The 2016 Recycled Water Master Plan showed a delivery of 248 acre-feet for an existing 21 users between August 2013 and July 2014. In 2019, 282 acre-feet of recycled water was delivered to customers which is still below the projected 391 acre-feet of recycled water in 2020. The proposed project would add an estimated 82.1 AFY of recycled water demand.
Systemwide Demand
Recent Actual System Demand
The 2015 UWMP provides a comprehensive assessment of anticipated future water demand that included projections for both potable and recycled water for 2015-2040. However, actual water usage between 2015 and 2020 differed from what was projected in the UWMP, suggesting that demand patterns for 2015-2040 may be different as well. Table 3.13-5 shows the actual water usage within the City’s distribution area since the 2015 UWMP was completed, as well as the interpolated yearly demand based on the projections in the UWMP. Since 2015, potable water demand has been much lower than that anticipated in the UWMP.
Table 3.13-5: Recent Potable and Recycled Water Usage for American Canyon Category
Acre-Feet Year
2015 2016 2017 2018 2019 2020
Total Potable Water Use 2,968 2,572 2,558 2,667 2,418 2,665 Total Project Water Demand (UWMP) 2,976 3,062 3,148 3,233 3,319 3,405 Total City Recycled Water Use 180 – – – 282 –
Total Projected Recycled Water Demand
(UWMP) 385 509 634 758 883 1,007
Total Water Usage (Actual) 3,148 2,572 2,558 2,667 2,700 2,665 Total Projected Water Demand (UWMP) 3,361 3,571 3,781 3,992 4,202 4,412 Notes: Actual water usage from Napa County Flood Control and Water Conservation District SWP delivery accounting tables (provided by the City) plus agricultural raw water. Agricultural raw water use estimated to remain at 2015 level (56 AFY) through 2020, then be reduced to zero thereafter.
Source: Balance Hydrologics 2021.
Projected System Demand
The 2015 UWMP projected future demand on a parcel-by-parcel basis relative to expected growth under the City’s general plan. The analysis assumed that recycled water would be available to meet a portion of the total demand, with the remainder supplied by potable water. Table 3.13-6 shows the water demand as presented in the 2015 UWMP.
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-13 Utilities.docx Table 3.13-6: Projected Potable, Recycled, and Total Water Demand for American Canyon UWMP Reported Value
Acre-Feet Year
2015 2020 2025 2030 2035 2040
Projected Potable Water Demand 2,345 3,150 3,350 3,606 3,862 4,131 Projected Potable System Losses 631 255 272 292 313 335 Recycled Water Demand 385 1,007 1,146 1,351 1,862 1,862 Total Water Demand 3,361 4,412 4,768 5,249 6,037 6,328
Source: Balance Hydrologics 2021.
Unbilled Water Losses
The UWMP assumed that unbilled water losses would be 7.5 percent for each year between 2020- 2040. This is consistent with standards adopted by the California Urban Water Conservation Council, which provides that systems that experience greater than 10 percent losses annually undergo a water audit. In 2015, water delivery and water use records indicate that system losses were 22 percent. The City is currently undertaking an aggressive response to the situation by replacing leaky services and water mains to reduce system loss. The City assumed it would reduce system losses to
7.5 percent of the total potable and raw water deliveries by 2020. In 2015, the City replaced more than 120 segments of residential services lines as part of its program to reduce distribution system losses.
Supply and Demand Comparison
The following analysis compares future citywide water demand to anticipated available supply under “normal year,” “single dry year,” and “multiple dry year” scenarios. The scenarios presented herein have been summarized from the 2015 UWMP analysis for citywide system planning.
This analysis addresses potable and recycled water separately, as recycled water supply is considered reliable (and available at 100 percent of capacity) under all year-types. Reliability of potable water varies by year-type as a percentage of contracted amount, as shown in Table 3.13-7.
Table 3.13-7: Supply Reliability for Various American Canyon Water Sources 2021-2040 Year Type
Source
Contracted
or Available
Volume Normal Year Single Dry Year Dry Year 1 Dry Year 2 Dry Year 3 State Water Project
(Table A allotment) 5,200 62% 5% 22% 22% 22%
Vallejo Permit Water1 500 100% 100% 100% 100% 100%
Vallejo Treated Water1 Varies2 100% 80% 80% 80% 80%
Vallejo Emergency Water1 500 0% 100% 100% 100% 80%
Groundwater3 n/a – – – – –
700
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Source
Contracted
or Available
Volume Normal Year Single Dry Year Dry Year 1 Dry Year 2 Dry Year 3 American Canyon Recycled
Water n/a 4 100% 100% 100% 100% 100%
Notes:
UWMP = Urban Water Management Plan
1 Percentages from 2015 UWMP, Table 7-4, 7-5, 7-6. 2 Contracted Amount is 2,074 in 2015; 2,640 in 2020; and 3,206 2021-onward. 3 Groundwater is not a source for citywide supply. 4 Recycled water is produced to meet demand, ultimately, maximum production capacity of City’s recycled water system is expected to be 1,000 acre-feet per year (AFY).
Potable Water
Table 3.13-8 summarizes available potable water supply under ‘normal year,’ ‘single dry year,’ and ‘multiple dry year’ scenarios. The City’s potable water supply relies exclusively on imported water, both from the SWP and through the City of Vallejo. A percentage of the full contracted amount is assumed for each source type under each scenario. These percentages are based on guidance by DWR, analysis in the City’s UWMP and the Vallejo UWMP. Resulting supply volumes for each source under the various scenarios through 2040 are shown in Table 3.13-8. The supply and demand for potable water for each of the year-types is discussed as follows. 701
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-13 Utilities.docx Table 3.13-8: Projected Water Supply for American Canyon for Various Year Types 2021-2040 2015 2020 2025 2030 2035 2040
Source
Contracted
or
Available
Volume Actual
Normal
Year
Single
Dry
Year
Dry
Year 1
Dry
Year 2
Dry
Year 3
Normal
Year
Single
Dry
Year
Dry
Year 1
Dry
Year 2
Dry
Year 3
Normal
Year
Single
Dry
Year
Dry
Year 1
Dry
Year 2
Dry
Year 3
Normal
Year
Single
Dry
Year
Dry
Year 1
Dry
Year 2
Dry
Year 3
Normal
Year
Single
Dry
Year
Dry
Year 1
Dry
Year 2
Dry
Year 3
State Water
Project
Table A
allotment
5,200 1,953 3,224 260 1,144 1,144 1,144 3,224 260 1,144 1,144 1,144 3,224 260 1,144 1,144 1,144 3,224 260 1,144 1,144 1,144 3,224 260 1,144 1,144 1,144 State Water
Project
(Article 21)
Varies 72 189 0 124 124 124 189 0 124 124 124 189 0 124 124 124 189 0 124 124 124 189 0 124 124 124 Vallejo
Permit
Water
500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Vallejo
Treated
Water
Varies 102 2,640 2,112 2,112 2,112 2,112 3,206 2,565 2,565 2,565 2,565 3,206 2,565 2,565 2,565 2,565 3,206 2,565 2,565 2,565 2,565 3,206 2,565 2,565 2,565 2,565 Vallejo
Emergency
Water
500 387 0 500 500 500 400 0 500 500 500 400 0 500 500 500 400 0 500 500 500 400 0 500 500 500 400 Total
Potable 6,200 3,014 6,553 3,372 4,380 4,380 4,280 7,119 3,825 4,833 4,833 4,733 7,119 3,825 4,833 4,833 4,733 7,119 3,825 4,833 4,833 4,733 7,119 3,825 4,833 4,833 4,733 American
Canyon
Recycled
Water
n/a2 180 616 616 616 616 616 655 655 655 655 655 760 760 760 760 760 1,271 1,271 1,271 1,271 1,271 1,271 1,271 1,271 1,271 1,271 NapaSan
Recycled
Water
Varies3 210 391 391 391 391 391 491 491 491 491 491 591 591 591 591 591 591 591 591 591 591 591 591 591 591 591 Total
Recycled – 390 1,007 1,007 1,007 1,007 1,007 1,146 1,146 1,146 1,146 1,146 1,351 1,351 1,351 1,351 1,351 1,862 1,862 1,862 1,862 1,862 1,862 1,862 1,862 1,862 1,862 Total Supply – 3404 7,560 4,379 5,387 5,387 5,287 8,265 4,971 5,979 5,979 5,879 8,470 5,176 6,184 6,184 6,084 8,981 5,687 6,695 6,695 6,595 8,981 5,687 6,695 6,695 6,595 Notes:
1. Contracted amount is 2,074 in 2015, 2,640 in 2020, and 3,206 2021-onward. 2. Recycled water is produced to meet demand; ultimately, maximum production capacity of City’s recycled water system is expected to be 1,000 acre-feet per year (AFY). 3. Projected deliveries from NapaSan to the northern Airport Industrial Area. Does not include demand for the Montalcino Resort, as that amount will not affect citywide demand. 702
City of American Canyon—Givannoni Logistics Center Project Draft EIR Utilities and Service Systems
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-13 Utilities.docx Table 3.13-9: Comparison of Potable and Recycled Water Supply and Demand Under Various Year-type Scenarios Source
2015 2020 2025 2030 2035 2040
Actual
Normal
Year
Single
Dry
Year
Dry
Year 1
Dry
Year 2
Dry
Year 3
Normal
Year
Single
Dry
Year
Dry
Year 1
Dry
Year 2
Dry
Year 3
Normal
Year
Single
Dry
Year
Dry
Year 1
Dry
Year 2
Dry
Year 3
Normal
Year
Single
Dry
Year
Dry
Year 1
Dry
Year 2
Dry
Year 3
Normal
Year
Single
Dry
Year
Dry
Year 1
Dry
Year 2
Dry
Year 3
(AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) Total potable
supply1 3,014 6,556 3,372 4,380 4,380 4,280 7,119 3,825 4,833 4,833 4,733 7,119 3,825 4,833 4,833 4,733 7,119 3,825 4,833 4,833 4,733 7,119 3,825 4,833 4,833 4,733 Potable
demand2 2,345 3,405 3,405 3,405 3,405 3,405 3,622 3,622 3,622 3,622 3,622 3,898 3,898 3,898 3,898 3,898 4,175 4,175 4,175 4,175 4,175 4,466 4,466 4,466 4,466 4,466 Potable
supply minus
demand
669 3,148 -33 975 975 875 3,497 203 1,211 1,211 1,111 3,221 -73 935 935 835 2,944 -350 658 658 558 2,653 -641 367 367 267 Recycled
water
supply3
390 1,007 1,007 1,007 1,007 1,007 1,146 1,146 1,146 1,146 1,146 1,351 1,351 1,351 1,351 1,351 1,862 1,862 1,862 1,862 1,862 1,862 1,862 1,862 1,862 1,862 Recycled
water
demand4
385 1,007 1,007 1,007 1,007 1,007 1,146 1,146 1,146 1,146 1,146 1,351 1,351 1,351 1,351 1,351 1,862 1,862 1,862 1,862 1,862 1,862 1,862 1,862 1,862 1,862 Recycled
supply minus
demand
5 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Notes:
AFY = acre-feet per year 1. From Table 7. 2. Projected potable normal year demand, from Table 5. 3. From Table 7. 4. From Table 5 703
City of American Canyon—Givannoni Logistics Center Project Utilities and Service Systems Draft EIR
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In a “normal year,” the City’s 2015 UWMP assumes “Table A” SWP deliveries would be 62 percent of the total contracted amount. Treated water from Vallejo water and raw Vallejo Permit Water are assumed to be 100 percent available in normal years, consistent with the 2015 UWMP.
The UWMP concluded that future supply is available to meet anticipated demand in normal years through buildout in 2035, as does the analysis in the WSA (Table 8). Excess supply in normal years ranges from a low of 2,653 in 2040 to a high of 3,497 AFY in 2025.
Single Dry Year
Under the “single dry year” scenario, the 2015 UWMP assumed SWP Table A deliveries to be curtailed to 5 percent of the contracted amount (see Table 3.13-8 and Table 3.13-9).
All water from Vallejo is considered a more reliable source than the City’s SWP supply. The 2015 UWMP assumes that raw Vallejo Permit Water is available at 100 percent and Treated Vallejo Water is available at 80 percent of the contracted amount during single dry years. In addition, the full allotment of raw Vallejo Emergency Water (500 acre-feet) would be available under dry year conditions. The analysis herein uses these same assumptions.
The 2015 UWMP shows that single dry year supply is not significantly currently constrained and the City will be able to reliably meet potable demand until the year 2030. Single dry year deficiencies are anticipated starting in 2035 (Table 3.13-9). The City has several options available to resolve dry-year supply deficiencies.
Multiple Dry Years
The multiple dry year scenario, as described in the UWMP, consists of three consecutive years of reduced water deliveries, though none are reduced to the same degree as the single dry year scenario. The UWMP assumed that SWP Table A water would be reduced to 22 percent of the contracted amount for each of the three years.
Raw Permit Water is assumed to be available at 100 percent, and Treated Water from Vallejo is assumed to be available at 80 percent of the contracted amount for years 1, 2, and 3 of the multiyear drought following the assumptions in the 2015 UWMP. Vallejo Emergency Water is assumed to be available at the full contracted amount (500 acre-feet) for each of the 3 years of a multi-year drought, consistent with the 2015 UWMP.
The 2015 UWMP projects that water supply will exceed demand during a 3-year drought through the full 2040 planning period.
Potable Water Deficiency Resolution
The prior analysis compares potable water supply and normal year demand, and projects supply shortages in several of the “dry year” and “multiple dry year” planning scenarios. This section describes a series of options available to the City to eliminate those shortfalls in order to provide reliable supply. Estimated SWP carryover water would be sufficient to eliminate dry year supply shortfalls and could also be used in combination with drought demand reductions to further improve supply reliability.
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-13 Utilities.docx State Water Project Carryover Water
If the City does not use its entire allotment of Table A water in a given year, the remaining water will carry over to the following year, assuming there is adequate storage in SWP reservoirs to contain the excess supply.
6 Between 2015 and 2020, the City has stored between 35 and 2,600 acre-feet of carryover water in a given year (Table 3.13-10), which has helped to meet demand during recent dry years. Because of the variability of carryover supply and the periodic “re-set” of the accounting when reservoirs are full, it is not considered a consistent yearly supply for planning purposes, but it does allow the City extra flexibility during droughts. As such, the carryover water has been incorporated into the analysis in the WSA.
Table 3.13-10: Recent State Water Project Carryover Water Supply 2015 2016 2017 2018 2019 2020 Mean
Table A deliveries
(percentage of total contract amount)1 25% 75% 100% 50% 85% 20% 59% Available carryover water
(remaining from previous year, in AFY)1 876 1,087 127 2,210 35 2,600 1,156 Notes:
AFY = acre-feet per year 1 From Napa County Flood Control and Water Conservation District SWP delivery accounting tables (provided by the City).
It is assumed that 1,156 acre-feet of carryover water, the average over the last six years, would be available at the beginning of a dry year and the first year of a multi-year drought. Projected excess normal year supply ranges from 2,653 to 3,497 acre-feet for 2020-2040, suggesting that the 1,156 acre-feet is a reasonable and somewhat conservative estimate for planning purposes. 7 In the second
and third year of a multi-year drought, the remaining carryover supply (presuming there is any) would continue to carry over to subsequent years to supplement supplies.
For example, in the single dry year scenario for 2035, 1,156 acre-feet would be available to meet the supply deficit of 350 acre-feet. The difference (806 acre-feet) would be available if there was another drought year. Under the above assumptions, the City would be able to meet projected supply deficiencies under all dry and multiple dry year scenarios within the planning period (2015-2040) through the use of available carry-overwater.
Advanced Table A Program
A recent court settlement (Area of Origin Settlement 18, 2014), clarifies another potential mechanism for the Napa County Flood Control and Water Conservation District, the Solano County Water Agency, and Yuba City (along with subcontractors to those agencies, which includes American Canyon) to obtain water during dry periods. The Advanced Table A Program allows these agencies to borrow against future SWP deliveries during times when annual deliveries are not sufficient to meet 6 In years when SWP reservoirs spill, the carryover water is released, effectively re-setting carryover accounting to zero. Typically, however, ample storage is available in dry years. 7 By definition, a single dry year would follow a normal or wet year, as would the first year of a 3-year drought 705
City of American Canyon—Givannoni Logistics Center Project Utilities and Service Systems Draft EIR
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-13 Utilities.docx demand. The agreement requires that all Table A and Table A carryover water be used prior to utilizing the Advanced Table A Program, but under those circumstances the City could request an advance of up to 949 acre-feet from future years’ Table A allotments.
The projections in Table 3.13-11 do not rely on the use of the Advanced Table A Program water to meet dry year demand, as estimated Table A carryover is enough to cover supply deficiencies for all scenarios. However, this program provides an important tool available to the City should unforeseen circumstances result in significantly lower-than-expected carryover. 706
City of American Canyon—Givannoni Logistics Center Project Draft EIR Utilities and Service Systems
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-13 Utilities.docx Table 3.13-11: Potable Water Deficiency Resolution for Dry- and Multi-dry Year Scenarios Source
2015 2020 2025 2030 2035 2040
Actual
Normal
Year
Single
Dry
Year
Dry
Year 1
Dry
Year 2
Dry
Year 3
Normal
Year
Single
Dry
Year
Dry
Year 1
Dry
Year 2
Dry
Year 3
Normal
Year
Single
Dry
Year
Dry
Year 1
Dry
Year 2
Dry
Year 3
Normal
Year
Single
Dry
Year
Dry
Year 1
Dry
Year 2
Dry
Year 3
Normal
Year
Single
Dry
Year
Dry
Year 1
Dry
Year 2
Dry
Year 3
(AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) (AFY) Potable
supply minus
demand1
669 3,403 222 1,230 1,230 1,130 3,769 475 1,483 1,483 1,383 3,513 219 1,227 1,227 1,127 3,257 -37 971 971 871 2,988 -306 702 702 602 Estimated
Table A
carryover
water2
– – 1,156 1,156 2,386 3,616 – 1,156 1,156 2,639 4,122 – 1,156 1,156 2,383 3,610 – 1,156 1,156 2,127 3,098 – 1,156 1,156 1,858 2,560 “Advanced
Table A”
water3
– – 0 0 0 0 – 0 0 0 0 – 0 0 0 0 – 0 0 0 0 – 0 0 0 0
Demand
savings
through
drought
restrictions4
– – 0 0 0 0 – 0 0 0 0 – 0 0 0 0 – 0 0 0 0 0 0 0 0 0
Open market
water
purchases5
– – 0 0 0 0 – 0 0 0 0 – 0 0 0 0 – 0 0 0 0 0 0 0 0 0
Adjusted
supply minus
demand6
669 3,403 1,378 2,386 3,616 4,746 3,769 1,631 2,639 4,122 5,505 3,513 1,375 2,383 3,610 4,737 3,257 1,119 2,127 3,098 3,969 2,988 850 1,858 2,560 3,162 Notes:
AFY = acre-feet per year 1 From Table 3.13-9. 2 Table A water not used in the prior year may be used in the following year, assuming storage is available; estimated from previous six years of carryover availability. Assume 1,156 acre-feet available in a dry year and the first year of a multi-year drought. Remaining carryover after the first year of a drought is available in the second year, and remaining water after the second year is available in the third year of a drought. 3 When the City exhausts its supply of carryover water, the City can "borrow" against future State Water Project (SWP) deliveries, up to 949 acre-feet. Projected water shortages can be met solely through carryover supply, so no Advanced water is projected to be needed to meet demand. 4 The City may choose to offset supply deficiency through demand reduction (drought restrictions) during dry periods. All supply deficiencies are projected to be satisfied through carryover water; restrictions are not likely to be required, but remain an option for the City, if needed; see Table 3.13-12 for projected estimated volume for drought conservation savings. 5 The City also has the option to purchase additional water on the open market. While not required to meet long-term supply deficiencies the City may choose to use this option during droughts, 6 Supply minus demand from above, plus additional supply available through carryover, “Advanced Table A,” demand savings, and open market purchases 707
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City of American Canyon—Givannoni Logistics Center Project Draft EIR Utilities and Service Systems
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It is important to note that the demand projections in the 2015 UWMP (as well as for the analysis in the WSA) were not explicitly adjusted for voluntary or mandatory water use reduction measures that may be implemented in response to drought conditions. The City has a Water Shortage Contingency Plan that outlines four stages of water demand reduction measures that could be utilized when water supply is constrained due to environmental or other conditions. The City projects demand reductions of 10/20/30/50 percent corresponding to each of the tiers, beginning with voluntary actions at Tier 1 and moving to increasingly restrictive mandatory measures for Tiers 2-4.
On June 1, 2021, in response to ongoing Statewide drought conditions, the City declared a Stage 1 drought emergency that called for a voluntary reduction from residential and commercial customers compared to the previous year. On July 20, 2021, the City declared a Stage 2 drought emergency, enacting mandatory water use restrictions, requiring all water customers to reduce their water use by 20 percent. As of the end of August 2021, water conservation measures have resulted in an 18 percent decrease from residential customers and 13 percent decrease from commercial customers.
Because estimated carryover water was sufficient to satisfy projected shortages, the supply and demand analysis in Table 3.13-11 does not account for drought year demand reduction. However, the City may choose to use these measures to provide additional flexibility during droughts.
Assuming drought reductions of 13 percent, similar to what was achieved in 2014, the City could be expected to reduce demand in future years ranging between 305 acre-feet in 2015 and 537 acre-feet in 2040 (Table 3.13-12). While these volumes would not solely eliminate projected dry year shortages, these measures could be used in conjunction with the above measures to provide additional buffer, as needed, if other supplies are unexpectedly curtailed. Stronger restrictions (level 3 or 4), could be used to achieve greater reductions if necessary, but are not likely to be needed.
Table 3.13-12: Projected Drought Year Demand Savings
2015 2020 2025 2030 2035 2040
(AFY) (AFY) (AFY) (AFY) (AFY) (AFY)
Projected normal year potable demand1 2,345 3,150 3,350 3,606 3,862 4,131 Estimated drought conservation volume2 305 410 436 469 502 537 Notes:
AFY = acre-feet per year 1 From Table 3.13-6. 2 13 percent of potable demand.
Open Market Purchases
The City has the option to purchase additional water from a variety of other sources on an asneeded and as-available basis. These potential purchases were not considered as a reliable longterm supply for the purposes of the WSA, though the City could choose to purchase additional supply in dry years when normal supplies are constrained. In fact, the City chose to utilize this option in 2015, and purchased 216 acre-feet of additional supply through the Dry Year Transfer and Yuba Accord Programs. As with the above options, Open Market Purchases can provide additional operational flexibility for the City during dry periods when other supplies are reduced. 709
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The City’s recycled water system has a supply capacity of up to 1,271 AFY by 2035, and NapaSan has agreed to provide up to 591 acre-feet to supply the northern portion of the Airport Industrial Area (which is located within the City’s water service area). Practically, however, the City produces recycled water to meet demand, as shown in Table 8 (above). Because recycled water is derived from wastewater that is: (1) less susceptible to fluctuation due to climatic conditions, and (2) available in excess of the capacity of the recycled water system, recycled water is assumed to be 100 percent available during single- and multi-year-drought scenarios. Table 3.13-9 presents recycled water supply versus demand for the 2015-2040 planning period under various year-type scenarios.
Because recycled water use offsets water that would otherwise be delivered from limited potable or imported water supply, it is in the City’s best interest to maximize recycled water use by way of increasing the number of recycled water users tied into the system.
The projections for recycled water use in the 2015 UWMP were, in effect, operational goals to maximize recycled water use. The UWMP projected 1,862 acre-feet of recycled water use by 2035.
Recent recycled water use has been much lower than projected in the UWMP. For example, in 2019 water demand was projected to be about 883 acre-feet, but the City only used 282 acre-feet of recycled water. The City expects a significant expansion in the recycled water delivery system by 2035, allowing full use of the system by that time. Recycled water demand by sector is shown in Table 3.13-13.
Table 3.13-13: Summary of Potential Recycled Water Demand by Sector Utility land-use classification Potable offset demand1 (AFY) Buildout demand2 (AFY) Single-family Residential – 22.8
Multi-family Residential – 41.8
Commercial 3.4 49.7
Industrial 4.7 209.9
Institutional/Governmental 101.9 127.4
Landscape 69.4 119.5
Open Space – –
Watson Ranch – 253.2
Recreation – 204.3
Agricultural 68.1 173.2
Total 24.7 1,201.9
Notes:
AFY = acre-feet per year 1 Projected demand used in WSA analysis (Table 3.13-7) are lower than the numbers shown here in order to provide a conservative estimate for future demand. 2 Buildout demand for Institutional/Governmental assumes the American Canyon High School will halve existing demand by fixing suspected leaks in irrigation system.
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City of American Canyon—Givannoni Logistics Center Project Draft EIR Utilities and Service Systems
FirstCarbon Solutions 3.13-31
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-13 Utilities.docx Conclusion
In summary, the analysis in the WSA shows that the City’s water supply is sufficient to meet projected demand, in all years and under all normal-, dry-, and multi-dry-year scenarios. The analysis shows that demand will exceed supply during some dry years, but the City will still be able to meet demand through the use of carryover SWP water or through some combination of carryover SWP water, Advanced Table A Water, demand reductions, and/or additional purchases on the open market. In addition, recycled water supply in the City is available to meet existing and projected demand and available in sufficient volume to support non-potable uses at the project site. Use of recycled water at the site will increase the City’s utilization of this supply. Impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is required.
Level of Significance After Mitigation
Less than significant impact.
Wastewater
Impact USS-2: The proposed project would not create a need for new or expanded wastewater collection or treatment facilities.
Impact Analysis
Phases 1 and 2
The proposed project would be served by City of American Canyon for wastewater collection and treatment. Table 3.13-14 estimated the proposed project’s wastewater generation using rates provided by the City’s Sewer Master Plan. The proposed project would generate 402,500 gallons of effluent per day (0.41 mgd) at buildout.
Table 3.13-14: Wastewater Generation Estimate
Developed Area Wastewater Generation Rate Daily Wastewater Generation 161 acres 2,500 gallons/day/acre 402,500 gallons (0.41) mgd) Notes:
mgd = million gallons per day
Sources: GHD 2016; FirstCarbon Solutions (FCS) 2021.
Phase 1 of the proposed project would generate 276,800 gallons per day (0.28 mgd) and Phase 2 would generate 125,700 gallons (0.13 mgd). Wastewater effluent generation would increase incrementally as each building comes online; there would not be a sudden influx of 0.41 mgd into the City’s sewer system.
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-13 Utilities.docx The proposed project would connect to both an existing 12-inch diameter sewer line within Green Island Road and a future sewer line within the Devlin Road extension. Both lines convey effluent to the Green Island Road Sanitary Pump Station and ultimately the City’s Water Reclamation Facility.
The Water Reclamation Facility has an existing design capacity of 2.5 mgd. In the 2008 Interim Facilities Plan for the Water Recycling Plant, a phased improvement plan is outlined to increase the plant capacity over time to 4.0 mgd. The proposed project’s wastewater generation of 0.41 mgd would represent 16 percent of the existing treatment capacity and 10 percent of the future capacity.
The Water Reclamation Facility would treat effluent and either reclaim it for beneficial use or discharge it to the Napa River. As such, existing and planned treatment capacity would be sufficient to serve the proposed project. Impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Storm Drainage
Impact USS-3: The proposed project would not result in a need for new or expanded off-site storm drainage facilities.
Impact Analysis
Phases 1 and 2
The proposed project would result in the development of 2.4 million square feet of high-cube warehouse uses on 161 acres of the project site. The remaining 44.8 acres would be preserved as open space. Thus, the proposed project would increase the amount of impervious surface coverage on the project site and would create the potential for increased runoff leaving the project site that may create potential flooding conditions in downstream waterways.
The proposed project would provide 110,766 square feet (2.6 acres) of storm drainage retention onsite. A network of underground piping ranging from 12- to 48-inches in diameter would convey runoff to bioretention and detention basins in the northern portion of the property.
In accordance with applicable provisions of Section C.3 of the San Francisco Bay RWQCB Municipal Regional Permit (Order No. R2-2015-0049, NPDES Permit No. CAS612008) (or more recent permit) as required under Mitigation Measure (MM) HYD-1b, the proposed project would implement LID stormwater management methods into the on-site storm drainage system consisting of rainwater harvesting and use, infiltration, evapotranspiration, or biotreatment.
Collectively, these measures would serve to slow, reduce, and meter the volume of runoff leaving the project site and ensure that downstream storm drainage facilities are not inundated with 712
City of American Canyon—Givannoni Logistics Center Project Draft EIR Utilities and Service Systems
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-13 Utilities.docx project-related stormwater such that new or expanded facilities would be required. Impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Solid Waste
Impact USS-4: The proposed project’s solid waste would not create a need for additional landfill capacity.
Impact Analysis
Phases 1 and 2
This impact discussion assesses whether the proposed project would be served by a landfill with adequate capacity or comply with federal, State, and local statutes and regulations related to solid waste. Solid waste would be generated by construction and operational activities. Each is discussed as follows.
Construction Waste
The proposed project would result in the construction of 2.4 million square feet of commercial and industrial uses. Using a nonresidential construction waste generation rate published by the United States Environmental Protection Agency (EPA), an estimate of the total construction debris generated by the proposed project is provided in Table 3.13-15.
Table 3.13-15: Construction Solid Waste Generation
Waste Generation Rate Square Feet
Construction Waste Generation
Tons Cubic Yards
3.89 pounds/square foot 2.4 million 4,668 6,536
Notes:
1 ton = 2,000 pounds; 1 ton = 1.4 cubic yards
Source: United States Environmental Protection Agency (EPA) 1998; FirstCarbon Solutions (FCS) 2021.
Development of the proposed project would generate an estimated 6,536 cubic yards of construction debris. This waste volume represents less than 0.01 percent of the 38.8 million cubic yards of remaining capacity at the Potrero Hills Landfill. Moreover, the values shown in the table do not adjust construction solid waste generation to account for C&D debris recycling that would serve 713
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Therefore, short-term construction impacts on landfill capacity would be less than significant.
Operational Waste
Table 3.13-16 summarizes the proposed project’s operational waste generation based on rates provided by Cal Recycle.
Table 3.13-16: Operational Solid Waste Generation
Waste Generation Rate Square Feet
Operational Waste Generation
Tons Cubic Yards
4.8 pounds/square foot 2.4 million 5,760 8,064
Notes:
1 ton = 2,000 pounds; 1 ton = 1.4 cubic yards
Source: California Department of Resources Recycling and Recovery (CalRecycle); FirstCarbon Solutions (FCS) 2021.
The proposed project would generate an estimated 8,064 cubic yards of operational solid waste on an annual basis at buildout. This waste volume represents less than 0.01 percent of the 38.8 million cubic yards of remaining capacity at the Potrero Hills Landfill. Moreover, the values shown in the table do not adjust operational solid waste generation to account for recycling and waste reduction activities that would serve to divert waste from the landfill. Therefore, long-term operational impacts on landfill capacity would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
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City of American Canyon—Givannoni Logistics Center Project Draft EIR Cumulative Effects
FirstCarbon Solutions 4-1
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec04-00 Cumulative Effects.docx CHAPTER 4: CUMULATIVE EFFECTS
4.1 - Introduction
California Environmental Quality Act (CEQA) Guidelines Section 15130 requires the consideration of cumulative impacts within an Environmental Impact Report (EIR) when a project’s incremental effects are cumulatively considerable. According to CEQA “. . . the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects” (CEQA Guidelines § 15065[a][3]). In identifying projects that may contribute to cumulative impacts, CEQA allows the use of a list of past, present, and reasonably anticipated future projects that have the potential to result in related or cumulative impacts, including those outside of the control of the lead agency.
In accordance with CEQA Guidelines Section 15130(b), “. . . the discussion of cumulative impacts shall reflect the severity of the impacts and their likelihood of occurrence, the discussion need not provide as great [a level of] detail as is provided for the effects attributable to the project alone.” The discussion should be guided by standards of practicality and reasonableness, and it should focus on the cumulative impact to which the identified other projects contribute rather than on the attributes of other projects that do not contribute to the cumulative impact.
In general, the cumulative study area for each particular environmental topic is defined based on what is reasonable given the environmental resource under analysis. For example, some environmental resource topics are naturally broad in their impact while others are localized.
Cumulative air quality effects, for instance, considers the cumulative effect on the entire Air Basin, whereas cumulative geological hazard impacts generally define the cumulative study area as the project site and potentially projects in the immediate vicinity that may combine to result in a cumulative geological hazard impact. With these qualifications, the list of related past, present, and probable future set forth in Table 4-1 below (Cumulative Projects) extends to the entire City of American Canyon, though some resources require a larger cumulative study area and some a smaller area.
Table 4-1: Cumulative Projects
Jurisdiction Project Location Characteristics Status
City of
American
Canyon
Pacific Gas and Electric
Company Napa Regional
Center
500 Boone Road 100,668-square-foot
maintenance and operations
center on 24.5 acres
Pending
Devlin Road Segment H Project Site 3,084-lineal-foot extension of Devlin Road between Green
Island Road to Boone Road;
Includes Napa Valley Vine Trail
Under
construction
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec04-00 Cumulative Effects.docx Jurisdiction Project Location Characteristics Status
Green Island Road
Widening
Green Island Road
between State
Route (SR) 29 and a
cul-de-sac
Reconstruction of roadway;
Addition of a two-way left-turn
lane, curb, gutter, sidewalks;
Construction of the Napa
Valley Vine Trail
Approved; Not
constructed
Napa-Vallejo Waste
Management Authority
Construction and
Demolition Debris
Recycling Facility
South Kelly
Road/Devlin Road
(southwest
quadrant)
Enclosed construction and
demolition debris recycling
facility on 9 acres
Approved; Not
constructed
Napa Airport Corporate
Center
South Kelly
Road/Devlin Road
(southeast
quadrant)
300,000-square-foot business
park on 35 acres
Approved; Not
constructed
Commerce Court
Distribution Centers
Commerce Court Two warehouses (224,593
square feet and 217,294
square feet) on 20.56 acres
Pending
Sentinels of Freedom
Property
West of Napa
Logistics; South of
Napa County
Airport
Two warehouses (224,593
square feet and 217,294
square feet) on 20.56 acres
Pending
Watson Ranch Specific
Plan
East of Napa
Junction
1,253 dwelling units; 50
live/work units; 93,500-squarefeet commercial; 100-room hotel; 600-student school
Under
construction
Broadway District
Specific Plan
SR-29 corridor
from the southern
city limit to Green
Island Road
1,200 dwelling units; 840,000
square feet of nonresidential
uses within 300 acres
Under
Construction
Source: City of American Canyon 2021.
4.2 - Cumulative Impact Analysis
The cumulative impact analysis below is guided by the requirements of CEQA Guidelines Section 15130. Key principles established by this section include:
• A cumulative impact only occurs from impacts caused by the proposed project together with other projects. An EIR should not discuss impacts that do not result from the proposed project.
• When the combined cumulative impact from the increment associated with the proposed project and other projects is not significant, an EIR need only briefly explain why the impact is not significant; detailed explanation is not required.
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City of American Canyon—Givannoni Logistics Center Project Draft EIR Cumulative Effects
FirstCarbon Solutions 4-3
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec04-00 Cumulative Effects.docx • An EIR may determine that a project’s contribution to a cumulative effect impact would be rendered less than cumulatively considerable if a project is required to implement or fund its fair share of mitigation intended to alleviate the cumulative impact.
The cumulative impact analysis that follows relies on these principles as the basis for determining the significance of the proposed project’s cumulative contribution to various impacts.
4.2.1 - Aesthetics, Light, and Glare
The geographic scope of the cumulative aesthetics, light, and glare analysis is the 0.25-mile radius surrounding the project site. This is the area within view of the project site and, therefore, the area most likely to experience cumulative changes in visual character or experience cumulative light and glare impacts.
Several of the projects listed in Table 4-1 are immediately adjacent to or within 0.25 mile of the project site (e.g., Napa Logistics Park, Napa Airport Corporate Center, Devlin Road Transfer Station Construction and Demolition Debris Recycling Facility, the Devlin Road Extension, etc.).
The project site and the surrounding area have long been planned to accommodate large industrial and warehouse uses and are isolated and separate from the residential areas of the City. The existing surrounding uses are large industrial uses. The City of American Canyon General Plan designates the project site as “Industrial,” and the American Canyon Zoning Ordinance zones the project site as “General Industrial.” Both land use designations permit the types of end uses envisioned by the proposed project and other existing, approved, and reasonably foreseeable future developments.
Although the development of the proposed project would fundamentally change the visual character of the project site, it would be compatible with surrounding industrial uses and would be consistent with the City of American Canyon General Plan land use designation for the project site. Because the proposed project would preserve 48 acres of the project site that contain No Name Creek and associated wetlands, this area would continue to provide a visual buffer between the industrial uses and the undeveloped marsh area near the Napa River. The project site would feature attractive landscaping consisting of trees, shrubs, and groundcover. Landscaping would be installed along internal roadways, around the buildings, and in the parking areas and would be approved and installed at the time of construction of each building. Design Permits would be required from the City to approve the specific building and site design on each lot, including building height.
Furthermore, due to its location, it would not degrade any views of a scenic vista such as the Napa River or Sulphur Springs Hills. Other past projects, present projects under construction, and reasonably foreseeable projects in the surrounding area would be subject to similar landscaping and design requirements. Therefore, the proposed project, in conjunction with other past, present, and reasonably foreseeable projects, would not result in cumulatively significant aesthetic impacts.
The past, present, and reasonably foreseeable developments near the project site have contributed to—and would continue to contribute to—ambient light and glare in the project vicinity. The proposed project would install new sources of light and glare on the project site from exterior building lighting, security lighting, and lights and glare associated with vehicles accessing the project 717
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec04-00 Cumulative Effects.docx site. Mitigation Measure (MM) AES-3 requires new exterior lighting fixtures to employ full cut-off fixtures to direct light downward and eliminate spillage. Other past, present, and reasonably foreseeable future developments in the project vicinity that involve the installation of new exterior lighting fixtures have been and would be required to implement similar standard measures to prevent light spillage. Therefore, the proposed project, in conjunction with other past, present, and reasonably foreseeable projects in the applicable geographic area, would not have a cumulatively significant impact related to light and glare.
4.2.2 - Air Quality
The geographic scope of the cumulative air quality analysis is the San Francisco Bay Area Air Basin, which covers all or portions of the counties of Alameda, Contra Costa, Marin, Napa, San Francisco, San Mateo, Santa Clara, Sonoma, and Solano. Air quality is impacted by topography, dominant air flows, atmospheric inversions, location, and season; therefore, using the Air Basin represents the area most likely to be impacted by air emissions. The Bay Area Air Quality Management District (BAAQMD) CEQA Guidelines cumulative significance criteria are used in the cumulative analysis of air quality.
The Air Basin is currently designated as nonattainment for the State and federal ozone and PM2.5 standards and the PM10 State standards. While an air quality plan exists for ozone, none currently exists for particulate matter. A project would be judged to conflict with or obstruct implementation of the regional air quality plan if it would result in substantial new regional emissions not foreseen in the air quality planning process. Regional emissions forecasts in the air quality plan are based on population and employment forecasts based on City and County General Plans. The proposed project is consistent with land use designations and applicable goals and policies of the American Canyon General Plan, site zoning, and other applicable land use regulatory documents. As such, the proposed project would be considered planned growth. The proposed project would not result in a substantial unplanned increase in population, employment, or regional growth or in Vehicle Miles Traveled (VMT) and would not conflict with or obstruct implementation of the air quality plan in this regard.
Additionally, the proposed project would meet all of the applicable Land Use Measures and Energy and Climate Measures contained in the BAAQMD’s Clean Air Plan. For example, the proposed project would not preclude extension of a transit line or bike path, propose excessive parking beyond parking requirements, or otherwise create an impediment or disruption to implementation of any air quality plan control measures.
In developing thresholds of significance for air pollutants, BAAQMD established numerical thresholds for determining when a project‘s individual contributions would be cumulatively considerable. If a project does not exceed the identified significance thresholds, its emissions would not be cumulatively considerable, resulting in less than significant air quality impacts to the region‘s existing air quality conditions. The proposed project would emit operational criteria pollutant emissions (reactive organic gases and oxides of nitrogen) at levels that would exceed the BAAQMD CEQA Guidelines and significance thresholds. Mitigation is proposed requiring the implementation of criteria pollutant emissions reduction measures; however, mitigation would not reduce these 718
City of American Canyon—Givannoni Logistics Center Project Draft EIR Cumulative Effects
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With implementation of fugitive dust control measures, the proposed project would not result in any localized construction fugitive dust impacts. The proposed project was not found to result in any CO hotspots or project-level health risk impacts to sensitive receptors or to create objectionable odors affecting a substantial number of people. Therefore, the proposed project would not contribute to any potential significant cumulative significant impact related to localized criteria pollutant impacts from fugitive dust, CO, or objectionable odors.
As noted above, the proposed project would emit operational criteria pollutant emissions (reactive organic gases and oxides of nitrogen) at levels that would exceed the BAAQMD 2010 CEQA Guidelines and significance thresholds. Therefore, the proposed project would contribute to a cumulatively significant and unavoidable regional air quality impact in regard to criteria pollutants.
As noted above, BAAQMD’s established numerical thresholds for individual projects are set at levels determined to represent cumulatively considerable emissions. Since the proposed project’s health risk impacts and PM2.5 concentration at sensitive receptors are below these levels under the BAAQMD criteria, the proposed project would not result in a cumulatively considerable contribution to any potentially significant cumulative impact. Nonetheless, because of emissions from existing nearby projects, this EIR concludes that a significant cumulative impact would occur.
4.2.3 - Biological Resources
The geographic scope of the cumulative biological resources analysis is a 0.5-mile radius of the project site. The project site is located at the transition between urban development and the marshes associated with the Napa River; accordingly, habitats in these areas tend to be disrupted and impacts would be localized.
The proposed project has the potential to impact special-status plant species and several specialstatus bird species, including Swainson’s hawk, golden eagle, northern harrier, and burrowing owl.
However, through the implementation of MM BIO-1a through MM BIO-2e, impacts to these species as a result of the development of the proposed project would be reduced to less than significant levels by requiring pre-construction surveys for these species and establishing buffer zones around any active nests. Although there would be loss of foraging habitat, the cumulative loss of this resource would not be considerable due to the abundance of habitat in the American Canyon area.
These mitigation measures would be consistent with other mitigation measure implemented for other projects within the local vicinity of the proposed project including the Devlin Road project and the Green Island Road Reconstruction and Widening project. With the implementation of these mitigation measures any potentially significant cumulative impacts by the probable future projects in Table 4-1, together with the proposed project, would be reduced to less than significant levels.
The proposed project would impact approximately 0.496-acres of palustrine emergent wetlands.
Plans for wetland mitigation, including the preservation of an approximately 44.8-acre Wetland 719
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The development of Phase 1 of the proposed project would impact 0.496 acres of palustrine emergent wetlands considered waters of the State under the Porter-Cologne Water Quality Control Act as well as 0.004 acres of palustrine emergent wetlands considered waters of the United States.
As described in MM BIO-1a, these impacts would require that the applicant apply for and obtain a Nationwide Permit from the United States Army Corps of Engineers (USACE) and a Section 401 Water Quality Certification from the San Francisco Bay Regional Water Quality Control Board (RWQCB) for discharge within 0.004 acres of wetlands. The applicant would also need to apply for and obtain a separate Waiver of Waste Discharge from the San Francisco Bay RWQCB for impacts to 0.496 acres of WOS.
The development of Phase 2 of the proposed project would impact approximately 3.7 acres of wetlands considered both waters of the United States and State. These impacts would require that the applicant submit a separate application for an Individual Permit from USACE to include a plan to compensate for wetland losses as well as a detailed alternatives analysis under the Section 404(b)(1) guidelines to include a detailed evaluation of both on-site and off-site alternatives for the proposed project. Similar to Phase 1, these impacts would also require a Clean Water Act Section 401 Water Quality Certification and a Waiver of Waste Discharge Requirements from the San Francisco Bay RWQCB, as described in MM BIO-1b.
As described in MM BIO-1c, to compensate the loss of these wetlands an approximately 44.8-acre Wetland Preserve fronting the northern boundary of the project site would preserve 7.71 acres of existing wetlands and create approximately 4.7 acres of new wetlands within the Wetland Preserve.
The creation of this Wetland Preserve and new wetlands would help offset any significant cumulative impacts to jurisdictional wetlands by the proposed project or other projects listed in Table 4-1 and reduce them to less than significant levels overall.
The wildlife corridor along No Name Creek would remain unaffected by the development of the proposed project and would be entirety contained and incorporated into the Wetland Preserve.
Therefore, the proposed project would not result in substantial change in animal populations at the site, nor would it cause a fish or wildlife population to drop below self-sustaining levels. Additionally, the requirement for the implementation of a Stormwater Pollution Prevention Plan (SWPPP) would assure that water quality of nearby waterways is not affected by on-site construction activities. This mitigation measure would be consistent with other mitigation measure implemented for other projects listed in Table 4-1, including the Devlin Road project and the Green Island Road Reconstruction and Widening project. As a result, the proposed project would not result in greater cumulative impacts to potential wildlife corridors.
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec04-00 Cumulative Effects.docx The development of the proposed project does have the potential to impact nesting birds if construction includes the removal of vegetation occurs during the breeding season (February 1 to August 31). However, the implementation of MM BIO-4a would avoid direct and indirect impacts to nesting birds by requiring pre-construction nesting bird surveys and establishing buffer zones around any active nests. This mitigation measures would be consistent with other mitigation measure implemented for other projects listed in Table 4-1, including the Devlin Road project and the Green Island Road Reconstruction and Widening project. With the implementation of MM BIO-4a, any cumulative impacts by the proposed project would be reduced to less than significant levels.
4.2.4 - Cultural Resources
The geographic scope of the cumulative cultural resources analysis is a 0.5-mile radius of the project site. Cultural resource impacts tend to be localized because the integrity of any given resource depends on what occurs only in the immediate vicinity around that resource, such as disruption of soils; therefore, in addition to the project site (including the off-site construction areas), the area near the project site would be the area most affected by project activities (generally within a 500- foot radius).
No listed historic resources are within the project boundaries. Thus, none would be adversely impacted by project construction, therefore no cumulative impacts would occur within the City of American Canyon or its immediate vicinity. Archaeological resource impacts tend to be localized, because the integrity of any given resource depends on what occurs in the immediate vicinity around that resource, such as disruption of soils; therefore, in addition to the project site itself, the area near the project site would be the area most affected by project activities (generally within a
0.5-mile radius). Given that the proposed project would not have a known, direct impact on any known archaeological resources, cumulative project impacts are less than significant. Construction activities associated with cumulative development projects in the project vicinity may have the potential to encounter undiscovered cultural resources. These cumulative projects listed in Table 4-1 would be required to mitigate for impacts through compliance with applicable federal and State laws governing cultural resources.
Additionally, the implementation of standard construction mitigation measures would ensure undiscovered cultural resources are not adversely affected by project-related construction activities, which would prevent the destruction or degradation of potentially significant cultural resources in the project vicinity. Given the standard archaeological resources mitigation measures that would apply to the cumulative projects listed in Table 4-1 (including the proposed project), the cumulative impact related to archaeological resources would be less than significant with mitigation (MM CUL2a, 2b, and 3) Although there is the possibility that previously undiscovered tribal cultural resources (TCRs) could be encountered by subsurface earthwork activities associated with the cumulative projects, the implementation of construction mitigation measures (MM CUL-4) would ensure that undiscovered TCRs are not adversely affected by cumulative project-related construction activities. Given the low potential for disruption, the standard conditions of approval, and mitigation measures that cumulative projects would be required to implement, the proposed project, in conjunction with 721
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With the implementation of MM CUL-2a, MM CUL-2b, MM CUL-3, and MM CUL-4, the proposed project would not result in a significant cumulative impact to cultural resources in the City of American Canyon or surrounding area.
4.2.5 - Geology, Soils, and Seismicity
The geographic scope of the cumulative geology, soils, and seismicity analysis is the project vicinity.
Adverse effects associated with geologic, soil, and seismic hazards tend to be site specific, because each project site has its own geologic and soils conditions, and each project has its own design characteristics, localized within the area near the project site most affected by project activities (generally within a 0. 5-mile radius).
Past, present, and future development projects in the project vicinity have the potential to exacerbate exposure to seismic hazards. The West Napa Fault bisects the project site and, thus, the project site may be susceptible to fault rupture during a seismic event. MM GEO-1a requires the project applicant to retain a qualified geotechnical consultant to prepare a fault investigation study and ensure project plans comply with all required setback requirements. Additionally, the project site may be subject to strong ground shaking during an earthquake; thus, MM GEO-1b requires the project applicant to retain a qualified geotechnical consultant to prepare a design-level geotechnical study and implement all California Building Standards Code applicable requirements into project plans. Other nearby past, present, and reasonably foreseeable development projects have been and may exacerbate exposure to similar potential seismic hazards and would be required to comply with the relevant State and local laws designed to mitigate seismic hazards and mitigation measures imposed under CEQA. Therefore, the proposed project in conjunction with other cumulative development would not expose people or structures to substantial adverse effects, including the risk of loss, injury, or death in the event of a major earthquake; fault rupture; ground shaking; seismicrelated ground failure; landslide; or liquefaction.
Regarding soil erosion, development activities could lead to increased erosion rates on-site soils, which could cause unstable ground surfaces and increased sedimentation in nearby streams and drainage channels. MM HYD-1a requires implementation of standard stormwater pollution prevention measures to ensure earthwork activities do not result in substantial erosion off-site. This mitigation, in turn, would have to comply with the National Pollution Discharge Elimination System (NPDES) stormwater permitting program, which regulates water quality originating from construction sites. The NPDES program, which governs projects statewide (and nationwide), requires the preparation and implementation of Stormwater Pollution Prevention Programs for construction activities that disturb more than 1 acre and the implementation of Best Management Practices (BMPs) that ensure the reduction of pollutants during stormwater discharges, as well as compliance with all applicable water quality requirements. The proposed project would be required to comply with these regulations, as have and would other nearby past, present, and reasonably foreseeable development projects. Therefore, the proposed project in conjunction with other nearby cumulative development would not have a cumulatively significant impact associated with erosion. 722
City of American Canyon—Givannoni Logistics Center Project Draft EIR Cumulative Effects
FirstCarbon Solutions 4-9
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec04-00 Cumulative Effects.docx The project site contains native soils that have shrink-swell characteristics, which may exacerbate exposure of project structures to expansive soil hazards. MM GEO-1b requires the project applicant to retain a qualified geotechnical consultant to prepare a design-level geotechnical study and incorporate all California Building Standards Code applicable requirements into project plans. Other nearby past, present, and reasonably foreseeable development projects could be exposed to expansive soil hazards and, therefore, have been and would be required to implement similar mitigation measures based on State and local regulations and CEQA requirements. As such, the proposed project, in conjunction with other nearby past, present, and reasonably foreseeable projects, would not have a cumulatively significant impact associated with expansive soils.
Paleontological resources resource impacts tend to be localized, because the integrity of any given resource depends on what occurs in the immediate vicinity around that resource, such as disruption of soils; therefore, in addition to the project site itself, the area near the project site would be the area most affected by project activities (generally within a 0.5-mile radius). Given that the proposed project would not have a known, direct impact on any known paleontological resources, cumulative project impacts are less than significant. Construction activities associated with cumulative development projects in the project vicinity may have the potential to encounter undiscovered paleontological resources. These cumulative projects listed in Table 4-1 would be required to mitigate for impacts through compliance with applicable federal and State laws governing paleontological resources.
Therefore, the proposed project, in conjunction with other past, present, and reasonably foreseeable planned and approved projects in the vicinity, would not have a cumulatively significant impact related to geology, soils, and seismicity.
4.2.6 - Greenhouse Gas Emissions
The geographic scope of the cumulative greenhouse gas (GHG) emissions analysis is the San Francisco Bay Area Air Basin, which covers all or portions of the counties of Alameda, Contra Costa, Marin, Napa, San Francisco, San Mateo, Santa Clara, Sonoma, and Solano. In a larger sense, however, the relevant geographic area is the entire Earth, as explained by the California Supreme Court. “[B]ecause of the global scale of climate change, any one project’s contribution is unlikely to be significant by itself.” (Center for Biological Diversity v. Department of Fish and Wildlife (2015) 62 Cal.4th 204, 219.) “’With respect to climate change, an individual project's emissions would most likely not have any appreciable impact on the global problem by themselves, but they would contribute to the significant cumulative impact caused by greenhouse gas emissions from other sources around the globe. The question therefore becomes whether the proposed project’s incremental addition of greenhouse gases is “cumulatively considerable” in light of the global problem, and thus significant.’” (Id., quoting Crockett, Addressing the Significance of Greenhouse Gas Emissions Under CEQA: California's Search for Regulatory Certainty in an Uncertain World (July 2011) Golden Gate U. Envtl. L.J. 203, 207–208).)
The proposed project would emit new GHG emissions, as would other past, present, and reasonably foreseeable projects within the Air Basin. The BAAQMD has not set a numerical threshold of significance for GHG emissions from construction. The BAAQMD has a numerical threshold of 723
City of American Canyon—Givannoni Logistics Center Project Cumulative Effects Draft EIR
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec04-00 Cumulative Effects.docx significance for GHG emissions from operation as well as a threshold on a per-service population basis. Although the proposed project would comply with relevant elements of the City of American Canyon Energy Efficiency Climate Action Plan (EECAP), such as exceeding the Title 24 standards for new construction, it exceeds both of the BAAQMD operational GHG thresholds and as such could be considered cumulatively significant. As the proposed project also includes a potential new stationary source, GHG emissions from the stationary source were compared to the BAAQMD significance threshold for GHG from stationary sources. The proposed stationary source emissions exceed the relevant BAAQMD significance threshold and as such could be considered cumulatively significant.
Therefore, the proposed project, in conjunction with other past, present, and reasonably foreseeable future development in the Air Basin and around the world, would result in a significant cumulative GHG emissions impact. The proposed project’s contribution would be cumulatively considerable and thus significant in and of itself.
4.2.7 - Hazards and Hazardous Materials
For most topics the geographic scope of the cumulative hazards and hazardous materials analysis is the project area. Adverse effects of hazards and hazardous materials tend to be localized; therefore, the area near the project area would be most affected by project activities. For the transport of hazardous materials, the geographic scope includes local and regional transportation facilities.
The proposed project would not result in any significant impacts associated with hazardous materials because there is no evidence of contamination from past uses, and any use or storage of hazardous materials during construction or operations would be subject to compliance with regulatory requirements and mitigation measures. Accordingly, all project-related impacts associated with hazardous materials were found be less than significant. As with the proposed project, other past, present, and reasonably foreseeable projects have been and would continue to be required to comply with applicable federal, State, and local regulatory requirements regarding the transport of hazardous materials, clean up of hazardous materials, and the use and storage of hazardous materials during construction and operation. Additionally, hazardous material impacts tend to be localized to individual project sites. Consequently, no significant cumulative impacts would occur.
The proposed project would create a wetland preserve in the northern portion of the project site.
Mitigation is proposed requiring the implementation of a wildlife management plan to minimize the avian attractant potential of the Wetlands Preserve to avoid creating hazards to aviation. Other past, present, and reasonably foreseeable projects would not create a wildlife attractant hazard for the Napa County Airport, because required compliance with the Napa County Airport Land Use Compatibility Plan and Federal Aviation Administration (FAA) regulations would ensure inappropriate land uses do not locate near the airport. Additionally, stormwater and landscaping features of the proposed project and other land uses would include management plans to avoid or reduce the potential for wildlife hazards. Consequently, no significant cumulative impacts would occur.
Therefore, the proposed project, in conjunction with other past, approved, and reasonably foreseeable future projects, would not have a cumulatively significant impact related to hazards and hazardous materials.
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City of American Canyon—Givannoni Logistics Center Project Draft EIR Cumulative Effects
FirstCarbon Solutions 4-11
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4.2.8 - Hydrology and Water Quality
The geographic scope of the cumulative hydrology and water quality analysis is the No Name Creek watershed, which generally encompasses the area within 0.5 mile of the project site. Hydrologic and water quality impacts tend to be localized to a watershed; therefore, the area within the No Name Creek watershed would be most affected by project activities.
The proposed project would involve short-term construction and long-term operational activities that would have the potential to degrade water quality in downstream water bodies. These activities are subject to regulatory requirements that would ensure no significant adverse impacts would occur. MM HYD-1a and MM HYD-1b would require implementation of various construction and operational water quality control measures that would prevent the release of pollutants into downstream waterways. These measures include preparation of a Stormwater Pollution Prevention Plan (SWPPP) in accordance with the requirements of the statewide Construction General Permit and compliance with the Municipal Regional Permit, including implementation of BMPs and Low Impact Development (LID) features.
Other past, present, and reasonably foreseeable projects that propose new development have been and would be required to implement similar mitigation measures in accordance with applicable laws and regulations. The combined implementation of construction and operation water quality control measures by other past, present, and reasonably foreseeable projects would avoid, or reduce to a less than significant level, any related cumulative impacts on downstream waterways including the Napa River.
All other project-related hydrology impacts were found to be less than significant and did not require mitigation (e.g., groundwater and drainage). Other past, present, and reasonably foreseeable projects that result in groundwater and drainage impacts have been and would be required to comply with applicable laws and regulations designed to protect groundwater resources and ensure adequate drainage facilities are provided for all projects and include facilities to prevent and reduce runoff from development sites.
Therefore, the proposed project, in conjunction with other past, present, and reasonably foreseeable planned and approved projects in the vicinity, would not have a cumulatively significant impact related to hydrology and water quality.
4.2.9 - Land Use
The geographic scope of the cumulative land use analysis is the area within 1 mile of the project site.
Existing development in this area is predominantly industrial uses, including the airport. Projects under construction include the Napa Logistics Park Project, which is approved for warehouse and other similar uses. Foreseeable future development in the area includes the Napa Airport Corporate Center and the Devlin Road Transfer Station Construction and Demolition Debris Facility.
The proposed project would be consistent with the American Canyon General Plan, American Canyon Zoning Ordinance, and the Napa County Airport Land Use Compatibility Plan because its proposed uses are allowed under these plans. The existing uses in the area are generally industrial 725
City of American Canyon—Givannoni Logistics Center Project Cumulative Effects Draft EIR
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec04-00 Cumulative Effects.docx and related compatible uses. Projects under consideration in the area and reasonably foreseeable future projects would be required to be consistent with the General Plan, the City’s Zoning Ordinance, and the Airport Land Use Compatibility Plan. Additionally, the proposed project and other nearby development would be and have been required to implement wildlife management plans to ensure compatibility with airport operations. Consequently, the proposed project, in conjunction with past, present, and reasonably foreseeable development, would not result in a cumulatively significant land use impact.
4.2.10 - Noise
The geographic scope of the cumulative noise analysis is the project vicinity, including surrounding sensitive receptors. Noise impacts tend to be localized; therefore, the area near the project site (approximately 0.25 mile) would be the area most affected by project activities. Furthermore, given the properties and the distance between other past, present, and reasonably foreseeable development projects (more than 0.5 mile away), project-related noise would not combine with other sources further away.
The proposed project’s construction noise levels may cause a temporary substantial increase in noise levels at nearby receptors. Mitigation is proposed that would require implementation of construction noise attenuation measures to reduce noise levels. Other projects in the project vicinity that could be under construction at the same time as the proposed project (such as Napa Logistics Park Phase 1 and Napa Corporate Center) could combine to expose nearby sensitive receptors to excessive construction noise from trucks and equipment. However, because noise is a localized phenomenon, the properties of noise are not additive, construction activities on these projects may not overlap, and all projects would be subject to the City’s noise ordinance requirements and mitigation measures, the proposed project, together with other past, present, and probable future projects, would not result in cumulatively significant construction noise impacts.
The proposed project’s construction and operational vibration levels would not exceed annoyance thresholds. Because vibration is a highly localized phenomenon, there would be no possibility for vibration associated with the proposed project to combine with vibration from other projects because of their distances from the project site. Therefore, the proposed project, together with other past, present, and probable future projects, would not result in cumulatively significant vibration impacts.
As discussed in Section 3.9, Noise, after mitigation, the proposed project’s vehicular trips would not make a substantial incremental contribution to ambient noise levels under baseline-with-project and future-with-project conditions. These noise levels account for existing vehicle trips as well as vehicle trips from future projects. Furthermore, the proposed project’s contribution to vehicular noise levels would not exceed the applicable thresholds of significance, which take into account existing noise levels as well as noise from trips associated with other planned or approved projects. Finally, because most of the other projects included within the scope of the transportation analysis are more than 1 mile from the project site, cumulative vehicular trips would be unlikely to add to roadway noise levels in the project vicinity. Thus, the proposed project would not combine with other projects to cause a cumulatively significant increase in ambient roadway noise. 726
City of American Canyon—Givannoni Logistics Center Project Draft EIR Cumulative Effects
FirstCarbon Solutions 4-13
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4.2.11 - Public Services and Utilities
The geographic scope of the cumulative public services analysis is the service area of each of the providers serving the proposed project. Because of differences in the nature of the public service and utility topical areas, they are discussed separately.
Fire Protection and Emergency Medical Services
The geographic scope of the cumulative fire protection and emergency medical services analysis is the American Canyon Fire Protection District service area, which consists of the American Canyon city limits.
The proposed project would result in the development of 2.4 million square feet of high-cube warehouse on the project site. The project site is located within 3.1 miles of the nearest fire station and is within an acceptable response time for fire protection (5 minutes or less). As such, the proposed project would not create a need for new or expanded fire protection facilities and would not result in a physical impact on the environment. Additionally, the proposed project would comply with all applicable requirements of the California Fire Code, including provision of adequate emergency access points, and it would be accessible to fire apparatus. Other past, present, and reasonably foreseeable development projects in the Fire District service area have been and would be reviewed for impacts on fire protection and emergency medical services and have been and would be required to address any potential impact with mitigation. Additionally, the Fire District plans for service needs consistent with existing demands and growth anticipated in the City planning documents. Therefore, the proposed project, in conjunction with other past, present, and reasonably foreseeable development, would not have a cumulatively significant impact related to fire protection and emergency medical services.
Police Protection
The geographic scope of the cumulative police protection analysis is the service area of the American Canyon Police Department, which consists of the American Canyon city limits.
The proposed project and other past, present, and reasonably foreseeable projects in the police service area have been and would continue to be reviewed for impacts on police services and also have been and would continue to be required to address any potential impact with mitigation.
Additionally, the police department plans for service needs consistent with existing demands and growth anticipated in the City planning documents. Therefore, the proposed project, in conjunction with other past, present, and reasonably foreseeable development, would not have a cumulatively significant impact related to police protection.
4.2.12 - Transportation
The geographic scope of the cumulative transportation analysis is on the nine-county San Francisco Bay Area region. VMT is evaluated and regulated at a regional level and, thus, the San Francisco Bay Area region is an appropriate geographical area.
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City of American Canyon—Givannoni Logistics Center Project Cumulative Effects Draft EIR
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec04-00 Cumulative Effects.docx Impact TRANS-1 concluded that the proposed project would not have a significant impact on the circulation system and, therefore, no mitigation would be necessary. As such, the proposed project would not have a cumulative considerable contribution in this regard. Impact TRANS-2 concluded that the proposed project would not have a significant impact on VMT because the proposed project would have a VMT rate of 16.24, well below the regional average of 23.00. As such, the proposed project would not have a cumulative considerable contribution in VMT.
With respect to Impact TRANS-3, the potential hazards from design features or incompatible uses are project site specific (e.g., site access, sight distance, etc.) and would not combine with other projects. The proposed project and other past, present, and reasonably foreseeable future projects have complied and must comply with local, standard requirements for transportation-related design features specifically adopted to avoid and reduce hazards from project design or the location of incompatible uses, thereby reducing the potential for significant cumulative impacts to less than significant levels. Therefore, no significant adverse cumulative impacts would result from the proposed project combined with past, present, and probable future projects.
With respect to Impact TRANS-4, the provision of adequate emergency access is site specific and would not combine with other projects. The proposed project and other past, present, and reasonably foreseeable future projects must comply with local, standard requirements for adequate emergency access specifically adopted to avoid or reduce the potential for inadequate access.
Furthermore, the proposed project and other projects would not have significant impacts on the performance of the study intersections and, therefore, it can be inferred that it would also not impair emergency response to the project vicinity. Therefore, no significant adverse cumulative impacts would result.
4.2.13 - Utilities and Service Systems
Water
The geographic scope of the cumulative potable water analysis is the City of American Canyon Public Works Department service area, which encompasses the American Canyon city limits.
The proposed project’s estimated demand is 23.9 acre-feet of potable water and 82.1 acre-feet of recycled water annually. The City of American Canyon 2015 Urban Water Management Plan (2015 UWMP) indicates that potable water demand and supplies would total 3,350 acre-feet and recycled water demand and supply would total 1,146 acre-feet in 2025. The proposed project’s demands would represent less than 1 percent of potable water supplies and 7 percent of recycled water supplies. Furthermore, the City of American Canyon’s 2015 UWMP estimates that sufficient water is available to meet the needs of the service area through the year 2040, which accounts for the City of American Canyon’s long-term growth assumptions. The City has adopted the Zero Water Footprint Policy that requires all new development to completely offset its potable water demand. This is accomplished by means including, but not limited to: replacing existing potable water use with recycled water use; securing new water supplies; or repairing infrastructure to eliminate existing losses of potable water. The proposed project is required to comply with this policy, as would other projects listed in Table 4-1 that are served by the City of American Canyon’s Water District. 728
City of American Canyon—Givannoni Logistics Center Project Draft EIR Cumulative Effects
FirstCarbon Solutions 4-15
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec04-00 Cumulative Effects.docx For those projects that are located within the City’s water service area and areas in the County that were included in the original water district service area, the 2015 UWMP anticipates adequate water supplies for all water year scenarios through 2040. These projects also would be required to demonstrate that they would be served with potable water service as a standard requirement of the development review process, and these projects may be required to implement water conservation measures and to meet the requirements of the Zero Water Footprint Policy. Furthermore, the proposed project does not require any off-site water facilities to be constructed and expanded and, thus, would not result in physical impacts on the environment from such activities. Therefore, the proposed project, in conjunction with other past, present, and reasonably foreseeable projects, would not have a cumulatively significant impact related to potable water supply.
Wastewater
The geographic scope of the cumulative wastewater analysis is the American Canyon Wastewater Treatment Plant service area, which encompasses the American Canyon city limits and areas within the Napa County Airport Industrial Park south of Fagan Creek.
The treatment plant has an existing design capacity of 2.5 million gallons per day (mgd) and the City has plans to increase it to 4.0 mgd over time. All future projects that are tributary to the American Canyon Wastewater Treatment Plant would be required to demonstrate that sewer service is available to ensure that adequate sanitation can be provided. The proposed project is estimated to generate 402,500 gallons of wastewater on a daily basis (0.41 mgd) at buildout. The proposed project’s estimated wastewater generation of 0.41 mgd per day would represent 10 percent of the average daily flow treated by the expanded Wastewater Treatment Plant.
The sewer flows assumed from the proposed project are significantly less than anticipated for industrial projects in previous City planning documents. The lower sewer flows are a direct result of the conservation activities that reduce water use and, in turn, reduce sewer flows. The original planning documents were drafted prior to the State passing all the conservations laws (2008-2010) and before the City defined the Zero Water Footprint Policy. Thus, conservation is the main reason for reduced sewer flows estimated in previous planning documents. The City has verified that the treatment plant has enough capacity to serve the planned development for Phases 1 and 2 of the proposed project, along with other projects that would be tributary to the Wastewater Treatment Plant. Therefore, the proposed project, in conjunction with other past, present, and reasonably foreseeable projects, would not have a cumulatively significant impact related to wastewater.
Storm Drainage
The City of American Canyon Public Works Department oversees municipal storm drainage within the American Canyon city limits. The municipal storm drainage system consists of ditches, inlets, basins, and underground piping that ultimately discharges flows into the Napa River. The City maintains a Storm Drainage Master Plan and engineering standards that guide development of the municipal storm drainage system.
All future development projects in the City are required to provide storm drainage facilities that collect and detain stormwater. The storm drainage facility shall include provisions for future 729
City of American Canyon—Givannoni Logistics Center Project Cumulative Effects Draft EIR
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec04-00 Cumulative Effects.docx upstream development and no development shall discharge at a rate that exceeds the capacity of any portion of the existing downstream system. Runoff from storms up to the 100-year return frequency are conveyed through storm facilities and disposed of in a manner that protects public and private improvements from flood hazards. The proposed project would install an on-site storm drainage system consisting of inlets, piping, and a series of detention basins. The peak discharge from the detention basin shall not exceed 90 percent of the undeveloped peak flow from the 24- hour, 100-year storm event. As such, the proposed project would ensure no net increase in stormwater would leave the project site during a peak storm event and would avoid cumulatively significant stormwater impacts to downstream waterways at times when capacity is most constrained. The proposed project would implement standard stormwater pollution prevention measures during construction to ensure downstream water quality impacts are minimized to the greatest extent possible. In addition, the proposed project would provide water quality measures to prevent pollution during project operations. Most past, and all present and reasonably foreseeable future, development must comply with these State and local requirements that ensure no significant adverse cumulative impacts would result. Therefore, the proposed project, in conjunction with other past, present, and reasonably foreseeable projects, would not have a cumulatively significant impact related to storm drainage.
Solid Waste
The geographic scope of the cumulative solid waste analysis is the City of American Canyon.
American Canyon Recology provides solid waste and recycling collection services to commercial customers in the City of American Canyon.
Many past and all present and reasonably foreseeable future development projects, which have or would generate construction and operational solid waste and, depending on the volumes and end uses, have been or would be required to implement recycling and waste reduction measures. The proposed project is anticipated to generate 6,536 cubic yards of solid waste during construction and 8,064 cubic yards annually during operations. For comparison purposes, the Potrero Hills Landfill has a remaining capacity of 38.8 million cubic yards. The proposed project’s construction and operational solid waste generation would represent less than 1 percent of the remaining capacity at this facility. As such, it appears that sufficient capacity would be available to serve the proposed project as well as existing and planned land uses in the City of American Canyon for the foreseeable future. Additionally, the nearby Devlin Road Transfer Station offers construction and demolition debris recycling and incentivizes such activities through pricing. Thus, it would be expected that some of the projects listed in Table 4-1 would take advantage of construction and demolition debris recycling, which would divert materials from the solid waste stream and contribute to conserving landfill capacity, thereby extending the operational life of Potrero Hills Landfill. Therefore, the proposed project, in conjunction with other past, approved, and reasonably foreseeable future projects, would not have a cumulatively significant impact related to solid waste. 730
City of American Canyon—Giovannoni Logistics Center Project Draft EIR Alternatives to the Proposed Project
FirstCarbon Solutions 5-1
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec05-00 Alternatives.docx CHAPTER 5: ALTERNATIVES TO THE PROPOSED PROJECT
5.1 - Introduction
In accordance with California Environmental Quality Act (CEQA) Guidelines Section 15126.6, this Draft Environmental Impact Report (Draft EIR) contains a comparative impact assessment of alternatives to the proposed project. The primary purpose of this section is to provide decisionmakers and the general public with a reasonable number of feasible project alternatives that could attain most of the basic project objectives, while avoiding or reducing any of the project’s significant adverse environmental effects. Important considerations for these alternatives analyses are noted below (as stated in CEQA Guidelines § 15126.6).
• An EIR need not consider every conceivable alternative to a project. • An EIR should identify alternatives that were considered by the lead agency, but rejected as infeasible during the scoping process.
• Reasons for rejecting an alternative include:
- Failure to meet most of the basic project objectives; - Infeasibility; or
- Inability to avoid significant environmental effects.
5.1.1 - Significant Unavoidable Impacts
The proposed project would result in the following significant unavoidable impacts:
• Consistency With Air Quality Management Plan: The proposed project would result in exceedances of regional emissions thresholds and, therefore, be inconsistent with the Bay Area Air Quality Management District (BAAQMD) regional air quality planning assumptions.
Mitigation is proposed requiring the implementation of feasible emissions reduction measures; however, these measures would not reconcile this inconsistency. Therefore, the significance after mitigation is significant and unavoidable. • Cumulative Criteria Pollutant Emissions Impacts: The project would result in a cumulatively considerable net increase of criteria pollutants for which the project region is nonattainment under an applicable federal or state ambient air quality standard. Mitigation is proposed requiring the implementation of air emissions reduction measures, but it would not fully reduce this impact to a level of less than significant. Therefore, the significance after mitigation is significant and unavoidable.
5.1.2 - Alternatives to the Proposed Project
The three alternatives to the proposed project analyzed in this section are as follows:
• No Project/No Development Alternative: The project site would remain undeveloped for the foreseeable future and no development would occur.
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City of American Canyon—Giovannoni Logistics Center Project Alternatives to the Proposed Project Draft EIR
5-2 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec05-00 Alternatives.docx • No Project/Existing General Plan Alternative: A 2.4-million-square-foot food and beverage processing facility would be developed on the project site. • Reduced Density Alternative: A 1.6-million-square-foot logistics center would be developed on the project site, which represents a 25 percent reduction in square footage relative to the proposed project. The layout and project boundaries would remain the same as the proposed project.
• Phase 1 Only Alternative: Phase 1 of the proposed project would be developed, which consists of approximately 1.1 million square feet of high-cube warehouse on 95 acres. Phase 2 would not be developed, and the remaining 113 acres would remain undeveloped.
Three alternatives to the proposed project are analyzed below. These analyses compare the proposed project and each individual project alternative. In several cases, the description of the impact may be the same under each alternative when compared with the CEQA Thresholds of Significance (i.e., both the project and the alternative would result in a less than significant impact).
The actual degree of impact may be slightly different between the proposed project and each alternative, and this relative difference is the basis for a conclusion of greater or lesser impacts.
5.2 - Project Objectives and Underlying Purpose
The underlying purpose of the proposed project is to develop industrially-zoned undeveloped land within the American Canyon city limits to its highest and best use.
As stated in Section 2, Project Description, the objectives of the proposed project are to:
1. Promote economic growth in American Canyon by attracting new industries.
2. Promote development that that generates net positive tax revenues for the City by generating more in new tax revenues than are consumed by City expenditures on services provided to the development.
3. Create new employment opportunities for residents of Napa County and the surrounding region.
4. Develop compatible land uses near the Napa County Airport in the interests of avoiding interference with aviation operations.
5. Improve American Canyon’s jobs-housing ratio by adding new employment opportunities.
6. Continue the orderly development of the Devlin Road corridor with a well-designed project.
7. Further the goals and policies of the City of American Canyon General Plan by developing land contemplated to support urban development to its highest and best use.
8. Preserve the most biologically sensitive portions of the project site as open space. 732
City of American Canyon—Giovannoni Logistics Center Project Draft EIR Alternatives to the Proposed Project
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9. Install circulation improvements along Green Island Road and Devlin Road that provide efficient ingress and egress to the proposed project while also ensuring these facilities operate at acceptable levels.
10. Promote public safety by incorporating security measures into the project design.
11. Mitigate impacts on the environment through implementation of feasible mitigation measures.
5.3 - Alternative 1—No Project/No Development Alternative CEQA Guidelines Section 15126.6(e) requires that an EIR evaluate a “No Project Alternative,” which is intended to allow decision-makers to compare the impacts of approving the proposed project with the impacts of not approving the proposed project. In cases where the project constitutes a land development project, the No Project Alternative is the “circumstance under which the project does not proceed.” For many projects, the No Project Alternative represents a “No Development” scenario, in which the project site remains in its existing condition and no development occurs for the foreseeable future. However, CEQA Guidelines Section 15126.6(e)(3)(B) establishes that “If disapproval of the project under consideration would result in predictable actions by others such as the proposal of some other project, this ‘no project’ consequence should be discussed.” In the interests of informed decision-making, this EIR shall consider both a No Project/No Development Alternative and a No Project/Existing General Plan Alternative.
Under the No Project/No Development Alternative, the project site would remain undeveloped for the foreseeable future.
5.3.1 - Impact Analysis
The project site would remain undeveloped for the foreseeable future. Accordingly, this alternative would avoid all of the proposed project’s significant impacts (including significant and unavoidable impacts), as well as the need to implement any mitigation measures.
5.3.2 - Conclusion
The No Project/No Development Alternative would avoid the proposed project’s significant and unavoidable impacts and would avoid any potential impacts related to all environmental topical areas. However, this alternative would not advance any of the project objectives, including those related to facilitating the development of land planned for business park/industrial uses to its highest and best use; positively contributing to the local economy; providing the City of American Canyon with a high-quality, employment-generating industrial development; and serving local and regional demand for manufacturing, logistics warehouse, and other industrial uses. Finally, it should be noted that the project site is zoned for industrial use, has been the subject of previous industrial development proposals, and is currently served with infrastructure suitable for this type of development. Thus, should the proposed project not advance, it would be expected that another industrial development proposal would be submitted.
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City of American Canyon—Giovannoni Logistics Center Project Alternatives to the Proposed Project Draft EIR
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5.4 - Alternative 2–No Project/Existing General Plan Alternative Under the No Project/Existing General Plan Alternative, the project site would be developed as 2.4 million square feet of food and beverage processing uses. This alternative would have the same development footprint as the proposed project, albeit with single buildings on either side of Devlin Road. The end user would be a large-scale manufacturer of locally sourced food and beverage products such fruits, vegetables, sauces, oils, specialty items, wine, and beer.
Table 5-1: No Project/Existing General Plan Alternative Scenario Total Acres Developed Acres End Use Square Feet No Project/Existing
General Plan Alternative 208 163 Food and beverage processing 2,400,000 Proposed Project 208 163 High-Cube
Warehouse 2,400,000
Difference – – – –
Source: FirstCarbon Solutions (FCS) 2021.
5.4.1 - Impact Analysis
Aesthetics, Light, and Glare
The No Project/Existing General Plan Alternative consists of developing 2.4 million square feet of food and beverage processing uses and associated infrastructure on the project site. Similar exterior light fixtures would be installed, and Mitigation Measure (MM) AES-3 would be implemented. The buildings developed under this alternative would be industrial in appearance similar to other structures in the Green Island Road Business Park. Therefore, the No Project/Existing General Plan Alternative would have similar aesthetics, light, and glare impacts as the proposed project.
Air Quality
The No Project/Existing General Plan Alternative would result in an equivalent amount of construction activity and 5,544 more daily vehicle trips (refer to Table 5-2), which have an approximately 240 percent increase in operational criteria pollutant and toxic air contaminant (TAC) emissions, assuming an equal fleet proportion of passenger vehicles versus trucks as that considered in the proposed project. Additionally, this alternative would attract more truck trips beyond what was considered under the proposed project and, thus, increase the severity of the significant unavoidable sensitive receptor impact. MM AIR-2a, MM AIR-2b, MM AIR-2c, and MM AIR-2d would be implemented under this alternative. This alternative would increase the severity of the proposed project’s significant unavoidable air quality impacts by emitting more pollutants from operational activities. Therefore, this alternative would have greater impact on air quality than the proposed project.
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Similar ground-disturbing activities would occur within the same development footprint as the proposed project, and MM BIO-1a, MM BIO-1b, MM BIO-1c, MM BIO-1d, MM BIO-1e, MM BIO-3a, MM BIO-3b, MM BIO-3c, and MM BIO-4 would be implemented. Therefore, the No Project/Existing General Plan Alternative would have similar biological resources impacts as the proposed project.
Cultural and Tribal Cultural Resources
Similar ground-disturbing activities would occur within the same development footprint as the proposed project, and MM CUL-1a, MM CUL-1b, MM CUL-2, and MM CUL-3 would be implemented.
Therefore, the No Project/Existing General Plan Alternative would have similar cultural resources impacts as the proposed project.
Geology, Soils, and Seismicity
Similar development activities would occur within the same development footprint, and MM GEO-1a and MM GEO-1b would be implemented. Therefore, the No Project/Existing General Plan Alternative would have similar geology, soils, and seismicity resources impacts as the proposed project.
Greenhouse Gas Emissions and Energy
The No Project/Existing General Plan Alternative would result in an equivalent amount of construction activity and 5,544 more daily vehicle trips (refer to Table 5-2), which have an approximately 240 percent increase in operational greenhouse gas (GHG) emissions, assuming an equal fleet proportion of passenger vehicles versus trucks as that considered in the proposed project. MM GHG-1a and MM GHG-1b would be implemented under this alternative. This alternative would increase the severity of the proposed project’s significant unavoidable GHG impacts by emitting more pollutants from operational activities. Therefore, this alternative would have greater impact on GHG emissions than the proposed project.
Hazards and Hazardous Materials
As with the proposed project, no hazardous conditions exist on-site, and, therefore, impacts would be less than significant. This alternative would develop a 2.4-million-square-foot food and beverage processing facility, which would not involve the routine use of hazardous materials. Therefore, this alternative would have similar hazards and hazardous materials impacts as the proposed project.
Hydrology and Water Quality
Similar ground-disturbing activities would occur within the same development footprint, and MM HYD-1a and MM HYD-1b would be implemented. This alternative would develop an equivalent amount if impervious surface coverage as the proposed project and, thus, have equivalent drainage impacts. Therefore, the No Project/Existing General Plan Alternative would have similar hydrology and water quality impacts as the proposed project.
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This alternative would develop a 2.4-million-square-foot food and beverage processing facility, which is allowable under the existing General Plan and Zoning designations for the project site. Therefore, it would yield similar conclusions in terms of consistency with the City of American Canyon General Plan and the American Canyon Zoning Ordinance. Food and beverage processing would emit sources of steam, which have the potential to conflict with the provisions of the Napa County Airport Land Use Compatibility Plan. Therefore, the No Project/Existing General Plan Alternative would have greater land use impacts than the proposed project.
Noise
The No Project/Existing General Plan Alternative would result in equivalent construction activity and 5,544 more daily vehicle trips (refer to Table 5-2), which would have corresponding increases in the severity of operational noise impacts. MM NOI-1 would be implemented under this alternative.
Although this alternative would implement mitigation measures similar to the proposed project, the increase in vehicle trips would increase the severity of noise impacts. Therefore, this alternative would have greater impact on noise than the proposed project.
Public Services
End uses would be similar to the proposed project. Although the proposed project’s public services impacts were found to be less than significant and did not require mitigation, this alternative would result in less demand for fire protection and police protection through the 600,000-square-foot reduction in development potential. Accordingly, no new or expanded fire or police facilities would be required. Therefore, the No Project/Existing General Plan Alternative would have less impact on public services than the proposed project.
Transportation
Table 5-2 summarizes the daily and peak-hour trip generation associated with the No Project/Existing General Plan Alternative. As shown in the table, this alternative would yield an increase of 5,544 daily vehicle trips, 1,248 AM peak-hour vehicle trips, and 1,344 PM peak-hour vehicle trips. Although the proposed project’s transportation impacts were found to be less than significant and did not require mitigation, the substantial increase in Vehicle Miles Traveled (VMT) by the No Project/Existing General Plan Alternative would be considered detrimental from a transportation perspective. The No Project/Existing General Plan Alternative would have greater transportation impacts than the proposed project.
Table 5-2: No Project/Existing General Plan Alternative Trip Generation Comparison Scenario Daily AM Peak-hour PM Peak-hour
No Project/Existing General Plan Alternative 9,432 1,488 1,608 Proposed Project 3,888 240 264
Difference 5,544 1,248 1,344
Notes:
Source: W-Trans, 2021; FirstCarbon Solutions (FCS) 2021. 736
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The No Project/Existing General Plan Alternative end uses would consist of food and beverage processing, which would demand more water and generate more effluent and solid waste by an estimated 240 percent. The proposed project’s utilities and service system impacts were found to be less than significant and did not require mitigation. Because this alternative would result in an approximately 240 percent increase in demand for water and an approximately 240 percent increase in generation of wastewater and solid waste, it would have more severe impacts on utilities and service systems. Therefore, the No Project/Existing General Plan Alternative would have less impact on utilities and service systems than the proposed project.
5.4.2 - Conclusion
The No Project/Existing General Plan Alternative would not avoid the significant and unavoidable air quality and GHG emissions impacts associated with the proposed project and in fact would increase the severity of these impacts. The No Project/Existing General Plan Alternative would increase the severity of impacts associated with land use, noise, public services, transportation, and utilities.
Additionally, the No Project/Existing General Plan Alternative would have similar impacts on aesthetics, biological resources, cultural resources, geology, hazards, and hydrology and water quality.
The No Project/Existing General Plan Alternative would advance most of the project objectives including those related to facilitating the development of land planned for business park/industrial uses to its highest and best use; positively contributing to the local economy; providing the City of American Canyon with a high-quality, employment-generating industrial development. However, the change of the end use would not advance the project objective concerning serving local and regional demand for logistics warehouse uses.
5.5 - Alternative 3—Reduced Density Alternative
Under the Reduced Density Alternative, a 1.6 million square-foot logistics center would be developed on the project site, which represents a 25 percent reduction in the proposed project’s square footage. This would yield a 600,000-square-foot reduction in buildout potential, which would be applied proportionately to all project buildings. The reduction in building square footage would allow for 10 additional acres of the site to be preserved in its natural state.
The project boundaries, layout, (including disturbance area) and high-cube warehouse end uses would remain the same. Vehicular access points would remain at the same locations. The Napa Valley Vine Trail would be constructed along the project’s frontages with Devlin Road and Green Island Road.
Table 5-3 summarizes the Reduced Density Alternative. The purpose of this alternative is to evaluate a smaller project with end uses identical to the proposed project that may avoid or substantially lessen the severity of significant project impacts.
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Scenario Total Acres Developed Acres End Use Square Feet Reduced Density Alternative 208 153 High-Cube Warehouse 1,800,000 Proposed Project 208 163 High-Cube Warehouse 2,400,000
Difference – (10) – (600,000)
Source: FirstCarbon Solutions (FCS) 2021.
5.5.1 - Impact Analysis
Aesthetics, Light, and Glare
The Reduced Density Alternative consists of developing 1.8 million square feet of high-cube warehouse uses and associated infrastructure on the project site. Similar exterior light fixtures would be installed, and MM AES-3 would be implemented. The buildings developed under this alternative would retain a similar appearance to the proposed project’s structures; however, 600,000-squarefoot reduction in warehouses would reduce the amount of development on the project site and add 10 acres to the open, natural area of the site. Therefore, the Reduced Density Alternative would have less impact on aesthetics, light, and glare than the proposed project.
Air Quality
The Reduced Density Alternative would result in less construction activity and 972 fewer daily vehicle trips (refer to Table 5-4), which have an approximately 25 percent reduction in construction and operational criteria pollutant and TAC emissions. Additionally, this alternative would attract approximately 25 percent fewer truck trips and passenger vehicle trips and, thus, lessen the severity of the significant unavoidable sensitive receptor impact. MM AIR-2a, MM AIR-2b, MM AIR-2c, and MM AIR-2d would be implemented under this alternative. Although this alternative would not avoid the proposed project’s significant unavoidable air quality impacts, it would lessen the severity by emitting fewer pollutants from operational activities. Therefore, this alternative would have less impact on air quality than the proposed project.
Biological Resources
Similar ground-disturbing activities would occur within the same development footprint as the proposed project, and MM BIO-1a, MM BIO-1b, MM BIO-1c, MM BIO-1d, MMBIO-1e, MM BIO-3a, MM BIO-3b, MM BIO-3c, and MM BIO-4 would be implemented. Therefore, the Reduced Density Alternative would have similar biological resources impacts as the proposed project.
Cultural and Tribal Cultural Resources
Similar ground-disturbing activities would occur within the same development footprint as the proposed project, and MM CUL-1a, MM CUL-1b, MM CUL-2, and MM CUL-3 would be implemented.
Therefore, the Reduced Density Alternative would have similar cultural resources impacts as the proposed project.
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Similar development activities would occur within the same development footprint, and MM GEO-1a and MM GEO-1b would be implemented. Therefore, the Reduced Density Alternative would have similar geology, soils, and seismicity resources impacts as the proposed project.
Greenhouse Gas Emissions and Energy
The Reduced Density Alternative would result in less construction activity and 972 fewer daily vehicle trips (refer to Table 5-4), which have corresponding reductions in the severity of construction and operational greenhouse gas emissions. MM GHG-1a and MM GHG-1b would be implemented under this alternative. Although this alternative would not avoid the proposed project’s significant unavoidable greenhouse gas impacts, it would lessen the severity by emitting fewer emissions from operational activities. Therefore, this alternative would have less impact on GHGs than the proposed project.
Hazards and Hazardous Materials
As with the proposed project, no hazardous conditions exist on-site, and, therefore, impacts would be less than significant. This alternative would result in a 600,000-square-foot reduction in high-cube warehouse development potential and, thus, would reduce the potential for hazardous material releases during construction and operations. Therefore, this alternative would have less impact on hazards and hazardous materials than the proposed project.
Hydrology and Water Quality
Similar ground-disturbing activities would occur within the same development footprint, and MM HYD-1a and MM HYD-1b would be implemented. This alternative would reduce the project’s less than significant (after mitigation) hydrology and water quality impacts because there would be less impervious surface coverage. Therefore, the Reduced Density Alternative would have less impact on hydrology and water quality than the proposed project.
Land Use
This alternative would develop similar uses to the proposed project, and, therefore, would yield similar conclusions in terms of consistency with the City of American Canyon General Plan, American Canyon Zoning Ordinance, and the Napa County Airport Land Use Compatibility Plan. Thus, MM LU-3 would be implemented to reduce wildlife hazards associated with aviation to a level of less than significant. Therefore, the Reduced Density Alternative would have land use impacts similar to the proposed project.
Noise
The Reduced Density Alternative would result in less construction activity and 972 fewer daily vehicle trips (refer to Table 5-4), which would have corresponding reductions in the severity of construction and operational noise impacts. MM NOI-1 would be implemented under this alternative. Although this alternative would implement mitigation measures similar to the proposed project, the reduction in development potential and vehicle trips would reduce the severity of noise impacts. Therefore, this alternative would have less impact on noise than the proposed project. 739
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End uses would be similar to the proposed project. Although the proposed project’s public services impacts were found to be less than significant and did not require mitigation, this alternative would result in less demand for fire protection and police protection through the 600,000-square-foot reduction in development potential. Accordingly, no new or expanded fire or police facilities would be required. Therefore, the Reduced Density Alternative would have less impact on public services than the proposed project.
Transportation
Table 5-4 summarizes the daily and peak-hour trip generation associated with the Reduced Density Alternative. As shown in the table, this alternative would yield a reduction of 972 daily vehicle trips, 60 AM peak-hour vehicle trips, and 66 PM peak-hour vehicle trips. Although the proposed project’s transportation impacts were found to be less than significant and did not require mitigation, the substantial reduction in VMT by the Reduced Density Alternative would be considered beneficial from a transportation perspective. The Reduced Density Alternative would have less transportation impacts than the proposed project.
Table 5-4: Reduced Density Alternative Trip Generation Comparison Scenario Daily AM Peak-hour PM Peak-hour
Reduced Density Alternative 2,916 180 198
Proposed Project 3,888 240 264
Difference (972) (60) (66)
Notes:
Source: W-Trans, 2021; FirstCarbon Solutions (FCS) 2021.
Utilities and Service Systems
End uses would be similar to the proposed project. Although the proposed project’s utilities and service system impacts were found to be less than significant and did not require mitigation, this alternative would result in an approximately 25 percent reduction in demand for water, and energy, and an approximately 25 percent reduction in generation of wastewater and solid waste through the 600,000-square-foot reduction in development potential. Therefore, the Reduced Density Alternative would have less impact on utilities and service systems than the proposed project.
5.5.2 - Conclusion
The Reduced Density Alternative would lessen the severity of, but would not avoid, the significant and unavoidable air quality and GHG emissions impacts associated with the proposed project.
Additionally, the Reduced Density Alternative would lessen the severity of several of the significant impacts that can be reduced to a level of less than significant with mitigation (e.g., hydrology and water quality, and noise).
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City of American Canyon—Giovannoni Logistics Center Project Draft EIR Alternatives to the Proposed Project
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec05-00 Alternatives.docx The Reduced Density Alternative would advance all of the project objectives, with several advanced to a lesser degree. However, the reduction in square footage would result in fewer positive economic benefits and, thus, would advance the project objectives to a lesser degree. (For example, this alternative would be expected to employ fewer workers than the proposed project.) This includes objectives related to facilitating the development of land planned for business park/industrial uses to its highest and best use; positively contributing to the local economy; providing the City of American Canyon with a high-quality, employment-generating industrial development; and serving local and regional demand for logistics warehouse uses.
5.6 - Alternative 3—Phase 1 Only Alternative
Phase 1 of the proposed project would be developed, which consists of 1.1 million square feet on 95 acres. Phase 2 would not be pursued, and the remaining 113 acres would remain undeveloped as a wetland preserve.
Phase 1 would have the same layout and boundaries as the proposed project. Two high-cube warehouses totaling 1.1 million square feet would be developed on 95 acres north of Green Island Road and west of Devlin Road. Vehicular access would be taken from both roadways. Phase 2 would remain undeveloped for the foreseeable future.
Table 5-5 summarizes the Phase 1 Only Alternative. The purpose of this alternative is to evaluate the phase of the project most likely to develop in the near-term and also reduce the development footprint and buildout potential to avoid or substantially lessen the severity of significant project impacts.
Table 5-5: Phase 1 Only Alternative
Scenario Total Acres Developed Acres End Use Square Feet Phase 1 Only Alternative 95 72 High-Cube Warehouse 1,100,000 Proposed Project 208 163 High-Cube Warehouse 2,400,000
Difference (113) (91) – (1,300,000)
Source: FirstCarbon Solutions (FCS) 2021.
5.6.1 - Impact Analysis
Aesthetics, Light, and Glare
The Phase 1 Only Alternative consists of developing 1.1 million square feet of high-cube warehouse uses and associated infrastructure on 95 acres. The remaining 113 acres would remain undeveloped for the foreseeable future. Similar exterior light fixtures would be installed, and MM AES-3 would be implemented. The buildings developed under this alternative would retain a similar appearance to the proposed project’s structures; however, 1.3-million-square-foot reduction in warehouses would reduce the amount of development and add 113 acres to the open, natural area of the site. 741
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Air Quality
The Phase 1 Only Alternative would result in less construction activity and 2,106 fewer daily vehicle trips (refer to Table 5-6), which have an approximately 55 percent reduction in criteria pollutant and TAC emissions. Additionally, this alternative would attract fewer truck trips and, thus, lessen the severity of the significant unavoidable sensitive receptor impact. MM AIR-2, MM AIR-3a, and MM AIR-3b would be implemented under this alternative. Although this alternative would not avoid the proposed project’s significant unavoidable air quality impacts, it would lessen the severity by emitting fewer pollutants from operational activities. Therefore, this alternative would have less impact on air quality than the proposed project.
Biological Resources
The Phase 1 Only Alternative consists of developing 1.1 million square feet of high-cube warehouse uses and associated infrastructure on 95 acres. The remaining 113 acres would remain undeveloped for the foreseeable future. Similar development activities would occur for Phase 1 and, therefore, MM BIO-1a, MM BIO-1b, MM BIO-1c, MM BIO-1d, MM BIO-1e, MM BIO-3a, MM BIO-3b, MM BIO3c, and MM BIO-4 would be implemented. However, the elimination of Phase 2 would lessen the potential for impacts to biological resources. Therefore, the Phase 1 Only Alternative would less impact on biological resources impacts than the proposed project.
Cultural and Tribal Cultural Resources
The Phase 1 Only Alternative consists of developing 1.1 million square feet of high-cube warehouse uses and associated infrastructure on 95 acres. The remaining 113 acres would remain undeveloped for the foreseeable future. Similar development activities would occur for Phase 1 and, therefore, MM CUL-1a, MM CUL-1b, MM CUL-2, and MM CUL-3 would be implemented. However, the elimination of Phase 2 would lessen the potential for impacts to cultural resources. Therefore, the Phase 1 Only Alternative would less impact on cultural resources impacts than the proposed project.
Geology, Soils, and Seismicity
The Phase 1 Only Alternative consists of developing 1.1 million square feet of high-cube warehouse uses and associated infrastructure on 95 acres. The remaining 113 acres would remain undeveloped for the foreseeable future. Similar development activities would occur for Phase 1 and, therefore, MM GEO-1a and MM GEO-1b would be implemented. However, the elimination of Phase 2 would lessen the potential for impacts to geology, soils, and seismicity. Therefore, the Phase 1 Only Alternative would have less impact on geology, soils, and seismicity than the proposed project.
Greenhouse Gas Emissions and Energy
The Phase 1 Only Alternative would result in less construction activity and 2,106 fewer daily vehicle trips (refer to Table 5-6), which have an approximately 55 percent reduction in the severity of GHG emissions. MM GHG-1 and MM GHG-2 would be implemented under this alternative. Although this alternative would not avoid the proposed project’s significant unavoidable GHG emission impacts, it 742
City of American Canyon—Giovannoni Logistics Center Project Draft EIR Alternatives to the Proposed Project
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Hazards and Hazardous Materials
The Phase 1 Only Alternative consists of developing 1.1 million square feet of high-cube warehouse uses and associated infrastructure on 95 acres. The remaining 113 acres would remain undeveloped for the foreseeable future. As with the proposed project, no hazardous conditions exist on-site, and, therefore, impacts would be less than significant. This alternative would result in a 1.3-millionsquare-foot reduction in high-cube warehouse development potential and, thus, would reduce the potential for hazardous material releases during construction and operations. Therefore, this alternative would have less impact on hazards and hazardous materials than the proposed project.
Hydrology and Water Quality
The Phase 1 Only Alternative consists of developing 1.1 million square feet of high-cube warehouse uses and associated infrastructure on 95 acres. The remaining 113 acres would remain undeveloped for the foreseeable future. Similar development activities would occur for Phase 1 and, therefore, MM HYD-1a and MM HYD-1b would be implemented. However, the elimination of Phase 2 would lessen the potential for impacts to hydrology and water quality. Therefore, the Phase 1 Only Alternative would have less impact on hydrology and water quality than the proposed project.
Land Use
The Phase 1 Only Alternative consists of developing 1.1 million square feet of high-cube warehouse uses and associated infrastructure on 95 acres. The remaining 113 acres would remain undeveloped for the foreseeable future. This alternative would develop similar uses to the proposed project, and, therefore, would yield similar conclusions in terms of consistency with the City of American Canyon General Plan, American Canyon Zoning Ordinance, and the Napa County Airport Land Use Compatibility Plan. Thus, MM LU-3 would be implemented to reduce wildlife hazards associated with aviation to a level of less than significant. Therefore, the Phase 1 Only Alternative would have land use impacts similar to the proposed project.
Noise
The Phase 1 Only Alternative would result in less construction activity and 2,106 fewer daily vehicle trips (refer to Table 5-6), which would have corresponding reductions in the severity of construction and operational noise impacts. MM NOI-1 would be implemented under this alternative. Although this alternative would implement mitigation measures similar to the proposed project, the reduction in development potential and vehicle trips would reduce the severity of noise impacts. Therefore, this alternative would have less impact on noise than the proposed project.
Public Services
End uses would be similar to the proposed project. Although the proposed project’s public services impacts were found to be less than significant and did not require mitigation, this alternative would result in less demand for fire protection and police protection through the 1.3-million-square-foot 743
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Transportation
Table 5-6 summarizes the daily and peak-hour trip generation associated with the Phase 1 Only Alternative. As shown in the table, this alternative would yield a reduction of 2,106 daily vehicle trips, 130 AM peak-hour vehicle trips, and 143 PM peak-hour vehicle trips. Although the proposed project’s transportation impacts were found to be less than significant and did not require mitigation, the substantial reduction in VMT by the Phase 1 Only Alternative would be considered beneficial from a transportation perspective. The Phase 1 Only Alternative would have less transportation impacts than the proposed project.
Table 5-6: Phase 1 Only Alternative Trip Generation Comparison Scenario Daily AM Peak-hour PM Peak-hour
Phase 1 Only Alternative 1,782 110 121
Proposed Project 3,888 240 264
Difference (2,106) (130) (143)
Source: W-Trans, 2021; FirstCarbon Solutions (FCS) 2021.
Utilities and Service Systems
End uses would be similar to the proposed project. Although the proposed project’s utilities and service system impacts were found to be less than significant and did not require mitigation, this alternative would result in an approximately 55 percent reduction in demand for water, and energy, and an approximately 55 percent reduction in generation of wastewater and solid waste through the
1.3-million-square-foot reduction in development potential. Therefore, the Phase 1 Only Alternative would have less impact on utilities and service systems than the proposed project.
5.6.2 - Conclusion
The Phase 1 Only Alternative would lessen the severity of, but would not avoid, the significant and unavoidable air quality and GHG emissions impacts associated with the proposed project.
Additionally, the Phase 1 Only Alternative would lessen the severity of several of the significant impacts that can be reduced to a level of less than significant with mitigation (e.g., biological resources, cultural resources, hydrology and water quality, and noise).
The Phase 1 Only Alternative would advance all of the project objectives, with several advanced to a lesser degree. However, the reduction in square footage would result in fewer positive economic benefits and, thus, would advance the project objectives to a lesser degree. (For example, this alternative would be expected to employ fewer workers than the proposed project.) This includes objectives related to facilitating the development of land planned for business park/industrial uses to its highest and best use; positively contributing to the local economy; providing the City of 744
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As a practical matter, the project applicant has a 100-year lease agreement with the property owner, and it would be unlikely that it forgo development on the Phase 2 portion of the project site.
Moreover, the project site is the single largest undeveloped site in the City of American Canyon and is zoned for industrial use. Preserving 113 acres the site as a wetland preserve would not represent the highest and best use of the property, particularly since approximately 45 acres of the project site would be assigned for this use.
5.7 - Environmentally Superior Alternative
The qualitative environmental effects of each alternative in relation to the proposed project are summarized in Table 5-7.
Table 5-7: Summary of Alternatives
Environmental Topic
Area Issue(s)
No Project/No
Development
Alternative
No
Project/Existing
General Plan
Alternative
Reduced
Density
Alternative
Phase 1 Only
Alternative
Aesthetics, Light, and
Glare
Scenic Vistas; Visual
Character; Light and
Glare
Less impact Similar impact Less impact Less impact
Air Quality Air Quality Plan,
Criteria Pollutants,
Toxic Air
Contaminants
Less impact Greater
Impact Less impact Less impact
Biological Resources Special-status species;
Wetlands, Wildlife
Movement
Less impact Similar impact Similar
impact Less impact
Cultural and Tribal
Cultural Resources
Historic Resources,
Archaeological
Resources; Human
Remains; Tribal
Cultural Resources
Less impact Similar impact Similar
impact Less impact
Geology, Soils, and
Seismicity
Seismic Hazards;
Erosion; Unstable
Geologic Units;
Expansive Soils
Less impact Similar impact Similar
impact Less impact
Greenhouse Gas
Emissions and Energy
Greenhouse Gas
Reduction Plans;
Energy
Less impact Greater impact Less impact Less impact
Hazards and
Hazardous Materials
Routine Use; Risk of
Upset; Aviation
Hazards; Emergency
Response
Less impact Similar impact Less impact Less impact
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Area Issue(s)
No Project/No
Development
Alternative
No
Project/Existing
General Plan
Alternative
Reduced
Density
Alternative
Phase 1 Only
Alternative
Hydrology and Water
Quality
Water Quality;
Groundwater;
Drainage
Less impact Similar impact Similar
impact Less impact
Land Use General Plan; Zoning;
Airport Land Use Plan
Consistency
Less impact Greater impact Similar
impact
Similar
impact
Noise Noise Level Standards;
Vibration; Aviation
Noise
Less impact Greater impact Less impact Less impact
Public Services Fire; Police Less impact Greater impact Less impact Less impact Transportation Circulation System;
Vehicle Miles
Traveled; Roadway
Hazards; Emergency
Access
Less impact Greater impact Less impact Less impact
Utilities and Service
Systems
Water; Wastewater;
Solid Waste Less impact Greater impact Less impact Less impact Source: FirstCarbon Solutions (FCS) 2021.
CEQA Guidelines Section 15126(e)(2) requires an EIR to identify an environmentally superior alternative. If the No Project Alternative is the environmentally superior alternative, the EIR must also identify an environmentally superior alternative from among the other alternatives.
The No Project/No Development Alternative reduces impacts on all categories and, thus, would be the environmentally superior alternative. Of the three remaining alternatives, the Phase 1 Only Alternative achieves the greatest reduction in impacts both reducing buildout potential and disturbance areas. Therefore, the Phase 1 Only Alternative is the environmentally superior alternative.
5.8 - Alternatives Rejected From Further Consideration
The following alternatives were initially considered, but rejected from further consideration for the reasons described below.
5.8.1 - Phase 2 Only Alternative
A Phase 2 Only Alternative was initially considered as a project alternative. This alternatives analysis evaluated a Phase 1 Only Alternative because it has less acreage and development potential than Phase 2. In addition, development plans are available for Phase 1 whereas Phase 2 is conceptual.
Furthermore, the applicant has indicated that Phase 1 would develop first followed by Phase 2. 746
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5.8.2 - Alternative Location
CEQA Guidelines Section 15126.6(f)(2) sets forth considerations to be used in evaluating an alternative location. The section states that the “key question” is whether any of the significant effects of the proposed project would be avoided or substantially lessened by relocating the proposed project. The CEQA Guidelines identify the following factors that may be taken into account when addressing the feasibility of an alternative location:
1. Site suitability
2. Economic viability
3. Availability of infrastructure
4. General Plan consistency
5. Other plans or regulatory limitations
6. Jurisdictional boundaries
7. Whether the project applicant can reasonably acquire, control, or otherwise have access to the alternative site
Here, “General Plan consistency” is an important factor. CEQA case law is clear that EIRs for proposed private projects consistent with governing General Plan designations generally need not address alternative sites, given that such existing General Plan designations embody policy decisions already made by governing city councils and boards of supervisors. “[T]he keystone of regional planning is consistency—between the general plan, its internal elements, subordinate ordinances, and all derivative land use decisions.” (Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 572.) “Case-by-case reconsideration of regional land use policies, in the context of a project-specific EIR, is the very antithesis of that goal.” (Id. at p. 573.) “[A]n EIR is not ordinarily an occasion for the reconsideration or overhaul of fundamental land use policy.” (Ibid.) Table 5-8 evaluates the feasibility of three alternative locations located within 1 mile of the project site in either the City of American Canyon or unincorporated Napa County. The three locations are shown on Exhibit 5-1. As indicated in Table 5-8, none of the three sites would meet CEQA Guidelines criteria for a feasible alternative location.
Table 5-8: Alternative Location Feasibility Analysis
Name Description Feasibility Determination
Sentinels of
Freedom
Property
Approximately 25 acres located west of Napa
Logistics Park and south of Napa County Airport
in unincorporated Napa County and within the
City of American Canyon Sphere of Influence. This
site contains undeveloped land, is bisected by No
Name Creek, and parts are within a 100-year
flood hazard area. This site is designated
“Industrial” by the Napa County General Plan and
Not Feasible: This site is controlled by the
Sentinels of Freedom and is not owned,
controlled, or otherwise accessible to the
project applicant. The Sentinels of Freedom
have conceptually proposed developing
two warehouses on the property with
vehicular access occurring from either Napa
County Airport and the Napa Logistics Park.
Additionally, the acreage of this site (25
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zoned “Business/Industrial” by the Napa County
Airport Industrial Area Specific Plan.
acres) is 12 percent of the acreage of the
project site (208 acres) and, thus, is too
small to accommodate the level of
development contemplated by the
proposed project.
Commerce
Court
Approximately 21 acres located near the south
end of Commerce Court in the City of American
Canyon. The site is undeveloped.
This site is designated “Commercial Recreation”
by the City of American Canyon General Plan and
zoned “Recreation” by the American Canyon
Zoning Ordinance. This site is the subject of a
development application for two distribution
centers (224,000 and 217,000 square feet).
Not Feasible: This site is owned by a third
party and is not owned, controlled, or
otherwise accessible to the project
applicant. Additionally, the acreage of this
site (21 acres) is 10 percent of the acreage
of the project site (208 acres) and, thus, is
too small to accommodate the level of
development contemplated by the
proposed project. Moreover, this site is the
subject of an active development
application to develop a similar type use as
the proposed project and, thus, is not
available.
Hess
Vineyards
Approximately 100 acres located east of SR-29/S.
Kelly Road in unincorporated Napa County. This
site contains cultivated agricultural land. This site
is designated “Agricultural, Watershed, and Open
Space” by the Napa County General Plan and
zoned “Agricultural Watershed” by the Napa
County Zoning Ordinance.
Not Feasible: This site is owned by a third
party and is not owned, controlled, or
otherwise accessible to the project
applicant. Additionally, the acreage of this
site (100 acres) is 52 percent of the acreage
of the project site (208 acres) and, thus, is
too small to accommodate the level of
development contemplated by the
proposed project. Finally, this property was
re-designated from “Industrial” to
“Agricultural, Watershed, and Open Space”
in 2008, signifying the County’s policy
direction for this particular property.
Source: FirstCarbon Solutions (FCS) 2021.
748
54600001 • 10/2021 | 5-1_alt_locations.mxd
Exhibit 5-1
Alternative Locations
Source: Google Earth Aerial Imagery, 10/2020. County of Napa.
CITY OF AMERICAN CANYON
GIOVANNONI LOGISTICS CENTER PROJECT
ENVIRONMENTAL IMPACT REPORT
Eucalyptus Dr
Green Island Rd
Green Island Rd
Paoli Loop Rd
Watson Ln
Hanna Dr
Com
merce B vl d
29 Devlin Rd
Kelly Rd
Airport Rd
12 Napa County Airport
Napa
Branch
Line
California Northern Railroad
California
Northern
Railroad
Middleton
Way
Sentinels of Freedom Property
Commerce Court
Hess Vineyards
2,000 1,000 0 2,000
Feet
Legend
Project Site
749
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6.1 - Significant Unavoidable Impacts
California Environmental Quality Act (CEQA) Guidelines Section 15126.2(a)(c) requires an Environmental Impact Report (EIR) to identify and focus on the significant environmental effects of the proposed project, including effects that cannot be avoided if the proposed project were implemented.
Based on the analyses contained in this Draft EIR, the City has determined that the proposed project would result in the following significant and unavoidable impacts:
• Consistency With Air Quality Management Plan: The proposed project would result in exceedances of regional emissions thresholds and, therefore, be inconsistent with the Bay Area Air Quality Management District regional air quality planning assumptions. Mitigation is proposed requiring the implementation of feasible emissions reduction measures; however, these measures would not reconcile this inconsistency. Therefore, the significance after mitigation is significant and unavoidable.
• Cumulative Criteria Pollutant Emissions Impacts: The proposed project would result in a cumulatively considerable net increase of criteria pollutants for which the project region is nonattainment under an applicable federal or State ambient air quality standard. Mitigation is proposed requiring the implementation of air emissions reduction measures, but it would not fully reduce this impact to a level of less than significant. Therefore, the significance after mitigation is significant and unavoidable.
6.2 - Growth-Inducing Impacts
There are two types of growth-inducing impacts that a project may have: direct and indirect. To assess the potential for growth-inducing impacts, the project’s characteristics that may encourage and facilitate activities that individually or cumulatively may affect the environment must be evaluated (CEQA Guidelines § 15126.2(e)). CEQA Guidelines, as interpreted by the City, state that a significant growth-inducing impact may result if the project would:
• Induce substantial population growth in an area (for example, by proposing new homes and commercial or industrial businesses beyond the land use density/intensity envisioned in the general plan);
• Substantially alter the planned location, distribution, density, or growth rate of the population of an area; or
• Include extensions of roads or other infrastructure not assumed in the general plan or adopted capital improvements project list when such infrastructure exceeds the needs of the project and could accommodate future developments.
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The proposed project does not include residential uses and therefore would not directly induce population growth.
The proposed project would develop approximately 2.4 million square feet of new high-cube warehouse uses on an undeveloped site. The proposed project would employ an estimated 1,200 workers during construction and 3,643 workers when fully operational at buildout. The proposed project’s warehouses would likely be built incrementally over a period of years and, thus, jobs would be added in blocks as the project builds out. As such, there would not be an “overnight” influx of new employment opportunities.
The California Employment Development Department estimated the combined Napa-Solano labor force at 273,500 in October 2021. As such, the local labor force is sufficiently large enough to allow the project’s employment opportunities to be filled locally such that unplanned growth would not occur.
During the Notice of Preparation (NOP) review period, the County of Napa requested the Draft EIR evaluate whether there is sufficient housing for project employees. At the time of this writing, no prospective employees have been identified and, thus, it would be speculative to make any statements about where they would reside. Nonetheless, the City of American Canyon has more than 2,400 dwelling units in the pipeline (refer to Table 4-1 in Chapter 4, Cumulative Effects). For comparison purposes, American Canyon’s population was estimated to be 20,837. Thus, the addition of more than 2,400 dwelling units to the City’s housing inventory would more than offset the employment growth attributable to the proposed project.
The proposed project would be served by connections to existing water, wastewater, storm drainage, electricity, and natural gas lines that exist in Green Island Road or Devlin Road. No extension of infrastructure into unserved areas would be required and, therefore, no removal of physical barriers to growth would occur.
As such, the proposed project would not indirectly induce substantial population growth. No impacts would occur.
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6.3 - Energy Conservation
Note to Reader: Section 3.6, Greenhouse Gas Emissions and Energy, also addresses energy conservation.
Public Resources Code Section 21100(b)(3) and CEQA Guidelines Section 15126.4 require EIRs to describe, where relevant, the wasteful, inefficient, and unnecessary consumption of energy caused by a project. In 1975, largely in response to the oil crisis of the 1970s, the State Legislature adopted AB 1575, which created the California Energy Commission (CEC). The statutory mission of the CEC is to forecast future energy needs, license thermal power plants of 50 megawatts or larger, develop energy technologies and renewable energy resources, plan for and direct State responses to energy emergencies, and—perhaps most importantly—promote energy efficiency through the adoption and enforcement of appliance and building energy efficiency standards. AB 1575 also amended Public Resources Code Section 21100(b)(3) to require EIRs to consider the wasteful, inefficient, and unnecessary consumption of energy caused by a project. Thereafter, the State Resources Agency created Appendix F of the CEQA Guidelines. Appendix F assists EIR preparers in determining whether a project will result in the inefficient, wasteful, and unnecessary consumption of energy. Appendix F was substantially revised in 2010 to address greenhouse gas emissions and focus on reducing fossil fuel consumption. For the reasons set forth below, this Draft EIR concludes that the proposed project will not result in the wasteful, inefficient, and unnecessary consumption of energy, will not cause the need for additional natural gas or electrical energy-producing facilities, and, therefore, will not create a significant impact on energy resources.
6.3.1 - Regulatory Setting
Federal and state agencies regulate energy use and consumption through various means and programs. At the federal level, the United States Department of Transportation, the United States Department of Energy, and the United States Environmental Protection Agency are three federal agencies with substantial influence over energy policies and programs. Generally, federal agencies influence and regulate transportation energy consumption through establishment and enforcement of fuel economy standards for automobiles and light trucks, through funding of energy-related research and development projects, and through funding for transportation infrastructure improvements. At the State level, the California Public Utilities Commission (CPUC) and the CEC are two agencies with authority over different aspects of energy. The CPUC regulates privately owned utilities in the energy, rail, telecommunications, and water fields. The CEC collects and analyzes energy-related data, prepares Statewide energy policy recommendations and plans, promotes and funds energy efficiency programs, and adopts and enforces appliance and building energy efficiency standards. California is exempt under federal law from the normal prohibition against states setting their own fuel economy standards for new on-road motor vehicles. Some of the more relevant federal and State energy-related laws and plans are discussed below.
Title 24, Energy Efficiency Standards
Title 24, which was promulgated by the CEC in 1978 in response to a legislative mandate to create uniform building codes to reduce California’s energy consumption, provides energy efficiency standards for residential and nonresidential buildings. According to the CEC, since the energy efficiency standards went into effect in 1978, it is estimated that California residential and 753
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Pursuant to the California Building Standards Code and the Title 24 Energy Efficiency Standards, the City will review the design and construction components of the project’s Title 24 compliance when specific building plans are submitted.
6.3.2 - Energy Requirements of the Proposed Project
Short-term construction and long-term operational energy consumption are discussed below.
Short-Term Construction
The United States Environmental Protection Agency (EPA) regulates nonroad diesel engines that power both mobile equipment (bulldozers, scrapers, front-end loaders, etc.) and stationary equipment (generators, pumps, compressors, etc.). The EPA has no formal fuel economy standards for nonroad (e.g., construction) diesel engines but does regulate diesel emissions, which indirectly affects fuel economy. In 1994, EPA adopted the first set of emission standards (“Tier 1”) for all new nonroad diesel engines greater than 37 kilowatts (kW) or 50 horsepower. The Tier 1 standards were phased in for different engine sizes between 1996 and 2000, reducing nitrogen oxide (NOx) emissions from these engines by 30 percent. Subsequently, the EPA adopted more stringent emission standards for NOX, hydrocarbons, and particulate matter for new nonroad diesel engines. This program included the first set of standards for nonroad diesel engines less than 37 kW. It also phased in more stringent “Tier 2” emission standards from 2001 to 2006 for all engine sizes and added yet more stringent “Tier 3” standards for engines between 37 and 560 kW (50 and 750 horsepower) from 2006 to 2008. These standards further reduced nonroad diesel engine emissions by 60 percent for NOX and 40 percent for particulate matter (PM) from Tier 1 emission levels. In 2004, the EPA issued the Clean Air Nonroad Diesel Rule. This rule cut emissions from nonroad diesel engines by more than 90 percent, and was phased in between 2008 and 2014. These emission standards are intended to promote advanced clean technologies for nonroad diesel engines that improve fuel combustion, but they also result in slight decreases in fuel economy.
The project site is located within the nine-county San Francisco Bay metropolitan region.
Construction equipment is widely available throughout the region and is subject to the aforementioned EPA emissions standards. There are no unusual project characteristics that would necessitate the use of construction equipment that would not meet EPA standards. Therefore, it is expected that construction fuel consumption associated with the project would not be any more inefficient, wasteful, or unnecessary than at other construction sites in the region.
Long-term Operations
Transportation Energy Demand
Vehicle fuel efficiency is regulated at the federal level. Pursuant to the Federal Energy Policy and Conservation Act of 1975, the National Highway Traffic Safety Administration (NHTSA) is responsible for establishing additional vehicle standards and for revising existing standards. NHTSA indicated that the fuel economy of passenger vehicles averaged 34.2 miles per gallon and light trucks averaged 26.2 miles per gallon. Heavy trucks and other heavy vehicles are not subject to fuel economy standards; however, they average 6.5 miles per gallon.
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Building Energy Demand
Marin Clean Energy (MCE) is the electricity provider and Pacific Gas and Electric Company (PG&E) is the natural gas provider to American Canyon.
Electricity
MCE offers its customers three options for energy: Light Green, Deep Green, and Local Sol. The Light Green option relies on 60 percent renewable (biomass/renewable, geothermal, eligible hydroelectric, solar and wind) and the balance from other sources (large hydroelectric, nuclear, open market purchases). Deep Green and Local Sol are 100 percent renewable, with the former 50:50 solar and wind and the latter 100 percent solar.
PG&E delivers electricity for MCE. PG&E operates approximately 18,000 circuit miles of transmission lines, approximately 107,000 circuit miles of distribution lines, 68 transmission switching stations, and 760 distribution substations. PG&E is interconnected with electric power systems in the western Electricity Coordinating Council, which includes 14 western states; Alberta and British Columbia, Canada; and parts of Mexico.
Natural Gas
PG&E provides natural gas to all or part of 39 counties in California comprising most of the northern and central portions of the State, including Solano County. PG&E charges connection and user fees for all new development and sliding use-based rates for natural gas service. PG&E operates approximately 43,300 miles of distribution pipelines and approximately 6,300 miles of backbone and local transmission pipelines, and three underground storage fields. In 2019, PG&E delivered 227 billion cubic feet of natural gas to its 4.5 million natural gas customers.
Energy Consumption
Using consumption figures provided by the United States Energy Information Administration, the proposed project’s estimated building electricity and natural gas consumption is summarized in Table 6-1.
Table 6-1: Energy Consumption Estimates
Energy Source Square Feet Annual Consumption Rate Annual Consumption Electricity
2,400,000
6.6 kWh/square foot 15.8 million kWh
Natural Gas 19.4 cubic feet/square foot 46.6 million cubic feet Notes:
‘Warehouse and storage’ energy consumption rate used.
Source: United States Energy Information Administration, 2016. 755
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7.1 - Introduction
This chapter, prepared in satisfaction of California Environmental Quality Act (CEQA) Guidelines Section 15128 (Effects Not Found to Be Significant), is based in part on the Notice of Preparation (NOP), dated January 12, 2021, and contained in Appendix A of this Draft Environmental Impact Report (Draft EIR). The NOP was prepared to identify the potentially significant effects of the proposed project and was circulated for public review between January 12, 2021, and February 10, 2021. In the course of this evaluation, certain impacts were found to be less than significant because the proposed project’s characteristics would not create such impacts. Consistent with section 15128, this chapter provides a brief description of the reasons why effects were found not to be significant or less than significant, based on the NOP comments or more detailed analysis conducted as part of the EIR preparation process. Note that a number of impacts that are found to be less than significant are addressed in the various EIR topical sections (Sections 3.1 through 3.13) to provide more comprehensive discussion of why impacts are less than significant, in order to better inform decision-makers and the general public.
7.2 - Effects Found not to be Significant
7.2.1 - Aesthetics, Light, and Glare
State Scenic Highways
State Route (SR) 29 is located approximately 750 feet east of the project site. SR-29 is classified as an “Eligible” State Scenic Highway. Because of the project site’s distance from SR-29 and the presence of intervening development, vegetation, and topography, the proposed project would have minimal visibility from the highway. Therefore, this precludes any possibility of the proposed project adversely altering views from a State Scenic Highway. No impacts would occur.
7.2.2 - Agriculture and Forest Resources
Important Farmland
The project site supports grazing land use activities. The California Department of Conservation maps the project site as “Farmland of Local Importance,” which does not fall under the Important Farmland umbrella (Prime Farmland, Unique Farmland, and Farmland of Statewide Importance) as defined by CEQA Guidelines Appendix G. Two of the three project site’s soils (Haire loam, 2 to 9 percent soils; and Haire clay loam, 2 to 9 percent) are not classified as prime soils by the United States Department of Agriculture, a key attribute used by the California Department of Conservation in classifying farmland. No impacts would occur.
Agricultural Zoning or Williamson Act Contracts
The project site is zoned “Industrial” by the American Canyon Zoning Ordinance, a non-agricultural zoning designation. The project site is not encumbered by any active Williamson Act contracts, which precludes the possibility of conflicts in this regard. No impacts would occur. 757
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The project site is zoned “Industrial” by the American Canyon Zoning Ordinance, a non-forest zoning designation. No impacts would occur.
Timberland
The project site contains undeveloped land. There are no stands of commercially harvestable trees and, thus, the proposed project would not convert forestland to non-forest use. No impacts would occur.
Pressures to Convert Agricultural or Timberland
The project site is currently within the American Canyon city limits and designated for urban development by the City of American Canyon General Plan (General Plan); thus, it is considered committed to urban use within the foreseeable future. The surrounding land is also within the American Canyon city limits and designated for urban development by the General Plan. Thus, it is also committed to urban use. This condition precludes the possibility of the proposed project creating pressures to convert farmland to non-agricultural use. As noted above, moreover, the project site does not qualify as “Important Farmland” as that term is used by the State of California.
No impacts would occur.
7.2.3 - Biological Resources
Conservation Plans
The project site is not within the boundaries of an adopted habitat conservation plan or natural community conservation plan. This condition precludes the possibility of the proposed project conflicting with such a plan. No impacts would occur.
7.2.4 - Geology, Soils, and Seismicity
Septic or Alternative Wastewater Disposal Systems
The proposed project would be served with sanitary sewer service provided by the City of American Canyon. No septic or alternative wastewater disposal system would be employed. This condition precludes the possibility of related impacts. No impacts would occur.
7.2.5 - Hazards and Hazardous Materials
Exposure of Schools to Hazardous Materials
Calvary Baptist Church School, the closest school to the project site, is located 0.65 mile to the south.
This distance precludes the possibility of the proposed project exposing schools located within 0.25 mile of the site to hazardous materials or hazardous air emissions. No impact would occur.
Wildland Fires
The project site contains undeveloped land and is surrounded by urban development within the American Canyon city limits. The project site is not located within a “high” or “very high” fire hazard severity zone as identified by the California Department of Forestry and Fire Protection (CAL FIRE).
The site also lacks the kind of vegetation associated with wildland fires. For these reasons, the 758
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7.2.6 - Hydrology and Water Quality
100-Year Flood Hazards
The project site is not within a 100-year flood hazard zone. This condition precludes the possibility of the proposed project exposing people or structures to 100-year flood hazards. No impacts would occur.
Levee or Dam Failure
Exhibit 15 of the General Plan indicates that the western portion of the project site is within the dam failure inundation area of Conn Dam, Milliken Dam, and Rector Reservoir. The western portion of the project site is proposed as a wetland preserve and retention basin and, thus, inundation by floodwaters would not pose a risk to public safety. Moreover, dam failure is considered remote and unlikely due to regular monitoring of the structural integrity of these facilities. Additionally, the project site is not protected by any levees, which precludes the potential for inundation by levee failure. No impacts would occur.
Seiches, Tsunamis, or Mudflows
There are no large inland bodies of water such as lakes or reservoirs near the project site, a condition that precludes seiche inundation. The project site is located more than 30 miles from the Pacific Ocean and more than 1 mile from the Napa River, a condition that precludes tsunami inundation.
The project site is not located in a volcanically active area or at the base of a mountain range, a condition that precludes mudflow inundation. No impacts would occur.
7.2.7 - Land Use
Division of an Established Community
The project site currently does not contain any occupied dwelling units and is surrounded with a barbed wire fence intended to deter trespassing. Thus, it does not contain any established communities or serve as a linkage between established communities. This condition precludes the division of an established community. No impacts would occur.
7.2.8 - Mineral Resources
Mineral Resources of Statewide or Local Importance
The project site does not support mineral resource extraction operations. Neither the California Department of Conservation nor the General Plan designates the site a location of known mineral deposits. In addition, the California Department of Conservation Geologic Energy Management 759
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7.2.9 - Population and Housing
Growth Inducement
Please refer to Chapter 6, Other CEQA Considerations, Section 6.2 for discussion of growth inducement.
Displacement of Persons or Dwelling Units
The project site does not contain any existing dwelling units. This condition precludes the possibility of displacement of persons or dwelling units. No impacts would occur.
7.2.10 - Public Services
Schools
The proposed project is nonresidential in nature and would not directly induce population growth and, therefore, would not increase demand for schools such that new or expanded facilities would be required. This condition precludes the possibility of related impacts. No impacts would occur.
Parks
The proposed project is nonresidential in nature and would not directly induce population growth and therefore would not increase demand for park facilities such that new or expanded facilities would be required. This condition precludes the possibility of related impacts. No impacts would occur.
Other Public Facilities
The proposed project is nonresidential in nature and would not directly induce population growth and therefore would not increase demand for public facilities, such as libraries, such that new or expanded facilities would be required. This condition precludes the possibility of related impacts. No impacts would occur.
7.2.11 - Recreation
Physical Deterioration of Recreational Facilities
The proposed project is nonresidential in nature and would not directly induce population growth and therefore would not increase the demand for recreational facilities such that new or expanded facilities would be required. This condition precludes the possibility of related impacts. No impacts would occur.
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7.2.12 - Wildfire
Emergency Response or Evacuation
The project site contains undeveloped land and is surrounded by urban development within the American Canyon city limits. The project site is not within a State responsibility area or classified as a very high fire hazard severity zone. As such, the project site is not susceptible to wildfires.
Regardless, the proposed project would have multiple connections to Green Island Road and the future Devlin Road. As such, adequate emergency response and evacuation routes would be available in the event of an emergency. No impact would occur.
Exposure to Wildfire
The project site contains undeveloped land and is surrounded by urban development within the American Canyon city limits. The project site is not within a State responsibility area or classified as a very high fire hazard severity zone. As such, the project site is not susceptible to wildfires. Thus, persons or structures would not be exposed to wildfire hazards. No impact would occur.
Fire Infrastructure
The project site contains undeveloped land and is surrounded by urban development within the American Canyon city limits. The project site is not within a State responsibility area or classified as a very high fire hazard severity zone. As such, the project site is not susceptible to wildfires. Thus, no wildfire suppression infrastructure would be required. No impact would occur.
Post-Fire Flooding or Landslides
The project site contains flat, undeveloped land and is surrounded by urban development within the American Canyon city limits. The project site is not within a State responsibility area or classified as a very high fire hazard severity zone. As such, the project site is not susceptible to wildfires and, thus, it would not be susceptible to post-fire flooding or landslides. No impact would occur. 761
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PREPARERS
8.1 - Lead Agency
8.1.1 - City of American Canyon
Community Development Department
Community Development Director.........................................................................Brent Cooper, AICP Public Works Department
Public Works Director...................................................................................... Erica Ahmann Smithies Engineer III..................................................................................................................... Edison Bisnar
8.1.2 - Public Agencies
State Agencies
California Air Resources Board
Chief, Transportation and Toxics Division ........................................................................Heather Arias California Department of Fish and Wildlife
Regional Manager, Bay Delta Region...............................................................................Greg Erickson Native American Heritage Commission
Analyst............................................................................................................. Nancy Gonzalez-Lopez Local Agencies
American Canyon Fire Protection District
Fire Chief............................................................................................................................Mike Cahill County of Napa
Planning, Building & Environmental Services Department
Senior Planner............................................................................................................. John McDowell
8.1.3 - Private Parties and Organizations
Center for Biological Diversity
Staff Attorney............................................................................................................ Ross Middlemiss Legal Fellow .............................................................................................................. Mary Rassenfoss Ironworkers Local 378
President/Business Agent..................................................................................................Jason Gallia Business Representative.................................................................................................Jason Lindsey 763
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8.2 - List of Preparers
8.2.1 - Lead Agency
City of American Canyon
Community Development Department
Community Development Director........................................................................ Brent Cooper, AICP
8.2.2 - Lead Consultant
FirstCarbon Solutions
Project Director..................................................................................................................Mary Bean Project Manager............................................................................................................. Grant Gruber Senior Archaeologist.............................................................................................. Dana DiPietro, PhD Biologist ...................................................................................................................... Alex Villanueva Air Quality Analyst.............................................................................................................. Lance Park Senior Noise Analyst...............................................................................................................Phil Ault Publications Manager........................................................................................................Susie Harris Word Processor..........................................................................................................Melissa Ramirez GIS/Graphics ........................................................................................................... Karlee McCracken
8.2.3 - Technical Subconsultants
Balance Hydrologics
Senior Hydrologist......................................................................................................Scott Brown, PG Huffman–Broadway Group
Senior Environmental Scientist ...........................................................................................Gary Deghi Senior Wetland Scientist............................................................................................... Robert Perrera Wildlife Biologist............................................................................................................ Emilie Strauss W-Trans
Principal .....................................................................................................Dalene Whitlock, PE, PTOE Traffic Engineer...........................................................................................................Kenny Jeong, PE Assistant Engineer......................................................................................................... Kathryn Tellez Graphic Artist ..............................................................................................................Cameron Wong Editor.................................................................................................................Hannah Yung-Boxdell 764
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Draft EIR References
FirstCarbon Solutions 9-1
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec09-00 References.docx CHAPTER 9: REFERENCES
Balance Hydrologics, Inc. 2021. Water Supply Assessment for Giavannoni Logistics Project, American Canyon, California. September.
California Department of Conservation, Farmland Mapping and Monitoring Program. 2019. Napa County Important Farmland 2018.
California Department of Finance. 2021. E-5 Population and Housing Estimates for Cities, Counties and the State–January 1, 2011–2021.
California Department of Health Services. 2016. California Indoor Radon Levels Sorted by Zip Code.
February.
California Department of Resources Recycling and Recovery (CalRecycle). 2021. “Solid Waste Information System.” Website: https://www2.calrecycle.ca.gov/SolidWaste/Site/Search.
Accessed February 2.
California Department of Transportation (Caltrans). 1998. Technical Noise Supplement to the Traffic Noise Analysis Protocol. October.
California Department of Transportation (Caltrans). 2004. Transportation- and Construction-Induced Vibration Guidance Manual. June 2010.
California Department of Transportation (Caltrans). 2013. 2010-2012 California Household Travel Survey Final Report. June.
California Department of Transportation (Caltrans). 2021. California Scenic Highway System.
Website: https://dot.ca.gov/programs/design/lap-landscape-architecture-and-communitylivability/lap-liv-i-scenic-highways. Accessed February 2.
California Department of Water Resources (DWR). 2003. Bulletin 118: Napa-Sonoma Valley Groundwater Basin.
California Employment Development Department (EDD). 2021. Monthly Labor Force Data for Cities and Census Designated Places. June. Website: http://www.labormarketinfo.edd.ca.gov.
California Geological Survey. 2002. Geologic Map of the Cuttings Wharf 7.5-Minute Quadrangle.
California Geological Survey. 2002. How Earthquakes and Their Effects are Measured.
City of American Canyon. 1994. City of America Canyon General Plan. November 3.
City of American Canyon. 2021. Final Urban Water Management Plan–2020.
City of American Canyon. 2021. City of American Canyon Municipal Code.
County of Napa. 1986. Napa County Airport Industrial Area Specific Plan. July 29. 765
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References Draft EIR
9-2 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec09-00 References.docx County of Napa. 2008. Napa County General Plan.
FirstCarbon Solutions (FCS). 2021. Section 106 Cultural Resources Assessment, Giovannoni Logistics Center Project.
Gallaway Enterprises. 2019. Initial Study/Mitigated Negative Declaration for the Proposed Green Island Road Reconstruction and Widening Project. April.
GHD. 2018. Devlin Road and Napa Valley Vine Trail Extension Project Initial Study/Mitigated Negative Declaration. December.
Huffman-Broadway Group, Inc. 2021. Biological Resources Report, Giovannoni Logistics Center, American Canyon, California. May.
Jensen, Peter. 2014. Napa Valley Register: “A lesser fault line blamed for Sunday’s earthquake.” August 30.
Marin Clean Energy. 2021. “About MCE’s Energy Suppliers.” Website:
https://www.mcecleanenergy.org/energy-suppliers/. Accessed August 19.
Napa County Airport Land Use Commission (ALUC). 1999. Airport Land Use Compatibility Plan. April
22. Napa Local Agency Formation Commission. 2018. South County Region Municipal Service Review and Sphere of Influence Updates. December 3.
Napa Valley Vine Trail Coalition. 2021. Website: https://vinetrail.org. Accessed March 12, 2021.
San Francisco Bay Regional Water Quality Control Board (San Francisco Bay RWQCB). 2011. 2010 Integrated Report (Clean Water Act Section 303(d) List/305(b) Report).
San Francisco Bay Regional Water Quality Control Board (San Francisco Bay RWQCB). 2011. Basin Plan.
United States Department of Agriculture (USDA), Natural Resources Conservation Service. 2021.
Web Soil Survey. Website: websoilsurvey.nrcs.usda.gov. Accessed February 10, 2021.
United States Environmental Protection Agency (EPA). 1998. Characterization of Building Related Construction and Demolition Debris in the United States. June.
United States Geologic Survey (USGS). 1983. Cuttings Wharf, California 7.5-Minute Topographical Map Quadrangle.
United States Geological Survey (USGS). 2014. “M6.0–6km NW of American Canyon, California.” Website: http://earthquake.usgs.gov/earthquakes/eventpage/nc72282711#shakemap.
W-Trans. 2021. Traffic Impact Study for the Giovannoni Logistics Center. July 22.
Western Regional Climate Center. 2021. Website: www.wrcc.dri.edu. Accessed April 6, 2021. 766
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FINAL
Environmental Impact Report
Giovannoni Logistics Center Project
City of American Canyon, Napa County, California
State Clearinghouse Number 2021010104
Prepared for:
City of American Canyon
4381 Broadway Street, Suite 201
American Canyon, CA 94503
707.647.5345
Contact: Brent Cooper, AICP, Community Development Director Prepared by:
FirstCarbon Solutions
2999 Oak Road, Suite 250
Walnut Creek, CA 94597
925.357.2562
Contact: Mary Bean, Project Director
Grant Gruber, Project Manager
Date: October 31, 2022
ATTACHMENT 1.K
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City of American Canyon—Giovannoni Logistics Center Project Administrative Final EIR Table of Contents
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Section 1: Introduction ............................................................................................................... 1-1 Section 2: Master Responses....................................................................................................... 2-1
2.1 - List of Master Responses................................................................................................2-1
2.2 - Master Responses ..........................................................................................................2-1 Section 3: Responses to Written Comments................................................................................ 3-1
3.1 - List of Authors ................................................................................................................3-1
3.2 - Responses to Comments................................................................................................3-1 Section 4: Responses to June 23, 2022, Planning Commission Meeting Comments...................... 4-1
4.1 - Introduction....................................................................................................................4-1
4.2 - List of Speakers and Authors..........................................................................................4-1
4.3 - June 23, 2022, Planning Commission Meeting Minutes ................................................4-1
4.4 - Responses to June 23, 2022, Planning Commission Meeting Comments......................4-5 Section 5: Errata.......................................................................................................................... 5-1
5.1 - Changes in Draft EIR .......................................................................................................5-1 List of Appendices
Appendix J: Travel Behavior Memorandum
Appendix K: Fire Fiscal Impact Analysis
Appendix L: Wildlife Hazard Assessment
List of Tables
Table 3-1: Proposed Mitigation Measure Feasibility Analysis...........................................................3-99 Table 3-2: Feasibility Analysis of Proposed Additional Mitigation Measures..................................3-293 769
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City of American Canyon—Giovannoni Logistics Center Project Final EIR Introduction
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In accordance with California Environmental Quality Act (CEQA) Guidelines Section 15088, the City of American Canyon (Lead Agency) has evaluated the comments received on the Giovannoni Logistics Center Project Draft Environmental Impact Report (Draft EIR). Pursuant to CEQA Guidelines Section 15132, this Final EIR includes a list of persons, organizations, and agencies that provided comments on the Draft EIR; responses to the comments received regarding the Draft EIR; and errata, or revisions to the Draft EIR; as well as a Mitigation Monitoring and Reporting Program (MMRP) for use by the City of American Canyon during its review.
This document is organized into five sections:
• Section 1—Introduction. Provides an introduction to the Final EIR. • Section 2—Master Responses. Provides a single, comprehensive response to similar comments about a particular topic.
• Section 3—Responses to Written Comments. Provides a list of the agencies, organizations, and individuals who commented on the Draft EIR. Copies of all of the letters received regarding the Draft EIR and responses thereto are included in this section. • Section 4—Responses to June 23, 2022, Planning Commission Meeting Comments. Provides a list of the speakers who commented on the Draft EIR, a summary of their comments, and responses thereto are included in this section.
• Section 5—Errata. Includes an addendum listing refinements and clarifications on the Draft EIR, which have been incorporated.
The Final EIR includes the following contents:
• Draft EIR (provided under separate cover)
• Draft EIR Appendices (provided under separate cover)
• Responses to Written Comments on the Draft EIR (Section 3), Responses to Planning Commission Meeting Comments (Section 4), and Errata (Section 5)
• Mitigation Monitoring and Reporting Program (provided under separate cover) 771
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Master responses address similar comments made by multiple public agencies, businesses, organizations, or individuals through written comments submitted to the City of American Canyon.
Master responses are provided in the order in which they are referenced in the responses in Section 3.
The master responses are intended to provide thorough responses to all of the individual comments that raised the same issue or very similar issues.
2.1 - List of Master Responses
• Master Response 1—Impacts to Swainson’s Hawk/Golden Eagle Foraging Habitat • Master Response 2—New “North” Fire Station
• Master Response 3—Buildout Assumptions
• Master Response 4—Vehicle Miles Traveled
2.2 - Master Responses
Master Response 1—Impacts to Swainson’s Hawk/Golden Eagle Foraging Habitat Summary of Relevant Comments
Both the California Department of Fish and Wildlife (CDFW) and Scott Cashen stated that the proposed project would result in the loss of Swainson’s hawk foraging habitat and this impact should be mitigated in accordance with CDFW mitigation guidelines. Mr. Cashen also provided similar comments about the loss of golden eagle foraging habitat. The CDFW noted that the Draft Environmental Impact Report (Draft EIR) identifies that the proposed project would remove Swainson’s hawk foraging habitat but does not specify the acreage. The CDFW also stated that the approximately 45 acres of wetlands that would be preserved by the proposed project may not be sufficient to mitigate for the loss of Swainson’s hawk foraging habitat, and the presence of suitable Swainson’s hawk foraging habitat near the site does not negate the need to mitigate for permanent removal of foraging habitat for this species.
Response
Swainson’s Hawk
The development of Phase 1 would permanently impact approximately 68.8 acres of Swainson’s hawk foraging habitat, and the development of Phase 2 would permanently impact approximately
85.9 acres of Swainson’s hawk foraging habitat.
Draft EIR Section 3.3, Biological Resources, page 3.3-24 acknowledges that development of the proposed project would remove some foraging area for this species, but also indicated that the proposed project would also provide and preserve in perpetuity approximately 45 acres of wetlands that would include habitat currently suitable for foraging by the Swainson’s hawk as indicated by the observation of a Swainson’s hawk foraging in the site in spring 2021. In addition, the Draft EIR acknowledges the Napa Logistics Park Project has preserved 37 acres of grassland and wetlands in perpetuity that provides foraging habitat for Swainson’s hawk and that there are several large open 773
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This demonstrates that, based upon the limited number of known Swainson’s hawk to occur within a 10-mile radius of the project site, and with the acreage of existing foraging habitat currently protected, there is more than sufficient foraging habitat near the project site. Accordingly, the proposed project would not result in significant impacts to foraging habitat nor affect the nesting populations of Swainson’s hawk near the project site either directly, indirectly, or cumulatively.
Therefore, no mitigation is warranted for Swainson’s hawk foraging habitat. Importantly, the operative significance thresholds for impacts to Swainson’s hawk are (i) whether the proposed project would have a substantial adverse effect on the species, either directly or through habitat modifications, or (ii) whether the proposed project would substantially reduce the number or restrict the range of the species. Although the proposed project would result in a net loss of foraging habitat, such a net loss occurring in the particular area in which the project site is located, the proposed project would not cause either a substantial adverse effect on the species, a substantial reduction in its numbers, or a substantial restriction of its range. There is no need to “net out the impact of a proposed project” for that impact to be less than significant. (See Save Panoche Valley v.
San Benito County (2013) 217 Cal.App.4th 503, 529.)
CDFW’s Life History Account for the Swainson’s hawk indicates that this species feeds on small mammals, amphibians, reptiles, and birds, and soars and low and high levels in search of prey. The Life History Account also indicates that the Swainson’s hawk can be found in riparian habitat, sparsely vegetated flatlands, open desert, grassland, or cropland containing scattered large trees or small groves. In sum, Swainson’s hawk is a hardy species that can survive on a range of prey in a variety of very different habitats throughout California; it does not only occur in southern Napa County. The relatively small loss of foraging habitat on the project site would not affect the range of the species or cause the loss of substantial numbers of individual hawks.
Geoff Monk of Monk & Associates, one of the biological consulting firms that prepared the biological resources analysis, worked extensively with the Swainson’s hawk over four decades, and banded many nestlings of this species. The Swainson’s hawk is a California designated threatened species protected pursuant to the California Endangered Species Act (CESA). To obtain known/recorded information for the occurrence of nesting Swainson’s hawk nearest the project site, Monk & Associates completed a record search in the California Natural Diversity Database (CNDDB). It should be noted that all species of Buteo frequently change nesting locations from year to year, and may reuse a nest site in successive years or may move to a different nest site for one year and then back to nest sites used previously. Raptor biologists generally regard nests that are currently in use to be the “active nests,” while nests that are used in successive years or in alternate years are regarded as “alternate nest sites.” CESA (FGC § 2050 et seq.) and Fish and Game Code statutes that protect nesting birds (and raptors) (FGC §§ 3503, 3503.5, 3513, and 3800) would afford protections only to those nests that are currently in use by the nesting birds. Alternate nesting sites that are not occupied are afforded no protections pursuant to CESA or the Fish and Game Codes that protect nesting birds.
In 1979, Dr. Peter Bloom published a report estimating that the historical baseline for Swainson’s hawk breeding pairs in California was somewhere between 4,284 to 17,136. Dr. Bloom’s 1979 report 774
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In 2005, Dr. Bloom noted that the Swainson’s hawk population in California (and throughout North America) was suffering from acute poisoning from grasshopper insecticide use in Argentina applied directly to Swainson’s hawk’s gregarious migration roosts in Argentina. Detrimental Argentinian insecticide use has largely stopped in recent years, and the Swainson’s hawk nesting population in California has grown significantly. In 2007, the CDFW estimated 1,948 Swainson’s hawk breeding pairs in California’s Central Valley, with most of the population occurring in the area from Stanislaus County north to Butte County.
Dr. Bret Furnas’ 2022 study titled “Rapid Growth of the Swainson’s Hawk Population in California Since 2005”3 estimated the total Statewide population of 18,810 breeding Swainson’s hawk breeding pairs based on survey data collected in 2005, 2006, 2017, and 2018. The research group, which included Dr. Bloom, concluded that California’s Swainson’s hawk summering population grew between 2005 and 2018 at the rapid rate of 13.9 percent per year. It should also be noted that the current estimate of 18,810 breeding pairs is extraordinary given Dr. Bloom’s 1979 estimate of 375 nesting pairs in the State. The 2022 estimate is within the range of the historical baseline that Dr.
Bloom estimated in 1979 prior to the population decline.
The Swainson’s hawk nesting distribution now occurs in many areas where the Swainson’s hawk has not been known to nest for decades, if ever. Napa County, while considered within the historic distribution of the Swainson’s hawk, was not known to support any nesting sites for this hawk in the 1970s or 1980s. Similarly, the nesting population now extends into east Contra Costa County where nesting previously had not been recorded for many decades. Other nesting population recovery includes Southern California in the Antelope Valley and in Kern County. 1 Bloom, P.H. 1979. The Status of the Swainson’s Hawk in California, 1979. State of California, The Resources Agency, Department of Fish and Game. United States Department of the Interior, Bureau of Land Management, California State Office, 2800 Cottage Way, Sacramento, CA 95825. 2 California Department of Fish and Wildlife. 2007. Final Report, California Swainson’s Hawk Inventory 2005-2007. UC Davis Wildlife Health Center, Department of Fish and Game Resource Assessment Program, Final Report. May 31, 2007. 3 Furnas, Brett J., David H. Wright, Erin N. Tennant, Reagen M. O’Leary, Michael J. Kuehn, Peter H. Bloom, and Carie L. Battistone. 2022. Rapid Growth of the Swainson’s Hawk population in California since 2005. Ponithological applications, Volume 124, Issue 2.
May 2022.
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It is noteworthy that other raptors that were State and federally listed when the Swainson’s hawk was State listed in 1983 such as the bald eagle (Haliaeetus leucocephalus) and the peregrine falcon (Falco peregrinus) have been delisted (i.e., removed from protections provided by both CESA and the federal Endangered Species Act). The federal government conducted routine census surveys for these species and determined that the nesting populations of these species had fully recovered, and, thus, protection pursuant to the Endangered Species Act was no longer warranted. The CDFW followed these delisting efforts. In contrast, the Swainson’s hawk was never federally listed, and as the State of California does not have a recovery plan for the Swainson’s hawk, there is no guideline for what constitutes recovery. In addition, the Swainson’s hawk has not been counted to the extent that federal listed raptor species were. Thus, mitigation prescriptions developed more than 25 years ago are very likely outdated today.
The proposed 45-acre Wetland Preserve with its seasonal wetlands would be available to provide foraging habitat for the Swainson’s hawk in perpetuity. Additionally, less than 2 miles from the project site are 620 acres of dedicated open space (Newell Open Space) that are also preserved in perpetuity. The Newell Open Spaces appears to primarily comprise annual grassland with discrete areas of oak woodland and riparian woodland. Further, the Newell Open Space abuts other dedicated open space preserves, including the 1,039-acre Lynch Canyon Open Space Park and the American Canyon 308-acre California red-legged frog preserve. Combined, these open spaces dedicate over 2,000 acres of open space that can be used for foraging by the Swainson’s hawk because the open space supports the small mammals, amphibians, reptiles, and birds on which Swainson’s hawks prey. This demonstrates that based on the limited number of Swainson’s hawk records in Napa County, there is more than sufficient foraging habitat in the area that will be preserved in perpetuity to support actively nesting hawks and that further provide foraging habitat for other raptors of concern, specifically golden eagles and western burrowing owls. Accordingly, the proposed project would not result in significant impacts to foraging habitat either directly, indirectly, or cumulatively. The net loss of foraging habitat resulting from the proposed project will not cause either a substantial adverse effect on the species, a substantial reduction in its numbers, or a 4 Furnas, Brett J., David H. Wright, Erin N. Tennant, Reagen M. O’Leary, Michael J. Kuehn, Peter H. Bloom, and Carie L. Battistone. 2022. Rapid Growth of the Swainson’s Hawk population in California since 2005. Ponithological applications, Volume 124, Issue 2.
May 2022. 5 California Natural Diversity Database (CNDDB). 2015. RareFind 3.2. Computer printout for special-status species within a 5-mile radius of the project site. California Natural Heritage Division, California Department of Fish and Game, Sacramento, CA. 776
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Golden Eagle
CDFW’s Life History Account indicates that the golden eagle feeds on small mammals, reptiles, and birds, as well as carrion. The Life History Account also indicates that the golden eagle forages in open terrain, including grasslands, deserts, savannas, and early successional stages of forests. Like the Swainson’s hawk, the golden eagle is a hardy species that can survive on a range of prey in a variety of very different habitats throughout California; it does not only occur in southern Napa County.
Accordingly, for the same reasons the proposed project would not result in an indirect or cumulative loss of Swainson’s hawk foraging habitat, it would also not result in a significant indirect or cumulative loss of golden eagle foraging habitat.
Master Response 2—New “North” Fire Station
Summary of Relevant Comments
The American Canyon Fire Protection District (ACFPD) indicated that the proposed project, along with other planned development, would trigger the need for a new “North” fire station and related apparatus. The Sentinels of Freedom, a 501(c3) nonprofit organization, indicated that it owns a
25.44-acre vacant property adjacent to Napa Logistics Park and would like to offer to sell the site to the City of American Canyon for the development of a fire station and training center.
Response
As the ACFPD letter indicates, the Giovannoni Logistics Center Project and other planned projects in the northern portion of American Canyon create a need for a new fire station. The need is not solely caused by the Giovannoni Logistics Center Project. At the time of Final EIR publication, the new “North” fire station is conceptual in nature and no facility planning has occurred. The ultimate fate of the potential facility therefore remains speculative. (See California Environmental Quality Act [CEQA] Guidelines, § 15145 [lead agencies need not address speculative impacts].) The letter from ACFPD identified a number of possible “mitigation measures” for addressing ACFPD’s “annual operating deficit.” The City notes in response that “mitigation” is not the right word to describe any fair share funding that the project proponent may contribute to ACFPD’s operations.
Under CEQA, the proper focus of service-related impacts is on the physical effects of the construction of new or expanded facilities to provide services. Any inadequacy in the provision of actual services due to funding shortfalls is not a CEQA impact triggering mitigation. (See City of Hayward v. Board of Trustees of the Cal. State University (2015) 242 Cal.App.4th 833, 843 [“[t]he need for additional fire protection services is not an environmental impact that CEQA requires a project proponent to mitigate”]; Goleta Union School Dist. v. Regents of Univ. of Cal. (1995) 37 Cal.App.4th 1025, 1031–1034 [school overcrowding attributable to new development is not an environmental effect subject to CEQA, though the physical effects of new facility construction to 777
City of American Canyon—Giovannoni Logistics Center Project Master Responses Final EIR
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The Sentinels of Freedom property was evaluated as a potential alternative location for the proposed project in Chapter 5, Alternatives to the Proposed Project. As discussed in Draft EIR Chapter 5, Alternatives to the Proposed Project, page 5-17, the site was determined to be too small to support a 2.4-million-square-foot logistics center. However, the property is designated for “Industrial” use by the Napa County General Plan, zoned “Business/Industrial” by the Napa County Airport Industrial Area Specific Plan, and is within both the City of American Canyon’s Sphere of Influence (SOI) and Urban Limit Line (ULL). From a preliminary perspective, the Sentinels property may be a suitable location for a new fire station but more due diligence would be required to confirm its suitability.
Regardless, at the time of Final EIR publication, no decisions had been made regarding the acquisition of the Sentinels property or any other property for a new “North” fire station. Hence, the development of a new fire station is outside the scope of the Draft EIR.
Master Response 3—Buildout Assumptions
Summary of Relevant Comments
Both Golden State Environmental Justice Alliance (GSEJA) and Napa-Solano Residents for Responsible Growth (NSRRG) alleged that the Draft EIR used inconsistent buildout assumptions. Both organizations first cited a statement in Draft EIR, Chapter 2, Project Description, page 2-9, to the effect that the Draft EIR assumes that Phase 1 would buildout first followed by Phase 2 and then noted a subsequent statement indicating that, as a practical matter, the proposed project would likely buildout over a period of years, if not decades. NSRRG alleged that a prolonged construction schedule that extends over several years (multiple nesting seasons, multiple “rainy seasons”) increases the potential for construction-related impacts to aquatic resources.
Response
The Draft EIR provided the following statement on page 2-9 in Chapter 2, Project Description:
For the purposes of providing a conservative, worst-case scenario, this Draft EIR assumes that Phases 1 and 2 would be developed concurrently over a period of 18 months.
As a practical matter, the proposed project would buildout over a period of years or decades.
Phase 1 would be developed first, followed by Phase 2.
The applicant has indicated that actual buildout is expected to occur as follows:
• Phase 1 is permitted through the resource agencies.
• Phase 1 is mass graded; building pads and wetland restoration areas are created. • Phase 1 is developed with buildings, either spec or with known end user(s). • Phase 2 is permitted through the resource agencies.
• Phase 2 is mass graded; building pads and wetland restoration areas are created. • Phase 2 is developed with buildings, either spec or with known end user(s). 778
City of American Canyon—Giovannoni Logistics Center Project Final EIR Master Responses
FirstCarbon Solutions 2-7 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/3 - Final EIR/54600001 Sec02-00 Master Responses.docx Given the uncertainty regarding the timing of each of these stages, using a “front loaded” buildout horizon allowed the Draft EIR to disclose the maximum amount of construction and operational emissions that could be emitted. The California Emissions Estimator Model (CalEEMod) air emissions model is predicated on both the construction equipment and operational vehicle fleet getting cleaner over time. Thus, “front loading” buildout for the purposes of modeling reasonable worstcase emissions is consistent with CEQA principles, which disfavor the understatement of environmental impacts. Moreover, this was the same approach used in the Napa Logistics Park Phase 2 and Napa Airport Corporate Center EIRs. Furthermore, this statement reflects observations of how buildout of the neighboring Napa Logistics Park and the Green Island Business Park has occurred.
Likewise, if a longer buildout schedule were used (i.e., 10 years), the net effect would be to reduce the amount of construction and operational emissions attributable to the project because it would benefit from a cleaner fleet. Moreover, such an approach would also require a more complicated multi-phased analysis that would involve considerable speculation and would require a significant amount of time and effort to complete and which may not yield any more meaningful, probative information about project impacts.
NSRRG is speculating in assuming that a prolonged buildout schedule would result in greater impacts to aquatic resources. In fact, however, the approach taken in the EIR has created a more conservative, reasonable worst-case approach. As indicated previously, Phase 1 and Phase 2 would be mass graded following resource agency permitting. Building pads and wetland restoration areas would be created. Furthermore, the applicant is required by Mitigation Measure (MM) HYD-1a to implement a Storm Water Pollution Prevention Plan (SWPPP) and Best Management Practices (BMPs) during grading and construction. Those protections would remain in place in the interim period between mass grading and building completion. Thus, it is speculative to assume that a prolonged buildout schedule would result in greater impacts to aquatic resources.
Lastly, the statement on page 2-9 about “a period of 18 months” has been corrected to “a period of 20 to 24 months” and change is noted in Section 5, Errata. The change does not materially affect any conclusions of the air quality analysis since it used a 20-month buildout schedule.
NSRRG also alleged that a prolonged construction schedule that extends over several years increases the potential for construction-related impacts to aquatic resources and nesting birds. As stated above in the response to emissions, given the uncertainty regarding the timing of each of these stages, using a “front loaded” buildout horizon allowed the Draft EIR to disclose the maximum amount of impacts to aquatic resources wetland impacts.
Constructing Phase 1 and 2 concurrently over an 18-month period would impact 0.496-acre of wetlands for Phase 1 and 3.7 acres of wetlands for Phase 2 for a total of 4.196 acres of wetlands, which is the worst-case scenario, meaning the maximum acreage of wetland impacts would be 4.196 acres. The “worst-case scenario” assumption is not linked to the number of months it would take to complete each Phase but rather is a function of the acreage of wetland impacts. Phase 2 wetland impacts were assessed based on a full buildout with a maximum impact of 3.7 acres of wetlands. It is possible that, once Phase 2 has gone through the entitlement process, the site plan may be modified to reduce impacts to under 3.7 acres, just as Phase 1 has avoided impacts. 779
City of American Canyon—Giovannoni Logistics Center Project Master Responses Final EIR
2-8 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/3 - Final EIR/54600001 Sec02-00 Master Responses.docx It should be noted that, if construction takes 18 months to complete or longer, all mitigation measures outlined in the Draft EIR would apply for the entirety of the construction period.
Therefore, there is no basis to assume new impacts would occur if Phases 1 and 2 take two months to complete or 24 months. It should also be noted that the project will occur over at least two nesting periods, and if birds do nest in the project vicinity and construction has commenced, it should be assumed that the nesting bird(s) are habituated to the ambient level of noise and disturbance emanating from the project site. Therefore, a prolonged construction period that extends beyond 18 months would not increase the chance of construction-related impacts.
Regardless, for consistency and to address the commenters concerns, MM BIO-4 was revised to require additional pre-construction breeding bird surveys if construction activities are discontinued for more than 7 days.
Master Response 4—Vehicle Miles Traveled
Summary of Relevant Comments
Both GSEJA and NSRRG alleged that the Vehicle Miles Traveled (VMT) analysis provided no justification for the threshold of 23 miles per employee, and improperly used the California Statewide Travel Demand Model. NSRRG referenced the VMT analysis for a 217,000-square-foot wine distribution warehouse (SDG Commerce 217 Distribution Center Project) less than 2 miles away, which employed a different methodology and thresholds. GSEJA also argued that the VMT analysis was flawed due to its failure to account for non-employee heavy-duty truck trips in the analysis.
Response
To preface this response, VMT is a relatively new area of CEQA, having only been added to the Appendix G Checklist in late 2018 and only applying to environmental documents issued on or after July 1, 2020. Similar to the early years of greenhouse gas (GHG) emissions being introduced to the environmental review process, there is a range of guidance—sometimes conflicting—as to how to evaluate VMT. Likewise, many lead agencies have not adopted their own VMT thresholds or issued any guidance regarding methodology, which is the case for the City of American Canyon.
Furthermore, the Napa-Solano regional traffic model is limited in its abilities to calculate projectlevel VMT. Lastly, there is very little in the way of guidance for evaluating VMT for industrial or warehousing projects. With these factors in mind, W-Trans evaluated VMT with the best information available using the most relevant guidance.
Giovannoni VMT Analysis
Guidance contained in the Technical Advisory on Evaluating Transportation Impacts in CEQA, 2018, California Governor’s Office of Planning and Research (OPR) (OPR Technical Advisory) was used in selecting an appropriate VMT threshold of significance for the proposed project. While this publication provides no specific direction on the threshold that should be applied to warehouserelated land uses, it does indicate that office-related land uses should use a metric based on automobile commute VMT per employee, with a significance threshold tied to the regional average VMT per employee. Basing the proposed warehouse project’s VMT analysis on a commute VMT per employee performance metric was deemed appropriate since the employee automobile commute characteristics of a warehouse project are similar to those produced by an office project. The term 780
City of American Canyon—Giovannoni Logistics Center Project Final EIR Master Responses
FirstCarbon Solutions 2-9 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/3 - Final EIR/54600001 Sec02-00 Master Responses.docx “regional” refers to the Metropolitan Planning Organization (MPO) boundary that the site is located within; for American Canyon this is the nine-county Bay Area overseen by the Metropolitan Transportation Commission (MTC). This approach to defining “regional” is consistent with direction provided by OPR in an online document entitled, “SB 743 Frequently Asked Questions.” That document defines “regional” as “the full geography within the jurisdictional borders of a Metropolitan Planning Organization or a regional transportation planning agency.” Accordingly, the proposed project’s VMT significance threshold was based on an automobile commute VMT per employee performance metric that that was compared to the nine-county Bay Area regional average.
With respect to the use of a significance threshold for commute VMT per employee that is equal to the regional average, rather than 15 percent below the regional average as suggested in the OPR Technical Advisory for office uses, thresholds adopted by other jurisdictions, including Sacramento County and San José, were reviewed as noted in the project’s Draft EIR. As discussed in the Transportation Analysis Guidelines, County of Sacramento, 2020, “placing industrial land uses in less urban areas characterized by having higher VMT per employee allows land in efficient VMT areas to be more effectively utilized as high-density residential and commercial or office/business professional uses. This threshold is consistent with achieving an overall reduction in regional VMT, as it recognizes that industrial uses, which are relatively lower total VMT generating uses, are most appropriate in areas that have a lower potential to reduce VMT because it results in more available land within areas with a high potential to achieve VMT reductions available for more dense development.” Note that Sacramento County applies the same significance threshold for both industrial and warehousing uses. San José applied similar logic in developing its VMT thresholds for industrial and warehousing uses, which are also equal to the regional average VMT per employee.
It is also noted that during “office hours” webinars conducted by OPR in summer 2020, OPR staff acknowledged that industrial/warehousing projects are different from traditional “office” developments, and OPR offered the opinion that jurisdictions looking to establish significance thresholds for such uses may benefit from reviewing the thresholds set by San José. The proposed project’s applied VMT significance threshold was developed using the evidence provided by these sources, including the overall premise that locating industrial and warehouse projects in less VMTefficient areas can play an important role in reducing the community’s overall VMT, helping to achieve established GHG reduction targets.
Notwithstanding the foregoing, it is worth noting that, although the Draft EIR used a threshold of commute VMT per employee that is equal to the regional average rather than 15 percent below the regional average as suggested in the OPR Technical Advisory for office uses, the VMT for the proposed project is actually substantially more than 15 percent below regional average. As shown in Draft EIR on page 3.12-18, Table 3.12-9, Vehicle Miles Traveled Summary, the regional average VMT per employee is 23.0 miles, while the proposed project’s VMT per employee is 16.24 miles, which is roughly 29 percent below the regional average. Thus, the Draft EIR would have reached the same conclusion with respect to the VMT-related impacts of the proposed project—namely, that they were less than significant—even if the City had used the OPR-recommended threshold of 15 percent below the regional average for office projects.
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City of American Canyon—Giovannoni Logistics Center Project Master Responses Final EIR
2-10 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/3 - Final EIR/54600001 Sec02-00 Master Responses.docx The California Statewide Travel Demand Model (CSTDM) was determined to be the best available source of traffic analysis zone (TAZ)-level VMT data when the proposed project's Notice of Preparation (NOP) was released (January 2021). While a model including the Napa-Solano region exists, it was deemed inappropriate for use in the proposed project's VMT analysis because it truncates vehicle trip lengths at the county line, thereby resulting in an incomplete calculation of a project's potential trip lengths.
Since the Napa-Solano travel demand model does not account for full trip lengths and is not capable of calculating a regional commute VMT per employee metric tied to the nine-county Bay Area used to establish the VMT significance threshold, it was necessary to research other appropriate sources for this value. The City of Vallejo Transportation Impact Analysis Guidelines were deemed to be an appropriate source, not only because of Vallejo’s proximity to the proposed project, but because Vallejo faces the same constraints as American Canyon and Napa County in establishing VMT metrics and averages using the Napa-Solano model.
With respect to the use of a different VMT threshold of significance for a nearby distribution center, as discussed below, that project’s Mitigated Negative Declaration (MND) has not been accepted by the City of American Canyon. Accordingly, it would be inappropriate to compare the proposed project’s VMT methodology and thresholds to those applied in evaluating that project.
SDG Commerce 217 Distribution Center Project
The SDG Commerce 217 Distribution Center Project was initially evaluated in an MND issued in December 2020. Following receipt of comments, the City of American Canyon recirculated the MND in April 2021. Following another round of comments, the applicant requested that the City withdraw consideration of the MND in July 2021. The applicant then elected to proceed with the preparation of an EIR, which has not yet been publicly released at the time of Final EIR publication. It should be noted that neither FirstCarbon Solutions (FCS) nor W-Trans had any involvement with the SDG Commerce 217 Distribution Center Project MND and, thus, have no insights into the decision-making process concerning the VMT analysis.
The Giovannoni Logistics Center EIR did not tier from or rely upon any of the SDG Commerce 217 Distribution Center Project MND’s conclusions. Furthermore, the SDG Commerce 217 Distribution Center Project MND has no legal significance given that it was withdrawn from consideration. Lastly, lead agencies have the discretion to use different methodologies and thresholds on a project-byproject basis so long as they are supported by substantial evidence. For these reasons, the VMT methodologies and thresholds used in the SDG Commerce 217 Distribution Center Project MND do not have any bearing on Giovannoni Logistics Center EIR.
Medium- and Heavy-Duty Truck Trips from Logistics operations As explained above, the VMT analysis in the Draft EIR focused on employee trips and not on truck trips associated with the anticipated functioning of the proposed project’s logistics operations. This focus on employee trips in cars and light-duty trucks rather than incoming and outgoing trips by medium- or heavy-duty trips associated with logistics operations is consistent with direction provided by OPR and with the legislation (Senate Bill [SB] 743 of 2013) that authorized OPR and the California Natural Resources Agency to promulgate what became CEQA Guidelines Section 15064.3. 782
City of American Canyon—Giovannoni Logistics Center Project Final EIR Master Responses
FirstCarbon Solutions 2-11 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/3 - Final EIR/54600001 Sec02-00 Master Responses.docx As the Draft EIR explained on page 3.12-17, the OPR Technical Advisory defines “automobile,” as the term is used in Section 15064. 3, as referring to “on-road passenger vehicles, specifically cars and light trucks.” (Technical Advisory, page 4.) Thus, OPR understands the requirement to address transportation VMT as not reaching heavy-duty trucks. The focus on automobiles and not on heavyduty trucks is consistent with the policy focus behind the elimination of automobile delay as a factor in assessing the significance of transportation-related impacts, as set forth in SB 743. Public Resources Code Section 21099, subdivision (b)(1), directed the OPR and California Natural Resources Agency to develop alternative significance criteria that would “promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses.” Accounting for heavy-duty trucks engaged in interstate commerce would not contribute to these policy goals, as local and State governments have little or no control over interstate commerce involving trucking.
Furthermore, as the Draft EIR explained in its discussion of environmental effects associated with greenhouse gas (GHG) emissions, “[e]missions associated with heavy-duty trucks involved in goods movements are generally controlled on the technology side and through fleet turnover of older trucks and engines to newer and cleaner trucks and engines.” The following State strategies reduce GHG emissions from medium and heavy-duty trucks:
• California Air Resources Board (ARB) Mobile Source Strategy focuses on reducing GHGs by transitioning to zero and low emission vehicles and from medium- duty and heavy-duty trucks.
ARB’s Sustainable Freight Action Plan establishes a goal to improve freight efficiency by 25 percent by 2030, deploy over 100,000 freight vehicles and equipment capable of zeroemission operation and maximize both zero and near-zero-emission freight vehicles and equipment powered by renewable energy by 2030.
• ARB’s Truck and Bus Regulation requires diesel-fueled trucks and buses that operate in California to be upgraded to reduce emissions. Newer heavier trucks and buses were required to meet particulate matter (PM) filter requirements beginning January 1, 2012. Lighter and older heavier trucks had a compliance date of January 1, 2015. By January 1, 2023, nearly all trucks and buses will need to have 2010 model year engines or equivalent. • ARB’s Emissions Reduction Plan for Ports and Goods Movement (Goods Movement Plan) in California focuses on reducing heavy-duty truck-related emissions and the establishment of emissions standards for trucks, fleet turnover, truck retrofits, and restriction on truck idling.
While the focus of the Goods Movement Plan is to reduce criteria air pollutant and air toxic emissions, the strategies to reduce these pollutants would also generally have a beneficial effect in reducing GHG emissions.
Trucks and truck fleet owners and operators accessing the proposed project would be subject to the above trucking and freight regulations. Thus, these strategies would contribute to controlling heavyduty truck GHG emissions associated with the proposed project, and the proposed project would not conflict with or inhibit these Statewide strategies.” (Draft EIR, page 3.6-57, footnotes omitted.) In sum, not only do local governments have little or no control over interstate trucking operations, but GHG emissions (and thus VMT as a source of such emissions) resulting from medium- and heavy783 City of American Canyon—Giovannoni Logistics Center Project Master Responses Final EIR
2-12 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/3 - Final EIR/54600001 Sec02-00 Master Responses.docx duty truck trips are being addressed separately from GHG emissions (and thus VMT as a source of such emissions) from cars and light trucks. For these reasons, the transportation VMT analysis contained in the Draft EIR met applicable legal standards despite not accounting for medium- and heavy-duty truck trips that, if the proposed project is approved, will result from project operations as a logistics facility.
Even so, however, a recent technical study performed by a leading transportation consultant has found that the significance conclusions in the VMT analysis would not have changed if the analysis were expanded to account for medium- and heavy-duty trucks engaged in logistic operations. The conclusion would still be that VMT-related impacts are less than significant.
Appendix J to the Final EIR is a June 16, 2022, technical memorandum prepared for Joe Livaich of Buzz Oates Construction from Kevin Johnson and David Robinson of Fehr & Peers, a leading transportation consultant, on the subject of “American Canyon Industrial Warehouse Travel Behavior Data.” According to its authors, “[a] primary objective of the analysis in this memorandum is to address whether VMT from such heavy-duty truck trips would be more or less than 15 percent below the regional average for the Bay Area.” The authors conservatively chose to look at this particular metric because, as noted earlier, the OPR Technical Advisory proposed a significance threshold of 15 percent below the regional average for office projects (although, for reasons discussed above, that threshold was not used in the Draft EIR). The threshold of 15 percent below the regional average was thus the most conservative threshold recommended by OPR, and more conservative than the one used in the Draft EIR.
The Fehr & Peers technical memorandum “describes the travel behavior data collected for the proposed 208-acre high-cube industrial warehouse project (the Project) in American Canyon, CA.
Fehr & Peers understands the uniqueness of warehousing and logistics facilities that make them extremely difficult to study with traditional data collection methods. Fehr & Peers combined traffic count data previously collected in San Joaquin County for similar warehousing uses with new mobile device origin-destination data from StreetLight for similar industrial warehouse sites around the Bay Area to provide Buzz Oates Construction, Inc. with detailed trip generation, vehicle origindestination pattern, and average trip length data.” (Fehr & Peers, page 1.) “This data collection effort was undertaken by Fehr & Peers in June 2021 to better understand the travel behavior of existing warehousing buildings across San Joaquin County, as a review of local and regional planning studies revealed a lack of data and understanding of the travel characteristics of these types of facilities. Specifically, there was a lack of local or national trip generation data for warehousing uses, a lack of understanding of the travel patterns and demographics of warehouse users, and a lack of inclusion of these facilities in regional travel forecasting models.” (Fehr & Peers, page 2.)
Fehr & Peers coordinated the collection of 72 hours of driveway vehicle classification count data at 39 warehousing buildings across San Joaquin County in June 2021. The data collection was performed by National Data and Surveying Services (NDS) using cameras to count and classify vehicles entering and exiting the individual building driveways. Fehr & Peers staff visited each of the 39 warehousing buildings on one day during the data collection to observe the following:
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City of American Canyon—Giovannoni Logistics Center Project Final EIR Master Responses
FirstCarbon Solutions 2-13 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/3 - Final EIR/54600001 Sec02-00 Master Responses.docx • Check traffic and weather conditions
• Confirm the placement of the cameras
• Observe activity levels at the surveyed buildings
• Count the number of truck bays
• Classify the buildings
• Observe general operations and travel behavior
Fehr & Peers used this data to develop average trip generation rates per thousand square feet (KSF) for warehousing uses in San Joaquin County.” (Fehr & Peers, page 2.) Fehr & Peers obtained StreetLight’s GPS-based commercial vehicle data product for 23 existing industrial warehousing sites around the Bay Area, including eight sites in Napa County, of which four were located within the City of American Canyon. Fehr & Peers relied on StreetLight’s “O-D to Preset Geography” product to analyze travel patterns to and from the land use zone system at the census block group level, which has over 23,000 zones within California.
A land use zone system was developed for the 23 existing industrial warehousing sites, each of which included a separate zone for each of the existing buildings or groupings of buildings. The analysis tracked all heavy-duty truck trips starting or ending at one of these zones. The start of trips coming to the zones and end of trips leaving the zones were tagged to the national census block group system, allowing for aggregation to any desired geography such as the city or county level.
The land use zone system consisted of eight industrial warehousing sites in Napa County, which are listed below, and include similar existing warehousing sites in full operation during the data collection period. These sites were selected to understand the potential average trip length of heavyduty truck trips generated by the proposed project.
The “key findings” of the Fehr & Peers study, summarized on page 12, were as follows:
• The average daily trip generation per KSF of warehousing building space is 0.078 medium-duty truck trips, 0.447 heavy-duty truck trips, 0.995 auto trips, and 1.52 total vehicle trips. • The average trip length of heavy-duty truck trips generated by the eight existing Napa County industrial warehousing sites in full operation during the data collection period is 35.6 miles. • The average trip length of heavy-duty truck trips generated by the eight existing Napa County industrial warehousing sites is roughly 39 percent lower than the average trip length for all 23 Bay Area warehousing sites combined.
In short, if the Draft EIR had taken account of medium- and heavy-duty truck trips from logistics operations, as GSEJA suggested was necessary, the analysis would still have concluded that the proposed project would have less than significant VMT-related impacts.
This conclusion is also relevant to the analysis of GHG emissions for the proposed project, which employed a significance threshold very similar to one adopted relatively recently by the Bay Area Air Quality Management District (BAAQMD), by which one factor indicating a less than significant 785
City of American Canyon—Giovannoni Logistics Center Project Master Responses Final EIR
2-14 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/3 - Final EIR/54600001 Sec02-00 Master Responses.docx operational GHG impact was VMT 15 percent below the existing VMT per employee in the Bay Area Region. (Draft EIR, pages 3.6-45 and 3.6-56.) As the preceding discussion indicates, the VMT per employee for the proposed project is roughly 30 percent below the regional average. If medium- and heavy-duty truck traffic from project operations is added to the discussion, the VMT from such traffic is roughly 39 percent below the regional average. Thus, the Fehr & Peers study reinforces and fortifies the Draft EIR’s conclusion that operational GHG impacts are less than significant (Draft EIR, page 3.6-59), just as it reinforces and fortifies the Draft EIR’s conclusion that VMT-related impacts are less than significant.
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City of American Canyon—Giovannoni Logistics Center Project Final EIR Responses to Written Comments
FirstCarbon Solutions 3-1 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/3 - Final EIR/54600001 Sec03-00 Responses to Written Comments.docx SECTION 3: RESPONSES TO WRITTEN COMMENTS
3.1 - List of Authors
A list of public agencies, organizations, and individuals that provided comments on the Giovannoni Logistics Center Project Draft EIR is presented below. Each comment has been assigned a code.
Individual comments within each communication have been numbered so comments can be crossed-referenced with responses. Following this list, the text of the communication is reprinted and followed by the corresponding response.
Author Author Code
State Agencies
California Department of Transportation.................................................................................CALTRANS California Department of Fish and Wildlife .................................................................................... CDFW Local Agencies
American Canyon Fire Protection District ..................................................................................... ACFPD Tribal Government
Yocha Dehe Wintun Nation ..................................................................................................................YD Organizations
Golden State Environmental Justice Alliance ................................................................................ GSEJA1 Sentinels of Freedom............................................................................................................... SENTINELS Napa-Solano Residents For Responsible Growth .......................................................................NSSRRG2
3.2 - Responses to Comments
3.2.1 - Introduction
In accordance with the California Environmental Quality Act (CEQA) Guidelines Section 15088, the City of American Canyon, as the lead agency, evaluated the comments received on the Draft EIR (State Clearinghouse No. 2021010104) for the proposed Giovannoni Logistics Center Project (proposed project), and has prepared the following responses to the comments received. This Response to Comments document becomes part of the Final EIR for the proposed project in accordance with CEQA Guidelines Section 15132.
Comments on an EIR should focus on the sufficiency of the document’s identification and analysis of significant environmental impacts, and the adequacy of measures designed to avoid or mitigate those impacts (CEQA Guidelines § 15204(a)). Reviewers should explain the basis for their comments 1 Includes comments from SWAPE (SWAPE) 2
Includes comments from Clark & Associates (CLARK), Shannon & Wilson (S&W), Scott Cashen (CASHEN) and Smart Mobility (SM) 787
City of American Canyon—Giovannoni Logistics Center Project Responses to Written Comments Final EIR
3-2 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/3 - Final EIR/54600001 Sec03-00 Responses to Written Comments.docx and provide data, references, or other evidence to support their comments (CEQA Guidelines § 15204(c)).
CEQA requires that the Final Environmental Impact Report (Final EIR) address comments submitted during the public comment period that raise significant environmental issues (Public Resources Code [PRC] § 21091(d)(2)(B)). The lead agency’s written responses shall describe the disposition of such significant environmental issues (e.g., revisions to the proposed project to mitigate anticipated impacts or objections) CEQA Guidelines § 15088(c)).
CEQA does not require that the lead agency respond to every comment submitted to it. While conclusory statements by the lead agency unsupported by factual information will not suffice, the level of detail in the response may correspond to the level of detail in the comment. A general response may be appropriate when a comment does not contain or specifically refer to readily available information or does not explain the relevance of evidence submitted with the comment (CEQA Guidelines § 15088(c)). Additionally, the lead agency generally has considerable leeway regarding responses to comments and need not respond to comments that do not raise a significant environmental issue. The lead agency also need not respond to general reference materials submitted in support of comments, comments that repeat those already considered, or comments that are clearly irrelevant, and the lead agency has the discretion to reject comments that are not focused as provided by the CEQA Guidelines (CEQA Guidelines § 15204(e)).
Pursuant to CEQA Guidelines, personal opinions expressing general support for, or opposition to, the proposed project are noted and will be noted in the response to comments and included within the administrative record for the proposed project, but do not require a specific written response if they do not relate to a significant environmental issue that is addressed within the Draft EIR and/or otherwise within the purview of CEQA. Likewise, opinions about the general desirability, merits, and/or purely economic, social, or political considerations of the proposed project are not within the purview of CEQA and do not require a specific written response in this Final EIR. In cases where the comment provides background information, an opinion and/or generalized concerns about the merits of the proposed project but does not challenge the sufficiency of the Draft EIR, the City will note the comment in these responses and include the opinion in this Final EIR for informational purposes. Where a commenter offers unsubstantiated assertions about a significant environmental issue or the adequacy of the Draft EIR, the City will note the assertion in these responses and include the comment in the Final EIR for informational purposes but will not alter or augment the analysis in the Draft EIR, pursuant CEQA Guidelines Section 15204. Although CEQA does not require a detailed response to each of these general comments in this Final EIR, each comment is part of the administrative record on the proposed project and will be forwarded to City decision-makers for consideration.
3.2.2 - Comment Letters and Responses
The comment letters reproduced in the following pages follow the same organization as used in the List of Authors.
788
CEQA REVIEW COMMENT SHEET
USDA-Rural Development Environmental Assessment
Giovannoni Logistics Center Project
LDR GTS # 04-NAP-2021-00280
PROJECT LIMITS: 04-NAP-029 PM 3.05
REVIEWED BY: Wichai Hanittinan (510)-286-6431
Office of Highway Operations June 17, 2022
For: Yunshen Luo
Comments:
1) Suggest being specific on a period of time for the VMT mentioned in this report. Is the VMT reported for one year, one month, or one day?
2) In Appendix H Transportation Supporting Information, suggest clarifying the following sentence: "The morning peak hour occurs between 7:00 and 9:00 a.m. and reflects conditions during the home to work or school commute, while the p.m. peak hour occurs between 4:00 and 6:00 p.m. and typically reflects the highest level of congestion during the homeward bound commute."
According to its Appendix B Traffic Count Data, the peak hour at each intersection varies, especially during the AM peak period, suggest explain/describe this information in the report.
3) For the traffic count results at the Devlin Rd and S Kelly Rd intersection (intersection 2 as referred in the report) in Appendix B Traffic Count Data of Appendix H Transportation Supporting Information, why are the truck volumes more than the total traffic volumes for the same movement?
Are the truck volumes reported separately from the traffic volumes for regular vehicles? If this is the case, there are additional 36 trucks on NB Devlin Rd marking the left turn to EB S Kelly Rd during the 8-9 AM peak hour, why are they not accounted/included in the left turn traffic volumes from NB Devlin Rd to EB S Kelly Rd reported in Exhibit 3.12-4 Existing Plus Project Traffic Volumes in the Transportation section of the Draft EIR and Figure 6 – Existing Plus Project Traffic Volumes of Appendix H Transportation Supporting Information?
The same question can also be applied to the 11 trucks on NB Devlin Rd marking the left turn to EB S Kelly Rd during the 4-5 PM peak hour.
4) In Exhibit 3.12-3 Project Traffic Volumes in the Transportation section of the Draft EIR and in Figure 5 – Project Traffic Volumes of Appendix H Transportation Supporting
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Information, are the traffic volumes reported here additionally generated and reported separately as the results of the project?
And what year of these Project traffic volumes are for, are they for the existing year (2019) or the future year (2040)?
5) If the traffic volumes show in Exhibit 3.12-3 Project Traffic Volumes in the Transportation section of the Draft EIR and in Figure 5 – Project Traffic Volumes of Appendix H Transportation Supporting Information are for the future year (2040), please verify the 2458 (veh) traffic volumes for the northbound through traffic on SR 29. Should it be 2464 (veh) traffic volumes?
6) In Exhibit 3.12-3 Project Traffic Volumes in the Transportation section of the Draft EIR and in Figure 5 – Project Traffic Volumes of Appendix H Transportation Supporting Information,
6.1) Why isn't there any EB traffic on Green Island Rd making a left turn to the NB of the future Devlin Rd? Will the intersection between Green Island Rd and the future Devlin Rd prohibit the left-turn movement from the EB Green Island Rd to the NB of the future Devlin Rd? If that is the case, please document and specify it in the report.
6.2) Why isn't there any SB traffic on the future Devlin Rd making a right turn to the WB of Green Island Rd . Will the intersection between Green Island Rd and the future Devlin Rd prohibit the right-turn movement from the SB of the future Devlin Rd to the WB Green Island Rd? If that is the case, please document and specify it in the report.
7) For Exhibit 3.12-4 Existing Plus Project Traffic Volumes in the Transportation section of the Draft EIR and Figure 6 – Existing Plus Project Traffic Volumes of Appendix H Transportation Supporting Information,
If these added-on traffic volumes as the results of the project are for the future year (2040), why are they directly added to the traffic volumes for the existing year (2019) to obtain the results for Existing Plus Project Traffic Volumes as shown in the Exhibit 3.12-4 and Figure 6 mentioned above?
8) In Exhibit 3.12-5 Future Traffic Volumes in the Transportation section of the Draft EIR and in Figure 3 – Future Traffic Volumes of Appendix H Transportation Supporting Information, are these future traffic volumes for the future year (2040) under the existing conditions without the project?
9) For Exhibit 3.12-6 Future Plus Project Traffic Volumes in the Transportation section of the Draft EIR and Figure 7 – Future Plus Project Traffic Volumes of Appendix H Transportation Supporting Information,
If these added-on traffic volumes as the results of the project are for the existing year (2019), why are they directly added to the traffic volumes for the future year (2040) to obtain the results for Future Plus Project Traffic Volumes as shown in the Exhibit 3.12-4 and Figure 6 mentioned above? Are they expected to increase in the future year (2040) to get the traffic volumes for the Future Plus Project Traffic Volumes? 10) Since the traffic data presented in Appendix B Traffic Count Data of Appendix H Transportation Supporting Information were collected from a few samples, suggest also
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presenting and discussing/comparing with the historical traffic data and census, such as those obtained by Caltrans or from other sources.
For an example, the traffic volumes for the Ahead Peak Hour and Back Peak Hour at NAP 29 PM 3.601 (at the S Kelly Rd and SR-29 intersection) were 3,700 and 3,100 respectively. In addition, the average historical traffic volumes during the AM and PM peak hour(s) in weekdays at nearby SR-29 PM 3.601 can be obtained and compared with the traffic data presented in this report.
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City of American Canyon—Giovannoni Logistics Center Project Final EIR Responses to Written Comments
FirstCarbon Solutions 3-7 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/3 - Final EIR/54600001 Sec03-00 Responses to Written Comments.docx State Agencies
California Department of Transportation (CALTRANS)
Response to CALTRANS-1
The agency inquired about the time period for the Vehicle Miles Traveled (VMT) analysis (e.g., one year, one month, or one day?).
As described on page 20 of the Traffic Impact Study for the Giovannoni Logistics Center (Appendix H, Transportation Supporting Information), the VMT reported is measured in VMT per capita, or the number of daily miles driven per employee. See also Master Response 4—Vehicle Miles Traveled.
Response to CALTRANS-2
The agency requested a clarification about the description of the AM and PM peak-hours and suggested that an explanation be provided about the variation in the peak-hour at each study intersection.
The peak-hour varies from intersection to intersection, and all were evaluated based on the highestvolume hour at that location to provide a conservative analysis.
Response to CALTRANS-3
The agency inquired about discrepancies in the traffic volumes for various turn movements at Devlin Road/South Kelly Road shown on Draft EIR Section 3.12, Transportation Exhibit 3.12-4.
The reported truck values in Appendix B Traffic Count Data of Draft EIR Appendix H summarize the percentage of vehicles that are trucks at each turning movement, and do not report the number (or volume) which are trucks.
Response to CALTRANS-4
The agency inquired whether the traffic volumes shown on Draft EIR Exhibit 3.12-3 are additionally generated or reported separately. The agency inquired about the year the volumes shown on Draft EIR Exhibit 3.12-3.
The number of newly-generated vehicle trips is summarized in Draft EIR Exhibit 3.12-3. The number of trips does not change between the existing and future conditions. Therefore, these projectgenerated trips are applicable to both the Existing Plus Project and Future Plus Project conditions evaluated.
Response to CALTRANS-5
The agency requested clarification about the northbound through volumes on State Route (SR) 29 shown in Draft EIR Exhibit 3.12-3.
The value of 2,458 shown at Intersection No. 1 on Draft EIR Exhibit 3.12-6 is correct. However, the value 2,458 shown at Intersection No. 1 on Draft EIR Exhibit 3.12-5 is a typo and should be 2,451 instead. The proposed project is expected to add seven vehicles to the existing 2,451 trips without the proposed project, resulting in a volume of 2,458 when project trips are added (as depicted on Draft EIR Exhibit 3.12-6). The analysis was based on the correct number and is unaffected by this typo. The corrected Draft EIR Exhibit 3.12-5 is provided in Final EIR Section 5, Errata. 793
City of American Canyon—Giovannoni Logistics Center Project Responses to Written Comments Final EIR
3-8 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/3 - Final EIR/54600001 Sec03-00 Responses to Written Comments.docx Response to CALTRANS-6
The agency inquired about the traffic volumes at Green Island Road/Devlin Road shown in Draft EIR Exhibit 3.12-3 and requested clarification about various turn movements.
The trip distribution, summarized on Table 7 (Appendix H Transportation Supporting Information), shows all project-related traffic would solely use SR-29 to access the project site. This means there are assumed to be no trips heading to or arriving from Green Island Road west of the project site, as this route does not have a direct connection with SR-29.
Turn prohibitions are not proposed at the future intersection of Devlin Road/Green Island Road.
Response to CALTRANS-7
The agency inquired about the volumes shown in Draft EIR Exhibit 3.12-4.
The number of new trips attributable to the proposed project is constant and not anticipated to change from year to year. Therefore, the proposed project is expected to contribute the same number of vehicle trips to the roadway network during both the existing and future years.
Response to CALTRANS-8
The agency requested clarification about the traffic volumes shown on Draft EIR Exhibit 3.12-5.
As described on pages 9 through 11 of Appendix H, Transportation Supporting Information, the volumes shown in Figure 3 represent the anticipated volumes for the year 2040 without the proposed project.
Response to CALTRANS-9
The agency requested clarification about traffic volumes shown on Draft EIR Exhibit 3.12-6.
Refer to Response to CALTRANS-4 and Response to CALTRANS-7.
Response to CALTRANS-10
The agency requested the traffic volumes provided in Appendix H on SR-29 at Post Mile 3.601 be compared to historical traffic data and census.
Traffic volumes provided in Appendix H were based on actual counts taken at the study intersections.
Comparing traffic volumes in Appendix H to historical traffic data along SR-29 would not provide further insight into assessing traffic effects attributable to the proposed project. 794
State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director Bay Delta Region
2825 Cordelia Road, Suite 100
Fairfield, CA 94534
(707) 428-2002
www.wildlife.ca.gov
Conserving California’s Wildlife Since 1870
July 18, 2022
Brent Cooper
Community Development Director
City of American Canyon
4381 Broadway Street, Suite 201
American Canyon, CA 94503
[email protected]
Subject: Giovannoni Logistics Center Project, Draft Environmental Impact Report, SCH No. 2021010104, City of American Canyon, Napa County Dear Mr. Cooper:
The California Department of Fish and Wildlife (CDFW) received a Notice of Availability of a draft Environmental Impact Report (DEIR) from the City of American Canyon (City) for the Giovannoni Logistics Center Project (Project) pursuant the California Environmental Quality Act (CEQA) and CEQA Guidelines.1 CDFW previously submitted comments in response to the Notice of Preparation of the DEIR.
CDFW is submitting comments on the DEIR to inform the City, as the Lead Agency, of potentially significant impacts to biological resources associated with the Project.
CDFW ROLE
CDFW is a Trustee Agency with responsibility under CEQA pursuant to CEQA Guidelines section 15386 for commenting on projects that could impact fish, plant, and wildlife resources. CDFW is also considered a Responsible Agency if a project would require discretionary approval, such as permits issued under the California Endangered Species Act (CESA), the Lake and Streambed Alteration Program, or other provisions of the Fish and Game Code that afford protection to the state’s fish and wildlife trust resources.
PROJECT DESCRIPTION SUMMARY
Proponent: Buzz Oates
Objective: Develop a 2.4-million square-foot logistics center on an approximately 208- acre site; 163 acres would be developed, and 45 acres would be preserved as wetlands. In conjunction with the Project, the City would extend Devlin Road through the
1 CEQA is codified in the California Public Resources Code in section 21000 et seq. The “CEQA Guidelines” are found in Title 14 of the California Code of Regulations, commencing with section 15000.
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July 18, 2022
Project site. The Project is proposed to occur in two phases. During Phase 1, the 94.7- acre area east of the Devlin Road extension would be developed. During Phase 2, the 113.1-acre area west of Devlin Road would be developed.
Location: The Project site is in the City of American Canyon, approximately one mile southeast of the Napa County Airport and directly west of State Route 29, in southern Napa County. The Project site is bounded by the Napa Logistics Park and Devlin Road to the north and Green Island Business Park (i.e., industrial development) to the southwest, and centered at approximately Latitude 38.198921°N, Longitude 122.268598°W.
REGULATORY REQUIREMENTS
California Endangered Species Act
Please be advised that a CESA Incidental Take Permit (ITP) must be obtained if the Project has the potential to result in “take” of plants or animals listed under CESA, either during construction or over the life of the Project. The Project has the potential to impact Swainson’s hawk (Buteo swainsoni) and tricolored blackbird (Agelaius tricolor), both of which are CESA listed as threatened species, as further described below. Issuance of an ITP is subject to CEQA documentation; the CEQA document must specify impacts, mitigation measures, and a mitigation monitoring and reporting program. If the Project will impact CESA listed species, early consultation is encouraged, as significant modification to the Project and mitigation measures may be required in order to obtain an ITP.
CEQA requires a Mandatory Finding of Significance if a project is likely to substantially restrict the range or reduce the population of a threatened or endangered species. (Pub.
Resources Code, §§ 21001, subd. (c) & 21083; CEQA Guidelines, §§ 15380, 15064, & 15065). Impacts must be avoided or mitigated to less-than-significant levels unless the CEQA Lead Agency makes and supports Findings of Overriding Consideration (FOC).
The CEQA Lead Agency’s FOC does not eliminate the project proponent’s obligation to comply with CESA.
Fully Protected Species
Fully Protected species, such as golden eagle (Aquila chrysaetos), may not be taken or possessed at any time (Fish & G. Code, §§ 3511, 4700, 5050, & 5515) except for collecting these species for necessary scientific research, relocation of the bird species for the protection of livestock, or if they are a covered species whose conservation and management is provided for in a Natural Community Conservation Plan.
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City of American Canyon
July 18, 2022
COMMENTS AND RECOMMENDATIONS
CDFW offers the comments and recommendations below to assist the City in adequately identifying and/or mitigating the Project’s significant, or potentially significant, direct and indirect impacts on fish and wildlife (biological) resources. Editorial comments or other suggestions may also be included to improve the document. Based on the potential for the Project to have a significant impact on biological resources, CDFW concludes that an environmental impact report is appropriate for the Project.
Mandatory Findings of Significance: Does the Project have the potential to substantially reduce the number or restrict the range of an endangered, rare, or threatened species?
Environmental Setting and Mitigation Measures
COMMENT 1: Swainson’s Hawk MM BIO-1a (Section 3.3, Pages 24-27) Issue: Mitigation measure (MM) BIO-1a identifies a 1,000-foot no disturbance buffer shall be established for any Swainson’s hawk nest, which may be insufficient to reduce impacts to Swainson’s hawk to less-than-significant and comply with CESA.
Furthermore, the language of MM BIO-1a regarding when surveys will occur should be revised for clarity to ensure any nesting Swainson’s hawks that could be disturbed by the Project are detected. In the first paragraph it states that surveys will be completed for at least two survey periods prior to commencement of construction. In the second paragraph it inconsistently states that construction may commence if no nesting Swainson’s hawks are found during the first non-optional survey period.
Additionally, the DEIR identifies the Project will remove Swainson’s hawk foraging habitat, but it does not specify the number of acres that the Project will remove.
Therefore, the approximately 45 acres of wetlands that will be preserved by the Project may not be sufficient to mitigate for the loss of Swainson’s hawk foraging habitat.
Additionally, please note that the presence of suitable Swainson’s hawk foraging habitat near the Project site does not negate the need to mitigate for the permanent removal of foraging habitat for this species.
Specific impacts and why they may occur and be significant: If active Swainson’s hawk nests are not detected by the proposed surveys or appropriate buffer zones are not established, Swainson’s hawks could be disturbed by Project activities resulting in nest abandonment and loss of eggs or reduced health and vigor and loss of young, thereby substantially reducing the number of the species. Additionally, loss of foraging habitat is the primary threat to Swainson’s hawk populations in California (CDFW 2016).
Swainson’s hawk is CESA listed as a threatened species and therefore is considered to be a threatened species pursuant to CEQA Guidelines section 15380. Therefore, if an DocuSign Envelope ID: A59D3452-8C9D-4684-8C9C-56BA7F98131A 797
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active Swainson’s hawk nest is disturbed by the Project, the Project may result in a substantial reduction in the number of a threatened species, which is considered a Mandatory Finding of Significance pursuant to CEQA Guidelines section 15065, subdivision (a)(1).
Recommendation: For an adequate environmental setting, to reduce impacts to Swainson’s hawk to less-than-significant, and to comply with CESA, CDFW recommends revising MM BIO-1a to require that Swainson’s hawk surveys be conducted by a qualified biologist with experience surveying for and detecting the species pursuant to the Recommended timing and methodology for Swainson’s Hawk Nesting Surveys in California’s Central Valley Swainson’s Hawk (2000) survey protocol, within 0.5 mile of the Project site each year that Project activities occur. Pursuant to the above survey protocol, surveys shall be completed for at least the two survey periods immediately prior to a Project’s initiation. For example, if the project is scheduled to begin on June 20, the qualified biologist shall complete three surveys in Period III and three surveys in Period V. It is recommended that surveys be completed in Periods II, III and V. Surveys in Period I may be required if the Project will commence by April 5. The Project shall obtain CDFW’s written acceptance of the qualified biologist and survey report prior to Project construction occurring between March 1 and August 31 each year. If the qualified biologist identifies nesting Swainson’s hawks, the Project shall implement a 0.5 mile no disturbance buffer zone around the nest, unless otherwise approved in writing by CDFW. Project activities shall be prohibited within the buffer zone between March 1 and August 31, unless otherwise approved in writing by CDFW. If take of Swainson’s hawk cannot be avoided, the Project shall consult with CDFW pursuant to CESA and obtain an ITP.
Additionally, to mitigate for the loss of foraging habitat, CDFW recommends including a mitigation measure that requires the preservation through a conservation easement of Swainson’s hawk foraging habitat, of equal or greater habitat value than that which will be impacted by the Project, in perpetuity at a minimum 1:1 mitigation to impact ratio.
CDFW must provide written approval of the habitat proposed for preservation prior to the start of Project activities.
COMMENT 2: Tricolored Blackbird (Section 3.3, Page 26)
Issue: The DEIR identifies there will be no impact on tricolored blackbird because there is no suitable nesting habitat within the Project site. However, the Project may impact tricolored blackbird that occur within 500 feet of the Project site.
Specific impacts and why they may occur and be significant: If active tricolored blackbird nests are not detected by the proposed surveys or appropriate buffer zones are not established, tricolored blackbird could be disturbed by Project activities resulting in nest abandonment and loss of eggs or reduced health and vigor and loss of young, DocuSign Envelope ID: A59D3452-8C9D-4684-8C9C-56BA7F98131A 798
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thereby substantially reducing the number of the species. Tricolored blackbird is CESA listed as a threatened species and therefore is considered to be a threatened species pursuant to CEQA Guidelines section 15380. Therefore, if an active tricolored blackbird nest is disturbed by the Project, the Project may result in a substantial reduction in the number of a threatened species, which is considered a Mandatory Finding of Significance pursuant to CEQA Guidelines section 15065, subdivision (a)(1).
Recommendation: For an adequate environmental setting, to reduce impacts to tricolored blackbird to less-than-significant, and to comply with CESA, CDFW recommends revising MM BIO-4 to require that a survey for active tricolored blackbird nests shall be conducted by a qualified biologist within seven days prior to the beginning of Project activities, and within a minimum 500-foot distance of the Project. If nesting bird surveys, per MM BIO-4, detect nesting tricolored blackbird or evidence of their presence, CDFW shall be notified immediately, and Project activities shall not occur without written approval from CDFW allowing the Project to proceed. Presence of nesting tricolored blackbird may require CESA consultation and an Incidental Take Permit before Project activities may commence. If a lapse in Project construction of seven days or more occurs during nesting season, another survey shall be conducted.
Please note, this also addresses impacts to nesting birds, which are protected under Fish and Game Code sections 3503, 3503.5, and 3513. Migratory birds are also protected under the federal Migratory Bird Treaty Act.
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 CDFW or U.S. Fish and Wildlife Service?
Mitigation Measures
COMMENT 3: Golden Eagle MM-BIO 1b (Section 3.3, Pages 27) Issue: MM-BIO 1b identifies a 1,000-foot no disturbance buffer shall be established for any golden eagle nests within 1,000 feet of construction activities, which may be insufficient to reduce impacts to golden eagle to less-than-significant. Additionally, the measure allows for modification of the buffer zone depending on behavioral factors and acclimation of nesting golden eagles. CDFW should be consulted before implementation of a reduced buffer zone to ensure protection of any nesting golden eagle.
Specific impacts and why they may occur and be significant: Golden eagle is a fully protected species and may not be taken or possessed at any time, except as described above (Fish & G. Code, §§ 3511), and is also protected under the federal Bald and Golden Eagle Protection Act. Golden eagle is highly sensitive to human disturbance which can result in lower brood size (Steenhof et al. 2014), lower nest DocuSign Envelope ID: A59D3452-8C9D-4684-8C9C-56BA7F98131A 799
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attendance (Spaul and Heath 2016), and increased time spent away from the nest (Spaul and Heath 2017). If appropriate buffer zones are not established around active golden eagle nests, Project impacts to golden eagle would be potentially significant.
Recommendation: For an adequate environmental setting and to reduce impacts to golden eagle to less-than-significant, CDFW recommends revising MM BIO-1b to require that the survey area for golden eagle shall be determined by a qualified Raptor Biologist in consultation with CDFW, and if any golden eagle nest is identified during pre-construction golden eagle nesting surveys, a biological based justification for the buffer zone, as determined by a qualified Raptor Biologist, shall be submitted to CDFW for review. Project activities shall not proceed between March 1 and August 31 unless CDFW provides written approval of the buffer zone around any golden eagle nest.
COMMENT 4: Northern Harrier MM-BIO 1c (Section 3.3, Pages 27) Issue: It appears that surveys for nesting northern harrier (Circus hudsonius) would only occur within the Project site. However, nesting northern harrier may be impacted if they occur off-site within a minimum 500-foot radius around the Project site.
Additionally, MM-BIO 1c allows for modification of the buffer zone depending on behavioral factors and acclimation of northern harrier. CDFW should be consulted before implementation of a reduced buffer zone.
Specific impact and why they may occur and be significant: If an active northern harrier nest is present within a minimum of 500 feet of the Project and is not detected by the proposed surveys, or appropriate no disturbance buffer zones are not implemented, nesting northern harriers could be disturbed by Project activities resulting in nest abandonment and loss of eggs or reduced health and vigor and loss of young. Northern harrier is a California Species of Special Concern (SSC). An SSC is a species, subspecies, or distinct population of an animal native to California that currently satisfies one or more of the following (not necessarily mutually exclusive) criteria: is extirpated from the State or, in the case of birds, is extirpated in its primary season or breeding role; is listed as Federally-, but not State-, threatened or endangered; meets the State definition of threatened or endangered but has not formally been listed; is experiencing, or formerly experienced, serious (noncyclical) population declines or range retractions that, if continued or resumed, could qualify it for State threatened or endangered status; or has naturally small populations exhibiting high susceptibility to risk from any factor(s), that if realized, could lead to declines that would qualify it for State threatened or endangered status. Therefore, if nesting northern harriers are present and would be disturbed by the Project, impacts to northern harrier would be potentially significant.
Recommendation: For an adequate environmental setting and to reduce impacts to northern harrier to less-than-significant, CDFW recommends revising MM BIO-1c to DocuSign Envelope ID: A59D3452-8C9D-4684-8C9C-56BA7F98131A 800
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require submission of a biological based justification for reducing the buffer zone, as determined by the qualified Raptor Biologist, to CDFW for review. Project activities shall not commence until CDFW provides written approval for the reduction of the no disturbance buffer zone around any northern harrier nest.
Additionally, MM BIO-1c should be revised to state that surveys shall be conducted to determine the presence of nesting northern harrier within a minimum 500-foot radius around the Project site.
COMMENT 5: Burrowing Owl MM BIO-1d (Section 3.3, Page 28) Issue: MM BIO-1d indicates that surveys for burrowing owl (Athena cunicularia) would occur within two weeks prior to Project construction and a 100-foot no disturbance buffer would be implemented around refugia occupied by non-nesting wintering owls.
However, the aforementioned survey and buffer distance may not be adequate to detect and avoid Project impacts to burrowing owls. The Project may result in the loss of burrowing owl breeding and non-breeding habitat and would likely result in the loss of foraging habitat.
Specific impacts and why they may occur and be significant: The Project could result in burrowing owl nest abandonment, loss of young, reduced health and vigor of owlets, or injury or mortality of adults, and a permanent reduction of burrowing owl habitat in Napa County.
Burrowing owl is an SSC because the species’ population viability and survival are adversely affected by risk factors such as precipitous declines from habitat loss, fragmentation, and degradation; evictions from nesting sites without habitat mitigation; wind turbine mortality; human disturbance; and eradication of California ground squirrels (Spermophilus beecheyi) resulting in a loss of suitable burrows required by burrowing owls for nesting, protection from predators, and shelter (Shuford and Gardali 2008; CDFW 2012 Staff Report; personal communication, CDFW Statewide Burrowing Owl Coordinator Esther Burkett, May 13, 2022). Preliminary analyses of regional patterns for breeding populations of burrowing owls have detected declines both locally in their central and southern coastal breeding areas, and statewide where the species has experienced breeding range retraction (CDFW 2012 Staff Report; personal communication, Esther Burkett, May 13, 2022).
Historically, the most abundant populations of burrowing owl within the San Francisco Bay Area were in Alameda, Contra Costa, and Santa Clara counties and populations were locally abundant within portions of Solano and San Mateo counties. Burrowing owls are no longer abundant and may be disappearing entirely from western Contra Costa, western Alameda, and Santa Clara counties. Breeding burrowing owls may be extirpated in Marin County, and only use the region on a limited basis in winter DocuSign Envelope ID: A59D3452-8C9D-4684-8C9C-56BA7F98131A 801
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(Townsend and Lenihan 2007 as cited in Sheffield 2021). Habitat loss caused by development is the most immediate threat to burrowing owls in high growth areas of the San Francisco Bay Area, and loss of burrowing owl habitat will likely continue well into the future (Townsend and Lenihan 2007). As urbanization increases and local burrowing owl populations decline, they become vulnerable to stochastic events (demographic, genetic, and environmental) associated with small population size, creating the potential for an extinction “vortex” (Gilpin and Soulé 1986 as cited in Townsend and Lenihan 2007).
Based on the above, if the Project would result in impacts to burrowing owl, Project impacts to burrowing owls would be potentially significant.
Recommendation: For an adequate environmental setting and to reduce impacts to burrowing owl to less-than-significant, CDFW recommends that MM BIO-1d be revised to require that a habitat assessment, and if warranted based on the habitat assessment breeding and non-breeding surveys, be conducted in conformance with the CDFW 2012 Staff Report on Burrowing Owl Mitigation (2012 Staff Report), which states: A) breeding season surveys should include four survey visits: 1) at least one site visit between 15 February and 15 April, and 2) a minimum of three survey visits, at least three weeks apart, between 15 April and 15 July, with at least one visit after 15 June; and B) nonbreeding season surveys shall be conducted according to the methods described for breeding season surveys (i.e., a minimum of three survey visits, at least three weeks apart), but conduct at least four visits, spread evenly throughout the non-breeding season. The habitat assessment and surveys shall be conducted within 500 meters (1,640 feet) of the Project site for breeding or non-breeding burrowing owls and the no disturbance buffer distance of 500 meters outlined in the 2012 Staff Report shall be implemented, unless otherwise approved in writing by CDFW.
Additionally, pursuant to the 2012 Staff Report, CDFW does not consider eviction of western burrowing owl (i.e., passive removal of an owl from its burrow or other shelter) as a “take” avoidance, minimization, or mitigation measure. Therefore, to reduce impacts to burrowing owl to less-than-significant, off-site habitat compensation shall be included in the eviction plan. Habitat compensation acreages shall be approved by CDFW, as the amount depends on site-specific conditions, and completed before Project construction. It shall also include placement of a conservation easement and preparation and implementation of a long-term management plan.
If the Project would impact an unoccupied nesting burrowing owl burrow or burrow surrogate (i.e., a burrow known to have been used in the past three years for nesting), or an occupied burrow (where a non-nesting owl would be evicted as described above), the following habitat mitigation shall be implemented prior to Project construction:
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Impacts to each nesting site shall be mitigated by permanent preservation of two occupied nesting sites with appropriate foraging habitat within Solano County, unless otherwise approved by CDFW, through a conservation easement and implementing and funding a long-term management plan in perpetuity. The same requirements shall apply for impacts to non-nesting evicted owl sites.
Impacts to burrowing owl foraging habitat shall be mitigated by permanent preservation through a conservation easement of foraging habitat at a 1:1 mitigation to impact ratio, in the same manner described above, and accepted by CDFW in writing. The CDFW 2012 Staff Report states, “current scientific literature supports the conclusion that mitigation for permanent habitat loss necessitates replacement with an equivalent or greater habitat area for breeding, foraging, wintering, dispersal…”
EDITORIAL SUGGESTIONS
Clarify the development footprint for the Project component compared to the Program component. It is unclear if the 208-acre Project site will be used for both Phase 1 and Phase 2, or if a different site will be used for Phase 2.
The Project Summary (Section 2.3.1) indicates 163-acres will be developed. However, it also states that the Phase 1 will develop 94.7 acres and Phase 2 will develop 113.1 acres, for a total of approximately 208 acres. If the 208-acre Project site is specific to Phase 1, and only 94.7 acres will be developed during Phase 1, it is unclear what is occurring on the remaining 68.3 acres of the 163 acres planned for development.
CDFW recommends providing an aerial image outlining where both Phase 1 and Phase 2 development will occur, as well as the 44.8 acres that will be preserved as open space.
ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports and negative declarations be incorporated into a database which may be used to make subsequent or supplemental environmental determinations. (Pub. Resources Code, § 21003, subd. (e)). Accordingly, please report any special-status species and natural communities detected during Project surveys to the California Natural Diversity Database (CNDDB). The CNNDB field survey form can be filled out and submitted online at the following link: https://wildlife.ca.gov/Data/CNDDB/Submitting-Data. The types of information reported to CNDDB can be found at the following link:
https://www.wildlife.ca.gov/Data/CNDDB/Plants-and-Animals.
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City of American Canyon
July 18, 2022
ENVIRONMENTAL DOCUMENT FILING FEES
The Project, as proposed, would have an impact on fish and/or wildlife, and assessment of environmental document filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the Lead Agency and serve to help defray the cost of environmental review by CDFW. Payment of the environmental document filing fee is required in order for the underlying project approval to be operative, vested, and final. (Cal. Code Regs, tit. 14, § 753.5; Fish & G. Code, § 711.4; Pub. Resources Code, § 21089).
CONCLUSION
CDFW appreciates the opportunity to comment on the DEIR to assist the City in identifying and mitigating Project impacts on biological resources.
Questions regarding this letter or further coordination should be directed to Alicia Bird, Environmental Scientist, at (707) 980-5154 or [email protected]; or Melanie Day, Senior Environmental Scientist (Supervisory), at (707) 210-4415 or [email protected].
Sincerely,
Erin Chappell
Regional Manager
Bay Delta Region
ec: Office of Planning and Research, State Clearinghouse (SCH No. 2021010104)
REFERENCES
CDFW. 2016. Status Review: Swainson’s Hawk (Buteo swainsoni) in California.
Prepared for the California Fish and Game Commission. Nongame Bird and Mammal Program 1416 Ninth Street, Sacramento, CA.
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=133622&inline Shuford, W. D., and Gardali, T., editors. 2008. California Bird Species of Special Concern: A ranked assessment of species, subspecies, and distinct populations of birds of immediate conservation concern in California. Studies of Western Birds 1. Western Field Ornithologists, Camarillo, California, and California Department of Fish and Game, Sacramento.
DocuSign Envelope ID: A59D3452-8C9D-4684-8C9C-56BA7F98131A 804
Brent Cooper
City of American Canyon
July 18, 2022