ecomm digital microwave project, phase ii phase ii is-ea and...ecomm digital microwave project,...

Initial Study / Environmental Assessment and Mitigated Negative Declaration

ECOMM DIGITAL MICROWAVE PROJECT, PHASE II

February 2010Prepared forSanta Clara County Communications Department;National Telecommunications and Information Administration

225 Bush StreetSuite 1700San Francisco, CA 94104415.896.5900www.esassoc.com

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Woodland Hills

209451

Initial Study / Environmental Assessment and Mitigated Negative Declaration

ECOMM DIGITAL MICROWAVE PROJECT, PHASE II

February 2010Prepared forSanta Clara County Communications Department;National Telecommunications and Information Administration

ECOMM Digital Microwave Project, Phase II i ESA / 209451 Initial Study / Environmental Assessment and Mitigated Negative Declaration February 2010

TABLE OF CONTENTS ECOMM Digital Microwave Project, Phase II Initial Study / Environmental Assessment and Mitigated Negative Declaration

Page Background 1 Proposed Project Overview 2 Purpose and Need 3 Project Approvals 5 Environmental Review Methodology 8 Project Description 10 Proposed Project Location and Schedule 10 Existing ECOMM Network and Proposed Expansion 10 Individual ECOMM Sites 13 Category 0 – Interior Equipment Upgrades at Existing Facilities 14 Category 1 – Replace Existing Antennas at Existing Facilities 17 Category 2 – Add New Microwave Antennas at Existing Facilities 19 Category 3 – Construct New Towers / Shelters at Existing Sites 33 Environmental Impacts 43 1. Aesthetics 43 2. Agricultural Resources 48 3. Air Quality 50 4. Biological Resources 59 5. Cultural Resources 68 6. Geology and Soils 73 7. Hazards and Hazardous Materials 78 8. Hydrology and Water Quality 92 9. Land Use and Planning 102 10. Noise 104 11. Population and Housing 108 12. Public Services 109 13. Mineral Resources and Recreation 110 14. Transportation / Traffic 112 15. Utilities and Services Systems 115 16. Mandatory Findings of Significance 120

Table of Contents

Page

ECOMM Digital Microwave Project, Phase II ii ESA / 209451 Initial Study / Environmental Assessment and Mitigated Negative Declaration February 2010

List of Photos Carol Drive Site 13 Pacheco Peak 17 Gilroy Target Range 18 San Jose Communication Center 19 Frazier Peak 21 Sunnyvale Police Department 21 Los Altos Police Department 22 Rodoni 22 Carol Drive 23 Holiday Lake 24 Coyote Peak 25 El Toro 25 El Camino Hospital 26 El Camino Hospital 26 Sunnyvale Corporate Yard 27 Good Samaritan Hospital 27 San Jose Airport 28 Fire Station 25 29 Fire Station 28 29 San Jose City Hall 30 Doyle Road 31 San Jose Police Department South Substation 32

List of Figures Figure 1 Regional Site Location 11 Figure 2 ECOMM Network Configuration 12 Figure 3 Typical Rack Configuration 16 Figure 4 Gilroy Reservoir Site 35 Figure 5 Woodland Acres Site 37 Figure 6 Lakeview Court Site 39 Figure 7 Gilroy City Hall Annex Site 41

List of Tables Table 1 Category 0 – Sites Requiring Interior Equipment Upgrades at

Existing Facilities 15 Table 2 Category 1 – Sites Requiring Replacement of Existing Antennas

at Existing Facilities 17 Table 3 Category 2 – Sites Requiring Placement of New Antennas at

Existing Facilities 20 Table 4 Category 3 – Sites Requiring Installation and Construction of

New Towers and/or Equipment Shelters 33

ECOMM Digital Microwave Project, Phase II 1 ESA / 209451 Initial Study / Environmental Assessment and Mitigated Negative Declaration February 2010

ECOMM DIGITAL MICROWAVE PROJECT, PHASE II Initial Study / Environmental Assessment and Mitigated Negative Declaration

Background In 2007, the City of San Jose prepared a joint California Environmental Quality Act (CEQA) Initial Study and National Environmental Policy Act (NEPA) Environmental Assessment (2007 IS/EA) to analyze the environmental impacts of implementing the first phase of a region-wide digital microwave interoperability communications network, also called the “E-COMM System.” The 2007 IS/EA included all NEPA and CEQA environmental criteria and considered the system first as a whole and then analyzed the isolated impacts of each of the 22 individual communication sites that were widely separated across Santa Clara County.

The San Jose Police Department managed the U.S. Department of Justice grant for the ECOMM Phase I project, the City of San Jose was the local CEQA lead agency, and the Department of Justice provided NEPA review. The project actions at each site ranged from upgrading radios, adding support equipment and replacing antennas to building new communications towers.

The 2007 IS/EA determined that all environmental impacts of implementing the overall ECOMM network were less than significant and the impacts of constructing and operating each of the individual communication sites were either less than significant or could be mitigated to less than significant levels. The project has been implemented and the ECOMM private (i.e., dedicated) microwave network now links all 14 of the 9-1-1 Call Centers in Santa Clara County and enables high-speed sharing of dispatch services, records databases, and voice traffic (via interoperable communications, when available) between law enforcement, fire protection, and emergency medical services throughout the County. ECOMM allows first responders to improve local incident response times as well as enables the County to better manage regional incidents.

Environmental Impacts


Proposed Project Overview In 2009, the Santa Clara County Communications Department was awarded a grant from the National Telecommunications and Information Agency1 (NTIA) to study and implement a second phase of the ECOMM System. ECOMM Digital Microwave Project, Phase II (ECOMM Phase II) would further expand the ECOMM system by linking to additional emergency communications networks throughout the County, thereby expanding the coverage area. Some of the communication sites selected for ECOMM Phase II installations were modified as part of the ECOMM Phase I project, while other sites are new.

As did the Phase I project, the proposed ECOMM Phase II project requires environmental review in accordance with the criteria, standards and provisions of the California Environmental Quality Act (CEQA) of 1970, as amended, and the National Environmental Policy Act (NEPA) of 1969. This IS/EA is being prepared in accordance with State of California, under CEQA, and U.S. Federal, under NEPA, laws and regulations2 designed to evaluate and minimize impacts of the proposed project. This document would be used by federal, state, regional, and local agencies to assess the environmental impacts of the proposed project on resources under their jurisdiction and to make decisions regarding the project.

Since the Santa Clara County Communications Department was awarded the grant, in accordance with County procedure the Department is the CEQA Lead Agency. The NTIA, as the issuer of the grant, would be the lead agency for NEPA environmental review purposes.

This document extends the analyses in the 2007 IS/EA. However, relevant parts of the 2007 document are reproduced below to provide context and to make this document as complete as possible without the need to reference the 2007 document.

Jurisdictional Involvement Nineteen participating jurisdictions have signed the Santa Clara County Data Communication Network Joint Funding Agreement dated March 5, 2002 and the Second Amended Santa Clara County Data Communication Network Joint Funding Agreement dated September 1, 2004. The following agencies will be directly involved in the approval or implementation of the ECOMM Phase II network expansion project:

1 An agency in the U.S. Department of Commerce that serves as the executive branch agency principally responsible

for advising the President on telecommunications and information policies. 2 California Environmental Quality Act (CEQA) Public Resources Code 21000 et seq., and CEQA Guidelines Code

of Regulations, Title 14, Section 15000 et seq., and Section 15063, specifically for preparation of Initial Studies. National Environmental Policy Act (NEPA), the Council on Environmental Quality (CEQ) implementing regulations Part 40 Code of Federal Regulations (CFR) Section 1500 et seq.

• County of Santa Clara (as Lead Agency) • City of San Jose • City of Gilroy

• City of Morgan Hill • City of Sunnyvale • City of Los Altos



The following participating agencies were involved in the Phase I project and several will be involved in the Phase II network expansion project. However, changes at these individual sites would be limited to actions that are equivalent to routine maintenance of the existing communications equipment and would normally be categorically exempt from environmental review. Therefore, these jurisdictions would not be required to issue additional permits or grant any additional approvals.

• City of Campbell • City of Cupertino • City of Milpitas • City of Monte Sereno • City of Mountain View • City of Palo Alto • City of Santa Clara

• City of Saratoga • City of Sunnyvale • San Jose State University • Santa Clara Valley Water District • South Santa Clara County Fire District • Town of Los Altos Hills

Purpose and Need

Purpose As presented in the 2007 IS/EA, the purpose of constructing the first phase of the ECOMM system was to establish a private3 microwave radio network that would provide a digital backbone to link all fourteen 9-1-1 call centers in Santa Clara County, as well as provide high-speed sharing of dispatch services, records databases, and voice traffic, to provide interoperable communications between law enforcement, fire protection, and emergency medical services throughout Santa Clara County. This would allow first responders to improve local incident response times as well as better manage regional incidents.

As stated above, the ECOMM Phase II project is a continuation and expansion of the Phase I project, with the primary purpose to fill in the communications capabilities of the network and connect it to other emergency facilities within the county.

Need The need for the proposed project (Phase II) is to ensure reliable connections across the specifically selected additional emergency facilities within the County and to expand into a more robust emergency communications network. The following text from the 2007 IS/EA is intended to provide a more comprehensive overview of the need for the ECOMM system as a whole.

The City of San Jose has a resident population of over 900,000. Currently, San Jose is the third largest city in California and the tenth largest city in the country. The U.S. Department of Commerce ranks San Jose as the second leading exporter in the country, with $28.2 billion dollars per year in trade. The electronics industry represents the majority of this figure, making San Jose the most wired city in the country. The City is located within the County of Santa Clara, which

3 “Private” meaning there would be no access or use other than by its operators / participating agencies.



has an overall population of 1.7 million. The Greater San Francisco Bay Area, which encompasses Santa Clara, San Mateo, Marin, Sonoma, Santa Cruz, Alameda, San Francisco, Contra Costa, and Napa counties, has a population of over 8,000,000. This represents over 25 percent of the total population of California.

Santa Clara County and the Greater Bay Area is host to a number of high-risk targets as defined by the California Anti-Terrorist Information Center (CATIC).4 Given this risk, it is likely that in the event of a major natural disaster or terrorist attack, emergency first responders from throughout the county will be called upon to respond and support each other. When that occurs, it will be vital that these first responders have the tools and resources necessary to support rescue efforts – in short, they must have the ability to effectively and efficiently share information and communicate directly with each other in “real-time”. In those circumstances, the current time delay in relaying information – from one first responder in the field to their dispatcher, to another dispatch center and then back to another agency’s first responder – is inadequate and inefficient.

Like its public safety counterparts across the nation, law enforcement, fire and emergency medical first responders in the City of San Jose and local agencies throughout Santa Clara County have had to contend with performance issues associated with the inefficient and untimely exchange of information, a lack of inter-agency field communication and unnecessarily long call processing times. These limitations severely and detrimentally impact the delivery of timely and quality law enforcement, fire and emergency service delivered by more than 3,300 public safety emergency responders handling nearly 1.5 million calls for service each year.

Following the 1993 World Trade Center terrorist attack, the Oklahoma City Bombing, and Columbine High School shooting, the need for interoperable communication and the reliability and compatibility of our radio systems once again surfaced as a critical public safety issue. The historic and tragic events of September 11, 2001, made that issue all the more clear for public safety personnel. “It is important to remember the first line of defense against domestic terrorism and the first response to terrorist attacks and other emergencies is by state and local public safety agencies…local governments therefore must have the necessary tools, including communications capabilities, to protect the safety of life, health and property.”5

One of the major challenges facing public safety in San Jose and surrounding communities is disparate systems – radio and computer systems. For a variety of reasons established long before interoperability was a common phrase in public safety language, agencies acquired radio channels in vastly different frequency bands. In Santa Clara County alone, law enforcement, fire and emergency medical agencies operate in five distinct frequency bands – Low-Band Very High Frequency (VHF), High-Band VHF, 460 megahertz (Mhz), 480 Mhz “T-Band” and 800 Mhz. Most of the law enforcement radio networks are decades old and are not equipped for interoperability functions. On the other hand, fire agencies in the County and throughout the State of California have fewer issues of voice radio interoperability with each other, as they predominately operate in the same bandwidths, have a secondary mobile radio in their fire apparatus for communication with those that do operate in different frequency bands, and widely utilize county and statewide mutual aid networks. Although law enforcement has a countywide Mutual Aid Radio Channel (MACS – Mutual Aid Communications System), a system that was upgraded in the late 1990s to improve coverage, it still requires dispatcher intervention to activate a “patch” between the various bands in order for field personnel to communicate with each other. Time delays in bridging agencies together with training issues rising from infrequent use makes smooth and coordinated inter-agency communication almost non-existent for law enforcement.

4 CATIC Informational Released to Law Enforcement, 2003–Law Enforcement Sensitive Information 5 APCO President Thera Bradshaw testimony, Sept 25, 2002 before the United States House of Representatives

Committee on Commerce, Science & Transportation Subcommittee on Telecommunications and the Internet, Public Safety Communications, November 2002



It may become necessary, in the future, to further expand the ECOMM network in response to the establishment of new agency offices, changing population patterns, need for additional communication sites, and the like. Any further extensions of the network in the future would be for the same basic purpose and to satisfy the same basic need as those of the proposed project, namely to increase the effectiveness and efficiency of the regional communication system and enable first responders to communicate on demand, when needed, in real time, when authorized, across disciplines and jurisdictions, during day-to-day, task force, mutual aid operations and major incidents throughout the County.

Project Approvals Santa Clara County Communications Department, as Lead Agency, will coordinate with Responsible Agencies during preparation of the Initial Study to assure that information relevant to CEQA is obtained and considered. Likewise, the NTIA will ensure that information relevant to NEPA will be obtained and considered. In addition, the City of Morgan Hill and Gilroy will administer building permits for sites where ground disturbance is expected.

CEQA Environmental Review Santa Clara County Communications Department is the CEQA Lead Agency for the ECOMM system environmental review. Under CEQA, some of the participating jurisdictions in Santa Clara County may be Responsible Agencies, in that they may need to rely on the findings of this environmental review for any discretionary actions they may need to take with regard to implementing or approving their part of the proposed project. It is assumed that the conditions of approval for each site would be implemented for permitting purposes as required by the appropriate Responsible Agency (e.g., design review by a planning commission or similar body).

This Initial Study will consider all of the elements in the CEQA Guidelines, Appendix G environmental checklist. In addition, the Initial Study will also include the required NEPA elements, as described in the section below.

NEPA Environmental Review In February 2009, the National Telecommunications and Information Administration (NTIA) published a Programmatic Environmental Assessment that evaluated the environmental impacts of the Public Safety Interoperable Communications (PSIC) Grant Program. This document assessed the nationwide and network-based aspects of the program. The programmatic document concluded that environmental effects of the project would be associated entirely with the site-specific disturbances caused by each communication site. Therefore, this NEPA review focuses on the communication site-specific aspects of the proposed project and not on the system-wide effects, since NTIA determined that these effects were less than significant.

This environmental review, which tiers off of the programmatic document and continues the analysis begun in the first 2007 ECOMM IS/MND, considers all of the NEPA study elements



enumerated in the Department of Justice NEPA Guidelines, 28 CFR 61, and due to the nature of the E-COMM project, the Federal Communications Commission NEPA Guidelines for radio communications systems, 47 CFR Chapter 1, Subpart I, Section 1.1311. These additional elements for NEPA review include the following sections:

• Alternatives Analysis (presented below)

• Section 1 – Aesthetics: Would the project create a new source of substantial light or glare?

• Section 4 – Biological Resources: Would the project be located within a wilderness area or wildlife preserve; would affect listed or proposed endangered or threatened species or designated or proposed critical habitats?

• Section 5 – Cultural Resources: a) Would the project affect districts, sites, buildings, structures or objects significant in American history, architecture, archeology, engineering or culture, that are listed, or are eligible for listing, in the National Register of Historic Places? b) Would the project affect Native American religious sites (Senate Bill 18)?

• Section 6 – Geology: Would the project involve significant change in surface features such as wetlands fill, deforestation, or water diversion?

• Section 7 – Health and Safety: Would the project result in human exposure to levels of radio frequencies in excess of FCC guidelines?6

• Section 8 – Hydrology and Water Quality: Would the project be located within a floodplain?

Alternatives Analysis An analysis of alternatives for the proposed project is required as part of an Environmental Assessment under NEPA (CEQ Section 1502.14). Alternatives are not required to be analyzed in an Initial Study under CEQA.

No Action Alternative Under the No Action Alternative, the Phase II extension of the emergency communications network would not occur. The Phase I network would continue to operate as it does presently, using the system established under that first phase of the project. Because Phase II of the project would not be implemented and because Phase I of the project is already complete, no additional environmental impacts would occur.

6 The Federal Communications Commission (FCC) is an independent United States government agency, directly

responsible to Congress. The FCC was established by the Communications Act of 1934 and is charged with regulating interstate and international communications by radio, television, wire, satellite and cable. The FCC's jurisdiction covers the 50 states, the District of Columbia, and U.S. possessions. All microwave stations and towers require licensing by the FCC, in accordance with the Code of Federal Regulations (CFR) Title 47, Chapter 1, Part 101, Section 101.1 et seq.



Preferred Alternative (Proposed Project) The primary objective of the proposed project is to expand the ECOMM system by filling in the network already established under Phase I and establishing network connections to additional emergency facilities within the County. The secondary objective is to evaluate additional public safety sites within Santa Clara County for suitability to interconnect with these emergency call centers in the future. To achieve this goal, 10 existing sites would be modified in order to connect the 15 new sites to the existing communications network, with 10 additional existing sites selected to undergo minor equipment upgrades.

As with sites selected for the ECOMM Phase I project, the sites selected for the ECOMM Phase II project were chosen based on the following criteria, to the degree feasible:

• Use sites with existing structures that provide microwave antenna supports without new construction.

• Use the shortest paths between sites in order to:

- Maximize transmission reliability - Use the smallest practical microwave dish size - Use the lowest practical microwave transmitter power - Maximize the likelihood of available FCC frequency pairs - Avoid terrain, vegetation or man-made obstructions on the microwave path. - Provide higher transmission capacity to the larger population regions on the ring, and

provide lower transmission capacity to the lower population regions, on spur paths.

Environmental Justice (Executive Order 12898, enacted February 11, 1994) Pursuant to Executive Order 12898 on Environmental Justice, Federal agencies are to make the achievement of environmental justice part of their mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of their programs, policies, and activities on minority populations, low-income populations, and Indian tribes and allowing all portions of the population a meaningful opportunity to participate in the development of, compliance with, and enforcement of Federal laws, regulations, and policies affecting human health or the environment regardless of race, color, national origin, or income.

Composition of Proposed Project Area Based on the data from the U.S. Bureau of Census, the following data was obtained on population, ethnicity and economic status for each affected jurisdiction.



DATA

COUNTY CITIES

SAN

TA

CLA

RA

CA

MPE

LL

GIL

RO

Y

LOS

ALT

OS

MIL

PITA

S

MO

RG

AN

H

ILL

MO

UN

TAIN

VI

EW

PALO

ALT

O

SAN

JO

SE

SAN

TA

CLA

RA

SUN

NYV

ALE

Total Population 1,731,281 38,138 41,464 27,693 62,698 33,556 70,708 58,598 894,943 102,361 131,760 White 882,547 27,758 24,426 22,250 19,353 24,296 45,090 44,391 425,017 56,903 70,193 Black/ African American 44,840 964 745 130 2,295 573 1,789 1,184 31,349 2,341 2,927 Latino/Black 445,481 5,083 22,298 822 10,417 9,229 12,911 2,722 269,989 16,364 20,390 Asian 514,151 5,402 1,810 4,271 32,482 2,020 14,613 10,090 240,375 29,966 42,524 Native Hawaiian/ Pacific Islander 7,317 88 105 45 393 77 182 84 3,584 437 428 American Indian/ Alaskan Native 8,284 248 661 48 388 362 273 122 6,865 542 608

Income (1999) Total Households 585,430 15,973 11,933 10,455 17,158 10,813 31,229 25,308 276,408 38,564 52,610

Median $80,838 $67,214 $62,135 $126,740 $84,429 $81,598 $69,362 $90,377 $70,243 $69,466 $74,409 Mean $104,229

Total Families 408,873 9,216 9,773 8,036 14,194 8,618 16,074 14,848 205,906 24,427 32,918 Median $93,072 $78,663 $65,330 $148,201 $84,827 $90,134 $80,379 $117,574 $74,813 $77,189 $81,634 Mean $117,506

Income Below Poverty Level All Families 6.4% 3.2% 7.3% 1.1% 3.3% 3.3% 3.6% 3.2% 6.0% 4.5% 3.7% All People 9.0% 4.8% 10.4% 2.4% 5.0% 4.7% 6.8% 4.8% 8.8% 7.8% 5.4%

SOURCE: County: U.S. Census Bureau, 2006. American Community Survey Estimates for Santa Clara County, California. (http://factfinder.census.gov); Cities: U.S. Census Bureau, 2000. Summary File 1 (SF 1) and Summary File 3 (SF 3) (http://factfinder.census.gov)

Site Evaluation All of the ECOMM Phase II sites are located at existing police department sites, government buildings, hospitals, or within existing communications facilities. With two exceptions, the project sites are not located within or adjacent to residential areas. None are sited specifically in minority or low income areas. As discussed in Section 5 of the Environmental Impacts section, the Native American Heritage Commission (NAHC) was contacted for information on any local tribes within the local area of sites where ground disturbance is anticipated as part of the proposed project; no information on local Indian tribes was provided by the NAHC. As discussed in the Environmental Impacts section of this IS/EA, all significant or adverse impacts have been mitigated to less than significant levels. Further, the public will have an opportunity to comment on the IS/EA during the 20-day public review period. Notice of the availability and intent to adopt the IS/EA would be posted on the websites of County of Santa Clara, and Notice of Intents would be mailed to each of the affected jurisdictions and agencies for local posting. Therefore, implementation of the project would be in compliance with Executive Order 12898.

Environmental Review Methodology The 2007 IS/MND considered each of the actions involved in implementing the ECOMM system as a whole, as well as each of the actions to develop each communication site. To facilitate the environmental review of the many individual communication sites, the 2007 IS/MND grouped the sites into three categories that reflect the general level of development involved at each site



and, therefore, the potential for site development and operation to cause adverse environmental effects. The categorical hierarchy ranged from actions typically considered to be normal communication site maintenance activities (Category 1) to more substantive actions that could adversely affect the environment (Category 3). The three categories used were:

Category 1 - Replace Existing Antennas at Existing Communications Facilities Category 2 - Add New Microwave Antennas at Existing Communications Facilities Category 3 - Erect New Towers / Equipment Shelters and Install Microwave Antennas at

Existing Communications Sites

The 2007 IS/MND found no significant effects related to CEQA or NEPA environmental criteria that would result from operating the network. The 2007 IS/MND also determined that project impacts resulted only from the individual and cumulative impacts from the individual candidate sites.

In this current IS/MND, the actions involved in expanding the ECOMM system are also considered in order to identify impacts of the system itself. However, based on the findings of the 2007 IS/MND, adverse impacts are not expected from the Phase II expansion of ECOMM; rather, it is expected that all impacts of the project would be those specific effects that occur at the communication sites proposed for development. To facilitate this current environmental review of the individual communication sites, the same three categories from the 2007 IS/MND are used here. In addition, a new lesser category (Category 0) is added to represent sites where only new or replacement communications equipment would be installed within existing shelters at existing sites, with no new exterior microwave feeds or antennas. For example, replacing radio equipment inside an existing equipment shelter is equivalent to a routine maintenance activity7 and is unlikely to result in environmental impacts; therefore, it is designated as “Category 0.” Although it is reasonable to consider that Category 0, and even Category 1, actions are just normal communication site maintenance activities, these actions are included in this analysis because they are a part of the larger Phase II expansion project, and it is necessary to consider the whole of a project in assessing its environmental impact. The four action categories used here are:

Category 0 - Interior Equipment Upgrades At Existing Facilities Category 1 - Replace Existing Antennas at Existing Facilities Category 2 - Add New Microwave Antennas at Existing Facilities Category 3 - Construct New Towers / Shelters at Existing Sites

Note that each category is based on the most environmentally consequential action to be taken; each category may include actions that are included in one or more lower categories. For example, at a Category 3 site, new microwave antennas would be added (a Category 2 action) and equipment installations or upgrades (a Category 0 action) would also occur.

7 Such activities at an individual site can be exempt from CEQA under CEQA Guidelines Section 15301 Existing

Facilities, Section 15302 Replacement or Reconstruction, or Section 15303 New Construction or Conversion of Small Structures. CEQA Guidelines, Sections 15000–15387, California Code of Regulations, Title 14, Chapter 3.



These four categories are used to group the individual sites and these categories are compared to the CEQA or NEPA environmental criteria in the composite checklist to assess the environmental impacts of each component of the Project.

Project Description

Proposed Project Location and Schedule The proposed project would be located within the County of Santa Clara, California. The County of Santa Clara is located at the southern end of the San Francisco Bay and encompasses 1,312 square miles. Also known as the “Silicon Valley,” the county includes the City of San Jose, which is the County’s government seat and has the distinction of being the largest city in the county, the third largest city in the state and the tenth largest city in the United States (City of San Jose, 2006). The Santa Clara Valley runs the entire length of the county from north to south, ringed by the rolling hills of the Diablo Range on the east, and the Santa Cruz Mountains on the west. Salt marshes and wetlands lie in the northwestern part of the county, adjacent to the waters of San Francisco Bay. Figure 1 shows the regional location of the proposed project.

The project would commence in March 2010 and would be completed within approximately three months. Construction duration at each individual site would range from approximately one day at Category 0 sites to approximately three days at Category 3 sites.

Existing ECOMM Network and Proposed Expansion The basic topology of the existing ECOMM network is that of a large “ring” of microwave communications links with a “spur” extension stretching to the southeast to connect to participating jurisdictions in the south part of Santa Clara County. Each of the sites, or nodes, on the basic ring connects to two or more sites and allows communications to all other sites in the ring, whether clockwise or counter-clockwise around the ring. Various other sites in the north County and all of the sites in the southern portion of the County are served by individual transmission links that radiate from the nodes of the basic ring. The basic ring topology provides the network with a redundancy that allows service to continue to all other nodes within the ring, and possibly to all other radiating links as well, in the event that one of the nodes in the basic ring goes offline. Figure 2 illustrates the basic structure proposed for the ECOMM network.

The ECOMM Phase II project would add 15 new nodes as spurs to the existing network, thereby linking additional existing control centers and major communication sites by microwave transmissions, allowing currently isolated jurisdictions to effectively communicate and share resources across jurisdictional boundaries during local and region-wide public safety incidents. ECOMM is independent of commercial wireless and telephone networks, which typically overload and fail during major regional incidents, and could eventually link to other regional interoperable public safety microwave systems being built around the Bay Area.

Pacheco PeakCity Hall Annex

Carol Drive (CountyCommunication Center)

Frazier Peak

Rodoni

Holiday Lake

Palo Alto Civic Center

Eagle Rock

E-COMM Phase II Project. 209451

Figure 1Regional Site Location

SOURCE: GlobeXplorer; Harris Stratex

Existing ECOMM Network Segments

Proposed Phase II Segments

0 5

Miles

YOLO

SOLANO

ALAMEDA

SANTA CRUZ

SANMATEO

SAN FRANCISCO

NAPA

SONOMA

MARIN

CONTRACOSTA

STANISLAUS

SANTACLARA

SACRAMENTO

SANJOAQUIN

Fire Station 28 (2)

Fire Station 25 (2)

Lakeview Court (3)

El Toro (2)

Pacheco Peak (1)

Good Samaritan Hospital (2)

Sunnyvale Corporate Yard (2)

SunnyvalePolice Dept (2)

Woodland (3)

Gilroy Target (2)

Gilroy Reservoir D (3)

San Jose Airport (2)

San Jose Police Dept South Substation (2)

Doyle Road (2)

City Hall Annex (2)

Stickney (0)

Valley Medical Center

Los Gatos Police Department (0)

Carol Drive (2)

Data Center (0)

Frazier Peak (2)

Rodoni (2)

Holiday Lake (2)

Sheriff

Campbell Tower (0)

Morgan Hill Police Department (0)

California Dept of Forestry

Carol Drive (CountyCommunication Center) (0)

Milpitas Police Station (0)

Mountain ViewPolice Department (0)

Los Altos Police Department (2)

El CaminoHospital

Palo Alto Civic Center (0)

Cadwallader Reservoir

Coyote Peak (2)

Eagle Rock (0)

County Admin San Jose CommunicationCenter

San Jose City Hall (2)


Figure 2Existing ECOMM Network and Proposed Phase II Expansions

SOURCE: Harris Stratex

Category (0)

Category (1)

Category (2)

Category (3)

Interior Equipment Modifications

Replace Existing Antennas at Existing Facilites

Add New Antennas at Existing Facilites

Erect New Towers/Shelters and Install New Antennas at Existing Facilites

The following categories, indicated in parentheses (), signify the level of development proposed at each communication network site

Existing ECOMM Network Segments

Proposed Phase II Segments



Most of the communication sites selected for the Phase II project already have existing microwave antennas mounted on existing buildings or towers, and also have their microwave transmitting and receiving equipment located in existing structures. However, the infrastructure at these sites cannot now engage in ECOMM communications. Most of the infrastructure components and advanced interoperability applications needed to do this would be internal to those buildings and support structures, but external microwave dishes would be needed to transmit directional ECOMM digital microwave signals from one node to the next.

Expanding the ECOMM network to these selected 15 sites requires the installation of similar additional microwave dish antennas (or replacement of similarly sized antennas) and equipment at these sites, as well as at each of the 9 corresponding existing ECOMM nodes to which they would connect. The relative flexibility of the ECOMM network, with respect to the microwave antenna sites, would allow the overall system to be considered, approved and developed without being obstructed by the prospect of causing a significant adverse environmental impact due to the location or construction of any particular ECOMM site, since a particular site could potentially be relocated to a nearby location that could avoid any significant impacts.

Individual ECOMM Sites All of the individual communication nodes of the ECOMM system would be located at sites that already serve the radio communications of each participating agency; some would be located at current microwave relay sites. Modifications at most of the individual sites would include the installation of one or two microwave dishes mounted on top of an existing building, on an existing lattice or monopole tower, or on a newly constructed lattice or monopole tower, as well as the replacement or addition of electronic equipment and wiring.

Modifications at the Woodland Acres and Fire Station 25 sites would also require the placement of a new small bridge-like structure, or “waveguide bridge” to house the cabling that connects the microwave antennae to the radio transmitter housed in an adjacent equipment shelter as shown in photographs at right.8 Antennas mounted on rooftops or buildings would require internal cabling to connect the antenna to the equipment inside.

8 All other sites would use existing waveguide bridges or existing underground conduit.

Carol Drive Site Waveguide Bridge from Tower to Shelter



Free-standing equipment shelters or interior equipment rooms would house the ECOMM’s microwave radios, multiplex equipment, direct current charger, batteries, and pressurization equipment on racks.

Establishing a reliable microwave transmission network requires that a clear, straight-line path be available between each pair of transmitting and receiving antennas, i.e., the microwave dishes; therefore, the actual location and orientation of these transmitting and receiving dishes must be precisely determined. Any intervening structures and vegetation along a path would interrupt microwave transmission and make that path unusable.

Since the ECOMM network was already established under Phase I, the Harris Corporation, working closely with the County and the participating jurisdictions, surveyed various existing communication centers and facilities to determine the optimal locations to accommodate the Phase II network expansion. The Harris corporation also prepared Engineering Study Reports for each of the chosen locations that identified specific actions and equipment required to implement the proposed changes at each site.

The level of development that would be required to implement the ECOMM network at each of the individual candidate sites falls into four distinct categories. These categories, and the sites to which they apply, are described below.

Category 0 – Interior Equipment Upgrades at Existing Facilities These sites would require the replacement of or additions of equipment within the interior of the existing communication facilities to optimize the functionality at each site. No other installation, including new towers, monopoles or equipment sheds, or microwave antennas, would occur at these locations. Typically, these types of changes are equivalent to routine maintenance activities at these sites, and do not require any discretionary permits or approvals. Consequently, such minor activities typically do not require any review under CEQA or NEPA. However, they are presented here for informational purposes and to provide a complete account of actions proposed under the whole of the Phase II project. These sites are listed in Table 1, below.

For each individual site, the equipment upgrades9 to be made within a shelter or building’s interior room would include one or more of the following:

• Battery Upgrade: Adding cells to extend the time period that the battery would keep the site operating after commercial power fails. These batteries are similar in size and electrical capacity10 to automobile batteries.

9 Note that these or similar equipment upgrades are required at a number of sites. These are referred to in this text

and tables as “electronic equipment” or “communications equipment” installations or upgrades. 10 The electrical capacities of the batteries proposed for change range from 105 to 530 Ampere-hours (Ah).



TABLE 1 CATEGORY 0 – SITES REQUIRING INTERIOR EQUIPMENT UPGRADES AT EXISTING FACILITIES

Site Name Site Address

Interior Equipment Modifications

MHSB Upgrade

Install Channel

Bank

Install TRAK Clock

Install DSM card

Battery Upgrade

Eagle Rock 4040 Claitor Way San Jose X (1)

Santa Clara County Data Center 1555 Berger Avenue San Jose X (2) X X X

City of Santa Clara 1990 Walsh Avenue Santa Clara X (2) X X X

Mountain View Police Department 1000 Villa Street Mountain View X (2) X X X

Palo Alto Civic Center 250 Hamilton Avenue Palo Alto X (2) X X X

Morgan Hill Police Department 16200 Vineyard Boulevard Morgan Hill X X X

Stickney Cellular Communications Facility

Oak Knoll Road Los Gatos X X X X

Los Gatos Police Department 110 East Main Street Los Gatos X X X X

Campbell Police Department 70 N. First Street Campbell X X X

Milpitas Police Station 1275 North Milpitas Blvd. Milpitas X X X

SOURCE: County of Santa Clara, 2009

• MHSB Upgrade: Increases link reliability by adding a second "standby" microwave radio into the equipment shelf, to be automatically switched on-line if the main radio fails (a duplicate transmitter receiver).

• Channel bank: A network component that converts the microwave radio payload to voice circuits, typically used to connect dispatch centers to radio base stations.

• TRAK clock: Provides a timing reference to synchronize the digital network data traveling between network components such as channel banks, multiplexers, and microwave radios.

• DSM Card: Provides an adjustable time delay to synchronize the signal arrival from multiple radio base stations to the first responder’s radio (Simulcast).

• GPS Antennas: To receive GPS signals needed for simulcasting, two small, cone-shaped antennas, each approximately 3.5 inches in diameter at the base and 4 inches in height, are typically mounted on the equipment shelter, as needed.


Figure 3Typical ECOMM Equipment Rack Configuration


40

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0

7' 0"

#A64859AB #2

Battery/Charger Rack

Weight: 363 KgLife: 20 years

160AH/48V Battery #1

LXP 30A Charger #1

Dehydrator #1

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#A64859AB #1

TRuepoint5200 RFU

11 #1

TRuepoint 5000 SPU #1

IMACS 800 #1

DS1 jackfield #1

Zyxel Ethernet Switch #1

Cisco ASA 5510 #1

TRAK GPS #1

Std F & A Panel #1

DSM card plugsinto this shelf

This shelf is theChannel Bank

At some sites thisweatherproof cabinetis mounted outdoorsnear the antenna



Category 1 – Replace Existing Antennas at Existing Facilities Two sites fall within this category. Modifications here would require only the direct replacement of an existing microwave dish on the existing towers. No new towers, monopoles or equipment sheds would be constructed. The replacement microwave dishes typically would be the same size or smaller than the existing dishes to be replaced and new dishes may also require replacement of similar existing waveguide bridges and cabling. The ancillary microwave radios, multiplex equipment, DC charger, batteries, and pressurization equipment on racks would be installed within the existing building or equipment shelters, replacing similar existing microwave radio equipment11. The sites with actions that fall under Category 1 are listed in Table 2. Detailed descriptions of the proposed actions are presented below.

TABLE 2 CATEGORY 1 – SITES REQUIRING REPLACEMENT OF EXISTING ANTENNAS AT EXISTING FACILITIES

Site Name Site Address Proposed Actions

Pacheco Peak 10164 Pacheco Peak Pass Road Hollister

Remove 1 existing dish, place 1 new dish on existing tower; Replace electronics in existing rack in vault

Gilroy Target Range 1598 Southside Drive Gilroy

Remove 2 dishes, place 2 new dishes on existing tower; Place 2 racks in existing shelter


Pacheco Peak The Pacheco Peak site is located at 10164 Pacheco Pass Road, in unincorporated Santa Clara County. The isolated project site is surrounded by undeveloped land and is located on top of a hill accessed via a 4.5-mile private, largely unpaved road. The paved site contains shelters, towers and equipment associated with the communications facilities, and is surrounded by natural vegetation and boulders. Highway 152 is north of the project area and Pacheco State Park is adjacent to and east of the site.

The existing site, owned by the state of California, contains two towers with various antennas and three concrete, air-conditioned equipment shelters. Santa Clara County leases space on a tower and in shelters owned by the California Department of Forestry and Fire Protection (CALFIRE). Utility-supplied electric power is backed-up by an emergency generator on the site.

11 Replacements and upgrades of microwave dishes and interior equipment (as would occur at Category 1 sites) are

normal maintenance and repair activities at microwave facilities. Typically, individual actions such as these do not require discretionary permits or approvals and require no further environmental review under CEQA (categorically exempt under CEQA Guideline Section 15302) or NEPA.

Pacheco Peak Existing tower



The proposed project would install a new 6-foot diameter antenna at 95-feet above ground level, with the path directed toward the Gilroy Annex site. A new waveguide would also be installed and would run from the antenna through the existing waveguide port, terminating at the ECOMM rack inside of the County’s equipment shelter. The existing radio would be replaced with an ECOMM radio on the existing rack. Following the installation of the new antenna, the existing 8-foot antenna (at 21-ft elevation and as shown at the lower left on the tower) and corresponding waveguide would be removed. No other equipment upgrades would be required and no ground disturbance would occur at this site.

Gilroy Target Range The Gilroy Target Range site is located at 1598 Southside Drive in Gilroy. The site, which is used by the City of Gilroy Police Department for target practice, is surrounded by agricultural uses as well as a wastewater treatment facility (to the west and south). The existing paved site contains one approximately 100-foot-tall tower with two microwave dishes mounted on it and a small equipment shelter adjacent to the tower.

The proposed project would replace the two new microwave antennas on the existing tower. One 3-foot diameter antenna would be mounted at 43 feet above ground surface and would be directed toward the Gilroy City Hall Annex site. A second 4-foot antenna would be installed at 95 feet above ground level and would be directed toward the Gilroy Reservoir “D” site. Both new antennas would be installed on the southwest leg of the tower, with a new waveguide connected to each antenna. A new ECOMM radio would also be installed in the existing rack. Interior equipment modifications at this site would include a battery upgrade, a MHSB upgrade, and installations of a channel bank, TRAK clock and a DSM card12. No ground disturbance would be required at this site.

Following the installation of the two new microwave antennas, the existing antennas would be removed. However, to maintain communications until the system is in full operation, the existing antennas would remain until the installation of the new antennas is complete, resulting in a time delay between the installation of the new equipment and the removal of existing equipment.

12 Please refer to Category 0 actions shown in Table 1 and the related descriptions of equipment upgrades.

Gilroy Target Range Existing lattice tower and equipment shelter



Category 2 – Add New Microwave Antennas at Existing Facilities Category 2 sites would require adding new microwave dishes on rooftops or existing towers at existing communications facilities. The microwave dishes also would require extending the cabling to carry the signals to the radio units. At Fire Station 25, a new exterior waveguide bridge to support the cabling would be necessary. At some sites, minor modifications to the towers may be necessary to mount the microwave dishes. The ancillary microwave radios, multiplex equipment, DC charger, batteries, and pressurization equipment on racks would be installed within the existing building or equipment shelters.

Microwave dish antenna and equipment upgrades and the addition of new microwave dishes are part of normal operations at microwave facilities. Typically, although such actions may require a building permit, they require no discretionary approval and consequently, require no environmental review under CEQA (pursuant to CEQA Guideline section 15301) or NEPA.

The 18 sites with actions that fall into Category 2 are summarized in Table 3.

Detailed descriptions of each of the Category 2 sites and the actions proposed at each, follow.

San Jose Communication Center The City of San Jose Communication Center site is located at 855 North San Pedro Street, in the City of San Jose. The proposed site would be located on the rooftop of the two-story building. The Communications Center is located within San Jose’s Civic Center, and is surrounded by parking lots and multi-story office buildings housing county and city departments. The existing 25-foot roof-top mounted monopole currently has several antennas, including the 3-foot diameter antenna (dish with grey cover, shown at top right on monopole) and associated waveguide that were installed as part of the ECOMM Phase I project.

The proposed project would install a new 3-foot diameter antenna below the existing antenna on the pipe mount, to be directed toward the City Hall site. A new waveguide would also be installed from the antenna to the equipment room using existing conduit, and other interior equipment modifications at this site would include installations of a new channel bank and DSM card. No ground disturbance would be required at this site.

San Jose Communication CenterSome of the existing roof-top antennas



TABLE 3 CATEGORY 2 - SITES REQUIRING PLACEMENT OF NEW ANTENNAS AT EXISTING FACILITIES


San Jose Communications

855 N. San Pedro St. San Jose

Place 1 new dish on existing roof mount; Place electronics in new and existing racks in existing radio vault

Frazier Peak Ed Levin County Park 3100 Calaveras Road Milpitas

Place 2 new dishes on existing lattice tower; Place new electronics in existing rack in radio vault

Sunnyvale Police Department

700 All American Way Sunnyvale

Place 1 new dish on existing monopole; Place 1 new rack in existing radio vault

Lost Altos Police Department

One North San Antonio Rd Los Altos

Place 2 new dishes on existing monopole; Place new electronics in existing rack in radio vault

Rodoni 19070 Bohlman Road, Saratoga

Place 1 new dish on existing lattice tower; Place new electronics in existing rack in radio vault

Carol Drive 2700 Carol Drive San Jose

Place 1 new dish on existing lattice tower; Place new electronics in existing rack in radio vault

Holiday Lake 17445 Lakeview Dr., Morgan Hill

Place 1 new dish on existing tower; Place 2 new dishes on existing roof structure; Electronics in existing racks

Coyote Peak 26060 Bernal Road San Jose

Place 2 dishes on existing lattice towers; Place new electronics in existing rack in radio vault

El Toro 2000 West Dunne Avenue Morgan Hill

Place 1 new dish on existing monopole; Place 1 rack in existing shelter

El Camino Hospital 2500 Grant Rd Mountain View

Place 1 new dish on new roof mount on existing building; Place 2 racks in existing radio vault

Sunnyvale Corporate Yard

221 Commercial St. Sunnyvale

Place 1 new dish on existing lattice tower; Place 2 racks in existing radio vault

Good Samaritan Hospital 2425 Samaritan Drive San Jose

Place 1 new dish on existing roof structure; Place new electronics in existing rack in radio vault

San Jose Airport 1661 Airport Blvd San Jose

Place 1 new dish on new roof mount on existing building; Place 2 racks in existing radio vault

Fire Station 25 1590 Gold St San Jose

Place 1 new dish on existing roof structure; Place 2 racks in existing radio vault

Fire Station 28 19911 McKean Ave. San Jose

Place 1 new dish on building wall; Place 1 outdoor cabinet on existing concrete slab

San Jose City Hall 200 East Santa Clara Street San Jose

Place 1 new dish on existing roof structure; Place 1 rack in existing radio vault

Doyle Road 5090 Williams Road San Jose

Place 1 new dish on existing monopole; Place 2 racks in existing shelter

San Jose Police Department South Substation

6087 Great Oaks Parkway San Jose

Place 1 new dish on existing roof structure; Place 1 rack in existing radio vault




Frazier Peak The Frazier Peak site is located above Ed Levin County Park at 3100 Calaveras Road, in an unincorporated area above Milpitas. The site is located on the top of a hill at an elevation of 2,321 feet above sea level (msl) and currently has a 25-foot tall, 4-legged communications tower with one 6-foot diameter antenna (at 15 feet above ground) and two 3-foot diameter antennas (one at 15 feet above ground and one at 20 feet above ground), as well as four waveguides that were installed as part of the ECOMM Phase I project. A second tower (approximately 40 feet in height) with two antennas is located to the north of the 25-foot tower. A radio shelter with equipment room and a propane tank are located within the communications site boundary. Access to the site is from either Calaveras Road on the east side or through Ed Levin County Park on the west side. However, both entrances are locked and gated, and the road is unpaved. A four-wheel drive vehicle is required at all times to access the towers.

The proposed project would install two new, 3-foot diameter microwave antennas and pipe mounts at this site. One antenna and pipe mount would be installed at 10.5 feet above ground surface, with the path directed toward Fire Station 25. The other antenna and pipe mount would be installed at 9 feet above ground surface, with the path directed toward the San Jose Airport. Two new waveguide runs would be installed – one from each of the antennas – and would be connected to the new equipment in the existing microwave radio shelter through one new entry port. Two entry ports would be installed at the shelter, however, only one would be used for the proposed project, while the other would be reserved for future use. New radios and MHSB transmitters would also be installed in the existing ECOMM rack. No ground disturbance would be required at this site.

Sunnyvale Police Department The Sunnyvale Police Department is located at 700 All American Way in Sunnyvale. The two-story brick building is located in the City’s civic center. The Police Department site is bound by All American Way and the City Public Library on the north, South Pastoria Avenue and residential neighborhood on the west, Highway 82/El Camino Real on the south, and South Mathilda Avenue and commercial uses on the east. There is an existing 160-foot monopole tower with several mounted cellular and radio antennas, as well as two 3-foot diameter microwave antennas installed as part of the ECOMM Phase I project. The tower is located in the secured parking area behind the Police Department building. The radio room is located on the second floor of the building adjacent to the monopole.

Frazier PeakExisting towers and equipment shelter

Sunnyvale Police Department Existing monopole with antennas



The proposed project would install a new 3-foot diameter antenna on the existing monopole, at 133 feet above ground surface, to be directed toward the Sunnyvale Corporate Yard site. A new waveguide would be installed from the antenna to the existing equipment room, and the new radio system would be connected to the existing DC power system and dehydrator. As part of the project, a new 8-foot radio rack would also be installed in the equipment room. Interior equipment modifications at this site would include a MHSB upgrade and installations of a channel bank, TRAK clock and a DSM card. No ground disturbance would be required at this site.

Los Altos Police Department The Los Altos Police Department site is located at One North San Antonio Road in the town of Los Altos. The site is located in the civic center area of Los Altos. Surrounding areas include residential, commercial, and civic uses. A public baseball field is located east of the site. The building is a single-story wood sided structure with a shingle roof. The areas around the building are covered with grassy areas and mature trees, along with associated parking lots. Access to the site is from surface streets.

The project site contains a 140-foot tall monopole with two mounted microwave antennas – one 3-foot diameter antenna at 135 feet above ground surface and one 6-foot diameter antenna at 120 feet above ground surface.

The proposed project would install a new 3-foot diameter antenna at 132 feet above ground surface, to be directed toward the El Camino Hospital site. A new radio outdoor unit would be installed at 5 feet above ground surface on the supporting pipe for the waveguide bridge. Signal cables would be installed from the outdoor unit to the indoor unit located in the equipment room. Pressurization tubing would be installed from the distribution manifold to the waveguide connector. Two new gray hypalon radomes would be mounted on the existing Andrew antennas, which would also be painted a standard “battleship gray” color. Interior equipment modifications at this site would include a battery replacement, a MHSB upgrade, and installations of a channel bank, TRAK clock and a DSM card. No ground disturbance would be required at this site.

Rodoni The Rodoni site is located at 19070 Bohlman Road, in an unincorporated area of Saratoga. The site is an existing communications facility at the top of a hill (elevation of 2,529 feet msl), in a rural residential area. A 140-foot tall lattice tower with three mounted microwave antennas currently exists on the site. All dishes were installed as part of the ECOMM Phase I project. The two 6-foot diameter antennas are mounted at 95 feet and 50 feet above ground

Los Altos Police Department Existing towers (the lattice tower shown here on the roof-top has been removed as part of ECOMM Phase I project

RodoniExisting towers and equipment shelter



surface, while the 4-foot diameter antenna is mounted at 96 feet above ground surface. Waveguide runs exist between the existing antennas and an existing equipment room. Access to the site is from surface streets to a private driveway secured by an electronic gate, which requires passing through the private driveway under a prescriptive easement. Access to the site road, which is unpaved, is through a second locked gate at the entry point.

The proposed project would install a new 4-foot diameter microwave antenna at 62 feet above ground surface. The antenna path would be directed toward the Doyle Road site. A new waveguide would be installed between the antenna and existing ECOMM radio. One 265 Ah battery bank from the Los Altos site would be relocated to the Rodoni site and installed parallel to the existing batteries. In addition, one of the unused conduits would be converted to a 4-inch waveguide entry port. An MHSB upgrade would also occur at the Rodoni site as part of the proposed project. No ground disturbance would be required at this site.

Carol Drive The Carol Drive site is located at 2700 Carol Drive in the Santa Clara County Communication Center, in unincorporated San Jose. The site is located on a hill at about 436 feet msl. The site currently contains a 150-foot tall four-legged, self-supported tower with 13 mounted microwave antennas. Three of these antennas were installed as part of the ECOMM Phase I project - one 3-foot diameter antenna and two 6-foot diameter antennas, all at 35 feet above ground surface, facing different directions. Approximately 12 smaller whip antennas are also mounted on the existing tower. Site access is from the surface street to the gated, controlled access Communications Center. The access road to the tower is paved.

The proposed project would install one 4-foot diameter microwave antenna at 13-feet above ground surface, below an existing antenna on the same pipe mount. The antenna path would be directed toward the Good Samaritan Hospital site. A new waveguide would be installed and would run from the antenna to the equipment room through existing waveguide ports. A new radio terminal, installed in the existing rack, would connect to the existing DC power source and dehydrator. Interior equipment modifications at this site would include installations of a channel bank, TRAK clock and a DSM card. No ground disturbance would be required at this site.

Carol DriveExisting lattice tower and antennas



Holiday Lake The Holiday Lake site is located at 17445 Lakeview Drive in an unincorporated area of Morgan Hill. The site is situated on a hill (974 feet msl) just west of Anderson Lake, and overlooking a residential area.

An existing communication facility is located at the site that includes four wooden monopoles with radio antennas mounted on each, and two 8-foot diameter microwave dishes mounted on the existing equipment shelter (owned by Santa Clara County) located between the wooden poles. The site also contains a 20-foot tall, 3-legged, self-supported tower on the east side of the shelter, with four antennas mounted on this tower: two 3-foot diameter antennas mounted on the southwest leg of the tower, at 14 and 18 feet above ground; one 6-foot diameter antenna mounted on the southeast leg of the tower at 17 feet above ground; and one 6-foot diameter antenna mounted on the north leg of the tower at 17 feet above ground surface. All antennas face different directions. A second 10-foot-tall, air conditioned equipment shelter (dedicated to ECOMM equipment) and a 25 kW propane-powered generator also exist on the project site. The self-supported tower, the ECOMM equipment shelter and the power generator were installed as part of the ECOMM Phase I project.

Access to the site is from Lakeview Drive, a paved local street, to a dirt access road. There are two equipment shelters at this site, an ECOMM shelter and a Santa Clara County (SCC) shelter.

The proposed project would install one 2-foot diameter microwave antenna on the existing 20-foot tower at 21-feet above ground surface (using a pipe mount), to be directed toward the Lakeview Court site. A waveguide from this antenna would be connected to the radio outdoor unit mounted on the ECOMM shelter. Two 3-foot antennas would also be installed on the existing wooden pole structure, to be directed toward the El Toro and Woodland sites. Waveguides from these antennas would be connected to the radio outdoor units located in the other (SCC) equipment shelter. A 6-port pressure manifold would be installed in the ECOMM shelter, while relocating the existing 4-port manifold from the ECOMM shelter to the SCC shelter. Three radio indoor units would also be installed in the ECOMM shelter. Signal cables would be installed between the ECOMM and SCC shelters. Interior equipment modifications at this site would include a battery upgrade and installations of a channel bank and a TRAK clock. No ground disturbance would be required at this site.

Holiday LakeExisting antennas and equipment shelter



Coyote Peak The Coyote Peak site is located at 26060 Bernal Road, in unincorporated San Jose. The site is at an existing communications facility on the top of a hill (elevation of 1,137 feet msl). The existing site has a 300-foot high tower and a 20-foot tower, with antennas mounted on each. As part of the ECOMM Phase I project, two new 6-foot diameter antennas were mounted on the 20-foot tower, one on the northwest leg of the tower at 18 feet above ground surface and the other on the south leg of the tower at 12 feet above ground surface (both are seen at the bottom right of the photo). A propane tank is located in front of the 300-foot tower. Site access is from Bernal Road to a gated and locked, hard-packed dirt and gravel road.

The proposed project would reuse the existing pipe mount at 45-feet above ground surface on the northwest leg of the 300-foot tower and install one 3-foot diameter antenna there facing Fire Station 28. A second 3-foot antenna (also using an existing pipe mount) would be installed at 15-feet above ground level on the 20-foot tower and would face the San Jose South Substation site. A waveguide from each antenna would be installed and connected to the radio equipment inside the existing shelter. A new rack for the new radio terminals would be installed, and a 6-inch wide cable ladder between the existing ECOMM equipment and the SCC racks would be provided. In addition, the existing 265 Ah 48-volt battery bank would be replaced with a new battery bank with 350 Ah capacity. No ground disturbance would be required at this site.

El Toro The El Toro site is located at 2000 West Dunne Avenue in Morgan Hill (unincorporated Santa Clara County). The site is located on a flat surface atop a mountain. A single family residence is approximately 600 feet east of the project site, with more single family homes descending down the mountain into residential subdivisions. The existing site has a 2-door equipment shelter atop a concrete pad and an adjacent monopole with several mounted antennas. A large water tank is located at the northern end of the property. The area is generally undeveloped with sporadic vegetation surrounding the project site and is enclosed by cyclone fencing with barbed wire along the top. Additional cellular telephone broadcast and receive antennas owned by wireless communications carriers surround the project site along the fence line.

Coyote PeakExisting lattice tower, antennas and equipment shelter

El ToroExisting monopole and shelter



The proposed project would install a new 3-foot diameter antenna at 15-feet above ground surface, which would be directed toward Holiday Lake (the new antenna would be painted to match the existing monopole). Two new radio equipment racks would be installed in the existing equipment shelter, one to hold the radio equipment and one to house the electrical panel. A new waveguide would be installed to run from the new microwave antenna to the radio equipment rack. The new antenna and radio equipment would be connected to AC power supply. Interior equipment modifications at this site would include installations of a channel bank, TRAK clock and a DSM card. No ground disturbance would be required at this site.

El Camino Hospital The El Camino Hospital site is located at 2500 Grant Road in Mountain View. The project site is an existing recently constructed hospital and the proposed equipment would be installed on top of the roof (antenna) and in the rooftop penthouse/equipment room (radio equipment) that contains the hospital’s HVAC equipment. The equipment would be housed in the rooftop penthouse on the right in the illustration. The antenna would mount near the exterior wall of that penthouse, with a view from the rooftop depicted in the photo below. Views from the rooftop generally consist of dispersed vegetation and the surrounding low-rise developments.

The proposed project would install one 3-foot diameter microwave antenna on the rooftop, in the direction of the Los Altos Police Department. The antenna mount design has not been finalized, but the new antenna would most likely be installed on new horizontal support bars attached to an existing rooftop support structure that surrounds existing ducting. Two new 7-foot radio equipment racks containing new radio equipment would be installed in the existing equipment room. A new waveguide would be installed to run through a new access port from the proposed antenna to the ECOMM rack. All proposed equipment would connect to the hospital’s electric power system. A new channel bank and a TRAK clock would also be installed at this site. The hospital is an existing structure and no ground disturbance would be required at this site.

El Camino HospitalView of and from the roof-top

El Camino Hospital



Sunnyvale Corporate Yard The Sunnyvale Corporate Yard site is located at 221 Commercial Street in Sunnyvale. The project site is located within the City’s corporate yard, which stores the City’s heavy duty machinery and vehicles. The surrounding uses are mainly commercial and light industrial (including research and development) and the project site itself is paved and enclosed within locked cyclone fences with barbed wire along the top. The site currently contains an approximately 90-foot tall three-legged, self-supported lattice tower, with existing antennas mounted at various heights. An existing 270-square-foot shelter is located adjacent to the tower.

The proposed project would install a new 3-foot diameter microwave antenna and pipe mount at 87-feet above ground surface on the northwest leg of the existing tower and would install a new radio rack in the existing shelter. The antenna path from this location would be directed toward the Sunnyvale Police Department site. A new waveguide would be installed and would run from the antenna to the rack inside the shelter. The new equipment would be connected to the existing electric panel. Interior equipment modifications at this site would include installations of a TRAK clock and a DSM card. Prior to undertaking this work, the City of Sunnyvale would repair two areas of minor damage within the equipment shelter, one near the shelter entrance and the other at the proposed ECOMM rack location. No ground disturbance would be required at this site.

Good Samaritan Hospital The Good Samaritan Hospital site is located at 2425 Samaritan Hospital in San Jose. The project site is located at an existing hospital, which is located within a mixed use area that contains primarily residential and office uses. The West Valley Freeway (Highway 85) runs along the northern boundary of the hospital. The proposed antenna would be installed on the roof of the existing hospital structure, which already

Sunnyvale Corporate Yard Existing lattice tower and equipment shelter

Good Samaritan HospitalExisting antenna on the roof (left) and hospital’s front façade (above)



contains other antennas and hospital ventilation system and air-handling equipment. The associated radio equipment would be installed within the rooftop penthouse/equipment room.

The proposed project would install a new 3-foot diameter antenna on an existing pipe mount, with the signal directed towards the Carol Drive site. The antenna would be painted to match the existing penthouse, and a new radio outdoor unit would be installed below the antenna. Using the existing ports for the existing cable runs, new coaxial cables would be installed between the outdoor unit and the equipment room. Fire-proof packing would be used to ensure that any interior cable port is sealed. A new radio indoor unit and communications equipment would be installed within the rooftop penthouse/equipment room, on an existing rack that connects to the hospital’s existing electrical system. Interior equipment modifications at this site would include installations of a TRAK clock and a DSM card. No ground disturbance would be required at this site.

San Jose Airport The San Jose Airport site is located within the Normal Y. Mineta San Jose International Airport, located at 1661 Airport Boulevard in San Jose. The airport is located two miles northwest of the City’s downtown, near the intersections of three major freeways, Highway 101 to the north, Interstate 880 to the south, and State Route 87 (Guadalupe Parkway) to the east. Residential, commercial, and light industrial land uses surround the airport. The site itself is within the Terminal 3 building, which is a two story building with windows along the first story (street level).

The proposed project would install a new 4-foot diameter microwave antenna on the roof of the building, mounted on a new pole that would be attached to an existing beam. The signal from this antenna would be directed toward Frazier Peak. A new waveguide would also be installed that would run from the new antenna through the existing conduits to the equipment room, directly below. A new radio rack would be installed in the equipment room to hold the new ECOMM radio equipment. The project would also revise the ground plate at the waveguide entry port and revise the ground connection between the plate and the site ground for optimum connectivity to the antenna. Interior equipment modifications at this site would include installations of a channel bank, TRAK clock and a DSM card. Since the antenna would be mounted on the rooftop of the

San Jose AirportExisting pipe framework and antennas on the roof-top (left) and Terminal Building 3 (above).



existing Terminal 3 building and all equipment would be installed in the equipment room below, no ground disturbance would be required at this site.

Fire Station 25 The Fire Station 25 site is located at 1590 Gold Street in San Jose. The site is located within a mixed-use are that contains residential, commercial, and institutional uses, with larger wetland areas located to the north and west.

The fire station consists of two building masses, a two story building and an attached one-story garage. It is surrounded by a paved surface lot and unpaved area containing vegetation. Several antennas are mounted on the pipe mount frameworks on top of the existing upper roof.

The proposed project would install a new 3-foot microwave diameter antenna on the rooftop, on an existing pipe mount framework that would be modified to accommodate the proposed project. The antenna would be installed 9 feet above the lower roof level, and would have its signal directed toward the Frazier site. A waveguide and waveguide support would be installed and connected from the antenna through a conduit support to the existing equipment room located on the ground level at the northeast corner of the property. Any additional equipment necessary to operate the new ECOMM system would be installed in an existing rack. The equipment would be connected to the existing electrical power supply and the existing DC power cables from the battery would be replaced. A TRAK clock would also be installed at this site. No ground disturbance would be required at this site.

Fire Station 28 The Fire Station 28 site is located at 19911 McKean Road in San Jose. The site is located in an area that contains a mix of uses, including institutional, recreational, and residential uses. The Almaden Primary School is across the street from the fire station at 19950 McKean Road

Fire Station 25 Fire Station 25 and existing roof-top antennas.

Fire Station 28Location of the proposed outdoor unit (left) and station and existing rooftop antennas (above).



and the St. Anthony Church property abuts the project site to the east. A tree grove exists immediately to the west and south of the station, with a single-family residential area further west.

The existing station consists of two building masses, a single story office area and a double-height fire vehicle garage. Several antennas, mounted on a pipe framework, already exist on top of the lower and upper roof structures.

The proposed project would install a new 3-foot diameter microwave dish in the center of the upper east wall of the building, below the peak of the upper roof structure, at approximately 18 feet above ground surface, using a to-be-designed mounting system. The antenna signal from this location would be directed toward the Coyote Peak site. A weatherproof outdoor equipment cabinet would also be installed on the front north side of the building, to be mounted on two steel skids atop of an existing concrete pad, to allow for water drainage. Four steel vertical posts would be installed in the driveway, in front of the outdoor cabinet, to protect the cabinet from vehicles. A new waveguide would be installed that would run under the roof eaves from the equipment cabinet to the antenna. The weatherproof outdoor radio would connect to the existing electrical system within the building. Interior equipment modifications at this site would include installations of a channel bank, TRAK clock and a DSM card. No ground disturbance would be required at this site.

San Jose City Hall The San Jose City Hall site is an 18-story, 285-foot-tall structure located at 200 East Santa Clara Street in San Jose. The project site is in a developed area containing a mix of commercial, institutional and residential uses. The San Jose University campus is approximately one block south of the project site.

The locations where the proposed project would implement changes are the rooftop, where several antennas already exist, and the radio room, where communications equipment also already exists.

The proposed project would mount a new 3-foot diameter microwave antenna on a pipe mount that would be affixed to the existing horizontal mounting structure. The new antenna would be about 10 feet above the roof surface level and the signal would be directed toward the San Jose Communication Center site. A new weatherproof outdoor unit (ODU or radio unit) would be mounted on the same pipe mount as the antenna and would be positioned about 5 feet above the roof level. A waveguide would be installed between the ODU and the antenna. New pressurization tubing would be installed from the dehydrator to the waveguide connector, and existing conduit

San Jose City HallExisting roof-top pipe framework and antenna



would be used to install the coaxial signal cables from the indoor radio unit to the ODU. The IDU would be installed below the existing equipment rack in the radio room, which is located on the top floor of the building. The new equipment would connect to the existing electrical system within the building. Interior equipment modifications at this site would include installations of a channel bank, TRAK clock and a DSM card. Since all modifications would occur on the rooftop and within the top floor radio room, no ground disturbance would be required at this site.

Doyle Road The Doyle Road site is located at 5090 Williams Road in San Jose. The project site is located on a surface parking lot, and nearby uses beyond the lot include primarily low-density residential uses with a shopping center to the north. The Lawrence Expressway runs several hundred feet to the west of the project site.

The existing site is enclosed by a secured cyclone fence with barbed wire along the top and contains a 126-foot- tall monopole with existing antennas mounted at various heights as well as two one-story structures – an air-conditioned equipment shelter and a building containing an emergency power generator. The structures sit atop a paved area and are surrounded by various trees and shrubs.

The proposed project would install a 4-foot diameter microwave antenna on the existing monopole at 96-feet above ground level, with the signal directed toward the Rodoni site. A new waveguide would be installed through the waveguide port from the antenna to connect to the existing ECOMM equipment. The internal electrical grounds would be revised as necessary to accommodate the project. A new TRAK clock would also be installed at this site. No ground disturbance would be required at this site.

Doyle RoadExisting monopole and equipment shelter (left) and closer view of equipment shelter (above)



San Jose Police Department South Substation The site is located at 6087 Great Oaks Parkway in San Jose, near the intersection of Highway 85 and Monterey Road in the southern part of San Jose and is surrounded by a mix of commercial, light industrial, and residential land uses as well as some undeveloped areas.

San Jose Police Department South Substation Existing roof-top pipe framework (above left) and view of the building (above right)

The existing site contains a partially constructed building that, at completion, is intended to house the San Jose Police Department’s South Substation. The building shell is largely constructed, while the interior construction and landscaping have yet to be completed. The building is of an irregular plan and is made up of two masses, one single story and one two-stories tall. The modifications proposed by the project would occur on the rooftop and within a future equipment room located on the second floor of the existing building.

The proposed project would install a 3-foot diameter microwave antenna on the roof of the facility utilizing the existing pipe mounting structure. The antenna would be affixed at 8-feet above the roof level on the corner mount bracket’s vertical pole and would be directed toward the Coyote Peak site. A weatherproof outdoor radio unit would be installed underneath the antenna, and a waveguide would be installed between the radio unit and the new antenna. Pressure tubing would be installed from the dehydrator to the waveguide connector, and coaxial cables would be run from the ODU to the IDU. A new equipment rack and radio equipment would also be installed in the building (the new radio equipment would connect to the electrical system that would be in place once the building’s interior construction is complete). Interior equipment modifications at this site would include installations of a channel bank, TRAK clock and a DSM card. No ground disturbance would be required at this site.



Category 3 – Construct New Towers / Shelters at Existing Sites Category 3 sites would require the construction of new lattice or monopole towers and, in some cases equipment shelters, in order to mount and operate the microwave dishes. Also required would be the exterior placement of waveguide bridges and cabling. The ancillary microwave radios, multiplex equipment, DC charger, batteries, and pressurization equipment on racks would be installed within a new or existing building or equipment shelter.

This level of new construction typically would require a building permit and may also require a land use permit. Other permits or approvals may also be required. When adopted, this Initial Study/Environmental Assessment may be used by the permitting agencies to satisfy environmental review for project approval and/or construction.

The three sites with actions that fall into Category 3 are summarized in Table 4.

TABLE 4 CATEGORY 3 – SITES REQUIRING INSTALLATION AND CONSTRUCTION OF NEW TOWERS

AND/OR EQUIPMENT SHELTERS


Gilroy Reservoir D 2265 Periwinkle Drive Gilroy

Place 1 new dish on the new monopole. Place new electronics in existing rack in existing shelter.

Woodland Acres 2275 Rolling Hills Dr. Morgan Hill

Place 1 new dish on a new monopole; Place 1 new shelter on existing foundation. Place electronics in rack.

Lakeview Court 3100 Lakeview Court Morgan Hill

Place 1 new dish on a new monopole; Place 1 new shelter on existing foundation. Place electronics in rack.

Gilroy City Hall Annex

7370 Rosanna Street, Gilroy

Place 1 new dish on existing monopole; Place 1 new dish on new roof mount; Place new electronics in existing rack

SOURCE: County of Santa Clara, 2009.

Detailed descriptions of each of the Category 3 sites and the actions proposed at each, follow.



Gilroy Reservoir “D” The Gilroy Reservoir site is located at 2265 Periwinkle Drive in the City of Gilroy. The reservoir site is on top of a hill, surrounded by low density, single-family residential uses. The project site contains two equipment shelters, a lattice tower containing a small microwave dish and a monopole containing additional antennas, all of which sit on top of a concrete slab. The concrete slab, which is also enclosed by a secured cyclone fence, is located on a vegetated slope, situated next to a paved area containing two water reservoir tanks belonging to the City of Gilroy. The perimeter of the reservoir site is fenced. Access to the reservoir site is provided via a locked gate. See Figure 4.

To accommodate the proposed project, the City of Gilroy would install a 55-foot-long monopole approximately 25.5 feet north (left) of the edge of the concrete slab containing existing communication equipment. Approximately 15 feet of the monopole would be installed beneath the ground surface, with about 40 feet exposed. The pole would be installed within a graded slope, approximately 2 feet from the curb, and would require the excavation of approximately 5 yards of soil (3 feet in diameter and 15 feet deep). After the monopole is installed, Santa Clara County would mount a new 3-foot diameter microwave antenna on the new pole at 35 feet above ground surface, with the signal directed toward the Gilroy Target Range site. A new weatherproof ODU would be installed at the base of the pole, which would contain the new signal cable run that would run to the existing equipment shelter (via a 2-inch underground conduit). New ECOMM radio equipment would be installed within an existing rack in the shelter, and would connect to the existing electric panel located adjacent to the equipment racks. Interior equipment modifications would include installations of a channel bank, TRAK clock and a DSM card.


Figure 4Gilroy Reservoir D Site


Dirt area along graded slope

2ft in fromcurb

New 2” diameter underground conduit tocarry signal cables from ODU to shelter

Northerly Water Tank



Woodland Acres The Woodland Acres site, at 2275 Rolling Hills Drive in Morgan Hill, is located on a level graded pad cut for a water reservoir tank, on top of a hill at the terminus of Rolling Hills Drive. The project area contains primarily residential uses with single-family homes dispersed throughout the valley. The areas proximate to the project site are largely undeveloped, and the site itself is partially paved and contains patches of vegetation and four mature trees.

The existing site contains a small equipment shelter atop a concrete pad with a pipe mount extending from the roof-top of the equipment shelter. A 20-foot-tall water tank is located adjacent to and west of the shelter. See Figure 5.

The proposed project would demolish the existing equipment shelter (leaving the concrete pad intact for future uses) and construct an adjacent larger pad and a new equipment shelter measuring approximately 8 feet by 12 feet in size. In addition, a new 18-foot galvanized steel monopole would be installed adjacent to the new equipment shelter. Approximately 5 feet of the monopole would be installed beneath the ground surface, with approximately 13 feet exposed. The installation of the monopole would require excavation of approximately 1 cubic yard of soil (2 feet in diameter and 5 feet deep). Following this construction, a 3-foot diameter microwave antenna would be installed on the monopole at 11.5 feet above ground surface and would be directed toward the Holiday Lake site. New ECOMM radio equipment would be installed in a new rack within the shelter and a waveguide would be extended between the new antenna and the rack. Interior equipment modifications at this site would include installations of a channel bank, TRAK clock and a DSM card. Construction would require excavation for erection of the monopole and placement of the pad.

New 8' x 12' shelter

ExistingShelter

(to be removed)

New Monopoleand Antenna


Figure 5Woodland Acres Site




Lakeview Court The Lakeview Court site is located at 3100 Lakeview Court in the City of Morgan Hill. The project site is located at the terminus of Lakeview Court, and is within a low-density, primarily single-family residential area, approximately one quarter mile south of Anderson Lake. A single family home abuts the property to the southeast. The project site is partially paved, and contains gravel and patches of vegetation (including mature trees).

The property contains two underground water reservoirs, whose roofs are exposed close to ground level. Other structures on the site include one equipment shelter, two small weatherproof equipment lockers, and two radio antennas atop an existing 40-foot lattice tower. The areas that contain the equipment shelters are paved. A fence surrounds the reservoir site and access is provided via a secured gate. See Figure 6.

The proposed project would demolish an existing concrete pad and the existing equipment shelter on the site and construct in their place a new concrete pad and equipment shelter to accommodate the ECOMM Phase II radio equipment. The new shelter would be approximately 6 feet by 8 feet in size, the same size as the existing. Approximately 20 feet south of the site of the new shelter, a new 17-foot monopole would be erected on a pervious surface, with 5 feet beneath the ground surface and 12 feet exposed. A 2-foot diameter microwave antenna would be installed on the new monopole at 11 feet above ground surface, and would be directed toward the Holiday Lake site. A weatherproof radio unit would also be installed at the base of the monopole, and a new signal cable and pressure line would be run from the base of the pole to an existing pull box, and would then continue inside an existing shallow conduit to the equipment shelter (a distance of about 63 feet). Approximately 1 cubic yard of soil excavation would be required to accommodate the proposed project and maximum excavation would extend about 6 feet beneath the ground (excavation for the conduit run would extend 1 foot beneath the ground). New radio equipment would be installed within a new ECOMM rack within the new shelter and would be connected to the existing power supply on the site. Interior equipment modifications at this site would include installations of a channel bank, TRAK clock and a DSM card.

New Monopoleand Antenna


Figure 6Lakeview Court Site




Gilroy City Hall Annex The Gilroy City Hall Annex is located at 7370 Rosanna Street, on a block bounded by Rosanna Street to the west, W. Sixth Street to the north, Church Street to the east and W. Seventh Street to the south. The project site is located within a mixed-use neighborhood that contains institutional, commercial, and residential (mostly low density, single-family) uses. The Gilroy Public Library is located across Rosanna Street, just west of the project site, and the Gilroy Rail Station is located about three blocks southeast of the property.

The project site contains a one-story building that formerly housed the City’s Police Department; however, following the completion of the new police headquarters, this building became an extension of the City’s administration offices (i.e., extension of the City Hall). The Wheeler Community Center is located adjacent to and north of the City Hall Annex building. The project site is paved. As part of the ECOMM Phase I project, a new 90-foot-tall monopole was constructed in the area between the Wheeler Community Center and the City Hall Annex (old Police Department) building. A 6-foot diameter microwave antenna was mounted on the new monopole, at 87 feet above ground surface, directed toward the Holiday Lake site. In addition, a 65-foot tall guyed lattice tower, that was for several decades located on top of the City Hall Annex building, was removed. See Figure 7.

The proposed project would install two new microwave antennas at the site. A new 3-foot diameter microwave antenna would be mounted on the existing 90-foot monopole at a height of 70 feet above ground surface, and would be directed toward the Gilroy Target Range site. In addition, a new guyed 20-foot roof tower would be installed on the rooftop of the City Hall Annex building. The new tower would be placed on the same base that held the previous lattice tower and would use the same anchor points for its guy wires. A new 6-foot diameter microwave antenna would be mounted on this new tower at a height of 17 feet above the upper roof level, to be directed toward the Pacheco Peak site. New waveguides would be installed to run from the new microwave antennas to the new radio equipment that would be installed in the existing rack (in the Annex building basement-level equipment room). The new antennas and radio equipment would be connected to the existing AC power supply. Interior equipment modifications at this site would include a battery upgrade and installations of a channel bank, TRAK clock and a DSM card. No ground disturbance would be required at this site beyond that done to erect the monopole tower constructed in Phase I.

New 3-ft antenna to Gilroy Target Range, mounted on the existing monopole at a height of 70 ft, Azimuth 116.25 True.

New 6- ft. Antenna to Pacheco Peak, mounted on a new 20 ft roof tower at a height of 17 ft above the upper roof level. Azimuth

89.3 degrees True.

Equipment Room in basement of Annex

ExistingMonopole

Main Lower Roof

Upper Roof

50’-0” ±

N

29’-3” ±

New 6 ft. Antenna to Pacheco Peak, mounted on a new 20 ft roof tower at a height of 17 ft above the upper roof level.

New 3 ft. antennawill replaceexisting antenna toGilroy Target


Figure 7Giroy City Hall Annex Site




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Environmental Impacts To simplify the readability of the environmental impacts analysis, the discussion for each topic below is organized into five categories, the overall ECOMM system and the four project types (Categories 0, 1, 2, and 3), which are discussed above under Project Description.

Issues (and Supporting Information Sources):

Potentially Significant

Impact

Less Than Significant

with Mitigation

Incorporation


Impact No Impact

1. AESTHETICS—Would the project:

a) Have a substantial adverse effect on a scenic vista?

b) Substantially damage scenic resources along a designated scenic highway?

c) Substantially degrade the existing visual character or quality of the site and its surroundings?

d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?

e) If subject to ASA, be generally in non-compliance with the Guidelines for Architecture and Site Approval?

f) If within a Design Review Zoning District for purposes of viewshed protection (d, -d1, -d2), conflict with applicable General Plan policies or Zoning Ordinance provisions?

Comments 1a) Would the project have a substantial adverse affect on a scenic vista?

ECOMM System and Category 0 and 1 Sites:

No Impact. ECOMM is a private1 microwave radio network that provides interoperable communications between law enforcement, fire protection, and emergency medical services throughout Santa Clara County. The visible aspects of ECOMM are the microwave antennas and communications equipment that operate at communications sites throughout the County. The proposed Phase II expansion of ECOMM would occur at sites that include existing communications sites at local police or public safety agency facilities, the sides or rooftops of buildings, or existing communications sites on hilltops. There are no aesthetic impacts inherent to the ECOMM system itself; aesthetic impacts would result only from visible change at individual microwave antenna sites. Interior equipment modifications would be implemented within building/equipment shelter interiors at Category 0 sites and would result in no aesthetic impacts, since these would not be discernible to the general public. One-for-one replacements of microwave dish

1 “Private” meaning there would be no access or use other than by its operators / participating agencies.



antennas at existing sites (Category 1) would result in no aesthetic impacts, since the replacement antennas would be essentially the same as the dish antennas to be replaced.

Category 2 Sites:

Less than Significant Impact. The proposed Phase II expansion of ECOMM would add new microwave dish antennas to existing towers or mounts at existing communications sites (Category 2), including existing sites at local police or public safety agency facilities, the rooftops of buildings, or existing communications sites on hilltops. Although most of the sites are visible, some for a considerable distance, the visual impacts of the Category 2 changes are not considered to be significant, since the proposed antennas are typically 4 ft. in diameter or less and would be added at sites with existing antennas, towers, or monopoles. If mounted against a building, the dish antennas would be painted to match the building; otherwise they would be grey, a color that makes them difficult to see from a distance. Equipment would be housed in existing equipment shelters, rooms, or outdoor radio units and would not alter the existing visual character of those sites.

Category 3 Sites:

Less than Significant Impact. The proposed ECOMM Phase II expansion would require installation and construction of new towers and/or new equipment shelters at Category 3 sites. New poles or towers would be constructed with designs that minimize massing and visibility, with three of the four new poles of a slim-line design and one (at Gilroy City Hall Annex) of a guyed lattice-tower design (see Project Description). If it would be silhouetted against a water tank, dish antennas would be painted to match the tank; otherwise they would be grey, a color that makes them difficult to see from a distance. Equipment would be housed in new or existing equipment shelters or rooms. Where feasible, vegetation would be used to screen the site from nearby neighbors. It is possible that the Cities of Gilroy and Morgan Hill would require design review of a site to ensure the project would visually blend in with the neighborhood character and surrounding environment to the extent possible.

Gilroy Reservoir D

The proposed project would install a 55-foot-long monopole approximately 25.5 feet north (left) of the edge of the concrete slab containing existing communication equipment. About 40 feet of the monopole would be exposed (above ground surface). The pole would be installed within a graded slope, approximately 2 feet from the curb. After the monopole is installed, a new 3-foot diameter microwave dish antenna would be mounted on the new pole at 35 feet above ground surface. The project site is enclosed by a cyclone fence and, with the exception of the adjacent residence to the east, the new structures would not be easily visible from the surrounding areas. The monopole would not substantially affect views of, or through, the site. The visual impact related to a scenic vista would, therefore, be less than significant.



Woodland Acres

The proposed project would construct a new 13-foot tall pipe-column-type monopole and install a 3-foot diameter microwave dish antenna on the pole at approximately 11.5 feet above ground surface. A new, pre-fabricated equipment shelter would also be constructed near the base of the monopole and would replace the existing shelter. The new shelter would be slightly larger than the existing shelter, but would not materially alter the appearance of the project site.

The closest residence to the project site is approximately 800 feet away. None of the proposed components would be easily visible from the surrounding residential areas due to a steep grade variation between the project site and the surrounding development as well as due to intervening vegetation. From other medium- and long-range views, the new structures would blend in with the other natural and man-made features on the site. The visual impact related to a scenic vista would, therefore, be less than significant.

Lakeview Court

The proposed site is surrounded by single-family residences and is south of Anderson Lake. The project would install a new 2-foot diameter dish antenna on a new 12-foot-tall pole, with the dish mounted at a height of 11 feet above ground surface. Because there are two antennas currently on the existing adjacent lattice tower, the additional antenna is not anticipated to alter the existing visual quality of the site. A new 6-foot by 8-foot equipment shelter would also be installed on the site, to replace an existing equipment shelter of the same size. However, vegetation around the site would adequately screen the shelter from nearby residences. The visual impact related to a scenic vista would, therefore, be less than significant.

Gilroy City Hall Annex

The proposed project would install two new microwave antennas at the site. A new 3-foot diameter microwave dish antenna would be mounted on the existing 90-foot monopole at a height of 70 feet above ground surface and a new guyed 20-foot roof lattice tower would be installed on the rooftop of the City Hall Annex building. The new tower would be placed on the same base that held the previous lattice tower and would use the same anchor points for its guy wires. A new 6-foot diameter microwave dish antenna would be mounted on this new tower at a height of 17 feet above the upper roof level.

While these components would be visible from the surrounding parcels (which include institutional, commercial, and residential uses), they would not substantially or adversely affect a scenic vista in the project vicinity, which contains a mix of building types and other structures, varying both in height and massing. Furthermore, the project would constitute a continuation of the types of structures that have historically existed on the site (as noted in the Project Description, a 65-foot tall guyed lattice tower was located on top of the City Hall Annex building for several decades).

1b) Would the project substantially damage scenic resources along a designated scenic highway?



ECOMM System and All Sites:

Less than Significant Impact. As discussed in 1a), above, the proposed project is a system of microwave antennas linked at various locations throughout the County and there are no aesthetic impacts inherent to the ECOMM system itself; any aesthetic impacts would result only from visible change at individual microwave antenna sites. There are no scenic resources at or near the proposed individual sites and none of the sites are located within a State scenic highway. Therefore, impacts are less than significant.

1c) Would the project substantially degrade the existing visual character or quality of the site and its surroundings?

ECOMM System and Category 0, 1 and 2 Sites:

No Impact. As discussed in 1a), above any visual impacts would result only from changes at the individual communication sites. All sites are located at police and public safety agency facilities, the rooftops of existing buildings, or on hilltop telecommunication facilities. All have communication equipment installed. Some sites require only the placing of a microwave dish antenna onto an existing monopole or lattice tower that already includes other similar-looking antennae, and most of the sites are located in developed areas.

Category 3 Sites:

Less than Significant Impact. Sites that require the installation of a new monopole or lattice tower would occur within the site boundary of an existing communication facility and would be similar in appearance or character to the existing communications tower or to the existing Police or communications buildings, all of which include existing communications antennas. Therefore, the proposed project would result in less than significant impacts related to scenic vistas at these sites - Gilroy Reservoir D, Lakeview Court, Woodland Acres, and Gilroy City Hall Annex.

1d) Would the project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?


No Impact. No additional site lighting would be installed at the project sites. In compliance with Federal Aviation Administration (FAA) requirements, flashing red and white beacon lighting is required on certain new monopoles or towers over 200 feet in height to minimize hazards to air navigation. However, since no proposed towers would be 200 or more feet in height, no impact would occur at any of the ECOMM Phase II sites from additional lighting. The antennas are painted and would not create glare when in direct sunlight.



1e) If subject to ASA, would the project be generally in non-compliance with the Guidelines for Architecture and Site Approval?


No Impact. No Architecture and Site Approval would be required for any of the proposed sites. As a result, no impact would occur at any of the ECOMM Phase II sites.

1f) If within a Design Review Zoning District for purposes of viewshed protection (d, -d1, -d2), conflict with applicable General Plan policies or Zoning Ordinance provisions?


No Impact. As discussed above, the proposed project would not adversely affect any viewshed or visual character of any of the existing sites, most of which already contain similar equipment (i.e., towers and antennas) or are zoned to allow the proposed uses. To the degree feasible, the individual projects would be designed in a way that would minimize their visual disturbance. Furthermore, the project would not conflict with any applicable General Plan policies or Zoning Ordinance provisions related to viewshed protection. Therefore, this impact would be less than significant.

Sources Harris Stratex Networks, 2009. Engineering Study Reports for ECOMM Phase II Microwave

Radio System Installation, November 25, 2009.





Impact


with Mitigation

Incorporation


Impact No Impact

2. AGRICULTURE RESOURCES In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. Would the project:

a) Convert 10 or more acres of farmland classified as prime in the report Soils of Santa Clara County to non-agricultural use?

b) Conflict with existing zoning for agricultural use?

c) Conflict with an existing Williamson Act Contract or the County’s Williamson Act Ordinance (Section C13 of County Ordinance Code)?

d) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use?

Comments 2a) Would the project convert 10 or more acres of farmland classified as prime in the

report Soils of Santa Clara County to non-agricultural use?


No Impact. ECOMM is a system of microwave antennas linked at various locations throughout the County. The proposed Phase II expansion of ECOMM would add microwave antennas on existing poles, towers or building or constructing new towers or equipment shelters. This would not result in conversion of existing farmland to non-agricultural uses. Any ground disturbance proposed would be limited to less than 1 acre. Therefore, the proposed project would have no impact on such agricultural uses.

2b) Would the project conflict with existing zoning for agricultural use?


No Impact. All of the ECOMM sites are located at existing communications sites and none are located on land zoned for agricultural uses. Therefore, no impacts would occur.

2c) Would the project Conflict with an existing Williamson Act Contract or the County’s Williamson Act Ordinance (Section C13 of County Ordinance Code)?


No Impact. None of the ECOMM sites are located on land under a Williamson Act contract. Therefore, no impacts would occur.



2d) Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use?


No Impact. Neither the ECOMM System nor construction and operation of any of the individual expansion sites would result in employment or population growth that would require construction of additional housing and services, or in the development of surrounding sites or nearby farmland to non-agricultural uses. Therefore, the proposed project would have no impacts on Farmland.







Impact


with Mitigation

Incorporation


Impact No Impact

3. AIR QUALITY Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project:

a) Conflict with or obstruct implementation of the applicable air quality plan?

b) Violate any air quality standard or contribute substantially to an existing or projected air quality violation?

c) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)?

d) Expose sensitive receptors to substantial pollutant concentrations?

e) Create objectionable odors affecting a substantial number of people?

f) Would the project increase greenhouse gas emissions that hinder or delay the State’s ability to meet the reduction target (25% reduction by 2020) contained in CA Global Warming Solutions Act of 2006 (AB 32)?

Discussion The project site is located within the County of Santa Clara and is within the boundaries of the San Francisco Bay Area Air Basin (Bay Area). The climate of the Bay Area is determined largely by a high-pressure system that is almost always present over the eastern Pacific Ocean off the West Coast of North America. High-pressure systems are characterized by an upper layer of dry air that warms as it descends, restricting the mobility of cooler marine-influenced air near the ground surface, and resulting in the formation of subsidence inversions. In winter, the Pacific high pressure system shifts southward, allowing storms to pass through the region. During summer and fall, emissions generated within the Bay Area can combine with abundant sunshine under the restraining influences of topography and subsidence inversions to create conditions that are conducive to the formation of photochemical pollutants, such as ozone.

Specifically, the project site would be located within the southernmost climatological subregion of the Bay Area Air Basin, in Santa Clara County. This subregion encompasses the south side of the San Francisco Bay, from San Jose to Gilroy, and is bordered by the Diablo Range on the east and on the west by the Santa Cruz Mountains. This subregion is indirectly affected by marine air flow. Marine air entering through the Golden Gate is blocked by the East Bay hills north of the Diablo Range, forcing the air to diverge into northerly and southerly paths. The southern flow is directed down the bay, parallel to the hills, where it eventually passes over Santa Clara County. These sea breezes are strongest in the afternoon. As the marine air travels further from the ocean,



the ocean’s effect is diminished. Therefore, although the climate in this region is affected by sea breezes, it is affected less than regions closer to the Golden Gate.

National Ambient Air Quality Standards (NAAQS) The Clean Air Act, which was last amended in 1990, requires EPA to set National Ambient Air Quality Standards (40 CFR part 50) for pollutants considered harmful to public health and the environment. The Clean Air Act established two types of national air quality standards. Primary standards set limits to protect public health, including the health of "sensitive" populations such as asthmatics, children, and the elderly. Secondary standards set limits to protect public welfare, including protection against decreased visibility, damage to animals, crops, vegetation, and buildings.

The EPA Office of Air Quality Planning and Standards (OAQPS) has set National Ambient Air Quality Standards for six principal pollutants, which are called "criteria" pollutants. Units of measure for the standards are parts per million (ppm) by volume, milligrams per cubic meter of air (mg/m3), and micrograms per cubic meter of air (µg/m3).

AMBIENT AIR QUALITY STANDARDS AND BAY AREA ATTAINMENT STATUS

Pollutant Averaging Time

California Standards (1) National Standards (2)

Concentration Attainment

Status Concentration (3) Attainment

Status

Ozone 8 hour 0.070 ppm

(137µg/m3) N (9) 0.08 ppm N (4)

1 hour 0.09 ppm (180 µg/m3) N -- (5)

Carbon Monoxide

8 hour 9.0 ppm (10 mg/m3) A 9 ppm

(10 mg/m3) A (6)

1 hour 20 ppm (23 mg/m3) A 35 ppm

(40 mg/m3) A

Nitrogen Dioxide

1 hour 0.18 ppm (338 µg/m3) A -- --

Annual Arithmetic Mean 0.030 ppm (56 µg/m3) -- 053 ppm

(100 µg/m3) A

Sulfur Dioxide

24 Hour 0.04 ppm (105 µg/m3) A 0.14 ppm

365 µg/m3) A

1 Hour 0.25 ppm (655 µg/m3) A -- --

Annual Arithmetic Mean -- -- 0.030 ppm (80 µg/m3) --

Particulate Matter (PM10)

Annual Arithmetic Mean 20 µg/m3 N (7) -- -- 24 Hour 50 µg/m3 N 150 µg/m3 U

Particulate Matter (PM2.5)

Annual Arithmetic Mean 12 µg/m3 N (7) 15 µg/m3 A 24 Hour -- -- 35 µg/m3 (10) U

Sulfates 24 Hour 25 µg/m3 A

Lead Calendar Quarter -- -- 1.5 µg/m3 A

30 Day Average 1.5 µg/m3 A -- --

A = Attainment mg/m3=milligrams per cubic meter (7) Footnote N = Non-attainment µg/m3=micrograms per cubic meter -- Not applicable U = Unclassified ppm = parts per million



AMBIENT AIR QUALITY STANDARDS AND BAY AREA ATTAINMENT STATUS 1. California standards for ozone, carbon monoxide (except Lake Tahoe), sulfur dioxide (1-hour and 24-hour), nitrogen dioxide,

suspended particulate matter - PM10, and visibility reducing particles are values that are not to be exceeded. The standards for sulfates, Lake Tahoe carbon monoxide, lead, hydrogen sulfide, and vinyl chloride are not to be equaled or exceeded. If the standard is for a 1-hour, 8-hour or 24-hour average (i.e., all standards except for lead and the PM10 annual standard), then some measurements may be excluded. In particular, measurements are excluded that ARB determines would occur less than once per year on the average. The Lake Tahoe CO standard is 6.0 ppm, a level one-half the national standard and two-thirds the state standard.

2. National standards other than for ozone, particulates and those based on annual averages are not to be exceeded more than once a

year. The 1-hour ozone standard is attained if, during the most recent three-year period, the average number of days per year with maximum hourly concentrations above the standard is equal to or less than one. The 8-hour ozone standard is attained when the 3-year average of the 4th highest daily concentrations is 0.08 ppm or less. The 24-hour PM10 standard is attained when the 3-year average of the 99th percentile of monitored concentrations is less than 150 µg/m3. The 24-hour PM2.5 standard is attained when the 3-year average of 98th percentiles is less than 65 µg/m3.

3. Except for the national particulate standards, annual standards are met if the annual average falls below the standard at every site. The

national annual particulate standard for PM10 is met if the 3-year average falls below the standard at every site. The annual PM2.5 standard is met if the 3-year average of annual averages spatially-averaged across officially designed clusters of sites falls below the standard.

4. National air quality standards are set at levels determined to be protective of public health with an adequate margin of safety. 5. In June 2004, the Bay Area was designated as a marginal nonattainment area of the national 8-hour ozone standard. 6. The national 1-hour ozone standard was revoked by U.S. EPA on June 15, 2005. 7. In April 1998, the Bay Area was redesignated to attainment for the national 8-hour carbon monoxide standard. 8. In June 2002, CARB established new annual standards for PM2.5 and PM10. 9. Statewide VRP Standard (except Lake Tahoe Air Basin): Particles in sufficient amount to produce an extinction coefficient of 0.23 per

kilometer when the relative humidity is less than 70 percent. This standard is intended to limit the frequency and severity of visibility impairment due to regional haze and is equivalent to a 10-mile nominal visual range.

10. The 8-hour CA ozone standard was approved by the Air Resources Board on April 28, 2005 and became effective on May 17, 2006. 11. U.S EPA lowered the 24-hour PM2.5 standard from 65 µg/m3 to 35 µg/m3 in 2006. EPA is required to designate the attainment status

of BAAQMD for the new standard by December of 2009. SOURCE: Bay Area Air Quality Management District, http://www.baaqmd.gov/pln/air_quality/ambient_air_quality.htm; Updated January 4,

2007.

Comments 3a) Would the project conflict with or obstruct implementation of the applicable air

quality plan?


Less than Significant Impact. The entire San Francisco Bay Area is currently designated “non-attainment” for the state one-hour ozone standard. The Bay Area 2005 Ozone Strategy reviews the region’s progress over the years in reducing ozone levels, describes current conditions, and charts a course for future actions to further reduce ozone levels in the Bay Area. The control strategy, a central element of the Bay Area 2005 Ozone Strategy, outlines a set of control measures to further reduce ozone precursor emissions in order to reduce ozone levels in the Bay Area and to reduce transport of pollution to downwind regions.

Neither the ECOMM System nor the 15 individual sites where new towers, equipment shelters and/or microwave antennas are proposed nor the 10 individual sites where only



interior equipment modifications are proposed are growth-inducing since none would include any residential development or employment centers that would permanently increase the region’s population. Therefore, the proposed project would be consistent with the population growth and vehicle miles traveled assumptions included in the Bay Area 2005 Ozone Strategy. As a result, the proposed project would not conflict with or obstruct implementation of the Ozone Strategy. The project would comply with all applicable rules and regulations that have been developed as part of the Strategy and, as noted in 3b), would adhere to the Bay Area Air Quality Management District (BAAQMD) CEQA mitigation recommendations. Therefore, impacts resulting from the proposed project to applicable air quality plans would be less than significant.

3b) Would the project violate any air quality standard or contribute substantially to an existing or projected air quality violation?


Operation – No Impact. The proposed project is a system of microwave antennas linked at various locations throughout the County. The proposed sites include existing communications sites at local police or public safety agency facilities, the rooftops of buildings, or existing communications sites on hilltops. Operation of the project would not generate significant pollutant emissions from facilities or from the vehicle trips associated with site maintenance. Thus, there would be little or no change in vehicle emissions over baseline conditions, and therefore, the proposed project would not result in any air quality violation standards.

Category 0, 1 and 2 Sites:

Construction - Less than Significant Impact. Trucks would be required to deliver antennas and equipment to the sites and remove old antennas and equipment; however, no major construction activity or use of heavy equipment would occur at these sites, and trucks would only be used once for each site in Categories 0, 1 and 2 (delivery and possibly removal). Therefore, since there would be no significant increase in truck traffic arriving at or leaving the sites, the proposed project’s contribution to air quality would not be significant and no air quality standards would be violated.

Category 3 Sites:

Construction - Less than Significant Impact with Mitigation. The entire San Francisco Bay Area is currently designated “non-attainment” for the State particulate matter standard of 10 microns or less (PM10) and 2.5 microns or less (PM2.5) standards (national attainment status is “unclassified” for both PM10 and PM2.5) , and the State one-hour and the national eight-hour ozone standards. As part of the effort to reach attainment of these standards, the BAAQMD has established thresholds of significance for several criteria air pollutants associated with operation of projects. Specifically, a project is considered to have a potential to violate air quality standards if it would result in an increase in



emissions of 80 pounds per day or 15 tons per year of PM10, reactive organic gases (ROG) or nitrogen oxides (NOx). ROG and NOx are both precursors to ozone formation.

Individual project sites that require the installation of a new monopole or lattice tower would require construction activities to occur. In addition to tailpipe emissions, construction activities typically result in emission of PM, usually in the form of fugitive dust from activities such as demolition or removal of structures, excavation, grading, and vehicle travel on unpaved surfaces. In the absence of mitigation, construction activities may raise quantities of dust on a temporary and intermittent basis during the construction period. BAAQMD’s approach to analyses of construction impacts as noted in the BAAQMD CEQA Guidelines is to emphasize implementation of effective and comprehensive control measures rather than detailed quantification of emissions. With implementation of dust control measures presented as Mitigation Measure 3-1, which would be a part of the proposed Phase II expansion project, the project’s construction-related dust impacts would be less than significant.

Construction activities would also result in the emission of other criteria pollutants from equipment exhaust and construction-related vehicular activity. While emissions of ROG and NOx from these sources would incrementally add to the regional atmospheric loading of ozone precursors during project construction, these emissions are included in the emission inventory that is the basis for regional air quality plans. As such, project-related construction emissions would not impede attainment or maintenance of ozone standards in the Bay Area, and the project’s impact related to construction-vehicle emissions would be less than significant.

Mitigation Measure 3-1 (at Gilroy Reservoir D, Woodland Acres, and Lakeview Court sites only): During all phases of construction at Category 3 sites, the following dust control procedures shall be implemented:

• Water all active construction areas at least twice daily.

• Cover all trucks hauling soil, sand, and other loose materials or require all trucks to maintain at least two feet of freeboard (i.e., the minimum required space between the top of the load and the top of the trailer).

• Pave, apply water three times daily, or apply (non-toxic) soil stabilizers on all unpaved access roads, parking areas and staging areas at construction sites.

• Sweep daily (with water sweepers) all paved access roads, parking areas and staging areas at construction sites.

• Sweep streets daily (with water sweepers) if visible soil material is carried onto adjacent paved streets.



3c) Would the project 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)?


Operation – No Impact. Operation of the proposed project would mainly include vehicle trips associated with maintenance activities at each communication site. However, since maintenance would not be a daily activity at each site, and because the number of vehicles accessing the site would be similar to current numbers, operation of the project would not generate significant additional pollutant emissions from vehicle trips associated with site operation and maintenance. Therefore, operation of the proposed project would result in little or no change in emissions over baseline conditions. There would be no impacts to air quality and there would be no cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment.

Category 0, 1 and 2 Sites:

Construction - Less than Significant Impact. Trucks would be required to deliver antennas and equipment to the sites; however, trucks would only be used once for each site in Categories 0, 1 and 2 (delivery and possibly removal). Therefore, impacts to ambient air quality would be less than significant and there would be no cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment.

Category 3 Sites:

Construction - Less than Significant Impact with Mitigation. As noted in Section 3(b) above, emissions of particulate matter from construction activities would be reduced to less than significant with implementation of Mitigation Measure 3-1. As a result, there would be no cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment.

3d) Would the project expose sensitive receptors to substantial pollutant concentrations?


Operation – No Impact. As described in Item 3c), above, operation of the proposed project would mainly include vehicle trips associated with maintenance activities at each site. Vehicles visiting the site would typically include pick-up trucks and utility vehicles. Some jurisdictions have also incorporated vehicles that use clean-burning fuels (i.e., natural gas, biofuels, etc.) into their maintenance fleets. These vehicles, and the relatively small number of them that would visit the sites in a month, would result in no substantial pollutant concentrations being generated that would affect sensitive receptors. The



generators that provide back-up electricity at some of the communications site are propane powered and would not operate on a full-time basis. While several sites, including Gilroy City Hall Annex and Lakeview Court, are located in proximity to sensitive receptors (i.e., residential neighborhoods), the proposed projects would not result in substantial pollutant concentrations and would, therefore, not expose any sensitive receptors to substantial pollutant concentrations. In summary, operation of the proposed project would result in little or no change in pollutant concentrations over baseline conditions.


Construction – Less than Significant Impact. As identified in 3c), above, trucks would be required to deliver antennas and equipment to the sites; however, trucks would only be used once for each site in Categories 0, 1 and 2 (delivery and possibly removal). There are no sensitive receptors closer than approximately 100 feet to any of the sites. Therefore, the exposure of sensitive receptors would be less than significant.

Category 3 Sites:

Construction - Less than Significant Impact with Mitigation. As noted in Section 3(b) above, pollutant concentrations from construction activities would be reduced to less than significant with implementation of Mitigation Measure 3-1.

3e) Would the project create objectionable odors affecting a substantial number of people?


Operation – No Impact. No objectionable odors would be generated by operation of the proposed project.


Construction – Less than Significant Impact. During construction of the project, diesel-powered vehicles and equipment in use on the site could create minor odors. Since the construction footprint at each site is small (less than 1 acre) and the quantity of construction equipment used would be relatively few, any odors generated by the diesel equipment are not likely to be noticeable beyond the immediate area and, in addition, would be temporary and short-lived. Furthermore, the project would not include development of any uses that are associated with objectionable odors. Therefore, odor impacts would be less than significant.

3f) Would the project increase greenhouse gas emissions that hinder or delay the State’s ability to meet the reduction target (25% reduction by 2020) contained in CA Global Warming Solutions Act of 2006 (AB 32)?



Gases that trap heat in the atmosphere are called greenhouse gases (GHGs). Increases in GHGs are causing global climate change. Global climate change is a change in the average weather on earth that can be measured by wind patterns, storms, precipitation, and temperature. Although there is disagreement as to the speed of global warming and the extent of the impacts attributable to human activities, most agree that there is a link between increased emissions of GHGs and long-term global temperature. What GHGs have in common is that they allow sunlight to enter the atmosphere, but they also trap a portion of the outward-bound infrared radiation and warm up the air. The process is similar to the effect greenhouses have in raising their internal temperature, hence the name GHGs. Both natural processes and human activities emit GHGs.

The accumulation of GHGs in the atmosphere regulates the earth’s temperature; however, emissions from human activities such as electricity production and motor vehicles have elevated the concentration of GHGs in the atmosphere. This accumulation of GHGs has contributed to an increase in the temperature of the earth’s atmosphere and contributed to global climate change. The principal GHGs of concern are carbon dioxide (CO2), methane, nitrous oxide (N2O), sulfur hexafluoride, perfluorocarbons, and hydrofluorocarbons. Carbon dioxide is the reference gas for climate change. To account for the warming potential of GHGs, and to combine emissions of gases with differing properties, GHG emissions are typically quantified and reported as CO2 equivalents (CO2e).

Globally, climate change has the potential to impact numerous environmental resources through potential, though uncertain, impacts related to future air temperatures and precipitation patterns. The projected effects of global warming on weather and climate are likely to vary regionally, but are expected to include the following direct effects:

• Higher maximum temperatures and more hot days over nearly all land areas; • Higher minimum temperatures, fewer cold days and frost days over nearly

all land areas; • Reduced diurnal temperature range over most land areas; • Increased heat index over land areas; and • More intense precipitation events.

Also, there are many secondary effects that are projected to result from global warming, including global rise in sea level, impacts to agriculture, changes in disease vectors, and changes in habitat and biodiversity. While the possible outcomes and the feedback mechanisms involved are not fully understood, and much research remains to be done, the potential for substantial environmental, social, and economic consequences over the long term may be great.

In 2005, in recognition of California’s vulnerability to the effects of climate change, Governor Schwarzenegger established Executive Order S-3-05, which sets forth a series of target dates by which statewide emissions of greenhouse gas would be progressively reduced, as follows:



• By 2010, reduce greenhouse gas emissions to 2000 levels;

• By 2020, reduce greenhouse gas emissions to 1990 levels; and

• By 2050, reduce greenhouse gas emissions to 80 percent below 1990 levels.

The proposed project entails replacement of existing radio equipment and microwave antennas, installation of new antennas, and construction of new poles/towers and equipment shelters. Greenhouse gas emissions which would result from the construction and operations of the proposed project are associated with construction activities (emissions from construction equipment), materials used for construction (secondary impacts from cement production, transportation of materials), future vehicle trips to the site, and energy usage (emissions from power plants) from equipment operation.

As the California Air Resources Board (CARB) and Office of Planning and Research (OPR) have not yet adopted a methodology or defined quantitative thresholds that can be applied to a specific development project to evaluate the significance of it’s GHG emissions, no significance determination from the State is available at this time. Due to the relatively small scale of the project, and with implementation of Mitigation Measure 3-2, below, it is anticipated that the proposed project would not result in any cumulatively considerable greenhouse gas emissions.

The County adopted a Green Building Ordinance in December 2008. However, the proposed construction at each individual ECOMM site would be so small that it would fall under the 500-square-foot threshold exemption of the Green Building Ordinance. With respect to quantifying project greenhouse gas emissions, most energy use for the project would be electricity consumed, which, although not quantified, would be small, especially because transportation-related greenhouse gas emission are less than significant, and significance standards typically exclude transportation from such calculations.

The following measures mitigate the project’s impacts regarding greenhouse gas emissions:

Mitigation Measure 3-2 (at Gilroy Reservoir D, Woodland Acres, and Lakeview Court sites only): All Construction vehicles, equipment and delivery trucks shall have a maximum idling time of 5 minutes. Engines shall be shut off if construction requires longer idling time unless necessary for proper operation of the vehicle.







Impact


with Mitigation

Incorporation


Impact No Impact

4. BIOLOGICAL RESOURCES— Would the project:

a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?

b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?

c) Affect listed threatened or endangered species or designated critical habitats; or would it be likely to jeopardize the continued existence of any proposed endangered or threatened species or likely to result in the destruction or adverse modification of proposed critical habitats? (NEPA)

d) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) or state-protected wetlands, through direct removal, filling, hydrological interruption, or other means?

e) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?

f) Fundamentally conflict with any local policies or ordinances protecting biological resources, such as local tree preservation and removal ordinances, creek protection ordinance, or open space and conservation elements of the local General Plan?

g) Fundamentally conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?

h) Be located in an officially designated wilderness area or preserve? (NEPA)

Comments The majority of sites for Phase II of the ECOMM project would install microwave equipment on existing structures near public facilities. These sites would have minimal impacts on biological resources, as construction activities would be limited and no ground disturbance would occur. Four Category 3 ECOMM sites (Category 3 Sites) do involve erection of new towers or small amounts of ground disturbance, and were assessed in greater detail. These areas would require construction of a new towers, excavation for installation of monopoles, minor grading and pouring of concrete pads for equipment shelters, or renovation of existing structures to house



electrical or control boxes. It is anticipated that no more than 15 feet of ground disturbance would occur when necessary to complete construction at three of these sites.

4a) Would the project 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?


Less than Significant Impact with Mitigation. Proposed ECOMM sites are located in the southern Santa Clara Valley, which has been developed rapidly in the last 40 years from mostly farmland and rangeland to suburban residential and commercial development. However, large tracts of agricultural land and relatively undisturbed open space still exist in the area, and these can support connected wildlife and plant communities. Common natural habitats include annual grassland, oak woodland, chaparral/coastal scrub, and valley foothill riparian corridors.

All proposed ECOMM sites have trees, shrubs, or structures within 200 feet of existing facilities or construction areas that could support nesting birds. Although many bird species do not have any special status designation, the Migratory Bird Treaty Act, as well as California Fish and Game Code, afford protection to almost all nesting native bird species. Breeding birds are protected under California Fish and Game Code 3503 and raptors are protected under Section 3503.5. In addition, Section 3513 of the Code and the Federal Migratory Bird Treaty Act (16 USC, Sec. 703 Supp. I, 1989) prohibit the killing, possession, or trading of migratory birds. Finally, Section 3800 of the Code prohibits the taking of non-game birds, that are defined as birds occurring naturally in California that are not game birds or fully protected species. Tree trimming has the potential to result in direct harm to individual birds through “take” of their nests, eggs, or nestlings. ECOMM equipment upgrade and construction activities may also result in indirect impacts to protected breeding birds resulting from construction noise, even when the physical nest is unaffected. Protected birds, especially raptors, could potentially nest on large lattice towers or monopole structures, and replacement of microwave antennae on existing towers could significantly impact nesting birds. Potential impacts to breeding or nesting birds occurring as a result of utility upgrades or construction would be minimized to less-than-significant levels with the implementation of Mitigation Measure 4-1.

Mitigation Measure 4-1 (at all sites): If microwave utility construction or vegetation removal must be performed in the bird nesting season (February 1st through August 31st), a qualified biologist shall be retained to survey the project area for nesting raptors and other birds and verify the presence or absence of nesting birds or raptors no more than 14 days prior to construction activities. If active nests are observed, buffer zones shall be established around trees/shrubs with nests, with a buffer size established by the qualified biologist through consultation with the appropriate regulatory agency (e.g., CDFG). Buffered zones shall be



avoided during construction activities until young have fledged or the nest is otherwise abandoned.

Equipment replacement at ECOMM Category 0 sites would not have impacts on nesting birds, and these sites do not require implementation of Mitigation Measure 4.1.

Impacts on special-status2 species are not expected at ECOMM Category 0, 1, and 2 sites. Access roads to these sites already exist, and heavy equipment would not be necessary to upgrade microwave systems on existing structures. Locations for addition or replacement of microwave equipment have been previously disturbed from construction of existing public facilities, and any habitats near these areas suitable for special status species would not be disturbed by limited project activities occurring at Category 0, 1, and 2 sites.

Category 3 Sites:

Less than Significant Impact. Category 3 Sites are located in the cities of Morgan Hill and Gilroy, and are: Lakeview Court, Gilroy Reservoir D, and Woodland Acres.

• Lakeview Court. Located near 3100 Lakeview Court in Morgan Hill, approximately 2 miles northeast of US-101 and less than 0.5 miles south of Anderson Lake. Habitats near this site include landscaped/ornamental vegetation, developed areas, and annual grassland. Mature ornamental trees are present in residential neighborhood surrounding the site. Pole location is on an open area adjacent to two water reservoirs, with only ruderal vegetation present.

• Gilroy Reservoir D. Located near 2265 Periwinkle Drive, Reservoir D is approximately 2.5 miles west of US-101 and 0.5 miles north of CA-152. Habitats near this site include oak savannah, annual grassland, and developed areas. Mature coast live oak trees (Quercus agrifolia) grow around most of the site. Pole location is on an artificial dirt embankment adjacent to two large reservoir tanks.

• Woodland Acres. Located near 2275 Rolling Hills Drive in Morgan Hill, approximately 3 miles southwest of US-101 and less than 0.5 miles north of the Chesboro Reservoir. Habitats near this site include coastal scrub and annual grassland. Four mature eucalyptus trees (Eucalyptus spp.) grow on a graded dirt pad for a reservoir tank. Pole location is on bare ground adjacent to reservoir.

• Gilroy City Hall Annex. Located at 7370 Rosanna Street in Gilroy, CA, approximately 0.75 miles east of US-101 and approximately 0.5 miles north of East Pacheco Pass Road. This site is surrounded by the residential and

2 The term “special-status” species includes those species that are listed and receive specific protection defined in

federal or state endangered species legislation, as well as species not formally listed as Threatened or Endangered, but designated as “Rare” or “Sensitive” on the basis of adopted policies and expertise of state resource agencies or organizations, or local agencies such as counties, cities, and special districts. A principle source for this designation is the California “Special Animals List” (CDFG, 2009b).



commercial developments of downtown Gilroy. Any vegetation in the area is either ornamental or in close proximity to paved surfaces. Pole location is on top of an existing building currently used by the City of Gilroy, and no ground disturbance would occur during installation.

The California Natural Diversity Database (CNDDB) documents 45 special-status species within the Chittenden, Gilroy, Mount Madonna, Mount Sizer, and Morgan Hill U.S. Geological Survey (USGS) quadrangles that includes the Category 3 Sites (CDFG, 2009a). Habitats at the Category 3 Sites were assessed for their potential to support special-status species using the CNDDB (CDFG, 2009a), the US Fish and Wildlife Service’s endangered and threatened species database (USFWS, 2009), and a reconnaissance-level site visit conducted by an ESA biologist on January 8th, 2010 (ESA, 2010). Habitats suitable for California tiger salamander (Ambystoma californiense) and burrowing owl (Athene cunicularia) are present within 0.5 miles of Reservoir D, and habitats suitable for bay checkerspot butterfly (Euphydryus editha bayensis) and California tiger salamander are present within 0.5 miles of Lakeview Court. Recent CNDDB occurrences for California tiger salamander are located between 1 and 2 miles west of the Reservoir D site, and an occurrence for burrowing owl is located approximately 1 mile north of the Reservoir D site. However, the Project Sites lack suitable aquatic or upland habitat for California tiger salamander and lack suitable burrowing or foraging habitat for burrowing owl. Additionally, foodplants for the bay checkerspot butterfly are not present at the Lakeview Court project site.

Sites for monopoles or concrete pads at all the locations requiring ground disturbance are largely devoid of native vegetation and were previously disturbed or graded for construction of other water or communications facilities. Small patches of ruderal vegetation exist, but sites generally lack vegetation and are on gravel or concrete surfaces. Ground disturbance in these areas would not impact habitat for special-status species, and access to these areas would be on existing asphalt or gravel roads also devoid of special-status species habitat. Significant residential developments are located between large habitat areas and the project sites at Reservoir D and Lakeview Court, creating barriers for terrestrial species to disperse into project areas. No substantial adverse effects on special-status species from construction activities are expected at Category 3 Sites.

4b) Would the project 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?


Less than Significant Impact. Wetland areas are the only natural community potentially affected by project activities, and are addressed in 4c).



4c) Would the project have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) or tributary to an already impaired water body, as defined by section 303(d) of the Clean Water Act, through direct removal, filling, hydrological interruption, or other means?


Less than Significant Impact. Wetlands are a subset of “waters of the United States,” which are defined in the Code of Federal Regulations (CFR) (33 CFR 328.3[a]; 40 CFR 230.3[s]) as rivers, streams, mud flats, sand flats, wetlands, sloughs, prairie potholes, wet meadows, playa lakes, or natural ponds, the use, degradation, or destruction of which could affect interstate or foreign commerce including any such waters. These waters fall under the jurisdiction of the U.S. Army Corps of Engineers (Corps) and San Francisco Bay Regional Water Quality Control Board (RWQCB) under Sections 404 and 401 of the Clean Water Act, respectively, and CDFG jurisdiction under Sections 1600 through 1616 of the California Fish and Game Code. Riparian corridors associated with these streams are also protected under Sections 1600 through 1616 of the California Fish and Game Code. Chesboro and Anderson Lake are within 0.5 miles of the Woodland Acres and Lakeview Court sites, and Uvas Creek is within 1 mile of Reservoir D, all of which are under the jurisdiction of the Corps, RWQCB, and/or CDFG. However, none of the project sites are directly adjacent to a waterway, and BMPs described in Section 8, Hydrology, would prevent any runoff from significantly impacting jurisdictional waters.

4d) Would the project have a substantial adverse effect on oak woodland habitat as defined by Oak Woodlands Conservation Law (conversion/loss of oak woodlands) – Public Resource Code 21083.4?


No Impact. The Oak Woodlands Conservation Law states that significant impacts on oak woodland habitats (woodlands composed of trees in the genus Quercus with greater than 10% canopy cover) must be mitigated. Several mitigation measures are described in the law, including

• Purchasing conservation easements

• Replanting and maintaining compensatory oak trees

• Contributing funds to the Oak Woodlands Conservation Fund, a fund managed by CDFG that awards grants to restore oak woodland habitat, or

• Implement other mitigation measures developed by the county.

Removal of oak trees is not anticipated during utility upgrades or construction activity for any site categories. Impacts to any oak trees that require minor trimming would be mitigated in local or county tree protection ordinances, addressed in 4g) below.



4e) Would the project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?


Less than Significant Impact. Extensive open habitat areas exist in Santa Clara County, and many of these undeveloped areas are well-suited to support connected wildlife populations. Additionally, the San Francisco Bay Area is located along the pacific flyway, a significant migratory route for shorebirds and waterfowl. Upgrades to microwave equipment on existing structures would not significantly increase structure size or width, and would not significantly impact migratory bird species. Limited construction activities for ECOMM upgrades at category 0, 1, and 2 sites would not impact habitats for any terrestrial or aquatic migratory wildlife.

Category 3 Sites:

Less than Significant Impact with Mitigation. Research on migrating passerines and shorebirds shows they are often attracted to utility poles, radio towers, large buildings, and wind turbines, and collisions with these structures can prove fatal. Collisions are more likely to occur at night, during storm events, or along known migration routes. Lights on these structures can confuse migrating birds and increase chances of collision. Several long-term studies have documented thousands of bird fatalities on large tower structures, but data for shorter tower structures is typically not as thorough. One study collected 73 birds killed by collisions with a 100-foot tall fire tower, and songbird collisions with small towers cannot be completely discounted until more research is conducted (Manville, 2005). Poles proposed for Lakeview Court, Reservoir D, and Woodland Acres would not exceed 40 feet tall, and most migrating birds would not encounter them. The tallest monopole at the Gilroy City Hall Annex site would rise less than 50 feet above the ground level, resulting is a relatively short height for transient birds. USFWS recommends structures be less than 200 feet tall to mitigate serious bird collision risks, which is significantly larger than proposed ECOMM monopole heights (USFWS, 2000). While the height of these monopoles is unlikely to adversely affect birds, guy wires proposed as part of the Gilroy City Hall Annex roof-top tower design could create significant bird strike impacts. These potential impacts would be reduced to less-than-significant levels by Mitigation Measure 4-2.

Mitigation Measure 4-2 (at Gilroy City Hall Annex Site):

• At the Gilroy City Hall Annex site, daytime visual markers, such as brightly colored plastic sheaths, shall be installed on the guy wires used to support the 20-foot roof-top tower, to prevent daytime bird or raptor collisions.

Impacts to avian nursery sites are addressed in 4a), above.



4f) Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?


No Impact. Many ECOMM sites are within the planning area of the Draft Santa Clara Valley Habitat Conservation Plan (SCVHCP) (Santa Clara County, 2009). The plan seeks to protect, restore, and enhance habitats in the Santa Clara Valley and streamline the permitting process for projects in the area. A second Administrative Draft was recently published by Santa Clara County, but the plan is not yet completed or fully implemented. Proposed project activities would not conflict with any provisions of the SCVHCP.

4g) Would the project conflict with any local policies or ordinances protecting biological resources:

i) Tree Preservation Ordinance [Section C16]?

ii) Wetland Habitat [GP Policy, R-RC 25-30]?

iii) Riparian Habitat [GP Policy, R-RC 31-41]?


Less than Significant Impact with Mitigation. Nearly all ECOMM sites are located within at least 200 feet of mature vegetation. Many of the cities where these sites are located have local tree ordinances that require tree removal permits for removal or significant damage to designated protected trees. Utility upgrades and construction involved in category 0, 1, 2, and 3 sites would not require removal of any trees. However, minor tree trimming may occur for installation and maintenance purposes, but trimming is not anticipated to require tree removal permitting.

In the event that the project design is altered and requires the removal or substantial modification of trees the project applicant would abide by local tree ordinances. Impacts from tree modification or removal would be mitigated to less-than significant levels by Mitigation Measure 4-3.

Mitigation Measure 4-3 (at all sites): Pursuant to the Santa Clara County Code, Division C16-Tree Preservation and Removal (County of Santa Clara, 1998), the County requires a permit for any tree, regardless of size, within road rights-of-way and easements of the County, whether within or without the unincorporated territory of the County. One criterion the County uses to determine permit approval is whether the tree interferes with vital public utilities or if it will be replaced by approved plantings.

Therefore, any person desiring to remove any tree under an Administrative Permit shall file an application with the County Planning Office not less than 10 days prior



to the date of such planned removal. Removal of any tree, regardless of size, located within a County road right-of-way shall require an Encroachment Permit from the Department of Roads & Airports not less than 60 days prior to planned removal. The following information shall be included in applications for tree removal:

• A brief statement of the reasons for removal of the tree.

• A photograph of the tree(s) proposed for removal.

• A tree survey (map) with the accurate location, number, species, size (diameter measured four and one-half feet above ground, approximate height, and approximate canopy diameter), general health, and approximate age, if known.

• Location of property lines, names of the streets fronting the property and edge of any street right-of-way.

• A replanting and/or revegetation plan for all trees to be removed. Replacement trees shall be of a like kind and species of tree removed, if native and feasible, or of a kind and species to be determined by the Planning Department. Replacement tree planting shall utilize at least five (5) gallon size stock.

Additionally, depending on the location of the removed tree, local tree ordinances may apply to removal or replacement of protected significant trees. Removal of any trees shall require a tree removal permit from Santa Clara County as well as tree removal permits from applicable city planning agencies.

With implementation of Mitigation Measures 4-1 and 4-2, impacts resulting from tree trimming and tree removal would be reduced to less than significant.

The project would not conflict with any provisions in Wetland Habitat or Riparian Habitat conservation sections of the Santa Clara County General Plan. Any indirect impacts on riparian or wetland areas would be mitigated to less-than-significant levels with BMPs described in Section 8, Hydrology.

4h) Be located in an officially designated wilderness area or preserve? (NEPA)


No Impact. No impacts would occur system-wide or at any of the Category 0, 1, or 2 sites that would have the potential to adversely impact an officially designated wilderness area or preserve. Furthermore, none of the individual Category 3 sites, which would involve ground disturbance, are located within an officially designated wilderness area or preserve.



Sources California Department of Fish and Game (CDFG), 2009a, California Natural Diversity Database

query for USGS 7.5 minute topographic quadrangles of San Rafael, Commercial Version, Accessed December, 2009.

CDFG. California Natural Diversity Database, 2009b, Special Animals (901 Taxa), Accessed December 16, 2009, http://www.dfg.ca.gov/biogeodata/cnddb/pdfs/SPAnimals.pdf.

County of Santa Clara, 1998. County Code, Division C16 Tree Preservation and Removal.

ESA, 2009, Site reconnaissance, January 8, 2010.

Manville, 2005. Bird strikes and electrocutions at power lines, communications towers, and wind turbines: state of the art and state of the science – next steps toward mitigation. USDA Forest Service General Tech Report PSW-GTR-191.

Santa Clara County, 2009. Administrative Draft Santa Clara Valley Habitat Conservation Plan. Accessed January 2010. Available online at: http://www.scv-habitatplan.org/www/site/alias__default/documents_draft_hcp_chapters/292/draft_hcp_chapters.aspx

USFWS. Listed Species Letter for USGS 7.5 minute topographic quadrangles of Mount Sizer, Morgan Hill, Gilroy, Mount Madonna, and Chttenden. Accessed January 2010.

USFWS. 2000. Service Guidance on the Siting, Construction, Operation and Decommissioning of Communications Towers. From directors Jaime, Rappaport, and Clark.





Impact


with Mitigation

Incorporation


Impact No Impact

5. CULTURAL RESOURCES— Would the project:

a) Cause a substantial adverse change in the significance of a historical resource as defined in CEQA §15064.5, or affect districts, sites, buildings, structures or objects significant in American history, architecture, archeology, engineering or culture, that are listed, or are eligible for listing, in the National Register of Historic Places? (CEQA and NEPA)

b) Cause a substantial adverse change in the significance of an archaeological resource as defined in §15064.5 of the CEQA Guidelines?

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?

e) Affect any Native American religious sites? (NEPA)

f) If within New Almaden Historic area, conflict with General Plan policies of this designated special policy area?

Methods The effort to identify cultural resources in the project area included a record search and review of existing documents and reference materials, contacts with Native Americans, and a field survey.

A records search at the Northwest Information Center of the California Historical Resources Information System at Sonoma State University was completed on December 16, 2009 (File No. 09-0772). The review included the Category 3 project sites with a ¼-mile radius. Previous surveys, studies, and archaeological site records were accessed. Records were also reviewed in the Historic Property Data File for Santa Clara County that contains information on sites of recognized historical significance including those evaluated for listing in the National Register of Historic Places, the California Register of Historical Resources, the California Inventory of Historical Resources, California Historical Landmarks, and California Points of Historical Interest.

An archaeological field inspection of the Category 3 project sites was conducted on January 11, 2010 by an ESA Registered Professional Archaeologist (Koenig, 2010). Categories 1 and 2 sites would not require ground disturbance and are located within completely built environments of modern construction. The Category 1 and 2 sites also currently have numerous towers and communication antennae; as such, the inclusion of the new tower or an upgrade to an existing tower would not impact the setting of the individual building, nor any adjacent buildings. In areas where the natural ground surface was visible, the surface was examined for evidence of archaeological materials.



Comments 5a) Would the project cause a substantial adverse change in the significance of a

historical resource as defined in CEQA §15064.5, or affect districts, sites, buildings, structures or objects significant in American history, architecture, archeology, engineering or culture, that are listed, or are eligible for listing, in the National Register of Historic Places? (CEQA and NEPA)

ECOMM System and Category 1 and 2 Sites:

No Impact. Category 1 sites would require only the direct replacement of existing microwave dishes on rooftops or existing towers at existing communications facilities. No new towers, monopoles or equipment sheds would be constructed. The replacement dishes typically would be the same size or smaller than the existing dishes to be replaced, and in some instances, one new dish may replace two or more old dishes. As such, no mechanism to cause impacts to historical resources or unique archaeological resources are expected. That is, no material alteration (or excavation) or setting alteration of a site or structure that has not been previously altered by microwave dishes or similar structures would occur. Therefore, no impact to cultural resources would occur.

Category 2 sites would require adding new microwave dishes on rooftops or existing towers at existing communications facilities. Similar to Category 1, no new material or setting alteration of a site or structure that has not been previously altered would occur with the proposed project.

Category 3 Sites:

Less than Significant Impact with Mitigation. Category 3 sites would require the construction of new monopole towers and, in some cases equipment shelters, in order to mount and operate the microwave dishes. However, in all three cases the installation of the new site would not exceed the current boundaries of the facility and no substantial excavation is required in undisturbed areas. The survey conducted at each site did not identify any historical resources or unique archaeological resources. The areas are graded and disturbance with no native topography visible. However, in some cases excavation can reveal unknown significant historical or archaeological resources in areas of low sensitivity. Implementation of Mitigation Measure 5-1, however, would reduce the impact to a less-than-significant level.

Mitigation Measure 5-1 (at Gilroy Reservoir D, Woodland Acres, and Lakeview Court sites only): If any prehistoric or historic-era subsurface cultural resources are discovered during ground-disturbing activities, all work within 50 feet of the resources shall be halted and the responsible public agency shall consult with a qualified archaeologist to assess the significance of the find according to CEQA Guidelines Section 15064.5. If any find is determined to be significant, the project proponent and the archaeologist shall meet to determine the appropriate avoidance measures or other appropriate mitigation. The responsible public agency (as applicable) shall make the final determination. All significant cultural materials



recovered shall be, as necessary and at the discretion of the consulting archaeologist, subject to scientific analysis, professional museum curation, and documentation according to current professional standards.

In considering any suggested mitigation proposed by the consulting archaeologist in order to mitigate impacts to historical resources or unique archaeological resources, the responsible public agency will determine whether avoidance is necessary and feasible in light of factors such as the nature of the find, project design, costs, and other considerations. If avoidance is infeasible, other appropriate measures (e.g., data recovery) will be instituted. Work may proceed on other parts of the project site while mitigation for historical resources or unique archaeological resources is being carried out.

Implementation of Mitigation Measure 5-1 would reduce impacts associated with human remains at any of the sites to less than significant.

5b) Would the project cause a substantial adverse change in the significance of a unique archaeological resource pursuant to CEQA §15064.5?


Less than Significant Impact with Mitigation. No unique archaeological resources have been identified within the project sites through field and archival research. However, unknown subsurface resources may occur in most any area. Implementation of Mitigation Measure 5-1 (above) would reduce or avoid any impacts to unknown unique archaeological resources to less than significant.

5c) Would the project cause a substantial adverse change in the significance of a unique paleontological resource or site or unique geological feature?


Less than Significant Impact with Mitigation. Paleontological resources are the fossilized evidence of past life found in the geologic record. Despite the tremendous volume of sedimentary rock deposits preserved worldwide and the enormous number of organisms that have lived through time, preservation of plant or animal remains as fossils is an extremely rare occurrence. Because of the infrequency of fossil preservation, fossils—particularly vertebrate fossils—are considered to be nonrenewable resources. Because of their rarity and the scientific information they can provide, fossils are highly significant records of ancient life. The paleontological review and survey conducted on the project site did not identify any paleontologic site or any geologic phenomena that may predict such resources.

While fossils are not expected to be discovered during project construction, significant fossils could be discovered during excavation activities (i.e., trenching or grading), even in areas with a low likelihood of occurrence. Fossils encountered during excavation could be inadvertently damaged. If a paleontological resource is discovered, the impact to the



resource could be substantial. However, implementation of Mitigation Measure 5-2 would minimize this impact to a less-than-significant level.

Mitigation Measure 5-2 (at Gilroy Reservoir D, Woodland Acres, and Lakeview Court sites only): The responsible public agency shall notify a qualified paleontologist of unanticipated discoveries, who shall document the discovery as needed, evaluate the potential resource, and assess the significance of the find under the criteria set forth in Section 15064.5 of the CEQA Guidelines. In the event of an unanticipated discovery of a breas, true, and/or trace fossil during construction, excavations within 50 feet of the find shall be temporarily halted or diverted until the discovery is examined by a qualified paleontologist (per Society of Vertebrate Paleontology standards [SVP 1995]). The paleontologist shall notify the appropriate agencies to determine procedures that would be followed before construction is allowed to resume at the location of the find. If the responsible public agency determines that avoidance is not feasible, the paleontologist shall prepare an excavation plan for mitigating the effect of the project on the qualities that make the resource important, and such plan shall be implemented. The paleontologist shall submit the excavation plan to the responsible public agency for review and approval.


5d) Would the project disturb any human remains, including those interred outside of formal cemeteries?


Less than Significant Impact with Mitigation. There is no indication that any particular site in the project area has been used for human burial purposes in the recent or distant past. Therefore, it is unlikely that human remains would be encountered during construction of the proposed project. However, in the unlikely event that human remains were discovered during ground-disturbing activities, including those interred outside of formal cemeteries, the human remains could be inadvertently damaged, which could be a significant impact. However, this impact would be minimized by implementation of Mitigation Measure 5-3.

Mitigation Measure 5-3 (at Gilroy Reservoir D, Woodland Acres, and Lakeview Court sites only): If human skeletal remains are uncovered during project construction, the project proponent (depending upon the project component) shall immediately halt work, contact the Santa Clara County coroner to evaluate the remains, and follow the procedures and protocols set forth in Section 15064.5 (e)(1) of the CEQA Guidelines. If the County coroner determines that the remains are Native American, the project proponent shall contact the NAHC, in accordance with Health and Safety Code Section 7050.5, subdivision (c), and Public Resources Code 5097.98 (as amended by AB 2641). Per Public Resources Code 5097.98, the landowner shall ensure that the immediate vicinity, according to generally accepted cultural or archaeological standards or practices, where the Native American human remains are located, is not damaged or disturbed by further development activity



until the landowner has discussed and conferred, as prescribed in this section (PRC 5097.98), with the most likely descendents regarding their recommendations, if applicable, taking into account the possibility of multiple human remains.


5e) Would the project affect any Native American religious sites?


Less than Significant Impact with Mitigation. A letter addressed to the Native American Heritage Commission (NAHC) was sent on December 23, 2009, requesting information on locations of importance to Native Americans that might occur within or near the ECOMM sites and a list of Native Americans that should be contacted. The NAHC provided a list of Native American organizations that should be contacted concerning locations of importance to Native Americans in the project area. ESA sent a letter to each organization on the NAHC list, providing information about the proposed project and requesting information on locations of importance to Native Americans. No responses have been received to date.

It is not anticipated that any site would be located on a Native American location of importance since all of the sites are at existing communications facilities or buildings. However, in the event it becomes apparent that the site could be a location of importance, such as if religious artifact or human remains are discovered during grading or trenching activities at a site (affecting Category 3 sites), Mitigation Measure 5-3 would require that work cease at the site and the NAHC be contacted for further consultation. Implementation of Mitigation Measure 5-3 would thus, avoid or reduce impacts related to disturbance of a Native American site to less than significant.

5f) If within New Almaden Historic area, conflict with General Plan policies of this designated special policy area?


No Impact. None of the individual sites are within the New Almaden Historic area. Therefore, there the proposed project would not conflict with General Plan policies of this designated special policy area.

Sources Koenig, Heidi, ECOMM Digital Microwave Phase II Project, Archaeological Survey Report,

Prepared for the County of Santa Clara. On file at ESA, 2009.

Society of Vertebrate Paleontology (SVP). Assessment and mitigation of adverse impacts to nonrenewable paleontologic resources: standard guidelines, Society of Vertebrate Paleontology News Bulletin, Vol. 163, p. 22-27. 1995.





Impact


with Mitigation

Incorporation


Impact No Impact

6. GEOLOGY AND SOILS—Would the project:

a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving:

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) Strong seismic ground shaking?

iii) Seismic-related ground failure, including liquefaction?

iv) Landslides?

b) Result in substantial soil erosion or the loss of topsoil?

c) Be located on geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?

d) Be located on expansive soil, as defined in the report, Soils of Santa Clara County, 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 waste water?

f) Cause substantial compaction or over-covering of soil either on-site or off-site?

g) Cause substantial change in topography or unstable soil conditions from excavation, grading, or fill?

h) Involve significant change in surface features (wetland fill, deforestation, or water diversion? (NEPA)

Discussion The County of Santa Clara lies within the geomorphic region of California referred to as the Coast Range, which lies between the Pacific Ocean and the Great Valley and stretches from the Oregon border to the Santa Ynez River near Santa Barbara.3 Discontinuous northwest-trending mountain ranges, ridges, and intervening valleys characterize this province. Much of the Coast Range province is composed of marine sedimentary and volcanic rocks that form the Franciscan Assemblage. The Franciscan Assemblage in this region of California is Jurassic to Cretaceous-aged (approximately 65 to 150 million years old), and consists primarily of greenstone (altered volcanic rocks), basalt, chert (ancient silica-rich ocean deposits), and sandstone that originated as ancient sea floor sediments.

3 A geomorphic province is an area that possesses similar bedrock, structure, history, and age. California has 11

geomorphic provinces.



Comments 6a) Would the project expose people or structures to potential substantial adverse

effects, including the risk of loss, injury, or death involving i) rupture of a known earthquake fault; ii) strong seismic ground shaking; iii) seismic-related ground failure including liquefaction; or iv) landslides?


i-iv) Less than Significant Impact. The project facilities at the project sites would be unoccupied except during periodic maintenance visits. Therefore, the potential for risk to people or structures from fault rupture at a project is considered less than significant.

The proposed project lies within a region of California that contains many active and potentially active faults and is considered an area of high seismic activity.4 The 2001 California Building Code locates the entire Bay Area within Seismic Risk Zone 4. Areas within Zone 4 are expected to experience maximum magnitudes and subsequent damage in the event of an earthquake. The U.S. Geological Survey (USGS) Working Group on California Earthquake Probabilities evaluated the probability of one or more earthquakes of Richter magnitude 6.7 or higher occurring in the San Francisco Bay Area within the next 30 years. The result of the evaluation indicated a 62 percent likelihood that such an earthquake event would occur in the Bay Area between 2003 and 2032 (USGS, 2003).

The closest active faults to the project site include the San Andreas fault (running northwest to southeast in the center portion of the County), the Hayward fault (running northwest to southeast in the eastern-central part of the County), Calaveras fault (running northwest to southeast in the northeastern portion of the County), San Gregorio Fault (running northwest to southeast along the westernmost part of the County), Monte Vista fault (running northwest to southeast in the north central part of the county); and the Sargent fault and Vergeles fault (running northwest to southeast in the southern portion of the County) (USGS, 2006). The San Andreas and the Hayward-Calaveras fault segments are considered to have the highest potential for causing a significant earthquake in the Bay Area.

• Ground motions within the Loma Prieta earthquake epicenter region were approximately 0.6 g (CGS, 1990). Structures on alluvium or artificial fill are generally more susceptible to damage than structures on bedrock.5 In addition, the Association of Bay Area Governments (ABAG) determined that ground

4 An “active” fault is defined by the State of California as a fault that has had surface displacement within Holocene

time (approximately the last 11,000 years). A “potentially active” fault is defined as a fault that has shown evidence of surface displacement during the Quaternary (last 1.6 million years), unless direct geologic evidence demonstrates inactivity for all of the Holocene or longer. This definition does not, of course, mean that faults lacking evidence of surface displacement are necessarily inactive. “Sufficiently active” is also used to describe a fault if there is some evidence that Holocene displacement occurred on one or more of its segments or branches.

5 Alluvial and alluvium refers to deposits of clay, silt, sand, and gravel deposited by a stream or running water.



shaking in the project area would most likely be felt as violent if a moment magnitude 6.7 earthquake were to occur on the San Andreas fault zone (ABAG, 2006). Underlying geologic materials can intensify ground shaking; areas that are underlain by bedrock tend to experience less ground shaking than those underlain by unconsolidated sediments such as artificial fill. Since the project site is located on Quaternary-age undivided surface deposits, which consist of a mixture of gravel, sand, silt, and clay, as well as artificial fill, it is likely that ground shaking would be intensified during an earthquake event.

• Although some structural damage is typically not avoidable during an earthquake, building codes and construction ordinances have been established to protect against building collapse and major injury during a seismic event. Because the sites are not manned (only for brief periods for maintenance), the potential for human injury is low. The design and construction of the proposed facilities and their foundations, in accordance with current applicable requirements of the Uniform Building Code (UBC), the California Building Code (CBC), and FCC requirements would reduce the potential for injury and structural damage. Therefore, the potential impact from seismic events would be less than significant.

6b) Would the project result in substantial soil erosion or the loss of topsoil?

ECOMM System Category 0, 1 and 2 Sites:

No Impact. No soil disturbance would occur at the Category 0, 1 and 2 sites, so there is no potential for soil erosion or the loss of topsoil.

Category 3 Sites:

Less than Significant Impact. Minimal grading would occur at the 3 sites requiring excavation to construct a new monopole or tower or construction of an equipment shelter. The proposed project and individual sites would be subject to all local ordinances and laws, as well as Best Management Practices and requirements of any Stormwater Pollution Prevention Plans (SWPPP) prepared for a site, in reducing soil erosion, resulting in a less than significant impact.

6c) Would the project 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?


Less than Significant Impact. The individual sites are located on rooftops of existing buildings or existing monopoles and towers, or at existing telecommunications sites that have been previously analyzed for stability and include structures similar to the proposed project. A geotechnical evaluation would be required for each individual site that requires installation of a pole or tower prior to grading of the site. The geotechnical evaluation



would provide recommendations to reduce geological hazards to acceptable levels. Therefore, impacts resulting from unstable ground would be less than significant.

6d) Would the project be located on expansive soil, as defined in the report, Soils of Santa Clara County, creating substantial risks to life or property?


No Impact. The individual Category 0, 1 and 2 sites are located on rooftops of existing buildings or existing monopoles and towers, or at existing telecommunications sites that have been previously analyzed for stability and include structures similar to the proposed project.

Category 3 Sites:

Less than Significant Impact. Expansive soils are often remedied during pre-construction site preparation either through treatment with lime or replacement with engineered fill. A geotechnical evaluation would be required to specify such necessary measures for each individual site that requires installation of a pole or tower prior to grading of the site. Therefore, impacts from expansive soils would be less than significant.

6e) Would the project 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 waste water?


Less than Significant Impact. No septic tanks or alternative wastewater disposal systems are proposed as part of the project (as the project would not generate any wastewater). Furthermore, the proposed project would not disturb soils to the degree that would preclude the placement of septic tanks or wastewater disposal systems in the future, should the intended uses at any of the individual sites change.

6f) Would the project cause substantial compaction or over-covering of soil either on-site or off-site?


No Impact. The proposed project would not result in any ground-disturbing activities on any of the Category 0, 1, or 2 sites. Therefore, it would not involve any construction that would result in a substantial compaction or over-covering of soil, either on-site or off-site and would, thus, result in no impact.

Categories 3 Sites:

Less than Significant Impact. The proposed project would result in minor ground disturbances on three of the four Category 3 sites: Gilroy Reservoir D, Woodland Acres, and Lakeview Court. Ground disturbance at these locations would be limited to



construction of the equipment shelters and/or construction of a pole/tower for microwave antenna mounting. At all sites, construction would be limited to less than one acre and would not require substantial compaction or over-covering of soil either on-site or off-site. For these reasons, this impact would be less than significant.

6g) Would the project cause substantial change in topography or unstable soil conditions from excavation, grading, or fill?


Less than Significant Impact. No substantial excavation, grading, or fill is proposed on a system-wide level or at any of the individual project sites. At Category 3 sites, ground disturbance would be limited to small areas of equipment shelter construction or pole/tower installation, and would not substantially change the topography at those sites, since they are already developed with similar communications-related equipment and some of the proposed installations would occur on rooftops of existing buildings. Furthermore, the proposed project would not increase soil instability at any of the individual sites and this impact would be less than significant.

6h) Involve significant change in surface features (wetland fill, deforestation, or water diversion? (NEPA)


No Impact. There would be no surface feature changes associated with the System or the Category 0, 1 and 2 sites, and because disturbances for the Category 3 sites would be within developed and disturbed communications facilities. Thus, the proposed project would not require any change in surface features such as filling wetlands, extensive tree removal or water diversion.

Sources County of Santa Clara, 1994. Santa Clara County General Plan: 1995-2010. December 20.

Harris Stratex Networks, 2009. Engineering Study Reports for ECOMM Phase II Microwave Radio System Installation, November 25, 2009.





Impact


with Mitigation

Incorporation


Impact No Impact

7. HAZARDS AND HAZARDOUS MATERIALS Would the project:

a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?

b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?

c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 1/4 mile of an existing or proposed school?

d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?

e) For a project located within an airport land use plan referral area or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area?

f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?

g) Expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands?

h) Provide breeding grounds for vectors?

i) Proposed site plan result in a safety hazard (i.e., parking layout, access, closed community, etc.)?

j) Involve construction of a building, road or septic system on a slope of 30% or greater?

k) Involve construction of a roadway greater than 20% slope for a distance of 300' or more?

l) Cause human exposure to levels of radiofrequency radiation in excess of Federal Communications Commission-adopted guidelines? (NEPA)

Discussion The U.S. EPA defines a “hazardous” material as one “which, because of its quantity, concentrations, or physiochemical or infectious properties, may either increase mortality or produce irreversible or incapacitating illness, or pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed” (U.S. Public Health and Welfare Code, §6903). Materials and wastes that exhibit hazardous properties require special handling and management. Their treatment, storage,



transport, and disposal are highly regulated by federal, State, and local governments, which minimize the risk to the public presented by these potential hazards.

The federal hazardous waste laws are generally known as the Resource Conservation and Recovery Act (RCRA). These laws provide for the “cradle to grave” regulation of hazardous wastes. Any business, institution, or other entity that uses hazardous materials and 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 EPA has primary responsibility for implementing RCRA, but California received authorization to implement RCRA in August 1992. The California Environmental Protection Agency (Cal-EPA) Department of Toxic Substances Control oversees implementation of RCRA, and implements and enforces California’s own hazardous waste laws. Chapter 6.95, Section 25503(a) of the California Health and Safety Code and Title 19 of the California Code of Regulations §2729, et seq., require any business that handles a hazardous material or mixture containing a hazardous material in reportable quantities to establish and implement a Hazardous Materials Business Plan for emergency response to a release or threatened release of a hazardous material. The State’s minimum reportable quantities are 500 pounds for a solid, 55 gallons for a liquid, and 200 cubic feet for a gas at standard temperature and pressure.

Hazards from exposure to radio frequency (RF) radiation is another possible public health and safety effect at communications sites. RF is defined as a type of electromagnetic energy that includes radio waves and microwaves – two forms of electromagnetic waves that are used for telecommunications and broadcasting. In general, electromagnetic energy, which manifests itself in the form of waves and particles called photons, is a ubiquitous phenomenon in our daily lives. The familiar manifestations, ranging from the longer waves and lower frequencies to the shorter waves and higher frequencies, include AM radio, FM radio, microwaves, infrared, visible light, ultraviolet, x-rays and gamma rays. The higher the frequency of the electromagnetic waves, the greater the energy associated with them.

Microwaves are specific bands of radio waves with frequencies that range upward from several hundred megahertz (MHz) to several gigahertz (GHz). Microwaves are widely used for telecommunications such as for cellular radio, personal communications services, microwave point-to-point communication, transmission links between ground stations and orbiting satellites, and in certain broadcasting operations such as studio-to-transmitter and electronic news gathering radio links. One familiar and widespread use of microwave energy is in household microwave ovens, which operate at a frequency of 2.45 GHz. Another is for WI-FI communications; types 802.11b and 802.11g use 2.4 GHz band, type 802.11a uses 5 GHz, and type 802.11n uses 2.4 GHz and/or 5 GHz. Bluetooth devices, baby monitors and cordless telephones also use the 2.4 GHz band.

Point-to-point microwave antennas, such as those proposed for ECOMM, transmit and receive microwave signals across relatively short distances (from a few tenths of a mile to 30 miles or more). These antennas are typically rectangular or circular in shape and are mounted on a supporting tower, on rooftops, sides of buildings or on similar structures that provide solid



support for the antennas and in locations with clear and unobstructed line-of-sight paths between both ends of a transmission path or link. Solid support is required to maintain the precise alignment of the microwave antenna.

All of the existing project communication sites include associated radio units, switching mechanisms and batteries. The proposed ECOMM microwave radios and antennas would operate at frequencies of 6.7 GHz, 11.2 GHz and 18.7 GHz. All electronic equipment would be housed either in a room inside an adjacent building or in a fully enclosed and secured equipment shelter constructed on a concrete pad formed without a drain and with a raised perimeter to contain spilled fluids. Electronic equipment spaces would be air-conditioned. Sites with equipment shelters do have, or would have, a generator and either a propane tank or diesel tank to power the generator.

Comments 7a) Would the project create a significant hazard to the public or the environment

through the routine transport, use, or disposal of hazardous materials?

ECOMM System:

No Impact. There is no aspect of the ECOMM system operations that could create a significant hazard to the public or to the environment.

All Sites:

Less than Significant Impact. Each project site includes one or more batteries that are similar in size and electrical capacity to typical automobile batteries. These batteries are housed in the equipment racks inside the equipment rooms or shelters (See Figure 3, Typical ECOMM Equipment Rack Configuration). These batteries power the communications equipment when the utility electrical power fails. Small, dry batteries are also used at the sites to power other equipment; these are handled and disposed of as Universal Waste. Isolated communication sites also have an emergency generator and fuel to power the generator.

Propane, if present at a site, is used to power the back-up emergency generator and is stored in a standard propane pressure tank. Similarly, if diesel is present at a site, it is stored in a small secure tank. Propane and/or diesel are trucked into the site to replenish the tanks as the fuel is consumed. Both the larger and the small batteries are transported for periodic replacement. The storage and transportation of these hazardous materials are fully regulated by state and federal law. However, to further reduce the potential for exposure of hazardous materials during transport, use, or disposal, the project construction contractor would comply with Best Management Practices, similar to the following (Harris Stratex, 2007b):

The project’s construction contractor qualifies as a Conditionally Exempt Small Quantity Generator (CESQG), which allows the project to participate in Santa



Clara County and surrounding Counties CESQG Disposal Program to properly dispose and/or recycle the materials involved with the decommissioning of wireless telecommunication structures. The ECOMM system construction contractor would follow all federal, state and local regulations with regards to the disposal of all materials involved with the decommission of the wireless telecommunication structures for each affected jurisdiction. Therefore, impacts resulting in significant hazards to the public or environment through transport or disposal would be less than significant. Handling of Universal Waste (Batteries) / Management of Universal Waste: A small quantity handler of universal waste shall manage universal waste batteries in a way that prevents releases of any universal waste or component of universal waste to the environment as follows: 1) A small quantity handler of universal waste shall contain any universal waste

battery that shows evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions in a container. The container shall be closed, structurally sound, compatible with contents of the battery and shall lack evidence, spillage, or damage that could cause leakage under reasonable foreseeable conditions.

2) A small quantity handler of universal waste may conduct the following activities as long as the casing of each individual battery cell is not breached and remains intact and closed, (except that cells may be opened to remove electrolyte but shall be immediately closed after removal):

a. Sorting batteries by type; b. Mixing battery types in one container; c. Discharging batteries so as to remove the electric charge; d. Regenerating used batteries; e. Disassembling batteries or battery packs into individual batteries or

cells; f. Removing batteries from consumer products; or g. Removing electrolyte from batteries

3) A small quantity handler of universal waste who removes electrolyte from batteries, or who generates other solid waste, (e.g. battery pack materials, discarded consumer products) as a result of the activities listed above, shall determine whether the electrolyte and/or other solid waste exhibit a characteristic of hazardous waste.

h. If the electrolyte and/or other solid waste exhibits a characteristic of hazardous waste, it is subject to all applicable requirements. The handler is considered the generator of the hazardous electrolyte and/or other waste and is subject to follow the applicable requirements set forth for generators of hazardous waste;



i. If the electrolyte or other solid waste is not hazardous, the handler may manage the waste in any way that is in compliance with applicable federal, state or local solid waste regulations.

Labeling/Marking of Universal Waste Batteries: A small quantity handler of universal waste shall label or mark the universal waste to identify the type of universal waste as specified following:

Universal waste batteries, (i.e. each battery) or a container in which the batteries are contained, shall be labeled or marked clearly with any one of the following phrases: “Universal Waste – Battery(ies)”, or “Waste Battery(ies)”, or “Used Battery(ies)”

Employee Training: A small quantity handler of universal waste shall inform all employees who handle or have responsibility for managing universal waste. The information shall describe proper handling and emergency procedures appropriate to the type(s) of universal waste handled at the facility. Response to Releases: A small quantity handler of universal waste shall immediately contain all releases of universal wastes and other residues from universal wastes. A small quantity handler of universal waste shall determine whether any material resulting from the release is hazardous waste, and if so, shall manage the hazardous waste in compliance with all applicable requirements. The handler is considered the generator of the material resulting from the release, and shall manage it according to the applicable requirements set forth for the generators of hazardous waste. Waste consisting of only residues of leaking, broken, or otherwise damaged universal waste may be managed as universal waste provided that the leaking, broken or otherwise damaged universal waste is repackaged according to Item 1, above, of the handling universal waste battery section. Off-Site Shipments: A small quantity handler of universal waste is prohibited from sending or taking universal waste to a place other then another universal waste handler, a destination facility, or a foreign destination. If a small quantity handler of universal waste self-transports universal waste off-site, the handler becomes a universal waste transporter for those self-transportation activities and shall comply with the transporter requirements mentioned in this policy while transporting the universal waste.



If a universal waste being offered for off-site transportation meets the definition of hazardous materials under 49 CFR parts 171 through 180, a small quantity handler of universal waste shall package, label, mark and placard the shipment, and prepare the proper shipping papers in accordance with the applicable Department of Transportation regulations under 49 CFR parts 172 through 180. Prior to sending a shipment of universal waste to another universal waste handler, the originating handler shall ensure that the receiving handler agrees to receive the shipment. If a small quantity handler of universal waste sends a shipment of universal waste to another handler or a destination facility and the shipment is rejected by the receiving handler or destination facility the original handler shall either: 1) Receive the waste back when notified that the shipment has been rejected; or 2) Agree with the receiving handler on a destination facility to which the shipment would be sent. Tracking Universal Waste Shipments: A small quantity handler of universal waste shall keep a record of each shipment of universal waste sent from the handler to other facilities. The record may take the form of a log, invoice, manifest, bill of lading or other shipping document. The record of each shipment of universal waste sent shall include the following information: 1) The name and address of the universal waste handler, destination facility, or foreign destination to whom the universal waste was sent; 2) The quantity of each type of universal waste sent, (e.g. batteries, thermostats, lamps mercury switches, etc.); and 3) The date the shipment of universal waste left the facility. A small quantity handler of universal waste shall retain the records described above for at least three years from the date of shipment of universal waste left the facility. Prohibitions: A small quantity handler of universal waste is: 1) Prohibited from disposing of universal waste; and 2) Prohibited from diluting or treating universal waste, except by responding to releases. Notification: A small quantity handler of universal waste is not required to notify the Department or the US EPA of universal waste handling activities except for small quantity universal waste electronic device handlers. Transportation of Universal Waste (Batteries) / Management of Universal Waste: A universal waste transporter shall comply with all applicable US Department of Transportation regulations under 49 CFR part 171 through 180 for transport of any universal waste that meets the definition of hazardous material in 49 CFR 171.8. For purposes of the DOT regulations, a material is considered a hazardous waste if it is subject to the Hazardous Waste Manifest Requirements of the US



Environmental Protection Agency specified in 40 CFR Part 262. Because universal waste does not require a hazardous waste manifest, it is not required a hazardous waste under the DOT regulations. Some universal waste materials are regulated by the DOT as hazardous materials because they meet the criteria for one or more hazard classes specified in 49 CFR 173.2. As universal waste shipments do not require a manifest under chapter 12, (standards applicable to generators of hazardous waste) and are conditionally exempt from classification as a hazardous waste, they may not be described by the DOT proper shipping name “hazardous waste”. Storage Time Limits: A universal waste transporter or a CRT material transporter may only store the universal waste or CRT materials at a universal waste transfer facility for ten days or less in an area zoned “industrial” and for six days or less in all other areas. If a universal waste transporter or a CRT materials transporter stores universal waste or CRT material for more than ten days in an area zoned “industrial” or for more than six days in any other area, the transporter becomes a universal waste handler or a CRT material handler and shall comply with the applicable requirements. Response to Releases: A universal waste transporter shall immediately contain all releases of universal wastes and other residues from universal wastes. A universal waste transporter shall determine whether any material resulting from the release is hazardous waste, and if so, it is subject to all applicable requirements. If the waste is determined to be hazardous waste, the transporter is subject to the standards applicable to generators of hazardous waste. Waste consisting only of residues of leaking, broken, or otherwise damaged universal waste may be managed as universal waste provided that the leaking, broken, or otherwise damaged universal waste is repackaged to the standards mentioned in number 1 of the section for handling universal waste, (batteries) / management of universal waste. Off-Site Shipments: A universal waste transporter is prohibited from transporting the universal waste to a place other than a universal waste handler, destination facility, or a foreign destination. If the universal waste being shipped off-site meets the DOT’s definition of hazardous materials under 49 CFR section 171.8, the shipment shall be properly described on a shipping paper in accordance with the applicable DOT regulations under 49 CFR part 172.



7b) Would the project 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?

ECOMM System:

No Impact. There is no aspect of the ECOMM system operations that could create a hazard to the public or to the environment through upset or accident.

All Sites:

Less than Significant Impact. The ECOMM system and individual sites would generate hazardous waste by the use of batteries and accident or upset scenarios could involve propane or diesel at each of the isolated sites. Therefore, there could be upset or accident conditions involving the release of hazardous materials, either at the site or during transport. Upset or accident involving propane could pose risks of fire or explosion, while diesel could involve a minor risk of fire. Sites that use propane are isolated and would not pose a risk to the public. Sites close to dwellings use diesel but are expected to pose little risk. Sites in existing buildings usually rely on the building’s emergency power system and do not pose accident or upset risks.

The total quantities of hazardous materials at any single communication site are typically small, and the individual sites are isolated from the public, either by physical isolation of the site itself or by being housed in secure shelters or interior equipment rooms of public buildings. In the event of a fire or other upset condition, the risk of a substantive release of hazardous materials is negligible.

To reduce or avoid impacts from accidental release of hazardous materials, the project construction contractor would comply with the following Best Management Practices (Harris Stratex, 2009):

Materials Storage

• Prevent, reduce or eliminate the discharge of pollutants from material storage to the stormwater system or watercourses by minimizing the storage of hazardous materials and universal waste on site, storing materials in a designated area, installing secondary containment and training employees and subcontractors;

• Temporary storage areas shall be located away from vehicular traffic; • Construction site areas shall be designated for material delivery, pick-up and

storage; • Material Safety Data Sheets (MSDS) shall be supplied for all stored materials; • During the rainy season, consider storing materials in a covered area. If it is not

feasible to store in a covered area measures shall be taken to cover the material with a sufficient tarp and secured as to prevent contact with rain;



• Do not store chemicals, drums, or bagged materials directly on the ground. Place these items on a pallet, and when possible a secondary containment;

• Chemicals shall be kept in their original labeled containers; • Employees and subcontractors shall be trained on the proper material delivery

and storage practices; • Employees trained in emergency spill cleanup procedures must be present

when dangerous materials or liquid chemicals are transported; • Throughout the rainy season, each temporary containment facility shall be

covered during non-working days, prior to and during rain events; Spill Clean-Up: • Contain and clean up any spill immediately; • Properly remove and dispose of any hazardous materials or universal waste or

contaminated soil if significant residual materials remain on the ground after construction is complete.

7c) Would the project emit hazardous emissions or handle hazardous or acutely

hazardous materials, substances, or waste within 1/4 mile of an existing or proposed school?


Less than Significant Impact. No acutely hazardous materials would be present at any site. Other hazardous materials are in common forms, such as batteries, and in small quantities that would not result in emissions that would be hazardous off-site.

There are no existing or proposed schools within a one-quarter mile radius of the Category 3 sites (Lakeview Court, Woodland Acres, Gilroy City Hall Annex or Gilroy Reservoir D).

7d) Would the project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?

ECOMM System and Category 0, 1, and 2 Sites:

No Impact. All project actions would occur at interior locations for Category 0 sites. Although exterior actions are involved at Category 1 and Category 2 sites, there would be no soil or groundwater disturbance, and therefore no impact.

Category 3 Sites:

Less than Significant Impact. A hazardous materials search was conducted using the State Water Quality Control Board GeoTracker website to search for underground storage tank



sites, hazardous materials leaks and spills incidents, and groundwater concerns. The Lakeview Court, Woodland Acres and Gilroy Reservoir D sites were not identified on any of the lists that were searched and there were no other such sites within 1000 feet.

A completed and closed cleanup of a LUST site is recorded on Gilroy City property at the New Gilroy Police Department (T0608502197), 7350 Rosanna Street (RB Case #: 599); this site is adjacent to or may be at the Gilroy City Hall Annex site. However, there would be no ground disturbance at the Gilroy City Hall Annex site, so there would be no impact.

Construction at each of the three sites that include trenching would disturb soil or groundwater that may have been previously contaminated. Although it is not expected that impacted groundwater or soil would be encountered due to the minimal disturbance area and shallow grading that would occur, Mitigation Measure 7-1 would be implemented in order to further reduce or minimize impacts to construction workers exposed to such materials.

Mitigation Measure 7-1 (at Gilroy Reservoir D, Woodland Acres, and Lakeview Court sites only): During construction, the excavation or exposure of soil in areas suspected of containing soil or groundwater contamination shall be monitored by the contractor and overseen by the authorized personnel of the local jurisdiction for subsurface contamination in compliance with the California Department of Occupational Safety and Health Administration (Cal/OSHA). The monitoring, at a minimum, would include visual observation by personnel with appropriate hazardous materials training. The ECOMM system construction contractor and the local jurisdiction shall follow all federal, state and local regulations with regards to the disposal of all materials involved with the decommission of the wireless telecommunication structures for each affected jurisdiction. Therefore, impacts resulting in significant hazards to the public or environment through transport or disposal would be less than significant.

7e) For a project located within an airport land use plan referral area or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area?

ECOMM System:

No Impact. No aspect of ECOMM system operations could result in a safety hazard for people residing or working in the project area.

All Sites:

Less than Significant Impact. The ECOMM System would have no adverse affect on any airport land use plan. All microwave antennas installed at the sites are required to comply with the standards of the Federal Aviation Administration (FAA) for federal aviation safety requirements.



No project action would install antennas higher than the tops of presently existing towers. Of the new poles to be constructed, all would be lower than existing structures or antennas that exist nearby, and therefore not present a new physical hazard.

Overall, none of the noise or safety policies in the ALUC's Land Use Plan would apply. Also, because all sites are un-manned, the impact of Single Event Noise Level on persons is minimal to non-existent. Therefore, impacts associated with airports would be less than significant.

7f) Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?


No Impact. The ECOMM System and the individual sites would not interfere with an adopted emergency response plan or evacuation plan. In fact, the system and the sites would be part of the emergency response planning in that it would allow several jurisdictions to quickly communicate with each other in the event of a catastrophic event, such as an earthquake or a large fire.

7g) Would the project expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wild lands are adjacent to urbanized areas or where residences are intermixed with wild lands?


No Impact. Although some of the sites are located in rural and wild areas, maintenance of the sites is currently conducted on a regular basis, and any hazardous vegetation is removed. Therefore, the project would not result in impacts with regards to propagating wildland fires.

7h) Would the project provide breeding grounds for vectors?


No Impact. Site construction for the three sites that involve ground disturbance would involve cleanup to prevent ponding or retention of water on the small area of the site that would be disturbed.

7i) Would the project’s proposed site plan result in a safety hazard (i.e., parking layout, access, closed community, etc.)?


No Impact. Communication sites are unmanned, with no need for public access, and are designed to operate autonomously with high reliability, so traffic is infrequent and no safety hazard could result. Therefore, the project would not result in a safety hazard.



7j) Would the project involve construction of a building, road or septic system on a slope of 30% or greater?


No Impact. Although some of the sites would be located on hilltops in rural areas, all sites are presently graded. No roads would be constructed or re-graded. Since communication sites are unmanned, no septic systems would be constructed. Therefore, the project would not result in impacts with regards to construction on slopes of 30% or greater.

7k) Would the project involve construction of a roadway greater than 20% slope for a distance of 300' or more?


No Impact. Although some sites would be located on hilltops in rural areas, all sites are presently graded. No roads would be constructed or re-graded. Therefore, the project would not result in impacts from construction of a roadway on slopes of 20% or greater.

7l) Would the project cause human exposure to levels of radiofrequency radiation in excess of Federal Communications Commission-adopted guidelines? (NEPA)


Less than Significant Impact. The Federal Communications Commission (FCC) governs the requirements for radio frequency (RF) exposure guidelines. Under the National Environmental Policy Act of 1969 (NEPA), the FCC has certain responsibilities to consider whether its actions would "significantly affect the quality of the human environment." Therefore, FCC approval and licensing of transmitters and facilities must be evaluated for significant impacts on the environment. Human exposure to RF radiation emitted by FCC-regulated transmitters is one of several factors that must be considered in such environmental evaluations.

The RF signals from point-to-point antennas, such as the microwave dish antennas proposed in the ECOMM system, travel in a directed beam from a focused transmitting antenna to a directional receiving antenna, and dispersion of microwave energy outside of the relatively narrow focused beam is minimal or insignificant. In addition, these antennas transmit using very low power levels, usually on the order of tens of watts or less. Measurements have shown that ground-level power densities due to microwave directional antennas are normally a thousand times or more below recommended safety limits. Moreover, the ECOMM microwave tower sites are designed to be inaccessible to the general public and the ECOMM microwave paths are intended to be well clear of obstacles, in order to insure the high operating reliability of the system. These design measures provide an added margin of safety for the public, since significant RF exposures from these microwave antennas could only occur if an individual were to stand directly in front of and very close to an antenna for a long time (FCC, 1999; 1997).



Pursuant to Title 47 CFR Part 1, Section 1.1310 of the FCC Guidelines, all microwave antennas and equipment installed on the site are required to comply with the maximum permissible exposure limits for human health and safety. In order for the sites to obtain operating licenses from the FCC, RF emissions must not exceed these established standards. The FCC maximum exposure limits are shown below:

FCC MAXIMUM EXPOSURE LIMITS

Frequency Range (MHz)

Electric Field Strength (V/m)

Magnetic Field Strength (A/m)

Power Density (mW/cm2)

Averaging Time (minutes)

(A) Limits for Occupational/Controlled Exposures 0.3 to 3.0 614 1.63 *(100) 6 3.0 to 30 1842/f 4.89/f *(900/f2) 6 30 to 300 61.4 0.163 1.0 6 300 to 1,500 -- -- f/300 6 1,500 to 100,000 -- -- 5 6 (B) Limits for General Population/Uncontrolled Exposures 0.3 to 1.34 614 1.63 *(100) 30 1.34 to 30 824/f 2.19/f *(180/f2) 30 30 to 300 27.5 0.073 0.2 30 300 to 1,500 -- -- f/1500 30 1,500 to 100,000 -- -- 1.0 30

SOURCE: FCC Guidelines Title 47 CFR, Part 1, Section 1.1310 (August 1996)

f = frequency in MHz * = Plane-wave equivalent power density A. Occupational/controlled limits apply in situations in which persons are exposed as a consequence of their employment

provided those persons are fully aware of the potential for exposure and can exercise control over their exposure. Limits for occupational/controlled exposure also apply in situations when an individual is transient through a location where occupational/controlled limits apply provided he or she is made aware of the potential for exposure.

B. General population/uncontrolled exposures apply in situations in which the general public may be exposed, or in which persons that are exposed as a consequence of their employment may not be fully aware of the potential for exposure or can not exercise control over their exposure.

The FCC requires the proposed ECOMM microwave transmitters to be "Type Accepted" before they may be offered for sale commercially. The type acceptance process verifies the transmitter's signal would neither interfere with other adjacent users nor exceed the safety standards called out by the FCC's Office of Engineering Technology (OET). When the frequency coordination process was performed by the project engineers, the data sheets that are part of the Engineering Study show the transmitter power output, the antenna gains, and the total radiated power of that site's installation. These calculations are required to obtain the FCC license for the frequency channel.

The proposed ECOMM microwave radios and antennas would operate at frequencies of 6 GHz (6,000 MHz), 11 GHz (11,000 MHz) and 18 GHz (18,000 MHz), all of which are within the highest frequency range established for maximum exposure limits shown above. As such, the exposure limit for a member of the general public would be 1.0 mW/cm2 (1/1,000 of a watt on each square centimeter of area) over an averaging time of 30 minutes. Given the power of the radios and the sizes of the microwave antennas,



direct exposure to the focused beam of a dish antenna would be close to or might exceed the FCC criterion for public exposure. However, as noted above, the design of the system, and especially the locations of the antennas on towers in secured sites, ensures that public exposure does not occur, because it excludes the public from all areas where direct exposure could occur.

Therefore, impacts to human health and safety resulting from RF exposure from the ECOMM project would be less than significant.

Sources Code of Federal Regulations (CFR), Title 47, Part 1, Subpart I, sections 1.1301 to 1.1319.

County of Santa Clara Airport Land Use Commission (ALUC), 2007. Land use review conducted by Mr. Mark Connolly, Planner III. August 16.

FCC, 1997. OET Bulletin 65: Evaluating Compliance with FCC-Specified Guidelines for Human Exposure to Radiofrequency Radiation. Edition 97-01, August.


Harris Stratex, 2007a. Environmental Control Best Management Policies. Revision 1. August.

Harris Stratex, 2007b. Universal Waste Management Policies. August.





Impact


with Mitigation

Incorporation


Impact No Impact

8. HYDROLOGY AND WATER QUALITY—Would the project:

a) Violate any water quality standards or waste discharge requirements?

b) Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted)?

c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion of siltation on- or off-site?

d) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site? (Note policy regarding flood retention in watercourse and restoration of riparian vegetation for West Branch of the Llagas.)

e) Create or contribute increased impervious surfaces and associated runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?

f) Otherwise substantially degrade water quality?

g) Place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map?

h) Place within a 100-year flood hazard area structures which would impede or redirect flood flows?

i) Expose people or structures to a significant risk of loss, injury or death involving flooding, including flooding as a result of the failure of a levee or dam?

j) Be located in an area of special water quality concern (e.g., Los Gatos or Guadalupe Watershed)?

k) Be located in an area known to have high levels of nitrates in well water?

l) Result in a septic field being constructed on soil where a high water table extends close to the natural land surface?

m) Result in a septic field being located within 50 feet of a drainage swale; 100 feet of any well, water course or water body or 200 feet of a reservoir at capacity?

n) Conflict with Water Collaborative Guidelines and Standards for Land Uses Near Streams?



Comments 8a) Would the project violate any water quality standards or waste discharge

requirements?


Less than Significant Impact. The proposed project or any of the individual sites would not affect water quality or require discharge into water streams. None of the sites are located adjacent to a waterway. In addition, the following Best Management Practices would be incorporated into the proposed project to reduce or eliminate discharge and runoff during construction and installation of project components (Jones, 2009):

Erosion Control:

• Erosion control is any source control practice that protects the soil surface and prevents soil particles from being detached by rainfall, flowing water or wind. Erosion control is also referred to as soil stabilization.

• All in active soil-disturbed areas on the project site, and most active areas prior to the onset of rain, must be protected from erosion.

Scheduling:

• Monitor the weather forecast for rainfall;

• When rainfall is predicted, adjust the construction schedule to allow the implementation of soil stabilization and sediment treatment controls on all disturbed areas prior to rain;

Preservation of Existing Vegetation:

• Mark areas to be preserved with temporary fencing. Include sufficient setback to protect roots:

- Orange colored plastic mesh fencing works well;

- Use appropriate fence posts and adequate post spacing and depth to completely support the fence in an upright position.

• Locate temporary roadways, stockpiles, and layout areas to avoid stands of trees, shrubs and grass;

• Maintain existing irrigation systems where feasible. Temporary irrigation may be required;

• Instruct employees and subcontractors to honor protective devices. Prohibit heavy equipment, vehicular traffic, or storage of construction materials within the protected area;

• Retain protective measures until all other construction activity is complete to avoid damage during site clean up and stabilization.



Sediment Control: Sediment control is any practice that traps soil particles after they have been detached and moved by rain, flowing water or wind. Sediment control measures are usually passive systems that rely on filtering or settling the particles out of the water or wind that is transporting them.

Silt Fence: • A silt fence shall be made from a filter fabric that has been entrenched,

attached to supporting poles, and shall sometimes be backed by a plastic or wire mesh for support;

• A silt fence shall detain sediment-laden water, promoting sedimentation behind the fence;

• Suitable silt fence applications shall include: - Along the perimeter of a project; - Below the toe or down slope of exposed and erodible slopes; - Along streams and channels; - Along temporary spoil areas and stockpiles; - Below other small cleared areas.

• Use silt fences principally in areas where sheet flow occurs; • Don’t use in streams, channels, or anywhere flow is concentrated. Don’t use

silt fences to divert flow; • Don’t use below slopes subject to creep, slumping or landslides; • Select filter fabric that retains 85% of soil by weight, based on sieve analysis,

but that is not finer than an equivalent opening size of 70; • Install along a level contour, so water does not pond more than 1.5ft at any

point along the silt fence; • The maximum length of slope draining to any point along the silt fence should

be 200ft or less; • Silt fences should remain in place until the disturbed area is permanently

stabilized.

Fiber Rolls: • A fiber roll shall consist of straw, flax or other similar materials bound into a

tight tubular roll. When fiber rolls are placed at the toe and on the face of slopes, they intercept runoff, reduce its flow velocity, release the runoff as sheet flow, and provide removal of sediment from the runoff. Suitable applications for fiber rolls include the following: - Along the toe, top, face and at grade breaks of exposed and erodible

slopes to shorten slope length and spread runoff as sheet flow; - At the end of a downward slope where it transitions to a steeper slope; - Along the perimeter of a project;



- Down slope of exposed soil areas; - Around temporary stockpiles.

• Turn the ends of the fiber roll up slope to prevent runoff from going around the roll.

• Locate fiber rolls on level contours spaced as follows: - Slope inclination of 4:1 (H:V) or flatter: Fiber rolls shall be placed at a

maximum interval of 20 ft; - Slope inclination of 4:1 to 2:1 (H:V): Fiber rolls shall be placed at a

maximum interval of 15ft. (a closer spacing is more effective); - Slope inclination of 2:1 (H:V) or greater: Fiber rolls shall be placed at a

maximum interval of 10ft. (a closer spacing is more effective). • Stake fiber rolls into a 2 to 4 in deep trench with a width equal to the diameter

of the fiber roll.

Gravel Bags: • A gravel bag berm is a series of gravel-filled bags placed on a level contour to

intercept sheet flow. Gravel bags pond sheet flow runoff, allowing sediment to settle out, and release runoff slowly as sheet flows, preventing erosion. Suitable applications for gravel bag berms are as follows: - As a linear sediment control measure; - Below the toe of slopes and erodible slopes; - As sediment traps at culvert/pipe outlets; - Below other small cleared areas; - Along the perimeter of the site; - Down slope of exposed soil areas; - Around temporary stockpiles and spoil areas; - Parallel to a roadway to keep sediment off paved areas. - At the top of slopes to divert runoff away from disturbed slopes; - As check dams across mildly sloped construction roads;

• Turn the ends of the gravel bag barriers up slope to prevent runoff from going around the berm;

• Allow sufficient space up slope from the gravel bag berm to allow ponding, and to provide room for sediment storage;

• Butt ends of bags tightly; • On multiple row, or multiple layer construction, overlap butt joints of adjacent

row and row beneath; • Use a pyramid approach when stacking bags. • Materials shall consist of the following:



- Bag Material: Bags shall be woven polypropylene, polyethylene, or polyamide fabric or burlap, minimum unit weight of 4 ounces/yd2, Mullen burst strength exceeding 300 lbs/in2;

- Bag Size: Each gravel filled bag shall have a length of 18 inches, width of 12 inches, thickness of 3 inches and mass of approximately 33 lbs;

- Fill Material: Fill material shall be 0.5 to 1 inch. Class 2 aggregate base, clean and free from clay, organic matter and other deleterious material, or other suitable open graded, non-cohesive, porous gravel.

Waste Management and Materials Pollution Control: Waste management and materials pollution control BMPs are source control BMPs that prevent pollution by limiting or reducing potential pollutants at their source before they come into contact with stormwater. Materials pollution control consists of implementing BMPs in the handling, storing and use of construction materials.

Vehicle Equipment and Fueling: • Vehicle equipment fueling procedures and practices are designed to prevent

fuel spills and leaks, and reduce or eliminate contamination of stormwater; • These procedures are suitable on all construction sites where vehicle and

equipment fueling takes place; • Use off site fueling stations as much as possible. These businesses are better

equipped to handle fuel and spills properly; • Discourage “topping off” of fuel tanks; • Absorbent spill cleanup materials and spill kits shall be available in fueling

areas and on fueling trucks, and shall be disposed of properly after use; • Drip pans or absorbent pads shall be used during vehicle and equipment

fueling; • Use absorbent materials on spills. Do not hose down or bury the spill. Remove

the absorbent materials promptly and dispose of properly; • Train employees and subcontractors in proper fueling and cleanup procedures;

Material Storage: • Prevent, reduce or eliminate the discharge of pollutants from material storage

to the stormwater system or watercourses by minimizing the storage of hazardous materials and universal waste on site, storing materials in a designated area, installing secondary containment and training employees and subcontractors;

• Temporary storage area shall be located away from vehicular traffic; • Construction site areas shall be designated for material delivery, pick-up and

storage; • Material Safety Data Sheets (MSDS) shall be supplied for all stored materials; • During the rainy season, consider storing materials in a covered area. If it is not

feasible to store in a covered area measures shall be taken to cover the material with a sufficient tarp and secured as to prevent contact with rain;



• Do not store chemicals, drums, or bagged materials directly on the ground. Place these items on a pallet, and when possible a secondary containment;

• Chemicals shall be kept in their original labeled containers; • Employees and subcontractors shall be trained on the proper material delivery

and storage practices; • Employees trained in emergency spill cleanup procedures must be present

when dangerous materials or liquid chemicals are transported; • Throughout the rainy season, each temporary containment facility shall be

covered during non-working days, prior to and during rain events;

Spill Clean-Up: • Contain and clean up any spill immediately; • Properly remove and dispose of any hazardous materials or universal waste or

contaminated soil if significant residual materials remain on the ground after construction is complete.

With implementation of the above BMPs, impacts to water quality would be less than significant.

8b) Would the project substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted)?


No Impact. Neither the proposed overall project nor the individual sites would require the use of any groundwater nor would it interfere with ground water recharge or the production rate of pre-existing nearby wells.

8c) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion of siltation on- or off-site?


No Impact. The project would not alter the course of any streams or rivers. Minimal grading would occur at sites requiring installation of a monopole/tower or equipment shelters (Category 3 sites, with the exception of Gilroy City Hall Annex, where no grading would occur). Such grading would not result in substantial erosion of siltation on or off site. Construction activities would comply with BMPs for erosion control as described in Paragraph 8a), above, and all local ordinances that would be required as conditions of approval to the project to minimize or avoid such impacts.



8d) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site?


No Impact. The project system and Category 0, 1 and 2 sites would not increase stormwater runoff, nor alter the course of any streams or rivers as there would be no grading or additional impervious surfaces.

Category 3 Sites:

Less than Significant Impact. At three of the Category 3 sites, minimal grading would occur to accommodate the installation of a new monopole/tower, a new equipment shelter or a replacement shelter. A summary of impervious surfaces that would be added by the proposed project at three of the Category 3 sites are shown in Table 8-1.

TABLE 8-1 SUMMARY OF INCREASE IN IMPERVIOUS SURFACE AREA

Site Name Structure Surface Area Increased

Impervious Surface (square feet)

Gilroy Reservoir D New monopole 3 foot diameter at base 3

Woodland Acres New monopole Equipment Shelter pad

2 foot diameter at base 117 square feet for equipment shelter pad (approx.)

6 117

Lakeview Court New monopole New equipment shelter on existing shelter footprint

3 foot diameter at base (approx.) 0

3

Gilroy City Hall Annex Roof-mounted pole 0 0

Total Increase in Impervious Surface Area in feet 129 SOURCE: Harris Stratex Networks, 2009.

The total additional impervious surface area that would occur with construction of the proposed project would be approximately 129 feet, which is not a substantial increase over existing conditions. Therefore, impacts would be less than significant.

8e) Would the project create or contribute increased impervious surfaces and associated runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?




Less than Significant Impact. See Paragraph 8d), above.

8f) Would the project otherwise substantially degrade water quality?


Less than Significant Impact. As described above (Paragraphs 8a through 8e), through the implementation of BMPs and the fact that most of the project sites would not alter drainage patterns or affect water sources in any way, the proposed project would not substantially degrade water quality within the ECOMM system area or at individual sites below existing standards.

8g) Would the project place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map?


No Impact. The proposed project does not include the construction or placement of housing at any of the sites. In addition, none of the individual sites are located within a 100-year flood hazard area or floodplain.

8h) Would the project place within a 100-year flood hazard area which would impede or redirect flood flows?


No Impact. A majority of the proposed project would be installed on existing structures such as rooftops or monopoles or lattice towers. The individual sites that require construction of a monopole or lattice tower are not located within a 100-year flood hazard area or floodplain.

8i) Would the project 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?


Less than Significant Impact. The individual sites that are located on higher elevations such as hilltops would not be affected by dam failures. These sites include: Pacheco Peak, El Toro, Woodland Acres, Lakeview Court, Cadwallader, Carol Drive, Coyote Peak, Frazier Peak, Eagle Rock, Holiday Lake, and Rodoni. The other sites could be subject to flooding from dam failure due to their location within the valley floor, but the likelihood is remote. These individual sites are either located on rooftops of multi-story buildings (from 1 to 15 stories or more) or located on monopoles that are 10 feet tall or higher.



Therefore, flooding impacts to the project due to dam failure would be less than significant.

8j) Would the project be located in an area of special water quality concern (e.g., Los Gatos or Guadalupe Watershed)?


Less than Significant Impact. Several individual project sites, including Los Gatos Police Department, Stickney, and Good Samaritan Hospital, are located within the Guadalupe Watershed. However, as discussed above, the proposed project would not deplete groundwater supplies (8b), would not alter drainage patterns on the site or area or increase the rate or amount of surface runoff (8c and 8d), and would not otherwise degrade water quality (8f). Therefore, the project would not adversely affect the Guadalupe Watershed or any other area with special water quality concerns. This impact would, thus, be less than significant.

8k) Would the project be located in an area known to have high levels of nitrates in well water?


No Impact. The proposed project would replace radio equipment or microwave antennas, install new antennas on existing poles/towers or construct new poles/towers and/or equipment shelters. The individual project sites would be accessed by authorized personnel on an intermittent basis for routine maintenance and no connections to the existing potable water systems would be established. Although no testing was performed to analyze the nitrate levels in the water in the project areas, since the proposed project would not generate an increase in water demand or require access to local water supplies, this impact is considered less than significant.

8l) Would the project result in a septic field being constructed on soil where a high water table extends close to the natural land surface?


No Impact. The proposed project would replace radio equipment or microwave antennas, install new antennas on existing poles/towers or construct new poles/towers and/or equipment shelters. No construction of a septic field is proposed and, therefore, no impact would occur related to contamination of the water table from septic fields.

8m) Would the project result in a septic field being located within 50 feet of a drainage swale; 100 feet of any well, water course or water body or 200 feet of a reservoir at capacity?




No Impact. The proposed project would replace radio equipment or microwave antennas, install new antennas on existing poles/towers or construct new poles/towers and/or equipment shelters. No construction of a septic field is proposed and, therefore, no impact would occur related to siting a septic field in proximity to existing water sources.

8n) Would the project conflict with Water Collaborative Guidelines and Standards for Land Uses Near Streams?


No Impact. The individual projects would be implemented on existing communications sites at local police or public safety agency facility, the rooftops of buildings, or existing communications sites on hilltops. All ground disturbance and construction activities would comply with all water quality standards or waste discharge requirements and would incorporated Best Management Practices (discussed under 8a, above) into the proposed project. Therefore, this impact would be less than significant.

Sources County of Santa Clara, 2010. “About the County: Natural Environment.” Information from

website: http://www.sccgov.org, accessed on January 25, 2010.

County of Santa Clara, 1994. Santa Clara County General Plan: 1995-2010. December 20.


Jones, Steve. Personal communication with ESA staff, January 22, 2010.





Impact


with Mitigation

Incorporation


Impact No Impact

9. LAND USE AND PLANNING— Would the project:

a) Physically divide an established community?

b) Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect?

c) Conflict with special policies:

i) San Martin and/or South County?

ii) Los Gatos Specific Plan or Lexington Watershed?

iii) Guadalupe Watershed?

iv) Stanford?

v) City of Morgan Hill Urban Growth Boundary Area?

vi) West Valley Hillsides Preservation Area?

vii) Water Collaborative (Guidelines and Standards for Land Use Near Streams)?

Comments 9a) Would the project physically divide an established community?


No Impact. The proposed project would install microwave antennas (i.e., “dishes”) on existing structures or construct a new monopole and/or equipment shelters or replace equipment shelters at existing communication sites. The project would not create a physical division of any established community.

9b) Would the project conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect?


No Impact. Municipal codes for local jurisdictions provide for the installation of communication networks for telecommunications and emergency services and the installation of new microwave antennas, monopoles/towers or equipment shelters would occur on sites where such uses already exist and are appropriate. Therefore, the proposed project would be in compliance with applicable land use plans and policies.



9c) Would the project conflict with special policies, including the following:

• San Martin and/or South County; • Los Gatos Specific Plan or Lexington Watershed; • Guadalupe Watershed; • Stanford; • City of Morgan Hill Urban Growth Boundary Area; • West Valley Hillsides Preservation Area; • Water Collaborative (Guidelines and Standards for Land Use Near Streams).


Less than Significant Impact. The proposed Phase II expansion project would install microwave antennas (i.e., “dishes”) on existing structures or construct a new monopole and/or equipment shelters or replace equipment shelters at existing communication sites. The projects would be constructed on sites where such uses are permitted and would be consistent with all policies and guidelines designed to reduce environmental impacts in areas listed above. Therefore, this impact would be less than significant.







Impact


with Mitigation

Incorporation


Impact No Impact

10. 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?

c) Result in a substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project?

d) Result in a substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project?

e) For a project located within an airport land use plan referral area or, where such a plan has not been adopted, within two miles of a public airport or public use airport, or private airstrip would the project expose people residing or working in the project area to excessive noise levels?

Comments 10a) 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?


Less than Significant Impact. During construction or installation of the antennas, noise levels could increase slightly over baseline, mainly from truck traffic, crane operations, and attaching the antennas to the structure. The noise level generated by project-related construction activity would generally range from 75 to 80 dBA at a distance of 50 feet. Construction noise would be temporary, with most of the installations occurring within one workday. Construction noise would be very short-term in duration and would comply with local noise ordinances regarding attenuation and times of day construction can occur. Therefore, impacts from short-term noise resulting from the construction phase would be less than significant.

Project operation noise levels would be minimal as the sites would not generate additional noise above existing levels. Generators at the site would only operate as emergency back-up power, and thus, would be temporary.

Category 3 Sites:

Less than Significant Impact. During construction or installation of the antennas, noise levels could increase over baseline. Construction activities would require the use of



heavy equipment such as trenchers, jack hammers, backhoes, cranes and tractor-trailer/haul trucks. Noise levels associated with construction activity is generally summarized as an average noise level of all construction activities. The noise level generated by project-related construction activity would generally range from 75 to 80 dBA at a distance of 50 feet.

The noise levels created during the construction of this project could create a temporary disturbance to neighboring properties. The project shall conform to the County Noise Ordinance. The County Noise Ordinance (Section B11-152) sets maximum exterior noise levels for land use categories, and compliance with these specifications would ensure that the neighboring properties are not significantly impacted. Furthermore, construction noise would be very short-term in duration. Therefore, short-term noise resulting from the construction phase would present a less than significant impact.

Project operation noise levels would be minimal as the sites would not generate additional noise above existing levels. Generators at the site would only operate as emergency back-up power, and thus, would be temporary.

10b) Would the project result in exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels?


Less than Significant Impact. Operation of the proposed project would not result in vibrations. However, heavy equipment associated with very short term construction activities of the proposed project could generate perceptible vibration in the immediate vicinity of the construction site. The activity most likely to cause groundborne vibration would be the pass-by of heavy trucks on uneven surfaces and the use of jack-hammers during concrete or pavement removal. No pile driving would occur at any of the project sites.

Therefore, impacts to sensitive receptors associated with vibrations from typical construction activities or operations at the sites would be less than significant.

10c) Would the project result in a substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project?

ECOMM System and Category 0, 1, and 2 Sites:

No Impact. Project operation noise levels would be minimal as the sites would not generate additional noise above existing levels. Generators at the site would only operate as emergency back-up power, and thus, would be temporary.

Equipment shelters associated with the microwave antennas would house data transfer and switching technology and would be fully enclosed. All sites would use the existing equipment shelter located internally or in a standalone structure. These existing



equipment shelters already use fans and air-conditioning; the project would not increase the noise generated by these existing features.

Category 3 Sites:

Less than Significant Impact. No new shelter is proposed at Gilroy Reservoir D site. The new monopole and microwave antenna at this site would not increase noise levels at this location.

At the Lakeview Court site, the proposed pole and microwave antenna would have no effects on ambient noise levels, while the proposed equipment shelter and interior equipment would replace an existing equipment shelter and interior equipment, resulting in no net changes in the level of ambient noise in the project vicinity. Residential uses are located in close proximity to this site. However, impacts at Lakeview Court would be less than significant.

The proposed changes at the Woodland Acres site include the construction of a new equipment shelter that would contain fans and air conditioning. The new equipment shelter would replace an existing smaller shelter and would not result in noise levels that would be substantial. Furthermore, the location of the Woodland Acres site is remote, and no sensitive receptors are located within 100 feet of the site. Therefore, impacts at this site would be less than significant.

No new shelter is proposed at the Gilroy City Hall Annex site. Neither the new microwave antenna on the existing monopole nor the proposed 20-foot roof-top pole and microwave antenna would increase noise levels as compared to existing conditions.

Based on the above, any noise generated by the individual sites would not exceed noise standards and these impacts would be considered less than significant.

10d) Would the project result in a substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project?


Less than Significant Impact. As discussed above, the implementation of the proposed project would result in temporary increase in ambient noise levels due to construction. However, once operational, ambient noise levels in the vicinity would not be noticeably greater than under existing conditions. No temporary or periodic increases in ambient noise levels would result system-wide. Therefore, this impact would be less than significant.

10e) For a project located within an airport land use plan referral area or, where such a plan has not been adopted, within two miles of a public airport or public use airport, or private airstrip would the project expose people residing or working in the project area to excessive noise levels?




No Impact. With the exception of the individual project site at the San Jose Airport, the proposed project and all of the individual sites are not located within an airport land use plan or within the vicinity of a private airstrip. The project proposed at the San Jose Airport site would add a pipe mount and new 4-foot diameter microwave antenna on the roof of the existing Terminal 3 building, mounted on a new pole that would be attached to an existing beam. This, however, would not expose people residing or working in the project area to excessive levels since, after construction, it would not generate any additional noise, and the site is unmanned as well. Therefore, the project as a whole would generate virtually no noise and would not expose people residing or working in the area of the proposed project to excessive noise levels.



Santa Clara County Planning Office, 2005. ALUC Land Use Referral Boundary, San Jose International Airport. Adopted December 14, 2005.





Impact


with Mitigation

Incorporation


Impact No Impact

11. POPULATION AND HOUSING— Would the project:

a) Induce substantial 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 or people, necessitating the construction of replacement housing elsewhere?

Comments 11a,b) 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 or people?


No impact. The proposed project would not require an increase in staff for construction or operation of the system. No homes or population would be displaced or induced, either temporarily or permanently.





Impact


with Mitigation

Incorporation


Impact No Impact

12. PUBLIC SERVICES— Would the project:

a) Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:

i) Fire protection?

ii) Police protection?

iii) School facilities?

iv) Parks?

v) Other public facilities?

Comments 12a) Would the project result in substantial adverse physical impacts associated with the

provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services, including fire protection, police protection, school facilities, parks or other public facilities?


No Impact. The proposed project would not require additional personnel not generate additional population that would cause the need for construction of new public facilities. Furthermore, it would not generate an increase in need for fire protection, police protection, school enrollment, or the use of parks or other public facilities.





Impact


with Mitigation

Incorporation


Impact No Impact

13. MINERAL RESOURCES AND RECREATION— Would the project:

a) Result in the loss of availability of a known mineral resource that would be of future 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 as delineated on a local general plan, specific plan or other land use plan?

c) Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?

d) Include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?

e) Be on, within or near a public or private park, wildlife reserve, or trail or affect existing or future recreational opportunities?

f) Result in loss of open space rated as high priority for acquisition in the “Preservation 20/20” report?

Comments 13a,b) Would the project result in the loss of availability of a known mineral resource that

would be of future value to the region and the residents of the state, or result in the loss of availability of a locally-important mineral resource recovery site as delineated on a local general plan, specific plan or other land use plan?


No Impact. The proposed project would not disturb or otherwise impact known mineral resources. Individual sites would install antennas on existing structures or require the installation of new monopole towers within the boundaries of existing communications facility sites. As described in the Project Description, grading at Category 3 sites would be minimal and within disturbed areas. In summary, the ECOMM microwave antennas would be located to have no impact to efforts to recover mineral resources.

13c,d) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated; or does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?




No Impact. Because the proposed project or individual sites would not result in an increase in population to the area (i.e., no increase in on-site employment), the proposed project would not require new recreational facilities. Therefore, the proposed project would result in no impacts to recreation in the region.

13e) Would the project be on, within or near a public or private park, wildlife reserve, or trail or affect existing or future recreational opportunities?


No Impact. The proposed project would install antennas on existing structures or require the installation of new monopole towers within the boundaries of the existing communication facility sites. None of the individual sites are within a wildlife reserve or a trail. Furthermore, no public or private parks exist close enough to any of the sites that they would be adversely affected by the proposed project. In summary, the ECOMM Phase II project would not affect existing or future recreational opportunities.

13f) Would the project result in loss of open space rated as high priority for acquisition in the “Preservation 20/20” report?


No impact. The proposed project would be implemented within the boundaries of the existing communications facilities sites where such uses are expected for the foreseeable future. Furthermore, the project would not alter the sites to a degree that would preclude them from being used for other uses in the future. Therefore, no loss of open space rated as high priority for acquisition in the “Preservation 20/20” report would occur.







Impact


with Mitigation

Incorporation


Impact No Impact

14. TRANSPORTATION / TRAFFIC— Would the project:

a) Cause an increase in traffic which is substantial in relation to the existing traffic load and capacity of the street system (i.e., result in a substantial increase in either the number of vehicle trips, the volume-to-capacity ratio, or congestion at intersections)?

b) Exceed, either individually or cumulatively, a level of service standard established by the County congestion management agency for designated roads or highways?

c) Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks?

d) Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?

e) Result in inadequate emergency access?

f) Result in inadequate parking capacity?

g) Conflict with adopted policies, plans, or programs supporting alternative transportation (e.g., bus turnouts, bicycle racks)?

h) Not provide safe access, obstruct access to nearby uses or fail to provide for future street right of way?

Comments 14a) Would the project cause an increase in traffic which is substantial in relation to the

existing traffic load and capacity of the street system (i.e., result in a substantial increase in either the number of vehicle trips, the volume-to-capacity ratio, or congestion at intersections)?


No Impact. The proposed project would add no new daily car trips to the region or in the vicinity of the individual sites. Total daily trips would be minimal to periodically inspect the unmanned facilities and would be similar to the travel now needed to support the existing communications sites.

14b) Would the project exceed, either individually or cumulatively, a level of service standard established by the County congestion management agency for designated roads or highways?


No Impact. The proposed project would not add a significant number of new daily car trips to the region or in the vicinity of the individual sites. Total daily trips would be the minimum needed to periodically inspect and repair the unmanned facilities.



14c) Would the project 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?


No Impact. The proposed project and Category 1 and 2 sites would not affect air traffic patterns as no change to the height of the existing structures would occur.

Category 3 Sites:

Less than Significant Impact. For the Category 3 sites, new monopoles or tower structures would be installed as described earlier. Pursuant to the FCC’s Antenna Structure Registration (ASR) procedures, antenna structures that are taller than 60.96 meters (200 feet) above ground level or that may interfere with the flight path of a nearby airport must be cleared by the Federal Aviation Administration (FAA). The new monopoles and towers are well under 200 feet in height and therefore, would not require clearance from the FAA.

None of the Category 3 sites are within the Referral Boundary for the San Jose International Airport or within the Airport Influence Areas of the Palo Alto Airport, South County Airport, or the Reid Hillview Airport (County of Santa Clara ALUC, 2009a and 2009b, County of Santa Clara, 2007), the airports within the ALUC review authority. Therefore impacts to traffic patterns would be less than significant.

14d) Would the project substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?


No Impact. No new access roads would be constructed for the proposed project, and no incompatible uses would occur at the site. Access along the roads would be used by authorized personnel for maintenance activities at the individual sites.

14e) Would the project result in inadequate emergency access?


No Impact. Each site in the proposed system is located at an existing telecommunications facility or on the rooftop of an existing building. The project sites are unmanned and traffic to and from the sites would be minimal. Therefore, no impacts to emergency access would result from the proposed project.



14f) Would the project result in inadequate parking capacity?


No Impact. There is currently sufficient parking to accommodate maintenance activities at each site. Since each of the sites within the system are unmanned, no additional parking is required.

14g) Would the project conflict with adopted policies, plans, or programs supporting alternative transportation (e.g., bus turnouts, bicycle racks)?


No Impact. Each site in the proposed system is located at an existing telecommunications facility or on the rooftop of an existing building. The project sites are unmanned and traffic to and from the sites would be for maintenance activities only. Therefore, there would be no conflict with existing plans or policies on alternative transportation.

14h) Would the project not provide safe access, obstruct access to nearby uses or fail to provide for future street right of way?


No Impact. Each site in the proposed system is located at an existing telecommunications facility or on the rooftop of an existing building, with adequate existing access to each of the sites. Some of the sites, such as Pacheco Peak, are accessed by a private road that is not intended for public use, but this feature would not be impacted by the project. Furthermore, the project sites would not change existing access routes or fail to provide for future street right of way. Therefore, the project would not result in any impacts related to provision of safe access to any of the sites or a failure to provide for future street right of ways.

Sources Federal Communications Commission (FCC) Antenna Structure Registration website:

http://wireless.fcc.gov/antenna/index.htm?job=about


County of Santa Clara Airport Land Use Commission, 2009a.Comprehensive Land Use Plan , Santa Clara County, Palo Alto Airport, November 19, 2009.

County of Santa Clara Airport Land Use Commission, 2009b. Comprehensive Land Use Plan, Santa Clara County, South County Airport, November 19, 2009.

County of Santa Clara, 2007. Santa Clara County Airport Land Use Commission’s Land Use Plan Amendment, Initial Study Checklist, September 7, 2007.





Impact


with Mitigation

Incorporation


Impact No Impact

15. UTILITIES AND SERVICE SYSTEMS—Would the project:

a) Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board?

b) Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects?

c) Require or result in the construction of new storm water drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects?

d) Require new or expanded entitlements in order to have sufficient water supplies available to serve the project?

e) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?

f) Not be able to be served by a landfill with sufficient permitted capacity to accommodate the project’s solid waste disposal needs?

g) Violate federal, state, and local statutes and regulations related to solid waste?

h) Be in non-compliance applicable federal, state and locate statutes and regulations relating to energy statutes?

Comments 15a) Would the project exceed wastewater treatment requirements of the applicable

Regional Water Quality Control Board?


No Impact. The proposed project would not connect to wastewater treatment facilities.

15b) Would the project 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?


No Impact. The proposed project would not connect to water or wastewater facilities.



15c) Would the project 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?


No Impact. The proposed project would not require the construction of new stormwater drainage facilities or require the expansion of existing facilities as the project would not generate additional volumes of stormwater runoff.

15d) Would the project require new or expanded entitlements in order to have sufficient water supplies available to serve the project?


No Impact. The proposed project requires no water service connections.

15e) Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?


No Impact. The proposed project requires no wastewater service connections.

15f) Would the project not be able to be served by a landfill with sufficient permitted capacity to accommodate the project’s solid waste disposal needs?

ECOMM System:

Construction Less than Significant Impact. Solid waste from construction activities at each site would be generated and handled at the individual sites.

The construction contractor for the proposed project qualifies as a Conditionally Exempt Small Quantity Generator (CESQG), which would allow the construction contractor to participate in Santa Clara County and surrounding counties’ CESQG Disposal Program. This program would allow the contractor to properly dispose and/or recycle the materials involved with the decommissioning of wireless telecommunication structures.

The proposed project and the construction contractor would follow all federal, state and local regulations with regards to the disposal of all materials involved with the decommission of the wireless telecommunication structures for each jurisdiction in which the project sites are located (Harris Stratex 2007b).



Operations Less than Significant Impact. Each individual site within the ECOMM system uses batteries and other materials that require special handling and disposal. The project is identified as a small quantity handler and transporter of universal waste construction. Therefore, the construction contractor has developed a Universal Waste Management Policy that establishes the requirements for managing, transporting and handling of batteries designated as universal waste (Harris Stratex, 2007c).

Category 0 Sites:

Construction Less than Significant Impact. Category 0 sites involve the replacement, installations or upgrades of interior radio equipment at existing sites. Any equipment removed would be disposed in accordance with the construction contractor’s CESQG disposal program requirements.

Operations Less than Significant Impact. Category 0 sites would store, use, and replace batteries and other radio equipment as part of the system operations. Management, transport, and disposal of waste batteries would be in accordance with the construction contractor’s Universal Waste Management Policy described above.

Category 1 Sites:

Construction Less than Significant Impact. Category 1 sites involve the replacement of existing antennas for new antennas. The existing antennas would be removed and disposed in accordance with the construction contractor’s CESQG disposal program requirements.

Operations Less than Significant Impact. Category 1 sites would also store, use, and replace batteries as part of the system operations. Management, transport, and disposal of waste batteries would be in accordance with the construction contractor’s Universal Waste Management Policy described above.

Category 2 Sites:

Construction No Impact. Category 2 sites involve the placement of microwave antennas on existing structures. These sites would not generate construction waste such as removed antennas or structure mounts.



Operations Less than Significant Impact. Category 2 sites would also store, use, and replace batteries as part of the system operations. Management, transport, and disposal of waste batteries would be in accordance with the construction contractor’s Universal Waste Management Policy described above.

Category 3 Sites:

Construction Less than Significant Impact. Category 3 sites involve the placement of new antennas on new monopoles or towers as well as construction of new equipment shelters. No removal of existing towers is proposed, although at Woodland Acres and Lakeview Court sites, existing shelters would be removed (and replaced). All dismantling and disposal would be conducted in accordance with the construction contractor’s CESQG disposal program requirements. This would ensure that any impacts related to construction activities at Category 3 sites would be less than significant.

Operations Less than Significant Impact. Category 3 sites would also store, use, and replace batteries as part of the system operations. Management, transport, and disposal of waste batteries would be in accordance with Universal Waste Management Policy described previously.

15g, h) Would the project be in non-compliance with applicable federal, state, and local statutes and regulations related to solid waste or energy statutes?


No Impact. The proposed project would comply with all applicable federal, state, and local statutes related to solid waste or energy. The generators at each site would only be used for emergency back-up power.


Less than Significant Impact. The proposed project sites would be located at existing sites such as the rooftop of buildings or existing telecommunications facilities where electrical service is already provided through an established electric network. Thus, electricity would be available to serve the proposed project. At several sites, new antennas would replace existing antennas and thus, would not result in a substantial increase in energy consumption (Harris Stratex, 2009). At other sites where new microwave antennas would be installed, power requirements would be minimal, and would not significantly increase consumption over existing levels. Therefore, impacts would be less than significant.

Category 3 Sites:

Less than Significant Impact. Category 3 sites are located within areas that already contain telecommunications equipment or, in the case of the Gilroy City Hall Annex, on



the rooftop of an existing building. Specific energy requirements for each site are described below:

Gilroy Reservoir D – Power would be provided from the existing service that connects to the equipment shelters on the site. Power requirements for the system are minimal, mainly used to recharge the antenna batteries, and the project would not significantly increase consumption over existing levels. Therefore, impacts would be less than significant.

Woodland Acres – Power that currently services the other antennas and radio equipment on the site would be used to power the new antenna and new radio equipment. Therefore, because there would be no significant increase in energy consumption over existing levels, impacts would be less than significant.

Lakeview Court – The power that currently services the existing equipment shelter on the site would be used to power the new equipment shelter, radio unit, and the microwave antenna. The project would not significantly increase consumption over existing levels as power requirements for the system would be minimal, mainly used to recharge the antenna batteries. Therefore, impacts would be less than significant.

Gilroy City Hall Annex – The proposed project would generate a small increase in electricity demand at this site, but it would not be substantially more than what is already provided to the existing microwave tower on the existing monopole. Therefore, even with the power requirement for the two new microwave antennas, there would be no significant increase in energy consumption over existing levels.



Harris Stratex, 2007c. Universal Waste Management Policy. August.





Impact


with Mitigation

Incorporation


Impact No Impact

16. MANDATORY FINDINGS OF SIGNIFICANCE

a) Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory?

b) Does the project have impacts that are individually limited, but cumulative considerable? (“Cumulative considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)?

c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?

Comments 16a) Does the project have the potential to degrade the quality of the environment,

substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory?


Less than Significant Impact. The proposed project (expansion of the ECOMM system and changes at each of the individual sites) does not have the potential to substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, 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. Any potential short-term increases in potential effects to the environment during construction are mitigated to a less than significant level, as described in this Initial Study/Environmental Assessment.

16b) Does the project have impacts that are individually limited, but cumulative considerable? (“Cumulative considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)?




Less than Significant Impact. In accordance with CEQA Guidelines Section 15183, the environmental analysis in this Initial Study was conducted to determine if there were any project-specific effects that are peculiar to the project or its site. No project-specific significant effects peculiar to the project or its site were identified that could not be mitigated to a less than significant level. The project would not be growth-inducing and would not generate an increase in population levels or traffic volume. The proposed project could contribute to environmental effects in the areas of air quality, biological resources, hazardous materials and wastes, and temporary increases in construction-generated dust and noise. Mitigation measures incorporated herein, however, mitigate any potential contribution to cumulative impacts associated with these environmental issues.

The proposed ECOMM system would not be affected by other projects planned for the region since the individual sites are located at existing communication facilities or police departments. The system has been designed to add additional to-be-determined jurisdictions at future dates. When these future sites are ready to join the ECOMM network, each site would be required to prepare the appropriate CEQA and NEPA environmental document. Therefore, the proposed project does not have impacts that are individually limited, but cumulatively considerable.

16c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?


Less than Significant Impact. The project may have significant adverse effects on human beings in the areas of air quality, hazardous wastes and materials, exposure to radio frequencies, and noise during construction. Mitigation measures identified in the appropriate sections of this Initial Study/Environmental Assessment would reduce the effects to a less than significant level.

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