January 6, 2009
e-mail from Palo Alto Public Works Department requesting clarification
regarding permissibility of current composting operations

(Emphasis and Link Added)



Kennedy, Sean <Sean.Kennedy@CityofPaloAlto.org> 01/06/2009 3:45 PM

Nanci-

I talked with you on the phone in December about an activity that might require a lease amendment to Palo Alto's Byxbee Park Landfill's State Lands Commission (SLC) Lease-Agreement PRC 7348.9.

As you probably are aware, the City of Palo Alto currently operates the Palo Alto Landfill and a composting operation that is fully permitted by the State of California (standardized permits), at a 137.24 acre parcel near the baylands at 2380 Embarcadero Road. This parcel comprises a 50-acre section of active landfill and composting operation (Phase IIC), a 30-acre section of closed landfill converted into pastoral park open to public (Phase I), and about another 50 acres of closed landfill (Phases IIA and IIB) which is not open to the public but fenced off (acreages approximate). The 50-or-so acres of active landfill (and composting operation) is expected to be filled to capacity and undergo closure in late 2010, at which time all activities will cease. By early 2010, we will conduct and submit CEQA and an application to amend the SLC Lease-Agreement for final closure activities, as we usually do in order to complete closure of the landfill in accordance with SLC permitting requirements and California Integrated Waste Management Board (CIWMB) state regulations.

Recently, our City Council has indicated that they might want to continue composting operations on top of the closed landfill, if it proves to be economically and environmentally desirable to the Council and citizens of Palo Alto. They are currently reviewing and assessing this possibility. You could help us by answering the following questions:

*          Would continuing composting after the landfill is closed be an activity that would require an amendment to the SLC Lease Agreement PRC 7348.9 or would it just be subject to permitting under the CIWMB?

*          Would the SLC view such an activity as consistent or inconsistent with the public trust needs?

*          Could you outline the process for obtaining an SLC permit or approval for such an activity.

Your timely response to these questions would be greatly appreciated, if you need any further information to answer these questions, please con tact me.

Sincerely, Sean Kennedy, P.E., Superintendent, City of Palo Alto Public Works/Operations, phone (650) 496-6904, fax (650) 852-9289, sean.kennedy@cityofpaloalto.org