near the science building and bike racks near the Haymarket Theatre/Arts Building. Approximately 25-30+ students lock their bikes to the fence along the bike path that runs alongside the Cal Train tracks. It would be helpful if the CEQA document specified how many additional bike parking spaces are required to accommodate growth. 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 540. The high school would continue to encourage bicycling to campus as part of their Transportation Demand Management program, and thus would provide adequate and secure bicycle parking, in the form of bicycle cages, at convenient and commute entrances. Their counts seem low and they acknowledged that the PTSA counts were 27% higher (520 vs. 410) as the counts took place during a warmer month. Why weren't these higher numbers used to estimate future needs. They also refer to a TDM program that is run with some variability by volunteers - a PTSA Traffic Safety Representative and members of Paly's Green Team. Is PAUSD planning to organize a program with dedicated staff to insure sustainability? Mitigation Measure TRAN-2: PAUSD shall integrate the following measures to reduce potential queuing impacts: • Circulate informational flyers to parents and students that discuss on-site 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 on-site traffic during peak drop-off/pick- up times both before and after school (i.e., 7:45 a.m. to 8:00 a.m.). I would question the effectiveness of informational flyers and the use of staff to monitor and direct on-site traffic. Funding for additional staff resources might be necessary to accomplish this. PTA volunteers CANNOT direct traffic. Our insurance policy explicitly declares that we are not covered for directing traffic. 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. There are two areas that have potential for conflict between vehicles and bicycles: Churchill at the Castilleja driveway and possibly along Embarcadero near the school entrance. With no stop signs on Churchill, bicycles and vehicles make right turns into the school driveway at the same time in the AM. Bicycles make a right turn from the bike lane on Churchill to the street/driveway at Castilleja. No bike lanes exist along the driveway. During the PM, bikes exit the school along the bike/pedestrian path, turn left and travel the wrong way on Churchill. Bikes cross at Alma and eventually cross Churchill (usually mid block). Bikes use the bike/pedestrian path because there is so much outbound traffic on Churchill making the crosswalk at Castilleja difficult to use. 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. Paid parking permits are distributed to eligible students. The carpooling program was eliminated last year by Paly staff because it was difficult to monitor. At present, Page 2 of 3 1/29/2010 the TDM program at Paly is comprised of bike/ped encouragement events that are organized by the PTSA Traffic Safety Rep and the Green Team. Additionally, the Traffic Safety Rep provides advocacy support of engineering improvements to campus and school routes that support alternative modes. Students are encouraged to use the Palo Alto Shuttle. Many do. (Shuttle funding may be in jeopardy with proposed Tier II CPA budget cuts to be considered by City Council Finance Committee in December 2009). The Paly Green Team supports/promotes bicycling/walking/pubic transit as one of their programs, however; there is no group (student/teacher/parent) dedicated to a TDM program at Paly. Thank you for your consideration of the above comments. Best regards, Carol Anderson PTSA Traffic Safety Representative Palo Alto High School Page 3 of 3 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