4.7 HAZARDS AND HAZARDOUS MATERIALS

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1 4.7 This chapter discusses the regulatory framework, existing conditions, and potential environmental impacts related to hazards and hazardous materials in Palo Alto as a result of the proposed Plan. Hazardous materials refer generally to hazardous substances that exhibit corrosive, poisonous, flammable, and/or reactive properties and have the potential to harm human health and/or the environment. Hazardous materials are used in products (e.g., household cleaners, industrial solvents, paint, pesticides) and in the manufacturing of products (e.g., electronics, newspapers, plastic products). Hazardous materials can include petroleum, natural gas, synthetic gas, acutely toxic chemicals, and other toxic chemicals that are used in agriculture, industrial uses, businesses, hospitals, and households. Accidental releases of hazardous materials have a variety of causes, including roadway incidents, warehouse fires, train derailments, shipping accidents, and industrial incidents. The term hazardous materials, as used in this chapter, includes all materials defined in the California Health and Safety Code (H&SC): A material that, because of its quantity, concentration, or physical or chemical characteristics, poses a significant present or potential hazard to human health and safety or to the environment if released into the workplace or the environment. Hazardous materials include, but are not limited to, hazardous substances, hazardous waste, and any material that a handler or the unified program agency has a reasonable basis for believing that it would be injurious to the health and safety of persons or harmful to the environment if released into the workplace or the environment. The term includes chemicals regulated by the United States Department of Transportation (DOT), the United States Environmental Protection Agency (EPA), the California Department of Toxic Substances Control (DTSC), the California Governor s Office of Emergency Services (Cal OES), and other agencies as hazardous materials, wastes, or substances. Hazardous waste is any hazardous material that has been discarded, except those materials specifically excluded by regulation. Hazardous materials that have been intentionally disposed of or inadvertently released fall within the definition of discarded materials and can result in the creation of hazardous waste. Hazardous wastes are broadly characterized by their ignitability, toxicity, corrosivity, reactivity, radioactivity, or bioactivity. Federal and State hazardous waste definitions are similar, but contain enough distinctions that separate classifications are in place for federal Resource Conservation and Recovery Act (RCRA) hazardous wastes and State non-rcra hazardous wastes. Hazardous wastes require special handling and disposal because of their potential to impact public health and the environment. Some materials are designated acutely or extremely hazardous under relevant statutes and regulations. PLACEWORKS 4.7-1

2 4.7.1 ENVIRONMENTAL SETTING REGULATORY FRAMEWORK Hazardous materials and wastes can pose a significant actual or potential hazard to human health and the environment when improperly treated, stored, transported, disposed of, or otherwise managed. Many federal, State, and local programs that regulate the use, storage, and transportation of hazardous materials and hazardous waste are in place to prevent these unwanted consequences. These regulatory programs are designed to reduce the danger that hazardous substances may pose to people and businesses under normal daily circumstances and as a result of emergencies and disasters. Federal Regulations United States Environmental Protection Agency The EPA is the primary federal agency that regulates hazardous materials and waste. In general, the EPA works to develop and enforce regulations that implement environmental laws enacted by Congress. The agency is responsible for researching and setting national standards for a variety of environmental programs and delegates to states and Native American tribes the responsibility for issuing permits and for monitoring and enforcing compliance. EPA programs promote handling hazardous wastes safely, cleaning up contaminated land, and reducing waste volumes through such strategies as recycling. California falls under the jurisdiction of EPA Region 9. Under the authority of RCRA, and in cooperation with State and tribal partners, the EPA Region 9 Waste Management and Superfund Divisions manage programs for site environmental assessment and cleanup, hazardous and solid waste management, and underground storage tanks. United States Department of Transportation Transportation of chemicals and hazardous materials are governed by the DOT, which stipulates the types of containers, labeling, and other restrictions to be used in the movement of such material on interstate highways. Occupational Safety and Health Administration The Occupational Safety and Health Administration (OSHA) oversees administration of the Occupational Safety and Health Act, which requires: specific training for hazardous materials handlers; provision of information to employees who may be exposed to hazardous materials; and acquisition of material safety data sheets (MSDS) from materials manufacturers. Material safety data sheets describe the risks, as well as proper handling and procedures, related to particular hazardous materials. Employee training must include response and remediation procedures for hazardous materials releases and exposures FEBRUARY 5, 2016

3 Resource Conservation and Recovery Act of 1976, as Amended by the Hazardous and Solid Waste Amendments of 1984 Federal hazardous waste laws are generally promulgated under the RCRA. These laws provide for the cradle to grave regulation of hazardous wastes. Any business, institution, or other entity that generates hazardous waste is required to identify and track its hazardous waste from the point of generation until it is recycled, reused, or disposed. The DTSC is responsible for implementing the RCRA program, as well as California s own hazardous waste laws, which are collectively known as the Hazardous Waste Control Law. Under the Certified Unified Program Agency (CUPA) program, the California Environmental Protection Agency (CalEPA) has, in turn, delegated enforcement authority to the County of Santa Clara for State law regulating hazardous waste producers or generators in the EIR Study Area. Comprehensive Environmental Response, Compensation, and Liability Act and the Superfund Amendments and Reauthorization Act of 1986 Congress enacted the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as Superfund, on December 11, CERCLA established prohibitions and requirements concerning closed and abandoned hazardous waste sites; provided for liability of persons responsible for releases of hazardous waste at these sites; and established a trust fund to provide for cleanup when no responsible party could be identified. Superfund Amendments and Reauthorization Act (SARA) amended CERCLA on October 17, The SARA stressed the importance of permanent remedies and innovative treatment technologies in cleaning up hazardous waste sites; required Superfund actions to consider the standards and requirements found in other federal and State environmental laws and regulations; provided new enforcement authorities and settlement tools; increased State involvement in every phase of the Superfund program; increased the focus on human health problems posed by hazardous waste sites; encouraged greater citizen participation in making decisions on how sites should be cleaned up; and increased the size of the trust fund to $8.5 billion. Emergency Planning Community Right-to-Know Act The Emergency Planning Community Right-to-Know Act (EPCRA), also known as SARA Title III, was enacted in October This law requires any infrastructure at the State and local levels to plan for chemical emergencies. Reported information is then made publicly available so that interested parties may become informed about potentially dangerous chemicals in their community. EPCRA Sections 301 through 312 are administered by EPA s Office of Emergency Management. EPA s Office of Information Analysis and Access implements the EPCRA Section 313 program. In California, SARA Title III is implemented through the California Accidental Release Program (CalARP). The State of California has delegated local oversight authority of the CalARP program to the County of Santa Clara. Hazardous Materials Transportation Act The DOT regulates hazardous materials transportation under Title 49 of the Code of Federal Regulations (CFR). State agencies that have primary responsibility for enforcing federal and State regulations and PLACEWORKS 4.7-3

4 responding to hazardous materials transportation emergencies are the California Highway Patrol and the California Department of Transportation (Caltrans). The California State Fire Marshal s Office has oversight authority for hazardous materials liquid pipelines. The California Public Utilities Commission has oversight authority for natural gas pipelines in California. These agencies also govern permitting for hazardous materials transportation. Federal Response Plan The Federal Response Plan of 1999 is a signed agreement among 27 federal departments and agencies and other resource providers, including the American Red Cross, that: 1) provides the mechanism for coordinating delivery of federal assistance and resources to augment efforts of State and local governments overwhelmed by a major disaster or emergency; 2) supports implementation of the Robert T. Stafford Disaster Relief and Emergency Assistance Act, as well as individual agency statutory authorities; and 3) supplements other federal emergency operations plans developed to address specific hazards. The Federal Response Plan is implemented in anticipation of a significant event likely to result in a need for federal assistance or in response to an actual event requiring federal assistance under a Presidential declaration of a major disaster or emergency. The Federal Response Plan is part of the National Response Framework. The Stafford Act The Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act) of 1988 authorizes the federal government to provide assistance in emergencies and disasters when State and local capabilities are exceeded. The Stafford Act constitutes statutory authority for most federal disaster response activities especially as they pertain to the Federal Emergency Management Agency (FEMA) and FEMA programs. National Response Framework The 2013 National Response Framework, published by the Department of Homeland Security, is a guide to how the Nation responds to all types of disasters and emergencies. The Framework describes specific authorities and best practices for managing incidents that range from serious local to large-scale terrorist attacks or catastrophic natural disasters. In addition, the Framework describes the principles, roles, responsibilities, and coordinating structures for responding to an incident and further describes how response efforts integrate with those of the other mission areas. Homeland Security Presidential Directive No. 5 Through the development of a National Incident Management System (NIMS), Presidential Directive 5 is intended to prevent, prepare for, respond to, and recover from terrorist attacks, major disasters, and other emergencies through a single, comprehensive approach to domestic incident management. The objective of the Directive is to ensure that all levels of government across the nation have the capability to work efficiently and effectively together, using a national approach FEBRUARY 5, 2016

5 Homeland Security Presidential Directive No. 8 Presidential Directive 8 establishes policies for strengthening national preparedness, including the National Preparedness Goal and Target Capabilities List. Directive 8 required the preparation of an implementation plan that described the departmental responsibilities and delivery timelines for the development of the national planning frameworks and associated interagency plans. State Regulations California Environmental Protection Agency CalEPA was created in 1991 by Governor Executive Order W Several State regulatory boards, departments, and offices were placed under the CalEPA umbrella to create a cabinet-level voice for the protection of human health and the environment and to assure the coordinated deployment of State resources. Among those responsible for hazardous materials and waste management are the DTSC, Department of Pesticide Regulation, and Office of Environmental Health Hazard Assessment (OEHHA). CalEPA also oversees the unified hazardous waste and hazardous materials management regulatory program (Unified Program), which consolidates, coordinates, and makes consistent the following six programs: Hazardous Materials Release Response Plans and Inventories (Business Plans) Underground Storage Tank Program Aboveground Petroleum Storage Tank Act Hazardous Waste Generator and Onsite Hazardous Waste Treatment Programs California Uniform Fire Code: Hazardous Material Management Plans and Inventory Statements CalARP California Department of Toxic Substances Control The California DTSC, which is a department of CalEPA, is authorized to carry out the federal RCRA hazardous waste program in California to protect people from exposure to hazardous wastes. The department regulates hazardous waste, cleans up existing contamination, and looks for ways to control and reduce the hazardous waste produced in California, primarily under the authority of RCRA and in accordance with the California Hazardous Waste Control Law (California H&SC Division 20, Chapter 6.5) and the Hazardous Waste Control Regulations (Title 22, California Code of Regulations (CCR), Divisions 4 and 4.5). Permitting, inspection, compliance, and corrective action programs ensure that people who manage hazardous waste follow federal and State requirements and other laws that affect hazardous waste specific to handling, storage, transportation, disposal, treatment, reduction, cleanup, and emergency planning. State Water Resources Control Board The San Francisco Bay Regional Water Quality Control Board (RWQCB) is authorized by the State Water Resources Control Board (SWRCB) to enforce provisions of the Porter-Cologne Water Quality Control Act PLACEWORKS 4.7-5

6 of This act gives the San Francisco RWQCB authority to require groundwater investigations when the quality of groundwater or surface waters of the State is threatened and to require remediation actions, if necessary. California Division of Occupational Safety and Health Like OSHA at the federal level, the California Division of Occupational Safety and Health (Cal OSHA) is the responsible State-level agency for ensuring workplace safety. Cal OSHA assumes primary responsibility for the adoption and enforcement of standards regarding workplace safety and safety practices. In the event that a site is contaminated, a Site Safety Plan must be crafted and implemented to protect the safety of workers. Site Safety Plans establish policies, practices, and procedures to prevent the exposure of workers and members of the public to hazardous materials originating from the contaminated site or building. California Department of Forestry and Fire Protection The California Department of Forestry and Fire Protection (CAL FIRE) has mapped fire threat potential throughout California. 1 CAL FIRE ranks fire threat based on the availability of fuel and the likelihood of an area burning (based on topography, fire history, and climate). The rankings include no fire threat and moderate, high, and very high fire threat. Additionally, CAL FIRE produced a 2010 Strategic Fire Plan for California that contains goals, objectives, and policies to prepare for and mitigate the effects of fire on California s natural and built environments. 2 CAL FIRE s Office of the State Fire Marshal provides oversight of enforcement of the California Fire Code as well as overseeing hazardous liquid pipeline safety. California Department of Transportation Caltrans manages more than 50,000 miles of California's highway and freeway lanes, provides inter-city rail services, permits more than 400 public-use airports and special-use hospital heliports, and works with local agencies. Caltrans is also the first responder for hazardous material spills and releases that occur on those highway and freeway lanes and inter-city rail services. California Health and Safety Code California H&SC, Division 20, Chapter 6.95, and Title 19 of the California Code of Regulations, Section 2729, set out the minimum requirements for business emergency plans and chemical inventory reporting. These regulations require businesses to provide emergency response plans and procedures, training program information, and a hazardous material chemical inventory disclosing hazardous materials stored, used, or handled on site. A business which uses hazardous materials or a mixture containing hazardous materials must establish and implement a business plan if the hazardous material is handled in certain quantities. 1 CAL FIRE, available online at accessed February 3, CAL FIRE, 2010 Strategic Fire Plan for California, available online at fpppdf668.pdf, accessed February 3, FEBRUARY 5, 2016

7 California Education Code The California Education Code (CEC) establishes the law for California public education. CEC requires that the DTSC be involved in the environmental review process for the proposed acquisition and/or construction of school properties that will use State funding. The CEC requires that a Phase I Environmental Site Assessment be completed prior to acquiring a school site or engaging in a construction project. Depending on the outcome of the Phase I Environmental Site Assessment, a Preliminary Environmental Assessment and remediation may be required. The CEC also requires potential, future school sites that are proposed within two miles of an airport to be reviewed by the Caltrans Division of Aeronautics. If Caltrans does not support the proposed site, no State or local funds can be used to acquire the site or construct the school. California State Aeronautics Act The State Aeronautics Act is implemented by the Caltrans Division of Aeronautics. The purpose of this Act is to: 1) foster and promote safety in aeronautics; 2) ensure that State provides laws and regulations relating to aeronautics are consistent with federal aeronautics laws and regulations; 3) assure that persons residing in the vicinity of airports are protected against intrusions by unreasonable levels of aircraft noise; and 4) develop informational programs to increase the understanding of current air transportation issues. The Caltrans Division of Aeronautics issues permits for and annually inspects hospital heliports and public-use airports, makes recommendations regarding proposed school sites within two miles of an airport runway, and authorizes helicopter landing sites at or near schools. California Building Code The State of California provides a minimum standard for building design through Title 24 of the California Code of Regulations (CCR), also known as the California Building Standards) Code. The 2013 California Building Code (CBC), is Part 2 of Title 24. The 2013 CBC is based on the 2012 International Building Code, but has been modified for California conditions. It is generally adopted on a jurisdiction-by-jurisdiction basis, subject to further modification based on local conditions. Commercial and residential buildings are plan-checked by local City and County building officials for compliance with the CBC Typical fire safety requirements of the CBC include the installation of sprinklers in all new high-rise buildings and residential buildings; the establishment of fire resistance standards for fire doors, building material; and particular types of construction. California Fire Code The California Fire Code (CFC) is Part 9 of Title 24. Updated every the years, the CFC includes provisions and standards for emergency planning and preparedness, fire service features, fire protection systems, hazardous materials, fire flow requirements, fire hydrant locations and distribution, and the clearance of debris and vegetation within a prescribed distance from occupied structures in wildlife hazard areas. The Palo Alto Fire Department provides fire protection services for the City and, as such, implements and enforces the CFC in Palo Alto. PLACEWORKS 4.7-7

8 Asbestos-Containing Materials (ACM) Regulations State-level agencies, in conjunction with the federal EPA and OSHA, regulate removal, abatement, and transport procedures for asbestos-containing materials (ACM). Releases of asbestos from industrial, demolition, or construction activities are prohibited by these regulations and medical evaluation and monitoring is required for employees performing activities that could expose them to asbestos. Additionally, the regulations include warnings that must be heeded and practices that must be followed to reduce the risk for asbestos emissions and exposure. Finally, federal, State, and local agencies must be notified prior to the onset of demolition or construction activities with the potential to release asbestos. Polychlorinated Biphenyls The United States EPA prohibited the use of polychlorinated biphenyls (PCBs) in the majority of new electrical equipment starting in 1979, and initiated a phase-out for much of the existing PCB-containing equipment. The inclusion of PCBs in electrical equipment and the handling of those PCBs are regulated by the provisions of the Toxic Substances Control Act (TSCA), United States Code Title 15, Section 2601 et seq. Relevant regulations include labeling and periodic inspection requirements for certain types of PCBcontaining equipment and outline highly specific safety procedures for their disposal. Likewise, the State of California regulates PCB-laden electrical equipment and materials contaminated above a certain threshold as hazardous waste. These regulations require that such materials be treated, transported, and disposed accordingly. At lower concentrations for non-liquids, RWQCBs may exercise discretion over the classification of such wastes. Lead-Based Paint Cal OSHA s Lead in Construction Standard is contained in Title 8 CCR, Section The regulations address all of the following areas: permissible exposure limits (PELs); exposure assessment; compliance methods; respiratory protection; protective clothing and equipment; housekeeping; medical surveillance; medical removal protection (MRP); employee information, training, and certification; signage; record keeping; monitoring; and agency notification. The Childhood Lead Poisoning Prevention Acts (CLPPA) of 1986 and 1989 with Subsequent Legislative Revisions (California H&SC, Division 106, Sections to ) declared childhood lead exposure as the most significant childhood environmental health problem in the state. The CLPPA established the Childhood Lead Poisoning Prevention Program and instructed it to continue to take steps necessary to reduce the incidence of childhood lead exposure in California. California Emergency Services Act, Chapter 7, Division 1, Title 2 of the California Government Code The California Emergency Services Act (ESA) confers emergency powers to the Governor and establishes the California Emergency Management Agency (Cal EMA). The ESA also delineates the emergency responsibilities of State agencies and establishes the State mutual aid system FEBRUARY 5, 2016

9 Standardized Emergency Management System Chapter 1, Division 2, Title 21 of the California Code of Regulations The standardized Emergency Management System (SEMS) is intended to standardize responses to emergencies involving multiple jurisdictions or multiple agencies. SEMS requires that emergency response agencies use basic principles and components of emergency management, multi-agency or inter-agency coordination, the operational area concept, and established mutual aid systems. As of December 1, 1996, local government must use SEMS in order to be eligible for State funding of response-related personnel costs. Governor s Executive Order W-9-91 In 1991, Executive Order W-9-91 established basic emergency preparedness objectives and policies to be carried out by State officials. The order states that California is to maintain a high degree of preparedness in the event of a disaster, such as fire, flood, storm, air pollution, plant or animal infestation, disease, or earthquake. California Disaster and Civil Defense Master Mutual Aid Plan The California Disaster and Civil Defense Master Mutual Aid Plan outlines policies, procedures, and authorities for provision of emergency management personnel from unaffected jurisdictions to support affected jurisdictions during an emergency event, in accordance with the Master Mutual Aid Agreement. The Master Mutual Aid Agreement establishes that jurisdictions should voluntarily aid and assist each other in the event that a disaster should occur, by the interchange of services and facilities, including, but not limited to, fire, police, medical and health, communication, and transportation services and facilities. State of War Emergency Orders and Regulations The State of War Emergency Orders and Regulations establishes broad powers to the Governor to have complete authority over all agencies of the State government and the right to exercise within the area or regions designated all police power vested in the State by the Constitution and laws of the State of California. State Emergency Plan In 2009, the California State Emergency Plan was adopted to address the State s response to extraordinary emergency situations associated with natural disasters or human-caused emergencies. The State Emergency Plan describes the methods for carrying out emergency operations, the process for rendering mutual aid, the emergency services of governmental agencies, and how the public will be informed during an emergency or disaster. PLACEWORKS 4.7-9

10 Regional Regulations Bay Area Air Quality Management District The Bay Area Air Quality Management District (BAAQMD) has primary responsibility for control of air pollution from sources other than motor vehicles and consumer products (which are the responsibility of CalEPA and the California Air Resources Board [CARB]). The BAAQMD is responsible for preparing attainment plans for non-attainment criteria pollutants, control of stationary air pollutant sources, and the issuance of permits for activities including demolition and renovation activities affecting AC (District Regulation 11, Rule 2) and lead (District Regulation 11, Rule 1). Association of Bay Area Governments Multi-Jurisdictional Local Hazard Mitigation Plan for the San Francisco Bay Area The Federal Disaster Mitigation Act of 2000 (DMA) requires all cities, counties, and special districts to adopt a Local Hazard Mitigation Plan (LHMP) to receive disaster mitigation funding from the Federal Emergency Management Agency (FEMA). The DMA provides that a local agency may adopt a Local Hazard Mitigation Plan or participate in the preparation of and adopt a Multi-Jurisdictional Hazard Mitigation Plan. ABAG received funds from FEMA to serve as the lead agency in the creation of a Multi-Jurisdictional Hazard Mitigation Plan for the nine-county Bay Area. With participation from the City of Palo Alto and other local agencies, ABAG created an umbrella Hazard Mitigation Plan entitled Taming Natural Disasters. Regional Catastrophic Earthquake Mass Transportation/Evacuation Plan The Regional Catastrophic Earthquake Mass Transportation/Evacuation Plan (Evacuation Plan) was been prepared for the Bay Area Urban Area Security Initiative Approval Authority on behalf of the counties and cities within 12-county Bay Area region. The Evacuation Plan describes the general strategy for emergency response to an incident with regional impact. The Evacuation Plan was prepared in accordance with the standards of the National Incident Management System, the California Standardized Emergency management System, and other Federal and state requirements and standards for emergency response plan applicable as of the date of the plan s preparation. Further, the Evacuation Plan provides guidance only; it is intended for use in further development of response capabilities, implementation of training and exercises, and defining the general approach to incident response. Local Regulations Santa Clara County Department of Environmental Health A CUPA is a local agency that has been certified by CalEPA to implement the local Unified Program. The CUPA can be a County, City, or joint powers authority. A participating agency is a local agency that has been designated by the local CUPA to administer one or more Unified Programs within their jurisdiction on behalf of the CUPA. A designated agency is a local agency that has not been certified by CalEPA to become a CUPA, but is the responsible local agency that would implement the six Unified Programs until they are FEBRUARY 5, 2016

11 certified. Currently, there are 83 CUPA s in California. The Santa Clara County Department of Health s Hazardous Materials Compliance Division (HMCD) is the certified CUPA for the EIR Study Area and consolidates, coordinates, and makes consistent the following existing programs: Hazardous Materials Release Response Plans and Inventories (Business Plans) CalARP Program Underground Storage Tank Program Hazardous Waste Generator and Onsite Hazardous Waste Treatment (tiered permitting) Programs California Uniform Fire Code: Hazardous Materials Management Plans and Hazardous Material Inventory Statements The County of Santa Clara Ordinance Code, specifically Title B, Division B11, Chapter XIII, contains requirements that pertain to hazardous materials, including containment and disclosure standards; inspections, records, permitting, and enforcement procedures, and remedial action requirements. Santa Clara County Hazard Mitigation Plan Pursuant to the Disaster Mitigation Act, the Santa Clara County s Office of Emergency Services prepared an annex to the 2010 ABAG Local Hazard Mitigation Plan (LHMP) to serve as Santa Clara County s Local Hazard Mitigation Plan. The LHMP emerged from a collaborative planning effort that involved the assembly of a Local Planning Team (LPT) comprised of representatives from County departments, private sector businesses, stakeholders, and 13 of the 15 incorporated cities in Santa Clara County, including Palo Alto. The LHMP identifies and prioritizes potential and existing hazards across jurisdictional borders, including hazards that may be further amplified by climate change. In an effort to guide the County s ongoing hazard mitigation efforts, through the life of the LHMP, the following priority mitigation objectives were identified: Collaborate as a County and create a county-wide Community Wildfire Protection Plan (CWPP). Reduce number of unreinforced masonry/soft-story buildings through demolition or seismic retrofitting. Implement a combination of financial incentives and regulated mandates in order to mitigate the clear and present danger of soft-story buildings pervading Santa Clara County. Engage infrastructure providers in a cooperative partnership with County government to develop a responsible middle ground sharing the most critical infrastructure information with those stakeholders that have a need to know. Collaborate as a County and verify or create the plan for replacing and/or upgrading localized flooding pump systems, including the generation of alternate power to operate these systems. Establish a siren system targeted specifically for catastrophic dam failure to provide a complete public warning system in Santa Clara County. PLACEWORKS

12 In order to meet these priority mitigation objectives, the LHMP further identifies and prioritizes specific actions for each objective. In addition, the responsible departments, potential funding sources, and target completion date are identified for each mitigation action with the highest priority, in order to guide their implementation. Palo Alto Airport Comprehensive Land Use Plan Assembly Bill 2776, which went into effect January 1, 2004, defines an airport influence area as the area where airport-related factors may significantly affect land uses or necessitate restrictions on those uses as determined by an airport land use commission (ALUC). The California Public Utilities Code establishes airport land use commissions in every county to provide for the orderly development of air transportation and ensure compatible land uses around airports that are open to public use. According to the State Division of Aeronautics, the airport influence area is usually the planning area designated by an airport land use commission for each airport. A Comprehensive Land Use Plan (CLUP) was adopted in November 2008 by the Santa Clara County ALUC 3 and provides guidance related to the placement of land uses near the Palo Alto Airport. On June 1, 2009, Palo Alto adopted a Resolution 8935 incorporating the County CLUP into the Comprehensive Plan and adding policies the Land Use Element. Specifically, the CLUP seeks to protect the public from adverse effects of aircraft noise, to ensure that people and facilities are not concentrated in areas susceptible to aircraft accidents, and to ensure that no structures or activities adversely affect navigable airspace. Land use compatibility safety zones established by the CLUP are shown on Figure and discussed further in Chapter 4.9, Land Use and Planning. The safety policies of the CLUP restrict land uses such as schools, hospitals, nursing homes, and other uses in which the majority of occupants are children, elderly, and/or disabled; amphitheaters, sports stadiums and other very high concentrations of people; and storage of fuel or other hazardous materials. City of Palo Alto Annex to the Santa Clara County Local Hazard Mitigation Plan In 2005, the City of Palo Alto adopted an Annex to the 2005 ABAG LHMP. The City's LHMP Annex was updated in 2011 through the regional planning process coordinated by ABAG and the local planning process coordinated by Santa Clara County Office of Emergency Services. A resolution approving the City of Palo Alto Annex was adopted in April City of Palo Alto Municipal Code The Palo Alto Municipal Code contains requirements that pertain to hazards and hazardous materials. For example, the purpose of Title 17 of the Municipal Code is the protection of health, life, resources, and property through prevention and control of unauthorized discharges of hazardous materials. Chapter addresses materials regulated and those that are excluded. Chapter discusses underground storage 3 Santa Clara County Airport Land Use Commissions, 2008, Palo Alto Airport Comprehensive Land Use Plan FEBRUARY 5, 2016

13 tank requirements, including fees, permitting and inspection procedures, and monitoring requirements. Chapter includes containment standards for new and existing storage facilities. Chapters and discuss hazardous materials management plans and hazardous materials inventories, respectively. Reporting responsibilities, inspections, and records are discussed in Chapters and Hazardous materials storage permits are discussed in Chapter Section establishes that the Director of Emergency Services is accountable to the City Manager. 4 Additionally, this section lays out the official duties of the Director of Emergency Services, which includes being responsible for the request for City Council to proclaim a local emergency, to control and direct the City's emergency organization, 5 and to represent the City in all dealings with public or private agencies on matters pertaining to emergencies and disasters. City of Palo Alto Zoning Ordinance The City s Zoning Ordinance, Title 18, Chapters to , Special Regulations for Hazardous Waste Facilities, contains provisions for new or expanded hazardous waste facilities to comply with certain siting criteria, contained in the Santa Clara County Hazardous Waste Management Plan, in order to assure compatibility with neighboring land uses, adequate mitigation for any identified environmental impacts, and consistency with the City s Comprehensive Plan and zoning and the county hazardous waste management plan. The City is currently considering changes to the Zoning Ordinance related to hazardous materials in industrial districts and compatibility with sensitive receptors. The changes would define three tiers of facilities, with requirements for each; define sensitive receptors; establish distances between facilities and sensitive receptors; and establish an amortization schedule and process for non-conforming uses. Along with these changes, the City would make conforming changes to the Fire Code. 6 Palo Alto Fire Department The Palo Alto Fire Department, pursuant to Titles 15 and 17 of the City s Municipal Code, administers the following programs through the Fire Prevention Bureau: California Fire Code (with local amendments) Hazardous Materials Storage Ordinance 4 Per the Municipal Code language, the City Manager is the statutory director of emergency services who appoints the assistant director of emergency services (who has the title of Director of Emergency Services or "OES Chief"). Per the recommendations of the outside consulting firm retained by the City Manager: "The City is advised to appoint a Director of Emergency Services assigned at a senior staff level, with a position description that defines specific responsibility for the City s overall emergency/ disaster readiness.... This position would be a direct report to the City s executive management with organization-wide authority. Available online at filebank/blobdload.asp?blobid=26844, page 8, accessed October 23, Per the recommendations of the ICMA Tri-Data study, the Palo Alto Office of Emergency Services is considered a public safety department, along with the Police Department and the Fire Department, and the Director of Emergency Services retains his status as a sworn officer, available online at civica/filebank/blobdload.asp?blobid=26200,october 23, See Palo Alto Municipal Code Section City of Palo Alto, 2015, presentation to the hazardous materials zoning changes neighborhood meeting, available online at accessed on January 20, PLACEWORKS

14 Toxic Gas Ordinance In addition, as a Participating Agency (PA), the Department also administers the following hazardous materials programs: Hazardous Materials Business Plans (California Health and Safety Code Chapter 6.95) Aboveground Storage Tanks (California Health and Safety Code Chapter 6.67) Palo Alto Office of Emergency Services The Mission of the Office of Emergency Services (Palo Alto OES) is to coordinate the unified and efficient use of City resources, outside agencies (mutual aid), and community resources to prevent, prepare for, respond to, and recover from all hazards. OES is responsible for planning, training, and exercises to maintain and improve our operational readiness. OES manages the Emergency Operations Center (EOC) and the new Mobile Emergency Operations Center (MEOC), in collaboration with the Public Safety Answering Point (911 Communications Dispatch Center) for Palo Alto and Stanford University Palo Alto Department of Public Works, Watershed Protection Group The Public Works Watershed Protection group regulates discharges to the sanitary sewer system through permitting, inspection, and enforcement. The Sewer Use Ordinance (Municipal Code Chapter 16.09) prohibits discharge of hazardous waste and regulates the storage of hazardous materials above sinks. Mercury and Dioxin Elimination Policy The City in July 2000 approved a Mercury and Dioxin Elimination Policy to eliminate the creation of dioxin and its subsequent release to the environment and to eliminate the use of mercury and its subsequent release to the environment. 7 The mercury elimination strategy focuses on products that contain mercury as an intentional ingredient; laboratory, medical, and manufacturing processes that use mercury; and the combustion of mercury-containing fuels or wastes. The dioxin elimination strategy will focuses on products that contain dioxin, manufacturing processes that create dioxin as a by-product, and combustion of fuels or wastes that contain dioxin precursors. Integrated Pest Management Policy The City adopted in October 2001 an Integrated Pest Management Policy to reduce or eliminate chemicals to the maximum extent. 8 The policy states that the City will carry out its pest management activities using low-risk integrated pest management techniques, with chemicals used only as a last resort. The policy also states that the City will actively pilot non-toxic alternatives using the most recent technology, best management practices, and least toxic methods available. Lastly, the policy states that the City will educate staff and the public about its integrated pest management commitment. 7 City of Palo Alto Mercury and Dioxin Elimination Policy, July 17, City of Palo Alto Integrated Pest Management Policy, October FEBRUARY 5, 2016

15 Environmentally Preferred Purchasing Policy The City adopted in February 2008 an Environmentally Preferred Purchasing Policy, recognizing its purchases of goods and services can contribute significantly to the success of its sustainability polices and goals. This policy aligns the City s purchases and Purchasing Department policies and procedures with the City s sustainability policies and programs to (1) protect and conserve natural resources; (2) minimize the City s contributions to global warming, solid waste, local, and global pollution, and toxic chemical exposures to people and the environment; and (3) promote human health and well-being EXISTING CONDITIONS Hazardous Materials Sites California Government Code Section requires CalEPA to compile, maintain, and update specified lists of hazardous material release sites. CEQA Guidelines (California Public Resources Code Section ) require the lead agency to consult the lists compiled pursuant to Government Code Section to determine whether a proposed project and any alternatives are identified on any of the following lists: United States EPA National Priorities List (NPL): Lists all sites under the EPA s Superfund program, which was established to fund cleanup of contaminated sites that pose risk to human health and the environment. United States EPA Toxics Release Inventory (TRI) Program: Tracks the management of certain toxic chemicals that may pose a threat to human health and the environment. United States EPA Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS) and Archived Sites: CERCLIS contains 15,000 sites nationally identified as hazardous sites. This would also involve a review for archived sites that have been removed from CERCLIS due to No Further Remedial Action Planned (NFRAP) status. United States EPA Resource Conservation and Recovery Act Information System (RCRIS or RCRAInfo): RCRAInfo is a national inventory system about hazardous waste handlers. Generators, transporters, handlers, and disposers of hazardous waste are required to provide information for this database. DTSC Cortese List: The DTSC maintains the Hazardous Waste and Substances Sites (Cortese) List as a planning document for use by the State and local agencies to comply with the CEQA requirements in providing information about the location of hazardous materials release sites. This list includes the Site Mitigation and Brownfields Reuse Program Database (CalSites). DTSC HazNet: DTSC uses this database to track hazardous waste shipments. SWRCB Leaking Underground Storage Tank Information System (LUSTIS): The SWRCB maintains an inventory of USTs and leaking USTs, which tracks unauthorized releases. PLACEWORKS

16 The required lists of hazardous material release sites are commonly referred to as the Cortese List after the legislator who authored the legislation. Because the statute was enacted more than 20 years ago, some of the provisions refer to agency activities that were conducted many years ago and are no longer being implemented and, in some cases, the information to be included in the Cortese List does not exist. Those requesting a copy of the Cortese List are now referred directly to the appropriate information resources contained on internet websites hosted by the boards or departments referenced in the statute, including DTSC s online EnviroStor database and the SWRCB s online GeoTracker database. These two databases include hazardous material release sites, along with other categories of sites or facilities specific to each agency s jurisdiction. A search of commonly accessed online databases on October 12, 2015 identified the following information potentially relevant to proposed land uses changes due to adoption and implementation of the proposed Plan. The details results of this search are provided in Appendix E, Hazardous Materials, of this EIR. EnviroStor The EnviroStor database, maintained by the DTSC, identifies sites that have known contamination or sites for which there may be reasons to investigate further. The database includes federal Superfund sites (National Priorities List); State response sites; voluntary cleanup sites; school investigation and cleanup sites; corrective action sites; and tiered California permit sites. It also includes sites that are being investigated for suspected but unconfirmed contamination. A search of this database for the EIR Study Area using zip codes within the jurisdictional boundaries of the City of Palo Alto and SOI found the following numbers of such facilities listed in Table 4.7-1, and shown on Figure Records from the EnviroStor database are included in Appendix E of this EIR. At the time of the records search, there were 29 cleanup sites, 17 tiered permit sites, and 24 hazardous waste facilities listed in the database for the EIR Study Area. Of these sites, only four sites were listed as active. Thirty, or over 40 percent, of the listed sites were designated as certified, no further action, or historical and non-operating. The remainder of the listed sites were either inactive and in need of evaluation or referred to another agency. GeoTracker The GeoTracker database, maintained by the SWRCB, lists a range of types of hazardous materials sites that could affect groundwater quality, including leaking underground storage tank (LUST) sites, cleanup program sites, land disposal sites, and military sites, as shown in Table and on Figure A search of this database found, using zip codes within the jurisdictional boundaries of the City of Palo Alto and SOI found the following numbers of such facilities. Records from the GeoTracker database are included in the Appendix E of this EIR. At the time of the records search, there were 224 LUST cleanup program sites listed in the database for the EIR Study Area. Of this number, 192, or 85 percent, of these sites were designated as closed or eligible for closure. The remainders of the sites were listed as undergoing assessment, remedial action, or cleanup verification monitoring. There were no listed land disposal sites or military cleanup sites. There were 39 permitted UST sites FEBRUARY 5, 2016

17 TABLE ENVIROSTOR CLEANUP PROGRAM SITES IN THE EIR STUDY AREA STATUS School Investigation and School Cleanup Sites Number of Sites Certified or No Further Action 0 Active 0 Inactive or Referred to Other Agency 0 Subtotal 0 Evaluation, Border Zone/Hazardous Waste Evaluation, or Military Evaluation Sites Certified, No Further Action, or De-Listed 0 Active 0 Backlog, Inactive, or Referred to Other Agency 0 Subtotal 0 Federal Superfund, Corrective Action, State Response, or Voluntary Cleanup Sites Completed, Certified, No Further Action, or De-Listed 17 Active 2 Backlog, Inactive, or Referred to Other Agency 10 Subtotal 29 Tiered Permit Sites Certified or No Further Action 1 Active 1 Backlog, Inactive, or Referred to Other Agency 15 Subtotal 17 Hazardous Waste Facilities Permitted Operating, Interim Operating Permitted, and Post-Closure Permitted 1 Historical Non-Operating 11 Referred to Other Agency 12 Subtotal 24 Total 70 Note: This table is based on actual zip codes for the sites listed in EnviroStor, correcting for some inaccuracies in State data. Source: DTSC EnviroStor, October PLACEWORKS

18 COMPREHENSIVE PLAN UPDATE EIR East Palo Alto UN IVE RS IT Y AV LINCOLN AVE E Menlo Park S A N F R A N C I S C O B A Y 101 AR C EM B AY OW AD ER D PY OR EG ON AL Stanford University 82 ÿ M LO IA AV E LI F OR N 280 HA SAN Mountain View FO O THI L RD AN TO N STO RD PAGE MILL RD EC E RL L EXP Y RO D AS T N IO BLV AL M DE RA SE R CA PE RO VE NI EA JU D ER AV AR A ST R A FABIAN WAY RE R EX AV E SE AL E NO UR D RD RY R QUA R H I AM PAST E D D C EL N SA R IL L Los Altos Los Altos Hills Railroads Cleanup Sites Highways Tiered Permit Sites Park/Open Space Hazardous Waste Facilities City Boundary Miles 1 Los Altos Hills Sphere of Influence Sources: City of Palo Alto, 2013; USGS, 2010; NHD 2013; ESRI, 2010; Tiger Lines, 2010; Department of Toxic Substance Control, 2014; PlaceWorks, Figure EnviroStor Cleanup Program Sites

19 TABLE GEOTRACKER SITES IN THE EIR STUDY AREA Status Number of Sites Leaking Underground Storage Tank (LUST) Sites Open Site Assessment or Open Assessment and Interim Remedial Action 4 Open Remediation or Open Verification Monitoring 1 Open Eligible for Closure or Open - Inactive 3 Completed Case Closed 168 Subtotal 176 Cleanup Program Sites Open All Open Statuses 27 Completed Case Closed 21 Subtotal 48 Land Disposal Sites Open All Open Statuses 0 Completed Case Closed 0 Subtotal 0 Military Sites Military Cleanup Sites, Military Privatized Sites, and Military UST Sites Open All Open Statuses 0 Subtotal 0 Underground Storage Tank (UST) Sites Permitted Facilities 39 Subtotal 39 Total 263 Note: This table is based on actual zip codes for the site listed in Geo Tracker, correcting for some inaccuracies in State data. Source: SWRCB Geo Tracker, October PLACEWORKS

20 COMPREHENSIVE PLAN UPDATE EIR S A N F R A N C I S C O B A Y East Palo Alto LINCOLN AVE UN I VE RD LL I H ND SA EX PY ON NI D RD B LV IO RA FABIAN WAY SE R AV E ÿ L E X PY RD FO O T HIL Mountain View AR A ST R AD ER O PAGE MILL RD SA N PE RO VE EA CA NI 82 RD VE MA LO R D ALMA ON ST ST LE AR H EC JU AN TO N Stanford University SE AL E R AA VE EU R D OW OR PA ST AD ER LI F QUA R RY RD A RC EM B 101 AY EG RS IT Y OR AV E Menlo Park Atherton 280 Los Altos Los Altos Hills Miles 1 Caltrain Stations Permitted Underground Storage Tank Sites Railroads Ongoing Leaking Underground Storage Tank Sites Highways Closed Leaking Underground Storage Tank Sites Park/Open Space Ongoing Cleanup Program Sites City Boundary Closed Cleanup Program Sites Sphere of Influence Sources: City of Palo Alto, 2013; USGS, 2010; NHD 2013; ESRI, 2010; Tiger Lines, 2010; Department of Toxic Substance Control, 2014; PlaceWorks, Figure GeoTracker Sites

21 Groundwater Contaminant Plumes The EPA and the RWQCB currently are engaged in oversight of the investigation and cleanup of several groundwater contaminant plumes underlying certain areas in the City of Palo Alto, including notably what is known as the Hewlett-Packard Page Mill Road property, the former Varian facility at 601 California Avenue, and the Fairchild Semiconductor Site at 4001 Miranda Avenue. Contaminants variously include volatile organic compounds (VOCs), primarily trichloroethence (TCE) and other chlorinated hydrocarbons, gasoline and related aromatic hydrocarbons, most notable benzene, and certain metals such as arsenic. Hazardous Waste Generators Large quantity generators are those that generate 1,000 kilograms per month or more of hazardous waste, or more than one kilogram per month of acutely hazardous waste. Small quantity generators generate from 100 to 999 kilograms per month of hazardous waste. Conditionally exempt small quantity generators generate 100 kilograms or less per month, or one kilogram or less per month of acutely hazardous waste, or less than 100 kilograms per month of acute spill residue or soil. Palo Alto has two industrial areas where hazardous materials are used: the Stanford Research Park just south of Stanford University and the industrial area adjacent to US 101 in south Palo Alto. Businesses located in these areas are engaged in a wide variety of activities, including research and scientific instrumentation, product manufacturing, information technology, and computer hardware and software development, as well as more main stream activities such as cleaners, service stations, and repair shops. A search of the RCRAInfo database, maintained by the United States EPA, using zip codes of within the jurisdictional boundaries of the City of Palo Alto and SOI found a number of hazardous waste generators, as shown in Table and shown on Figure Records from the RCRA Info database are included in the Appendix E of this EIR. Communications and Power Industries TABLE HAZARDOUS WASTE GENERATORS IN THE EIR STUDY AREA Number Status of Sites Large Quantity Generators 32 Small Quantity Generators 129 Subject to Corrective Action 8 Note: This table is bases on information contained in RCRA Info Envirofacts Database, using correcting for some inaccuracies in federal data. Source: United States EPA, RCRCAInfo, October The City of Palo Alto hired an outside consultant to conduct an independent assessment of potential health risks associated with industrial processes conducted at Communications and Power Industries, Inc. (CPI), 9 which is a facility located at Hansen Way, within the Stanford Research Park, and adjacent to the Barron Park residential neighborhood to the south. 9 City of Palo Alto, available online at accessed February 3, PLACEWORKS

22 COMPREHENSIVE PLAN UPDATE EIR S A N F R A N C I S C O B A Y East Palo Alto SIT Y ER UN IV A EM B R C AD 101 N EX AV E a Re GO OR E UR D R LE ino E AY RO W PY SE A L QUA RR HI am PAST E D C El N SA Y RD D LR l Stanford University 82 ÿ V OMA L E EA RD VE LVD PAGE MILL RD 280 D HA Mountain View FOO TH I LL E EC IO R AB RD TO N RR N TO ES RL AN SE AL MA ST SAN RD RO ERO PE X PY AR A STR AD JU NI CA LI F OR NIA AV E FABIAN WAY AV E Menlo Park LINCOLN AVE Los Altos Railroads Large Quantity Generators Highways Small Quantity Generators Los Altos Hills Park/Open Space City Boundary Miles Miles 11 Sphere of Influence Sources: City of Palo Alto, 2013; USGS, 2010; NHD 2013; ESRI, 2010; Tiger Lines, 2010; US Environmental Protection Agency, Figure Hazardous Waste Generators

23 CPI manufactures microwave and radio frequency products for defense, communications, medical, scientific, and other applications. Given the proximity of CPI to adjacent residences, the use of hazardous materials in the manufacturing process, and past accidental releases, the City wanted to provide an objective evaluation of CPI operations, in which the consultant prepared an assessment and evaluated offsite public health risks from the use, storage, and handling of acutely hazardous materials at CPI. The report was completed was completed in January In addition, the city is considering new ordinances that would change the way hazardous materials are regulated in Palo Alto. The new ordinances as now envisioned could force CPI to move its operations at least 300 feet from nearby homes in Barron Park. A public hearing and vote on the new ordinances is scheduled to take place by the end of February Palo Alto Regional Water Quality Control Plant The City of Palo Alto operates the Regional Water Quality Control Plant (RWQCP) for the benefit of the City and the surrounding communities. Hazardous waste materials processed onsite at the RWQCP include laboratory materials, waste oil, household hazardous waste items, fluorescent lamps, and paints. Hazardous waste management at the RWQCP is governed by applicable federal, State, and local regulations discussed above. The RWQCP currently uses a solids process of thickening, dewatering, and incineration (with a multiple hearth furnace) that produces ash that is classified as a hazardous waste, requiring special disposal. The City's 2012 Long Range Facilities Plan for the RWQCP recommended that the existing incineration process be retired as soon as a new solids process can be selected and implemented. 10 A Household Hazardous Waste (HHW) Station at the RWQCP provides Palo Alto residents with a safe and convenient way to dispose of their unwanted or unused toxic household items. 11 The Station is open every Saturday from 9:00 a.m. to 11:00 a.m. and the first Friday of each month from 3:00 p.m. and 5:00 p.m. Home collection service is available for residents with physical limitations. The HHW Station accepts up to 15 gallons or 125 pounds of household hazardous waste per visit from Palo Alto residents. Additionally, the HHW Station provides reuse cabinets, where residents can pick up usable household products such as paints, cleaners, and unused motor oil, brought to the HHW Station for disposal by other residents and screened by the City before being placed in the cabinets for reuse. Airport Hazards There is only one public use airport within the EIR Study Area. Palo Alto Airport, located in the northeast portion of the city, on the western shore of San Francisco Bay. There are three international airports within 20 miles of Palo Alto. San Jose International is the closest, located 13 miles southeast of Palo Alto. San Francisco International and Metropolitan Oakland International are a bit farther northwest, at 18 and 20 miles respectively. All distances are from the approximate geographic center of Palo Alto. There are no 10 City of Palo Alto, 2012, Long Range Facilities Plan for the Regional Water Quality Control Plant, page City of Palo Alto, "Hazardous Waste Program," available online at whatgoeswhere/hazwaste.asp, February 3, 2015 accessed October 28, PLACEWORKS

24 private or limited use airstrips in Palo Alto, but five are located within 30 miles of the city. Moffett Federal Airfield is the closet to Palo Alto, located five miles east in Mountain View. Emergency Response Plans The City of Palo Alto has features that make it susceptible to a variety of disaster emergencies. It has homes in dry, brushy foothills, lies along a major earthquake fault, has steep hillsides, and has creeks that can flood and dams that can break. Geological hazards are addressed in Chapter 4.5, Geology, Soils, and Seismicity, of this Draft EIR. The impacts associated with increased risk of wildfires due to climate change are addressed in Chapter 4.6, Greenhouse Gas Emissions and Climate Change, of this Draft EIR. Hazards related to flooding are addressed in Chapter 4.8, Hydrology and Water Quality, of this Draft EIR. Palo Alto has its own airport, railroad tracks that cross through the length of the city, and freeways to the east and west. It is also home to a major research university, two major hospitals, and a technologically advanced industrial research park, where hazardous materials are used. The Palo Alto Emergency Operations Plan (EOP), adopted by the City in 2007, establishes the policies and structures for City government management of emergencies and disasters. The EOP prescribes four phases of emergencies and disasters: preparedness, response, recovery, and mitigation/prevention. The EOP is an all-hazard plan. It assigns responsibilities for action and tasks that the City will take to help protect the safety and welfare of its citizens against the treat of natural, technological, and national security emergencies and disasters. It established a base on which further plans procedures, guidelines, arrangements, and agreements can be elaborated. Emergency operations for the City of Palo Alto are consistent with California s Standardized Emergency Management System (SEMS) and the federal National Incident Management System (NIMS). All components are included in the City s EOP. Additionally, the Palo Alto RWQCP maintains an emergency response plan, as a large industrial facility. The City also has an Emergency Services Volunteers (ESV) program. 12 The mission of the program is to 1) provide supplemental resources to the professional first responders of the city and communities, and 2) facilitate means for neighbors to help neighbors (including business and other entities). The Emergency Services Volunteers nomenclature is an umbrella to include all City-sponsored emergency preparedness volunteer programs, such as Amateur Radio Emergency Services/Radio Amateur Civil Emergency Services (ARES/RACES) (ham radio), Block Preparedness Coordinators (BPCs) and Neighborhood Preparedness Coordinators (NPCs) the Community Emergency Response Team (CERT) volunteers and the Emergency Medical Unit (EMU). The Palo Alto Office OES is the sponsor of the ESV program. In addition, the city participated in development of the Regional Catastrophic Earthquake Mass Transportation/Evacuation Plan. 13 This Plan is an annex to the 2008 San Francisco Bay Area Regional Emergency Coordination Plan and addresses mass transportation/evacuation issues in response to a major earthquake. 12 City of Palo Alto, Emergency Services Volunteers Policy Manual and Standard Operating Procedures, 2013, available online at accessed October 23, California Emergency Management Agency, 2011, Regional Catastrophic Earthquake Mass Transportation/Evacuation Plan FEBRUARY 5, 2016

25 Wildfire Hazards The severity of the wildlife hazard is determined by the relationship between three factors: fuel classification, topography, and critical fire weather frequency. CAL FIRE defines Fire Hazard Severity Zones for areas within the State: fire hazard is defined as a measure of the likelihood of an area burning and how it burns, with a zone being an area characterized by a particular level of fire hazard. CAL FIRE Fire Hazard Severity Zone maps indicate areas for which the State of California has fiscal responsibility of wildland fire protection services as the State Responsibility Area (SRA), and areas for which local jurisdictions have fiscal responsibility as the Local Responsibility Area (LRA). CAL FIRE describes wildland/urban interface as the condition where highly flammable native vegetation meets high-value structures, such as homes. In most cases, there is not a clearly defined boundary or interface between the structures and vegetation that present the hazard. Historically, homes in these illdefined wildland/urban intermix boundaries areas were particularly vulnerable to wildfires because they were built with a reliance on fire department response for protection rather than fire resistance, survivability, and self-protection. However, more recently, a greater appreciation has developed for the need to regulate development in these hazardous areas as a result of a number of serious wildland fire conflagrations throughout the State. The State Fire Marshal included adoption of Chapter 7A in the California Building Code, which requires ignition resistant exterior construction in hazardous fire areas. The City of Palo Alto has adopted these requirements for new construction or significant remodels of dwellings in the moderate to high fire hazard severity areas in Palo Alto. The City also mandated fire sprinklers in new buildings and significant remodels in these areas starting in As shown in Figure 4.7-4, much of the area surrounding Palo Alto, west of Interstate 280 (I-280), is considered moderate and high risk of wildland fire, whereas incorporated Palo Alto, such as downtown, does not have any wildland fire hazards. No portion of Palo Alto s city limits or SOI is within a Very High Fire Hazard Severity Zone as recommended by CAL FIRE. 14 As discussed in Chapter 3, Project Description, development under the proposed plan would largely occur closer to the Downtown, Stanford University, and areas along El Camino Real, which are within close proximity to fire stations 1, 2, and 6 and not subject to wildland fire. The City has entered into mutual aid and automatic aid agreements with the City of Menlo Park, CAL FIRE, the Central County Fire Department (CCFD), the City of Mountain View, and the Woodside Fire Protection District. 15 The environmental consequences of climate change include higher temperatures that are expected to result in extreme weather patterns, prolonged drought periods, and more frequent and destructive wildfires. Extreme weather events have become more frequent over the past 40 to 50 years, and the trend of extreme weather events is projected to continue. 14 State of California Department of Forestry and Fire Protection, 2008, Very High Fire Hazard Severity Zones in LRA, available online at accessed October 27, Local Agency Formation Commission, Santa Clara County, 2010, 2010 Countywide Fire Service Review, page 66. PLACEWORKS

26 COMPREHENSIVE PLAN UPDATE EIR Local Responsibility Area (Palo Alto) Redwood City Non-Very High Fire Hazard Severity Zone State Responsibility Areas AV E LINCOLN AVE East Palo Alto RS IT Y Atherton UN IVE RD EM RE AL AV E MA ST CA LI F OR NIA AL VE EA RD X PY Mountain View AS TR A LL E AR FO O TH I N STO DE RO RD E LE AR CH D NO 82 ÿ RD IO R MI Stanford University VE MA LO AN T ON LL 101 WAY CA HI ERO EL SA ND AD BAR C SA N Menlo Park Moderate High Very High Railroads Highways City Boundary Sphere of Influence 280 Portola Valley Los Altos Los Altos Hills 0 1 Sunnyvale 2 Scale (Miles) Sources: City of Palo Alto, 2013; ; ESRI, 2010; Tiger Lines, 2010; CAL FIRE, 2007, 2008; PlaceWorks Figure Fire Hazard Severity Zones in the Palo Alto Local Responsibility Area and All State Responsibility Areas

27 Extreme weather patterns could lead to changes in rainfall distribution and intensity, resulting in fewer but more intense rainfall events followed by prolonged dry periods. More intense heat waves may cause more heat-related illnesses, droughts, and wildfire events. 16 Prolonged dry periods in Palo Alto could contribute to the evaporative loss of potable water and exacerbate drought conditions. Drier environmental conditions can further contribute to soil moisture depletion, vegetative loss, and accelerated soil erosion of undeveloped open space in Palo Alto. Soil moisture depletion can result in large scale vegetation die-offs which create prime kindling for high intensity wildfires STANDARDS OF SIGNIFICANCE Appendix G of the California Environmental Quality Act (CEQA) Guidelines contains standards of significance for the evaluation of a project s impacts. Section of the CEQA Guidelines encourages each public agency to develop and publish its own thresholds of significance that the agency uses in evaluating the significance of environmental effects for projects in its jurisdiction. The City of Palo Alto prepared its Environmental Criteria Used by the City of Palo Alto in In determining which standards of significance to use for evaluating the hazards and hazardous materials impacts of the proposed Plan, Appendix G of the CEQA Guidelines and the City s published environmental criteria were considered. As part of this review, one of the City s criteria were reworded or a new criterion was added to better match the CEQA Guidelines. Based on this consideration, the analysis in Section uses the following standards of significance. The proposed Plan would result in a significant impact associated with hazards and hazardous materials if it would: Create a significant hazard to the public or the environment as a result of the routine transport, use or disposal of hazardous materials. Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within ¼-mile of an existing or proposed school. Create a significant hazard to the public or the environment from existing hazardous materials contamination by exposing future occupants or users of the site to contamination either in excess of soil and groundwater cleanup goals developed for the site or from location on listed hazardous materials sites compiled pursuant to Government Code Section Expose people or structures to a significant risk of loss, injury or death involving wildland fires. Result in a safety hazard from a public airport for people residing or working within the project area. Impair implementation of or physically interfere with an adopted emergency response or evacuation plan. 16 Santa Clara County, 2011, Santa Clara County Hazard Mitigation Plan, pages 4-1 and PLACEWORKS

28 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 IMPACT DISCUSSION The remaining sections of this chapter provide an analysis of the potential project impacts, including impacts from growth expected to occur during the life of the proposed Plan, as well as cumulative hazards and hazardous materials impacts that could occur as a result of the implementation of the proposed Plan when combined with projects outside of Palo Alto. All potential impacts described below would be the same for all scenarios. As such, the various scenarios are not distinguished below. HAZ-1 The proposed Plan would not create a significant hazard to the public or the environment as a result of the routine transport, use, or disposal of hazardous materials. (Less than Significant All Four Scenarios) Summary: The four scenarios would allow varying levels of residential and commercial growth throughout the EIR Study Area. Future development under all four scenarios would be regulated pursuant to federal, State, and local laws. Compliance with applicable regulations would reduce the potential for a significant adverse effect on the environment to occur as a result of the routine transport, use, or disposal of hazardous materials. Therefore, the impact would be less than significant under all four scenarios. The proposed Plan would substantially affect the environment if future development allowed under the Plan would involve the routine use, transport, or disposal of hazardous materials. Hazardous materials are regularly used, transported, and disposed of in Palo Alto. Additional residential, commercial, and lightindustrial would likely increase the amount of hazardous materials transported, used, or disposed of in the City. As described in Section , Regulatory Framework, these activities are subject to a variety of local, State, and federal regulations. Hazardous materials would be required to be transported under DOT regulations. Future development under the proposed Plan would be subject to regulatory programs such as those overseen by the RWQCB and the DTSC. These agencies require applicants for development of potentially contaminated properties to perform investigation and cleanup if the site is found to be contaminated with hazardous substances. In addition, Santa Clara County has substantial regulations concerning hazardous materials under its CUPA jurisdiction and related Unified Programs. This is further enforced by Palo Alto Fire Department Programs. For example, businesses in Palo Alto must submit a Business Plan for the safety storage and use of chemicals if the business handles and/or stores a hazardous material equal to or greater than the minimum reportable quantities. Adoption and implementation of the proposed Plan would not directly result in new development, but new development allowed by the Plan that use hazardous materials or generates hazardous waste, would be regulated pursuant to federal, State, and local laws. Compliance with federal, state and local regulations FEBRUARY 5, 2016

29 would reduce the potential for a significant adverse effect on the environment, due to upset and accident involving the use, transport, and disposal of hazardous materials, to a less-than-significant level. Applicable Regulations: United States Department of Transportation Hazardous Materials Transport Act (49 Code of Federal Regulations) United States Environmental Protection Agency Resource Conservation and Recovery Act United States Environmental Protection Agency Comprehensive Environmental Response, Compensation and Liability Act California Division of Occupational Safety and Health California Health and Safety Code (Chapter 695) California Code of Regulations (Title 19, Section 2729) California Building Code Santa Clara County Department of Health s Hazardous Materials Compliance Division County of Santa Clara Ordinance Code (Title B, Division B11, Chapter XIII) Palo Alto Municipal Code (Title 17, Hazardous Materials Storage, all chapters, and Title 18, Zoning, Chapter , Hazardous Materials) Significance before Mitigation: Compliance with federal, State, and local regulations would reduce the potential for a significant adverse effect on the environment due to upset and accident involving the use, transport, and disposal of hazardous materials that would be generated by new development approved under the proposed Plan, Therefore, the impact is less than significant for all scenarios. HAZ-2 The proposed Plan would not create a significant hazard to the public or the environment through reasonable upset and accident conditions involving the release of hazardous materials into the environment. (Less than Significant All Four Scenarios) Summary: The four scenarios would allow varying levels of residential and commercial growth throughout the EIR Study Area. Future development would be regulated pursuant to federal, State, and local laws. Compliance with applicable regulations would ensure future development would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions. Therefore, the impact would be less than significant under all four scenarios. The proposed Plan would substantially affect the public or the environment if future development allowed under the Plan would result in significant upset and accident conditions involving the release of hazardous materials into the environment. The Plan would allow new development, including residential, mixed use, and commercial uses. Some of the new development could occur on properties that possibly are contaminated and inactive, undergoing evaluation, and/or undergoing corrective action, as indicated in Table Future construction of new buildings and redevelopment activities under implementation of the Plan could have the potential to release potentially hazardous soil-based materials into the environment PLACEWORKS

30 during site grading and excavation operations. Likewise, demolition of existing structures could potentially result in release of hazardous materials (e.g., asbestos or lead paint) into the environment. Use of hazardous materials on newly developed properties after construction could potentially include cleaning solvents, fertilizers, pesticides, and other materials used in the regular maintenance and operation of future development. In addition, as noted in the discussion of HAZ-1 above, hazardous materials are regularly used, transported, and disposed of in Palo Alto. The city implements a variety of federal, State, and local regulations designed to address the use, transportation, and disposal of these materials. Adoption and implementation of the proposed Plan would not directly result in new development, but new development allowed by the Plan that uses hazardous materials or generates hazardous waste, would be regulated pursuant to federal, State, and local laws. Compliance with applicable laws and regulations regarding handling of these materials described in Section , Regulatory Framework, and compliance with the Stormwater Pollution Prevention Plan and Best Management Practice (BMP) requirements for future development (see Chapter 4.8, Hydrology and Water Quality, for additional detail), would ensure future development under the proposed Plan would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions. Therefore, impacts would be less than significant. Applicable Regulations: United States Department of Transportation Hazardous Materials Transport Act (49 Code of Federal Regulations) United States Environmental Protection Agency Resource Conservation and Recovery Act United States Environmental Protection Agency Comprehensive Environmental Response, Compensation and Liability Act California Division of Occupational Safety and Health California Health and Safety Code (Chapter 695) California Code of Regulations (Title 19, Section 2729) California Building Code Santa Clara County Department of Health s Hazardous Materials Compliance Division County of Santa Clara Ordinance Code (Title B, Division B11, Chapter XIII) Palo Alto Municipal Code (Title 17, Hazardous Materials Storage, all chapters, and Title 18, Zoning, Chapter , Hazardous Materials) Significance before Mitigation: Compliance with applicable federal, State, and local laws and regulations regarding the use of hazardous materials and generation of hazardous waste would ensure the new development approved under the proposed Plan would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions. Therefore, the impact would be less than significant for all scenarios FEBRUARY 5, 2016

31 HAZ-3 The proposed Plan would not result in hazardous emissions or the handling of hazardous or acutely hazardous material, substances or, waste within ¼-mile of an existing or proposed school. (Less than Significant All Four Scenarios) Summary: The four scenarios would allow varying levels of residential and commercial growth throughout the EIR Study Area. It is possible that such uses could occur within ¼-mile of existing or proposed schools. However, none of the scenarios include land use changes in areas that would affect established educational uses. Compliance with applicable regulations regarding hazardous materials would ensure impacts under all four scenarios would be less than significant. The proposed Plan would substantially affect existing or proposed schools if it would allow development that would emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within ¼-mile of an existing or proposed school. As discussed in Section , Schools, in Chapter 4.12, Public Services and Recreation, of this Draft EIR, Palo Alto is served by the Palo Alto Unified School District (PAUSD), which has 13 elementary schools, three middle schools, and two high schools within the EIR Study Area. In addition, there are a number of other private schools not operated by PAUSD. Development allowed under the proposed Comp Plan Update would allow land uses that could be reasonably expected to handle hazardous materials or generate hazardous emissions, as described under Impacts HAZ-1 and HAZ-2, above. It is possible that such uses could occur within ¼-mile of existing or proposed schools. However, as discussed under Impacts HAZ-1 and HAZ-2, the storage, use, and handling of these materials would be subject to existing federal, State, and local regulations. Buildout under the proposed Plan would result in increased population levels and could result in the need for additional school facilities. One of the major constraints to increasing school facilities is the limited supply of land available to build new schools facilities. However, in terms of new public schools that may result from implementation of the proposed Plan, DTSC s School Property Evaluation and Cleanup Division is responsible for assessing, investigating, and cleaning-up proposed school sites. The Division s goal is to ensure that proposed school properties are free of contamination or that they have been cleaned to a level that protects the students and staff who will occupy the new school. School sites that will receive State funding for acquisition or construction are required to go through an environmental review and cleanup process under DTSC s oversight. Compliance with applicable federal, State, and local laws and regulations regarding storage, use, and handling of hazardous materials as described in Section , Regulatory Framework, and reiterated in Impacts HAZ-1 and HAZ-2, would ensure future development under the proposed Plan does not emit hazardous emissions within ¼-mile of an existing or proposed school site. Therefore, impacts would be less than significant. Applicable Regulations: United States Department of Transportation Hazardous Materials Transport Act (49 Code of Federal Regulations) PLACEWORKS

32 United States Environmental Protection Agency Resource Conservation and Recovery Act United States Environmental Protection Agency Comprehensive Environmental Response, Compensation and Liability Act California Division of Occupational Safety and Health California Health and Safety Code (Chapter 695) California Code of Regulations (Title 19, Section 2729) California Building Code California Department of Toxic Substances Control (School Property Evaluation and Cleanup Program) California Department of Education (School Facility) Santa Clara County Department of Health s Hazardous Materials Compliance Division County of Santa Clara Ordinance Code (Title B, Division B11, Chapter XIII) Palo Alto Municipal Code (Title 17, Hazardous Materials Storage, all chapters, and Title 18, Zoning, Chapter , Hazardous Materials) Significance before Mitigation: Compliance with applicable federal, State, and local laws and regulations regarding storage, use, and handling of hazardous materials would ensure future development under the proposed Plan does not emit hazardous emissions within ¼-mile of an existing or proposed school site. Therefore, the impact would be less than significant for all scenarios. HAZ-4 The proposed Plan would not create a significant hazard to the public or the environment from existing hazardous materials contamination by exposing future occupants or users of the site to contamination either in excess of soil and groundwater cleanup goals developed for the site or from location on listed hazardous materials sites compiled pursuant to Government Code Section (Less than Significant All Four Scenarios) Summary: The four scenarios would allow varying levels of residential and commercial growth throughout the EIR Study Area. Future development under all four scenarios would be regulated pursuant to federal, State, and local laws. Compliance with applicable regulations would reduce the potential for a significant adverse effect on the environment as a result of exposure to site contamination. Therefore, the impact would be less than significant under all four scenarios. The proposed Plan would substantially affect the public or the environment if future development allowed under the Plan would expose future occupants or users of development sites to existing hazardous materials contamination in soil and/or groundwater at these sites. As discussed in Section , Hazardous Materials Sites, a number of hazardous materials sites are listed on databases complied pursuant to Government Code Section Most of the sites are listed as closed, indicating that they have been investigated and/or remediated to the satisfaction of the lead responsible agency (i.e. RWQCB, DTSC, SCCDEH) based on land use at the time of closure. The proposed Comp Plan Update would allow new FEBRUARY 5, 2016

33 development, including residential, mixed use, and commercial uses within the EIR Study Area. Some of the new development could occur on properties that are included in the database listed above. Construction of new buildings and improvements on these listed sites could have the potential to release potentially hazardous soil-based materials into the environment during site grading and excavation operations. Demolition of any existing structures, likewise, could potentially result in the release hazardous building materials (e.g., asbestos, lead paint into the environment. Use of hazardous materials on newly developed properties after construction could the potentially include cleaning solvents, fertilizers, pesticides, and other materials used in the regular maintenance and operation of future development. Adoption and implementation of the proposed Plan would not directly result in new development, but new development allowed by the proposed Plan that uses hazardous materials or generates hazardous waste, would be regulated pursuant to federal, State, and local laws. Compliance, with applicable laws and regulations regarding cleanup and reuse of a listed hazardous material site described in Section , Regulatory Framework, and reiterated in Impacts HAZ-1 and HAZ-2, would ensure that impacts would be less than significant. Applicable Regulations: United States Department of Transportation Hazardous Materials Transport Act (49 Code of Federal Regulations) United States Environmental Protection Agency Resource Conservation and Recovery Act United States Environmental Protection Agency Comprehensive Environmental Response, Compensation and Liability Act California Division of Occupational Safety and Health California Health and Safety Code (Chapter 695) California Code of Regulations (Title 19, Section 2729) California Building Code California Department of Toxic Substances Control ( Strategic Plan) Regional Water Quality Control Board (Porter-Cologne water Quality Act) Santa Clara County Department of Health s Hazardous Materials Compliance Division County of Santa Clara Ordinance Code (Title B, Division B11, Chapter XIII) Palo Alto Municipal Code (Title 17, Hazardous Materials Storage, all chapters, and Title 18, Zoning, Chapter , Hazardous Materials) Significance before Mitigation: Compliance with applicable federal, State, and local laws and regulations regarding soil and groundwater cleanup and reuse of a listed hazardous material site would ensure future development under the proposed Plan would not create a significant hazard. Therefore, the impact would be less than significant for all scenarios. HAZ-5 The proposed Plan would not expose people or structures to a significant risk of loss, injury, or death involving wildland fires. (Less than Significant All Four Scenarios) PLACEWORKS

34 Summary: The four scenarios include varying levels of residential and commercial growth throughout the EIR Study Area. Although portions of the EIR Study Area may be subject to wildfire risks, future development under all four scenarios would be concentrated within already urbanized and/or developed areas of the EIR Study Area, in proximity to Fire Stations 1, 2, and 6 and in areas not subject to wildland fire. In addition, future development under all four scenarios would be subject to existing regulations, such as the CFC, which would reduce risks to people and structures in areas subject to wildland fire risks. The impact would be less than significant under all four scenarios. The proposed Plan would result in a significant impact if it would allow development that would expose people or structures to a significant risk of loss, injury, or death involving wildland fires. As shown on Figure 4.7-4, much of the area surrounding Palo Alto west of I-280 is considered to have a moderate and high risk of wildland fire, whereas all of the urbanized areas of Palo Alto, such as downtown, do not have any wildland fire hazards. Although this information indicates that wildfire risk in the EIR Study Area may be present, there are many resources available to address wildland fires should they arise, including the CAL FIRE Strategic Plan and the CFC. For example, the CFC requires the clearance of debris and vegetation within a prescribed distance from structures in wildlife hazard areas. In addition, although each scenario would include varying amounts of new housing and non-residential uses, with associated increases to the EIR Study Area s population and the number of employees, future development under all four scenarios would be concentrated within already urbanized and/or developed areas of the EIR Study Area, given that Palo Alto is largely built out. Development under all four scenarios would largely occur closer to the Downtown, Stanford University, and areas along El Camino Real, which are within close proximity to Fire Stations 1, 2, and 6 and not subject to wildland fire. Cooperative fire service agreements with the CCFD, City of Menlo Park, City of Mountain View, Woodside Fire Protection District, and Stanford University would further assist the City in protecting people and structures from potential wildland fires. Overall, adoption and implementation of the proposed Plan would not directly result in new development, and new development allowed by the Plan would generally occur in areas of low wildland fire risk. Compliance with applicable federal, State, and local laws and regulations would ensure that impacts from wildland hazards would be less than significant. As described in Section , Wildfire Hazards, climate change will increase droughts and cause more hazardous wildfire conditions. The impacts associated with this increased risk of wildfires due to climate change are addressed in Chapter 4.6, Greenhouse Gas Emissions and Climate Change. Applicable Regulations: California Department of Forestry and Fire Protection (2012 Strategic Plan) California Code of Regulations (Section 2729) California Building Code California Fire Code County of Santa Clara Ordinance Code (Title B, Division B11, Chapter XIII) Palo Alto Municipal Code (Title 17, Hazardous Materials Storage, all chapters, and Title 18, Zoning, Chapter , Hazardous Materials) FEBRUARY 5, 2016

35 Significance before Mitigation: New development approved under the proposed Plan would generally occur in areas of low wildland fire risk. Further, compliance with applicable federal, State, and local laws and regulations would ensure that impacts from wildland hazards would be less than significant under all scenarios. HAZ-6 The proposed Plan would not result in a safety hazard from a public airport for people residing or working within the Plan area. (Less than Significant All Four Scenarios) Summary: As described in Section , Airport Hazards, there is only one public use airport located within the EIR Study Area. Palo Alto Airport is located in the northeast part of the city, on the western shore of San Francisco Bay. All potential impacts described below would be the same for all scenarios. As such, the scenarios are not distinguished below. The impact would be less than significant in all four scenarios. The proposed Plan would result in a significant impact if future development allowed under the Plan would be incompatible and in conflict with an existing airport land use plan for the Palo Alto Airport. As described in Section , Airport Hazards, the CLUP for the Palo Alto Airport was adopted in November 2008 by the Santa Clara County ALUC and the City amended the Comp Plan in 2009 to incorporate the CLUP. The CLUP includes policies intended to safeguard the general welfare of the inhabitants within the vicinity of the airport and ensure that new surrounding uses do not affect the airport s continued safe operation. None of the scenarios contemplate land use changes within the CLUP area. All of the scenarios primarily allow varying levels of residential and commercial development and do not change current Comp Plan land use designations. The zoning changes in Scenarios 3 and 4, which could shift housing density from south to north or add mixed use development in Stanford Shopping Center or Stanford Research Park, would not affect land within the vicinity of the Palo Alto Airport. None of the scenarios contemplates land use changes within the CLUP jurisdictional area or the Airport Influence Area of the Palo Alto Airport. The proposed Plan, therefore, would not interfere with any airport land use plan or otherwise create an airport-related safety hazard, and risk to people residing or working in the EIR Study Area would be less than significant. Applicable Regulations: Palo Alto Comprehensive Land Use Compatibility Plan Palo Alto Airport Palo Alto Municipal Code, Title 18, Zoning Palo Alto Municipal Code, Title 21, Subdivision and Other Divisions of Land Significance before Mitigation: The proposed Plan would not interfere with any airport land use plan or otherwise create an airport-related safety hazard, or result in a safety hazard to people residing or working in the EIR Study Area. Therefore, the impact would be less than significant for all scenarios. PLACEWORKS

36 HAZ-7 The proposed Plan would not impair implementation of or physically interfere with an adopted emergency response or evacuation plan. (Less than Significant All Four Scenarios) Summary: The four scenarios include varying levels of residential and commercial growth throughout the EIR Study Area. All development would be required to comply with all adopted emergency response or evacuation plans and therefore there would be no significant impacts. The proposed Plan would result in a significant impact if future development allowed under the Plan would impair implementation of or physically interfere with an adopted emergency response or evacuation plan. As discussed in Section , Regulatory Framework, the Palo Alto OES is responsible for coordinating agency response to disaster or other large-scale emergencies in the City of Palo Alto with assistance from the Santa Clara County Office of Emergency Services and the CCFD. Palo Alto EOP establishes policy direction for emergency planning, mitigation, response, and recovery activities within the city. The Palo Alto EOP addresses interagency coordination, procedures to maintain communication with county and State emergency response teams, and methods to assess the extent of damage and management of volunteers. With participation from the City of Palo Alto and other local agencies, ABAG created an umbrella Hazard Mitigation Plan entitled Taming Natural Disasters. In addition, the city participated in development of and has since adopted the Regional Catastrophic Earthquake Mass Transportation Plan, which is an annex to the San Francisco Bay Area Regional Emergency Coordination Plan and addresses mass transportation/evacuation issues in response to a major earthquake. Compliance with applicable federal, State, and local regulations and existing plans and policies regarding emergency operations, as described in Section , Regulatory Framework, would ensure that future development under all four scenarios would not interfere with an adopted emergency response plan or emergency evacuation plan. Therefore, impacts would be less than significant. As described in Section , Wildfire Hazards, climate change will increase extreme weather events. More intense storms could result in the need for increased emergency response services. The impacts associated with this increased risk due to climate change are addressed in Chapter 4.6, Greenhouse Gas Emissions and Climate Change. Applicable Regulations: United States Department of Transportation Hazardous Materials Transport Act (49 Code of Federal Regulations) California Health and Safety Code (Chapter 6.95) California Code of Regulations (Section 2729) Regional Catastrophic Earthquake Mass Transportation/Evacuation Plan (2011) County of Santa Clara Ordinance Code (Title B, Division B11, Chapter XIII) Palo Alto Emergency Operation Plan (2007) FEBRUARY 5, 2016

37 Significance before Mitigation: Compliance with applicable federal, State, and local regulations and existing plans and policies regarding emergency operations would ensure that future development approved under the proposed Plan would not interfere with an adopted emergency response plan or emergency evacuation plan. Therefore, impacts would be less than significant for all scenarios. HAZ-8 The proposed Plan would not result in a safety hazard for people residing or working within the vicinity of a private airstrip in the Plan area. (No Impact All Four Scenarios) Summary: As discussed in Section , Airport Hazards, there are no private or limited use airstrips in Palo Alto. Therefore, there would be no related safety hazard to people residing or working within the EIR Study Area and there would be no impact under all four scenarios. As discussed in Section , Airport Hazards, there are no private or limited use airstrips in Palo Alto. Therefore, none of the scenarios would allow development within the vicinity of a private airstrip. There would be no impact under all four scenarios. Significance before Mitigation: There would be no impact to people residing or working within the vicinity of a private airstrip in the Plan area under all scenarios CUMULATIVE IMPACTS HAZ-9 The proposed Plan, in combination with past, present, and reasonably foreseeable projects, would not result in significant cumulative impacts with respect to hazards and hazardous materials. (Less than Significant All Four Scenarios) Summary: In general, all of the scenarios focus on facilitating varying levels of residential and commercial development in specific areas, primarily in the downtown, Stanford Research Park and Shopping Center, and at the Fry s Electronic site, rather than changing existing land use designations (which the exception of the Fry s Electronics site, which may be redesignated under Scenario 4). As stated in Section in Chapter 3, Project Description, the current Comp Plan land use map (Figure 3-3 in Chapter 3), is likely to remain unchanged with the proposed Plan. The cumulative impacts would be less than significant. This cumulative analysis considers the effects of the proposed Plan combined with effects of past, present, and reasonably foreseeable development on adjacent land in the cities of Menlo Park, Los Altos Hills, Los Altos, and Mountain View. As discussed previously, development allowed by the proposed Plan would not result in significant impacts from the increased use of hazardous household materials and would not increase exposure to potential hazards associated with wildland fires. The proposed Plan would not interfere with implementation for emergency response plans. In addition, potential project-level impacts associated with hazards and hazardous materials would be further reduced through compliance with local, regional, State, PLACEWORKS

38 and federal regulations. Cumulative development in adjacent jurisdictions would be subject to the same federal, State, and regional regulations, as well as regional safety plans, such as The Palo Alto Airport CLUP, building codes, such as Chapter 7A in California Building Code, which requires ignition resistant exterior construction hazardous fire areas, and regional emergency response plans, such as the Santa Clara County Hazard Mitigation Plan. Compliance with these requirements would reduce cumulative, development-related impacts that relate to airport hazards, wildfire hazards, and emergency response. Since impacts associated with hazardous materials and wildland fire, are, by their nature, focused on specific sites or areas, the lessthan-significant impacts within the EIR Study Area from the proposed Plan would not contribute to a cumulative increase in hazards in the immediate vicinity of the EIR Study Area or throughout the region. Therefore, cumulative impacts associated with hazards and hazardous materials would be less than significant. Applicable Regulations: United States Department of Transportation Hazardous Materials Transport Act (49 Code of Federal Regulations) United States Environmental Protection Agency Resource Conservation and Recovery Act United States Environmental Protection Agency Comprehensive Environmental Response, Compensation and Liability Act California Division of Occupational Safety and Health California Health and Safety Code (Chapter 695) California Code of Regulations (Title 19, Section 2729) California Building Code Santa Clara County Department of Health s Hazardous Materials Compliance Division County of Santa Clara Ordinance Code (Title B, Division B11, Chapter XIII) Palo Alto Municipal Code (Chapters Title 17, Hazardous Materials Storage, all chapters, and Title 18, Zoning, Chapter , Hazardous Materials) California Department of Toxic Substances Control (School Property Evaluation and Cleanup Program) California Department of Education (School Facility) Regional Water Quality Control Board (Porter-Cologne water Quality Act) Regional Catastrophic Earthquake Mass Transportation/Evacuation Plan (2011) California Department of Toxic Substances Control ( Strategic Plan) Palo Alto Emergency Operation Plan (2007) Significance before Mitigation: Compliance with existing requirements would reduce cumulative, development-related impacts, and less-than-significant impacts within the EIR Study Area would ensure that the proposed Plan would not contribute to a cumulative increase in hazards in the immediate vicinity of the EIR Study Area or throughout the region. Therefore, cumulative impacts would be less than significant under all four scenarios FEBRUARY 5, 2016