225 Bush Street Suite 1700 San Francisco, CA phone fax

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1 225 Bush Street Suite 1700 San Francisco, CA phone fax memorandum date October 10, 2011 to from subject Lori Alvarez Project Manager, Palo Alto School District Lesley Lowe, AICP - ESA Project Manager 525 San Antonio Road : Response to Comments on the Draft Initial Study from DTSC On September 8, 2011 the Palo Alto School District (Lead Agency) released for public review a Draft Initial Study/ Negative Declaration for property acquisition at 525 San Antonio Road (SCH# ). The 30-day public review and comment period began on September 8, 2011 and will close at 4:00 p.m. on October 10, A public hearing on the project was held on September 27, 2011, at the School District Office, 25 Churchill Avenue, Palo Alto, CA 94306, at a School Board Meeting. This memorandum summarizes and responds to the comments and questions on the Draft Initial Study/ Negative Declaration from the Department of Toxic Substance Control (DTSC) in a letter dated October 6, The letter is presented as Attachment A. Responses to Comments Department of Toxic Substance Control 1. The comment summarizes the proposed project as presented in the Initial Study/Negative Declaration. Response: The comment is noted. The District is committed to ensuring that future uses of the property would include measures to minimize the potential for encountering or exposing any potential hazardous materials that may exist at the site. As indicated in the Initial Study, the property would remain in its present condition and any future re-use or redevelopment would be subject to later review under CEQA. 2. The comment asks about the occurrence of asbestos on the site due to prior demolish of buildings. Response: A Phase I investigation was conducted for the project site which included a summary of two former Phase I s and a limited Phase II study. The limited study included sampling of near-surface soils for pesticides and lead which may have come from lead-based paint. The findings indicated that samples were below regulatory thresholds. No other environmental conditions were identified in the most recent Phase I investigation. Asbestos removal from existing buildings, if applicable, would be done in compliance BAAQMD regulations, and other hazardous building materials, if present, would be identified in a building survey prior to any renovation or demolition of existing buildings.

2 3. The comment inquires if the property was formerly used for agricultural purposes, and if so states that soil investigation and mitigation should comply the Interim Guidance for Sampling Agricultural Soils (Third Revision) date August Response: Past agricultural use during the 1930s and 1940s appears to have been primarily for the production of hay as opposed to row crops which indicates a much lower potential for pesticide and herbicide use. By the 1950s, according to the Phase I report, a church building was located on the site indicating a change in land use. Regardless of previous soil sampling results which evaluated surface soils at the site, the most recent Phase I investigation concluded that a potential remains for near-surface soils to contain residual pesticides/herbicides or lead from lead-based paint. While the information regarding past site uses combined the limited soil sampling already conducted indicates a lower likelihood of encountering pesticides or herbicides, the conservative approach would be to ensure that no adverse effects would result from residual concentrations in surface soils through additional sampling. Therefore, the District would, prior to occupation of the property, evaluate the potential for these potential contaminants in accordance DTSC s Interim Guidance, Evaluation of School Sites Potential Soil Contamination as a Result of Lead from Lead-Based Paint, Organochlorine Pesticides from Termiticides, and Polychorinated Biphenyls from Electrical Transformers, dated June 9, The comment notes the naturally occurring asbestos in ten miles of the property and notes that site reuse should adhere to the Interim Guidance- Naturally Occurring Asbestos at School Sites, revised September 24, Response: Chrysotile and amphibole asbestos occur naturally in certain geologic settings in the San Francisco Bay Area, most commonly in serpentinite and other ultramafic rocks. These are igneous and metamorphic rocks a high content of magnesium and iron minerals. The most common type of asbestos is chrysotile, which is commonly found in serpentinite rock formations. When disturbed by construction, grading, quarrying, or surface mining operations, asbestos-containing dust can be generated. Exposure to asbestos can result in lung cancer, mesothelioma, and asbestosis. In July 2001, the California Air Resources Board approved an Asbestos Airborne Toxic Control measure for Construction, Grading, Quarrying, and Surface Mining activities in areas where naturally occurring asbestos (NOA) will likely be found and to provide best dust mitigation measures and practices. These are mountainous areas or areas of shallow bedrock that could be encountered during construction. Regional studies by Dibblee and Brabb (1978), and Pampeyan (1994), Wentworth et al., 1999 indicate the site is underlain by Quaternary alluvial deposits. These earth materials are very unlikely to contain serpentinite or another ultramafic rock NOA. A geologic formation exists in the general area that could potentially contain asbestos bearing rocks. These include a northwest trending band of ultramafic rock (serpentinized harzburgite and dunite) located approximately 3.6 miles southwest of the site. As such, naturally occurring asbestos should not be a hazard at the project site. 5. The comment notes that the use of State or federal funds would be required to conform regulations. 2

3 Response: The proposed property acquisition if funded solely through a local bond measure and does not seek funding from the State. If such funding is sought in the future, the District would comply Education Code Sections, and References Cornerstone Earth Group. Phase 1 Limited Preliminary Site Assessment, August 2011 Brabb, E.E., Graymer, R.W., and jones, D.L., 2000, Geologic map of the Palo Alto 30 x 60 Quadrangle, California, Miscellaneous Field Studies Map MF-2332, 1:100,000 scale. Dibblee, T. W., Jr., 1966, Geology of the Palo Alto Quadrangle, Santa Clara and San Mateo Counties, California: Dibblee Geology Center Map, scale 1:125,000. Churchill, R.K. and Hill, R.L., 2000, A general location guide for ultramafic rocks in California area more likely to contain naturally occurring asbestos: California Division of Mines and Geology, Open-File Report , scale 1:1,100,000. Pampeyan, Earl H., 1993, Geologic Map of the Palo Alto and Part of the Redwood Point 7-1/2 Quadrangles, San Mateo and Santa Clara Counties, California, U. S. Geological Survey, Miscellaneous Investigation Series, Map I

4 ATTACHMENT A DTSC Letter 4

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8 NOTICE OF REVIEW PERIOD NOTICE OF AVAILABILITY/NOTICE OF INTENT TO ADOPT A NEGATIVE DECLARATION Draft Initial Study/Negative Declaration for 525 San Antonio Road, Palo Alto, California To: Public Agencies and Concerned Citizens/Interested Parties From: Palo Alto Unified School District 25 Churchill Avenue Palo Alto, CA Project Applicant: Palo Alto Unified School District Notice: Notice is hereby given that the Palo Alto Unified School District ( PAUSD ), acting as Lead Agency under the California Environmental Quality Act (CEQA), intends to adopt a Negative Declaration for the subject project. The review period is to end on October 10, 2011 at 4:00 pm. Project Location: The project site is located at 525 San Antonio Road, Palo Alto, California. Project Description: The proposed project is the acquisition by PAUSD of the property. PAUSD is looking to purchase the property to preserve the possibility of expanding school facilities in the future. There is currently no building demolition being contemplated and no plans for reuse have been prepared. The property will remain in its present condition until such time as plans are developed and approved by PAUSD, and other regulatory agencies, as appropriate. Any future re-use or redevelopment on-site will be subject to separate review for compliance the California Environmental Quality Act. Potential Environmental s: The Initial Study did not find any potential environmental impacts as the proposed project is the acquisition San Antonio Road, and no alterations or reuse of the property are anticipated at this time. Public Review Period: The public review period for the Draft Initial Study extends from September 8, 2011 through October 10, Public Hearings: PAUSD will hold a public hearing on September 27, 2011 at 6:30 pm to take public comment on the Negative Declaration. The meeting will be at the District Office at 25 Churchill Avenue, Palo Alto, CA, The Initial Study/Negative Declaration will be adopted at a special meeting on October 11, Check the PAUSD website for the meeting time [ Location Where Document Can Be Reviewed: PAUSD has prepared a Draft Initial Study and Negative Declaration for the subject project pursuant to the California Environmental Quality Act. These documents are available for review at 1) the Palo Alto Unified School District Main Office, 25 Churchill, Palo Alto, CA, and 2) on the PAUSD website [ Comments on the Draft Negative Declaration must be received, in writing, by the end of the review period, October 10, 2011 at 4:00 p.m. Submit comments to: Tom Hodges Palo Alto Unified School District 25 Churchill, Palo Alto, CA, or THodges@pausd.org Phone: (650) Fax: (650) For comments please contact: Tom Hodges, Program Director, , THodges@pausd.org 25 Churchill Avenue, Building D Palo Alto, CA Phone Fax MEASURE A STRONG SCHOOLS BOND

9 ENVIRONMENTAL CHECKLIST Initial Study 1. Project Title: 525 San Antonio Road Property Acquisition 2. Lead Agency Name and Address: Palo Alto Unified School District District Office 25 Churchill Avenue, Building "D" Palo Alto, CA Contact Person and Phone Number: Tom Hodges, Program Director Telephone: Project Location: 525 San Antonio Road Palo Alto, California Project Sponsor s Name and Address: Palo Alto Unified School District 25 Churchill Avenue, Building D Palo Alto, CA General Plan Designation(s): Single Family Residential (as designated in the Palo Alto Comprehensive Plan) 7. Zoning Designation(s): R-1 (minimum residential lot size of 8,000 square feet) 8. Description of Project: The project site is located at 525 San Antonio Avenue, in the southern section of Palo Alto, west of U.S. Highway 101 and east of Interstate 280. The site is 2.65 acres, consisting of two parcels ( & ) zoned R-1 (8000) (Single Family Residential) and regulated by the Palo Alto Municipal Code (PAMC) Chapter 18.12, requiring a minimum residential lot size of 8,000 square feet. The Peninsula Day Care Center, a privately operated non-profit child care center and preschool on the site, closed in June 2011 after approximately 37 years of operation, as the remaining founder is retiring and selling the property. The R-1 zone allows for the daycare use via approval of a Conditional Use Permit (CUP). The daycare center, established prior to the CUP requirement, is operated in seven structures providing over 18,700 s.f. of floor area supported by a parking facility, play areas and minimal landscaping. The proposed project is the acquisition by the Palo Alto Unified School District of the property. The District is looking to purchase the property to preserve the possibility of expanding school facilities in the future. There is currently no building demolition being contemplated and no plans for reuse have been prepared. The property will remain in its 525 San Antonio Road 1 ESA /

10 present condition until such time as plans are developed and approved by the District, and other regulatory agencies, as appropriate. Any future re-use or redevelopment on site will be subject to separate review for compliance the California Environmental Quality Act. 9. Surrounding Land Uses and Setting. The subject site is located on the 500 block of San Antonio Avenue bounded by Middlefield Road to the east and Ferne Avenue to the southwest at the southern most end of the City of Palo Alto. The subject site exists in a transitional location in terms of surrounding uses and zoning designations. It is surrounded on three sides by developed land. Five single-family, single-story residences in the Greendell tract on parcels ranging from approximately 8,000 s.f. to 10,000 s.f. and zoned R-1 (8000), the same zoning as the project site, are along the site s southwesterly property line. The Greendell Campus and Cubberley Community Center beyond are to the northwest. Two low density multi-family zoned (RM-15) property, abut the northerat boundary of the site. Across San Antonio Avenue to the southeast is Gideon Hausner Day School, a private education facility and a Planned Community (PC 2640) providing affordable housing for elderly and families known as Palo Alto Gardens. Farther south across San Antonio Avenue is the Rosewalk condominium development zoned RM-30 and the Hewlett Packard site approved for development of a 45-unit multi-family housing project. 10. Other public agencies whose approval is required: Department of Education and Department of Toxic Substance Control. 525 San Antonio Road 2 ESA /

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12 Environmental Checklist Aesthetics No 1. AESTHETICS Would the project: a) Have a substantial adverse effect on a scenic vista? b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings in a state scenic highway? c) Substantially degrade the existing visual character or quality of the site and its surroundings? d) Create a new source of substantial light or glare which would adversely affect daytime or nighttime views in the area? a-d) No. The proposed project will not have any impacts on aesthetics as the project entails only the purchase of the property by the Palo Alto Unified School District. Existing lighting on the site would remain to maintain the security of the site. The purchase of the property would not substantially degrade or alter the existing visual character or quality of the site or its surroundings. Agricultural and Forest Resources No 2. AGRICULTURAL AND FOREST RESOURCES In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project: a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? b) Conflict existing zoning for agricultural use, or a Williamson Act contract? 525 San Antonio Road 4 ESA /

13 No c) Conflict existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))? d) Result in the loss of forest land or conversion of forest land to non-forest use? e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use? a-d) No. The project site is not located in a Prime Farmland, Unique Farmland, or Farmland of Statewide Importance area, as shown on the maps prepared for the Farmland Mapping and Monitoring Program of the California Resources Agency. The site is not zoned for agricultural use, and is not regulated by the Williamson Act. Moreover, the proposed project will not have impacts on agriculture resources as the project entails only the purchase of the property by the Palo Alto Unified School District and no construction or re-use of the property is planned. Air Quality No 3. AIR QUALITY Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project: a) Conflict or obstruct implementation of the applicable air quality plan? b) Violate any air quality standard or contribute substantially to an existing or projected air quality violation? c) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)? d) Expose sensitive receptors to substantial pollutant concentrations? e) Create objectionable odors affecting a substantial number of people? 525 San Antonio Road 5 ESA /

14 a-e) No. The proposed project will not have impacts on air quality as the project entails only the purchase of the property by the Palo Alto Unified School District and no construction or re-use of the property is planned at this time. The project site is in proximity to San Antonio Road an arterial roadway. Should the District elect to pursue use of the site in the future, as a education facility, the District would be required to conduct a health risk assessment, in accordance CEQA Guidelines Section 15186(c)(3)(B)(3). Biological Resources No 4. BIOLOGICAL RESOURCES Would the project: a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? c) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? d) Interfere substantially the movement of any native resident or migratory fish or wildlife species or established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? e) Conflict any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? f) Conflict the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? a-e) No. The project site is located in a developed urban area no riparian or tree habitat for the candidate, sensitive, or special status species in the area. No endangered, threatened, or rare animals, insects and plant species have been identified at this site. The 525 San Antonio Road 6 ESA /

15 project site is located in an established residential urban setting. Adobe Creek is ½ miles from the site, which is a channelized, flowing creek at its closest point. The proposed project will not have impacts on biological resources as the project entails only the purchase of the property by the Palo Alto Unified School District and no construction or re-use of the property is planned. Cultural Resources No 5. CULTURAL RESOURCES Would the project: a) Cause a substantial adverse change in the significance of a historical resource as defined in ? b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to ? c) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? d) Disturb any human remains, including those interred outside of formal cemeteries? a-d) No. The Comprehensive Plan indicates that this site is in a moderate archaeological resource sensitivity zone. Most of the City area east of Interstate 280 is designated in this zone. However, the proposed project will not have impacts on cultural resources as the project entails only the purchase of the property by the Palo Alto Unified School District and no construction or re-use of the property is planned. Geology, Soils, and Seismicity No 6. GEOLOGY, SOILS, AND SEISMICITY Would the project: a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: 525 San Antonio Road 7 ESA /

16 No i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? (Refer to Division of Mines and Geology Special Publication 42.) ii) iii) iv) Strong seismic ground shaking? Seismic-related ground failure, including liquefaction? Landslides? b) Result in substantial soil erosion or the loss of topsoil? c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse? d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property? e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater? a-e) No. The entire state of California is in a seismically active area. According to the Palo Alto Comprehensive Plan the project site is not in an area that is subject to very strong ground shaking in the event of an earthquake or in an area subject to expansive soils, surface rupture, liquefaction, or earthquake induced landslides. Regardless of potential geological hazards, the proposed project does not have any impacts on geology and soils as the project entails only the purchase of the property by the Palo Alto Unified School District and no construction or re-use of the property is planned. Greenhouse Gas Emissions No 7. GREENHOUSE GAS EMISSIONS Would the project: a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? 525 San Antonio Road 8 ESA /

17 No b) Conflict an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? a-b) No. The proposed project does not have any impacts on greenhouse gas emissions as the project entails only the purchase of the property by the Palo Alto Unified School District and no construction or re-use of the property is planned. Hazards and Hazardous Materials No 8. HAZARDS AND HAZARDOUS MATERIALS Would the project: a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste in one-quarter mile of an existing or proposed school? d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section and, as a result, would it create a significant hazard to the public or the environment? e) For a project located in an airport land use plan or, where such a plan has not been adopted, in two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? f) For a project in the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area? g) Impair implementation of or physically interfere an adopted emergency response plan or emergency evacuation plan? h) Expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed wildlands? 525 San Antonio Road 9 ESA /

18 a-h) No. The project site is not identified by the California Environmental Protection Agency or the California State Water Resource Control Board as a hazardous material site. Further, a Limited Phase I Preliminary Site Assessment (August, 2011) indicates that the project site is not on any list of known contaminated sites, nor do there appear to be any listed sites in the immediate vicinity that have an obvious potential to impact soil or groundwater quality at the project site. There is an existing PG&E pipeline present on the south side of the property near the play area. The line itself does not appear to represent a significant environmental concern, especially as the purchase of the property would not alter the site. The proposed project does not have any impacts on hazards and hazardous materials as the project entails only the purchase of the property by the Palo Alto Unified School District and no construction or re-use of the property is planned. Hydrology and Water Quality No 9. HYDROLOGY AND WATER QUALITY Would the project: a) Violate any water quality standards or waste discharge requirements? b) Substantially deplete groundwater supplies or interfere substantially groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted)? c) Substantially alter the existing drainage pattern of a site or area through the alteration of the course of a stream or river, or by other means, in a manner that would result in substantial erosion or siltation on- or off-site? d) Substantially alter the existing drainage pattern of a site or area through the alteration of the course of a stream or river, or by other means, substantially increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site? e) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? f) Otherwise substantially degrade water quality? 525 San Antonio Road 10 ESA /

19 No g) Place housing in a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map? h) Place in a 100-year flood hazard area structures that would impede or redirect flood flows? i) Expose people or structures to a significant risk of loss, injury or death involving flooding, including flooding as a result of the failure of a levee or dam? j) Expose people or structures to a significant risk of loss, injury or death involving inundation by seiche, tsunami, or mudflow? a-j) No. The project site currently contains seven structures which were mostly recently used as a day care facility. The seven structures total approximately 18,718 square feet. The project site is not located in an area of groundwater recharge and will not deplete the groundwater supplies. The project site is located approximately ½ mile outside the 100-year flood hazard area and would not impede or redirect flood flows. The site is approximately a ½ mile away from Adobe Creek which is located north/northwest of the project site. The project site is not in an area that is subject to seiche, tsunami or mudflow. The remainder of the project site consists of asphalt paving, permeable play areas and minimal landscaping. The proposed project does not have any impacts on hydrology and water quality as the project entails only the purchase of the property by the Palo Alto Unified School District and no construction or re-use of the property is planned. Land Use and Land Use Planning No 10. LAND USE AND LAND USE PLANNING Would the project: a) Physically divide an established community? b) Conflict any applicable land use plan, policy, or regulation of an agency jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? c) Conflict any applicable habitat conservation plan or natural community conservation plan? 525 San Antonio Road 11 ESA /

20 a-c) No. The site is currently designated as Single Family Residential and is zoned R- 1 (8000). It was most recently occupied by the Peninsula Day Care Center. There are no zoning or land use changes proposed as part of the project. The proposed project does not have any impacts on land use and planning as the project entails only the purchase of the property by the Palo Alto Unified School District and no construction or re-use of the property is planned. Mineral Resources No 11. MINERAL RESOURCES Would the project: a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state? b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? a-b) No. The City of Palo Alto has been classified by the California Department of Conservation (DOC), Division of Mines and Geology (DMG) as a Mineral Resource Zone 1 (MRZ-1). This designation signifies that there are no aggregate resources in the area. The proposed project does not have any impacts on mineral resources as the project entails only the purchase of the property by the Palo Alto Unified School District and no construction or re-use of the property is planned. Noise No 12. NOISE Would the project: a) Result in Exposure of persons to, or generation of, noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? b) Result in Exposure of persons to, or generation of, excessive groundborne vibration or groundborne noise levels? 525 San Antonio Road 12 ESA /

21 No c) Result in A substantial permanent increase in ambient noise levels in the project vicinity above levels existing out the project? d) Result in A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing out the project? e) For a project located in an airport land use plan area, or, where such a plan has not been adopted, in an area in two miles of a public airport or public use airport, would the project expose people residing or working in the area to excessive noise levels? f) For a project located in the vicinity of a private airstrip, would the project expose people residing or working in the project area to excessive noise levels? a-f) No. The project site is located in an area an existing noise level ranging between 56-70dBa. This level is typical for single-family residential districts. No construction activities will result as part of the purchase of the property. Long term noise associated the site would not increase the purchase of the property as there is no-reuse plan to-date. The proposed project does not have any impacts on noise as the project entails only the purchase of the property by the Palo Alto Unified School District and no construction or re-use of the property is planned. Population and Housing No 13. POPULATION AND HOUSING Would the project: a) Induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? b) Displace substantial numbers of existing housing units, necessitating the construction of replacement housing elsewhere? c) Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere? a-c) No. The proposed project is the acquisition of the 2.65 acre site by the Palo Alto Unified School District. The proposed project would not alter population or displace housing in or around the site. The proposed project does not have any impacts on 525 San Antonio Road 13 ESA /

22 population and housing as the project entails only the purchase of the property by the Palo Alto Unified School District and no construction or re-use of the property is planned. Public Services No 14. PUBLIC SERVICES Would the project: a) Result in substantial adverse physical impacts associated the provision of, or the need for, new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the following public services: i) Fire protection? ii) iii) iv) Police protection? Schools? Parks? v) Other public facilities? ai-av) No. The project is served by the Palo Alto Fire Department. The project would not impact service to the site or area. The site is located in the jurisdiction of the Palo Alto Police Department. The site acquisition would not result in the need for additional police officers, equipment or facilities. The purchase of the property by the School District would not generate an increase in residential population, thus generating the need for school construction. The future use of the site by the School District has not been determined and subsequent use would be required to undergo environmental analysis per CEQA. The proposed project would not alter or create a demand for parks. The proposed project would not increase the demand for community centers or libraries. The proposed project does not have any impacts on public services as the project entails only the purchase of the property by the Palo Alto Unified School District and no construction or re-use of the property is planned. 525 San Antonio Road 14 ESA /

23 Recreation No 15. RECREATION Would the project: a) Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facilities would occur or be accelerated? b) Include recreational facilities or require the construction or expansion of recreational facilities that might have an adverse physical effect on the environment? a-b) No. The proposed project does not have any impacts on recreation or increase the demand for recreation services as the project entails only the purchase of the property by the Palo Alto Unified School District and no construction or re-use of the property is planned. Transportation and Traffic No 16. TRANSPORTATION AND TRAFFIC Would the project: a) Conflict an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit? b) Conflict an applicable congestion management program, including, but not limited to, level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways? c) Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location, that results in substantial safety risks? d) Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? e) Result in inadequate emergency access? 525 San Antonio Road 15 ESA /

24 No f) Conflict adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities? a-f) No. The proposed acquisition of the project site would not increase trips to the site, alter access or circulation, increase transit service demand or impede emergency access. The proposed project does not have any impacts on transportation/traffic as the project entails only the purchase of the property by the Palo Alto Unified School District and no construction or re-use of the property is planned. Utilities and Service Systems No 17. UTILITIES AND SERVICE SYSTEMS Would the project: a) Conflict wastewater treatment requirements of the applicable Regional Water Quality Control Board? b) Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? c) Require or result in the construction of new storm water drainage facilities, or expansion of existing facilities, the construction of which could cause significant environmental effects? d) Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed? e) Result in a determination by the wastewater treatment provider that would serve the project that it has adequate capacity to serve the project s projected demand in addition to the provider s existing commitments? f) Be served by a landfill sufficient permitted capacity to accommodate the project s solid waste disposal needs? g) Comply federal, state, and local statutes and regulations related to solid waste? a-g) No. The proposed project does not have any impacts on utilities and service systems as the project entails only the purchase of the property by the Palo Alto Unified 525 San Antonio Road 16 ESA /

25 School District and no construction or re-use of the property is planned. The acquisition of the project would not alter or increase the demand on existing utilities and service systems, or use resources in a wasteful or inefficient manner. Mandatory Findings of Significance No 18. MANDATORY FINDINGS OF SIGNIFICANCE Would the project: a) Have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory? b) Have impacts that are individually limited, but cumulatively considerable? ( Cumulatively considerable means that the incremental effects of a project are considerable when viewed in connection the effects of past projects, the effects of other current projects, and the effects of probable future projects)? c) Have environmental effects that would cause substantial adverse effects on human beings, either directly or indirectly? a) No. The proposed project will not degrade the quality of the environment as the project entails only the purchase of the property by the Palo Alto Unified School District and no construction or re-use of property is planned. b) No. The proposed project has no cumulative impacts as the project entails only the purchase of the property by the Palo Alto Unified School District and no construction or re-use of the property is planned. c) No. The proposed project has no substantial adverse effects on human beings as the project entails only the purchase of the property by the Palo Alto Unified School District and no construction or re-use of the property is planned. 525 San Antonio Road 17 ESA /

26 References Cornerstone Earth Group. Phase 1 Limited Preliminary Site Assessment, August 2011 Palo Alto Comprehensive Plan, Palo Alto Municipal Code, Title 18- Zoning Ordinance Project Description of Acquisition by PAUSD 525 San Antonio Road 18 ESA /