City of Santa Cruz Resource Recovery Operational Change

2025061110

City of Santa Cruz

NOE - Notice of Exemption

6/24/2025

6/24/2025

Hoi Yu

City of Santa Cruz

Associate Professional Engineer

Lead/Public Agency

809 Center Street, Room 201
Santa Cruz, CA 95060

(831) 420-5160

HYu@santacruzca.gov

605 Dimeo Lane

100

59-121-01

Categorical Exemption

Section 15301

CEQA provides "categorical exemptions" which are applicable to categories of projects and activities that the California Natural Resources Agency has determined generally do not pose a risk of significant impacts on the environment. The Class 1 categorical exemption is for existing facilities and includes "minor alteration of existing public or private structures, facilities, mechanical equipment, or topographical features, involving negligible or no expansion of existing or former use." The project consists solely of a modification to the facility's operational schedule, adjusting the permitted start time for ancillary operations by one-half hour from 6:00 AM to 5:30 AM. This change is intended to provide sufficient time for site preparation activities, such as the removal of daily cover (either soil or tarp), prior to the facility's 6:00 AM opening to collection trucks. The change does not increase the facility's capacity, alter waste processing methods, or introduce new waste streams. No new construction, ground disturbance, or infrastructure changes are required, and all RRF activities will continue to operate as permitted. The proposed operational change does not involve any physical modifications to RRF facilities, facility capacity, or waste stream composition, and thus, would not result in impacts to the environment. No additional infrastructure, equipment, or staffing changes are required beyond adjusting the existing operational schedule. Operations at the facility will continue to follow existing protocols for waste handling and processing. The change is expected to benefit overall operational efficiency without altering the existing services or increasing traffic volumes beyond current levels. Vehicle activity associated with the facility, including collection vehicles, would not change as existing waste streams and processing volumes will remain the same. Thus, the adjusted operating hours represent a negligible alteration to existing operations and are consistent with the criteria outlined for a Class I categorical exemption. Furthermore, the project meets the "common sense" exemption set for in CEQA Guidelines section 15061(b)(3), which applies to projects where it can be seen with certainty that there is no possibility that the activity may have a significant effect on the environment. As indicated above, the minor change in the start time for ancillary operations by one-half hour, but would not result in new construction, alteration of existing facilities or changes in RRF processes or capacity, and thus would not result in a significant effect on the environment. The City has further considered whether the project is subject to any of the exceptions to the use of a categorical exemption found at CEQA Guidelines Section 15300.2. This section prohibits the use of categorical exemptions under the following circumstances: (a) for certain classes of projects (not the Class 1 exemption) due to location; (b) when the cumulative impact of successive projects of the same type in the same place, over time, is significant; (c) where there is a reasonable possibility that the activity will have a significant effect on the environment due to unusual circumstances; (d) where the project may result in damage to scenic resources, including but not limited to, trees, historic buildings, rock outcroppings, or similar resources, within a highway officially designated as a state scenic highway; (e) where the project is located on a state designated hazardous waste site; and (f) where the project may cause a substantial adverse change in the significance of a historical resource. Exception (a) - Location. Classes 3, 4, 5, 6, and 11 are qualified by consideration of where the project is to be located; a project that is ordinarily insignificant in its impact on the environment may in a particularly sensitive environment be significant. Therefore, these classes are considered to apply in all instances, except where the project may impact an environmental resource of hazardous or critical concern where designated, precisely mapped, and officially adopted pursuant to law by federal, state, or local agencies. This exception is not applicable to the Class 1 categorical exemption. Exception (b) - Cumulative Impact. All exemptions are inapplicable when the cumulative impact of successive projects of the same type in the same place, over time is significant. This exception is not applicable because there is no evidence of a potential significant cumulative impacts due to successive projects of the same type in the same place. There are no other known public projects of the same type planned at the RRF or in the project area that could result in significant cumulative impacts. However, there is a planned installation of a permanent enclosed low nitrogen oxide flare to ensure regulatory compliance by providing a backup device for landfill gas collection and destruction. However, there would be no cumulative impacts with the start time operational change as the project would not result in land disturbance or construction that would result in impacts that would contribute to potential impacts of the planned flare project. Exception (c) - Significant Effect. A categorical exemption shall not be used for an activity where there is a reasonable possibility that the activity will have a significant effect on the environment due to unusual circumstances. This exception is not applicable because no potential significant impacts have been identified. The proposed operational change of the RRF's opening time by one half hour for ancillary operations does not involve any new construction or modifications to the RRF, and would not result in impacts to the physical environment. The project would not change to the facility's accepted waste types or introduce new processing methods that could result in impacts. Ancillary operations such as the removal of daily cover--whether soil or tarp--are already part of routine facility activities and will continue to follow standard protocols. The shift in operational hours by 30 minutes is minor and occurs during early morning hours when onsite staff are preparing the disposal area for the facility's standard 6:00 AM opening for collection trucks. No sensitive receptors are located nearby, and vehicle trips with existing operations will remain unchanged. The project does not involve any construction or expansion of the facility footprint. Overall, the schedule change represents a negligible modification that would not result in significant environmental impacts. There are no "unusual circumstances" that differentiates the project from other similar routine operational adjustments at the RRF or that differentiates the project from the general class of similarly situated landfill/resource recovery projects permitted throughout the state. Exception (d) - Scenic Highways. A categorical exemption shall not be used for a project which may result in damage to scenic resources, including but not limited to, trees, historic buildings, rock outcroppings, or similar resources, within a highway officially designated as a state scenic highway. This exception is not applicable because the RRF is not located adjacent to or visible from a designated scenic highway. Highway 1, located to the west of the RRF, is identified as being eligible for designation, but is not currently an officially designated scenic highway. Furthermore, the project would not result in new construction or alteration of existing RRF facilities. Exception (e) - Hazardous Waste Sites. A categorical exemption shall not be used for a project located on a site which is included on any list compiled pursuant to Section 65962.5 of the Government Code. This exception is not applicable because the project site is not an identified hazardous waste site compiled pursuant to Government Code section 65962.5. Exception (f) - Historical Resources. A categorical exemption shall not be used for a project which may cause a substantial adverse change in the significance of a historical resource. This exception is not applicable because the project would not result in construction of new facilities, ground disturbance or alteration of existing facilities, and thus, and would not affect historical resources. There are no structures on the site that will be removed or altered. Therefore, the City is able to document that the project qualifies for the Categorical Exemption found at CEQA Guidelines section 15301, which allows for minor alteration to existing facilities and equipment, as well as the "common sense" exemption as there is no possibility of the project resulting in a significant impact on the environment. None of the potential exceptions to the use of a categorical exemption apply to this project.

Other

Section 15061(b)(3)

The project clearly will not have a significant effect on the environment.