Agenda packet — American Canyon City Council, March 21, 2023 (part 3 of 21)

The hazardous materials transportation regulations require carriers transporting hazardous materials to receive training in the handling and transportation of hazardous materials. Training requirements include pre-trip safety inspections; use of vehicle controls and equipment, including emergency equipment; procedures for safe operation of the transport vehicle; instruction on the properties of the hazardous material being transported; and loading and unloading procedures. All drivers must possess a commercial driver’s license as required by 49 Code of Federal Regulations Part 383.

Vehicles transporting hazardous materials must be properly placarded. In addition, the carrier is responsible for the safe unloading of hazardous materials at the site, and operators must follow specific procedures during unloading to minimize the potential for an accidental release of hazardous materials.

State
Cortese List
The provisions in Government Code Section 65962.5 are commonly referred to as the “Cortese List.” The list, or a site’s presence on the list, has bearing on the local permitting process as well as on compliance with the California Environmental Quality Act (CEQA). While Government Code Section 65962.5 makes reference to the preparation of a “list,” many changes have occurred related to webbased information access since 1992 and this information is now largely available on the websites of GeoTracker and EnviroStor. Those requesting a copy of the Cortese “list” are now referred directly to the appropriate information resources contained on the internet web sites (e.g., GeoTracker and EnviroStor).

Handling and Storage of Hazardous Waste
The handling and storage of hazardous materials is regulated on the federal level by the EPA under the CERCLA as amended by the Superfund Amendments and Reauthorization Act (SARA). Under SARA Title III, a nationwide emergency planning and response program was established that imposed reporting requirements for businesses that store, handle, or produce significant quantities of hazardous or acutely toxic substances as defined under federal laws. SARA Title III required each state to implement a comprehensive system to inform federal authorities, local agencies, and the public when a significant quantity of hazardous, acutely toxic substances are stored or handled at a facility.

In California, the handling and storage of hazardous materials is regulated by Chapter 6.95 of the California Health and Safety Code. Under Sections 25500-25543.3, facilities handling hazardous materials are required to prepare a Hazardous Materials Business Plan. The business plan provides information to the local emergency response agency regarding the types and quantities of hazardous materials stored at a facility and provides detailed emergency planning and response procedures in the event of a hazardous materials release. In the event that a facility stores quantities of specific acutely hazardous materials above the thresholds set forth by the California code, facilities are 443
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California Hazardous Waste Control Law
The California Hazardous Waste Control Law (HWCL) is administered by the California Environmental Protection Agency (Cal/EPA) to regulate hazardous wastes. While the HWCL is generally more stringent than RCRA, until the EPA approves the California program, both the State and federal laws apply in California. The HWCL lists 791 chemicals and approximately 300 common materials that may be hazardous; establishes criteria for identifying, packaging, and labeling hazardous wastes; prescribes management controls; establishes permit requirements for treatment, storage, disposal, and transportation; and identifies some wastes that cannot be disposed of in landfills.

The California Code of Regulations, Title 22, Chapter 11, Article 2, Section 66261.10 defines hazardous waste as a substance that may:
(1) Cause, or significantly contribute to, an increase in mortality or an increase in serious irreversible or incapacitating reversible, illness; or (2) pose a substantial present or potential hazard to human health or environment when improperly treated, stored, transported, or disposed or otherwise managed.

According to California Code of Regulations Title 22, substances having a characteristic of toxicity, ignitability, corrosivity, or reactivity are considered hazardous waste. Hazardous wastes are hazardous substances that no longer have a practical use, such as material that has been abandoned, discarded, spilled, or contaminated or is being stored prior to proper disposal.

Toxic substances may cause short-term or long-lasting health effects, ranging from temporary effects to permanent disability or death. For example, toxic substances can cause eye or skin irritation, disorientation, headache, nausea, allergic reactions, acute poisoning, chronic illness, or other adverse health effects if human exposure exceeds certain levels. (The level depends on the substance involved.) Carcinogens (substances known to cause cancer) are a special class of toxic substances. Examples of toxic substances include most heavy metals, pesticides, and benzene (a carcinogenic component of gasoline). Ignitable substances are hazardous because of their flammable properties. Gasoline, hexane, and natural gas are examples of ignitable substances. Corrosive substances are chemically active and can damage other materials or cause severe bums upon contact. Examples include strong acids and bases such as sulfuric (battery) acid or lye. Reactive substances may cause explosions or generate gases or fumes. Explosives, pressurized canisters, and pure sodium metal (which reacts violently with water) are examples of reactive materials.

Other types of hazardous materials include radioactive and biohazardous materials. Radioactive materials and wastes contain radioisotopes, which are atoms with unstable nuclei that emit ionizing radiation to increase their stability. Radioactive waste mixed with chemical hazardous waste is referred to as “mixed wastes.” Biohazardous materials and wastes include anything derived from living organisms. They may be contaminated with disease-causing agents, such as bacteria or viruses. 444
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The Porter-Cologne Water Quality Act (California Water Code, Section 13000, et seq.) established the authority of the State Water Board and provided the Regional Water Quality Control Board (RWQCB) with the primary responsibility of the protection of water quality in the State of California.

Hazardous Materials Worker Safety
Cal/OSHA and the Federal Occupational Safety and Health Administration (OSHA) are the agencies responsible for assuring worker safety by developing and enforcing workplace safety regulations in the handling and use of chemicals in the workplace. Cal/OSHA standards are generally more stringent than federal regulations. The employer is required to monitor worker exposure to listed hazardous substances and notify workers of exposure (8 CCR §§ 337-340, Chapter 3.2). The regulations specify requirements for employee training, availability of safety equipment, accident prevention programs, and hazardous substance exposure warnings.

California Fire Code
California Code of Regulations, Title 24, also known as the California Building Standards Code, contains the California Fire Code at Part 9. The California Fire Code includes provisions and standards for emergency planning and preparedness, fire service features, fire protection systems, hazardous materials, fire flow requirements, and fire hydrant locations and distribution. The Fire Code requires two points of vehicular access for any nonresidential building 30 feet tall or higher.

California Department of Transportation and California Highway Patrol The California Vehicle Code Section 31303 requires that hazardous materials be transported via routes with the least overall travel time and prohibits the transportation of hazardous materials through residential neighborhoods. In California, the California Highway Patrol (CHP) is authorized to designate and enforce route restrictions for the transportation of hazardous materials. To operate in California, all hazardous waste transporters must be registered with the California Department of Toxic Substances Control (DTSC). Unless specifically exempted, hazardous waste transporters must comply with the CHP Regulations, the California State Fire Marshal Regulations, and the USDOT Regulations. In addition, hazardous waste transporters must comply with Division 20, Chapter 6.5, Article 6 and 13 of the California Health and Safety Code, and the Title 22, Division 4.5, Chapter 13 of the California Code of Regulations, both of which are administered by the DTSC.

San Francisco Bay Regional Water Quality Control Board
There are nine RWQCBs throughout the State. The San Francisco Bay RWQCB has jurisdiction over the City of American Canyon. Individual RWQCBs function as the lead agencies responsible for identifying, monitoring, and cleaning up Leaking Underground Storage Tanks (LUSTs). Storage of 445
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California State Aeronautics Act
The State Aeronautics Act, Public Utilities Code Section 21001, et seq., is the foundation for the California Department of Transportation (Caltrans) Division of Aeronautics aviation policies. The Division issues permits for and annually inspects hospital heliports and public use airports, makes recommendations regarding proposed school sites within 2 miles of an airport runway, and authorizes helicopter landing sites at/near schools. Aviation system planning provides for the integration of aviation into transportation system planning on a regional, statewide, and national basis. The Division of Aeronautics administers noise regulation and land use planning laws that foster compatible land use around airports and encourages environmental mitigation measures to lessen noise, air pollution, and other impacts caused by aviation. The Division of Aeronautics also provides grants and loans for safety, maintenance, and capital improvement projects at airports.

Local
City of American Canyon
General Plan
The City of American Canyon General Plan sets forth the following guiding and implementing policies relevant to hazards and hazardous materials:

Goal 1N Ensure the compatibility of development within American Canyon with the Napa County Airport.

Objective 1.27 Ensure that lands in American Canyon are developed in a manner which protects them from the noise and operational impacts of, and does not adversely constrain, the Napa County Airport.

Policy
Policy 1.27.2 Review all applications for new development, expansion of existing uses, and re-use within Napa County Airport Compatibility Zones “A” through “E” for compliance with the appropriate use and development conditions.

Goal 6A Maintain a high level of fire protection and emergency services to City/District businesses and residences.

Objective 6.3 Ensure that the Fire District’s facility, manpower and equipment needs keep pace with the City’s growth.

Policy
Policy 6.3.1 Require that City planning staff work closely with Fire District officials to ensure that fie facilities and personnel are expanded commensurably to serve the needs of the City’s growing population and development base.
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County of Napa
Napa County Airport Land Use Compatibility Plan
The Airport Land Use Compatibility Plan (ALUCP) governs land use around two Napa County aviation facilities: the Napa County Airport and Parrett Field in Angwin. The ALUCP was adopted by the Napa County Airport Land Use Commission in April 1991 and revised in December 1999.

Flight Hazards
The ALUCP identifies two categories of flight hazards: physical obstructions and land use characteristics.

Physical obstructions are associated with tall objects or structures. The ALUCP establishes a height restriction ranging from 50 feet to 185 feet above ground level.

Land use characteristics involve uses that may produce hazards to aviation. Specific characteristics prohibited within the airport land use planning boundaries are listed below:
• Glare or distracting lights, which could be mistaken for airport lights • Sources of dust, steam, or smoke that may impair pilot visibility • Sources of electrical interference with aircraft communications or navigation • Any use that may attract large flocks or birds, especially landfills or certain agricultural uses Zone D
The ALUCP provides the following description of Zone D in Table 3-1:

Common Traffic Pattern: This area is defined by the flight pattern of each airport and illustrated in the respective “Airport Impact Areas” figures contained in Part III.

The ALUCP establishes the following standards for Zone D:
• Maximum density recommendation of 100 persons per acre inside structures for nonresidential uses.
• Maximum density recommendation of 150 persons per acre (both indoors and outdoors) for nonresidential uses.
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• Uses hazardous to flight are prohibited (i.e., features that attract large numbers of birds and sources of smoke, glare, distracting lights, or electrical interference). • Overflight easement or deed restrictions are required. • Building envelopes and approach surfaces are required on all development plans within 100 feet of approach zones.
• Clustering is encouraged to maximize open land areas. • Noise level reduction measures may be required for noise-sensitive uses.

The ALUCP states that most nonresidential uses are considered “normally acceptable” within Zone D.

Schools, libraries, hospitals, nursing homes, large shopping malls, amphitheaters, and ponds are identified as “not normally acceptable” within Zone D.

3.7.4 - Methodology
FirstCarbon Solutions evaluated potential impacts on hazards and hazardous materials through site reconnaissance, review of the State Water Board GeoTracker Database, and site reconnaissance performed in February 2021.

3.7.5 - Thresholds of Significance
Appendix G to the CEQA Guidelines is a sample Initial Study Checklist that includes questions for determining whether impacts related to hazards and hazardous materials are significant. These questions reflect the input of planning and environmental professionals at the Governor’s Office of Planning and Research (OPR) and the California Natural Resources Agency, based on input from stakeholder groups and experts in various other governmental agencies, nonprofits, and leading environmental consulting firms. As a result, many lead agencies derive their significance criteria from the questions posed in Appendix G. The City has chosen to do so for this project. Thus, the proposed project would have a significant effect if it would:
a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials;
b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment;
c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school (refer to Section 7, Effects Found not to be Significant);
d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment;
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g) Expose people or structures, either directly or indirectly to a significant risk of loss, injury, or death involving wildland fires (refer to Section 7, Effects Found not to be Significant).

3.7.6 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the development of the project and provides mitigation measures where appropriate.

Routine Transport, Use, or Disposal of Hazardous Materials/Risk of Upset Impact HAZ-1: Buildout of the proposed project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials and would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the likely release of hazardous materials into the environment.

Impact Analysis
Phases 1 and 2
The proposed project contemplates the development of a 2.4-million-square-foot logistics center on 163 acres of the project site and the preservation of the remaining 45 acres as open space.

Construction
Construction activities would entail the use of heavy equipment on the project site. Potential hazardous materials transported, used, or disposed of during project construction would be limited to commonly used substances such as gasoline, diesel, oil, grease, mechanical fluids, paints, and cleaning solvents. Construction equipment would be serviced by trained technicians and potentially hazardous materials would be stored in secured facilities. Furthermore, the safe handling of these commonly used substances is governed by occupational health and safety laws and regulations and construction contract requirements. Therefore, the use of this equipment and these substances during construction would not present any undue risks to the public or the environment.

Operation
High-cube warehouse facilities are typically used for distribution, fulfillment, and storage of nonhazardous commodities, goods, and manufactured products. As such, no large quantity hazardous materials users are contemplated as end users.

Project end users would be expected to handle small quantities of commonly used hazardous substances such as cleaning solvents, diesel, gasoline, grease/degreasers, mechanical fluids, and oil as part of daily operations. Given the small quantities involved and the characteristics of use (e.g., routine maintenance and cleaning), their use would not be considered a potential risk to human 449
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Conclusion
In summary, the construction and operational activities of the proposed project would not create a significant hazard to the public or environment. 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.

Government Code Section 65962.5 Sites
Impact HAZ-2: The proposed project would not be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would not create a significant hazard to the public or the environment.

Cortese List
The project site is not listed on the Cortese List, which includes various hazardous materials databases compiled to Government Code 65962.5.

Four sites within 0.5 mile of the project site are listed on the Cortese List. All are listed as “Case Closed,” signifying that the regulatory agency with jurisdiction has determined that no further action is necessary. Thus, they do not pose a risk to human health or the environment.

Agricultural Chemicals
The project site does not support cultivated agriculture. Aerial photographs and historic topographical maps indicate that the project site has not supported cultivated agricultural production. Thus, there is no basis to assume presence of agricultural chemicals, including herbicides and pesticides.
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The project site does not contain any structures. Aerial photographs and historic topographical maps indicate that the project site has not supported structures. Thus, there is no basis to assume presence of hazardous building materials including asbestos, lead, or PCBs.

Radon
The California Department of Health Services has conducted more than 48,000 indoor radon tests in more than 1,700 zip codes through the State, including in the 94503 (American Canyon) zip code. A total of 18 tests have been conducted in the 94503 zip code, none of which yielded indoor radon levels above 4 pCi/l.

Moreover, the proposed project proposes slab-on-grade construction, which has a low susceptibility to radon intrusion. In contrast, buildings with subsurface spaces such as basements or parking garages have a much higher susceptibility to radon intrusion.

Electromagnetic Fields
There are no high voltage electrical facilities within 0.5 mile of the project site. As such, the proposed project site would not be exposed to high levels of low-frequency EMFs.

Conclusion
The proposed project would not be exposed to hazards or hazardous materials from past uses of the project site. 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.

Airports
Impact HAZ-3: The proposed project may create aviation safety hazards for persons residing or working within 2 miles of the Napa County Airport.

Impact Analysis
Phases 1 and 2
The 208-acre project site is located 2,400 feet south of the Napa County Airport and is within Zone D of the Napa County Airport Land Use Compatibility Plan.

Although, as explained in Section 3.5.6 of this Draft Environmental Impact Report (Draft EIR), the California Supreme Court, in California Building Industry Association v. Bay Area Air Quality Management District (2015) 62 Cal.4th 369, 377, has held generally “agencies subject to CEQA generally are not required to analyze the impact of existing environmental conditions on a project’s 451
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The Napa County Airport Land Use Compatibility Plan states that most nonresidential uses are considered “normally acceptable” within Zone D. Schools, libraries, hospitals, nursing homes, large shopping malls, amphitheaters, and ponds are identified as “not normally acceptable” within Zone D. In addition, uses that are hazardous to flight are prohibited (i.e., features that attract large numbers of birds and are sources of smoke, glare, distracting lights, or electrical interference). The ALUCP encourages clustering to maximize open land areas and requires limits on building envelopes and building heights on all development plans within 100 feet of approach zones.

The proposed project’s end uses are all nonresidential and are acceptable within Zone D.

Finally, there are no project attributes that would produce sources of smoke, glare, distracting lights, or electrical interference. Therefore, the proposed project complies with the applicable safety requirements of Zone D. As such, the proposed project would not create aviation safety hazards for persons residing or working within 2 miles of the Napa County Airport. Impacts would be less than significant.

Level of Significance Before Mitigation
Potentially significant impact.

Mitigation Measures
No mitigation is necessary.

Level of Significance After Mitigation
Less than significant impact.

Emergency Response and Evacuation
Impact HAZ-4: The proposed project would not impair emergency response or evacuation in the project vicinity.

Impact Analysis
Phases 1 and 2
The proposed project would take vehicular access from multiple driveways on Green Island Road and Devlin Road. Phase 1 would have four driveways of Green Island Road and three driveways on Devlin Road. Reciprocal access would be provided between the two Phase 1 buildings. Accordingly, the proposed project would provide two points of emergency access and, thus, would comply with California Fire Code requirements.
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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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3.8 - Hydrology and Water Quality

3.8.1 - Introduction
This section describes the existing hydrology and water quality setting and potential effects from project implementation on the site and its surrounding area. Descriptions and analysis in this section are based on a Preliminary Hydrologic and Hydraulic Modeling Memo, prepared by Balance Hydrologics, provided in Appendix F. Additional information was obtained through site reconnaissance, review of project plans, and review of resources, including the City of American Canyon General Plan, the California Department of Water Resources (DWR) Bulletin 118, the Clean Water Act 303(d) list, and the Western Regional Climate Center.

3.8.2 - Environmental Setting
Climate and Meteorology
The City of American Canyon is characterized by a Mediterranean climate with warm summers, mild winters, and moderate precipitation. Temperatures in American Canyon range from an average monthly low of 38.3°F (degrees Fahrenheit) in January to an average monthly high of 82.1°F in September. Average annual rainfall is 24.6 inches with the majority occurring from November to March. General meteorological data for the American Canyon area, as measured at the Napa State Hospital weather station, are presented in Table 3.8-1.

Table 3.8-1: American Canyon Meteorological Summary
Month
Temperature (°F)
Average Low Average High Average Precipitation (inches) January 38.3 57.0 5.14
February 40.8 61.5 4.38
March 42.0 65.0 3.35
April 43.7 69.6 1.65
May 47.6 74.6 0.68
June 51.3 79.8 0.21
July 53.4 81.9 0.02
August 53.2 81.7 0.06
September 51.5 82.1 0.31
October 47.9 76.5 1.36
November 42.6 65.9 2.98
December 38.8 57.6 4.50
Annual Average 45.9 71.1 24.66
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Temperature (°F)
Average Low Average High Average Precipitation (inches) Notes:

Averages derived from measurements taken between January 1, 1893, and June 10, 2016, at Napa State Hospital (WRCC ID# 046074).

Source: Western Regional Climate Center 2021.

Regional Hydrology
The project site is located within the 426-square-mile Napa River Watershed. The Napa River drains 47 tributaries along its 55-mile length from the headwaters of Mount St. Helena in the Mayacamas Mountain Range at approximately 3,700 feet above mean sea level to San Pablo Bay, part of San Francisco Bay.

Within the large Napa River Watershed, major land cover types are forest (35 percent), grassland/rangeland (23 percent), and agriculture (19 percent). The San Francisco Bay Regional Water Quality Control Board (RWQCB) indicates that two-thirds of the agricultural land is vineyards, and urban development covers approximately 8 percent of the watershed. The majority of streams in the Napa Valley have been altered by urbanization, agriculture, and grazing. Since the 1800s, large sections of the Napa River have been straightened, the banks hardened, flows redirected, and several levees constructed.

At a more local scale, the project site has a contributing watershed area of 650 acres, measured where No Name Creek leaves the northwest corner of the site. Site drainage and the watershed boundary have been heavily influenced by the construction of ditches, roadway embankments, and other development. It is plausible that an additional area east of State Route 29 (SR-29) contributes runoff to the project site; however, this area does not affect the hydrology of the development footprint because it is either (1) routed through the drainage channel along Airport Road (which will not be affected by the project), or (2) routed through the undeveloped land to the south of the project site (also unaffected by the project). The watershed is not part of one of the larger, regional watersheds used for stormwater master planning.

Storm Drainage
The project site is undeveloped and does not have any existing storm drainage facilities. Runoff either ponds on-site and percolates into the soil or sheet flows into the municipal storm drainage facilities within Green Island Road.

Surface Water Quality
The Napa River is listed as impaired on the Clean Water Act 303(d) list for pathogens and sediment/siltation. These pollutants are a result of agriculture, urban runoff, and storm sewers; land development; and construction. The Napa River was previously listed on the Clean Water Act 303(d) list for nutrients; however, the RWQCB de-listed the Napa River for this pollutant in 2014 (Resolution Number R2-2014-0006).
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The project site is located within the 40,500-acre Napa-Sonoma Lowlands Groundwater Subbasin.

The subbasin consists primarily of alluvium and alluvial fans that were deposited at and near the mouths of the Napa River and Sonoma Creek adjacent to San Pablo Bay. To a lesser extent, portions of the City are underlain by sandstone and mudstone/shale, of which the former comprises some of the more productive water-bearing units within the region. The City of American Canyon does not maintain any municipal groundwater wells; however, as many as 41 private wells have been identified that draw from the subbasin within and near the City. Nearly all of these wells reported relatively low-flow rates, ranging from 0.5 gallon per minute (gpm) to 45 gpm.

Groundwater Quality
Groundwater quality in the Napa-Sonoma Lowlands Subbasin is generally suitable for municipal and agricultural uses. Primary constituents of concern are high total dissolved solids (TDS), nitrate, boron, and organic compounds. High TDS are typically found in wells in areas closest to the San Francisco Bay. The DWR indicates that the Napa-Sonoma Lowlands Subbasin shows a TDS range of 50 to 300 milligrams per liter (mg/L) with an average of 185 mg/L.

Geology and Soils
Napa County lies within the Coast Range of California, formed at and near the boundary of two major tectonic plates—the North American and Pacific plates. The lower Napa Valley can generally be considered a down-warped basin, the depth of which has been accentuated by additional downfaulting. The oldest rocks in the area, exposed along the flanks of the valley, are the sedimentary units of the Cretaceous-period Great Valley sequence. These units were originally part of the intact, overriding (North American) plate that were uplifted after the plate margin changed from a subduction zone to a transform fault, approximately 25 million years ago. The Great Valley sequence, in turn, is overlain by shales, sandstones, and siltstones of early to mid-Tertiary period. These sedimentary units were deformed and, in some places, moderately metamorphosed as a result of the uplift of the region. Thick deposits of late-Tertiary-period volcanic material, primarily tuff and rhyolite, cover the sedimentary units throughout much of the valley, as far south as Suscol Canyon.

The Napa Valley floor is composed of Quaternary-period sediments, deposited on the Napa River floodplain and in alluvial fans built-up at tributary mouths along the base of the valley flanks.

The project site is located near the southern end of the Napa Valley, at the distal end of the younger alluvial fan deposits that emanate from the hills to the east of the site. Young alluvial silt and clay floodplain and tidal deposits are also present at the site, deposited by the nearby Napa River.

The vast majority of the project site is underlain by Clear Lake clay and small areas of Haire loam, 2-9 percent slopes; and Fagan clay loam, 5-15 percent slopes. These soils are classified as hydrologic soils group D, meaning they have high runoff potential and very low infiltration rates, particularly when thoroughly wetted.
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3.8.3 - Regulatory Framework
Federal
Clean Water Act
Section 303 of the Clean Water Act (CWA) requires states to adopt water quality standards for all surface waters of the United States. Water quality standards are typically numeric, although narrative criteria based upon biomonitoring methods may be employed where numerical standards cannot be established or where they are needed to supplement numerical standards (see description of the Porter-Cologne Water Quality Control Act, below). Standards are based on the designated beneficial use(s) of the water body. Where multiple uses exist, water quality standards must protect the most sensitive use.

Section 401 of the CWA requires any person applying for a federal permit or license that may result in the discharge of pollutants into waters of the United States (including wetlands) to obtain a state water quality certification. In California, such certifications are administered by the California State Water Resources Control Board (State Water Board) through the nine RWQCBs (see a description of state regulations below). In order to acquire certification, it must be demonstrated that the activity complies with all applicable water quality standards, limitations, and restrictions. No license or permit by a federal agency may be granted until 401 certification has been granted. Section 401 water quality certifications are typically required prior to obtaining a Section 404 permit from the United States Army Corps of Engineers (USACE).

Section 402 of the CWA mandates that certain types of construction activity comply with the requirements of National Pollutant Discharge Elimination System (NPDES) stormwater program. In California, any construction activity (with the exception of certain industrial activities, none of which are proposed for this project) that disturbs at least 1 acre is covered under the Construction General Permit issued by the State Water Board and implemented and enforced by RWQCBs.

Pursuant to Section 402 of the CWA and the Porter-Cologne Water Quality Control Act, municipal stormwater discharges in the City of American Canyon are regulated under the San Francisco Bay Region Municipal Regional Stormwater NPDES Permit, MS4 Order No. 2013-0001-DWQ (General Permit). In 1987, Congress amended the CWA to mandate controls on discharges from municipal separate storm sewer systems (MS4s). Acting under the federal mandate and the California Water Code, California RWQCBs require cities, towns, and counties to regulate activities that can result in pollutants entering their storm drains. All municipalities prohibit non-stormwater discharges to storm drains and require residents and businesses to use Best Management Practices (BMPs) to minimize the amount of pollutants in runoff. The Municipal Regional Permit is overseen by the San Francisco Bay RWQCB. On February 5, 2013, the State Water Board reissued the Phase II Stormwater NPDES Permit for small MS4s. Provision E.12, “Post-Construction Stormwater Management Program,” mandates municipalities to require specified features and facilities—to control pollutant sources, runoff volumes, rates, and durations and to treat runoff before discharge from the site—be included in development plans of projects that create or replace 5,000 square feet or more impervious surface as conditions of issuing approvals and permits. The new requirements continue a progression of increasingly stringent requirements since 1989. 458
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In July of 2014, the Bay Area Stormwater Management Agencies Association (BASMAA), through the BASMAA Phase II Committee, created the BASMAA Manual to assist applicants for development approvals to prepare submittals to demonstrate that their project complies with the NPDES permit requirements. Applicants who seek development approvals for applicable projects should follow the manual when preparing their submittals. The manual is designed to ensure compliance with the requirements and promote integrated Low Impact Development (LID) design.

Section E.12.c of the General Permit pertains to LID and how it relates to hydromodification management. This Permit provision requires that stormwater discharges not cause an increase in the erosion potential of the receiving stream over the existing condition. Increases in runoff flow and volume must be managed so that the post-project runoff does not exceed estimated pre-project rates and durations, where such increased flow and/or volume is likely to cause increased potential for erosion of creek beds and banks, silt pollutant generation, or other adverse impacts on beneficial uses due to increased erosive force.

Section 404 of the CWA requires that a permit be obtained from the USACE prior to any activity associated with discharge of dredged or fill material into waters of the United States, including wetlands.

Floodplains
The Federal Emergency Management Agency (FEMA) oversees floodplains and administers the National Flood Insurance Program (NFIP) adopted under the National Flood Insurance Act of 1968.

The program makes federally subsidized flood insurance available to property owners within communities who participate in the program. Areas of special flood hazard (those subject to inundation by a 100-year flood) are identified by FEMA through regulatory flood maps titled Flood Insurance Rate Maps. The NFIP mandates that development cannot occur within the regulatory floodplain (typically the 100-year floodplain) if that development results in more than a 1-foot increase in flood elevation. In addition, development is not allowed in delineated floodways within the regulatory floodplain.

Federal Executive Order 11988 (Floodplain Management) addresses floodplain issues related to public safety, conservation, and economics. It generally requires federal agencies constructing, permitting, or funding a project in a floodplain to do the following:
• Avoid incompatible floodplain development,
• Be consistent with the standards and criteria of the NFIP, and • Restore and preserve natural and beneficial floodplain values.

Executive Order 11990 requires federal agencies to follow avoidance, mitigation, and preservation procedures, with public input, before proposing new construction in wetlands. It generally requires:
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• Minimization of activities in wetlands, and
• Coordination with the USACE and CWA Section 404 regarding wetlands mitigation.

State
Water Quality Statutes and Regulations
Section 303(d) of the CWA requires that the State Water Board identify surface water bodies within California that do not meet established water quality standards. Once identified, the affected water body is included in the State Water Board “303(d) Listing of Impaired Water Bodies” and a comprehensive program must then be developed to limit the amount of pollutant discharges into that water body. This program includes the establishment of Total Maximum Daily Loads (TMDL) for pollutant discharges into the designated water body. The most recent 303(d) listing for California was approved by the United States Environmental Protection Agency (EPA) in 2010.

The Porter-Cologne Water Quality Control Act of 1969 authorized the State Water Board to provide comprehensive protection for California’s waters through water allocation and water quality protection. The State Water Board implements the requirement of the CWA Section 303, indicating that water quality standards have to be set for certain waters by adopting water quality control plans under the Porter-Cologne Act. The Porter-Cologne Act established the responsibilities and authorities of the nine RWQCBs, which include preparing water quality plans for areas in the region, identifying water quality objectives, and issuing NPDES permits and Waste Discharge Requirements (WDRs). Water quality objectives are defined as limits or levels of water quality constituents and characteristics established for reasonable protection of beneficial uses or prevention of nuisance.

The Porter-Cologne Act was later amended to provide the authority delegated from the EPA to issue NPDES permits. The RWQCB with jurisdiction over the project site is the San Francisco Bay Region.

Post-construction stormwater controls to satisfy requirements of the NPDES Program are permitted under the Phase II Small Municipal Separate Storm Sewer System (MS4) Permit (Order R2-2015- 0049). Facilities must be designed to evapotranspire, infiltrate, harvest/use, and bio treat stormwater. As of July 1, 2016, hydromodification management procedures are required.

Projects disturbing more than 1 acre of land during construction are required to comply with the Construction General Permit (Order No. 2009-0009-DWQ as amended by 2010-0014-DWQ, effective February 14, 2011; NPDES No. CAS000002). Construction General Permit activities are regulated at a local level by the RWQCB pursuant to a general permit. No site-specific authorization is needed. To obtain coverage under the Construction General Permit, a project applicant must provide a Notice of Intent (NOI), a Storm Water Pollution Prevention Plan (SWPPP), and other documents required by Attachment B of the Construction General Permit. Activities subject to the Construction General Permit include clearing, grading, and disturbances to the ground, such as grubbing or excavation.

The Construction General Permit uses a risk-based permitting approach and mandates certain requirements based on the project risk level (Level 1, Level 2, or Level 3). The project risk level is based on the risk of sediment discharge and the receiving water risk. The sediment discharge risk depends on project location and timing (such as wet season versus dry season activities). The 460
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The performance standard in the Construction General Permit is that dischargers minimize or prevent pollutants in stormwater discharges and authorized non-stormwater discharges through the use of controls, structures, and BMPs. A SWPPP must be prepared by a qualified SWPPP developer that meets the certification requirements in the Construction General Permit. The purpose of the SWPPP is (1) to help identify the sources of sediment and other pollutants that could affect the quality of stormwater discharges, and (2) to describe and ensure the implementation of BMPs to reduce or eliminate sediment and other pollutants in stormwater as well as non-stormwater discharges resulting from construction activity. Examples of BMPs include silt fencing, street sweeping, and inspection. Operation of BMPs must be overseen by a qualified SWPPP practitioner who meets the requirements outlined in the permit.

Section 1600–1616 of the California Fish and Game Code requires that the California Department of Fish and Wildlife (CDFW) be notified of activity that will: substantially divert or obstruct the natural flow of any river, stream, or lake; or substantially change or use any material from the bed, channel, or bank of any river, stream, or lake; or deposit or dispose of debris, waste, or other material containing crumbled, flaked, or ground pavement where it may pass into any river, stream, or lake. If CDFW determines that the activity may substantially adversely affect fish and wildlife resources, a Lake or Streambed Alteration Agreement will be prepared that outlines reasonable conditions necessary to protect natural resources threatened by the proposed activity.

Stormwater Guidance Publications
California Stormwater Quality Association (CASQA), a professional organization, has published guidance for stormwater management. The organization’s Stormwater Best Management Handbook provides guidance for compliance with State stormwater regulations for construction. The Handbook provides detailed monitoring guidance and inspection forms, including a SWPPP Template. The Handbook addresses selection and implementation of BMPs to eliminate or to reduce the discharge of pollutants and control or reduce impacts to the hydrologic cycle associated with development and redevelopment activities.

The California Department of Transportation (Caltrans) also has published a Stormwater Quality Handbook Construction Site Best Management Practices Manual that provides similar guidance for transportation projects.

Local
City of American Canyon
General Plan
The City of American Canyon General Plan sets forth the following guiding and implementing policies relevant to hydrology and water quality:
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Objective 10.1 Design both new development and redevelopment projects in a manner that minimizes hazards associated with flooding.

Policies
Policy 10.1.1 Retain and enhance natural watercourses, including perennial and intermittent streams, as the City’s primary flood control channels whenever feasible.

Policy 10.1.4 Ensure that stormwater drainage is designed for peak flow conditions.

Policy 10.1.5 Prohibit the development of structures designed for human occupancy within the 100-year floodplain, unless flood hazards are adequately mitigated. Mitigation can be accomplished by building foundations a minimum of one (1) foot above the 100- year flood elevation, or by other means approved by the City Engineer.

Policy 10.1.12 Require that proposed developments within the 100-year floodplain submit information regarding the flood hazard prepared by a qualified Civil Engineer or Hydrologist.

Policy 10.1.13 Require that proposed developments within the 100-year floodplain submit plans to adequately mitigate flood hazards and demonstrate that such improvements will not create or increase downstream or upstream flood hazards.

Stormwater Management
As required under State Water Board Order No. 2013-001 DWQ, the City of American Canyon maintains a Storm Water Management Plan (SWMP) (NPDES Permit No. CAS 612007). As one element of that Program, the City requires regulated projects to address post-construction stormwater quality. The City of American Canyon requires regulated projects, such as this one, to prepare a Stormwater Control Plan in accordance with the Bay Area Stormwater Management Agencies Association–Post Construction Manual. The Stormwater Control Plan must include postconstruction stormwater treatment measures such as bioretention facilities and source control BMPs. The SWMP must also address ongoing maintenances of those facilities.

A Stormwater Control Plan and a Stormwater BMP Operations and Maintenance Plan will be required for the proposed project in accordance with the Bay Area Stormwater Management Agencies Association–Post Construction Manual. The proposed project would also incorporate LID design strategies including bioretention and inlet markings.

In addition, the City requires that a Preliminary Hydrology and Hydraulics Study be prepared to determine whether there are significant impacts. Storm drain design is required to conform to Section 4 of the City’s Engineering Standard Plans and Specifications for Public Improvements. Those standards require, among other things, that post-development runoff be no greater than 90 percent of pre-development runoff.
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3.8.4 - Methodology
Balance Hydrologics prepared a Preliminary Hydrologic and Hydraulic Modeling Memo that assessed and outlined how the changes in existing and proposed land cover, along with the proposed construction of Devlin Road, will impact the hydrology and hydraulics of the creek directly downstream of the project area and along the reach to its confluence with the Napa River. The memo is provided in Appendix F.

Additional information was provided by site reconnaissance, review of project plans, and review of resources including the City of American Canyon General Plan, the DWR Bulletin 118, the CWA 303(d) list, and the Western Regional Climate Center.

3.8.5 - Thresholds of Significance
Appendix G to the CEQA Guidelines is a sample Initial Study Checklist that includes questions for determining whether impacts related to utilities and service systems are significant. These questions reflect the input of planning and environmental professionals at the Governor’s Office of Planning and Research and the California Natural Resources Agency, based on input from stakeholder groups and experts in various other governmental agencies, nonprofits, and leading environmental consulting firms.

As a result, many lead agencies derive their significance criteria from the questions posed in Appendix G. The City has chosen to do so for this project. Thus, the proposed project would have a significant effect if it would:
a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality;
b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin;
c) Substantially alter the existing drainage pattern of area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
(i) result in substantial erosion or siltation on- or off-site; (ii) substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site;
(iii) create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or (iv) impede or redirect flood flows;
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation; or
e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.
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3.8.6 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the development of the project and provides mitigation measures where appropriate.

Water Quality
Impact HYD-1: Construction activities and changes to drainage patterns associated with the proposed project may degrade surface water quality in downstream water bodies.

Impact Analysis
Phases 1 and 2
This analysis assesses the potential for the proposed project to degrade surface water quality in downstream water bodies.

The potential for the proposed project to degrade water quality arises from (1) short-term land disturbance from construction activities and presence of contaminants associated with construction machinery, and (2) long-term changes to land use and drainage patterns that may increase the delivery of sediments, nutrients, organic compounds, trash/debris, and other contaminants to waterways tributary to the Napa River. Left unabated, increased loading of such pollutants could cause geomorphic change in downstream channel reaches, degrade habitat, and undermine TMDL and other water quality requirements.

Construction activities would disturb approximately 163 acres of the project site and include grading, building construction, paving, and utility installation. Construction would require the use of gasoline and diesel-powered heavy equipment, such as bulldozers, backhoes, water pumps, and air compressors. Chemicals, such as gasoline, diesel fuel, lubricating oil, hydraulic oil, lubricating grease, automatic transmission fluid, paints, solvents, glues, and other substances, could be used during construction. An accidental release of any of these substances could degrade the quality of the surface water runoff and adversely affect receiving waters. As such, Mitigation Measure (MM) HYD1a is proposed, requiring the development and implementation of a SWPPP to outline site-specific stormwater quality control measures (such as Best Management Practices [BMPs]) during construction activities to prevent pollutants from entering downstream waterways. With implementation of MM HYD-1a, impacts would be reduced to a less than significant level.

Post-construction, typical urban contaminants associated with roadways, parking areas, and rooftops will be introduced to the project site. Moreover, the increase in impervious area increases the efficiency by which sediment and other pollutants are delivered downstream. Concentration of flow by the storm drain system could increase the erosive energy of flows, thereby increasing sediment supply from the project site. Runoff from landscaped areas may also contain residual pesticides and nutrients. Consequently, there is potential for long-term degradation of runoff water quality from the implementation of the project.

The project proposes the following post-construction stormwater management features, according to a three-tiered LID/BMP design approach:
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/wp/54600001 Sec03-08 Hydrology.docx • The purpose of site design BMPs is to maintain pre-development runoff characteristics, protect sensitive resource areas, and attempt to minimize new impervious areas. The site has been designed to limit the amount of disturbed area and new impervious areas. • Source control BMPs use structural controls and operational procedures to limit pollutants at their source. The project would implement the following source control BMPs: mark “No Dumping! Flows to River” on storm drain inlets; plumb interior floor drains to sanitary sewer; carefully manage pesticide use for landscaped areas; post “Do Not Dump Hazardous Materials Here” on refuse areas; utilize enclosed trash compactors; grade loading docks to minimize run-on and contain spills; and drain parking areas to bioretention planters. • Treatment control BMPs are designed to reduce the amount of pollutants in stormwater and to reduce runoff rates or volumes. All new impervious areas will be routed through either a bioretention basin or an infiltration planter. The floors of bioretention basins will be amended with a layer of gravel overlain by a layer of specialized biosoil. The biosoil will be a sandy loam material to promote infiltration while allowing for vegetation to establish. An underdrain will be installed to facilitate infiltration as the local soils have low infiltration potential.

Bioretention basins have been configured to drain within 48 hours to prevent vector concerns.

Additionally, the wetland preserve would facilitate the natural sequestration of pollutants of stormwater leaving the project site.

MM HYD-1b is proposed requiring (1) that the Stormwater Control Plan be reviewed and verified by the City of American Canyon to ensure the proposed stormwater controls are adequate pursuant to the requirements Order No. R2-2015-0049 (or more recent permit), and (2) that an operation and maintenance program is in place to ensure the long-term functionality of the stormwater controls.

The various RWQCBs have evaluated the effectiveness of the types of BMPs required by MM HYD-1b and have determined that BMPs are known to be effective in protecting receiving waters. Thus, there is a high degree of certainty that the proposed project would not exacerbate the existing water quality status of the Napa River. Impacts would be less than significant with mitigation.

Level of Significance Before Mitigation
Potentially significant impact.

Mitigation Measures
MM HYD-1a Prior to issuance of grading permits for the proposed project, the applicant shall submit to the City of American Canyon for review and approval a Storm Water Pollution Prevention Plan (SWPPP) in accordance with the requirements of the statewide Construction General Permit. The SWPPP shall be designed to address the following objectives: (1) all pollutants and their sources (e.g., runoff), including sources of sediment associated with construction, construction site erosion, and all other activities associated with construction activity, are controlled; (2) where not otherwise required to be under a Regional Water Quality Control Board (RWQCB) permit, all non-stormwater discharges are identified and either eliminated, controlled, or treated; (3) site Best Management Practices (BMPs) (e.g., silt fencing, 465
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MM HYD-1b Prior to the issuance of building permits, the project applicant shall submit a Stormwater Control Plan to the City of American Canyon for review and approval.

The plan shall be developed using the California Stormwater Quality Association (CASQA) “New Development and Redevelopment Handbook” and include the applicable provisions of Section C.3 of the San Francisco Bay Regional Water Quality Control Board (RWQCB) Municipal Regional Permit (Order No. R2-2015-0049, NPDES Permit No. CAS612008 (or more recent permit). The Stormwater Control Plan shall identify pollution prevention measures and Best Management Practices (BMPs) to control stormwater pollution from operational activities and facilities and provide maintenance in perpetuity. The Stormwater Control Plan shall include Low Impact Development (LID) design concepts, as well as concepts that accomplish a “first flush” objective that would remove contaminants from the first 2 inches of stormwater before it enters area waterways. The project applicant shall also prepare and submit an Operations and Maintenance Agreement to the City, identifying procedures to ensure stormwater quality control measures work properly during operations.

Level of Significance After Mitigation
Less than significant impact.

Groundwater
Impact HYD-2: The proposed project would not deplete groundwater supplies or interfere substantially with groundwater recharge.

Impact Analysis
Phases 1 and 2
This analysis assesses the potential for the proposed project to deplete groundwater supplies or interfere substantially with groundwater recharge.

Groundwater Overdraft
The proposed project would be served with potable water service provided by the City of American Canyon; the proposed project would not rely groundwater wells as a water supply source. Therefore, 466
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Groundwater Recharge
The proposed project would result in an increase in additional pervious surfaces. However, the project site is at a relatively low elevation and is near the Napa River; thus, groundwater levels tend to be high and soils in the lowest portions of the site are often saturated. Accordingly, the groundwater water recharge potential of the project site would be limited. For these reasons, impacts to groundwater recharge 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.

Drainage
Impact HYD-3: The proposed project would not create or contribute runoff water that would exceed the capacity of existing or planned stormwater drainage systems.

Impact Analysis
Phases 1 and 2
This impact assesses the potential for the proposed project to create or contribute runoff water that would exceed the capacity of existing or planned stormwater drainage systems or cause flooding onor off-site.

The proposed project would result in the development of 2.4 million square feet of new industrial development and infrastructure on 163 acres of the project site. The remaining 45 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 install a storm drainage system designed for a 15-year storm event.

Inlets would capture surface runoff, where it would enter an underground piping system that would convey stormwater to one of four basins. The basins would provide 110,766 square feet (2.6 acres) of stormwater retention.

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 MM HYD-1b, the proposed project would implement LID stormwater management 467
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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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3.9 - Land Use

3.9.1 - Introduction
This section describes the existing land use and potential effects from project implementation on the site and its surrounding area. Descriptions and analysis in this section are based on-site reconnaissance and review of the City of American Canyon General Plan, the American Canyon Municipal Code, and the Napa County Airport Land Use Compatibility Plan.

3.9.2 - Environmental Setting
Land Use
Project Site
The project site contains undeveloped land. There are no structures on-site. Vegetation consists primarily of non-native grasslands, with seasonal wetlands and associated plant species scattered throughout the site. The project site gently slopes from east to west and the elevation ranges from 50 feet to 35 feet above mean sea level. The headwaters of No Name Creek are located in the northwestern portion of the site. No Name Creek flows off the site at the northwestern corner of the property into the Napa Logistics Park Wetland Preserve. The drainage is hydrologically connected to Fagan Slough, which flows into the Napa River. The majority of wetlands that occur throughout the site are supported by direct precipitation. Small soil mounds are located in various places throughout the site.

The West Napa Fault bisects the project site in a northwest/southeast direction. An existing 18-inch diameter force main that connects the Tower Road Pump Station with the Green Island Pump Station crosses the western portion of the project site.

The City of American Canyon owns an approximately 8-acre strip of land that bisects the site northto-south. This strip of land would support the planned extension of Devlin Road from Middleton Way to Green Island Road, which was under construction as of Summer 2021.

Photographs of the project site are provided in Exhibit 2-3.

Surrounding Area
West
The California Northern Railroad line, connecting American Canyon and Sonoma, and the Biagi Brothers distribution warehouse form the western boundary of the project site.

North
Devlin Road and the Napa Logistics Park form the northern boundary of the project site. Napa Logistics Park contains more than 2 million square feet of distribution warehouses as well as a planned Pacific Gas and Electric Company regional operations and maintenance center. Further north is the Napa County Airport.
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City of American Canyon—Giovannoni Logistics Center Project Land Use Draft EIR

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The Napa Branch Line, a railroad that connects American Canyon and Napa, forms the eastern boundary of the project site. East of the branch line are several industrial and commercial business that front State Route 29 (SR-29).

South
Green Island Road, Crown Hill Stone Supply, and the Wine Direct warehouse form the southern boundary of the project site. Further south are industrial and commercial businesses within the Green Island Business Park.

Land Use Designations
Project Site
The project site is designated “Industrial” by the City of American Canyon General Plan and zoned “General Industrial.” The project site is within the boundaries of the Napa County Airport Land Use Compatibility Plan.

Surrounding Land Uses
Table 3.9-1 summarizes the surrounding land uses. As shown in the table, all surrounding properties are designated for industrial use.

Table 3.9-1: Surrounding Land Use Designations
Land Use
Relationship to
Project Site
Land Use Designation
General Plan Zoning
Green Island Business Park West and South Industrial General Industrial (GI) Napa Logistics Park North Industrial Napa County Airport Industrial Area (SP-2)
Diablo Timber East Industrial Light Industrial (LI)
Undeveloped Land East Industrial Light Industrial (LI)
Crown Hill Stone Supply and
Wine Direct
South Industrial General Industrial (GI)
Source: City of American Canyon 2021.

Napa County Airport
The Napa County Airport is located north of the project site, just beyond the Napa Logistics property.

The County-owned airport occupies approximately 824 acres and contains three runways (ranging from 2,510 to 5,931 feet in length), associated taxiways and tarmacs, a control tower, approximately 200 hangars, approximately 160 tie down spaces, and a helicopter pad. The airport averages 148 operations per day and 54,020 operations annually. (The Federal Aviation Administration defines an “operation” as one takeoff or landing).
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3.9.3 - Regulatory Framework
State
State Aeronautics Act
The State Aeronautics Act requires each county with an airport to establish an Airport Land Use Commission (ALUC) to regulate land use around airports to protect public safety and ensure that land uses near airports do not interfere with aviation operations. The Napa County Airport Land Use Compatibility Plan regulates land use around the Napa County Airport, as well as two other aviation facilities in the County, by requiring compliance with the policies of the plan. In certain circumstances, local governments may override the decisions of the ALUC.

Local
City of American Canyon
General Plan
The City of American Canyon General Plan provides a blueprint for future development within American Canyon and the Sphere of Influence. The American Canyon Council adopted its most recent General Plan on November 3, 1994. The General Plan contains the following chapters: land use, housing, economic development, circulation, utilities, public facilities and services, parks and recreation, natural historic/cultural resources, geology, flooding, and noise. Each chapter establishes goals and policies to guide future land use activities and development within the General Plan boundaries. Note that the Circulation Element was comprehensively updated in 2013, the Housing Element was comprehensively updated in 2015, and incremental amendments have been made to the Land Use Element over time and as recently as 2021.

Industrial
The City of American Canyon General Plan designates the project site as Industrial. The following land use activities are identified as permitted uses within the Industrial land use designation: light manufacturing (including auto manufacturing); aviation-related; agribusiness related; industrial sector “clusters;” thematic industries; business parks; warehouses; professional offices; supporting retail, restaurant, and financial; and similar uses. The General Plan establishes a floor area ratio (FAR) of 0.5 for labor-intensive industries and a FAR of 0.7 for low labor uses.

American Canyon Zoning Ordinance
American Canyon Municipal Code Title 19 contains the Zoning Ordinance. The project site is designated General Industrial (GI) by the Zoning Ordinance. The General Industrial zoning district is defined as follows: “To provide areas appropriate for functional industrial activities, including warehousing, manufacturing, food processing, product and equipment assembly, and similar types of uses that may involve both indoor and outdoor activities, and related ancillary uses.” The Zoning Ordinance lists research and development, wholesaling, distribution, and storage as permitted uses within the General Industrial zoning district. New development within the General Industrial zoning 471
City of American Canyon—Giovannoni Logistics Center Project Land Use Draft EIR

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County of Napa
Napa County Airport Land Use Compatibility Plan
The Airport Land Use Compatibility Plan governs land use around two Napa County aviation facilities: the Napa County Airport and Parrett Field in Angwin. The Airport Land Use Compatibility Plan was adopted by the Napa County ALUC in April 1991 and revised in December 1999.

Noise
Table 2-1 of the Airport Land Use Compatibility Plan identifies acceptable aviation noise levels by land use. For warehouse and light industrial uses, aviation noise levels of up to 60 A-weighted decibel (dBA) Community Noise Equivalent Level (CNEL) are listed as “clearly acceptable” and noise levels between 60 and 65 dBA CNEL are listed as “normally acceptable.” Noise levels between 65 and 75 dBA CNEL are listed as “marginally acceptable.”
Flight Hazards
The Airport Land Use Compatibility Plan identifies two categories of flight hazards: physical obstructions and land use characteristics.

Physical obstructions are associated with tall objects or structures. The Airport Land Use Compatibility Plan establishes a height restriction ranging from 50 feet to 185 feet above ground level.

Certain land use activities may pose hazards to aviation. Specific characteristics that should be avoided within the airport land use planning boundaries are listed below:
• Glare or distracting lights, which could be mistaken for airport lights. • Sources of dust, steam, or smoke that may impair pilot visibility. • Sources of electrical interference with aircraft communications or navigation. • Any use that may attract large flocks or birds, especially landfills or certain agricultural uses.

Zone D
The Airport Land Use Compatibility Plan provides the following description of Zone D in Table 3-1:

Common Traffic Pattern: This area is defined by the flight pattern of each airport and illustrated in the respective “Airport Impact Areas” figures contained in Part III.

These areas are routinely overflown by aircraft operating to and from the airport with frequent single-event noise intrusion. Overflights in these areas can range from near the traffic pattern altitude (about 1,000 feet above the ground) to as low as 300 feet above the ground. Accident risk varies from low to moderate. Areas where aircraft are near pattern altitude (e.g., downwind leg) have the lowest risk. In areas where aircraft are at lower altitudes (especially on circle-to-land instrument approaches) a moderate level of risk exists.
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-09 Land Use.docx The Airport Land Use Compatibility Plan establishes the following standards for Zone D:
• Maximum density recommendation of 100 persons per acre inside structures for nonresidential uses.
• Maximum density recommendation of 150 persons per acre (both indoors and outdoors) for nonresidential uses.
• Residential uses are prohibited.
• Uses hazardous to flight are prohibited (i.e., features that attract large numbers of birds and sources of smoke, glare, distracting lights, or electrical interference). • Overflight easement or deed restrictions are required. • Building envelopes and approach surfaces are required on all development plans within 100 feet of approach zones.
• Clustering is encouraged to maximize open land areas. • Noise level reduction measures may be required for noise-sensitive uses.

The Airport Land Use Compatibility Plan states that most nonresidential uses are considered “normally acceptable” within Zone D. Schools, libraries, hospitals, nursing homes, large shopping malls, amphitheaters, and ponds are identified as “not normally acceptable” within Zone D.

3.9.4 - Methodology
FirstCarbon Solutions (FCS) evaluated the potential for land use impacts through site reconnaissance and review of applicable land use policy documents. FCS performed site reconnaissance on the project site and surrounding land uses in February 2021. Photographs were taken of the project site and surrounding land uses to document existing conditions. FCS reviewed the City of American Canyon General Plan, the American Canyon Zoning Ordinance, and the Napa County Airport Land Use Compatibility Plan to identify applicable policies and provisions that pertain to the proposed project. The proposed project’s plans were reviewed to evaluate consistency with General Plan and Zoning Ordinance’s standards.

3.9.5 - Thresholds of Significance
Appendix G to the California Environmental Quality Act (CEQA) Guidelines is a sample Initial Study Checklist that includes questions for determining whether impacts related to land use are significant.

These questions reflect the input of planning and environmental professionals at the Governor’s Office of Planning and Research (OPR) and the California Natural Resources Agency, based on input from stakeholder groups and experts in various other governmental agencies, nonprofits, and leading environmental consulting firms. As a result, many lead agencies derive their significance criteria from the questions posed in Appendix G. The City has chosen to do so for this project. Thus, the proposed project would have a significant effect if it would:
a) Physically divide an established community (refer to Section 7, Effects Found not to be Significant); or
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3.9.6 - Project Impacts Mitigation Measures
This section discusses potential impacts associated with the proposed project and provides mitigation measures where necessary.

General Plan Consistency
Impact LU-1: The proposed project would not conflict with the applicable provisions of the City of American Canyon General Plan.

Impact Analysis
The proposed project would consist of the development of up to 2.4 million square feet of high-cube warehouse on 163 acres. The remaining 45 acres would be preserved as wetlands.

Phase 1
The applicant has developed site design-level plans for Phase 1, the 94.7-acre area east of the Devlin Road extension. This area will support two high-cube warehouse buildings totaling 1,069,904 square feet. One of the buildings would be rail-served by the adjacent Napa Branch Line. Each building would provide docks, grade-level roll-up doors, and trailer parking stalls. The facility would be enclosed with a secure perimeter and access would be restricted to authorized users.

The Phase 1 end uses would be consistent with the types of permitted uses set forth in the General Plan. Additionally, Phase 1 would have a 0.26 FAR and would be within the General Plan’s allowable FAR of 0.50 for labor-intensive uses and FAR of 0.70 for low labor uses. The proposed high-cube warehouses would have 36 feet clear height and, thus, be within the 40-foot height limit.

Phase 2
Phase 2, the 113.1-acre area west of Devlin Road, is conceptually proposed for the remaining 1.3 million square feet of high-cube warehouse.

The Phase 2 end uses would be consistent with the types of permitted uses set forth in the General Plan. Additionally, Phase 2 would have a 0.26 FAR and would be within the General Plan’s allowable FAR of 0.50 for labor-intensive uses and FAR of 0.70 for low labor uses.

Phases 1 and 2
Table 3.9-2 evaluates Phase 1 and Phase 2 consistency with the relevant goals, objectives, and policies of the City of American Canyon General Plan. The conclusions expressed in Table 3.9-2 reflect the best judgment of City staff. The ultimate question of the meaning of particular General Plan policies, and thus the proposed project’s consistency with them, lies with the City Council. The language found in general plans is sometimes susceptible to varying interpretations. Case law interpreting the Planning and Zoning Law (Gov. Code, § 65000 et seq.) makes it clear that: (i) the ultimate meaning of such policies is to be determined by the elected city council or a lower tier decision-making body such as a planning commission, as opposed to city staff and EIR consultants, 474
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City of Oakland (1993) 23 Cal.App.4th 704, 719). Furthermore, courts strive to “reconcile” or “harmonize” seemingly disparate general plan policies to the extent reasonably possible (No Oil, supra, 196 Cal.App.3d at p. 244).

As shown in the table, City staff concludes that the proposed project is consistent with all applicable goals, objectives, and policies. Impacts would be less than significant. Should City decision-makers choose to approve the proposed project, they may rely on the analysis in the table as support for the conclusion that the project is consistent with the General Plan. Certification of the Final EIR will be indicative of agreement with the conclusions in the table.

Table 3.9-2: General Plan Consistency Analysis
Element
Goal/Objective/Policy
No. Text Consistency Determination
Land Use Goal 1A Provide for a diversity of land uses
that
a. serve the needs of existing and
future residents;
b. capitalize upon the tourism and
agricultural heritage of the
region;
c. capitalize upon and preserves the
unique environmental resources
and character of the area;
d. offer sustained employment
opportunities for residents of the
City and the surrounding region;
e. sustain and enhance the longterm economic viability of the City;
f. revitalize areas of physical and
economic deterioration and/or
obsolescence;
g. are developed at
densities/intensities that are
economically viable and
complementary with the natural
environmental setting and
existing development; and
h. provide a greater balance of jobs
and housing.

Consistent: The proposed project
would develop 2.4 million square
feet of high-cube warehouse on
the approximately 208-acre
project site. The project site is
designated “Industrial” by the
General Plan and the end uses are
consistent with the allowable uses
for this land use designation. The
proposed project would create as
many as 3,643 new jobs, stimulate
capital investment, and expand
the tax base. The proposed
project would also include an
existing Wetland Preserve in the
western portion of the site. As
such, the proposed project would
be consistent with the provisions
of this goal, including serving the
needs of residents, protecting
environmental resources, creating
employment opportunities, and
balancing jobs and housing.
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Goal/Objective/Policy
No. Text Consistency Determination
Objective 1.1 Accommodate the development of
a balance of land uses that (a)
provide for the housing,
commercial, employment,
educational, cultural,
entertainment, and recreation
needs of residents, (b) capture
visitor and tourist activity, (c)
provide employment opportunities
for residents of the greater sub
region; and (d) provide open space
and aesthetic relief from developed
urban/suburban areas.

Consistent: The proposed project
would develop 2.4 million square
feet of high-cube warehouse that
would create as many as 3,643
new jobs, primarily for residents
of the region. The proposed
project would also include an
existing Wetland Preserve,
consistent with the item that calls
for open space and aesthetic
relief from developed urban
areas.

Policy 1.1.4 Provide adequate transportation
(vehicle, bicycle, and pedestrian)
and utility (sewer, water, energy,
etc.) infrastructure and public
services (police, fire, schools, etc.)
to support the needs of the
residents and businesses of
American Canyon.

Consistent: This Draft EIR
evaluates the adequacy of public
services, transportation facilities,
and utility systems to serve the
proposed project and identifies
mitigation where necessary to
achieve acceptable service levels.

Refer to Section 3.11, Public
Services, Section 3.12,
Transportation, and Section 3.13,
Utilities and Service Systems, for
further discussion.

Goal 1B Provide for the orderly
development of American Canyon
that maintains its distinctive
character.

Objective 1.2 Promote a rate of growth that is
consistent with the ability of the
City to provide adequate
infrastructure and services and does
not adversely impact the distinctive
character and quality of life in
American Canyon.

Consistent: The proposed project
would develop 2.4 million square
feet of new industrial uses on a
site designated for such use
located within the American
Canyon city limits. The project site
is located within the Green Island
Business Park and is surrounded
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Goal/Objective/Policy
No. Text Consistency Determination
by urban uses and infrastructure
on three sides. Thus, the
proposed project would occur in
an area where adequate
infrastructure and services exist
such that it would not exceed the
City’s ability to serve it.

Policy 1.2.2 Establish as a priority the
development of projects that are
contiguous with and infill the existing
pattern of development, avoiding
leap-frog development, except for
large scale master planned projects
that are linked to and planned to be
extensions of existing development
and for which infrastructure and
services are in place or funded.

Consistent: The project site is
located within the Green Island
Business Park and is surrounded
by urban uses and infrastructure
on three sides. As such, it would
meet the criteria set forth in this
policy for a “priority” project.

Objective 1.3 Ensure that land use development
is coordinated with the ability to
provide adequate public
infrastructure (transportation
facilities, wastewater collection and
treatment, water supply, electrical,
natural gas, telecommunications,
solid waste disposal, and storm
drainage) and public services
(governmental administrative,
capital improvements, police, fire,
recreational, cultural, etc.).

Refer to Section 3.11, Public
Services, Section 3.12,
Transportation, and Section 3.13,
Utilities and Service Systems, for
further discussion.

Policy 1.3.1 Implement public infrastructure and
service improvements necessary to
support land uses accommodated
by the Land Use Plan (as defined in
the Circulation and Public Utilities
and Services Elements.)
Consistent: Adequate
infrastructure and service levels
exist in the project vicinity such
that only minor improvements or
upgrades are necessary to serve
the proposed project. Refer to
Section 3.11, Public Services,
Section 3.12, Transportation, and
Section 3.13, Utilities and Service
Systems, for further discussion.
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Goal/Objective/Policy
No. Text Consistency Determination
Policy 1.3.2 Require that type, amount, and
location of development be
correlated with the provision of
adequate supporting infrastructure
and services (as defined in the
Circulation and Public Utilities and
Services Elements.)
Consistent: This Draft EIR
evaluates the adequacy of public
services, transportation facilities,
and utility systems to serve the
proposed project and identifies
mitigation where necessary to
achieve acceptable service levels.

Refer to Section 3.11, Public
Services, Section 3.12,
Transportation, and Section 3.13,
Utilities and Service Systems, for
further discussion.

Policy 1.3.3 Regulate the type, location, and/or
timing of development as necessary
in the event that there is
inadequate public infrastructure or
services to support land use
development.

Consistent: Adequate
infrastructure and service levels
exist in the project vicinity such
that only minor improvements or
upgrades are necessary to serve
the proposed project. Refer to
Section 3.11, Public Services,
Section 3.12, Transportation, and
Section 3.13, Utilities and Service
Systems, for further discussion.

Goal 1C Create a pattern and character of
land use development that
establishes American Canyon as a
distinct “place” differentiated from
adjacent urban areas, maintains a
semi-rural character, and respects
the environmental setting.

Consistent: The project site is
located within the Green Island
Business Park and is designated
for industrial development. The
proposed project includes an
existing Wetland Preserve, which
occupies the western portion of
the site. As such, the proposed
project would promote a
development pattern that
differentiates American Canyon
from adjacent urban areas and
also respects the natural
environment.

Objective 1.4 Provide for a pattern of
development that (a) establishes
distinct neighborhoods, districts,
places of community activity and
culture and open spaces that are
interlinked and promote a cohesive
image, (b) locates jobs, commerce,
recreation, and other places of
community activity within close
proximity to all housing units,
minimizing the need for vehicular
use, (c) achieves a balance of uses
to serve both sides of Highway 29,
Consistent: The project site is
located within the Green Island
Business Park and is designated
for industrial development. The
proposed project site includes an
existing Wetland Preserve, which
is located on the western portion
of the site. Accordingly, the
proposed project would advance
the objectives associated with
balancing uses to serve both sides
of SR-29 and promoting a
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Goal/Objective/Policy
No. Text Consistency Determination
and (d) establishes an overall
compact urban form surrounded by
open space.
compact urban form surrounded
by open space.

Policy 1.4.1 Accommodate land use
development in accordance with
the patterns and distribution of use
and density depicted on the Land
Use Plan Map (Figure 1-1).

Consistent: The project site is
located within the Green Island
Business Park and is designated for
industrial development. This is
consistent with the patterns and
distribution of use and density
depicted on the Land Use Plan
Map (Figure 1-1 of the General
Plan).

Policy 1.4.2 Require that development within
each land use classification adheres
to applicable requirements and
standards.

Consistent: The project site is
located within the Green Island
Business Park and is designated
for industrial development. As
discussed in Impacts LU-1 and LU2, the proposed project would comply with all applicable
requirements and standards.

Objective 1.5 Maintain the character and quality
of the natural environmental
resources of the City and protect
the population and development
from the adverse impacts of
environmental hazards.

Consistent: The proposed project
site includes an existing Wetland
Preserve, located on the western
portion of the site. This area
coincides with a 100-year flood
plain and the highest quality
habitat on the project site. Given
that no development would occur
in the Wetland Preserve, the
proposed project would advance
the policy of maintaining the
quality of natural resources and
protecting the public from
adverse impacts of environmental
hazards.

Policy 1.5.1 Require that development be
designed and sited to protect
significant environmental resources
by adherence to the policies,
standards, and programs contained
in the Natural and Historic/Cultural
Resources, Geology and Flood
Hazards, and Noise Elements of the
General Plan, as well as federal
(NEPA) and State (CEQA)
regulations.

Consistent: The proposed project
site includes an existing Wetland
Preserve, located on the western
portion of the site. This area
coincides with a 100-year flood
plain and the highest quality
habitat on the project site. Given
that no development would occur
in the Wetland Preserve, the
proposed project would advance
the policy of protecting significant
environmental resources.
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Goal/Objective/Policy
No. Text Consistency Determination
Goal 1I Ensure the development of
industrial uses that provide
employment for residents of
American Canyon and the
surrounding region and contribute
significant revenue for the City.

Consistent: The proposed project
would develop 2.4 million square
feet of new industrial uses on a
site designated for such use
located within the American
Canyon city limits. The proposed
project is estimated to create as
many as 3,643 new jobs for local
residents. As such, it would
advance the goal of providing
employment opportunities and
contributing significant revenue
for the City.

Objective 1.22 Provide for the continuation of
existing and development of new
industries that capitalize upon the
geographic advantages of the City
(including adjacency to Napa
County Airport and the railroad),
the agricultural production of the
region, and emerging types of
businesses (such as “thematic” and
“environmental” based industries),
offer opportunities for the
clustering of key economic sectors,
and maintain the environmental
quality of the City.

Consistent: The project site is
located within the Green Island
Business Park and is designated
for industrial development. The
proposed project would develop

2.4 million square feet of highcube warehouse uses. At least one of the proposed buildings
would be “rail-served.” This is
consistent with the objective of
promoting the development of
existing and new industries that
capitalize on the geographic
advantages of the City.

Policy 1.22.1 Accommodate the continuation of
existing and development of new
manufacturing, research and
development, warehouse and
distribution, ancillary offices, and
similar uses in areas designated as
“Industrial (I)” on the Land Use Plan
Map (Figure 1-1).

Consistent: The project site is
located within the Green Island
Business Park and is designated
for industrial development. The
proposed project would develop

2.4 million square feet of highcube warehouse uses. This is consistent with the policy of
promoting the development of
existing and new warehouse and
distribution and ancillary offices in
areas designated as “Industrial (I)”
on the Land Use Plan Map (Figure
1-1 of the General Plan).

Policy 1.22.2 Allow for the inclusion of businesses
that are ancillary to and support
industrial uses such as related retail
sales facilities for manufacturers,
financial institutions, restaurants,
photocopy shops, specialty
recreational uses (batting cages and
health clubs/spas), and similar uses.

Consistent: The proposed project
would develop 2.4 million square
feet of high-cube warehouse uses.

Ancillary office space would be
provided within the warehouses.

The provision of these ancillary
uses is consistent with the intent
of this policy.
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Goal/Objective/Policy
No. Text Consistency Determination
Policy 1.22.3 Permit development according to
the following standards:
a. Labor-intensive uses: a maximum
floor area ratio of 0.5.
b. Low labor uses (such as
warehousing): a maximum floor
area ratio of 0.7.

Consistent: Phase 1 and Phase 2
would both have a 0.26 FAR,
which would be within the
General Plan’s allowable FAR of

0.50 for labor-intensive uses and
FAR of 0.70 for low labor uses.

Policy 1.22.4 Require that development be
designed to achieve a high level of
quality and compatibility with
existing uses including the
consideration of the following:
a. architectural treatment of all
building elevations;
b. use of extensive landscape along
the primary street frontages and
parking lots; and
c. enclosure of storage areas visible
from principal highways
(including Highway 29) and
peripheral residential and
commercial districts with
decorative screening or other
elements.

Outdoor storage areas would be
enclosed where necessary to
screen them from view from
major roadways. The City’s design
review process would ensure
consistency with the applicable
policies.

Policy 1.22.5 Require that industrial areas
developed as research and
development and office-oriented
business parks be designed to
convey a unified character by
consideration of Policy 1.22.4 and
the following:
a. inclusion of pedestrian walkways,
arcades, an/or other visual
elements to interconnect
individual buildings;
b. differentiation of building facades
by materials, color, architectural
details and modulation of
building volumes;
c. incorporation of extensive
landscape in parking areas, along
building frontages, and other
public areas;
d. use of consistent and welldesigned public and
informational signage; and
e. installation of elements that
define the key entries to the
industrial district.

Consistent: The proposed project
would provide internal pedestrian
facilities, contemporary finishes
and treatments similar to other
industrial buildings in the project
vicinity, landscaping within parking
areas and along the Devlin Road
frontage, and signage consistent
with this policy. The City’s design
review process would ensure
consistency with the applicable
policies.
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Policy 1.22.7 Require that truck access be
controlled so that it is safe and
efficient and minimizes exposure to
adjacent residential neighborhoods.

Consistent: Trucks would access
the project site from Green Island
Road or Devlin Road. Both roads
avoid residential areas. The
project site’s location also allows
for convenient access to SR-12
(east and west) such that
residential areas in American
Canyon would be avoided by
trucks using this highway.

Goal 1N Ensure the compatibility of
development within American
Canyon with the Napa County
Airport.

Consistent: As discussed in Impact
LU-3, the proposed project, with
Mitigation Measure (MM) LU-3, is
compatible with all applicable
provisions of the Napa County
Airport Land Use Compatibility Plan.

Objective 1.27 Ensure that lands in American
Canyon are developed in a manner
which protects them from the noise
and operational impacts of, and
does not adversely constrain, the
Napa County Airport.

Consistent: As discussed in Impact
LU-3, the proposed project is
compatible with all applicable
provisions of the Napa County
Airport Land Use Compatibility Plan
including those that pertain to
noise and safety.

Policy 1.27.1 Require that development comply
with the land use and development
conditions stipulated in Tables 1-1
and 1-2 for areas depicted on Figure
1-3. […]
ZONE D Common Traffic Pattern:

This area is defined by the flight
pattern for the Napa County Airport
as illustrated on Figure 1-3. These
areas are routinely overflown by
aircraft operating to and from the
airport with frequent single-event
noise intrusion. Overflights in these
areas can range from near the
traffic pattern altitude (about 1,000
feet above the ground) to as low as
300 above the ground. Accident risk
varies from low to moderate. Areas
where aircraft are near pattern
altitude (e.g., downwind leg) have
the lowest risk. In areas where
aircraft are at lower altitudes
(especially on circle-to-land
instrument approaches) a moderate
level of risk exists.

Consistent: The project site is
located within Zone D of the Napa
County Airport Land Use
Compatibility Plan. As discussed in
Impact LU-3, the proposed project
is compatible with all applicable
provisions of Zone D as set forth
in Tables 1-1 and 1-2.
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Policy 1.27.2 Review all applications for new
development, expansion of existing
uses, and reuse within Napa County
Airport Compatibility Zones “A”
through “E” for compliance with the
appropriate use and development
conditions.

Consistent: As discussed in Impact
LU-3, the proposed project is
compatible with all applicable
provisions of Zone D of the Napa
County Airport Land Use
Compatibility Plan.

Goal 1R Ensure a high quality of the City’s
built environment, architecture,
landscape, and public open spaces.

Consistent: The proposed project
consists of a contemporary 2.4-
million-square-foot industrial
development that includes a
Wetland Preserve. This would
advance the goal of providing a
high-quality built environment and
open space.

Objective 1.32 Attain residential, commercial,
industrial, and public buildings and
sites which convey a high-quality
visual image and character.

Consistent: The proposed buildings
would use concrete tilt‐up panel
construction and contemporary
finishes and treatments similar to
other industrial buildings in the
project vicinity. Landscaping would
be installed within parking areas
and along the Devlin Road
frontage. Outdoor storage areas
would be enclosed where
necessary to screen them from
view from major roadways. Overall,
these characteristics would
advance the objective of attaining
high-quality visual character. The
City’s design review process
would ensure consistency with
the applicable policies.

Policy 1.32.1 Require adherence to the Design
and Development Principles
prescribed in this Plan and the City’s
Design Review Guidelines which
shall be updated periodically.

Consistent: The proposed project
would incorporate relevant design
concepts set forth in the latest
adopted edition of the Design
Review Guidelines. Moreover, the
City’s design review process
would ensure consistency with
the applicable policies.

Policy 1.32.2 Require that development projects
subject to discretionary review
submit and implement a
landscaping plan.

Consistent: The proposed project
is subject to discretionary review
and, therefore, the applicant has
prepared and submitted a
preliminary landscaping plan to
the City, which will be considered
as part of the approval process. A
final landscaping plan will be
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required as part of the City’s
design review process, which
would ensure consistency with
the applicable policies.

Policy 1.32.5 Require the use of drought tolerant
species in landscape design in
accordance with the provisions of
the Water Conservation and
Landscape Act.

Consistent: The proposed
landscaping plan incorporates
drought tolerant species in
accordance with the provisions of
the Water Conservation and
Landscape Act.

Policy 1.32.6 Require that commercial, industrial,
and multi-family residential
development incorporate adequate
drought-conscious irrigation
systems and maintain the health of
the landscape.

Consistent: The proposed
landscaping plan incorporates
adequate drought-conscious
irrigation systems in accordance
with the provisions of the Water
Conservation and Landscape Act.

Policy 1.32.7 Require that all commercial,
industrial, multi-family, and
common area landscape be
adequately irrigated with automatic
irrigation systems.

Consistent: The proposed
landscaping plan incorporates
automatic irrigation systems.

Policy 1.32.8 Promote the use of reclaimed water
for the irrigation of public and
private landscape, as available.

Consistent: The proposed project
would be served with reclaimed
water provided by the City of
American Canyon for landscape
irrigation purposes.

Objective 1.33 Ensure that structures and sites are
designed and constructed to
maintain their long-term quality
and provide for the needs of their
occupants.

Consistent: All proposed
structures would be designed to
suit the needs of the end user,
consistent with this objective. The
City’s design review process
would ensure consistency with
the applicable policies.

Policy 1.33.1 Require that all structures be
constructed in accordance with the
requirements of the City’s building
and other pertinent codes and
regulations; including new,
adaptively reused, and renovated
buildings.

Consistent: All proposed
structures would be required to
adhere to the latest adopted
edition of the California Building
Standards Code at the time
building permits are sought.

Policy 1.33.3 Require that all development be
designed to provide adequate space
for access, parking, supporting
functions, open space, and other
pertinent elements.

Consistent: Phase 1 would
provide 860 off-street parking
spaces. Additionally, the proposed
project site includes an existing
Wetland Preserve.
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Policy 1.33.4 Require that all commercial,
industrial, and public development
incorporate appropriate design
elements to facilitate access for and
use by the physically challenged.

Consistent: All proposed
structures would be required to
incorporate all applicable
disability access requirements set
forth by the Americans with
Disability Act (ADA).

Economic
Development
Element
Goal 3 Provide for the economic needs of
American Canyon residents by
capitalizing on the marketability of
the City’s industrial land and
promoting a mix of uses which
create quality jobs and foster fiscal
stability.

Consistent: The proposed project
would develop 2.4 million square
feet of high-cube warehouse on an
approximately 208-acre site in the
Napa Airport Industrial Area. The
proposed project would create as
many as 3,643 new jobs, stimulate
capital investment, and expand the
tax base. These characteristics are
consistent with the goal of
providing for the economic needs
of American Canyon residents.

Objective 3.1 Maximize the City’s market
potential in terms of industrial/
business park and communityserving commercial activity.

Increased industrial activity can be a
catalyst for broadening the City’s
economic base by providing quality
jobs and tax revenues, as well as,
stimulating infrastructure
improvements.

Consistent: The proposed project
would develop 2.4 million square
feet of high-cube warehouse on an
approximately 208-acre site in the
Green Island Business Park. The
proposed project would create as
many as 3,643 new jobs, stimulate
capital investment, and expand the
tax base. These characteristics are
consistent with the objective of
maximizing the City’s market
potential in terms of industrial/
business park activity.

Policy 3.1.1 Adopt a Land Use Map which
designates acreage for heavy
industrial, light industrial/ business
park, commercial, and recreational
commercial activities.

Consistent: The approximately
208-acre project site is currently
designated “Industrial” by the City
of American Canyon General Plan
and the proposed project’s uses
are consistent with the allowable
uses of this land use designation.

Policy 3.1.3 Seek to expand the City’s economic
base and development
opportunities through planned
annexation program that is linked
to the General Plan and Land Use
Plan.

Consistent: The project site was
previously annexed into the City of
American Canyon in 2005 and the
proposed project contemplates
the development of 2.4 million
square feet of industrial uses on
the site.

Goal 3A Generate new industrial growth
through diversification of the
Consistent: The proposed project
would develop 2.4 million square
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industrial base and maintenance of
current activity to provide
employment opportunities for
residents and generate fiscal
revenues for the City.
feet of high-cube warehouse on
an approximately 208-acre site in
the Green Island Business Park.

This is consistent with the goal of
generating new industrial growth
through diversification of the
industrial base.

Objective 3.4 Increase the number of firms within
the industries now represented in
the City and capture new, clean,
nonpolluting industries that are
stable and compatible with City
needs in terms of traffic, air quality,
and employment.

Consistent: The proposed project
would develop 2.4 million square
feet of high-cube warehouse on
an approximately 208-acre site in
the Green Island Business Park.

These types of uses currently exist
within the Airport Industrial Area.

Additionally, the proposed project
is estimated to create 3,643 new
jobs. The proposed project would
implement traffic improvements
to mitigate for impacts on traffic
operations.

Policy 3.4.2 Establish design and FAR standards
for industrial buildings which will
create and maintain an attractive
image for American Canyon’s
industrial areas without imposing
overly restrictive regulations.

Consistent: As previously
discussed, Phase 1 and Phase 2
would each have a FAR of 0.26
that would be within the
allowable FARs of both 0.5 and

0.7, depending on the end user
and use.

Policy 3.4.3 In partnership with landowners and
tenants, improve the infrastructure
(particularly access across the North
Slough drainage channel and the
railroad) in the Green Island
Industrial Park and Annexes and
expand infrastructure services to
the undeveloped sites on the north
side of Green Island Road to link the
two industrial areas and provide
land use and design continuity to
both sides of Green Island Road.

Consistent: The proposed project
would take vehicular access from
Devlin Road and Green Island
Road. The City is in the process of
extending Devlin Road from
Green Island Road and Middleton
Way and this extension will be
completed by the time Phase 1 is
completed. In addition, the City
has planned improvements to
Green Island Road that would also
be in place by Phase 1.

Objective 3.5 Make available sufficient acreage in
order to capture the City’s fair share
of regional industrial growth
through the year 2010.

Consistent: The project site is
designated “Industrial” by the
General Plan and is served with
existing infrastructure. Thus, the
project site is well suited to
advance the objective of
facilitating industrial development
within American Canyon.
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Policy 3.5.1 Designate a sufficient amount of
land to accommodate the projected
growth in demand for industrial
space by 2010.

Consistent: The project site is
designated “Industrial” by the
General Plan and is served with
existing infrastructure. Thus, the
project site is well suited to
advance the policy of
accommodating new industrial
development within American
Canyon.

Circulation
Element
Guiding Policy

1.1 Community Priorities. Safe and
convenient access to activities in
the community is provided by a
well-designed local roadway
system. That system serves the
community’s primary need for
mobility and includes a planned
hierarchy of roadways to meet that
need. The following Community
Priorities relate most directly to this
Element:
- Encourage and foster a strong
sense of community and safety,
as well as the “hometown”
feeling by creation of a town
center through land use and
circulation planning.
- Improve a hierarchy of roadway
networks to achieve and maintain
acceptable traffic LOS and
provide a Citywide system of
bicycle lanes and recreational
trails that improve accessibility
without the use of an
automobile.
- Improve SR-29 so that it serves as
a visually attractive gateway into
the City while providing access to
commercial businesses and
serving intra and inter-regional
traffic and goods movement.

Consistent: Vehicular access to
the project site would be provided
from Green Island Road or the
Devlin Road extension, which
provides a connection to SR-29 via
South Kelly Road. The project
site’s location also allows for
convenient access to SR-12 (east
and west) such that safe and
convenient access can be
provided for trucks and residential
areas would be avoided.

Additionally, this Draft EIR
evaluates project impacts on the
roadway system using the City’s
adopted Level of Service (LOS)
standards. Refer to Section 3.12,
Transportation for further
discussion.

Guiding Policy

1.2 Implement planned roadway
improvements. Use Figure 3:

General Plan Circulation System,
and Table 3: Major Circulation
Improvements, to identify,
schedule, and implement roadway
and complimentary intersection
improvements to support General
Plan buildout conditions. Planned
Consistent: This Draft EIR
evaluates project impacts on the
roadway system using the City’s
adopted LOS standards. Refer to
Section 3.12, Transportation, for
further discussion.
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improvements may be phased as
development occurs and need for
increased capacity is identified.

Guiding Policy

1.3 Design circulation system to focus
regional travel on SR-29. SR-29 is
important for both Citywide and
north–south regional travel. As both
City and regional travel grow,
design the City circulation system to
discourage regional traffic from
bypassing SR-29 and impacting City
streets. Also, cooperatively work
with regional partners, including
Caltrans, NCTPA and others explore
a complete streets approach that
will expand the travel capacity of
SR-29.

Consistent: Vehicular access to
the project site would be provided
from Green Island Road or the
Devlin Road extension, which was
completed in 2012 and provides a
connection to SR-29 via South
Kelly Road. The project site’s
location also allows for
convenient access to SR-12 (east
and west) such that projectrelated traffic would not need to use side streets. Refer to Section

3.12, Transportation, for further
discussion.

Guiding Policy

1.6 Achieve and maintain a Multimodal
LOS D or better for roadways and
intersections during peak hours
where possible and as long as
possible. However, recognizing that
LOS D may not be achievable or
cannot be maintained upon full
buildout of the General Plan, due to
traffic generated from sources
beyond the control of the City, the
City Council shall have the
discretion to only require feasible
mitigation measures that may not
achieve LOS D, but will reduce the
impact of any development use or
density planned for in the Land Use
Element of the General Plan.

Consistent: This Draft EIR
evaluates project impacts on the
roadway system using the City’s
adopted LOS standards. Refer to
Section 3.12, Transportation, for
further discussion.

Guiding Policy

1.9 Use of existing facilities. Make
efficient use of existing
transportation facilities, and
improve these facilities as necessary
in accordance with the Circulation
Map.

Consistent: In addition to the Devlin
Road extension, the proposed
project would rely on existing
roadways (e.g., Green Island Road,
Devlin Road, and South Kelly Road)
for vehicular access.
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Guiding Policy

1.11 Reduce Vehicle Miles Traveled.

Through layout of land uses,
improved alternate modes, and
provision of more direct routes,
strive to reduce the total vehicle
miles traveled by City residents.

Consistent: The project site is
located within the Napa County
Airport Industrial Area, which has
convenient access to SR-12 and
SR-29. The development of the
proposed project’s 2.4 million
square feet of high-cube
warehouse is within the North
Bay Region and would contribute
to reducing trip length by locating
these facilities closer to customers
within this region. Finally, the
development of up to 3,643 new
jobs in a housing-rich part of the
Bay Area region would allow
employees to work closer to
where they live, thereby reducing
vehicle miles traveled.

Guiding Policy

1.12 Circulation System Enhancements.

Achieve, maintain and/or improve
mobility in the City by considering
circulation system enhancements
beyond improvements identified on
the Circulation Map, where feasible
and appropriate. Improve the
circulation system, in accordance
with the Circulation Map, at
minimum, to support multimodal
travel of all users and goods and
where feasible, apply creative
circulation system enhancements
that increase system capacity and
that are acceptable to the City and
its residents and where applicable,
Caltrans.

Consistent: This Draft EIR
evaluates project impacts on the
roadway system using the City’s
adopted LOS standards. This is
consistent with the policy of
maintaining and improving
mobility through circulation
system enhancements. Refer to
Section 3.12, Transportation, for
further discussion.

Implementing
Policy 1.13
Financing Program. Develop a
transportation financing program
that will fully fund the planned
expansion of the existing
transportation network consistent
with the General Plan. The financing
program will include an update to
the existing Transportation Impact
Fee (TIF) program consistent with
AB 1600.

Consistent: The proposed project
would pay fees in accordance with
the City’s latest adopted traffic
impact fee schedule, albeit with
credits for improvements installed
by the proposed project. This is
consistent with the policy of
implementing a transportation
financing program that will fully
fund the planned expansion of the
existing transportation network.

Implementing
Policy 1.14
Work with Caltrans on highway
improvements. Continue to work
Consistent: This Draft EIR
evaluates project impacts on
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with the Caltrans to achieve timely
context sensitive design solutions,
funding and construction of
programmed highway
improvements.
transportation facilities under the
jurisdiction of California
Department of Transportation
(Caltrans) (i.e., SR-29). This is
consistent with the policy of
working with Caltrans on highway
improvements. Refer to Section

3.12, Transportation, for further
discussion.

Implementing
Policy 1.16
Use of Congestion Management
Process. Utilize the NCTPA
Congestion Management Program
(CMP) to determine the timing and
degree of regional roadway facility
improvements in accordance with
region wide plans. Actively
participate in the Community-Based
SR 29 Gateway Corridor
Improvement Plan process to
identify a funded SR 29 travel
capacity enhancement through the
City.

Consistent: This Draft EIR
evaluates project impacts on CMP
transportation facilities (SR-29).

Refer to Section 3.12,
Transportation, for further
discussion.

Implementing
Policy 1.17
Regional fair-share fee program.

Work with Caltrans, NCTPA, Napa
County, and other jurisdictions to
establish a fair-share fee program
for improvements to routes of
regional significance and State
highways. This fee should reflect
traffic generated by individual
municipalities/ unincorporated
communities as well as passthrough traffic.

Consistent: The proposed project
would pay fees in accordance with
the City’s latest adopted traffic
impact fee schedule, albeit with
credits for improvements installed
by the proposed project. This
includes improvements under the
jurisdiction of Caltrans, Napa
County Transportation and
Planning Agency (NCTPA), and the
County of Napa. Refer to Section

3.12, Transportation, for further
discussion.
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Implementing
Policy 1.19
Complete Streets. When
constructing or modifying
transportation facilities, consistent
with Resolution 2012-72, “Complete
Streets Policy of the City of
American Canyon,”, strive to
provide for the movement of
vehicles, commercial trucks,
alternative and low energy vehicles,
transit, bicyclists and pedestrians
appropriate for the road
classification and adjacent land use.

Consistent: All improvements
required as mitigation for the
proposed project would comply
with the applicable provisions of
Resolution 2012-72, “Complete
Streets Policy of the City of
American Canyon.”
Implementing
Policy 1.23
Access Restriction. Minimize, where
possible, the number of access
points along arterial roadways,
including by consolidating or
relocating driveways to provide for
more efficient traffic movement.

Consistent: Phase 1 would have
four access points on both Devlin
and Green Island Road. Half of
these points would be designated
for trucks and the other half
would be designated for
passenger vehicles. This is
consistent with the policy of
providing for more efficient traffic
movement.

Implementing
Policy 1.24
Impacts of new development. Based
upon the findings of a traffic impact
study, consistent with Guiding
Policy 1.26, new development will
be responsible for mitigation of
transportation related impacts.

Consistent: A traffic impact study
was prepared as part of this Draft
EIR. Refer to Section 3.12,
Transportation, for further
discussion.

Implementing
Policy 1.26
Update and adopt Transportation
Impact Analysis (TIA) guidelines.

Update and adopt Transportation
Impact Analysis guidelines and a
Multimodal LOS assessment
methodology for the evaluation of
potential transportation impacts
resulting from new development
that is specific to the City and that
will supersede existing LOS
standards and guidelines.

Consistent: A traffic impact study
was prepared as part of this Draft
EIR in accordance with the City of
American Canyon’s latest
guidance for such studies. Refer
to Section 3.12, Transportation,
for further discussion.
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Implementing
Policy 1.35
General transit and pedestrian
access. In reviewing designs of
proposed developments, ensure
that provision is made for access to
current and future public transit
services. In particular, pedestrian
access to arterial and collector
streets from subdivisions should not
be impeded by continuous
segments of sound walls.

Additionally, there would be safe
and convenient locations within
the project site to allow for future
transit service.

Guiding Policy

2.1 Promote walking and bicycling.

Promote walking and bike riding for
transportation, recreation, and
improvement of public and
environmental health.

Consistent: The applicant would
develop the segment of the Class I
Napa Valley Vine Trail along the
project frontages with Devlin
Road and Green Island Road. The
proposed project’s internal
pedestrian facilities would
connect to the Napa Valley Vine
Trail. Additionally, the proposed
project would be accessible to
bicycles. Collectively, these
characteristics would promote
walking and bicycling.

Guiding Policy

2.3 Develop a safe and efficient nonmotorized circulation system.

Provide safe and direct pedestrian
routes and bikeways between
places.

Implementing
Policy 2.7
Universal design. Provide
pedestrian facilities that are
accessible to persons with
disabilities and ensure that roadway
improvement projects address
accessibility by using universal
design concepts.

Consistent: The applicant would
develop the segment of the Class I
Napa Valley Vine Trail along the
project frontages with Devlin
Road and Green Island Road.

These new trail segments would
comply with the ADA. The
proposed project’s internal
pedestrian facilities would also
comply with the ADA.
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Implementing
Policy 2.18
Pedestrian connections to
employment destinations.

Encourage the development of a
network of continuous walkways
within new commercial, town
center, public, and industrial uses to
improve workers’ ability to walk
safely around, to, and from their
workplaces. Where possible, route
pedestrians to grade-separated
crossings over State Route 29.

Consistent: The proposed
project’s internal pedestrian
facilities would connect to the
Napa Valley Vine Trail and, thus,
advance the policy of providing
pedestrian connections to
employment destinations. The
City’s design review process
would ensure consistency with
this policy.

Guiding Policy

4.1 Promote safe and efficient goods
movement. Promote the safe and
efficient movement of goods via
truck and rail with minimum
disruptions to residential areas.

Consistent: The project site is
located within the Green Island
Business Park, which has
convenient access to SR-12 and
SR-29. Additionally, at least one
project building may be railserved. This is consistent with the policy of promoting safe and
efficient goods movement.

Guiding Policy

4.2 Promote railroad safety. Minimize
the safety problems associated with
the railroad, including the
construction and maintenance of
at-grade crossings and the physical
barrier effect of the track alignment
on the City.

Consistent: Devlin Road provides
a grade-separated overcrossing of
the Napa Branch Line. Thus,
vehicles traveling to and from the
project site on Devlin Road would
avoid any related safety
problems. Additionally, both
railroad grade crossings on Green
Island Road would receive safety
improvements as part of the Cityled Green Island Road Widening Project.

Guiding Policy

4.4 New truck route designation. All
highways, arterials, and industrial
streets shall be designated truck
routes.

Consistent: Devlin Road, which
was completed in 2012, is a
designated truck route. The Devlin
Road extension would also be a
truck route. Additionally, Green
Island Road is a designated truck
route and would be improved
along the project frontage as part
of the City-led Green Island Road
Widening Project.

Guiding Policy

4.6 Location of industrial development.

Continue industrial expansion in the
north industrial area to minimize
the neighborhood impacts of truck
movements.

Consistent: The project site is
located within the Green Island
Business Park, which is designated
for industrial development. There
are no residential areas near this
area, nor would project-related
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truck routes travel through such
areas.

Guiding Policy

4.7 Secure truck parking. Encourage
high-security off-street parking for
tractor-trailer rigs in industrial
designated areas.

Consistent: Phase 1 would
provide 806 off-street parking
spaces, most of which would be
suitable for tractor-trailer rigs.

The project site would be secured
with fencing and lighting. As such,
the proposed project would
provide secure truck parking.

Utilities Goal 5 It shall be the goal of American
Canyon to establish and maintain a
secure water supply and treatment,
distribution and storage system to
serve the land uses proposed under
the general plan.

Consistent: This Draft EIR
evaluates project impacts on
water supply and distribution and
concludes that adequate supplies
and infrastructure are available to
serve the project. Refer to Section

3.13, Utilities and Service
Systems, for further discussion.

Objective 5.2 Obtain additional water supply
sources as necessary to supplement
the [North Bay Aqueduct] supply
and serve anticipated growth under
the proposed land use plan.

Consistent: A Water Supply
Assessment (WSA) was prepared
for the proposed project and
concludes that adequate supplies
are available to serve the project.

Refer to Section 3.13, Utilities and
Service Systems, for further
discussion.

Policy 5.2.4 Promote water conservation and
wastewater reclamation as
additional water supply sources.

Consistent: The proposed project
would employ drought tolerant
landscaping and be served with
recycled water for non-potable
irrigation purposes. This is
consistent with the policy of
promoting water conservation
and wastewater reclamation.

Refer to Section 3.13, Utilities and
Service Systems, for further
discussion.

Policy 5.2.5 In the event that sufficient capacity
is not available to serve a proposed
project, the City shall not approve
the project until additional capacity
or adequate mitigation is provided.

Consistent: A WSA was prepared
for the proposed project and
concludes that adequate supplies
are available to serve the project.

In addition, the proposed project
would comply with the City’s Zero
Water Footprint Policy, which
requires new development
projects to secure offsets to
ensure that existing customers do
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not experience a loss in reliability
or an increase in rates.

Objective 5.4 Establish a water management
program to promote water
conservation and wastewater reuse.

Consistent: The proposed project
would employ drought tolerant
landscaping and be served with
recycled water for non-potable
irrigation purposes. This is
consistent with the objective of
promoting water conservation
and wastewater reuse. Refer to
Section 3.13, Utilities and Service
Systems, for further discussion.

Policy 5.4.1 Promote the use of water-saving
plumbing fixtures and water-saving
landscaping.

Consistent: The proposed project
would employ drought tolerant
landscaping. The proposed
project’s plumbing fixtures would
comply with the water
conservation standards set forth
in the latest adopted edition of
the California Plumbing Code.

Goal 5B It shall be the goal of American
Canyon to develop and maintain a
water treatment and distribution
system that meets generally
accepted operational criteria for
service to provide daily and peak
demands, including fire flow
requirements, to meet present and
future needs in a timely and cost
effective manner.

Consistent: This Draft EIR
evaluates project impacts on
water supply and distribution and
concludes that adequate supplies
and infrastructure are available to
serve the project. Refer to Section

3.13, Utilities and Service
Systems, for further discussion.

Objective 5.7 Expand water treatment, storage
and distribution facilities as
necessary to meet increasing water
demands.

Consistent: The existing water
distribution lines in Green Island
Road have adequate capacity to
serve the project. Additionally, a
WSA was prepared for the
proposed project and concludes
that adequate supplies are
available to serve the project.

Refer to Section 3.13, Utilities and
Service Systems, for further
discussion.
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Policy 5.7.3 Require adequate water supply,
distribution, storage, and treatment
facilities to be operational prior to
the issuance of certificates of
occupancy.

Refer to Section 3.13, Utilities and
Service Systems, for further
discussion.

Policy 5.7.4 Require all new development to be
served from an approved domestic
water supply.

Consistent: The proposed project
would be served with potable
water provided by the City of
American Canyon, which is an
approved domestic water supply.

Policy 5.7.5 Monitor the demands on the water
system and, as necessary, manage
development to mitigate impacts
and/or facilitate improvements.

Consistent: This Draft EIR
evaluates project impacts on
water supply and distribution and
concludes that adequate supplies
and infrastructure are available to
serve the project. Refer to Section

3.13, Utilities and Service
Systems, for further discussion.

Objective 5.8 Ensure that the costs of
improvements to the water supply,
distribution, storage, and treatment
system are borne by those who
benefit.

Consistent: The project applicant
would construct or provide the
full cost of on-site water
infrastructure and off-site
improvements necessary to serve
the proposed project.

Policy 5.8.1 Require improvements to the
existing water supply, distribution,
storage, and treatment facilities
necessitated by a new development
proposal be borne by the project
proponent (in proportion to
benefit); either through the
payment of fees, or by the actual
construction of the improvements.

Consistent: The project applicant
would construct or provide the
full cost of on-site water
infrastructure and off-site
improvements necessary to serve
the proposed project.
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Goal 5C Establish and maintain adequate
planning, construction,
maintenance, and funding for storm
drain and flood control facilities to
support permitted land uses and
preserve the public safety;
upgrading existing deficient systems
and expanding, where necessary, to
accommodate new permitted
development and to protect
existing development in the City.

Pursue public funding sources (i.e.,
grants) to reduce fiscal impacts of
implementation to the City.

Consistent: The proposed project
would install an on-site
stormwater drainage system that
would include a network of
detention basins. The system
would be designed to
accommodate peak storm event
runoff in accordance with the
City’s latest adopted standards.

This is consistent with the goal of
providing adequate storm drain
and flood control facilities to
support permitted land uses and
preserve the public safety. Refer to
Section 3.8, Hydrology and Water
Quality, for further discussion.

Objective 5.10 Ensure that adequate storm drain
and flood control facilities are
provided and properly maintained
to protect life and property from
flood hazards.

Consistent: The proposed project
would install an on-site
stormwater drainage system that
would be designed to
accommodate peak storm event
runoff in accordance with the
City’s latest adopted standards.

Refer to Section 3.8, Hydrology
and Water Quality, for further
discussion.

Policy 5.10.1 Provide for the maintenance of
existing public storm drains and
flood control facilities and for the
construction of upgraded and
expanded storm drain and flood
control facilities, where necessary,
to protect existing and
accommodate new permitted
development.

Consistent: The project applicant
would install on-site storm
drainage infrastructure and be
responsible for its maintenance
and upkeep.

Policy 5.10.3 Require that adequate storm drain
and flood control facilities be
constructed coincident with new
development.

Consistent: The project applicant
would be required to install onsite storm drainage infrastructure prior to issuance of the certificate
of occupancy.

Policy 5.10.4 Limit new development, when
necessary, until adequate flood
control facilities are constructed to
protect existing development and
accommodate the new development
runoff, or until mitigation is provided.

Consistent: The project applicant
would be required to install onsite storm drainage infrastructure prior to issuance of the certificate
of occupancy. This is consistent
with the policy of requiring
adequate flood control facilities to
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be constructed in conjunction
with new development.

Objective 5.11 Ensure that the costs of
improvements to the storm drain
and flood control system are borne
by those who benefit.

Consistent: The project applicant
would construct or provide the
full cost of on-site storm drainage
infrastructure and off-site
improvements necessary to serve
the proposed project.

Policy 5.11.1 Require improvements to existing
storm drain and flood control
facilities necessitated by a new
development proposal be borne by
the project proponent; either
through the payment of fees, or by
the actual construction of the
improvements in accordance with
State Nexus Legislation.

Consistent: The project applicant
would construct or provide the
full cost of on-site storm drainage
infrastructure and off-site
improvements necessary to serve
the proposed project.

Policy 5.11.3 Collect adequate amounts of fees
and charges to fund the
operation/maintenance of existing
facilities and to construct new
facilities.

Consistent: The project applicant
would provide all required storm
drainage fees to the City of
American Canyon.

Goal 5D Maintain the quality of surface and
subsurface water resources within
the City of American Canyon and its
Planning Area.

Consistent: As required by
applicable laws and regulations,
the proposed project would
implement stormwater quality
measures and practices to
maintain the quality of surface
and subsurface water resources.

Objective 5.12 Enhance runoff water quality
upstream of points of discharge to
channelized drainage courses.

Consistent: As required by
applicable laws and regulations,
the proposed project would
implement stormwater quality
measures and practices that
would enhance runoff water
quality prior to discharge in
downstream waterways.

Policy 5.12.1 Capitalize on opportunities to
reduce pollutant loading through
passive treatment systems such as
vegetated filter strips, grass swales,
and infiltration/ sedimentation
areas in suitable open space areas,
and incorporated into landscaping
adjacent to parking lots and streets.

Consistent: Passive treatment
systems would be incorporated
into the proposed project’s storm
drainage system where
appropriate.
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Policy 5.12.2 Incorporate features in new
drainage detention facilities which
enhance the water quality of
discharges from the facility.

Consistent: The proposed
project’s storm drainage system
would include a network of
detention basins, which would
serve to enhance the water
quality of discharges from the
facility through percolation of
pollutants into the soil. Refer to
Section 3.8, Hydrology and Water
Quality, for further discussion.

Policy 5.12.3 Minimize impervious area that is
directly connected to piped or
channelized drainage systems in
new development.

Consistent: Approximately 44.8
acres of the project site (22
percent) would be dedicated for
Wetland Preserve and detention
basin use. This would be
consistent with the policy of
minimizing impervious area that is
directly connected to piped or
channelized drainage systems in
new development. Refer to
Section 3.8, Hydrology and Water
Quality, for further discussion.

Objective 5.13 Prevent degradation of surface
water quality due to construction
activities and industrial operations.

Consistent: As required by
applicable laws and regulations, the
proposed project would implement
construction and operation
stormwater pollution prevention
measures to prevent degradation
of surface water quality. Refer to
Section 3.8, Hydrology and Water
Quality, for further discussion.

Policy 5.13.1 Require that development activities
comply with the State General Storm
Water Permit For Construction
Activities with measures that protect
surface water quality to the
maximum extent practicable.

Consistent: The proposed project’s
construction and operation
stormwater pollution prevention
measures would comply with the
applicable stormwater permits.

Refer to Section 3.8, Hydrology and
Water Quality, for further
discussion.
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Goal 5E It shall be the goal of the City of
American Canyon to establish and
maintain adequate planning,
construction, maintenance, and
funding for wastewater collection
and treatment facilities to support
land uses; upgrading existing
deficient systems, and expanding,
where necessary, in the City’s
service area.

Consistent: This Draft EIR
evaluates project impacts on
wastewater collection and
treatment and concludes that
adequate capacity is available to
serve the project. Refer to Section

3.13, Utilities and Service
Systems, for further discussion.

Objective 5.14 Provide a system of wastewater
collection and treatment facilities
which will adequately convey and
treat wastewater generated by
existing and future development in
the City’s service area.

Policy 5.14.2 Provide for the construction of
upgraded and expanded
wastewater collection and
treatment improvements to
support existing and new
development.

Consistent: The proposed project
would connect to an existing
sewer line located within Green
Island Road. Aside from laterals to
serve proposed buildings, no
other wastewater upgrades would
be required.

Policy 5.14.4 Require new development to
connect to a master planned
sanitary sewer system. Where
construction of master planned
facilities is not feasible, and where
the future construction of master
planned faculties will not be
jeopardized, the City Council may
permit the construction of interim
faculties sufficient to serve the
present and short-term future
needs.

Consistent: The proposed project
would be served with sanitary
sewer service provided by the City
of American Canyon. The
proposed project would connect
to an existing sewer line located
within Green Island Road; no
interim facilities would be
necessary.

Policy 5.14.5 Require all new development to
secure sewer capacity rights prior to
or at the time building permits are
issued.

Consistent: The City of American
Canyon has indicated that the
proposed project would be served
with adequate sewer capacity.

Objective 5.15 Ensure that wastewater collection
and treatment facilities are
upgraded and installed in a timely
manner to meet usage
requirements and maximize cost
efficiency.

Consistent: Aside from laterals to
serve proposed buildings, all
wastewater infrastructure
necessary to serve the proposed
project is currently in place. The
laterals would be required to be in
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place prior to the issuance of a
certificate of occupancy.

Policy 5.15.1 Require that wastewater collection
and treatment facilities be installed
and available for use prior to the
issuance of a certificate of
occupancy.

Objective 5.16 Ensure that the costs of
infrastructure improvements are
borne by those who benefit.

Consistent: The project applicant
would construct or provide the
full cost of on-site sewer
infrastructure and off-site
improvements necessary to serve
the proposed project and would
be subject to City fee programs.

Policy 5.16.1 Require that the cost for
improvements to the existing
wastewater collection and
treatment facilities necessitated by
a new development proposal be
borne by the project proponent in
proportion to benefit; either
through the payment of fees, or by
the actual construction of the
improvements.

Public
Services and
Facilities
Goal 6A Maintain a high level of fire
protection and emergency services
to City/District businesses and
residences.

Consistent: This Draft EIR
evaluates project impacts on the
American Canyon Fire Protection
District and concludes that
adequate levels of service can be
provided. Refer to Section 3.11,
Public Services, for further
discussion.

Objective 6.3 Ensure that the Fire District’s
facility, manpower and equipment
needs keep pace with the City’s
growth.

Policy 6.3.1 Require that City planning staff
work closely with Fire District
officials to ensure that fire facilities
and personnel are expanded
Consistent: The American Canyon
Fire Protection District was
consulted during the preparation
of this Draft EIR to determine
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commensurably to serve the needs
of the City’s growing population and
development base.
whether the proposed project
would impede its ability to
provide fire protection. Refer to
Section 3.11, Public Services, for
further discussion.

Policy 6.4.3 Require, through the development
review process, that all structures
and facilities subject to the District’s
jurisdiction adhere to City, State
and federal regulatory standards
such as the Uniform Building and
Fire Codes and other applicable
safety guidelines.

Consistent: All proposed project
structures would be required to
comply with the latest adopted
edition of the California Fire Code.

Goal 6B Ensure a high level of police
protection for the City’s residents,
businesses and visitors.

Consistent: This Draft EIR
evaluates project impacts on the
American Canyon Police
Department and concludes that
adequate levels of service can be
provided. Refer to Section 3.11,
Public Services, for further
discussion.

Objective 6.7 Coordinate development activities
with the Napa County Sheriff’s
Department or other contract agency
to ensure that adequate facilities and
services are maintained for the City’s
residents, businesses and visitors.

Consistent: The American Canyon
Police Department was consulted
during the preparation of this Draft
EIR to determine whether the
proposed project would impede its
ability to provide police protection.

Refer to Section 3.11, Public
Services, for further discussion.

Policy 6.7.1 Work with the Sheriff’s Department
to ensure that enough personnel
are added to the Department to
serve the needs of a growing
population and a developing City.

Consistent: The American Canyon
Police Department was consulted
during the preparation of this
Draft EIR to determine whether
the proposed project would
impede its ability to provide
police protection. Refer to Section

3.11, Public Services, for further
discussion.

Objective 6.9 Increase the residents’ and Sheriff’s
Department ability to minimize
crime and improve security for all
uses of public and private buildings,
sites, and open spaces.

Consistent: The proposed project
incorporates design features such
as low-profile landscaping and
exterior lighting to prevent and
deter criminal activity.

Policy 6.9.2 Require that landscaping in proximity
to commercial, industrial, multifamily, and public structures be sited to allow for security surveillance.

Consistent: The proposed project
would provide low-profile, nonobtrusive landscaping along roadway frontages and within
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parking areas to allow for
adequate security surveillance.

Policy 6.9.3 Require the incorporation of
lighting which provides adequate
exterior illumination to facilitate
security surveillance around
commercial, industrial, multi-family,
and public structures.

Consistent: The proposed project
would provide exterior lighting that
would provide adequate
illumination.

Natural and
Historic/
Cultural
Resources
Goal 8 Protect and preserve the significant
habitats, plants and wildlife that
exist in the City and its Planning
Area.

Consistent: This Draft EIR evaluates
the proposed project’s potential
impacts on biological resources and
requires mitigation where
necessary to reduce impacts to a
level of less than significant. Refer
to Section 3.3, Biological Resources,
for further discussion.

Objective 8.1 Maintain data and information
regarding areas of significant
biological value within the Planning
Area to facilitate resource
conservation and the appropriate
management of development.

Consistent: This Draft EIR’s
evaluation of potential impacts on
biological resources included
review of relevant databases of
biological information and field
surveys of the project site. The
findings thereof were used in
developing appropriate mitigation
for project impacts. This is
consistent with the objective of
using best available information
to facilitate resource
conservation. Refer to Section 3.3,
Biological Resources, for further
discussion.

Policy 8.1.1 Acquire and maintain the most
current information available
regarding the status and location of
sensitive biological elements
(species and natural communities)
within the City and, as appropriate,
within the Sphere of Influence and
Urban Limit Line.

Consistent: This Draft EIR’s
evaluation of potential impacts on
biological resources included
review of relevant databases of
biological information and field
surveys of the project site. The
findings thereof were used in
developing appropriate mitigation
for project impacts. This is
consistent with the policy of using
the best available information to
evaluate impacts on biological
resources. Refer to Section 3.3,
Biological Resources, for further
discussion.
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Policy 8.1.4 Regularly monitor and review
developments proposed within the
City’s Planning Area to assess their
impacts on local biological
resources and to recommend
appropriate mitigation measures
that the developer and/or
government agency can implement.

Consistent: This Draft EIR
evaluates the proposed project’s
potential impacts on biological
resources and requires mitigation
where necessary to reduce
impacts to a level of less than
significant. Refer to Section 3.3,
Biological Resources, for further
discussion.

Objective 8.2 Balance the preservation of natural
habitat areas, including coastal
saltmarsh, mixed hardwood forest,
oak savanna, and wetland and
riparian habitats, with new
development in the City.

Consistent: The proposed project
site includes an existing Wetland
Preserve that coincides with the
highest quality habitat within the
project site. This is consistent with
the objective of balancing the
preservation of natural habitat
areas with new development.

Policy 8.2.1 Land use applications for
developments located within
sensitive habitats, including coastal
saltmarsh, mixed hardwood forest,
oak savanna, and riparian habitats or
with areas potentially occupied by
vernal pools (see Figure 8-2) shall be
accompanied by sufficient technical
background data to enable an
adequate assessment of the
potential for impacts on these
resources, and possible measures to
reduce any identifiable impacts. In
addition to examining Figure 8-1 for
information on these sensitive
habitats, an on-site assessment shall
be conducted by a City approved
qualified Biologist to determine
whether sensitive habitats exist onsite.

In instances where the potential for
significant impacts exists, the
applicant must submit a Biological
Assessment Report prepared by a
qualified professional.

Consistent: The project site
contains wetlands. This Draft EIR
includes biological and wetland
analysis conducted by HuffmanBroadway Group, a biological consulting firm. Refer to Section

3.3, Biological Resources, for
further discussion.

Objective 8.3 Protect natural drainages and
riparian corridors within the
American Canyon Planning Area.

Consistent: The proposed project
site includes an existing Wetland
Preserve that contains a segment
of No Name Creek. This is
consistent with the objective of
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protecting natural drainages and
riparian corridors.

Policy 8.3.1 Review proposed developments in
wetlands and riparian habitats to
evaluate their conformance with
the following policies and
standards:
a. The development plan shall fully
consider the nature of existing
biological resources and all
reasonable measures shall be
taken to avoid significant
impacts, including retention of
sufficient natural open space and
undeveloped buffer zones.
b.Development shall be designed
and sited to preserve
watercourses, riparian habitat,
vernal pools, and wetlands in
their natural condition, unless
these actions result in an
unfeasible project, in which case
habitat shall be replaced in
accord with subsection “g.”
c. Where riparian corridors are
retained, they shall be protected
by an adequate buffer with a
minimum 100-foot protection
zone from the edge of the tree,
shrub, or herb canopy (see policy

8.3.2).
d.Development shall incorporate
habitat linkages (wildlife
corridors) to adjacent open
spaces, where appropriate and
feasible.
e. Development shall incorporate
fences, walls, vegetative cover, or
other measures to adequately
buffer habitat areas, linkages or
corridors from built environment.
f. Roads and utilities shall be
located and designed such that
conflicts with biological
resources, habitat areas, linkages
or corridors are avoided where
feasible.
g. Future development shall utilize
appropriate open space or
conservation easements in order
Consistent: The proposed project
is designed in a manner to locate
buildings and infrastructure away
from the highest quality wetlands
that are located in the western
portion of the site. The highest
quality wetlands are located
within an existing Wetland
Preserve. Finally, the reach of No
Name Creek located within the
project site is within the existing
Wetland Preserve. The wetlands
impacted by the project cannot be
avoided due to their location;
however, their loss would be
offset through the creation of
compensatory wetlands in the
preserve. Lastly, the proposed
project would be required to
obtain approvals from USACE,
CDFW, and Regional Water
Quality Control Board (RWQCB)
and adhere to all provisions of
those permits. For these reasons,
the proposed project is consistent
with the provisions of this policy.
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to protect sensitive species or
their habitats.
h. Future development shall
mitigate unavoidable adverse
impacts to waters of the United
States, wetlands and riparian
habitats (pursuant to the Federal
Clean Water Act and the
California Fish and Game Code,
Section 1600 et seq.) by
replacement on an in-kind basis.

Furthermore, replacement shall
be based on a ratio determined
by the California Department of
Fish and Game and/or Army Corp.
of Engineers in order to account
for the potentially diminished
habitat values of replacement
habitat. Such replacement should
occur on the original
development site, whenever
possible. Alternatively,
replacement can be effected,
subject to State and federal
regulatory approval, by creation
or restoration of replacement
habitats elsewhere (off-site but
preferably within the City’s
Planning Area), protected in
perpetuity by provision for an
appropriate conservation
easement or dedication.

Policy 8.3.2 Prohibit development and grading
that alters the biological integrity of
the Riparian Corridors as depicted
on the Biological Habitats Map,
unless no feasible alternative exists
or the damaged habitat is replaced
with habitat of equivalent value.

Development that is permitted
within Riparian Corridors shall:
a. minimize removal of vegetation,
erosion, sedimentation and
runoff by appropriate protection
or vegetation and landscape;
b. provide for sufficient passage of
native and anadromous fish;
c. minimize wastewater discharges
and entrapment;
Consistent: A segment of No
Name Creek is located within the
proposed Wetland Preserve. For
those riparian areas located
where development is proposed,
mitigation is proposed requiring
any impacted riparian areas to be
offset through restoration of
comparable habitat within the
Wetland Preserve. The features
impacted by the project cannot be
avoided due to their location;
however, their loss would be
offset through the creation of
compensatory features in the
preserve.
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d. prevent ground water depletion
or substantial interference with
surface and subsurface flows;
e. provide for natural vegetation
buffers;
f. minimize the channelization of
streams and other watercourses;
g. provide for the enhancement of
riparian corridors.

Policy 8.3.3 Permit only the following uses within
retained Riparian Corridors:
a. education and research,
excluding buildings and other
structures;
b. passive (non-motorized)
recreation;
c. trails and scenic overlooks on
public land(s) if located outside of
undeveloped buffer zones;
d. fish and wildlife management
activities;
e. necessary water supply projects;
f. resource consumptive uses as
provided for in the Fish and Game
Code and Title 14 of the
California Administrative Code;
g. flood control projects where no
other methods are available to
protect the public safety;
h. bridges when supports are not in
significant conflict with riparian
resources; and
i. underground utilities.

Consistent: The proposed
Wetland Preserve that includes a
segment of No Name Creek would
be maintained and, consistent
with the approved Management
Plan, would be available for
education and research and
wildlife management activities.

Policy 8.3.5 Establish a network of open spaces
along the City’s natural drainages
and riparian corridors and link
significant biological habitats. Any
recreational use of these areas shall
be designed to avoid damaging
sensitive habitat areas.

Consistent: The proposed
Wetland Preserve that includes a
segment of No Name Creek would
be maintained by the proposed
project. As such, it would be
consistent with the policy of
establishing of a network of open
spaces along the City’s natural
drainages and riparian corridors.

Policy 8.3.6 Preserve and integrate the City’s
natural drainages in new
development, as opposed to their
channelization or undergrounding,
emphasizing opportunities for the
development of pedestrian paths
Consistent: The proposed
Wetland Preserve that includes a
segment of No Name Creek would
be maintained by the proposed
project. As such, it would be
consistent with the policy of
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and greenbelts along their lengths
throughout the City.
preserving and integrating natural
drainages in new development.

Objective 8.4 Protect local vernal pools as well as
the habitats of endangered species
living within American Canyon’s
Planning Area.

Consistent: The proposed
Wetland Preserve that includes a
segment of No Name Creek would
be maintained by the proposed
project and would include vernal
pools and the highest quality
habitat with the project site. The
vernal pools impacted by the
project cannot be avoided due to
their location; however, their loss
would be offset through the
creation of compensatory
features in the preserve. As such,
it would be consistent with the
policy of protecting vernal pools
and habitats of special-status
species.

Policy 8.4.1 Require that development plans
incorporate all reasonable
mitigation measures to avoid
significantly impacting vernal pools
for projects located within
American Canyon’s Planning Area.

Consistent: The proposed
Wetland Preserve that includes a
segment of No Name Creek would
be maintained by the proposed
project and would include vernal
pools. For those vernal pools
located where development is
proposed, mitigation is proposed
requiring any impacted resources
to be offset through restoration of
comparable habitat within the
Wetland Preserve.

Policy 8.4.2 Preserve, where possible, the
habitat of several in-fact
endangered species, including those
shown on Figure 8-2 and listed in
Table 8-1, as well as those that may
be considered by the City in the
future.

Consistent: The proposed
Wetland Preserve that includes a
segment of No Name Creek would
be maintained by the proposed
project and includes the highest
quality habitat for special-status
species with the project site. As
such, it would be consistent with
the policy of preserving habitats
of special-status species.

Geology Goal 9 Reduce the potential level of death,
injury, property damage, economic
and social dislocation (i.e., business
closures and homelessness due to
structural damage) and disruption
of vital services that could result
from earthquake damage.

Consistent: The West Napa Fault
crosses the project site. This Draft
EIR requires mitigation measures
consisting of a fault investigation
study and compliance with the
latest adopted edition of the
California Building Standards Code
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to reduce the potential level of
death, injury, property damage,
and economic and social
dislocation to acceptable levels.

Refer to Section 3.5, Geology,
Soils, and Seismicity, for further
discussion.

Goal 9C Ensure that seismic, geologic, and
soils hazards that might affect areas
designated for human use or
habitation are properly mitigated or
avoided entirely prior to
development.

Consistent: The West Napa Fault
crosses the project site. This Draft
EIR requires mitigation measures
consisting of a fault investigation
study and compliance with the
latest adopted edition of the
California Building Standards Code
to ensure that seismic hazards are
properly mitigated or avoided
entirely prior to development.

Refer to Section 3.5, Geology,
Soils, and Seismicity, for further
discussion.

Objective 9.1 Protect life, ensure public safety,
substantially reduce the damage to
and ensure the orderly evacuation
of building occupants following a
seismic event.

Consistent: The West Napa Fault
crosses the project site. This Draft
EIR requires mitigation measures
consisting of a fault investigation
study and compliance with the
latest adopted edition of the
California Building Standards Code
to protect life, ensure public
safety, and substantially reduce
damage to structures. Refer to
Section 3.5, Geology, Soils, and
Seismicity, for further discussion.

Policy 9.1.1 Promote the collection of relevant
data on fault location and the
history of fault displacement as a
basis for future refinement of fault
zone policies and development
standards. Particular attention
should be paid to the West Napa
Fault that is generally depicted in
Figure 9-1 and should be evaluated
in conjunction with proposed
development. Based on
predevelopment studies, limitations
on new development shall be
imposed if necessary in the
identified fault areas.

Consistent: The West Napa Fault
crosses the project site. This Draft
EIR requires mitigation measures
consisting of a fault investigation
study to determine to location of
the fault and identify appropriate
setbacks for project buildings. This
is consistent with the
requirements of this policy. Refer
to Section 3.5, Geology, Soils, and
Seismicity, for further discussion.
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Policy 9.1.2 Implement mandatory
development restrictions and
investigation requirements (by the
State, under the Alquist-Priolo Act,
or by the City) on that portion of
the West Napa Fault zone located
within American Canyon and its
Planning Area.

Consistent: The West Napa Fault
crosses the project site. This Draft
EIR requires mitigation measures
consisting of a fault investigation
study to determine to location of
the fault and identify appropriate
setbacks for project buildings in
accordance with the Alquist-Priolo
Act. This is consistent with the
requirements of this policy. Refer
to Section 3.5, Geology, Soils, and
Seismicity, for further discussion.

Policy 9.1.3 Require that any building intended
to have occupancy be located at
least 5O feet from either side of an
active or potentially active fault.

Refer to Section 3.5, Geology,
Soils, and Seismicity, for further
discussion.

Objective 9.2 Protect health and life safety, and
reduce the level of potential
property damage from the adverse
effects of strong seismic ground
shaking by implementing effective,
state-of-the-art standards for
seismic design of structures in the
City.

Consistent: This Draft EIR requires
compliance with the latest adopted
edition of the California Building
Standards Code to ensure that
strong seismic ground shaking
hazards are properly mitigated.

Refer to Section 3.5, Geology, Soils,
and Seismicity, for further
discussion.

Policy 9.2.1 Require that development be
designed in accordance with seismic
requirements of the Uniform
Building Code.

Consistent: This Draft EIR requires
compliance with the latest
adopted edition of the California
Building Standards Code seismic
design requirements. Refer to
Section 3.5, Geology, Soils, and
Seismicity, for further discussion.

Objective 9.3 Protect life and essential lifelines
(e.g., gas, electricity, water), reduce
the risk of property damage due to
liquefaction, and promote the
collection of more complete
information on liquefaction
susceptibility throughout the
Planning Area.

Consistent: The project site is
underlain by geologic units and
soils that would not be
susceptible to liquefaction. Refer
to Section 3.5, Geology, Soils, and
Seismicity, for further discussion.
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Policy 9.3.1 Avoid development in areas with
known liquefaction risk. If these
areas cannot be avoided, require a
qualified geologist, hydrologist, or
civil engineer to determine the
liquefaction potential at proposed
development sites.

Consistent: The project site is
underlain by geologic units and
soils that would not be
susceptible to liquefaction. Refer
to Section 3.5, Geology, Soils, and
Seismicity, for further discussion.

Objective 9.6 Minimize to the greatest extent
feasible the loss of life, serious
injuries, and major social and
economic disruption caused by the
collapse of, or severe damage to,
vulnerable structures (e.g.,
buildings, bridges, water storage
facilities, key railroad components)
resulting from an earthquake.

Consistent: Project structures and
infrastructure would be designed
and constructed in accordance with
the latest adopted edition of the
California Building Standard Code’s
seismic safety requirements.

Adherence to these standards
would minimize potential exposure
to disruptions associated with
earthquakes.

Flood
Hazards
Goal 10 Protect the lives and property of
American Canyon’s residents and
visitors from flood hazards.

Consistent: The developable
portions of the project site are
located outside of a 100-year
flood hazard area. Therefore, the
proposed project’s uses (including
employees) would not be exposed
to flood hazards.

Objective 10.1 Design both new development and
redevelopment projects in a
manner that minimizes hazards
associated with flooding.

Policy 10.1.1 Retain and enhance natural
watercourses, including perennial
and intermittent streams, as the
City’s primary flood control
channels whenever feasible.

Consistent: The western portion
of the project site, which contains
areas located within a 100-year
flood hazard area, is protected
within the existing Wetland
Preserve. This is consistent with
the policy of retaining and
enhancing natural watercourses
as the City’s primary flood control
channels.

Policy 10.1.4 Ensure that stormwater drainage is
designed for peak flow conditions.

Consistent: The proposed
project’s storm drainage system
would be designed in accordance
with the City’s peak flow design
standards.
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Policy 10.1.5 Prohibit the development of
structures designed for human
occupancy within the 100-year
floodplain, unless flood hazards are
adequately mitigated. Mitigation can
be accomplished by building
foundations a minimum of one (1)
foot above the 100-year flood
elevation, or by other means
approved by the City Engineer (see
Figure 10-1).

Consistent: The developable
portions of the project site are
located outside of a 100-year
flood hazard area. Therefore, the
proposed project’s structures
would not be located within the
100-year floodplain.

Policy 10.1.12 Require that proposed developments
within the 100-year floodplain
submit information regarding the
flood hazard prepared by a qualified
Civil Engineer or Hydrologist.

Consistent: The developable
portions of the project site are
located outside of a 100-year flood
hazard area. The western portion
of the project site, which contains
areas located within a 100-year
flood hazard area, is located within
the proposed Wetland Preserve.

Policy 10.1.13 Require that proposed
developments within the 100-year
floodplain submit plans to
adequately mitigate flood hazards
and demonstrate that such
improvements will not create or
increase downstream or upstream
flood hazards.

Consistent: The developable
portions of the project site are
located outside of a 100-year
flood hazard area. The western
portion of the project site, which
contains areas located within a
100-year flood hazard area, is
located within the proposed
Wetland Preserve.

Noise Goal 11 Ensure that American Canyon’s
existing and future residents,
employees and employers, as well as
visitors to the City, are protected
from the adverse human health and
environmental impacts of excessive
noise levels created by stationary and
ambient (intrusive) noise sources and
conditions. Take all necessary and
appropriate action to avoid or
mitigate the detrimental effects of
such excessive noise on the
community.

Consistent: This Draft EIR includes
an evaluation of project-related
noise impacts. Mitigation is
proposed as necessary to achieve
acceptable noise levels. Refer to
Section 3.10, Noise, for further
discussion.

Objective 11.1 Control both ambient and
stationary (intrusive) noise
conditions and impacts that may
occur in American Canyon. Maintain
base line information regarding
ambient and stationary noise
sources within the community.

Consistent: This Draft EIR includes
an evaluation of project-related
noise impacts including ambient
and stationary noise sources. Refer
to Section 3.10, Noise, for further
discussion.
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Policy 11.1.1 Promote noise compatible land use
relationships by implementing the
noise standards identified in Figure
11-2, to be utilized for design
purposes in new development and
for establishing a program to
attenuate existing noise problems.

Consistent: This Draft EIR includes
an evaluation of project-related
noise impacts and assesses noise
levels against the standards
identified in Figure 11-2 to
determine whether significant
impacts would occur. Mitigation is
proposed as necessary to achieve
acceptable noise levels. Refer to
Section 3.10, Noise, for further
discussion.

Policy 11.1.2 Monitor and update available data
regarding the community’s ambient
and stationary noise levels.

Consistent: This Draft EIR includes
an evaluation of project-related
noise impacts. As part of this
analysis, noise measurements
were taken in the project vicinity.

This is consistent with the policy of
monitoring and updating noise
level data. Refer to Section 3.10,
Noise, for further discussion.

Objective 11.2 Protect residents, employees, and
visitors to the community from
excessive noise exposure. If
possible, mitigate the adverse
impacts of existing or unavoidable
excessive noise on these same
groups.

Policy 11.2.1 Require that new development for
locations in which the exterior or
interior noise levels indicated in
Figure 11-2 are likely to be
exceeded, submit a noise
attenuation study prepared by a
qualified acoustical engineer in
order to determine appropriate
mitigation measures.

Consistent: The project site is not
located in any “Sensitive Noise
Areas” depicted on Figure 11-2.

Regardless, a noise analysis was
prepared for the proposed project
and mitigation is identified as
necessary. Refer to Section 3.10,
Noise, for further discussion.

Policy 11.2.4 Require that new industrial,
commercial and related land uses,
or the expansion of these existing
land uses, demonstrate that they
would not directly cause ambient
noise levels to exceed an exterior
Ldn of 65 dB(A) in areas containing
housing, schools, health care
facilities, or other “noise-sensitive”
land uses. Additionally, require that
potentially significant noise
generators, including uses such as
Consistent: The project site is
located in the Green Island
Business Park, which contains
noise-tolerant nonresidential
uses. There are no nearby noisesensitive receptors. The proposed project would not have the
potential to increase ambient
noise levels above 65 dBA Ldn.
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night clubs that cause sporadic
noise intensities, submit noise
analyses prepared by an acoustical
expert that include specific
recommendations for mitigation
when: a) the project is located in
close proximity to noise-sensitive
land uses or land that is planned for
noise-sensitive land uses, or b) the
proposed noise source could violate
the noise provisions of the General
Plan or City Noise ordinance.

Objective 11.3 Minimize the adverse impacts of
traffic-generated noise on
residential and other “noise
sensitive” uses as depicted on
Figure 11-5.

Consistent: The project site is
located in the Green Island
Business Park and there are no
noise-sensitive uses within 1,000
feet of the project site. Moreover,
trucks traveling to and from the
project site would use Green Island
Road or Devlin Road and South
Kelly Road to reach SR-29 and SR12, which would avoid areas designated for residential use by
the General Plan.

Policy 11.3.1 Minimize motor vehicle noise
impacts from streets and highways
through proper route location and
sensitive roadway design by
employing the following strategies:
a. Consider the impacts of truck
routes, the effects of a variety of
truck traffic, and future motor
vehicle volumes on noise levels
adjacent to master planned
roadways when improvements to
the circulation system are planned.
b. Mitigate traffic volumes and
vehicle speed through residential
neighborhoods.
c. Work closely with the State of
California Department of
Transportation (Caltrans) in the
early stages of highway
improvements and design
modifications to ensure that
proper consideration is given to
potential noise impacts on the
City.

Consistent: The project site is
located in the Green Island
Business Park and trucks would
use Green Island Road or Devlin
Road and South Kelly Road to
reach SR-29 and SR-12. This
routing would avoid residential
areas and, therefore, would be
consistent with this policy.
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Policy 11.3.2 Require that all new nonresidential
development design and configure
on-site ingress and egress points to
divert traffic (and its resultant
noise) away from “noise-sensitive”
land uses to the greatest degree
practicable.

Consistent: The project site is
located in the Green Island
Business Park, which contains
noise-tolerant nonresidential
uses. There are no nearby noisesensitive receptors. Thus, the proposed project would not need
to configure ingress and egress
points to divert traffic away from
“noise-sensitive” land uses.

Policy 11.4.1 Restrict the development of uses
located within the 65 CNEL contour
of Napa Airport to industrial,
agricultural, or other open space
uses (see Figure 11-5).

Consistent: A portion of the project
site is located within the 65 dBA
CNEL contour of Napa County
Airport. The proposed project
consists of industrial uses and the
site includes an existing wetland
preserve use, which are “normally
acceptable” land use activities
within this noise contour.

Policy 11.4.2 Require that development in the
vicinity of Napa Airport comply with
the noise standards contained in
the Airport Land Use Compatibility
Plan (ALUCP).

Consistent: The Napa County
ALUCP identifies aviation noise
levels between 60 and 65 dBA
CNEL as “normally acceptable” for
warehouse uses. As such, the
proposed project would be
consistent with the ALUCP noise
standards.

Objective 11.5 Minimize noise spillover or
encroachment from commercial
and industrial land uses into
adjoining residential neighborhoods
or “noise-sensitive” uses.

Consistent: The project site is
located in the Green Island
Business Park, which contains
noise-tolerant nonresidential
uses. As such, the proposed
project would not have the
potential to cause “spillover”
noise into adjoining residential
neighborhoods or “noisesensitive” uses.

Objective 11.7 Minimize the impacts of
construction noise on adjacent
uses.

Consistent: The project site is
located in the Green Island
Business Park, which contains
noise-tolerant nonresidential uses.

As such, surrounding land uses
would not experience intrusive
noise levels during project-related
construction activities.

Source: City of American Canyon 2021; FirstCarbon Solutions(FCS) 2021. 515
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Less than significant impact.

Mitigation Measures
No mitigation is necessary.

Level of Significance After Mitigation
Less than significant impact.

Municipal Code Consistency
Impact LU-2: The proposed project would not conflict with the applicable provisions of the American Canyon Municipal Code.

Impact Analysis
The proposed project would consist of the development of up to 2.4 million square feet of high-cube warehouse on 163 acres. The remaining 45 acres would be preserved as wetlands.

The Phase 1 end uses would be consistent with the types of permitted uses set forth in the Zoning Ordinance for the General Industrial zoning district. Additionally, Phase 1 would have a 0.26 FAR and would be within the Zoning Ordinance’s allowable FAR of 0.50 for labor-intensive uses and FAR of

0.70 for low labor uses. The proposed high-cube warehouses would have 36 feet clear height and, thus, be within the 40-foot height limit set by the Zoning Ordinance. Impacts would be less than significant.

Phase 2
Phase 2, the 113.1-acre area west of Devlin Road, is conceptually proposed for the remaining 1.3 million square feet of high-cube warehouse.

The Phase 2 end uses would be consistent with the types of permitted uses set forth in the Zoning Ordinance for the General Industrial zoning district. Additionally, Phase 2 would have a 0.26 FAR and would be within the General Plan’s allowable FAR of 0.50 for labor-intensive uses and FAR of 0.70 for low labor uses. Impacts would be less than significant.

Level of Significance Before Mitigation
Less than significant impact.
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No mitigation is necessary.

Level of Significance After Mitigation
Less than significant impact.

Airport Land Use Compatibility Plan Consistency
Impact LU-3: The proposed project may conflict with the applicable provisions of the Napa County Airport Land Use Compatibility Plan.

Impact Analysis
Phases 1 and 2
Airport Land Use Compatibility Review
The project site falls within the Napa County Airport Land Use Compatibility Plan (ALUCP) Area.

The (ALUCP) establishes policies and compatibility zones addressing four key focus areas: noise, safety, airspace protection, and overflight. The (ALUCP) defines five compatibility zones that address the key focus areas in a composite manner:
• Zone A encompasses the Runway Protection Zones and areas lateral to the runway. • Zone B includes the approach/departure zone where aircraft will be below 100 feet above ground. • Zone C is defined by the extended approach/departure zone where aircraft will be below 300 feet above ground level.
• Zone D encompasses the common traffic pattern. These areas are routinely overflown by aircraft.
• Zone E includes the other airport environs and defines the Airport’s influence area and ALUC’s planning area.

The project site falls entirely within Zone D. Zone D is characterized by moderate risk, frequent noise intrusion and routine overflights below 1,000 feet above ground level. The ALUCP indicates that warehousing, low intensity light industrial uses and office uses are normally acceptable uses. ALUCP Table 3-2, Airport Vicinity Land Use Compatibility Criteria, establishes maximum densities for indoor and outdoor uses. Within Zone D, indoor uses are limited to no more than 100 people per net acre.

Uses with an outdoor component can have up to 150 per net acre. The ALUCP does not limit the number of people that can be clustered in any one acre of the parcel within Zone D. Net acreage is defined as the total site area inclusive of parking areas and landscaping, less the area dedicated for streets.

Additionally, the ALUCP prohibits residential uses and uses posing hazards to flight. Hazards to flight include objects that penetrate FAR Part 77 airspace surfaces, uses that would attract large numbers of birds, and uses that would create smoke, glare, distracting lights, or electronic interference. 517
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-09 Land Use.docx The analysis that follows assesses the ALUCP density and airspace criteria that relate to the project site.

Maximum Density
The proposed project includes several buildings that would facilitate development of industrial uses, including warehousing, manufacturing, and general office uses. These land uses are generally consistent with ALUCP criteria, provided that the uses do not attract large concentrations of people.

The ALUCP sets forth maximum density criterion of 100 people per net acre for Zone D. The ALUCP identifies three methods for calculating density: (1) parking ordinance; (2) maximum occupancy; and (3) other methodologies in cases where density cannot be reasonably estimated based upon parking or square footage. The ALUCP identifies the parking ordinance methodology as the preferred method for calculating density.

In this case, the parking ordinance methodology would not be appropriate because parking stalls would be used for trailer storage,
1 which provides no insight into the maximum number of persons on-site at any given time. Thus, it is not possible to meaningfully calculate density using the parking ordinance methodology.

The maximum occupancy methodology is most appropriate because it is based on typical Building Code occupancy limits, which can be calculated based on the known project characteristics. Because the ancillary office space within each building is the most intense use, it has been broken out separately from the warehouse use.
2 Table 3.9-3 summarizes the maximum occupancy calculation.

Table 3.9-3: Maximum Occupancy Calculation
Use Maximum Square Feet
Maximum Floor Area Allowances per Occupant
(California Building Code)
Density
(Persons)
Warehouse 2,304,000 1 person/500 square feet (Gross) 4,608 Ancillary Office 96,000 1 person/100 square feet (Gross) 960 Total 2,400,000 – 5,568
Adjustment for Observed Occupancy (50 percent) 5,568 x .5 Adjusted Density 2,784
Notes:

Maximum Floor Area Allowances Per Occupant values obtained from California Airport Planning Land Use Handbook (Exhibit G1).
50 percent reduction applied to subtotal to reflect actual observed occupancy rates in accordance with California Airport Planning Land Use Handbook Guidance (Exhibit G2).

Source: FirstCarbon Solutions (FCS) 2021.
1 Warehouse end users typically have provisions in their contractual agreements with trucking companies that require empty trailers to be left on-site when loaded trailers are picked up. 2 Phase 1 is proposed for two warehouse buildings. Phase 2 was assumed to have as many as four warehouse buildings. Thus, 16,000 square feet of ancillary office per warehouse x 6 warehouses = 96,000 square feet. 518
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Table 3.9-4: Maximum Site Density Calculation
Maximum Site Density
(≤ 100 persons/acre)
Calculation Density Maximum Allowable Density
2,784 persons ÷ 163 acres 17.1 persons/acre 100.0 persons/acre Notes:

Calculations follow guidance provided in Exhibit G2 of California Airport Planning Land Use Handbook.

Source: FirstCarbon Solutions (FCS) 2021.

Wildlife Attractants
Approximately 45 acres of the project site would be permanently preserved as a Wetland Preserve.

This area contains wetlands that currently attract wildlife (e.g., avian species). Avian species are considered potential hazards to aviation activities due to the potential for bird strikes. The two aspects of the proposed project that have the greatest potential for creating aviation safety hazards are the open space area and the stormwater basins.

The open space area would represent the continuation of an existing condition. The proposed project would create new wetland features to offset those impacted as result of the proposed project. However, it would not substantially increase the bird attractant potential because the new compensatory wetlands represent a small portion of the total open space area. Thus, the proposed project would not introduce new aviation hazards in this respect.

The proposed stormwater basins would be designed to drain out within 48 hours of a 10-year storm event. This rapid drainage rate would minimize the amount of time the basins would hold standing water, which, in turn, would reduce their avian attractant attributes. Additionally, standing water would be prevalent in many areas in the project vicinity during and immediately after a storm event; thus, the basins would not represent a greater attractant in this respect. Moreover, the basins are not intended to hold water for extended periods or to be used as an aesthetic water feature.

Furthermore, the proposed project would result in an approximately 163-acre reduction in avian foraging habitat as a result of the development of the proposed structures and infrastructure. This would further minimize the avian attractant attributes of the project site relative to existing conditions.

Overall, the proposed project would not increase the avian attractant attributes of the project site or nearby areas under the Napa County Airport flight path compared to existing conditions.

The ALUCP indicates that projects that have the potential to attract wildlife are required to prepare a Wildlife Hazards Assessment. Accordingly, Mitigation Measure LU-3 requires the preparation of such an assessment and implementation of the recommendations into the design of the open space area. 519
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Light, Glare, Dust, Steam, and Other Aviation Hazards
The ALUCP Policy 3.3.5 states the following:

Policy 3.3.5: Land uses which may produce hazards to aircraft in flight shall not be permitted within any airport's planning area. Specific characteristics to be avoided include: (1) glare or distracting lights which could be mistaken for airport lights; (2) sources of dust, steam, or smoke which may impair pilot visibility; (3) sources of electrical interference with aircraft communications or navigation; and (4) any use which may attract large flocks of birds, especially landfills and certain agricultural uses.

The proposed project’s end uses include high-cube warehouse and ancillary office, which are considered normally acceptable by the ALUCP as long as they do not create hazards. In this case, MM AES-3 requires all exterior lighting to use full cut-off fixtures and be directed downward to prevent interference with Napa County Airport operations. Moreover, the proposed project would reduce the amount of natural vegetation on the project site by 163 acres. The proposed project also would include landscaping and on-site drainage facilities that would be designed and managed to discourage wildlife use of the site. MM LU-3 requires the applicant to retain a qualified Biologist to prepare a wildlife hazard assessment that would identify measures to reduce the bird attractant potential of the wetland area, consistent with the ALUCP’s policies. Collectively, the implementation of these two mitigation measures would ensure that the proposed project would not create hazards to aviation. Impacts would be less than significant.

Level of Significance Before Mitigation
Potentially significant impact.

Mitigation Measures
Implement Mitigation Measure AES-3 and:

MM LU-3 Prior to issuance of grading permits, the applicant shall retain a qualified Biologist to assess potential wildlife hazards to aviation. The assessment shall evaluate the characteristics of the emergent wetlands, drainages, other potential wildlife attractant features (i.e., ponded water) located within the open space area and identify management practices (e.g., storm drainage, vegetation, etc.) to prevent the creation of attractants for large flocks or birds or other wildlife species that may present safety hazards to aviation activities. As part of the assessment, the applicant shall consult with Napa County Airport and Napa County Airport Land Use Commission (ALUC) representatives, as appropriate, regarding findings and recommendations. The applicant shall submit a report to the City of American Canyon prepared by a qualified Biologist that confirms the wildlife hazard assessment’s findings and recommendations are incorporated into the design of the open space preserve.

Level of Significance After Mitigation
Less than significant impact.
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3.10 - Noise

3.10.1 - Introduction
This section describes the existing noise setting and potential effects from project implementation on the site and its surrounding area. Descriptions and analysis in this section are based on noise modeling performed by FirstCarbon Solutions (FCS). The noise modeling output is included in this Draft Environmental Impact Report (Draft EIR) as Appendix G.

3.10.2 - Environmental Setting
Characteristics of Noise
Noise is generally defined as unwanted or objectionable sound. Sound becomes unwanted when it interferes with normal activities, when it causes actual physical harm, or when it has adverse effects on health. The effects of noise on people can include general annoyance, interference with speech communication, sleep disturbance, and, in the extreme, hearing impairment. Noise effects can be caused by pitch or loudness. Pitch is the number of complete vibrations or cycles per second of a wave that result in the range of tone from high to low; higher-pitched sounds are louder to humans than lower-pitched sounds. Loudness is the intensity or amplitude of sound.

Sound is produced by the vibration of sound pressure waves in the air. Sound pressure levels are used to measure the intensity of sound and are described in terms of decibels. The decibel (dB) is a logarithmic unit that expresses the ratio of the sound pressure level being measured to a standard reference level. The 0 point on the dB scale is based on the lowest sound level that the healthy, unimpaired human ear can detect. Changes of 3 dB or less are only perceptible in laboratory environments. Audible increases in noise levels generally refer to a change of 3 dB or more as this level has been found to be barely perceptible to the human ear in outdoor environments. Only audible changes in existing ambient or background noise levels are considered potentially significant.

The human ear is not equally sensitive to all frequencies within the audible sound spectrum, so sound pressure level measurements can be weighted to better represent frequency-based sensitivity of average healthy human hearing. One such specific “filtering” of sound is called “A-weighting.” Aweighted decibels (dBA) approximate the subjective response of the human ear to a broad frequency noise source by discriminating against very low and very high frequencies of the audible spectrum. They are adjusted to reflect only those frequencies that are audible to the human ear.

Because decibels are logarithmic units, they cannot be added or subtracted by ordinary arithmetic means. For example, if one noise source produces a noise level of 70 dB, the addition of another noise source with the same noise level would not produce 140 dB; rather, they would combine to produce a noise level of 73 dB.

Noise Descriptors
There are many ways to rate noise for various intervals, but an appropriate rating of ambient noise affecting humans also accounts for the annoying effects of sound. Equivalent continuous sound level (Leq) is the total sound energy of time-varying noise over a sample period. However, the predominant rating scales for human communities in the State of California are the Leq and Community Noise 521
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Other noise rating scales of importance when assessing the annoyance factor include the maximum noise level (Lmax), which is the highest exponential time-averaged sound level that occurs during a stated time period. The noise environments discussed in this analysis are specified in terms of maximum levels denoted by Lmax for short-term noise impacts. Lmax reflects peak operating conditions and addresses the annoying aspects of intermittent noise.

Noise Propagation
From the noise source to the receiver, noise changes both in level and frequency spectrum. The most obvious is the decrease in noise as the distance from the source increases. The manner in which noise reduces with distance depends on whether the source is a point or line source, as well as ground absorption, atmospheric conditions (wind, temperature gradients, and humidity) and refraction, and shielding by natural and manmade features. Sound from point sources, such as an air conditioning condenser, a piece of construction equipment, or an idling truck, radiates uniformly outward as it travels away from the source in a spherical pattern.

The attenuation, or sound drop-off rate, is dependent on the conditions of the land between the noise source and receiver. To account for this ground-effect attenuation (absorption), two types of site conditions are commonly used in noise models: soft-site and hard-site conditions. Soft-site conditions account for the sound propagation loss over natural surfaces such as normal earth and ground vegetation. For point sources, a drop-off rate of 7.5 dBA per each doubling of the distance (dBA/DD) is typically observed over soft ground with landscaping, as compared with a 6 dBA/DD drop-off rate over hard ground such as asphalt, concrete, stone, and very hard packed earth. For line sources, such as traffic noise on a roadway, a 4.5 dBA/DD is typically observed for soft-site conditions compared to the 3 dBA/DD drop-off rate for hard-site conditions. Table 3.10-1 briefly defines these measurement descriptors and other sound terminology used in this section.

Table 3.10-1: Sound Terminology
Term Definition
Sound A vibratory disturbance created by a vibrating object which, when transmitted by pressure waves through a
medium such as air, can be detected by a receiving
mechanism such as the human ear or a microphone.

Noise Sound that is loud, unpleasant, unexpected, or
otherwise undesirable.
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Ambient Noise The composite of noise from all sources near and far in a given environment.

Decibel (dB) A unitless measure of sound on a logarithmic scale, which represents the squared ratio of sound pressure
amplitude to a reference sound pressure. The reference
pressure is 20 micropascals, representing the threshold of human hearing (0 dB).

A-Weighted Decibel (dBA) An overall frequency-weighted sound level that approximates the frequency response of the human ear.

Equivalent Noise Level (Leq) The average sound energy occurring over a specified time period. In effect, Leq is the steady-state sound level that in a stated period would contain the same
acoustical energy as the time-varying sound that
actually occurs during the same period.

Maximum and Minimum Noise Levels (Lmax and Lmin) The maximum or minimum instantaneous sound level measured during a measurement period.

Day-Night Level (DNL or Ldn) The energy average of the A-weighted sound levels occurring during a 24-hour period, with 10 dB added to
the A-weighted sound levels occurring between 10 p.m.
and 7 a.m. (nighttime).

Community Noise Equivalent Level (CNEL) The energy average of the A-weighted sound levels occurring during a 24-hour period, with 5 dB added to
the A-weighted sound levels occurring between 7 p.m.
and 10 p.m. and 10 dB added to the A-weighted sound
levels occurring between 10 p.m. and 7 a.m.

Source: Data compiled by FirstCarbon Solutions (FCS) 2021.

Traffic Noise
The level of traffic noise depends on the three primary factors: (1) the volume of the traffic, (2) the speed of the traffic, and (3) the number of trucks in the flow of traffic. Generally, the loudness of traffic noise is increased by heavier traffic volumes, higher speeds, and greater number of trucks. Vehicle noise is a combination of the noise produced by the engine, exhaust, and tires. Because of the logarithmic nature of noise levels, a doubling of the traffic volume (assuming that the speed and truck mix do not change) results in a noise level increase of 3 dBA. Based on the Federal Highway Administration (FHWA) community noise assessment criteria, this change is “barely perceptible”; for reference, a doubling of perceived noise levels would require an increase of approximately 10 dBA. The truck mix on a given roadway also has an effect on community noise levels. As the number of heavy trucks increases and becomes a larger percentage of the vehicle mix, adjacent noise levels increase.

Stationary Noise
A stationary noise producer is any entity in a fixed location that emits noise. Examples of stationary noise sources include machinery, engines, energy production, and other mechanical or powered equipment and activities such as loading and unloading or public assembly that may occur at 523
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The effects of stationary noise depend on factors such as characteristics of the equipment and operations, distance and pathway between the generator and receptor, and weather. Stationary noise sources may be regulated at the point of manufacture (e.g., equipment or engines), with limitations on the hours of operation or with provision of intervening structures, barriers, or topography.

Construction activities are a common source of stationary noise. Construction period noise levels are higher than background ambient noise levels but cease once construction is complete. Construction is performed in discrete steps, each of which has its own mix of equipment and, consequently, its own noise characteristics. These various sequential phases would change the character of the noise generated on each construction site and, therefore, would change the noise levels as construction progresses. Despite the variety in the type and size of construction equipment, similarities in the dominant noise sources and patterns of operation allow construction-related noise ranges to be categorized by work phase. Table 3.10-2 shows typical noise levels of construction equipment as measured at a distance of 50 feet from the operating equipment.

Table 3.10-2: Typical Construction Equipment Maximum Noise Levels, Lmax Type of Equipment
Specification Maximum Sound Levels for Analysis
(dBA at 50 feet)
Impact Pile Driver 95
Auger Drill Rig 85
Vibratory Pile Driver 95
Jackhammers 85
Pneumatic Tools 85
Pumps 77
Scrapers 85
Cranes 85
Portable Generators 82
Rollers 85
Bulldozers 85
Tractors 84
Front-End Loaders 80
Backhoe 80
Excavators 85
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Specification Maximum Sound Levels for Analysis
(dBA at 50 feet)
Graders 85
Air Compressors 80
Dump Truck 84
Concrete Mixer Truck 85
Pickup Truck 55
Notes:
dBA = A-weighted decibel
Source: Federal Highway Administration (FHWA). 2006. Highway Construction Noise Handbook, August.

Noise from Multiple Sources
Because sound pressure levels in decibels are based on a logarithmic scale, they cannot be added or subtracted in the usual arithmetical way. Therefore, sound pressure levels in decibels are logarithmically added on an energy summation basis. In other words, adding a new noise source to an existing noise source, both producing noise at the same level, will not double the noise level.

Instead, if the difference between two noise sources is 10 dBA or more, the louder noise source will dominate and the resultant noise level will be equal to the noise level of the louder source. In general, if the difference between two noise sources is 0–1 dBA, the resultant noise level will be 3 dBA higher than the louder noise source, or both sources if they are equal. If the difference between two noise sources is 2–3 dBA, the resultant noise level will be 2 dBA above the louder noise source.

If the difference between two noise sources is 4–10 dBA, the resultant noise level will be 1 dBA higher than the louder noise source.

Characteristics of Vibration
Groundborne vibration consists of rapidly fluctuating motion through a solid medium, specifically the ground, which has an average motion of zero and in which the motion’s amplitude can be described in terms of displacement, velocity, or acceleration. The effects of groundborne vibration typically only cause a nuisance to people, but in extreme cases, excessive groundborne vibration has the potential to cause structural damage to buildings. Although groundborne vibration can be felt outdoors, it is typically only an annoyance to people indoors, where the associated effects of the shaking of a building can be notable. Groundborne noise is an effect of groundborne vibration and only exists indoors, since it is produced from noise radiated from the motion of the walls and floors of a room and may also consist of the rattling of windows or dishes on shelves.

Several different methods are used to quantify vibration amplitude such as the maximum instantaneous peak in the vibrations velocity, which is known as the peak particle velocity (PPV) or the root mean square (rms) amplitude of the vibration velocity. Because of the typically small amplitudes of vibrations, vibration velocity is often expressed in decibels—denoted as LV—and is based on the reference quantity of 1 microinch per second. To distinguish vibration levels from noise levels, the unit is written as “VdB.”
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Off-site sources that may produce perceptible vibrations are usually caused by construction equipment, steel-wheeled trains, and traffic on rough roads, while smooth roads rarely produce perceptible groundborne noise or vibration. Construction activities, such as blasting, pile driving, and operating heavy earthmoving equipment, are common sources of groundborne vibration. Construction vibration impacts on building structures are generally assessed in terms of PPV. Typical vibration source levels from construction equipment are shown in Table 3.10-3.
1 Table 3.10-3: Vibration Levels of Construction Equipment Construction Equipment
PPV at 25 Feet
(inches/second)
rms Velocity in Decibels (VdB)
at 25 Feet
Water Trucks 0.001 57
Scraper 0.002 58
Bulldozer—Small 0.003 58
Jackhammer 0.035 79
Concrete Mixer 0.046 81
Concrete Pump 0.046 81
Paver 0.046 81
Pickup Truck 0.046 81
Auger Drill Rig 0.051 82
Backhoe 0.051 82
Crane (Mobile) 0.051 82
Excavator 0.051 82
Grader 0.051 82
Loader 0.051 82
Loaded Trucks 0.076 86
Bulldozer—Large 0.089 87
Caisson Drilling 0.089 87
Vibratory Roller (small) 0.101 88
Compactor 0.138 90
Clam Shovel Drop 0.202 94
1 Federal Highway Administration (FHWA). 2006. Highway Construction Noise Handbook. August. 526
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PPV at 25 Feet
(inches/second)
rms Velocity in Decibels (VdB)
at 25 Feet
Vibratory Roller (large) 0.210 94
Pile Driver (impact-typical) 0.644 104
Pile Driver (impact-upper range) 1.518 112
Notes:

PPV = peak particle velocity
rms = root mean square
Source: Compilation of scientific and academic literature, generated by the Federal Transit Administration (FTA) and Federal Highway Administration (FHWA).

The propagation of groundborne vibration is not as simple to model as airborne noise. This is because noise in the air travels through a relatively uniform medium, while groundborne vibrations travel through the earth, which may contain significant geological differences. Factors that influence groundborne vibration include:
• Vibration source: Type of activity or equipment, such as impact or mobile, and depth of vibration source;
• Vibration path: Soil type, rock layers, soil layering, depth to water table, and frost depth; and • Vibration receiver: Foundation type, building construction, and acoustical absorption.

Among these factors that influence groundborne vibration, there are significant differences in the vibration characteristics when the source is underground compared to at the ground surface. In addition, soil conditions are known to have a strong influence on the levels of groundborne vibration. Among the most important factors are the stiffness and internal damping of the soil and the depth to bedrock. Vibration propagation is more efficient in stiff clay soils than in loose sandy soils, and shallow rock seems to concentrate the vibration energy close to the surface and can result in groundborne vibration problems at large distance from the source. Factors such as layering of the soil and depth to the water table can have significant effects on the propagation of groundborne vibration. Soft, loose, sandy soils tend to attenuate more vibration energy than hard, rocky materials.

Vibration propagation through groundwater is more efficient than through sandy soils. There are three main types of vibration propagation: surface, compression, and shear waves. Surface waves, or Rayleigh waves, travel along the ground’s surface. These waves carry most of their energy along an expanding circular wave front, similar to ripples produced by throwing a rock into a pool of water. Pwaves, or compression waves, are body waves that carry their energy along an expanding spherical wave front. The particle motion in these waves is longitudinal (i.e., in a “push-pull” fashion). P-waves are analogous to airborne sound waves. S-waves, or shear waves, are also body waves that carry energy along an expanding spherical wave front. However, unlike P-waves, the particle motion is transverse, or side-to-side, and perpendicular to the direction of propagation.

As vibration waves propagate from a source, the vibration energy decreases in a logarithmic nature and the vibration levels typically decrease by 6 VdB per doubling of the distance from the vibration source.

As stated above, this drop-off rate can vary greatly depending on the soil type, but it has been shown to be effective enough for screening purposes in order to identify potential vibration impacts that may 527
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PPV= PPVref * (25/D)^n (in/sec)
Where:

PPVref = reference measurement at 25 feet from vibration source D = distance from equipment to the receptor
n = vibration attenuation rate through ground
According to Section 7 of the Federal Transit Administration (FTA) Transit Noise and Vibration Impact Assessment Manual, an “n” value of 1.5 is recommended to calculate vibration propagation through typical soil conditions.2
Existing Noise Levels
The project site is located in the City of American Canyon, Napa County, California. The project site is bounded by industrial development in the Green Island Business Park (west), the Napa Logistics Park and Devlin Road (north), the Napa Branch Line railroad (east), and Green Island Road, a stone supply business, and a wine distribution warehouse (south). Napa County Airport is located approximately 1 mile north of the project site. The dominant noise sources in the project vicinity is traffic on local roadways in the project vicinity and railroad and airport activity.

Existing traffic noise levels along selected roadway segments in the project vicinity were modeled using the FHWA Traffic Noise Prediction Model (FHWA-RD-77-108). The daily traffic volumes were obtained from the traffic analysis prepared for the proposed project by W-Trans. 3 The traffic volumes
described here correspond to the existing without project conditions traffic scenario as described in the transportation analysis. The model inputs and outputs—including the 60 dBA, 65 dBA, and 70 dBA CNEL noise contour distances—are provided in the Appendix G of this document. A summary of the modeling results is shown in Table 3.10-4.

The results show that traffic noise levels along Green Island Road adjacent to the project site range up to 62 dBA Ldn. The project’s nearest façade is located over 960 feet west of the centerline of State Route (SR) 29. At this distance traffic noise levels on SR-29 would attenuate to below 52 dBA Ldn.

Therefore, the dominant noise source on the project site would be traffic noise on Green Island Road.

Table 3.10-4: Existing Traffic Noise Levels
Roadway Segment
Approximate
ADT
Centerline to
70 Ldn (feet)
Centerline to
65 Ldn (feet)
Centerline to
60 Ldn (feet)
Ldn (dBA)
50 feet from
Centerline of
Outermost Lane
Paoli Loop Road–south of Green
Island Road
3,000 < 50 < 50 55 59.9
2 Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual. September. 3 W-Trans. 2021. Traffic Impact Study for the Giovannoni Logistics Center. July. 528
City of American Canyon—Giovannoni Logistics Center Project Draft EIR Noise
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-10 Noise.docx Roadway Segment
Approximate
ADT
Centerline to
70 Ldn (feet)
Centerline to
65 Ldn (feet)
Centerline to
60 Ldn (feet)
Ldn (dBA)
50 feet from
Centerline of
Outermost Lane
Green Island Road–Paoli Loop
Road to future Devlin Road
4,800 < 50 < 50 76 62.0
Green Island Road–west of future
Devlin Road
4,800 < 50 < 50 76 62.0
South Kelly Road–SR-29 to Devlin
Road
1,400 < 50 < 50 < 50 56.6
SR-29–South Kelly Road to Green
Island Road
30,900 128 273 586 73.8
Notes:

ADT = Average Daily Traffic
Ldn = day/night average sound level
dBA = A-weighted decibel 1 The ADT values are calculated based on the PM peak-hour traffic volumes multiplied by a factor of 10. 2 Modeling results do not take into account mitigating features such as topography, vegetative screening, fencing, building design, or structure screening. Rather, they assume a worst-case scenario of having a direct line of site on flat terrain.

Source: FirstCarbon Solutions (FCS) 2021.

3.10.3 - Regulatory Framework
Federal
Noise Control Act
The adverse impact of noise was officially recognized by the federal government in the Noise Control Act of 1972, which serves three purposes:
• Promulgating noise emission standards for interstate commerce • Assisting state and local abatement efforts
• Promoting noise education and research
The Federal Office of Noise Abatement and Control (ONAC) was initially tasked with implementing the Noise Control Act. However, the ONAC has since been eliminated, leaving the development of federal noise policies and programs to other federal agencies and interagency committees.

Among the agencies now regulating noise are the Occupational Safety and Health Administration (OSHA), which limits noise exposure of workers to 90 dB Leq or less for 8 continuous hours or 105 dB Leq or less for 1 continuous hour; the United States Department of Transportation (USDOT), which assumed a significant role in noise control through its various operating agencies; and the Federal Aviation Administration (FAA), which regulates noise of aircraft and airports. Surface transportation system noise is regulated by a host of agencies, including the FTA. Transit noise is regulated by the federal Urban Mass Transit Administration, while freeways that are part of the interstate highway system are regulated by the FHWA. Finally, the federal government actively advocates that local jurisdictions use their land use regulatory authority to arrange new development in such a way that “noise-sensitive” uses are either prohibited from being sited adjacent to a highway, or alternatively, that developments are planned and 529
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Since the federal government has preempted the setting of standards for noise levels that can be emitted by transportation sources, local jurisdictions are limited to regulating the noise generated by the transportation system through nuisance abatement ordinances and land use planning.

Federal Transit Administration Standards and Guidelines FTA has established industry accepted standards for vibration impact criteria and impact assessment.

These guidelines are published in its Transit Noise and Vibration Impact Assessment Manual.4 The FTA guidelines include thresholds for construction vibration impacts for various structural categories as shown in Table 3.10-5.

Table 3.10-5: Federal Transit Administration Construction Vibration Impact Criteria Building Category PPV (in/sec) Approximate VdB
I. Reinforced-Concrete, Steel, or Timber (no plaster) 0.5 102 II. Engineered Concrete and Masonry (no plaster) 0.3 98 III. Non-engineered Timber and Masonry Buildings 0.2 94 IV. Buildings Extremely Susceptible to Vibration Damage 0.12 90 Notes:

VdB = vibration measured as root mean square (rms) velocity in decibels of 1 microinch-inch per second PPV = peak particle velocity
Source: Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual. September.

State
California General Plan Guidelines
Government Code Section 65302 mandates that the legislative body of each county and city in California adopt a noise element as part of its comprehensive general plan. The Governor’s Office of Planning and Research (OPR) has issued and periodically updated advisory General Plan Guidelines that provide suggestions regarding how agencies may want to comply with this statutory requirement. The latest version of the General Plan Guidelines was issued in 2020. It contains an Appendix (D) entitled, Noise Element Guidelines, which were developed in 1976 by the former Department of Health Services Office of Noise Control pursuant to former Health and Safety Code section 46050.1. These Guidelines represent “an additional resource that local governments may consult in addition to this chapter to develop noise elements” (OPR, General Plan Guidelines, p. 130 [2020]). One significant model is the “Land Use Category and Community Noise Exposure Matrix,” 4 Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual. September. 530
City of American Canyon—Giovannoni Logistics Center Project Draft EIR Noise
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The Noise Element Guidelines rank noise/land use compatibility in terms of normally acceptable, conditionally acceptable, normally unacceptable, and clearly unacceptable (Noise Element Guidelines, Figure 2, p. 374). The project is also subject to review under the State of California Environmental Quality Act (CEQA). Appendix G of the CEQA Guidelines provides questions relating to potential noise impacts that can be used in the formulation of impact thresholds for potential noise and vibration impacts. The City of American Canyon has developed its own CEQA thresholds, which are described in the local regulatory section below.

California Building Standards Code
The State of California has established regulations that help prevent adverse impacts to occupants of buildings located near noise sources. Referred to as the “State Noise Insulation Standard,” it requires buildings to meet performance standards through design and/or building materials that would offset any noise source in the vicinity of the receptor. State regulations include requirements for the construction of new hotels, motels, apartment houses, and dwellings other than detached singlefamily dwellings that are intended to limit the extent of noise transmitted into habitable spaces.

These requirements are found in the California Code of Regulations, Title 24 (known as the Building Standards Administrative Code), Part 2 (known as the California Building Code), Appendix Chapters 12 and 12A. For limiting noise transmitted between adjacent dwelling units, the noise insulation standards specify the extent to which walls, doors, and floor-ceiling assemblies must block or absorb sound. For limiting noise from exterior noise sources, the noise insulation standards set an interior standard of 45 dBA CNEL in any habitable room with all doors and windows closed. In addition, the standards require preparation of an acoustical analysis demonstrating the manner in which dwelling units have been designed to meet this interior standard, where such units are proposed in an area with exterior noise levels greater than 60 dBA CNEL. Title 24 standards are typically enforced by local jurisdictions through the building permit application process.

Local
Since the state and federal government have preempted the setting of standards for noise levels that can be emitted by transportation sources, the City is restricted to regulating the noise generated by the transportation system through nuisance abatement ordinances and land use planning. The applicable sections of the General Plan6 and Municipal Code7 are stated below.

City of American Canyon
General Plan
The City of American Canyon General Plan sets forth the following goal of ensuring that American Canyon’s existing and future residents, employees and employers, as well as visitors to the City, are protected from the adverse human health and environmental impacts of excessive noise levels 5 Governor’s Office of Planning and Research. Noise Element Guidelines, Appendix D, Figure 2. 2020. Website:
https://opr.ca.gov/planning/general-plan/guidelines.html. Accessed June 29, 2021. 6 City of American Canyon. Noise Element. Accessed June 29th, 2020. Website:
https://www.cityofamericancanyon.org/government/community-development/planning-zoning/general-plan-update. 7 American Canyon Municipal Code. Community Noise. Accessed June 29, 2021. Website: https://qcode.us/codes/americancanyon/. 531
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3.10-12 FirstCarbon Solutions
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Objective 11.1 Control both ambient and stationary (intrusive) noise conditions and impacts that may occur in American Canyon. Maintain base line information regarding ambient and stationary noise sources within the community.

Policies
Policy 11.1.1 Promote noise-compatible land use relationships by implementing the noise standards identified in Figure 11-2 [of the General Plan], to be utilized for design purposes in new development and for establishing a program to attenuate existing noise problems.

Policy 11.1.2 Monitor and update available data regarding the community’s ambient and stationary noise levels.

Objective 11.2 Protect residents, employees, and visitors to the community from excessive noise exposure. If possible, mitigate the adverse impacts of existing or unavoidable excessive noise on these same groups.

Policies
Policy 11.2.1 Require that new development for locations in which the exterior or interior noise levels indicated in Figure 11-2 [of the General Plan] are likely to be exceeded, submit a noise attenuation study prepared by a qualified acoustical engineer in order to determine appropriate mitigation measures.

Policy 11.2.4 Require that new industrial, commercial, and related land uses, or the expansion of these existing land uses, demonstrate that they would not directly cause ambient noise levels to exceed an exterior Ldn of 65 dB(A) in areas containing housing, schools, health care facilities, or other “noise-sensitive” land uses. Additionally, require that potentially significant noise generators, including uses such as night clubs that cause sporadic noise intensities, submit noise analyses prepared by an acoustical expert that include specific recommendations for mitigation when: a) the project is located in close proximity to noise-sensitive land uses or land that is planned for noise-sensitive land uses, or b) the proposed noise source could violate the noise provisions of the General Plan or City Noise Ordinance.

Objective 11.3 Minimize the adverse impacts of traffic-generated noise on residential and other “noise-sensitive” uses as depicted on Figure 11-5 [of the General Plan]. 532
City of American Canyon—Giovannoni Logistics Center Project Draft EIR Noise
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Policy 11.3.1 Minimize motor vehicle noise impacts from streets and highways through proper route location and sensitive roadway design by employing the following strategies:
a. Consider the impacts of truck routes, the effects of a variety of truck traffic, and future motor vehicle volumes on noise levels adjacent to master planned roadways when improvements to the circulation system are planned. b. Mitigate traffic volumes and vehicle speed through residential neighborhoods. c. Work closely with the State of California Department of Transportation (Caltrans) in the early stages of highway improvements and design modifications to ensure that proper consideration is given to potential noise impacts on the City.

Policy 11.3.2 Require that all new nonresidential development design and configure on-site ingress and egress points to divert traffic (and its resultant noise) away from “noisesensitive” land uses to the greatest degree practicable.

Policy 11.4.1 Restrict the development of uses located within the 65 CNEL contour of Napa Airport to industrial, agricultural, or other open space uses (see Figure 11-5 [of the General Plan]).

Policy 11.4.1 Require that development in the vicinity of Napa Airport comply with the noise standards contained in the Airport Land Use Compatibility Plan (ALUP).

Objective 11.5 Minimize noise spillover or encroachment from commercial and industrial land uses into adjoining residential neighborhoods or “noise-sensitive” uses.

Objective 11.7 Minimize the impacts of construction noise on adjacent uses.

Municipal Code
The City of American Canyon General Plan establishes an exterior noise level criterion of 50 dBA in residential single or double and 55 in residential multiple land uses from 10:00 p.m. to 7:00 a.m. and 60 dBA for all residential land uses from 7:00 a.m. to 10:00 p.m. within outdoor activity areas of residential land uses. Additionally, the City requires that cumulative noise exposure from exterior noise sources within noise-sensitive dwellings not exceed 55 dBA from 10:00 p.m. to 7:00 a.m. and 60 dBA from 7:00 a.m. to 10:00 p.m. The City establishes different exterior noise limits for construction noise impacts for residential land uses to be 75 dBA from 7:00 a.m. to 7:00 p.m. and 60 dBA from 7:00 p.m. to 7:00 a.m.

3.10.4 - Methodology
Noise Assessment
Construction Noise Analysis Methodology
A worst-case scenario was analyzed assuming each piece of modeled equipment would operate simultaneously at the nearest reasonable locations to the closest noise-sensitive receptor for the loudest phase of construction. Noise emission levels recommended by FHWA’s Highway Construction Noise Handbook were used to ascertain the noise generated by specific types of construction 533
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3.10-14 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-10 Noise.docx equipment. The construction noise impact was evaluated in terms of maximum levels (Lmax). Analysis requirements were based on the sensitivity of nearby receptors and the Noise Ordinance specifications.

Traffic Noise Modeling Methodology
The FHWA highway traffic noise prediction model (FHWA-RD-77-108) was used to evaluate trafficrelated noise conditions in the vicinity of the project site. Traffic data used in the model was obtained from the traffic impact analysis prepared for this EIR by W-Trans. The resultant noise levels were weighted and summed over a 24-hour period in order to determine the Ldn values. The FHWARD-77-108 Model arrives at a predicted noise level through a series of adjustments to the reference energy mean emission level. Adjustments are then made to the reference energy mean emission level to account for the roadway active width (i.e., the distance between the center of the outermost travel lanes on each side of the roadway); the total Average Daily Traffic (ADT); the percentage of ADT that flows during the day, evening, and night; the travel speed; the vehicle mix on the roadway; a percentage of the volume of automobiles, medium trucks, and heavy trucks; the roadway grade; the angle of view of the observer exposed to the roadway; and the site conditions (“hard” or “soft”) as they relate to the absorption of the ground, pavement, or landscaping.

The level of traffic noise depends on the three primary factors: (1) the volume of the traffic, (2) the speed of the traffic, and (3) the number of trucks in the flow of traffic. Generally, the loudness of traffic noise is increased by heavier traffic volumes, higher speeds, and greater number of trucks.

Vehicle noise is a combination of the noise produced by the engine, exhaust, and tires. Because of the logarithmic nature of traffic noise levels, a doubling of the traffic volume (assuming that the speed and truck mix do not change) results in a noise level increase of 3 dBA. Based on the FHWA community noise assessment criteria, this change is considered “barely perceptible.” The model analyzed the noise impacts from the nearby roadways onto the project vicinity, which consists of the area that has the potential of being impacted from the on-site noise sources as well as the project-generated traffic on the nearby roadways. The roadways were analyzed based on a single-lane-equivalent noise source combining both directions of travel. A single-lane-equivalent noise source is when the vehicular traffic from all lanes is combined into a theoretical single-lane that has a width equal to the distance between the two outside lanes of a roadway, which provides almost identical results to analyzing each lane separately where elevation changes are minimal. The modeling assumes a direct line of sight to the roadway and flat terrain conditions.

Stationary Noise Source Analysis Methodology
The proposed project would generate noise from parking lot activities, new exterior mechanical equipment sources, such as rooftop ventilation systems on proposed industrial uses, and from truck loading and unloading activities. To provide a conservative analysis, the highest end of the range of reference noise levels for these stationary noise sources was used to calculate the reasonable worstcase hourly average noise levels from each noise source. These hourly averages were then assumed to occur for every hour for a 24-hour period to calculate the reasonable worst-case 24-hour average Ldn noise levels as measured at the nearest sensitive receptor land use. These individual source noise levels were then combined to calculate the reasonable worst-case combined stationary source 24- 534
City of American Canyon—Giovannoni Logistics Center Project Draft EIR Noise
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Vibration Impact Analysis Methodology
The City of American Canyon does not have adopted criteria for construction or operational groundborne vibration impacts. Therefore, the FTA’s vibration impact criteria and modeling and analysis methodology were utilized to evaluate potential vibration impacts. The FTA has established industry accepted standards for vibration impact criteria and impact assessment. These guidelines are published in its Transit Noise and Vibration Impact Assessment document, 8 and are summarized
in Table 3.10-5. in the regulatory discussion above.

3.10.5 - Thresholds of Significance
Appendix G to the CEQA Guidelines is a sample Initial Study Checklist that includes questions for determining whether noise impacts are significant. These questions input of planning and environmental professionals at the OPR and the California Natural Resources Agency, based on input from stakeholder groups and experts in various other governmental agencies, nonprofits, and leading environmental consulting firms. As a result, many lead agencies derive their significance criteria from the questions posed in Appendix G. The City has chosen to do so here, but has also included language consistent with CEQA case law. Thus, noise impacts resulting from the implementation of the proposed project would be considered significant if the project would cause:
a) Generation of a substantial temporary or permanent increase in ambient noise levels in noise-sensitive locations in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies; b) Generation of excessive groundborne vibration or groundborne noise levels; c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels.

3.10.6 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the development of the project and provides mitigation measures where appropriate.

Substantial Noise Increase in Excess of Standards
Impact NOI-1: The proposed project could generate a substantial temporary or permanent increase in ambient noise levels in noise-sensitive locations in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.
8 Federal Transit Administration (FTA). 2006. Transit Noise and Vibration Impact Assessment. May. 535
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Construction
For purposes of this analysis, a significant impact would occur if construction noise impacts were greater than 75 dBA between the hours of 7:00 a.m. and 7:00 p.m. or greater than 60 dBA from 7:00 p.m. to 7:00 a.m., per the City’s policies, and would result in a substantial temporary increase in ambient noise levels that could result in annoyance or sleep disturbance of nearby sensitive receptors.

Construction-related Traffic Noise
Noise impacts from construction activities associated with the project would be a function of the noise generated by construction equipment, equipment location, sensitivity of nearby land uses, and the timing and duration of the construction activities. One type of short-term noise impact that could occur during project construction would result from the increase in traffic flow on local streets associated with the transport of workers, equipment, and materials to and from the project site. The transport of workers and construction equipment and materials to the project site would incrementally increase noise levels on access roads leading to the site. Because workers and construction equipment would use existing routes, noise from passing trucks would be similar to existing vehicle-generated noise on these local roadways. Typically, a doubling of the ADT hourly volumes on a roadway segment is required in order to result in an increase of 3 dBA in traffic noise levels, which, as discussed in the characteristics of nose discussion above, is the lowest change that can be perceptible to the human ear in outdoor environments. Project-related construction trips would not be expected to double the hourly or daily traffic volumes along any roadway segment in the project vicinity. For this reason, short-term intermittent noise from construction trips would not be expected to result in a perceptible increase in hourly or daily average traffic noise levels in the project vicinity. Therefore, short-term construction-related noise impacts associated with the transportation of workers and equipment to the project site would be less than significant.

Construction Equipment Operational Noise
The second type of short-term noise impact is related to noise generated during construction on the project site. Construction is completed in discrete steps, each of which has its own mix of equipment and, consequently, its own noise characteristics. These various sequential phases would change the character of the noise generated on the site and, therefore, the noise levels surrounding the site as construction progresses. Despite the variety in the type and size of construction equipment, similarities in the dominant noise sources and patterns of operation allow construction-related noise ranges to be categorized by work phase. Table 3.10-2 lists typical construction equipment noise levels, based on a distance of 50 feet between the equipment and a noise receptor. Typical operating cycles for these types of construction equipment may involve 1 or 2 minutes of full power operation followed by 3 or 4 minutes at lower power settings. Impact equipment such as pile drivers are not expected to be used during construction of this project.

The site preparation phase, which includes excavation and grading of the site, tends to generate the highest noise levels because the noisiest construction equipment is earthmoving equipment.

Earthmoving equipment includes excavating machinery and compacting equipment, such as bulldozers, draglines, backhoes, front loaders, roller compactors, scrapers, and graders. Typical 536
City of American Canyon—Giovannoni Logistics Center Project Draft EIR Noise
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Construction of the project is expected to require the use of scrapers, bulldozers, water trucks, haul trucks, and pickup trucks. Based on the information provided in Table 3.10-2, the maximum noise level generated by each scraper is assumed to be 85 dBA Lmax at 50 feet from this equipment. Each bulldozer would also generate 85 dBA Lmax at 50 feet. The maximum noise level generated by graders is approximately 85 dBA Lmax at 50 feet. A characteristic of sound is that each doubling of sound sources with equal strength increases a sound level by 3 dBA. Assuming that each piece of construction equipment operates at some distance from the other equipment, a reasonable worst-case combined noise level during this phase of construction would be 90 dBA Lmax at a distance of 50 feet from the acoustic center of a construction area. This would result in a reasonable worst-case hourly average of 86 dBA Leq. The acoustic center reference is used because construction equipment must operate at some distance from one another on a project site and the combined noise level as measured at a point equidistant from the sources (acoustic center) would be the worst-case maximum noise level.

The effect on sensitive receptors is evaluated below.

The closest noise-sensitive receptor to the project site construction footprint is the single-family residence located southwest of the project site, on Green Island Road. The closest façade of the residence would be located 1,240 feet from the acoustic center of construction activity where multiple pieces of heavy construction equipment would operate simultaneously during construction of the proposed parking areas near the project’s northeastern boundary. At this distance, construction noise levels could range up to approximately 62 dBA Lmax, with a relative worst-case hourly average of 57 dBA Leq at this receptor. These noise levels could occur temporarily under the reasonable worst-case scenario of multiple pieces of heavy construction equipment operating simultaneously in relatively the same locations at the nearest project boundary for an hour period.

These construction noise levels are within the construction noise limits established by the City of no greater than 75 dBA during the hours of 7:00 a.m. to 7:00 p.m.; but these levels could exceed the City’s nighttime threshold for construction noise of 60 dBA. Therefore, construction activities shall be restricted to daytime hours and best management noise reduction techniques and practices shall be implemented as outlined in Mitigation Measure (MM) NOI-1, to ensure that construction noise would not result in a substantial temporary increase in ambient noise levels that would result in annoyance or sleep disturbance of nearby sensitive receptors. MM NOI-1 would reduce impacts from construction noise by requiring mufflers on construction equipment powered by internal engines, which are the primary source of construction noise. Additionally, MM NOI-1 would require contractors to limit idling times of vehicles with internal combustion engines to 5 minutes or less and utilize quiet mode on air compressors and other stationary noise sources. Furthermore, MM NOI-1 would require contractors to locate stationary noise-generating equipment be located as far away as the equipment allows and also placed such that noise is directed away from adjacent residential homes. Finally, MM NOI-1 would require construction staging areas be located as far away as possible from noise-sensitive receptors nearest the project site and would limit construction activities to the permitted hours Monday through Saturday. The measures outlined in MM NOI-1 would collectively reduce temporary construction noise impacts to a less than significant level. 537
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Implementation of the project would result in mobile and stationary operational noise sources.

Potential noise impacts with these project-related sources are analyzed below.

Mobile Source Operational Noise Impacts
A significant impact would occur if implementation of the proposed project would result in a substantial increase in traffic noise levels compared with traffic noise levels existing without the project. The County does not define what is a substantial increase in traffic noise levels. As noted in the characteristics of noise discussion, audible increases in noise levels generally refer to a change of 3 dBA or more, as this level has been found to be barely perceptible to the human ear in outdoor environments. A change of 5 dBA is considered the minimum readily perceptible change to the human ear in outdoor environments. Therefore, for purposes of this analysis, a 3 dBA or greater increase above traffic noise levels that would existing without the project would be considered a substantial permanent increase in traffic noise levels.

Table 3.10-6 shows a summary of the traffic noise levels for Existing, Existing Plus Project, Future without the Project, and Future Plus Project traffic conditions, as defined in the traffic study prepared by W-Trans.
9 These modeling results represent the projected traffic noise levels as measured at 50-feet from the centerline of the outermost travel lane of the modeled roadway segment.

Table 3.10-6: Traffic Noise Increase Summary
Roadway Segment
Existing No
Project
(dBA) Ldn
Existing Plus
Project
(dBA) Ldn
Increase
from Existing
No Project
Conditions
(dBA)
Future No
Project
(dBA) Ldn
Future Plus
Project
(dBA) Ldn
Increase
from Future
No Project
Conditions
(dBA)
Paoli Loop Road–south of
Green Island Road

59.9 60.8 0.9 60.8 61.5 0.7
Green Island Road–Paoli Loop
Road to future Devlin Road

62.0 63.2 1.2 62.9 63.8 0.9
Green Island Road–west of
future Devlin Road

62.0 62.0 0.0 62.9 62.9 0.0
South Kelly Road–SR-29 to
Devlin Road

56.6 59.1 2.5 59.0 60.6 1.6
SR-29–South Kelly Road to
Green Island Road

73.8 73.9 0.1 76.1 76.2 0.1
Notes:
dBA = A-weighted decibel
Ldn = day/night average sound level
Source: FirstCarbon Solutions (FCS) 2021.
9 W-Trans. 2021. Traffic Impact Study for the Giovannoni Logistics Center. July. 538
City of American Canyon—Giovannoni Logistics Center Project Draft EIR Noise
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-10 Noise.docx As shown in Table 3.10-6, the highest traffic noise level increase with implementation of the proposed project would occur along South Kelly Road under Existing Plus Project conditions. Along this roadway segment, the proposed project would result in traffic noise levels ranging up to 59.1 dBA Ldn as measured at 50 feet from the centerline of the nearest travel lane, representing an increase of 2.5 dBA over existing conditions for this roadway segment.

This increase is less than a 3 dBA or greater increase that would be considered a substantial increase.

Therefore, project-related traffic noise levels would not result in a substantial permanent increase in traffic noise levels in excess of applicable standards and would represent a less than significant impact.

Stationary Source Operational Noise Impacts
A significant impact would occur if operational noise levels generated by stationary noise sources at the proposed project site would result in a substantial permanent increase in ambient noise levels in excess of the City’s noise performance standards. The City requires that new industrial, commercial, and related land uses demonstrate that they would not directly cause ambient noise levels to exceed an exterior Ldn of 65 dBA in areas containing housing, schools, health care facilities, or other “noisesensitive” land uses.

The proposed project would generate noise from parking lot activities, new exterior mechanical equipment sources, such as rooftop ventilation systems on proposed industrial uses, and truck loading and unloading activities. Potential impacts from these noise sources are discussed below.

Parking Lot Activities
Typical parking lot activities include people conversing, doors shutting, and vehicles idling which generate noise levels ranging from approximately 60 dBA to 70 dBA Lmax at 50 feet. These activities are expected to occur sporadically throughout the day as visitors and staff arrive and leave parking lot areas at the project site.

The nearest noise-sensitive receptor is single-family residence located southwest of the project site on Green Island Road. The nearest façade of the residence is located approximately 1,360 feet southwest of the nearest proposed parking areas. With the distance attenuation, noise levels associated with daily parking lot activities would attenuate to approximately 41 dBA Lmax at this façade. Assuming a reasonable worst-case scenario of one parking movement for every parking stall within a single hour would result in an hourly average noise level of 24 dBA Leq as measured at this nearest façade. If these noise levels were to occur every hour for a 24-hour period, they would result in a reasonable worst-case average noise level of 30 dBA Ldn as measured at this nearest receptor.

The calculation spreadsheet with the detailed modeling assumptions is included in Appendix G.

Therefore, the proposed project’s reasonable worst-case parking lot noise levels would not cause ambient noise levels to exceed an exterior Ldn of 65 dBA as measured at the nearest receptor.

Existing traffic noise levels along Green Island Road are shown in Table3.10-6 to be 62 dBA Ldn.

Therefore, project parking lot activities would not result in a substantial permanent increase in ambient noise levels in the project vicinity. Because the proposed project would not generate a substantial permanent increase in ambient noise levels in noise-sensitive locations in the vicinity of 539
City of American Canyon—Giovannoni Logistics Center Project Noise Draft EIR

3.10-20 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-10 Noise.docx the project, and would also not generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, the impact of noise produced by project-related parking lot activities to off-site sensitive receptors would be less than significant.

Mechanical Equipment Operations
At the time of preparation of this analysis, details were not available pertaining to the proposed rooftop mechanical ventilation systems for the project; therefore, a reference noise level for typical rooftop mechanical ventilation systems was used. Noise levels from commercially available rooftop mechanical ventilation equipment range from 50 dBA to 60 dBA Leq at a distance of 25 feet.

The nearest noise-sensitive receptor is a single-family residence located southwest of the project site on Green Island Road. The nearest façade of the residence is located approximately 1,470 feet southwest of the nearest potential location for proposed rooftop mechanical ventilation equipment.

At this distance, noise generated by typical rooftop mechanical ventilation equipment would attenuate to below 22 dBA Leq at the nearest façade. If these noise levels were to occur every hour for a 24-hour period, they would result in a reasonable worst-case average noise level of 29 dBA Ldn as measured at this nearest receptor. The calculation spreadsheet with the detailed modeling assumptions is included in Appendix G.

Therefore, the proposed project’s reasonable worst-case mechanical ventilation equipment operations noise levels would not cause ambient noise levels to exceed an exterior Ldn of 65 dBA as measured at the nearest receptor. Existing traffic noise levels along Green Island Road are shown in Table 3.10-6 to be 62 dBA Ldn. Therefore, noise levels from proposed mechanical ventilation equipment operations would not result in a substantial permanent increase in ambient noise levels in the project vicinity. Because the project would not generate a substantial permanent increase in ambient noise levels in noise-sensitive locations in the vicinity of the project, and would also not generate a substantial temporary or permanent increase in ambient noise levels in the project vicinity in excess of standards established in the local general plan or noise ordinance, the impact of noise produced by proposed mechanical ventilation equipment operations to off-site sensitive receptors would be less than significant.

Truck Loading Activities
Noise would be also generated by truck loading and unloading activities at the loading docks along the western side of the proposed building and at the proposed surface level loading areas on the north and south sides of the building. Typical maximum noise levels from truck loading and unloading activity are 70 dBA Lmax as measured at 50 feet. These maximum noise levels include noise from associated truck loading/unloading activity, including trucks maneuvering, truck trailer loading, truck trailer unloading, backup alarms or beepers, and truck docking noise.

The nearest noise-sensitive receptor is a single-family residence located south of the project site on Green Island Road. The nearest façade of the residence is located approximately 1,600 feet from the nearest loading docks. Assuming a reasonable worst-case scenario of one truck loading operation for every loading stall and every loading dock within a single hour would result in an hourly average noise level of 40 dBA Lmax and 29 dBA Leq as measured at the nearest façade of the residence. If these 540
City of American Canyon—Giovannoni Logistics Center Project Draft EIR Noise
FirstCarbon Solutions 3.10-21
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-10 Noise.docx noise levels were to occur every hour for a 24-hour period, they would result in a reasonable worstcase average noise level of 35 dBA Ldn as measured at this nearest receptor. The calculation spreadsheet with the detailed modeling assumptions is included in Appendix G.

Therefore, the proposed project’s reasonable worst-case truck loading/unloading activity noise levels would not cause ambient noise levels to exceed an exterior Ldn of 65 dBA as measured at the nearest receptor. Existing traffic noise levels along Green Island Road are shown in Table3.10-6 to be 62 dBA Ldn. Therefore, project truck loading/unloading activities would not result in a substantial permanent increase in ambient noise levels in the project vicinity. Because the proposed project would not generate a substantial permanent increase in ambient noise levels in noise-sensitive locations in the vicinity of the project, and would also not generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, the impact of noise produced by projectrelated parking lot activities to off-site sensitive receptors would be less than significant.

Stationary Source Operational Noise Impact Conclusion
As shown in the analysis above, none of the project stationary operational noise sources would result in an increase of 3 dBA or greater above the City’s performance threshold of 65 dBA Ldn for stationary noise sources as measured at the nearest sensitive receptor. Therefore, noise impacts from stationary operational noise sources would be less than significant.

Table 3.10-7 provides a summary of the stationary source operation noise impacts. The combined stationary source operational noise levels would not exceed the City’s exterior Ldn threshold of 65 dBA as measured at the nearest receptor. Therefore, project stationary source operational noise levels would be less than significant.

Table 3.10-7: Stationary Operational Noise Impact Summary Source
(Reference Noise Levels)
Approximate
Distance from
Source to Nearest
Sensitive
Receptor (feet)
Operational
Noise Level as
Measured at the
Project
Boundary
City’s Noise
Performance
Threshold
Exceed
Threshold by 3
dBA or greater?
(Yes/No)
Parking Lot Activities
(70 dBA Lmax at 50 feet) 1,360 30 dBA Ldn 65 dBA Ldn No Mechanical Ventilation Equipment
(60 dBA Leq at a distance of 25 feet) 1,470 29 dBA Ldn 65 dBA Ldn No Truck Loading and Unloading Activities
(80 dBA Lmax as measured at 50 feet) 1,600 35 dBA Ldn 65 dBA Ldn No Combined Noise Levels NA 36.9 dBA Ldn 65 dBA Ldn No
Notes:
dBA = A-weighted decibel
Lmax = maximum noise/sound level
Ldn = day/night average sound level
Source: FirstCarbon Solutions (FCS) 2021.
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City of American Canyon—Giovannoni Logistics Center Project Noise Draft EIR

3.10-22 FirstCarbon Solutions
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Potentially significant impact.

Mitigation Measures
Based on the above analysis, impacts from noise generated from stationary operational noise sources would be less than significant. However, project construction activity noise impacts, which could result in a temporary increase in ambient noise levels in the project vicinity that could result in annoyance or sleep disturbance of nearby sensitive receptors, would be reduced to less than significant levels with implementation of the following multi-part mitigation measure.

MM NOI-1 Implementation of the following multi-part mitigation measure is required to reduce potential construction period noise impacts:
• The construction contractor shall ensure that all equipment driven by internal combustion engines shall be equipped with mufflers that are in good condition and appropriate for the equipment.
• The construction contractor shall ensure that unnecessary idling of internal combustion engines (i.e., idling in excess of 5 minutes) is prohibited. • The construction contractor shall utilize “quiet” models of air compressors and other stationary noise sources where technology exists. • At all times during project grading and construction, the construction contractor shall ensure that stationary noise-generating equipment shall be located as far as practicable from sensitive receptors and placed so that emitted noise is directed away from adjacent residences.
• The construction contractor shall ensure that the construction staging areas shall be located to create the greatest feasible distance between the staging area and noise-sensitive receptors nearest the project site.
• The construction contractor shall ensure that all on-site construction activities, including the operation of any tools or equipment used in construction, drilling, repair, alteration, grading, or demolition work, are limited to between the daytime hours of 7:00 a.m. to 7:00 p.m. Monday through Saturday. No construction shall be permitted on Sundays and federal holidays.

Level of Significance After Mitigation
Less than significant impact.

Groundborne Vibration/Noise Levels
Impact NOI-2: The proposed project would not result in generation of excessive groundborne vibration or groundborne noise levels.

Impact Analysis
This section analyzes both construction and operational groundborne vibration and noise impacts.

Groundborne vibrations consist of rapidly fluctuating motions within the ground that have an average motion of zero. Vibrating objects in contact with the ground radiate vibration waves through various soil and rock strata to the foundations of nearby buildings. Groundborne noise is generated when 542
City of American Canyon—Giovannoni Logistics Center Project Draft EIR Noise
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-10 Noise.docx vibrating building components radiate sound, or noise generated by groundborne vibration. In general, if groundborne vibration levels do not exceed levels considered perceptible, then groundborne noise levels would not be perceptible in most interior environments. Therefore, this analysis focuses on determining exceedances of groundborne vibration levels.

The City of American Canyon has not established quantitative groundborne vibration thresholds for construction or operation. Therefore, for purposes of this analysis, the FTA’s vibration impact criteria are utilized to analyze vibration impacts. The FTA has established industry accepted standards for vibration impact criteria and impact assessment. These guidelines are published in its Transit Noise and Vibration Impact Assessment Manual.10 The construction vibration impact criteria are summarized in Table 3.10-5.

Construction
A significant impact would occur if existing structures at the project site or in the project vicinity would be exposed to groundborne vibration levels in excess of levels established by the FTA’s Construction Vibration Impact Criteria for the listed type of structure, as shown in Table 3.10-5.

Of the variety of equipment used during construction, the large vibratory rollers that could be used in the site preparation phase of construction would produce the greatest groundborne vibration levels. Large vibratory rollers produce groundborne vibration levels ranging up to 0.201 inch per second (in/sec) PPV at 25 feet from the operating equipment.

The nearest off-site receptors to the project construction footprint where the heaviest construction equipment would operate is the commercial building located south of the project site on Green Island Road. The façade of this structure would be located approximately 120 feet from the nearest point on the project site where the heaviest construction equipment would potentially operate. At this distance, groundborne vibration levels would range up to 0.008 PPV from operation of the types of equipment that would produce the highest vibration levels, which is well below the FTA’s Construction Vibration Impact Criteria of 0.2 PPV for this type of structure, which is a building of non-engineered timber and masonry construction. Therefore, the impact of short-term groundborne vibration associated with construction to off-site receptors would be less than significant.

Operation
Implementation of the project would not include any permanent sources that would expose persons in the project vicinity to groundborne vibration levels that could be perceptible without instruments at any existing sensitive land use in the project vicinity.

The Napa Branch Line railroad is located approximately 130 feet east of the nearest proposed façade of the project. At this distance potential groundborne vibration impacts would be less than significant for the proposed type of structure, based on FTA vibration screening criteria. There are no other existing significant permanent sources of groundborne vibration in the project vicinity to which the proposed project would be exposed. Therefore, project operational groundborne vibration level impacts would be considered less than significant. 10 Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual. September. 543
City of American Canyon—Giovannoni Logistics Center Project Noise Draft EIR

3.10-24 FirstCarbon Solutions
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Less than significant impact.

Excessive Noise Levels from Airport Activity
Impact NOI-3: The proposed project would not expose people residing or working in the project area to excessive noise levels for a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport.

Impact Analysis
A significant impact would occur if the proposed project would expose people residing or working in the project area to excessive noise levels for a project located in the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within 2 miles of a public airport or public use airport. The City’s Policy 11.4.1 restricts the development of uses located within the 65 CNEL contour of Napa Airport to industrial, agricultural, or other open space uses; and Policy 11.4.1 requires that development in the vicinity of Napa Airport comply with the noise standards contained in the ALUP.

The project site is not located within the vicinity of a private airstrip. However, the project is located within 2 miles of a public airport; the Napa County Airport is located approximately 1 mile north of the project site. According to the airport’s noise exposure map and shown in Exhibit 3.10-2, the project site is located outside of the 55 dBA CNEL airport noise contours.11 Therefore, while aircraft noise is occasionally audible on the project site from aircraft flyovers, aircraft noise associated with nearby airport activity would not expose people residing or working near the project site to excessive noise levels. These noise levels are considered normally acceptable for new industrial land use development within the City as shown in Exhibit 3.10-1. On this basis, implementation of the project would not expose persons residing or working in the project vicinity to noise levels from airport activity that would be in excess of normally acceptable standards for the proposed land use development, and no impact would occur.

Level of Significance Before Mitigation
Less than significant impact.
11 Napa County Airport Master Plan. 2008. Noise Contours 2022. Website: https://www.countyofnapa.org/ DocumentCenter/View/1981/Airport-Master-Plan-Environmental-Assessment-NEPA-PDF. Accessed June 30, 2021. 544
54600001 • 12/2021 | 3.10-1_GP_noise_element.cdr CITY OF AMERICAN CANYON

GIOVANNONI LOGISTICS CENTER PROJECT

ENVIRONMENTAL IMPACT REPORT
Exhibit 3.10-1
General Plan Noise Element
Source: The City of American Canyon General Plan.
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54600001 • 12/2021 | 3.10-2_napa_county_airport_noise_levels.cdr CITY OF AMERICAN CANYON

GIOVANNONI LOGISTICS CENTER PROJECT

ENVIRONMENTAL IMPACT REPORT
Exhibit 3.10-2
Napa County Airport Noise Levels
Source: Napa County, 2004. The City of American Canyon General Plan. 547

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City of American Canyon—Givannoni Logistics Center Project Draft EIR Public Services
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3.11 - Public Services

3.11.1 - Introductions
This section describes the existing public services and potential effects from project implementation on the site and its surrounding area. Descriptions and analysis in this section are based on information provided by the City of American Canyon General Plan and the South County Region Municipal Service Review and Sphere of Influence Updates.

3.11.2 - Environmental Setting
Fire Protection and Emergency Medical Services
The American Canyon Fire Protection District (Fire District) provides fire protection and emergency medical services to the City of American Canyon as well as nearby unincorporated areas of Napa County. The Fire District’s service area encompasses approximately 8 square miles. The Fire District is headquartered at 911 Donaldson Way East (Station 11). The American Canyon City Council serves as the Fire District’s Board of Directors.

Stations
The Fire District operates two fire stations: Station 11 (911 Donaldson Way) and Station 2 (225 James Road). Station 2 was reopened in June 2020 after being closed for several years.

Organization
The Fire District is organized into three divisions: Operations, Prevention, and Administration.

Operations is the largest division and is responsible for responding to calls for service. Prevention oversees code compliance and conducts inspections through a private contractor. Administration is the principal responsibility of the Fire Chief, and this division oversees field operations, policy reviews, and budgeting.

Services Provided
The Fire District provides emergency operations, fire suppression, advanced life support emergency medical care, and rescue in a public-private partnership with American Medical Response. Other services and functions include fire prevention, public education, business fire safety inspections, plan review, construction site inspection, code enforcement, fire investigation, public education outreach programs, disaster preparedness, emergency operations plan development, emergency operations center operations, and coordination of disaster preparedness training. The Fire District is also recognized by California Emergency Management Agency as a Type 1 (heavy) rescue single resource.

Apparatus
The Fire District has four front line apparatus: three 1,500-gallon-per-minute (gpm) pumper engines and one 1,500-gpm, 75-foot aerial ladder truck (Quint). The Fire District also has air/light/rescue apparatus; command/utility vehicles, inflatable rescue boats, an ambulance, and towable technical rescue equipment trailers.
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The Fire District has 24 full-time employees including 22 sworn fire fighters and two executive assistants. Twenty fire personnel are assigned to Operations and staff three shifts: A, B, and C. The Fire Chief and Assistant Fire Chief are assigned to Administration along with the executive assistants.

The Fire District can supplement its full-time personnel with reserves and volunteers when needed.

Incidents
The Fire District responded to 1,868 incidents in 2021. Rescues and emergency services accounted for 63 percent of the incidents. The Fire District responded to 62 incidents in the industrial area near the Napa County Airport in 2020, with rescue and emergency services accounting for 48 percent of the calls.

Response Times
The Fire District has an established response time standard of first unit arrival within 5 minutes (total travel time) for 90 percent of all incidents. The Fire District responded to 13 percent of calls within 5 minutes in the industrial area near the Napa County Airport in 2021.

Insurance Services Office Rating
The Fire District has an Insurance Services Office (ISO) rating of Class 2 on a scale of 1 to 10, with 1 being the best. An ISO rating accounts for factors such as emergency communication systems, personnel, training, equipment, and water supply.

Police Protection
The American Canyon Police Department (Police Department) provides police protection to the City of American Canyon. The Police Department is staffed by the Napa County Sheriff’s Office, which provides law enforcement services on a contract basis to the City of American Canyon. The Police Department is headquartered at 911 Donaldson Way East.

Organization
The Sheriff’s Office consists of the following divisions: Administration, Operations, and Services.

Administration is responsible for policy development and implementation, and overall management of personnel and fiscal resources. Operations is made up of four bureaus: Patrol, Investigations, Special Operations, and Animal Services. The Services Division comprises five bureaus: Technical Services (Records), Property and Evidence, Coroner, Court Services and Transportation.

Staffing
The Police Department is staffed by 24 full-time sworn police officers and 2.7 (full-time-equivalent) civilian personnel. The Police Department consists of one chief (Sheriff’s Office Captain), four sergeants, and 19 officers. Two of the officers are assigned to traffic, one is a School Resource Officer, and one is a Community Resource Officer.

Calls for Service
Between 2013 and 2018, the Police Department responded to between 17,057 and 19,703 calls for service annually.
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3.11.3 - Regulatory Framework
State
California Building Standards Code
Title 24 of the California Code of Regulations, also known as the California Building Standards Code, is a compilation of three types of building standards from three different origins:
• Building standards that have been adopted by state agencies without change from building standards contained in national and international model codes. • Building standards that have been adopted and adapted from national and international model code standards to meet California conditions.
• Building standards, authorized by the California legislature, which constitute extensive additions not covered by the model codes that have been adopted to address particular California concerns.

The California Fire Code is a component of the California Building Standards Code and contains firesafety-related building standards.

Local
City of American Canyon
General Plan
The City of American Canyon General Plan sets forth the following goals relevant to public services:

Goal 6A Maintain a high level of fire protection and emergency services to City/District businesses and residents.

Goal 6B Ensure a high level of police protection for the City’s residents, businesses, and visitors.

Policies
Policy 6.7.1 Work with the Sheriff’s Department to ensure that enough personnel are added to the Department to serve the needs of a growing population and a developing City.

3.11.4 - Methodology
FCS reviewed the City of American Canyon General Plan, the South County Region Municipal Service Review and Sphere of Influence Updates, and the City’s website for information about public service providers.

3.11.5 - Thresholds of Significance
Appendix G to the California Environmental Quality Act (CEQA) Guidelines is a sample Initial Study Checklist that includes questions for determining whether impacts related to public services are significant. These questions reflect the input of planning and environmental professionals at the Governor’s Office of Planning and Research (OPR) and the California Natural Resources Agency, based 551
City of American Canyon—Givannoni Logistics Center Project Public Services Draft EIR

3.11-4 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-11 Public Services.docx on input from stakeholder groups and experts in various other governmental agencies, nonprofits, and leading environmental consulting firms. As a result, many lead agencies derive their significance criteria from the questions posed in Appendix G. The City has chosen to do so for this project. Thus, the proposed project would have a significant effect if it would:

Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
a) Fire protection.
b) Police protection.
c) Schools (Refer to Section 7, Effects Found not to be Significant). d) Parks (Refer to Section 7, Effects Found not to be Significant). e) Other public facilities (Refer to Section 7, Effects Found not to be Significant).

3.11.6 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the development of the project and provides mitigation measures where appropriate.

Fire Protection
Impact PS-1: The proposed project would not result in a need for new or expanded fire protection facilities that may have physical impacts on the environment.

Impact Analysis
Phases 1 and 2
The proposed project would be served with fire protection and emergency medical services provided by the American Canyon Fire Protection District.

The Fire Protection District indicates that the proposed project would increase the number of calls for service, with most being rescue and emergency medical service related. The proposed project would take vehicular access from Green Island Road and the Devlin Road extension, which is currently under construction. All access points would be accessible to large emergency vehicles such as fire engines. This would comply with California Fire Code requirements for emergency vehicle accessibility.

The project site is located 3.1 miles from Station 11, via Paoli Loop Road and Green Island Road.

However, emergency responders have the ability to avoid Paoli Loop Road and make a left turn directly onto Green Island Road from State Route (SR) 29. This route reduces the travel distance to

2.2 miles. Using an average travel speed of 35 miles per hour, it would take a fire engine 3 minutes and 46 seconds to reach the project site when responding from Station 11. This would be within the Fire District’s 5-minute response time objective. However, congestion on SR-29 may increase travel time such that it exceeds the 5-minute response time objective. 552
City of American Canyon—Givannoni Logistics Center Project Draft EIR Public Services
FirstCarbon Solutions 3.11-5 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-11 Public Services.docx The proposed project would be required to pay two separate special assessments to fund fire protection and emergency medical services. The first is the “Fire Mitigation Fee,” a one-time assessment to all new development. The second is the “Fire Service Fee” and an annual assessment for each parcel based on a formula that includes structure construction type, the fire flow area (square feet), proximity of other structures, the type of occupancy, and the presence of fire protection devices.

Because the Fire District’s existing facilities are adequate to serve the proposed project, there is no need to develop new or expanded fire protection facilities to serve the 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.

Police Protection
Impact PS-2: The proposed project would not result in a need for new or expanded police protection facilities that may have physical impacts on the environment.

Impact Analysis
Phases 1 and 2
The proposed project would be served with police protection provided by the American Canyon Police Department. The Police Department is staffed by the Napa County Sheriff’s Office, which provides law enforcement services on a contract basis to the City of American Canyon.

The proposed project would be surrounded with a secure perimeter and would only be accessible to authorized users. Depending on the ultimate end user, the site would be accessible via either a mechanical gate with key card access, or a manned security booth. The proposed project would be expected to be staffed 24 hours a day, 7 days a week. Security measures including exterior lighting, alarm systems, and video surveillance would be employed to deter and prevent criminal activity. The Police Department will have the opportunity to review and comment on security measures during the plan check review process. For these reasons, the proposed project would be expected to generate minimal calls for service and, therefore, would not create a need for new or expanded police facilities. Impacts would be less than significant.

Level of Significance Before Mitigation
Less than significant impact.

Mitigation Measures
No mitigation is necessary.
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Less than significant impact.
554
City of American Canyon—Giovannoni Logistics Center Project Draft EIR Transportation
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3.12 - Transportation

3.12.1 - Introduction
This section describes the existing transportation setting and potential effects from project implementation on the site and its surrounding area. Descriptions and analysis in this section are based on a Traffic Impact Study prepared by W-Trans. The study is provided in Appendix H.

3.12.2 - Environmental Setting
Study Area
The study area consists of the following intersections selected through consultation from City staff:

1. State Route (SR) 29/South Kelly Road

2. Devlin Road/South Kelly Road

3. Devlin Road/Green Island Road (Future Intersection)

4. Paoli Loop Road/Green Island Road
Operating conditions during the weekday AM and PM peak periods were evaluated to capture the highest potential impacts for the proposed project as well as the highest volumes on the local transportation network. The morning peak-hour occurs between 7:00 a.m. and 9:00 a.m. and reflects conditions during the home to work or school commute, while the PM peak-hour occurs between 4:00 p.m. and 6:00 p.m. and typically reflects the highest level of congestion during the homeward bound commute.

Study Intersections
SR-29/South Kelly Road is a signalized four-legged intersection with protected left turns on all approaches. There are crosswalks on the west, north, and east legs.

Devlin Road/South Kelly Road is an all-way stop-controlled intersection with crosswalks on the east and south legs.

Devlin Road/Green Island Road (Future) is a future tee intersection with stop control on the southbound Devlin Road approach. Crosswalks are planned at the north leg.

Paoli Loop Road/Green Island Road is a tee intersection with stop control on the northbound Paoli Loop Road approach. There are no crosswalks.

Exhibit 3.12-1 depicts the study facilities and land configurations.

Intersection Level of Service
Level of Service (LOS) is used to rank traffic operation on various types of facilities based on traffic volumes and roadway capacity using a series of letter designations ranging from A to F. Generally, LOS A represents free flow conditions and LOS F represents forced flow or breakdown conditions. A unit of measure that indicates a level of delay generally accompanies the LOS designation. 555
City of American Canyon—Givannoni Logistics Center Project Transportation Draft EIR

3.12-2 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-12 Transportation.docx As explained in detail later in subsection (3.12.3) below, transportation analyses under the California Environmental Quality Act (CEQA) formerly focused on reductions in LOS (dropping from one category [e.g., D] to another [e.g., E or F]), but no longer do. As of early 2019, CEQA expressly forbids lead agencies from measuring adverse transportation effects in terms of “automobile delay, as described solely by level of service or similar measures of vehicular capacity or traffic congestion” (with an exception not relevant here) (Public Resources Code [PRC], § 21099(b)(2)). Even so, many public agencies still require analyses of proposed projects’ potential effects on LOS, but do so under their general police power or General Plan policies, wholly independent of, and separate from, CEQA.

This section addresses LOS issues independent of CEQA, for use by the City of American Canyon for assessing whether and how to impose conditions of approval needed to maintain the reasonable free flow of traffic. In particular, this section addresses LOS in order to ensure that the proposed project complies with Guiding Policy 1.6 of the Circulation Element of the City’s General Plan (quoted in full in section 3.12.3 below).

The study intersections were analyzed using methodologies published in the Highway Capacity Manual (HCM), 6th Edition, Transportation Research Board, 2018. This source contains methodologies for various types of intersection control, all of which are related to a measurement of delay in average number of seconds per vehicle.

The LOS for the intersections with side street stop controls, or those that are unsignalized and have one or two stop-controlled approaches, were analyzed using the “Two-Way Stop-Controlled” intersection capacity method from the HCM. This methodology determines a LOS for each minor turning movement by estimating the level of average delay in seconds per vehicle. Results are presented for individual movements together with the weighted overall average delay for the intersection.

The study intersections with stop signs on all approaches were analyzed using the “All-Way StopControlled” Intersection methodology from the HCM. This methodology evaluates delay for each approach based on turning movements, opposing, and conflicting traffic volumes, and the number of lanes. Average vehicle delay is computed for the intersection as a whole and then related to an LOS.

The study intersections that are currently controlled by a traffic signal, or may be in the future, were evaluated using the signalized methodology from the HCM. This methodology is based on factors including traffic volumes, green time for each movement, phasing, whether the signals are coordinated or not, truck traffic, and pedestrian activity. Average stopped delay per vehicle in seconds is used as the basis for evaluation in this LOS methodology. For purposes of this study, delays were calculated using signal timing obtained from the California Department of Transportation (Caltrans).

The ranges of delay associated with the various LOS are indicated in Table 3.12-1. 556
City of American Canyon—Giovannoni Logistics Center Project Draft EIR Transportation
FirstCarbon Solutions 3.12-3
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-12 Transportation.docx Table 3.12-1: Intersection Level of Service Criteria
LOS Two-Way Stop-Controlled All-Way Stop-Controlled Signalized A Delay of 0 to 10 seconds. Gaps in
traffic are readily available for
drivers exiting the minor street.

Delay of 0 to 10 seconds. Upon
stopping, drivers are immediately
able to proceed.

Delay of 0 to 10 seconds.

Most vehicles arrive during
the green phase, so do not
stop at all.

B Delay of 10 to 15 seconds. Gaps in
traffic are somewhat less readily
available than with LOS A, but no
queueing occurs on the minor
street.

Delay of 10 to 15 seconds. Drivers
may wait for one or two vehicles to
clear the intersection before
proceeding from a stop.

Delay of 10 to 20 seconds.

More vehicles stop than with
LOS A, but many drivers still
do not have to stop.

C Delay of 15 to 25 seconds.

Acceptable gaps in traffic are less
frequent, and drivers may
approach while another vehicle is
already waiting to exit the side
street.

Delay of 15 to 25 seconds. Drivers
will enter a queue of one or two
vehicles on the same approach and
wait for vehicle to clear from one or
more approaches prior to entering
the intersection.

Delay of 20 to 35 seconds.

The number of vehicles
stopping is significant,
although many still pass
through without stopping.

D Delay of 25 to 35 seconds. There
are fewer acceptable gaps in
traffic, and drivers may enter a
queue of one or two vehicles on
the side street.

Delay of 25 to 35 seconds. Queues of
more than two vehicles are
encountered on one or more
approaches.

Delay of 35 to 55 seconds.

The influence of congestion
is noticeable, and most
vehicles have to stop.

E Delay of 35 to 50 seconds. Few
acceptable gaps in traffic are
available, and longer queues may
form on the side street.

Delay of 35 to 50 seconds. Longer
queues are encountered on more
than one approach to the
intersection.

Delay of 55 to 80 seconds.

Most, if not all, vehicles
must stop, and drivers
consider the delay excessive.

F Delay of more than 50 seconds.

Drivers may wait for long periods
before there is an acceptable gap
in traffic for exiting the side
streets, creating long queues.

Delay of more than 50 seconds.

Drivers enter long queues on all
approaches.

Delay of more than 80
seconds. Vehicles may wait
through more than one cycle
to clear the intersection.

Source: Highway Capacity Manual (HCM). 2018.

Existing Traffic Operations
The Existing Conditions scenario provides an evaluation of current operation based on existing traffic volumes during the AM and PM peak-hours. This condition does not include project-generated traffic volumes. Volume data was collected on various dates in February, May, and November 2019 while local schools were in session and prior to the outbreak of COVID-19 and the resulting change in travel patterns. It is noted that travel patterns within American Canyon vary between the AM and PM peak-hours and individual drivers may use different routes for their morning and evening commutes.

As shown in Table 3.12-2, all study intersections are operating acceptably during both peak-hours evaluated under existing conditions. Exhibit 3.12-2 depicts the existing traffic volumes. 557
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3.12-4 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-12 Transportation.docx Table 3.12-2: Existing Peak-hour Intersection Levels of Service Study Intersection
AM
Peak-hour
PM
Peak-hour
Delay LOS Delay LOS

1. SR-29/South Kelly Road 34.6 C 15.9 B

2. Devlin Road/South Kelly Road 7.8 A 8.0 A

3. Devlin Road/Green Island Road – – – –

4. Paoli Loop Road/Green Island Road
Northbound Approach

4.9 13.3
A
B

3.1 13.5
A
B
Notes:

LOS = Level of Service
Study intersection No. 3 Devlin Road/Green Island Road did not exist in 2015-2020.

Source: W-Trans 2021.

Collision History
The collision history for the study area was reviewed to determine any trends or patterns that may indicate a safety issue. Collision rates were calculated based on records available from the California Highway Patrol as published in their Statewide Integrated Traffic Records System (SWITRS) reports.

The most current 5-year period available is October 1, 2015, through September 30, 2020.

As presented in Table 3.12-3, the calculated collision rates for the study intersections were compared to average collision rates for similar facilities Statewide, as reported in the publication 2016 Collision Data on California State Highways, California Department of Transportation (Caltrans). These average rates Statewide are for intersections in the same environment (urban, suburban, or rural), with the same number of approaches (three or four), and the same controls (all-way stop, two-way stop, or traffic signal). A more detailed evaluation is provided for study intersections where the collision rates were higher than the Statewide average.

Table 3.12-3: Collision Rates for the Study Intersections Study Intersection
Number of Collisions
(2015-2020)
Calculated Collision Rate
(c/mve)
Statewide Average Collision
Rate (c/mve)

1. SR-29/South Kelly Road 48 0.82 0.58

2. Devlin Road/South Kelly
Road 2 0.32 0.55

3. Paoli Loop Road/Green
Island Road 2 0.20 0.16
Notes:
c/mve = collisions per million vehicles entering
Study intersection No. 3 Devlin Road/Green Island Road did not exist in 2015-2020.

Source: W-Trans 2021.
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-12 Transportation.docx Of the 48 reported collisions that occurred at the intersection of SR-29/South Kelly Road, 30 were rear-end collisions with the primary cause being unsafe speeds. This type of crash is common at signalized intersections where there is congestion, especially during peak periods. Because of the regional nature of the traffic that causes the congestion, and as this location is under the jurisdiction of Caltrans, there is little that the City can do to address this condition though increased enforcement and analysis of the potential to improve signal timing to reduce congestion could be requested of the Highway Patrol and Caltrans, respectively.

The collision rate at Paoli Loop Road/Green Island Road is higher than the Statewide average, with one of the two reported collisions being a head-on collision and the other being a broadside collision. The broadside collision resulted from “traffic signal and sign” violations, and the head-on collision was attributed to unsafe speed. With no clear pattern and given the very low number of crashes, no remedial actions are apparent.

Pedestrian Facilities
Pedestrian facilities include sidewalks, crosswalks, pedestrian signal phases, curb ramps, curb extensions, and various streetscape amenities such as lighting, benches, etc. In general, sidewalk coverage is limited in the area surrounding the project site. Existing gaps and obstacles along the connecting roadways impact convenient and continuous access for pedestrians and present safety concerns in those locations where appropriate pedestrian infrastructure would address potential conflict points. Within the study area, new sidewalks are planned along the future extension of Devlin Road.

Bicycle Facilities
The Highway Design Manual published by Caltrans classifies bikeways into four categories:
• Class I Multiuse Path–a completely separated right-of-way for the exclusive use of bicycles and pedestrians with cross flows of motorized traffic minimized. • Class II Bike Lane–a striped and signed lane for one-way bike travel on a street or highway. • Class III Bike Route–signing only for shared use with motor vehicles within the same travel lane on a street or highway.
• Class IV Bikeway–also known as a separated bikeway, a Class IV Bikeway is for the exclusive use of bicycles and includes a separation between the bikeway and the motor vehicle traffic lane. The separation may include, but is not limited to, grade separation, flexible posts, inflexible physical barriers, or on-street parking.

In the project area, Class II bike lanes exist on Devlin Road between Middleton Way and South Kelly Road. Bicyclists ride in the roadway and/or on sidewalks along all other streets within the project study area. Table 3.12-4 summarizes the existing and planned bicycle facilities in the project vicinity as contained in the Napa Countywide Bicycle Plan.
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3.12-6 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-12 Transportation.docx Table 3.12-4: Bicycle Facility Summary
Status Facility Class Length (miles) Beginning Point Ending Point Existing Devlin Road II 0.09 Middleton Way South Kelly Road Planned South Kelly Road I 0.20 SR-29 Devlin Road
Vine Trail I 1.62 Middleton Way Watson Lane
Green Island Road I 0.33 Vine Trail Commerce Boulevard
Green Island Road II 0.25 Mezzetta Court Vine Trail
Source: W-Trans 2021.

Transit Facilities
Valley Intercity Neighborhood Express (VINE) Transit provides fixed route bus service throughout Napa County. American Canyon Transit (ACT) is an on-demand, door-to-door, transit service for persons with disabilities who cannot independently use regular fixed route transit services. Neither VINE nor ACT maintains stops near the project site.

On-demand private taxi services are available in the study area 24 hours a day. Taxis can be used for trips within the local Planning Area and farther destinations, including nearby airports. Other ridehailing applications are also available in study area and provide transportation throughout the Bay Area.

3.12.3 - Regulatory Framework
State
California Environmental Quality Act
As mentioned in subsection 3.12.2 above, CEQA transportation analyses traditionally used LOS to rank traffic operations on various types of facilities based on traffic volumes and roadway capacity, using a series of letter designations ranging from A to F. In 2013, however, the Legislature passed legislation with the intention of ultimately doing away with LOS in most instances as a basis for environmental analysis under CEQA. Enacted as part of Senate Bill 743 (2013), Public Resources Code Section 21099, subdivision (b)(1), directed the Governor’s Office of Planning and Research (OPR) to prepare, develop, and transmit to the Secretary of the Natural Resources Agency for certification and adoption, proposed CEQA Guidelines addressing “criteria for determining the significance of transportation impacts of projects within transit priority areas. Those criteria shall promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses. In developing the criteria, [OPR] shall recommend potential metrics to measure transportation impacts that may include, but are not limited to, vehicle miles traveled, vehicle miles traveled per capita, automobile trip generation rates, or automobile trips generated.

The office may also establish criteria for models used to analyze transportation impacts to ensure the models are accurate, reliable, and consistent with the intent of this section.” 560
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-12 Transportation.docx Subdivision (b)(2) of Section 21099 further provides that “[u]pon certification of the guidelines by the Secretary of the Natural Resources Agency pursuant to this section, automobile delay, as described solely by level of service or similar measures of vehicular capacity or traffic congestion shall not be considered a significant impact on the environment pursuant to [CEQA], except in locations specifically identified in the guidelines, if any.” Pursuant to Senate Bill 743, the Natural Resources Agency promulgated CEQA Guidelines Section 15064.3 in late 2018. It became effective in early 2019. Subdivision (a) of that section provides that “[g]enerally, vehicle miles traveled [VMT] is the most appropriate measure of transportation impacts. For the purposes of this section, ‘vehicle miles traveled’ refers to the amount and distance of automobile travel attributable to a project. Other relevant considerations may include the effects of the project on transit and non-motorized travel. Except as provided in subdivision (b)(2) below (regarding roadway capacity), a project’s effect on automobile delay shall not constitute a significant environmental impact.” 1
California Department of Transportation
The study intersection of SR-29/South Kelly Road is located on the State Transportation Network (STN) and is therefore under jurisdiction of Caltrans. It is noted that Caltrans does not currently have a standard of significance relative to intersection operation as this is no longer a CEQA issue. The new Vehicle Miles Traveled-focused Transportation Impact Study Guide (TISG), published in May 2020, replaced the Guide for the Preparation of Traffic Impact Studies, 2002. As indicated in the TISG, Caltrans is transitioning away from requesting LOS or other vehicle operations analyses of land use projects and will instead focus on Vehicle Miles Traveled (VMT).

California Public Utilities Commission
The California Public Utilities Commission (CPUC) is the State agency responsible for rail safety. The CPUC’s jurisdiction includes railroad interlocking plants and public highway grade crossings. CPUC approval is required to modify a railroad interlocking plant (including construction of a new spur track) or modification to an existing public railroad grade crossing. Completion and submittal of a General Order 33-B is required for any proposed work to a railroad interlocking plant (e.g., spur track), and a General Order 88-B is required for any proposed work to a public highway grade crossing.

Regional
Metropolitan Transportation Commission
The Metropolitan Transportation Commission (MTC) serves as the transportation planning, coordinating, and financing agency for the nine county San Francisco Bay Area. The MTC created and maintains the Metropolitan Transportation System (MTS), a multimodal system of highways, major arterials, transit services, rail lines, seaports, airports, and transfer hubs that are critical to regional 1 Subdivision (b)(2) of CEQA Guidelines Section 15064.3 (“transportation projects”) provides that “[t]ransportation projects that reduce, or have no impact on, vehicle miles traveled should be presumed to cause a less than significant transportation impact. For roadway capacity projects, agencies have discretion to determine the appropriate measure of transportation impact consistent with CEQA and other applicable requirements. To the extent that such impacts have already been adequately addressed at a programmatic level, such as in a regional transportation plan EIR, a lead agency may tier from that analysis as provided in [CEQA Guidelines] Section 15152.”
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3.12-8 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-12 Transportation.docx transportation between the nine Bay Area counties. MTS facilities within the study area include SR12, SR-29, and Airport Boulevard. The MTS is incorporated into MTC’s 2001 Regional Transportation Plan (RTP) and is used as a guideline in prioritizing for planning and funding of facilities in the Bay Area. Facilities included in the MTS provide access to major Bay Area activity centers, supply convenient and efficient connections, and/or provide alternative routes or modes for congested areas or regions with limited facilities.

Local
City of American Canyon
General Plan
The City of American Canyon General Plan (General Plan) sets forth the following guiding and implementing policies relevant to transportation:

Guiding Policy 1.1 Community Priorities. Safe and convenient access to activities in the community is provided by a well-designed local roadway system. That system serves the community’s primary need for mobility and includes a planned hierarchy of roadways to meet that need. The following Community Priorities relate most directly to this Element:
- Encourage and foster a strong sense of community and safety, as well as the “hometown” feeling by creation of a town center through land use and circulation planning.
- Improve a hierarchy of roadway networks to achieve and maintain acceptable traffic LOS and provide a citywide system of bicycle lanes and recreational trails that improve accessibility without the use of an automobile. - Improve SR-29 so that it serves as a visually attractive gateway into the City while providing access to commercial businesses and serving intra and interregional traffic and goods movement.

Guiding Policy 1.2 Implement planned roadway improvements. Use Figure 3: General Plan Circulation System, and Table 3: Major Circulation Improvements, to identify, schedule, and implement roadway and complimentary intersection improvements to support General Plan buildout conditions. Planned improvements may be phased as development occurs and need for increased capacity is identified.

Guiding Policy 1.3 Design circulation system to focus regional travel on SR-29. SR-29 is important for both Citywide and north–south regional travel. As both City and regional travel grow, design the City circulation system to discourage regional traffic from bypassing SR-29 and impacting City streets. Also, cooperatively work with regional partners, including Caltrans, NCTPA and others explore a complete streets approach that will expand the travel capacity of SR-29.

Guiding Policy 1.6 Achieve and maintain a Multimodal LOS D or better for roadways and intersections during peak-hours where possible and as long as possible. 562
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The following locations that may not achieve or maintain LOS D are as follows and therefore will be exempt from the LOS D policy:
- State Route 29 through the City
- American Canyon Road from SR-29 to Flosden Road–Newell Drive - Flosden Road south of American Canyon Road
Guiding Policy 1.9 Use of existing facilities. Make efficient use of existing transportation facilities, and improve these facilities as necessary in accordance with the Circulation Map.

Guiding Policy 1.11 Reduce Vehicle Miles Traveled. Through layout of land uses, improved alternate modes, and provision of more direct routes, strive to reduce the total vehicle miles traveled by City residents.

Guiding Policy 1.12 Circulation System Enhancements. Achieve, maintain and/or improve mobility in the City by considering circulation system enhancements beyond improvements identified on the Circulation Map, where feasible and appropriate. Improve the circulation system, in accordance with the Circulation Map, at minimum, to support multimodal travel of all users and goods and where feasible, apply creative circulation system enhancements that increase system capacity and that are acceptable to the City and its residents and where applicable, Caltrans.

Implementing Policy 1.14
Work with Caltrans on highway improvements. Continue to work with the Caltrans to achieve timely context sensitive design solutions, funding, and construction of programmed highway improvements.

Implementing Policy 1.17
Regional fair-share fee program. Work with Caltrans, NCTPA, Napa County, and other jurisdictions to establish a fair-share fee program for improvements to routes of regional significance and State highways. This fee should reflect traffic generated by individual municipalities/unincorporated communities as well as pass-through traffic.
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3.12-10 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-12 Transportation.docx Implementing Policy 1.24
Impacts of new development. Based upon the findings of a transportation impact analysis, consistent with Guiding Policy 1.26, new development will be responsible for mitigation of transportation-related impacts.

Implementing Policy 1.35
General transit and pedestrian access. In reviewing designs of proposed developments, ensure that provision is made for access to current and future public transit services. In particular, pedestrian access to arterial and collector streets from subdivisions should not be impeded by continuous segments of sound walls.

Guiding Policy 2.1 Promote walking and bicycling. Promote walking and bike riding for transportation, recreation, and improvement of public and environmental health.

Guiding Policy 2.3 Develop a safe and efficient non-motorized circulation system. Provide safe and direct pedestrian routes and bikeways between places.

Implementing Policy 2.7
Universal design. Provide pedestrian facilities that are accessible to persons with disabilities and ensure that roadway improvement projects address accessibility by using universal design concepts.

Implementing Policy 2.18
Pedestrian connections to employment destinations. Encourage the development of a network of continuous walkways within new commercial, town center, public, and industrial uses to improve workers’ ability to walk safely around, to, and from their workplaces. Where possible, route pedestrians to grade separated crossings over State Route 29.

Guiding Policy 3.1 Promote safe, efficient, and convenient public transportation. Promote the use of public transportation for daily trips, including to schools and workplaces, as well as other purposes.

Guiding Policy 4.1 Promote safe and efficient goods movement. Promote the safe and efficient movement of goods via truck and rail with minimum disruptions to residential areas.

Guiding Policy 4.2 Promote railroad safety. Minimize the safety problems associated with the railroad, including the construction and maintenance of at-grade crossings and the physical barrier effect of the track alignment on the City.

Guiding Policy 4.4 New truck route designation. All highways, arterials, and industrial streets shall be designated truck routes.
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-12 Transportation.docx Guiding Policy 4.6 Location of industrial development. Continue industrial expansion in the north industrial area to minimize the neighborhood impacts of truck movements.

Guiding Policy 4.7 Secure truck parking. Encourage high-security off-street parking for tractortrailer rigs in industrial designated areas.

Performance Standards
The General Plan Circulation Element specifies minimum LOS standards for all streets and intersections in the City’s jurisdiction. In Section 4.1.6, the City establishes the following performance standards for acceptable LOS for purposes of compliance with its General Plan:

Achieve and maintain a Multimodal LOS D or better for roadways and intersections during peak-hours where possible for as long as possible. However, recognizing that LOS D may not be achievable or cannot be maintained upon full buildout of the General Plan, due to traffic generated from sources beyond control of the City, the City Council shall have the discretion to only require feasible mitigation measures that may not achieve LOS D, but will reduce the impact of any development use or VMT planned for in the Land Use Element of the General Plan.

The locations that may not achieve or maintain LOS D are as follows and will be exempt from the LOS D policy:
• SR-29 through the City
• American Canyon Road from SR-29 to Flosden Road–Newell Drive • Flosden Road south of American Canyon Road

3.12.4 - Methodology
W-Trans prepared a Traffic Impact Study for the proposed project, which is provided in its entirety in Appendix H. The methodology is summarized as follows:

Trip Generation
The anticipated trip generation for the proposed project was estimated using standard rates published by the Institute of Transportation Engineers (ITE) in Trip Generation Manual, 10th Edition, 2017 for a “High-Cube Transload and Short-Term Storage Warehouse” (Land Use No. 154). The project would be comprised of multiple warehouse buildings with a combined size of between 2.2 and 2.4 million square feet. To be conservative, the maximum size of 2.4 million square feet was used to estimate the trip generation. The project is not anticipated to generate any internal capture trips, pass-by trip credits or any other trip reductions. The number of truck trips associated with a high-cube warehouse was estimated using rates published in the Trip Generation Manual and validated using local vehicle classification counts conducted in June 2021.

As shown in Table 3.12-5, the proposed project is expected to generate an average of 3,888 net-new Passenger Car Equivalent (PCE) trips per day, including 240 trips during the AM peak-hour and 264 during the PM peak-hour. These new trips represent the increase in traffic associated with the 565
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3.12-12 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-12 Transportation.docx project compared to existing volumes. To account for the effect of heavy vehicles (such as tractor trucks), a heavy vehicle adjustment factor was applied to convert truck trips to an equivalent passenger car trip total. The (PCE) factor for heavy vehicles is assumed to be 2.0 (i.e., each tractor truck has the effect of two passenger cars due to longer start up times at intersections and when making turns). Thus, the number of truck trips per hour was multiplied by 2.0 to determine the equivalent passenger car trips per hour.

Table 3.12-5: Trip Generation Summary
Land Use Category Units
Daily AM Peak-hour PM Peak-hour
Rate Trips Rate Trips In Out Rate Trips In Out
High-cube
Warehouse
Vehicles (Trucks +
Passenger Cars)
2,400 ksf 1.40 3,360 0.08 192 148 44 0.10 240 67 173
Trucks 0.22 528 0.02 48 37 11 0.01 24 7 17
Passenger Cars – 2,832 – 144 111 33 – 216 60 156
Trucks (Passenger
Car Equivalents)
– 1,056 – 96 74 22 – 48 14 34
Total – 3,888 – 240 185 55 – 264 74 190
Notes:
ksf = 1,000 square feet
Source: W-Trans 2021.

Trip Distribution
The pattern used to allocate new project trips to the street network was determined by reviewing likely routes for employees, visitors, and deliveries. The directionality experienced on SR-29 during the morning and evening commute periods was considered in developing the proposed assumptions. Based on the assumptions shown in Table 3.12-6, the following distribution was applied. Exhibit 3.12-3 depicts project traffic volumes.

Table 3.12-6: Trip Distribution Assumptions
Route
AM PM
Percent Trips Percent Trips
To/From North on SR-29 50% 120 55% 145
To/From South on SR-29 50% 120 45% 119
Total 100% 240 100% 264
Source: W-Trans 2021.
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3.12.5 - Thresholds of Significance
Appendix G to the CEQA Guidelines is a sample Initial Study Checklist that includes questions for determining whether impacts related to transportation are significant. These questions reflect the input of planning and environmental professionals at the OPR and the California Natural Resources Agency, based on input from stakeholder groups and experts in various other governmental agencies, nonprofits, and leading environmental consulting firms. As a result, many lead agencies derive their significance criteria from the questions posed in Appendix G. The City has chosen to do so for this project. Thus, the proposed project would have a significant effect related to transportation if the proposed project would:
a) Conflict with a program plan, ordinance or policy of the circulation system, including transit, roadway, bicycle and pedestrian facilities.
b) Conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b). c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment). d) Result in inadequate emergency access.

3.12.6 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the proposed project and provides mitigation measures where necessary.

Circulation System
Impact TRANS-1: The proposed project would not conflict with a program plan, ordinance or policy of the circulation system, including transit, roadway, bicycle and pedestrian facilities.

As explained above, CEQA no longer permits lead agencies to assess the significance of transportation-related effects in terms of the potential worsening of LOS. Yet many agencies, including the City of American Canyon, continue to be concerned about LOS, and have General Plan policies, such as Guiding Policy 1.6. The analysis of LOS-related impacts set forth below has been prepared for purposes of addressing General Plan consistency. The analysis was not undertaken pursuant to CEQA and is not a CEQA analysis. In contrast, the analyses dealing with transit, bicycle, and pedestrian facilities and policies are CEQA analyses.

Impact Analysis
Phases 1 and 2
Existing Plus Project Conditions
Upon the addition of project-related traffic to the Existing volumes, all study intersections are expected to continue operating at LOS C or better. These results are summarized in Table 3.12-7.

Exhibit 3.12-4 depicts Existing Plus Project traffic volumes 567
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3.12-14 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-12 Transportation.docx Table 3.12-7: Existing Plus Project Peak-hour Intersection Levels of Service Study Intersection
AM
Peak-hour
PM
Peak-hour
AM
Peak-hour
PM
Peak-hour
Delay LOS Delay LOS Delay LOS Delay LOS

1. SR-29/South Kelly Road 34.6 C 15.9 B 34.7 C 16.7 B

2. Devlin Road/South Kelly Road 7.8 A 8.0 A 8.4 A 7.9 A

3. Devlin Road/Green Island Road
Southbound Approach – – – – 0.512.1
A
B

1.4 12.7
A
B

4. Paoli Loop Road/Green Island Road
Northbound Approach

4.9 13.3
A
B

3.1 13.5
A
B

7.5 17.9
A
C

4.0 18.1
A
C
Notes:

LOS = Level of Service
Study intersection No. 3 Devlin Road/Green Island Road did not exist in 2015-2020.

Source: W-Trans 2021.

Future Conditions
Future (2040) AM and PM peak-hour volume projections for SR-29/South Kelly Road were derived from a buildout analysis which is contained in the Napa Junction III Transportation Impact Analysis Report, Omni-Means, LTD, 2011; this scenario represents cumulative traffic conditions that would be expected upon build out of the land uses identified in the General Plan. Although some of the anticipated development included in this previous effort may already be complete and occupied, to provide a conservative estimate of future operation the incremental increase in trips associated with build out of the City of American Canyon under its current General Plan was added to current volumes to determine Future (year 2040) operating conditions without the project. A growth rate was then created for the intersection of SR-29/South Kelly Road based on the volumes for this location in the Napa Junction III Transportation Impact Analysis Report.

Because the west side of SR-29 is already nearly built out other than the project site, and so would be expected to experience considerably less of an increase in traffic compared to SR-29, a growth rate of 1 percent per year was used to develop future AM and PM peak-hour volumes for the study intersections located west of SR-29.

Under the anticipated Future volumes, the study intersections are expected to operate acceptably during the AM and PM peak-hours except for SR-29/South Kelly Road, which is expected to operate at LOS F during both peak-hours. Future volumes are shown in Exhibit 3.12-5 and operating conditions are summarized in Table 3.12-8.

While the intersection of SR-29/South Kelly Road is projected to operate at LOS F during each peakhour, this operation was considered acceptable since SR-29 is exempt from the City’s LOS standard and Caltrans no longer applies an LOS standard. The City of American Canyon–Broadway District Specific Plan Draft Environmental Impact Report (EIR), FirstCarbon Solutions, 2017, states that there are future plans for SR-29 to have three through lanes in each direction through American Canyon.

Because funding has not been identified for this capacity enhancement, it was conservatively 568
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Furthermore, the future year analysis results for facilities along SR-29 (specifically, the intersection of SR-29/South Kelly Road) is deemed to be more conservative than what was presented for this intersection in the Watson Ranch Specific Plan EIR (September 2018) which indicated LOS C and D operation for the AM and PM peak-hours, respectively.

Future Plus Project Conditions
Upon the addition of project-generated traffic to the anticipated Future volumes, all unsignalized study intersections are expected to operate acceptably. SR-29/South Kelly Road would continue to operate at LOS F during both peak-hours. Future Plus Project traffic volumes are shown in Exhibit

3.12-6 and operating conditions are summarized in Table 3.12-8.

Table 3.12-8: Future Plus Project Peak-hour Intersection Levels of Service Study Intersection
AM
Peak-hour
PM
Peak-hour
AM
Peak-hour
PM
Peak-hour
Delay LOS Delay LOS Delay LOS Delay LOS

1. SR-29/South Kelly Road 107.4 F 84.3 F 107.0 F 88.7 F

2. Devlin Road/South Kelly Road 8.0 A 8.0 A 8.5 A 7.6 A

3. Devlin Road/Green Island Road
Southbound Approach – – – – 0.413.1
A
B

1.4 13.9
A
B

4. Paoli Loop Road/Green Island Road
Northbound Approach

5.2 14.3
A
B

3.1 13.4
A
B

7.8 19.3
A
C

3.7 16.7
A
C
Notes:

LOS = Level of Service
Study intersection No. 3 Devlin Road/Green Island Road did not exist in 2015-2020.

Source: W-Trans 2021.

As mentioned previously, there are future plans for SR-29 to have three travel lanes in each direction through American Canyon. As required by the City in their Traffic Impact Fee Program, the proposed project would pay a proportional share fee toward the cost of this planned future infrastructure improvement. As specific building projects move forward, each would be required to contribute to the funds needed for the planned improvements to SR-29 based on the City’s fee schedule. Impacts would be less than significant.

Transit
Existing stops are not within an acceptable walking distance of the site, which is generally considered to be 0.5 mile. Should an employee need to use transit, they could ride a bicycle along Devlin Road to the nearest transit stop at the intersection of Airport Boulevard/Devlin Road. This is consistent with the various City of American Canyon General Plan policies that promote transit accessibility.

Impacts would be less than significant.
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Existing bicycle facilities, including Class II bike lanes on Devlin Road between Middleton Way and South Kelly Road together with shared use of minor streets provide adequate access for bicyclists.

The proposed project would include bicycle lanes along the Devlin Road extension and a multimodal path along the north side of Green Island Road. The planned Class I and II bicycle facilities on South Kelly Road and Green Island Road, as well as the Napa Valley Vine Trail along Devlin Road, would improve bicycle connectivity near the project site. This is consistent with the various City of American Canyon General Plan policies that promote bicycle mobility. Impacts would be less than significant.

Pedestrian
Given the nature of the study area and the surrounding industrial land use, it is reasonable to assume that very few project patrons and employees will desire to walk to reach the project site.

There may, however, be a desire by employees to walk in the area for recreational purposes during break times or to reach nearby buildings. Upon completion of the project, sidewalks will be provided along Devlin Road between Green Island Road to South Kelly Road. The proposed project also includes the construction of a multimodal path along Green Island Road, which would be available for use by pedestrians. This is consistent with the various City of American Canyon General Plan policies that promote pedestrian mobility. 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.

Vehicle Miles Traveled
Impact TRANS-2: The proposed project would not conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)?
Impact Analysis
Phases 1 and 2
As discussed earlier, Senate Bill (SB) 743 (2013) directed OPR and the California Natural Resources Agency to establish a change in the metric to be applied for determining traffic impacts associated with development projects. Rather than the delay-based criteria associated with an LOS analysis, the increase in VMT because of a project would be the basis for determining impacts. The City of American Canyon has not yet established thresholds of significance related to VMT. The Napa County travel demand model is not currently available for use as a source for VMT analysis. In lieu of an established local methodology, the project-related VMT impacts were quantitatively assessed based on guidance provided by the OPR in the publication Transportation Impacts (SB 743) CEQA Guidelines Update and Technical Advisory, 2018.
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-12 Transportation.docx Based on a review of established policies currently used by the OPR, Sacramento County, and the City of San José, a VMT impact would be identified at an industrial project if the project VMT per employee is higher than the regional average VMT per employee. This focus on employee trips, as opposed to truck traffic associated with the proposed land uses, reflects the focus in CEQA Guidelines Section 15064.3 on VMT associated with automobiles and light trucks. That section states that “[g]enerally, vehicle miles traveled [VMT] is the most appropriate measure of transportation impacts.” It further states that VMT “refers to the amount of automobile travel and distance of automobile travel attributable to a project.” (Italics added.) As of the effective date of section 15064.3, “automobile delay, as described solely by level of service or similar measures of vehicular capacity or traffic congestion shall not be considered a significant impact on the environment pursuant to [CEQA],” with exceptions not relevant here (PRC § 21099(b)(2)).

At roughly the same time that section 15064.3 came into effect, OPR also published its “Technical Advisory on Evaluating Transportation Impacts in CEQA.” Going beyond the very limited guidance found in section 15064.3, this Technical Advisory provides specific recommendations on how to evaluate transportation impacts under CEQA. The OPR guidance provides detailed suggestions about how public agencies should meet their obligations to address VMT issues in transportation analyses for CEQA documents. The document is currently the best and most authoritative source of information about how to comply with section 15064.3. Notably, the 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, p. 4 [italics added].) Thus, OPR understands the requirement to address VMT as not reaching heavy-duty trucks. The focus on automobiles and not on heavy-duty 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(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 trucking.

For this study, the regional average VMT is defined as the nine county Bay Area average. As reported by the City of Vallejo in their CEQA Transportation Impact Analysis Guidelines (dated October 2020), the Nine County Bay Area Average VMT per employee is 23.00 miles per employee. According to Statewide Travel Demand Model estimates, the proposed project is located within a Traffic Analysis Zone (TAZ) with a projected VMT per employee of 16.24 miles. Because this per capita VMT rate is lower than the significance threshold of 23.0 miles, the proposed project would be considered to have a less than significant VMT impact. It is noted that a more conservative methodology sometimes used by OPR for other employment-based land uses (such as office buildings) states that a project generating a VMT that is 15 percent or more below the regional average VMT, or 19.55 miles, is presumed to have a less than significant VMT impact. If this methodology were applied, the project would be considered to have a less than significant VMT impact since the VMT per employee of 16.24 miles is less than the threshold of 19.55 miles. A summary of the VMT findings is provided in Table 3.12-9.
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-12 Transportation.docx Table 3.12-9: Vehicle Miles Traveled Summary
VMT Metric
Regional
Average/Significance
Threshold Project VMT Rate Significance
Employment VMT per Capita 23.00 16.24 Less than significant impact
Notes:

VMT = Vehicle Miles Traveled
Source: W-Trans 2021.

Level of Significance Before Mitigation
Less than significant impact.

Mitigation Measures
No mitigation is necessary.

Level of Significance After Mitigation
Less than significant impact.

Roadway Safety
Impact TRANS-3: The proposed project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment).

Impact Analysis
Phase 1
W-Trans evaluated site access and sight distance for Phase 1 of the proposed project.

Site Access
Vehicular access to Phase 1 would be provided via four driveways on Green Island Road and four driveways on the future extension of Devlin Road. Access to Phase 2 is anticipated to be provided via numerous full access driveways with connections to the Devlin Road extension. All driveways and internal roadways would be designed to current City standards to accommodate heavy vehicles and so can be expected to accommodate the access requirements for both emergency and passenger vehicles. Impacts would be less than significant.

Sight Distance
A substantially clear line of sight should be maintained between the driver of a vehicle waiting at a driveway and the driver of an approaching vehicle. Sight distances along Green Island Road from the project driveways were evaluated based on sight distance criteria contained in the Highway Design Manual published by Caltrans. The recommended sight distance for driveway approaches is based on stopping sight distance using the approach travel speed as the basis for determining the recommended sight distance. Based on the posted speed limit of 40 miles per hour (mph), the 572
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Impacts would be less than significant.

Phase 2
Phase 2 would take access from both Green Island Road and Devlin Road. Standard design and engineering practices would dictate that driveways would be aligned with those on the opposite side of both Green Island Road Devlin Road and spaced sufficiently from other driveways and the western Green Island Road railroad grade crossing to avoid conflicting turning movements or the creation of safety hazards. 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.

Emergency Access
Impact TRANS-4: The proposed project would not result in inadequate emergency access.

Impact Analysis
Phase 1
Vehicular access to Phase 1 would be provided via four driveways on Green Island Road and four driveways on the future extension of Devlin Road. Access to Phase 2 is anticipated to be provided via numerous full access driveways with connections to the Devlin Road extension. All driveways and internal roadways would be designed to current City standards to accommodate heavy vehicles and so can be expected to accommodate the access requirements for both emergency and passenger vehicles.

Furthermore, construction of the Devlin Road extension began in 2021 and, thus, it is expected to be completed by the time Phase 1 is completed. This would provide a parallel north–south route to SR29, which would be beneficial from an emergency response perspective. Impacts would be less than significant.

Phase 2
Vehicular access to Phase 2 would be provided by driveways on Green Island Road and Devlin Road.

Pursuant to the California Fire Code, a minimum of two points of access would need to be provided to each building. Compliance would ensure that adequate emergency response is provided. Impacts would be less than significant.
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Less than significant impact.

Mitigation Measures
No mitigation is necessary.

Level of Significance After Mitigation
Less than significant impact.
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GIOVANNONI LOGISTICS CENTER PROJECT

ENVIRONMENTAL IMPACT REPORT
Exhibit 3.12-1
Study Area and Lane Configurations
Source: W-Trans, 4/2021.
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ENVIRONMENTAL IMPACT REPORT
Exhibit 3.12-2
Existing Traffic Volumes
Source: W-Trans, 4/2021.
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ENVIRONMENTAL IMPACT REPORT
Exhibit 3.12-3
Project Traffic Volumes
Source: W-Trans, 4/2021.
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ENVIRONMENTAL IMPACT REPORT
Exhibit 3.12-4
Existing Plus Project Traffic Volumes
Source: W-Trans, 4/2021.
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Exhibit 3.12-5
Future Traffic Volumes
Source: W-Trans, 4/2021.
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ENVIRONMENTAL IMPACT REPORT
Exhibit 3.12-6
Future Plus Project Traffic Volumes
Source: W-Trans, 4/2021.
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3.13 - Utilities and Service Systems

3.13.1 - Introduction
This section describes the existing public services and utilities and potential effects from project implementation on the site and its surrounding area. Descriptions and analyses in this section are based on information provided by the City of American Canyon General Plan, the Water Supply Assessment (WSA) prepared by Balance Hydrologics on behalf of the City of American Canyon, and the City of American Canyon Sewer Master Plan. Supporting information is provided in Appendix I.

3.13.2 - Environmental Setting
Water
The City of American Canyon Public Works Department provides potable water and non-potable water to customers within the city limits as well as more than 160 customer accounts located outside the city limits.

Water Supply
American Canyon obtains its water supply from a variety of sources, all of which (except for recycled water) are imported from outside of the City. All of the City’s imported water comes through the North Bay Aqueduct system. Table 3.13-1 identifies the City’s current sources of water, which are discussed in detail after the table.

Table 3.13-1: Current Sources of Water Supply
Source
Contacted Volume/Capacity
(Acre-Feet/Year)
State Water Project (Table A Allotment)1 5,200
Vallejo Permit Water2 500
Vallejo Treated Water 2011-2015 2,074
2016-2021 2,640
2021-Onward 3,206
Vallejo Emergency Water3 500
Groundwater4 0
American Canyon Recycled Water5 1,271
Napa Sanitation District-Produced Recycled
Water 591
Notes:
1 Includes allotment for American Canyon and additional supply from Kern County Water Agency 2 Non-Table A Water 3 Available only in dry years 4 No groundwater is used for citywide supply 5 As reported 2015 Urban Water Management Plan (UWMP). Maximum capacity of the City’s recycled water treatment system by 2035.

Source: City of American Canyon 2021.
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A significant portion of the City’s supply is obtained through various indirect contracts for water from the State Water Project (SWP). The Napa Flood Control and Water Conservation District is the State Water Contractor with the California Department of Water Resources (DWR), and the City receives its water through subcontracts with the Napa Flood Control and Water Conservation District.

Table A Allocation
In January 1967, the American Canyon County Water Agency1 entered into an agreement with the Napa Flood Control and Water Conservation District for water supply from the North Bay Aqueduct. In 2010, the agreement allowed for the delivery of up to 5,200 acre-feet of water per year.2 This contract runs through 2035 with provisions for extension. The actual amount of SWP water available to the City under the “Table A” allocation process (the method used by the DWR to allocate water in the SWP system) varies from year-to-year due to hydrologic conditions, water demands of other contractors, SWP facility capacity, and environmental/regulatory requirements. Deliveries have varied between 5 percent (in 2014) and 100 percent (last occurring in 2006) of the contracted amount.

City of Vallejo
In 1996, the City of American Canyon entered into an agreement with the City of Vallejo to allow the purchase of additional water supply. Vallejo receives its water from a variety of sources, including SWP water and an appropriative water right. Under the Vallejo Agreement, a specific source is identified for Permit Water supply but not for Treated or Emergency Water.

Vallejo Permit Water (Raw)
The City of Vallejo holds an appropriative right for Sacramento Bay-Delta water from the California State Water Resources Control Board (State Water Board) that pre-dates the construction of the SWP. The City of American Canyon has an agreement with the City of Vallejo for delivery of up to 500 acre-feet of water under this permit. This source of water is more reliable than the City’s Table A supply, but the Vallejo Agreement still allows for reductions. Addendum 2 to the 1996 Vallejo Agreement states that “In the event the State Water Resources Control Board, or any other agency, restricts Vallejo’s diversion of water [under the appropriative pre-SWP contract] for any reason whatsoever, American Canyon’s diversions will be reduced in the same proportion.” As such, curtailment is typically less than that of the City’s Table A supply under environmental or other constraints, but the City may not receive its full allotment during dry years.3 Vallejo Treated Water (Potable)
In 1996, the City of American Canyon entered into an agreement with the City of Vallejo to purchase up to 629 acre-feet of potable treated water supply. This agreement included the option for additional (cumulative) purchases in 5-year increments through 2021. Ultimately, this results in a total of 3,206 acre-feet of treated water available for purchase each year by the City from Vallejo for 2021-2040.
1 A predecessor agency to the City of American Canyon, which was not incorporated until 1992. 2 A total of 500 acre-feet of this water was obtained through a purchase of water, by the Napa Sanitation District, from Kern County Water Agency in 2000. 3 Vallejo Permit Water delivery was curtailed in both 2014 and 2015, for example. 588
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Vallejo Emergency Water (Raw)
When the City’s Table A water allotment is curtailed, the City of American Canyon has the option to purchase up to 500 acre-feet of emergency raw water supply from Vallejo under an agreement amended in 1996. The 2015 Urban Water Management Program (UWMP) assumes that this water would be available under dry year and multiple dry year scenarios but not during a normal year.

Groundwater
The City of American Canyon does not currently rely on groundwater as a source of water, though the 2015 UWMP states that the City remains open to the possibility and will consider potential supply opportunities as they present themselves.

Other Sources of Potable Supply
Dry Year Water Bank
In 2009, the City of American Canyon (along with other SWP contractors) entered into an agreement with DWR to obtain emergency supplies if rice farmers in the Sacramento Valley are willing to make their supplies available. The year-to-year availability of this supply is not known, and thus supplies are not factored into long-term planning in the 2015 UWMP.

Turn-Back Water Pool Program
DWR has a program for interested SWP contractors called the Turn-back Water Pool Program. SWP contractors may choose to sell Table A water or purchase turn-back pool water that is available through the program. Water from this pool program was not included in the reliability assessment in the 2015 UWMP because the program operates on an as-available basis and long-term availability is not reliable.

The amount of pool water available to the City of American Canyon is not a significant amount. For example, during 2010 the City purchased 17 acre-feet, and in 2012 it purchased 64 acre-feet. However, between 2015-2020 the City did not purchase any water from the Turn-back Pool Program.

Napa Treated Water
The City has an agreement with the City of Napa for the purchase of treated (potable) water under emergency conditions, or when the North Bay Aqueduct system is off-line for maintenance or other reasons. This water source is not a water supply and is not included in the reliability assessment in the 2015 UWMP since it is only available during emergencies. Napa treated water, however, does provide operational flexibility (such as providing water to customers even when the City’s water treatment plant is off-line for an extended period of time). During 2010, the City purchased 306 acrefeet of treated water when the plant was off-line for maintenance-related issues. Under this informal arrangement, the Napa treated water purchase counts against the City’s SWP Table A allotment and is not an additional supply (and is not included in Table 3.13-1). 4 Vallejo Water Service Agreement. May 1, 1996 (Appendix E.4 in the 2005 American Canyon UWMP). 589
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During dry years, varying amounts of additional water may be made available to SWP contractors through DWR’s Dry Year Transfer Program, which allows for transfers through a combination of crop idling, groundwater substitution, and changes in reservoir operation. For example, in 2015 the City of American Canyon purchased 92 acre-feet of additional supply (for that year) through this program.

While this option is available to the City on a per year authorization, the long-term reliability of this supply is not known and included only as potential supplementary supply for the analysis in this WSA.

Yuba Accord
In 2008, the DWR adapted the Lower Yuba River Accord, an agreement to settle issues related to instream flows in the Yuba River and fisheries habitat. As part of that agreement, the DWR is able to purchase water from the Yuba River Water Agency to, in part, offer to participating SWP contractors as a transfer during dry years. The Napa County Flood Control and Water Conservation District has authorized the execution of Yuba Accord Dry-year Water Purchase Agreement, and the City of American Canyon has the option to purchase water through this agreement in dry years, though at a cost that is considerably higher than under normal conditions. In 2015, the City authorized the purchase of 124 acre-feet through this program to cover projected water supply shortfalls during the drought. While this option is available to the City in drought conditions, the availability and reliability of such water past 2020 is unknown,
5 and therefore has not been included as long-term reliable supply for the analysis in the WSA.

Recycled Water
American Canyon Recycled Water
In 2010, the City of American Canyon completed the first phase of its Recycled Water Distribution System Project, which included a one-million-gallon reservoir, distribution piping, and associated improvements at the City’s water treatment plant. Initially, 13 users were connected to the system and 73 acre-feet of water was delivered in 2010. Ultimately, the Recycled Water Master Plan in 2016 projected over 1,200 acre-feet of water demand at buildout in 2035 for landscaping and agricultural irrigation. However, utilization of this supply is dependent on connection of additional users and completion of additional distribution pipe segments. Currently, the City produces recycled water to meet demand on an as needed basis.

The City is currently taking steps to increase capacity of their system to meet this demand in the future. The analysis in the WSA uses 1,271 acre-feet per year (AFY) as the full system capacity by 2035, as reported in the 2015 UWMP.

Napa Sanitation District Recycled Water
In addition to the City’s recycled water supply, Napa Sanitation District (NapaSan) has an existing recycled water supply pipe that extends to northern portions of the Airport Industrial Area (north of Fagan Creek). In 2015, NapaSan provided 210 acre-feet of recycled water to the City’s users. The 2015 UWMP projected that NapaSan will provide up to 391 acre-feet of recycled water in 2020, up to 491 acre-feet in 2025, and 591 acre-feet in 2030 and onwards. 5 The original term of the Napa County Flood Control and Water Conservation District agreement was through the end of 2015, but an amendment in 2014 authorized an extension until the end of 2020. 590
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The City of American Canyon provides wastewater collection and treatment to customers in both the city limits and nearby parts of unincorporated Napa County. The wastewater service area is 6.3 square miles and could potentially be 8.5 square miles in the future.

Collection System
The City’s wastewater collection system consists of gravity pipelines (53 miles), force mains (5 miles), and five pump stations that convey wastewater to the City’s Water Reclamation Facility located near the Napa River. The City’s system operates its collection system to segregate domestic water from high strength industrial wastewater flows. The Kimberly Pump Station and the Sunset Meadows Pump Station collect wastewater from residential areas and deliver 75 percent of the flow to the wastewater treatment plant. The Tower Road and Green Island Sewer Pump Stations transport wastewater from industrial areas in the northern part of the City. These two stations discharge a combination of domestic and industrial wastewater to a common force main and deliver the remaining 25 percent of the flow to the Water Reclamation Facility.

Green Island Pump Station
The project site is located within the Green Island Pump Station sewershed. The pump station’s sewershed is 2.3 square miles and has a capacity of 600 gallons per minute (gpm). The City’s Sewer Master Plan contemplates replacing the pump station with a new facility sized for 1,455 gpm.

Existing Sewer Facilities
An existing 18-inch diameter force main that connects the Tower Road Pump Station with the Green Island Pump Station crosses the western portion of the project site.

Planned Sewer Facilities
The City’s Sewer Master Plan contemplates a new 21-inch diameter gravity sewer line that would follow the planned extension of Devlin Road between Middleton Way (Napa Logistics Park) and Green Island Road. From there, the sewer line would continue west to the new Green Island Pump Station. Once operational, the existing 18-inch diameter force main that crosses the project site would be abandoned, along with the Tower Road Pump Station.

Water Reclamation Facility
The American Canyon Water Reclamation Facility is owned and operated by the City of American Canyon. The facility treats both domestic and industrial wastewater flows and is a secondary/tertiary treatment plant. It began operations in 2002 and employs a Membrane Bio Reactor and ultraviolet light disinfection. The treatment plant has an existing design capacity of 2.5 million gallons per day (mgd). The City has plans to expand the Water Reclamation Facility’s treatment capacity to 4.0 mgd.

Approximately 17 percent of total influent inflow received at the Water Reclamation Facility becomes recycled water. In 2019, 282 acre-feet of recycled water were delivered to various users for non-potable use. The remaining effluent is treated and discharged to the Napa River. 591
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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 discharge flows into the Napa River. The City maintains a Storm Drain Master Plan and engineering standards that guide the development of the municipal storm drainage system.

The City requires stormwater discharges to comply with San Francisco Bay Regional Water Quality Control Board (San Francisco Bay RWQCB) permit requirements and establishes non-point source pollution control measures as required by federal and State law. Stormwater pollution prevention measures for new development projects, such as bioswales, detention ponds, erosion, and sedimentation control, are incorporated in the planning, design, construction, and operation of projects with the potential to create pollutants in stormwater runoff.

Project Site Drainage
The project site does not contain any formal storm drainage facilities. Runoff from the project site either ponds on-site or sheet flows toward No Name Creek in the northern portion of the site.

Solid Waste
American Canyon Recology provides garbage pickup for all residents and businesses pursuant to a franchise waste hauling agreement with the City of American Canyon. Roll-off service is also available.

Devlin Road Transfer Station
American Canyon Recology transports solid waste to the Devlin Road Transfer Station within the Napa County Airport Industrial Area. The Transfer Station is owned by the Napa-Vallejo Waste Management Authority (NVWMA), a joint-powers agency consisting of the cities of American Canyon, Napa, and Vallejo, and the County of Napa. The Transfer Station accepts municipal solid waste and construction and demolition (C&D) debris. The NVWMA has plans to construct an enclosed C&D Debris Recycling Facility on a vacant parcel it owns immediately south of the Devlin Road Transfer Station.

Potrero Hills Landfill
Municipal solid waste and demolition debris from the Devlin Road Transfer Station are landfilled at the Potrero Hills Landfill in Solano County. The Potrero Hills Landfill, located approximately 1 mile south of Suisun City, is a regional facility that serves numerous jurisdictions within a 150-mile radius.

In 2005, the County of Solano approved a 260-acre expansion that increased capacity to 83.1 million cubic yards. In 2010, the San Francisco Bay Conservation and Development Commission (BCDC) issued a permit allowing the expansion to proceed. Following the conclusion of litigation, the expansion was cleared to move forward in 2014. Table 3.13-2 summarizes the Potrero Hills Landfill. 592
City of American Canyon—Givannoni Logistics Center Project Draft EIR Utilities and Service Systems
FirstCarbon Solutions 3.13-7
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-13 Utilities.docx Table 3.13-2: Potrero Hills Landfill Summary
Permitted
Area
Permitted Daily
Throughput
Permitted
Disposal
Capacity
Remaining
Capacity
Permitted Hours
of Operation
Permitted Traffic
Volume
Estimated
Closure Date
525.7 acres
(total)
3,400 tons
(7-day average)

83.1 million
cubic yards

38.8 million
cubic yards
MondayFriday: 24
hours a day
500 inbound daily
vehicles
(7-day average)
2048
340.0 acres
(disposal)
4,330 tons
(single day peak)
SaturdaySunday: 4:00
a.m. to 12:00
a.m.
1,000 inbound
daily vehicles
(single day peak)
Note:

Data obtained from Solid Waste Facility Permit No. 48-AA-0075 Source: California Department of Resources Recycling and Recovery (CalRecycle) 2021.

3.13.3 - Regulatory Framework
Federal
National Pollutant Discharge Elimination System
Pursuant to Section 402 of the Clean Water Act and the Porter-Cologne Water Quality Control Act, municipal stormwater discharges in Suisun City are regulated under the San Francisco Bay Region Municipal Regional Stormwater National Pollutant Discharge Elimination System (NPDES) Permit, MS4 Order No. 2013-001 (General Permit). In 1987, Congress amended the Clean Water Act to mandate controls on discharges from Municipal Separate Storm Sewer Systems (MS4s). Acting under the federal mandate and the California Water Code, RWQCBs require cities, towns, and counties to regulate activities that can result in pollutants entering their storm drains. All municipalities prohibit non-stormwater discharges to storm drains and require residents and businesses to use Best Management Practices (BMPs) to minimize the amount of pollutants in runoff. The Municipal Regional Permit is overseen by the San Francisco Bay RWQCB. On February 5, 2013, the State Water Board reissued the Phase II Stormwater NPDES Permit for small MS4s. Provision E.12, “PostConstruction Stormwater Management Program,” mandates municipalities to require specified features and facilities–to control pollutant sources, to control runoff volumes, rates, and durations, and to treat runoff before discharge from the site–be included in development plans of projects that create or replace 5,000 square feet or more impervious surface as conditions of issuing approvals and permits. The new requirements continue a progression of increasingly stringent requirements since 1989.

Provision E.12 requires all municipal permittees to implement these requirements by June 30, 2015, to the extent allowed by applicable law. This includes projects requiring discretionary approvals that have not been deemed complete for processing and discretionary permit projects without vesting tentative maps that have not requested and received an extension of previously granted approvals.

3.13-8 FirstCarbon Solutions
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Section E.12.c of the General Permit pertains to LID and how it relates to hydromodification management. This permit provision requires that stormwater discharges not cause an increase in the erosion potential of the receiving stream over the existing condition. Increases in runoff flow and volume must be managed so that the post-project runoff does not exceed estimated pre-project rates and durations, where such increased flow and/or volume is likely to cause increased potential for erosion of creek beds and banks, silt pollutant generation, or other adverse impacts on beneficial uses due to increased erosive force.

State
California Urban Water Management Planning Act
The Urban Water Management Planning Act (California Water Code §§ 10610–10656) requires that all urban water suppliers prepare UWMPs and update them every 5 years. In preparing a UWMP, an urban water supplier must describe or identify the following, among other things (as set forth in Water Code § 10631):
• “The service area of the supplier, including current and projected population, climate, and other demographic factors affecting the supplier’s water management planning.” • “Projected population estimates” based on “data from the State, regional, or local service agency population projections within the service area,” in “five-year increments to 20 years or as far as data is available.”
• “Past and current water use” and “projected water use.” • “Existing and planned sources of water” for each five-year increment of the 20-year planning period.
• Specific detailed information about groundwater where it is identified as “an existing or planned source of water available to the supplier.”
• “All water supply projects and water supply programs” that may be undertaken to meet “total projected water use,” including “specific projects” and the “increase in water supply” expected from each project.
• An estimate of “the implementation timeline for each project or program.” • “Plans to supplement or replace” any “water source that may not be available at a consistent level of use, given specific legal, environmental, water quality, or climatic factors” with “alternative sources or water demand management measures, to the extent practicable.” • “The reliability of the water supply and vulnerability to seasonal or climatic shortage, to the extent practicable,” for (i) an “average water year,” (ii) a “single dry water year,” and (iii) “[m]ultiple dry water years.”
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Senate Bill 610: Water Supply Assessments
As revised by Senate Bill (SB) 610 (Stats. 2002, ch. 643), Section 10910, et seq. of the California Water Code set forth the circumstances in which California Environmental Quality Act (CEQA) lead agencies must seek preparation of, or prepare themselves, “water supply assessments” for defined proposed “projects.” At the time a lead agency determines that a proposed project requires an Environmental Impact Report (EIR), the lead agency shall identify any “public water system” that would serve the project site and shall request that any such entity prepare a WSA for the project. In the absence of such a public water system, the city or county lead agency must prepared its own WSA. SB 610 functions together with CEQA, in that a WSA must be included in “any environmental document” for any “project” subject to SB 610 (Water Code Section 10911(b); see also State CEQA Guidelines Section 15155(e); see also Id. Section 15361 [defines “environmental documents” to include “Negative Declarations. . . [and] draft and final EIRs”]).

One of the fundamental tasks of a WSA is to determine whether “total projected water supplies available during normal, single dry, and multiple dry water years during a 20-year projection will meet the projected water demand associated with the proposed project, in addition to the public water system’s existing and planned future uses, including agricultural and manufacturing uses” (Water Code Section 10910 (c)(3), (c)(4)). In making such a determination, the authors of the WSA must address several factors. Specifically, the WSA must contain information regarding existing water supplies, projected water demand, and dry year supply and demand. In Vineyard Area Citizens for Responsible Growth v. City of Rancho Cordova (2007) 40 Cal.4th 412, 433 (“Vineyard”), the California Supreme Court briefly summarized the key content requirements as follows:

With regard to existing supply entitlements and rights, a water supply assessment must include assurances such as written contracts, capital outlay programs and regulatory approvals for facilities construction . . . but as to additional future supplies needed to serve the project, the assessment need include only the public water system’s plans for acquiring the additional supplies, including cost and time estimates and regulatory approvals the system anticipates needing (Water Code §§ 10910, subd. (d)(2), and 10911, subd. (a)). (Original italics.)
“Existing” water supplies can be based on different kinds of legal rights or arrangements, including entitlements, water rights, and water service contracts. In many cases, these supplies are likely already described in detail in the supplier’s UWMP (Water Code § 10631(b)). Suppliers are expressly permitted to rely on information contained in the most recently adopted UWMPs, provided that the water needed for proposed development project was accounted for therein (Water Code § 10910(c)(2)).
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3.13-10 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-13 Utilities.docx In preparing a WSA, the public water system must disclose and document the quantity of water received from these various sources. Such supplies must be demonstrated by providing the following:
(A) Written contracts or other proof of entitlement to an identified water supply. (B) Copies of a capital outlay program for financing the delivery of a water supply that has been adopted by the public water system.
(C) Federal, State, and local permits for construction of necessary infrastructure associated with delivering the water supply.
(D) Any necessary regulatory approvals that are required in order to be able to convey or deliver the water supply.
(Id. subd. (d)(2)).

A finding of insufficiency in a WSA does not require a city or county to deny or downsize a proposed development project. Rather, after identifying a shortfall, the public water system must provide its plans for acquiring “additional supplies” (or what the California Supreme Court called “future” supplies) (Water Code § 10911(a)). These plans should include information concerning the following:
(1) The estimated total costs, and the proposed method of financing the costs, associated with acquiring the additional water supplies. (2) All federal, State, and local permits, approvals, or entitlements that are anticipated to be required in order to acquire and develop the additional water supplies. (3) Based on the considerations set forth in paragraphs (1) and (2), the estimated timeframes within which the public water system, or the city and county . . . expects to be able to acquire additional water supplies.

These particular Water Code requirements for assessments are action-forcing, in that they require the public water system to lay out a roadmap for obtaining new water supplies once it becomes aware that existing supplies are insufficient for the proposed project together with other foreseeable planned growth.

Regardless of the information provided to a city or county in a WSA, SB 610 stops short of preventing cities and counties from approving the “projects” at issue absent “sufficient” water supplies. But where “existing water supply entitlements, water rights, or water service contracts” are “insufficient” to serve proposed projects, SB 610 does require that, in approving projects in the face of insufficient supplies, cities and counties must “include” in their “findings for the project[s]” their “determination[s]” regarding water supply insufficiency. SB 610 functions together with CEQA, in that a water supply assessment must be included in “any environmental document” for any “project” subject to SB 610. (Id. subd. (b); Guidelines, § 15155, subd. (e); see also id. § 15361 [defines “environmental documents” to include “Negative Declarations. . . [and] draft and final EIRs”]).
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City of American Canyon—Givannoni Logistics Center Project Draft EIR Utilities and Service Systems
FirstCarbon Solutions 3.13-11
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-13 Utilities.docx Recycled Water Policy
On February 3, 2009, by Resolution No. 2009-0011, the State Water Board adopted a Recycled Water Policy in an effort to move toward a sustainable water future. The Recycled Water Policy states “we declare our independence from relying on the vagaries of annual precipitation and move toward sustainable management of surface waters and groundwater, together with enhanced water conservation, water reuse and the use of stormwater.”
The following goals were included in the Recycled Water Policy:
• Increase use of recycled water over 2002 levels by at least 1 million AFY by 2020 and at least 2 million AFY by 2030.
• Increase the use of stormwater over use in 2007 by at least 500,000 AFY by 2020 and at least 1 million AFY by 2030.
• Increase the amount of water conserved in urban and industrial areas by comparison to 2007 by at least 20 percent by 2020.
• Included in these goals is the substitution of as much recycled water for potable water as possible by 2030.

The Recycled Water Policy provides direction to the RWQCBs regarding issuing permits for recycled water projects, addresses the benefits of recycled water, addresses a mandate for use of recycled water and indicates the State Water Board will exercise its authority to the fullest extent possible to encourage the use of recycled water.

The Recycled Water Policy also indicates that some groundwater basins contain salts and nutrients that exceed or threaten to exceed water quality objectives established in basin plans and states that it is the intent of this Recycled Water Policy that all salts and nutrients be managed on a basin-wide or watershed-wide basis through development of regional or subregional management plans. Finally, the Recycled Water Policy addresses the control of incidental runoff from landscape irrigation projects, recycled water groundwater recharge projects, anti-degradation, control of emerging constituents and chemicals of emerging concern and incentives for use of recycled water.

In accordance with the provisions of the Recycled Water Policy, a Constituents of Emerging Concerns Advisory Panel was established to address questions about regulating constituents of concern (COCs) with respect to the use of recycled water. The Advisory Panel’s primary charge was to provide guidance for developing monitoring programs that assess potential COC threats from various water recycling practices, including groundwater recharge/reuse and urban landscape irrigation. On June 25, 2010, the Advisory Panel provided recommendations to the State Water Board and California Department of Public Health in their Final Report “Monitoring Strategies for Chemicals of Emerging Concern in Recycled Water – Recommendations of a Scientific Advisory Panel”. The State Water Board used those recommendations to amend the Recycled Water Policy in 2013 (State Water Board Resolution No. 2013-003).

The April 2013 amendment provides direction to the RWQCBs on monitoring requirements for COCs in recycled water. The monitoring requirements pertain to the production and use of recycled water 597
City of American Canyon—Givannoni Logistics Center Project Utilities and Service Systems Draft EIR

3.13-12 FirstCarbon Solutions
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• Human health-based COCs: COCs of toxicological relevance to human health. • Performance indicator COCs: An individual COC used for evaluating removal through treatment of a family of COCs with similar physicochemical or biodegradable characteristics. • Surrogates: A measurable physical or chemical property, such as chlorine residual or electrical conductivity, that provides a direct correlation with the concentration of an indicator compound. Surrogates are used to monitor the efficiency of COC treatment.

Only groundwater recharge reuse facilities would be required to monitor for COCs and surrogates.

Surface application and subsurface application facilities would have different mandatory COCs and a different monitoring schedule. Monitoring is not required for recycled water used for landscape irrigation projects that qualify for streamlined permitting unless monitoring is required under the adopted salt and nutrient management plan. Streamlined permitting projects must meet the criteria specified in the Policy including compliance with Title 22, application at agronomic rates, compliance with any applicable salt and nutrient management plan, and appropriate use of fertilizers.

Water Conservation Act of 2009
Requirements regarding per capita water use targets are defined in the Water Conservation Act of 2009, which was signed into law in November 2009 as part of a comprehensive water legislation package. Known as SB X7-7, the legislation sets a goal of achieving a 20 percent reduction in urban per capita water use Statewide by 2020. SB X7-7 requires that retail water suppliers define in their 2010 UWMPs the gallons per capita per day targets for 2020, with an interim 2015 target.

Assembly Bill 1881
Assembly Bill (AB) 1881 expanded previous legislation related to landscape water use efficiency. AB 1881, the Water Conservation in Landscaping Act of 2006, enacted landscape efficiency recommendations of the California Urban Water Conservation Council for improving the efficiency of water use in new and existing urban irrigated landscapes in California. AB 1881 required the DWR to update the existing Model Local Water Efficient Landscape Ordinance and local agencies to adopt the updated model ordinance or an equivalent. The law also requires the California Energy Commission (CEC) to adopt performance standards and labeling requirements for landscape irrigation equipment, including irrigation controllers, moisture sensors, emission devices, and valves to reduce the wasteful, uneconomic, inefficient, or unnecessary consumption of energy or water.

Assembly Bill 2882
AB 2882 was passed in 2008 and encourages public water agencies throughout California to adopt conservation rate structures that reward consumers who conserve water. AB 2882 clarifies the allocation-based rate structures and establishes standards that protect consumers by ensuring a lower base rate for those who conserve water.
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City of American Canyon—Givannoni Logistics Center Project Draft EIR Utilities and Service Systems
FirstCarbon Solutions 3.13-13
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-13 Utilities.docx California Integrated Waste Management Act
To minimize the amount of solid waste that must be disposed of by transformation and land disposal, the State Legislature passed AB 939, the California Integrated Waste Management Act of 1989, effective January 1990. The legislation required each local jurisdiction in the State to set diversion requirements of 25 percent by 1995 and 50 percent by 2000; established a comprehensive Statewide system of permitting, inspections, enforcement, and maintenance for solid waste facilities; and authorized local jurisdictions to impose fees based on the types or amounts of solid waste generated. In 2007, SB 1016, Wiggins, Statutes of 2008, Chapter 343, introduced a new per capita disposal and goal measurement system that moves the emphasis from an estimated diversion measurement number to using an actual disposal measurement number as a per capita disposal rate factor. As such, the new disposal-based indicator (pounds per person per year) uses only two factors:
(1) a jurisdiction’s population (or in some cases employment) and (2) its disposal as reported by disposal facilities.

Assembly Bill 341 (75 Percent Solid Waste Diversion)
In 2011, the Legislature implemented a new approach to the management of solid waste. AB 341 (Chesbro, Chapter 476, Statutes of 2011) required that the California Department of Resources Recycling and Recovery (CalRecycle) oversee mandatory commercial recycling and established a new Statewide goal of 75 percent recycling through source reduction, recycling, and composting by 2020.

This paradigm adds to the policies in AB 939 in several significant ways. First, AB 341 established a Statewide policy goal, rather than a jurisdictional mandate. This places the onus for achieving the goal on the State rather than on the cities and counties that are directly responsible for waste disposal and recycling. Under the law, individual jurisdictions are not required to meet the new policy goal.

AB 341 requires CalRecycle to issue a report to the Legislature that includes strategies and recommendations that would enable the State to divert 75 percent of the solid waste generated in the State from disposal by January 1, 2020, requires businesses that meet specified thresholds in the bill to arrange for recycling services by January 1, 2012, and also streamlines various regulatory processes.

Title 24, California’s Energy Efficiency Standards for Residential and Nonresidential Buildings Title 24, Part 6, of the California Code of Regulations establishes California’s Energy Efficiency Standards for Residential and Nonresidential Buildings. The standards were updated in 2013. The 2013 standards set a goal of reducing growth in electricity use by 561.2 gigawatt-hours per year (GWh/y) and growth in natural gas use by 19 million therms per year. The savings attributable to new nonresidential buildings are 151.2 GWh/y of electricity savings and 3.3 million therms. For nonresidential buildings, the standards establish minimum energy efficiency requirements related to building envelope, mechanical systems (e.g., heating, ventilation, and air conditioning [HVAC]; and water heating systems), indoor and outdoor lighting, and illuminated signs. 599
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City of American Canyon
General Plan
The City of American Canyon General Plan sets forth the following goals and policies relevant to public services and utilities:

Goal 5 It shall be the goal of American Canyon to establish and maintain a secure water supply and treatment, distribution and storage system to serve the land uses proposed under the general plan.

Policy 5.2.5 In the event that sufficient capacity is not available to serve a proposed project, the City shall not approve the project until additional capacity or adequate mitigation is provided.

Goal 5C Establish and maintain adequate planning, construction, maintenance, and funding for storm drain and flood control facilities to support permitted land uses and preserve the public safety; upgrading existing deficient systems and expanding, where necessary, to accommodate new permitted development and to protect existing development in the City. Pursue public funding sources (i.e., grants) to reduce fiscal impacts of implementation to the City.

Policy 5.10.3 Require that adequate storm drain and flood control facilities be constructed coincident with new development.

Policy 5.10.12 Require that new development be designed to prevent the diversion of floodwaters onto neighboring parcels.

Policy 5.10.18 Require that development projects maximize the use of pervious surface materials (grass, ground cover, and other) that minimize stormwater runoff.

Goal 5D Maintain the quality of surface and subsurface water resources within the City of American Canyon.

Policy 5.12.2 Incorporate features in new drainage detention facilities which enhance the water quality of discharges from the facility.

Policy 5.13.1 Require that development activities comply with the State General Storm Water Permit for Construction Activities with measures that protect surface water quality to the maximum extent practicable.

Goal 6A Maintain a high level of fire protection and emergency services to City/District businesses and residents.

Goal 6B Ensure a high level of police protection for the City’s residents, businesses, and visitors.
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3.13.4 - Methodology
This section is based on the information provided by a number of sources, which are described below.

Balance Hydrologics prepared a WSA that evaluated water supply impacts in accordance with Water Code Section 10910. The WSA is provided in its entirety in Appendix I.

Additionally, FirstCarbon Solutions (FCS) reviewed relevant City documents, including the City of American Canyon General Plan, the Napa County Airport Industrial Area Specific Plan, the American Canyon Municipal Code, the City of American Canyon Sewer Master Plan, and the City of American Canyon Recycled Water Annual Report 2019. FCS also reviewed document and websites produced by the City of American Canyon and CalRecycle.

3.13.5 - Thresholds of Significance
Appendix G to the CEQA Guidelines is a sample Initial Study Checklist that includes questions for determining whether impacts related to utilities and service systems are significant. These questions reflect the input of planning and environmental professionals at the Governor’s Office of Planning and Research (OPR) and the California Natural Resources Agency, based on input from stakeholder groups and experts in various other governmental agencies, nonprofits, and leading environmental consulting firms. As a result, many lead agencies derive their significance criteria from the questions posed in Appendix G. The City has chosen to do so for this project. Thus, the proposed project would have a significant effect if it would:
a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects.
b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years. c) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments.
d) Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. e) Comply with federal, State, and local statutes and regulations related to solid waste.

On the subject of water supply, CEQA Guidelines Section 15155[f], which codifies the California Supreme Court’s decision in Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Cal.4th 412, sets forth additional analytical issues that must be addressed on the specific subject of water supply. “The analysis shall include the following:
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3.13-16 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec03-13 Utilities.docx (1) Sufficient information regarding the project’s proposed water demand and proposed water supplies to permit the lead agency to evaluate the pros and cons of supplying the amount of water that the project will need.
(2) An analysis of the reasonably foreseeable environmental impacts of supplying water throughout all phases of the project.
(3) An analysis of circumstances affecting the likelihood of the water’s availability, as well as the degree of uncertainty involved. Relevant factors may include but are not limited to, drought, salt- water intrusion, regulatory or contractual curtailments, and other reasonably foreseeable demands on the water supply.
(4) If the lead agency cannot determine that a particular water supply will be available, it shall conduct an analysis of alternative sources, including at least in general terms the environmental consequences of using those alternative sources, or alternatives to the project that could be served with available water.”
Each of these issues is addressed in the following analysis.

3.13.6 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the development of the project and provides mitigation measures where appropriate.

Water Supply
Impact USS-1: The proposed project would not require the City of American Canyon to obtain additional water supplies in order to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years.

Impact Analysis
Phases 1 and 2
Potable water demand for the project was estimated by CBG Engineers based on demand factors contained in the 2016 City of American Canyon Potable Water Master plan and is summarized in Table 3.13-3. These estimates were calculated using an average day demand of 0.015 gallons per day/square foot which is the average water use across all the industrial sector and believed to be an overly high estimate of water use for this project. Therefore, revised potable water use projections for the project were calculated using averages from other similar commercial warehouse projects with more in-depth water demand estimates and/or metered water usage.

Table 3.13-3: Estimated Project Water Demand
Project Feature
Building Floor Area
(Square Feet)
Acre-Feet Year
Potable
Water Use
Revised
Potable Water
Recycled
Water Use
Total
Water Use
Phase 1–Building A 601,383 10.1 6.1 20.8 30.9
Phase 1–Building A 468,521 7.9 4.7 16.2 24.1
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Building Floor Area
(Square Feet)
Acre-Feet Year
Potable
Water Use
Revised
Potable Water
Recycled
Water Use
Total
Water Use
Phase 2 1,300,000 21.8 13.1 45.0 66.9
Total 2,369,904 39.8 23.9 82.1 121.9
Notes:

Revised potable water use estimates based on average day demand of 0.009 gpd/sf. This is an average generated from three commercial water demand estimates.

Source: CBG Engineers 2021.

The Napa Airport Corporate Center (NACC) is an industrial warehouse development just north of the project site in the City of American Canyon. Multiple industrial warehouse buildings are planned in this development (Buildings B, D, E, G, and H). Details of the water demand estimates are reported in the NACC WSA report, with an estimated average day demand of 0.006 gpd/square foot. Similarly, the proposed Suisun Logistics Center is a planned industrial warehouse project in Fairfield, California, which is also owned and operated by Buzz Oates. The proposed Suisun Logistic Center used water meter data from similar Buzz Oates developments in Fairfield to project anticipated potable water demand. Using actual water use from four industrial developments, Suisun Logistics Center average day demand is estimated at 0.01 gpd/square foot (Appendix B). In order to provide a more realistic estimate of potable water demand for the proposed Giovannoni Logistics Center Project, the WSA prepared for the proposed project (see Appendix I) averaged various demand rates described above (CBG, NACC, and Suisun Logistics Center), resulting in an average day demand of 0.009 gpd/square foot. This revised average day demand was used to calculate a revised potable water use for the proposed project and is summarized in Table 3.13-3. The WSA estimates the total potable water demand of the proposed project at buildout to be 23.9 AFY (15.9 AFY less than the usage originally estimated by CBG Engineers).

For the purposes of the WSA, all indoor water demand is assumed to be from potable water. The applicant has not indicated that recycled water would be used for non-potable indoor uses, though that would remain an option to further reduce potable water demand at the site, should the applicant choose. Table 3.13-3 shows the estimated potable water demand for each building of the proposed project.

Recycled Water
The proposed project would use recycled water for all irrigation needs. Estimated recycled water use within the project is summarized in Table 3.13-3. The current project plans do not have estimates for the area of irrigated landscaping. The proposed project irrigation water demand was approximated by applying the average ratio of 0.604 between irrigated area and building footprint from the neighboring NACC project, with a demand factor of 2.5 acre-feet/acre (from Table 3.13 in the 2010 UWMP). These irrigation demand estimates may be high if the proposed project plans to landscape with xeric or native plant species that have lower-than-typical irrigation needs.

The recycled water usage estimates in Table 3.13-3 are intended to be used for environmental planning documentation. Actual use per building may vary based on final site plans, but total use is 603
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3.13-18 FirstCarbon Solutions
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Project Demand Comparison to Urban Water Management Plan Potable Water Demand
In order to project future systemwide water demand for the 2015 UWMP, the standard demand factors from the 2010 UWMP were used along with a variety of growth-rate estimates for various land-use sectors. For the commercial/industrial sector, the City analyzed the acreage of vacant land zoned for those uses, and applied a water use factor of 675 gallons/day/acre (gpd/acre) to each parcel. The project’s demand has been incorporated into long-term projections under an assumption of a buildout use of 675 gpd/acre (0.76 AFY per acre).

Table 3.13-4 compares the estimated project demand with the assumptions for the parcel included in the 2015 UWMP. Due to relatively low water use of warehouse space compared to industrial sector averages, the incorporation of recycled water for irrigation purposes, and the designation of a portion of the site for wetland preservation that would not require supplemental water supply, the proposed project is expected to use 133.3 AFY less water than expected under the 2015 UWMP growth scenario. Implementation of the City’s Zero Water Footprint Policy would result in an additional 23.9-acre-foot reduction in potable water demand relative to the UWMP systemwide demand analysis.

Table 3.13-4: Comparison of Estimated Water Demand to Urban Water Management Plan Phase
Acre-Feet Year
Potable Water Recycled Water
UWMP Project Difference ZWF Offset UWMP Project
1 71.6 10.8 (60.9) (10.8) – 37.1
2 85.6 13.1 (72.5) (13.1) – 45.0
Total 157.2 23.9 (133.3) (23.9) – 82.1
Notes:

UWMP = Urban Water Management Plan
ZWF = zero water footprint
The UWMP did not project irrigation demand on a parcel-by-parcel basis. Because project irrigation would be supplied by recycled water, comparison against projections in the UWMP is not necessary.

Source: Balance Hydrologics 2021.

Recycled Water
The American Canyon UWMP assumes irrigation use to be 2.5 acre-feet of water per acre of landscaping but (unlike for potable demand) did not project recycled water demand associated with particular parcels anticipated for development. Because recycled water use offsets demand for potable (or raw imported) water and it is in the City’s best interest to maximize use of recycled 604
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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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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 – – – – –
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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. 607
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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. 608
City of American Canyon—Givannoni Logistics Center Project Draft EIR Utilities and Service Systems
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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 5 609
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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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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 611
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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. 612
City of American Canyon—Givannoni Logistics Center Project Draft EIR Utilities and Service Systems
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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 613

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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. 615
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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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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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3.13-32 FirstCarbon Solutions
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 618
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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 619
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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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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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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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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 623
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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 624
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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 625
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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 627
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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. 628
City of American Canyon—Givannoni Logistics Center Project Draft EIR Cumulative Effects
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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 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 629
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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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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.

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 631
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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. 632
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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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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. 634
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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 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 635
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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. 636
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 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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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. 638
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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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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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City of American Canyon—Giovannoni Logistics Center Project Draft EIR Alternatives to 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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City of American Canyon—Giovannoni Logistics Center Project Alternatives to the Proposed Project Draft EIR
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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. 642
City of American Canyon—Giovannoni Logistics Center Project Draft EIR Alternatives to the Proposed Project
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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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City of American Canyon—Giovannoni Logistics Center Project Alternatives to the Proposed Project Draft EIR
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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.

Therefore, the Reduced Density Alternative would have similar cultural resources impacts as the proposed project.
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City of American Canyon—Giovannoni Logistics Center Project Draft EIR Alternatives to 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. 645
City of American Canyon—Giovannoni Logistics Center Project Alternatives to the Proposed Project Draft EIR
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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).
646
City of American Canyon—Giovannoni Logistics Center Project Draft EIR Alternatives to the Proposed Project
FirstCarbon Solutions 5-11
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. 647
City of American Canyon—Giovannoni Logistics Center Project Alternatives to the Proposed Project Draft EIR
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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 648
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 649
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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.

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 650
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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. 652
City of American Canyon—Giovannoni Logistics Center Project Draft EIR Alternatives to the Proposed Project
FirstCarbon Solutions 5-17
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec05-00 Alternatives.docx Hence, evaluating a Phase 2 Only Alternative would be illogical and out-of-sequence and, thus, it was rejected from further consideration.

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
653
City of American Canyon—Giovannoni Logistics Center Project Alternatives to the Proposed Project Draft EIR
5-18 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 Name Description Feasibility Determination
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.
654
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
655

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City of American Canyon—Giovannoni Logistics Center Project Draft EIR Other CEQA Considerations
FirstCarbon Solutions 6-1 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec06-00 Other CEQA.docx CHAPTER 6: OTHER CEQA CONSIDERATIONS

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.
657
City of American Canyon—Giovannoni Logistics Center Project Other CEQA Considerations Draft EIR
6-2 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5460/54600001/EIR/2 - Screencheck EIR/54600001 Sec06-00 Other CEQA.docx Direct growth-inducing impacts occur when the development of a project imposes new burdens on a community by directly inducing unplanned population growth, or by leading to the construction of additional developments in the same area. Also included in this category are projects that remove physical obstacles to population growth (such as a new road into an undeveloped area or a wastewater treatment plant with excess capacity that could allow additional development in the service area). Construction of these types of infrastructure projects cannot be considered isolated from the development they facilitate and serve. Projects that physically remove obstacles to growth, or projects that indirectly induce growth may provide a catalyst for future unrelated development in an area such as a new residential community that requires additional commercial uses to support residents.

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.

American Canyon City CouncilMarch 21, 2023

American Canyon City Council
March 21, 2023