Desk ItemsERC Study Session Potential Topics:
Follow the Placeworks book main topics in slideshow format for future reference for new ERC and PC members.
Consider a joint PC CCC or all commission public study session on EIRs? Somehow provide the information to educate.
1) Environmental Screening Levels
a) 2019 SF Bay Regional Water Quality Control Board
b) Who selects, what if there are disagreements?
c) Baseline study of Arsenic shows a regional range, one soils study showed the mid-range value and accepted it,
another used the max range value and accepted it; cannot both be right, and both were
2) Noticing
3) How to make effective comments about a CEQA document (EIR/MND)
4) Differences between the various CEQA documents
5) Checklists
6) Aesthetics
7) Level of Service
8) Legal issues— exposure to challenges
9) Who can answer questions regarding the CEQA document?
a) How should questions be presented from ERC members to consultants?
b) Legal issues of written communications (eg. Recent MND statements)
10) The following information is from the CEQA seminars from the 2019 PC Academy, Long Beach:
11) EIR approval does not mean project approval, explain
12) If not certified, the data does not exist, explain
13) Must respond to comments; how to make comments which get an actual response
14) If we disagree with the conclusions, talk to the Director, say it on the record, vote "no" and don't approve
15) Director needs to be able to guess what the commission wants: if you want a specific part of the DEIR (eg. Study
pink bunnies w/tutus); explain
16) Policies in the GP may make inconsistencies disqualify the proposed project
17) CEQA is not perfect, advocate for any project, chance to fix existing issues, a decision maker, anthology of everything
everywhere, analysis of worst case
18) Project Description: Stable and Consistent
19) Baseline discussion
20)' Thresholds of Significance — need to sit with planning to discuss
21) Mitigation Measures
a) Project design features
b) Measurable changes
c) What does feasible mean
d) What level to mitigate to?
e) After occupancy permit issued, if mitigation measures not done, out of luck
f) Hours of operation, tree canopy — use Ordinances to it is code compliance instead of mitigation (explain this)'
22) Findings, written logical process, showing your work, explaining reasoning, drafted by staff and approved by council
or commission
23) Late Hits: Testimony at Hearings
a) Give them to staff, take a 10 minute break
i) Ok to proceed or
ii) Continuance
24) Recirculation is not a bad thing
Midpeninsula Regional
apenSpace
July 12, 2019
Mr. Rob Salisbury
Midpeninsula Regional Open Space District
Santa Clara County Planning Dpt.
70 West Hedging Street
East Wing, 7th Floor
San Jose, CA 95110
GENERALMANAGER
Ana M. Ruiz
BOARD OF DIRECTORS
Pete Siemens
Yoriko Kishimoto
Jed Cyr .
Curt Riffle
Karen'Holman
Larry Hassett
Zoe Kersteen-Tucker
RE: Lehigh Southwest Cement Company Proposed Permanente: Quarry Reclamation Plan Amendment
Application
Dear Mr. Salisbury,
The Midpeninsula Regional Open Space District (District) submits, the following preliminary comments
on the May 2019 application from Lehigh Southwest_ Cement Company (Lehigh) for a proposed
Reclamation Plan Amendment (201,9 Amendment).; aur comments raise concerns regarding the
proposed expansion of the quarry operations into the. protected Scenic Easement area. These concerns
are focused on four main issues: inadequate geotechnical solutions to stabilize the existing quarry walls;.
continued water quality impacts of both groundwater and Permanente Creek; visual impacts resulting;
from the increased height of the West Materials Storage Area (WMSA) and lowering0 the ridgeline;
and the potential for increased: air quality impacts.. Additionally, the District is concerned that the
proposed amendment would also result in continued implementation delays to fulfill current stream
restoration obligations along Permanente Creek.
Protection of the Permanent Ridge Scenic Easement
The Permanente Ridge. Scenic Easement owned by Santa Clara County (County) is extremely important
to the District, our visitors; neighbors, and all County residents Who value the scenic views ofthe
prominent hillside. This easement protects the views looking to the north towards Leh igl1r,Quarry. Even
though the massive quarry is located just over the ridgeline from Rancho San. Antonio Open Space
Preserve, the scenic easement ensures that the viewshed remains one of natural splendor to be enjoyed
by preserve visitors, neighbors and everyone in the Santa Clara Valleyregion. The scenic easement
explicitly prohibits the mining activities proposed in the 2019 Amendment. To conform with existing
legal requirements and uphold the intent of the scenic easement, the District urges that the County
require Lehigh to amend its 2019 Amendment application to ensure compliance with County rules and
regulations, and with the land use restrictions that apply to this important scenic easement. At a
minimum, Lehigh should be required to provide an alternative in their application that complies with the
scenic easement before the application is deemed complete.
Geotechnical Stability
The District raises significant concerns that recent mining activities remain out. of compliance with the
County -approved 2012 Reclamation Plan. These activities have created over -steepened quarry wall
330 Distel Circle Los Altos, ,CA 94022_ P 65o:691.1aoo I F 6so.691.0485 I vrww.openspace.org
slopes with insufficient benches, resulting in a less stable hillside that is prone to erosion and landslides.
These over -steepened slopes are not properly mitigated in the 2019 Amendment, and should be
reviewed by the County Geologist, State Office of Mine Reclamation, and State. Mining and Geology
Board immediately.
The District also has concerns regarding Lehigh's proposal to mine the ridge that is protected by the
Permanente Ridge Scenic Easement. The 2019 Amendment cites the need to address potential erosion
and stability issues created by raining the northern quarry slope, However, the proposal to mine the
ridge that lies within the Scenic Easement in reality does little to lessen the slope steepness. To
sufficiently address the stability issues, Lehigh should be required to follow the approved 2012
Amendment that calls for buttressing -the -mined slope with material from the WMSA. Expanding the
mining area into the area protected by the Scenic Easement is not an acceptable approach to rectifying a
condition created by past mining practices. It appears that the main driving benefit in'mining this
protected ridlge.protected is to extract additional product for additional profit by the quarry.
Water Quality
in the application, Lehigh cites water quality concerns associated with backfilling the quarry pit and
buttressing the north quarry slope with the material stockpiled in the WMSA. However, the Regional
Water Quality Control Board (RWQ(B) developed and issued their recent 2018 Waste Discharge
Regauirements (WDR's) based upon the existing 2012 Reclamation Plan, which .included relocating the
WMSA into the quarry pit and (buttressing the steeply mined quarry walls, indicating that water quality
objectives are achievable using this approach. Lehigh does not provide material evidence to support
their position, except for their desire to stop treating the groundwater they have intercepted through
mining activities. ,Again, one has to assume that increasing the profit of the quarry through reductions in
operating costs are the plain driver for this proposal.
Important to a successful reclamation will be the non -limestone materials used to backfill the lowermost
elevations of the quarry pit (includingi leevations below the water table that have been' mined since the
2012 Amendment approval). Lehigh's proposed 201J Amendment estimates that 80% of the total
volume in the WMSA contains non -limestone rock. Lehigh has also stockpiled substantial volumes of
non -limestone rock (primarily greenstone) elsewhere in the quarry., Given the volume of non -limestone
material needed to backfill the large raining pit, itis critical to retain all existing non -limestone material.
onsite to use as backfsll..This materialshould not be sold or hauled off site. Rising existing onsite
material avoids the added environmental impacts related to greenhouse gas emissions, traffic, and
diesel exhaust that would otherwise occur if the County accepts Lehigh's proposal to sell and off: haul
existing material for profit and import and in -haul outside fill for an additional ,profit. The trucking of
this material is substantial with an estimate given of up to one -million cubic yards of construction soil
imported annually to the site from throughout the South San Francisco Ray Area. Theapplication fails to
describe the environmental impacts to Cupertino, surrounding communities, and Rancho San Antonio
Open Space Preserve related to the off -haul and in -haul of this material. Moreover, the, proposed use of
imported soil (rather than onsite material) to fill in the mining pit is anticipated to extend the current 5 -
year reclamation timeline by an additional 25-30 years. The resulting extensive delay is unacceptable.
Visual Impacts
Lehigh's proposed 2019 Amendment would raise the WMSA an additional 160 feet in elevation. This
proposal runs fully contrary to the prior approved 2012 Amendment, which requires removal of the
WMSA. As part of the 2012 Amendment, the County recognized the visual impact of the expanded
WMSA and allowed Lehigh to temporarily retain the WMSA during mining activities with the
requirement that the WMSA be removed as part of reclamation activities. Adding 160 feet of additional
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elevation would clearly result in greater visual impacts than the current 2012 Amendment and negate
the original agreements made between the County and Lehigh.
Air Quality Impacts
The proposed mining of the scenic easement and additional storage at the WMSA. are ridgetop
construction activities subject to wind erosion. The District conducted an extensive air monitoring study
in 2013-2014 at Rancho San Antonio Open Space Preserve (Winegar Air Sciences, October 2104). The
study noted a correlation in the increase of particulate matter with proximity to the Lehigh quarry. The
air was clearly degraded by particulate matter at a sample point located closest to Lehigh When
compared with up -wind monitoring locations. Concentrations of particulate matter 10 micrometers or
less in diameter (PM10) exceeded the California Standard at the monitoring.site closest to Lehigh. The
proposed mining activities pose a significant new air quality concern to the District and should 'be
sufficiently addressed in the application
Delays in Completing the Permanente. Creek Restoration Area
The ongoing delay in completing the Permanente Creek Restoration Area (PCRA) is of continued concern
to the District. The 2019 Amendment states that "The proposed reclamation plan. amendment would
not change the reclamation approach or requirements forthe PCRA". What appears to change is the
timeline. Under the existing 2012 Amendment, PCRA restoration is to be completed by 2030. Per the
2019 Amendment, the timeframe for restoration is 10-20 years from approval, an extension of up to an
additional 10 years — out to potentially 2040. Lehigh's existing -slow pace for submitting necessary items
requested by the County to comply with the 2012 Amendment raises serious concerns that the same
slow approach and resulting delays would occur if the proposed 2019 Amendment is approved. Our
concerns for the creek were recently justified and heightened by recent landslides from the Yeager Yard
area into Permanente Creek, The PCRA restoration should be completed as soon as possible, and should
not be delayed for another decade. The 2019 application should also be deemed incomplete because it
lacks specificity in describing the timeframe for restoration of the PCRA.
The County holds the authority to uphold its commitment to the surrounding communities by protecting
the Permanente Ridge Scenic Easement and requiring the timely implementation of the approved 2012
Amendment. It is clear that the existing 2012 Reclamation Plan is liar superior to the Proposed 2019
Amendment by remaining much more protective of human health,. the surrounding environment, and
scenic vistas. The County is asked to deem Lehigh's.2019 Reclamation Plan Amendment application as
incomplete until all the issues discussed above are adequately addressed.
Sincerely,
6 -
Ana M. Ruiz
General Manager
Midpeninsula Regional Open Space District
cc: Midpeninsula Regional Open. Space District:(District) Board of Directors
Erika Guerra, Environmental Director, Lehigh Quarry
Brian Malone, Assistant General Manager, District
Kirk Lenington, Natural Resources Manager, District
9
City of San Josh Earns LEED for Cities Platinum Certification
Amanda Komar Sep 21, 2018
San dose is the first city in California to be honored by the U.S. Green Building Council's LEED
for Cities program, which recognizes city -level sustainability policies and programs that reduce
air pollution and improve quality of life for residents
SAN JOSE, Calif. — The City of San Jose announced that it has achieved LEED Platinum
certification in recognition of its efforts to improve sustainability and quality of life, becoming
the first city in California and one of the first in the world to be certified under the U.S. Green
Building Council's LEED for Cities program.
Mahesh Ramanujam, president and CEO of the USGBC, the creators of LEED, said San Jose is
one of the global cities leading the way on green building, urban sustainability and climate
change mitigation.
"This is a wonderful accomplishment that signifies San Jose is setting the bar for what is
possible, creating a healthy and safe place where citizens can thrive," Ramanujam said. "Cities
and communities, that achieve LEED certification are lowering carbon emissions, creating a
healthier environment and striving to improve quality of life for their residents. San Jose has set
a standard for sustainability performance.
LEED, or Leadership in Energy and Environmental Design, helps buildings, communities and
cities achieve high performance in key areas of human and environmental health. LEED I for
Cities is a performance-based program that enables cities to measure, evaluate and benchmark
their sustainability performance. As a LEED-certified city; San Jose has access to Arc, a digital
performance platform that enables cities to 'better track sustainability performance and improve
related programs.
The LEED Platinum certification validates the City's commitment to sustainability policies that
benefit residents and ensure the long-term vitality of the community, with cleaner air and a
secure water supply. San Jose joins a short list of LEED-certified cities around the globe,
including Washington, D.C.; Phoenix, Arizona; Lancaster, Pennsylvania; Savona, Italy; and
Surat, India.
"I thank the U.S. Green Building Council for naming San Jose as California's first LEED-
certified city, and for recognizing our steadfast commitment to environmental sustainability,"
said San Jose Mayor Sam Liccardo. "While national leadership continues to abdicate its
environmental responsibilities, San Jose will persist in its efforts to fight climate change and
build a more sustainable community."
San Jose's LEED Platinum certification recognizes the City's sustainability leadership in several
key areas, including:
Climate Smart San Jose, a new initiative to reduce greenhouse gas emissions, save water and
improve quality of life. Climate Smart builds upon the City's 2007 Green Vision, making San
Jose one of the first major U.S. cities to establish a climate action plan that aligns with
the Paris Agreement
Waste reduction and diversion, including a goal of zero waste by the year 2022, as outlined in
the City's Zero Waste Strategic Plan
Transportation, as demonstrated by the City's new Vehicle Miles Traveled metric, a
sustainability -oriented method for analyzing transportation impacts
The certification also recognizes the City's community engagement. In shaping Climate Smart
San Jose, for instance, the City conducted extensive public outreach in English, Spanish and
Vietnamese and worked closely with our community and stakeholders.
"Sustainability is vital to San Jose," said Kerrie Romanow, director of the City's Environmental
Services Department. "We are constantly searching for new ways to improve the lives of our
residents and make sure San Jose is healthy for decades to come. Our new climate action
community plan, Climate Smart San Jose, is just the latest example of that commitment."
San Jose is one of six recipients of a generous grant the Bank of America Charitable Foundation
provided to accelerate the next generation of high-performance cities.
https•//www usgbc org/articles/city-sanjos%C3%A9-earns-leed-cities-platinum=certification-0
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Berkeley. first city in California to ban natural gas in new buildings
The city of Berkeley will no longer allow natural gas pipes in many new buildings starting Jan.
1, 2020. It's the first city in California to pass such a law, officials said.
The Berkeley City Council voted unanimously Tuesday night in favor of the legislation, put
forward by downtown Councilwoman Kate Harrison's office and council co-sponsors Cheryl
Davila, Ben Bartlett and Sophie Hahn.
Public support was also unanimous during 45 minutes of comment from community members
and representatives of the University of California's Office of the President (UCOP), energy
giant PG&E and the Sierra Club, among others who spoke.
UCOP Associate Director of Sustainability Ryan Bell told officials UC is on board with the idea
and already has a policy, as of July 1, to avoid natural gas space and water heating inmost new
facilities. The university has all -electric buildings — from labs and dormitories to office space
— going up around the state "in all climate zones.
https•//www berkeleyside com/2019/07/17/natural-gas-pipes-now-banned-in-new-berkeley-
buildings-with-some-exceptions
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