American Canyon City Council
November 7, 2023

Prohibit mass grading on slopes greater than 25 percent; except where such slopes are isolated anomalies within a generalized slope pattern.

Minimize the size of flat pads in site grading, limiting flat areas to the building footprint and a reasonable amount of related outdoor space, in areas where natural grades are 15 percent or greater.

The natural topographic character of hillsides shall be maintained, including ridgelines, rounded hill forms and angled slopes.
1 Policy 9.4.2 is related to liquefaction and not to aesthetics. As such, this policy is not discussed further. 295
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Significant natural systems and resources shall be maintained and restored, including existing vegetation, wildlife habitat, special geological features, canyons and natural drainage swales, steep slopes and important historic or cultural features.

Encourage the use of materials that complement their setting.

Buildings in hillside areas shall be designed to a scale and form that complement hillside character. Building forms, including roof lines, shall step with hill forms to minimize the visibility of building profiles on slopes. As a general rule, gabled roof ridgelines should be angled to follow the same direction of contour lines, thus reducing the exposure of gable roof ends and the primary building mass when viewed from a distance.

Design retaining walls with smooth, flowing forms that follow topographical lines, thereby minimizing long straight stretches and sharp angular forms. Minimize the height of retaining walls by terracing hillsides.

Plant all hillside slopes with drought- tolerant species to soften the visual impact of grading, retaining walls, buildings and roads. All manufactured slopes shall be revegetated with ground cover, shrubs and trees, and follow a planting pattern similar to the natural vegetation patterns in the area.

Arrange trees and shrubs in informal masses to produce a textured slope similar to natural chaparral.

American Canyon Municipal Code
The Zoning Code (Title 19) of the American Canyon Municipal Code implements the General Plan, particularly the Land Use Element. While General Plan designations are more generalized in nature, the Zoning Code and zoning districts provide specific controls on land use, density or intensity of development, and development standards to implement the City’s General Plan goals and policies.

The Zoning Code provides standards for protection of visual resources, compatible design, and illumination for new development in the City that is associated with zoning. Zoning Code Title 19 establishes standards for development within the City. Zoning Code Chapter 19.23 provides a list of prohibited signage in the City. The California Green Building Code, which includes lighting requirements, has been adopted in Chapter 16.02 of the Municipal Code.

4.1.3 Impact Analysis
a. Significance Thresholds and Methodology
CEQA Significance Thresholds
Based on Appendix G of the CEQA Guidelines a project may be deemed to have a significant impact on aesthetics if it would:

Have a substantial adverse effect on a scenic vista;
Substantially damage scenic resources, including but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway;
In non-urbanized areas, substantially degrade existing visual character or quality of public views of the site and its surroundings? If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality; or, Create a new source of substantial light or glare that would adversely affect day or nighttime views in the area.
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Methodology
Aesthetics impact assessments involve qualitative analysis that is subjective but informed by the City policies detailed above. Reactions to the same aesthetic conditions vary according to viewer taste and interests but are basically governed by the visual compatibility with the surroundings and existing development, coherence with design guidelines established by the jurisdiction, and use of high-quality materials that blend into the landscape. Ultimately, development decisions that prescribe aesthetic or design treatments for specific projects fall under the purview of the American Canyon Planning Commission and appointed or elected bodies charged with overseeing development permits. This project involves an annexation and rezone of properties in areas of Napa County and does not constitute a specific development proposal. This analysis focuses, therefore, on a general discussion of the aesthetic impacts on the annexation area, in terms of the arrangement of built space to open space and how new development might visually fit with the existing landscape characteristic of the area.
b. Project Impacts and Mitigation Measures
Threshold 1: Would the project have a substantial adverse effect on a scenic vista? Impact AES-1 THE PROJECT WOULD NOT HAVE A SUBSTANTIAL ADVERSE EFFECT ON A SCENIC VISTA, INCLUDING VIEWS OF HILLS, AND IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Scenic vistas are considered expansive views from elevated positions, such as those from a roadway in the mountains, or views provided from a public place where the landscape is visible into the distance (e.g., looking at mountains across a field with little intervening development or vegetation).

American Canyon is characterized by a unique scenic beauty that combines agriculture and viticulture in flat valley floors extending into the rolling terrain of the foothills, redwood forests, and grazing lands.

The City has no designated scenic vistas or scenic viewpoints. General Plan Policy 8.18, however, identifies views of the hills and ridgelines surrounding the City as important visual resources. Hills and ridgelines surrounding the City include the Sulphur Springs foothills to the east and Oat Hill to the west. Views from SR 29 provide motorists with expansive, although fleeting, views of these hills.

In addition, expansive scenic views of the City and surrounding natural areas are provided from the Newell Open Space Preserve. Views from the Newell Open Space Preserve include the City, the Napa Wetlands, the Napa River, and Oat Hill.

The project would facilitate industrial, commercial, and visitor serving development within the northern portion of the project site. In addition, the project would facilitate the extension of Newell Drive. The extension of Newell Drive would include overcrossings above the Union Pacific Railroad and the North Slough. This would introduce elevated portions of the roadway on the project site.

This development and extension would occur in a largely vacant, undeveloped area and would be visible from SR 29 and from the Newell Open Space Preserve. Figures 4.1-1 through 4.1-6 show typical views from and of the project site.

Motorists traveling on SR 29 currently experience views of hills in the background, as well as undeveloped, vacant areas with grasses on the project site. Figure 4.1-1 shows a view of these hills.

Motorists today also experience views of auto tire and trucking businesses, located near where future development would occur. These views, however, are fleeting and intermittent because it is experienced while driving. Motorists are not considered sensitive viewers because their primary 297
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focus is on road conditions. While future development and the Newell Drive Extension would be visible from SR 29 when the project is implemented, views of the hills would remain available in the background. Furthermore, views of the hills and undeveloped areas would remain visible north of the project site. As such, changes due to the project would not result in a substantial adverse effect on scenic vistas from SR 29. Thus, impacts from the project to the views from SR 29 would be less than significant.

Viewers at Newell Open Space Preserve are sensitive viewers because the viewpoint is in an open space/recreational area where views are an important element of the visitor experience. People experience public views from the public trails located in Newell Open Space Preserve. Future development from the project would be located approximately 1 mile from the nearest public trail in the Newell Open Space Preserve. While the project would introduce a roadway (Newell Drive Extension) and development, scenic resources, such as Oat Hill, the Napa River Wetlands, and the Sonoma Mountains would all remain visible. Views from the Newell Open Space Preserve would not result in a substantial adverse effect on a scenic vista. Therefore, impacts from the project to the view from the Newell Open Space Preserve would be less than significant.

The extension of Newell Drive would offer new opportunities for motorists to experience scenic views of undeveloped areas and the hills. Although portions of the roadway would be elevated to accommodate overcrossings, views of scenic resources such as hills would remain. Because the extension of Newell Drive would not significantly affect scenic views and because the extension would offer new opportunities for motorists to experience scenic views, impacts due to the extension of Newell Drive would be less than significant.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

Threshold 2: Would the project substantially damage scenic resources, including but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? Impact AES-2 THE CITY OF AMERICAN CANYON DOES NOT HAVE A DESIGNATED STATE SCENIC HIGHWAY AND THE PROJECT WOULD NOT DAMAGE SCENIC RESOURCES WITHIN A STATE SCENIC HIGHWAY. NO IMPACT WOULD OCCUR.

There are no designated scenic highways within or directly adjacent to project site (SR-29 is not officially designated as a state scenic highway). Because there are no state scenic highways in the project area, there would be no impacts related to scenic resources within a state scenic highway.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
There would be no impact and no mitigation would be required. 298
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Threshold 3: Would the project, in non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from a publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
Impact AES-3 THE PROJECT IS IN AN URBANIZED AREA AND WOULD NOT CONFLICT WITH APPLICABLE ZONING OR GENERAL PLAN POLICIES GOVERNING SCENIC QUALITY. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

CEQA Guidelines Section 21071 defines an urbanized area as an incorporated city that meets either of the following criteria:

A population of at least 100,000 persons.

A population of less than 100,000 persons if the population of that city and not more than two contiguous incorporated cities combined equals at least 100,000 persons.

The City of American Canyon does not meet the first criteria but does meet the second criteria.2 As such, this analysis considers whether the project conflicts with applicable zoning and other regulations governing scenic quality.

Scenic quality in American Canyon is governed by the policies in the General Plan, listed in Section

4.1.2, Regulatory Setting. The General Plan policies include requirements related to designing structures to have high visual quality (Objectives 1.18 and 1.32, Policies 1.18.1 through 1.18.4). The structures and the Newell Drive Extension that would be located on the project site have not been designed yet. Furthermore, the proposed pre-zoning includes design standards for new buildings in the industrial zoning district (see Section 2.5.1 in Chapter 2, Project Description). The design of any future buildings would be reviewed by the City’s Planning Commission to ensure that the buildings create a sense of place by interpreting the General Plan and Zoning. Likewise, the design of the Newell Drive Extension would be reviewed by the City. The policies in the General Plan also prohibit development along ridgelines (Policy 8.18.1) and requirements for development in hillside areas (Policy 8.18.2), which are meant to maintain American Canyon’s visual quality and character by preserving significant hillside and aesthetic resources (Objective 8.18.1). Because the project is not located on ridgelines or hillside areas, the project would not conflict with this objective and these policies. The project would not conflict with applicable zoning and other regulations governing scenic quality, and impacts would be less than significant.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
Impacts would be less than significant without mitigation. 2 The City of Vallejo is an incorporated city that is contiguous to the City of American Canyon. The combined population of both cities is more than 100,000 persons.
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Threshold 4: Would the project create a new source of substantial light or glare that would adversely affect daytime or nighttime views in the area? Impact AES-4 CONSTRUCTION AND OPERATION OF FUTURE DEVELOPMENT FACILITATED BY THE

PROJECT COULD CREATE NEW SOURCES OF LIGHT OR GLARE THAT COULD ADVERSELY AFFECT THE VISUAL ENVIRONMENT. IMPACTS WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION MEASURES INCORPORATED.

The project site proximate to a developed and urbanized area where day and nighttime lighting is part of the built environment, including street lighting at intersections and along Paoli Loop, parking lot lighting, security lighting, and building lighting, as well as various other sources of light from nearby urban uses. For example, existing light sources in the project area include residences off Watson Lane, the auto repair business and industrial uses off Paoli Loop, vehicle headlights on SR 29 and other roadways.

During construction, activities associated with the project would be limited to between 7:00 a.m. and 7:00 p.m. pursuant to the City’s Noise Ordinance. However, some temporary lighting may be necessary on site during the early morning or evening hours for safety and security reasons. This lighting could be bright, which would be a potentially significant impact. Implementation of Mitigation Measure AES-1 would require construction lighting to be minimized and downwardfacing.

Implementation of the project would result in conversion of the site from primarily undeveloped to a developed site with exterior lighting for security and aesthetic illumination, which would contribute to the overall ambient lighting. In addition, there would be lighting from vehicles using the Newell Drive Extension. The project would adhere to requirements in the California Green Building Code, including Chapter 5.106.8 to reduce light pollution. Furthermore, implementation of Mitigation Measure AES-2 would require the submittal of a photometric plan for future development to ensure that all exterior light fixtures are directed downward or employ full cut-off fixtures to minimize light spillage. Implementation of this mitigation, as well as the requirements in the Municipal Code and policies in the General Plan would minimize potentially significant light and glare impacts.

Mitigation Measures
AES-1 Construction Lighting Plan
Prior to nighttime construction, if needed for a particular project, project applicants shall submit a construction lighting plan to the City for review and approval. The construction lighting plan shall ensure that the minimum amount of lighting is used to meet safety requirements and ensure no spillover occurs to nearby sensitive uses. All lighting shall be directed downward and away from surrounding land uses.

AES-2 Operational Lighting Plan
Prior to discretionary project approval, the project applicant shall prepare and submit a photometric plan to the City for review and approval which demonstrates that all exterior light fixtures will be directed downward or employ full cut-off fixtures to prevent light spillage. The approved plan shall be incorporated into the project design plans.
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Significance After Mitigation
Implementation of Mitigation Measure AES-1 and AES-2 would ensure that lighting and glare is minimized during construction and operation of future development. With implementation of Mitigation Measure AES-1 and AES-2, impacts would be less than significant.

4.1.4 Cumulative Impacts
The geographic context for the cumulative aesthetics analysis is the City of American Canyon and Napa County, especially areas in the project vicinity. Cumulative development includes foreseeable future projects that could have a direct connection to the project from the perspective of visual resources. The Watson Ranch Specific Plan is the largest cumulative project and is close to the project site. As such, this cumulative project is discussed further below in the cumulative analysis.

As described in Impact AES-2, the project would have no impact on a scenic highway and therefore would not contribute to a cumulative impact. As such, it is not discussed further.

As described in Impact AES-1, the project would have a less than significant impact on scenic views for viewers on SR 29 and at the Newell Open Space Preserve. Under cumulative conditions, motorists on SR 29 would see the future development associated with the project, the Watson Ranch Specific Plan development, and the future Hess Collection-Laird General Plan Amendment industrial development north of the project site. While views of certain hills from SR 29 would be obstructed, hill views would not be completely obstructed. Furthermore, motorists are not considered sensitive viewers because their primary focus is on road conditions. As such, cumulative impacts on scenic views from SR 29 would be less than significant.

Under cumulative conditions, viewers from the Newell Open Space Preserve would see the project, as well as the future development associated with the Watson Ranch Specific Plan and any future industrial development from the Hess Collection-Laird General Plan Amendment. The Watson Ranch Specific Plan EIR identified that views of scenic resources (i.e., Oat Hill, Napa River Wetlands, and Sonoma Mountains) would remain even after implementation of the Specific Plan (City of American Canyon 2018). Similarly, the project would also maintain views of scenic resources from the Newell Open Space Preserve. As such, in the cumulative scenario, views of scenic resource would remain from the Newell Open Space Preserve and cumulative impacts on scenic views would be less than significant.

As described in Impact AES-3, the project would not conflict with applicable zoning or General Plan policies governing scenic quality. Similarly, all cumulative projects would be required to adhere to development standards included in the zoning ordinance and would be required to undergo design review by the City’s Planning Division. As such, cumulative impacts related to conflicting with applicable zoning or General Plan policies governing scenic quality would be less than significant.

Cumulative development projects could contribute to light and glare impacts as the city continues to build out, as envisioned under the General Plan. Regulations that govern light and glare would apply to these projects. For example, cumulative development projects would adhere to the lighting requirements of the California Green Building Code. As such, because all cumulative development projects would be required to implement these lighting requirements, operational cumulative impacts would be less than significant.

Due to the proximity of the project site with the Watson Ranch Specific Plan, a cumulative impact on lighting from construction could occur if construction occurred at the same time. An EIR has been certified for the Watson Ranch Specific Plan, which includes a mitigation measure, requiring a 301
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construction lighting plan, similar to the mitigation required for the project (City of American Canyon 2018). As such, because both the project and the Watson Ranch Specific Plan would mitigate lighting impacts during construction, cumulative lighting impacts from construction would be less than significant.
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4.2 Agriculture and Forestry Resources
This section analyzes the potential effects related to agriculture and forestry resources due to implementation of the project.

4.2.1 Setting
a. Regional Agriculture
Napa County provides a variety of agricultural uses, including row crops, field crops, orchards, vineyards, and grazing land. The production of wine grapes accounts for the largest crop produced in Napa County, with approximately 46,019 acres used to produce wine grapes in 2021 (County of Napa 2021). The City of American Canyon is primarily developed and classified by the California Department of Conservation (DOC) as Urban and Built-Up Land and Farmland of Local Importance (DOC 2018). As defined by the DOC, Urban and Built-Up Land is occupied by structures with a building density of at least one unit to 1.5 acres and typically include residential, commercial, and/or industrial uses. Farmland of Local Importance is land determined by each county’s board of supervisors and local advisory committees to be important to local agriculture (DOC 2018). b. Important Farmland
To characterize agricultural land, the DOC has created Important Farmland Maps, which provide a visual representation of the quality of agricultural land based upon soil quality and irrigation status (DOC 2019a). Unless otherwise expressed, the use of “Important Farmland” in this section specifically includes the following DOC definitions (DOC 2018):
 Prime Farmland. Land which has the best combination of physical and chemical features able to sustain long term production of agricultural crops. This land has the soil quality, growing season, and moisture supply needed to produce sustained high yields. Land must have been used for production of irrigated crops at some time during the four years prior to the mapping date.  Farmland of Statewide Importance. Irrigated land similar to Prime Farmland that has a good combination of physical and chemical characteristics for the production of agricultural crops.

This land has minor shortcomings, such as greater slopes or less ability to store soil moisture than Prime Farmland. Land must have been used for production of irrigated crops at some time during the four years prior to the mapping date.
 Unique Farmland. Lesser quality soils used for the production of the State’s leading agricultural crops. This land is usually irrigated, but may include non-irrigated orchards or vineyards as found in some climatic zones in California. Land must have been cropped at some time during the four years prior to the mapping date.

The project site is comprised of Urban and Built-Up Land and Farmland of Local Importance (DOC 2018). Figure 4.2-1 shows the distribution of both land designations on the project site. Farmland of Local Importance is not included in the DOC’s definition of Important Farmland. 303
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Figure 4.2-1 Farmland on the Project Site
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c. Williamson Act Contracts
Williamson Act contracts create an arrangement whereby private landowners enter a contract to voluntarily restrict their land to agricultural and compatible open space uses over a ten-year period in exchange for the land’s property tax being assigned a rate consistent with actual use rather than potential market value (DOC 2019b). According to the County of Napa’s Planning, Building, and Environmental Services Department (PBES) none of the parcels within the project site are under a Williamson Act contract (PBES 2018).
d. Napa County General Plan Land Use Designation and Zoning The Agriculture Preservation and Land Use Element for the Napa County General Plan includes a Land Use Map (Figure AG/LU-3 in the General Plan) that shows the project site with a land use designation of Industrial (Napa County 2013). The project site is currently zoned by Napa County as Agricultural Watershed: Airport Compatibility (AW:AC) (Napa County 2015).

4.2.2 Regulatory Setting
a. Federal Regulations
There are no federal regulations that would be applicable to the project. b. State Regulations
There are no State regulations that would be applicable to the project. c. Local Regulations
Napa County LAFCo
The Napa County LAFCo is established under the Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000 (California Government Code Section 56000, et seq.). The job of the commission is to, “review and approve with or without amendment, wholly, partially, or conditionally, or disapprove proposals for changes of organization or reorganization, consistent with written policies, procedures, and guidelines adopted by the commission,” (California Government Code Section 56375). This gives the commission exclusive power to consider city annexations.

Government Code Section 56377 requires the commission to minimize impacts on open space lands, including agricultural lands, as follows:
“In reviewing and approving or disapproving proposals which could reasonably be expected to induce, facilitate, or lead to the conversion of existing open-space lands to uses other than open-space uses, the commission shall consider all of the following policies and priorities:” a) Development or use of land for other than open-space uses shall be guided away from existing prime agricultural lands in open-space use toward areas containing nonprime agricultural lands, unless that action would not promote the planned, orderly, efficient development of an area.
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b) Development of existing vacant or nonprime agricultural lands for urban uses within the existing jurisdiction of a local agency or within the sphere of influence of a local agency should be encouraged before any proposal is approved which would allow for or lead to the development of existing open-space lands for non-open-space uses which are outside of the existing jurisdiction of the local agency or outside of the existing sphere of influence of the local agency.

Napa County General Plan
The Napa County General Plan Agricultural Preservation and Land Use Element sets goals in order to preserve existing agricultural land, keep urban development within already urbanized areas, support agricultural economy, and plan for environmental or climatic changes. Policies that address agricultural preservation in Napa County include (County of Napa 2013):

Policy AG/LU-2: “Agriculture” is defined as the raising of crops, trees, and livestock; the production and processing of agricultural products; and related marketing, sales and other accessory uses. Agriculture also includes farm management businesses and farm worker housing.

Policy AG/LU-130: The County recognizes the growth boundary for the City of American Canyon shown in Figure LU-5 [of the Napa County General Plan] and will support the City’s annexation of unincorporated land located within the boundary provided that: (a) voters of American Canyon approve a ballot measure establishing the boundary and requiring any amendments prior to 2030 to be approved by the voters; (b) the City provides water service within their service area without discriminating between in-city and out-of-city customers except to the extent that rates may differ in accordance with law; (c) for industrial properties north of the current (2007) city limits, property owners provide an easement to the County agreeing to keep the properties in industrial use in perpetuity, and the City and County agree to share property tax revenues equally; and (d) for properties east of the current (2007) city limits, the City and County execute a revenue sharing agreement.

City of American Canyon General Plan
The current City of American Canyon General Plan sets forth the following goals, objectives, and policies concerning agriculture and forestry resources:

Goal 1D: Promote continued agricultural production.

Goal 8B: Promote the preservation of American Canyon's soil resources by protecting areas that are suitable for agricultural uses or buffer zones.

Objective 8.10: Encourage the preservation of existing agricultural operations except where designated for urban uses.

4.2.3 Impact Analysis
a. Significance Thresholds and Methodology
Significance Thresholds
Based on Appendix G of the CEQA Guidelines a project may be deemed to have a significant impact on agricultural and forestry resources if it would:
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1. Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use;

2. Conflict with existing zoning for agricultural use or a Williamson Act contract;

3. Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)); timberland (as defined by Public Resources Code Section 4526); or timberland zoned Timberland Production (as defined by Government Code Section 51104(g);

4. Result in the loss of forest land or conversion of forest land to non-forest use; or

5. involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to nonforest use.

Methodology
The location of agricultural lands and forest lands were identified by reviewing the DOC’s Important Farmland Finder, information from the PBES, and aerial imagery. This analysis uses the definition of agricultural land provided in the California Environmental Quality Act (CEQA) Guidelines Section 21060.1, which provides the following definition: “Agricultural land” means prime farmland, farmland of statewide importance, or unique farmland, as defined by the United States Department of Agriculture land inventory and monitoring criteria, as modified for California. The definitions for prime farmland, farmland of statewide importance, and unique farmland are identified in Section

4.2.1, Setting.

Threshold 1: Would the project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?
Impact AG-1 THE PROJECT WOULD NOT CONVERT FARMLAND, AS SHOWN ON MAPS PREPARED PURSUANT TO THE FARMLAND MAPPING AND MONITORING PROGRAM, TO NON-AGRICULTURAL USE. NO IMPACT WOULD OCCUR.

As described in Section 4.2.1, Setting, the project site contains land designated by the DOC as Urban and Built-Up Land and Farmland of Local Importance. However, as shown on maps prepared pursuant to the Farmland Mapping and Monitoring Program, there are no Important Farmlands located on the project site (DOC 2018). Therefore, the project would not convert Important Farmland to non-agricultural use. No impact would occur.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
There would be no impact and no mitigation would be required. 307
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Threshold 2: Would the project conflict with existing zoning for agricultural use or a Williamson Act contract?
Impact AG-2 THE PROJECT WOULD NOT CONFLICT WITH EXISTING ZONING FOR AGRICULTURAL USE OR A WILLIAMSON ACT CONTRACT. NO IMPACT WOULD OCCUR.

As described in Section 4.2.1, Setting, the project site is not held under a Williamson Act or other land conservation contract. As such, there would be no impact from conflicting with a Williamson Act contract.

The northern portion of the project site, where development would occur, has an American Canyon land use designation of Agriculture and no pre-zoning, as well as a Napa County land use designation of Industrial and Agricultural Watershed: Airport Compatibility zoning. As a part of this project, the City would change the land use designation and pre-zoning to Paoli Light Industrial and Paoli Light Industrial with Paoli Commercial Overlay. This change would ensure that there would be no conflict with an agricultural zoning. Furthermore, it should be noted that this annexation would be consistent with the overall vision in the City of American Canyon and Napa County General Plan.

First, the annexation is within the City’s sphere of influence, which defines the probable physical boundary and service area of a local agency. Second, the Napa County General Plan identifies the envisioned land use at the project site as industrial and includes Policy AG/LU-130, which supports the City’s annexation of unincorporated land located within the growth boundary (the project site is located within the growth boundary). As such, there would be no impact from conflicting with zoning for agricultural uses.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
There would be no impact and no mitigation would be required.

Threshold 3: Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)); timberland (as defined by Public Resources Code Section 4526); or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))?
Threshold 4: Would the project result in the loss of forest land or conversion of forest land to nonforest use? Impact AG-3 THE PROJECT WOULD NOT CONFLICT WITH EXISTING ZONING FOR, OR CAUSE REZONING

OF FOREST LAND, TIMBERLAND, OR TIMBERLAND ZONED TIMBERLAND PRODUCTION, OR RESULT IN THE LOSS OF FOREST LAND OR CONVERSION OF FOREST LAND TO NON-FOREST USE. NO IMPACT WOULD OCCUR.

Historic aerial imagery dating to 1948 does not show any forest land which existed on the project site (County of Napa 2022; Environmental Risk Information Services 2022). In addition, the project site is not zoned for forest land or timberland. Therefore, the project would not conflict with the existing zoning for, or cause rezoning of forest land, timberland, or timberland zoned Timberland Production, or result in the loss of forest land or conversion of forest land to non-forest use. No impact would occur.
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Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
There would be no impact and no mitigation would be required.

Threshold 5: Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use?
Impact AG-4 THE PROJECT WOULD NOT INVOLVE OTHER CHANGES IN THE EXISTING ENVIRONMENT

AND WOULD NOT RESULT IN THE CONVERSION OF FARMLAND OR FORESTLAND TO NON-AGRICULTURAL USE OR NON-FOREST USE. NO IMPACT WOULD OCCUR.

As described in Impacts AG-1, AG-2, and AG-3, the project would not result in impacts to agricultural or forest lands. In addition, the project is not expected to result in off-site agricultural lands to nonagricultural use for the following reasons. The addition of industrial and commercial uses associated with the project would be located within the City’s sphere of influence, within an area designated by Napa County as Industrial, and within the City’s growth boundary. By locating industrial and commercial development within these areas of planned development, this would reduce pressure to convert agricultural lands in Napa County to industrial or commercial uses. As such, no impact would occur.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
There would be no impact and no mitigation would be required.

4.2.4 Cumulative Impacts
The cumulative context for agricultural and forestry resources is the City and the County. The largest cumulative project and the one closest to the project site is the Watson Ranch Specific Plan. The Watson Ranch Specific Plan EIR identified no impacts on agricultural or forestry resources (City of American Canyon 2018). Furthermore, as identified in Impact AG-4, the project is not expected to result in off-site conversion of agricultural lands to non-agricultural use. Furthermore, agricultural lands in unincorporated Napa County (which is where agricultural lands are concentrated) are protected through the “Right to Farm” provisions, which ensure that agriculture remains the primary land use in Napa County and is not threatened by potentially competing uses or neighbor complaints. The “Right to Farm” provisions are included in Section 2.94 of the Napa County Municipal Code. For these reasons, a cumulative impact on agricultural and forestry resources is not expected. Furthermore, because the project would have no impact on agricultural or forestry resources, the project would not contribute to a cumulative impact. 309
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4.3 Air Quality
This section analyzes the potential effects on air quality related to implementation of the project, including impacts due to construction, operations, and impacts to nearby sensitive receptors.

4.3.1 Setting
a. Climate and Topography
Air quality is affected by the rate and location of pollutant emissions and by climatic conditions that influence the movement and dispersion of pollutants. Atmospheric conditions, such as wind speed, wind direction, and air temperature gradients, along with local and regional topography, influence the relationship between air pollutant emissions and air quality.

The project site is in the San Francisco Bay Area Air Basin (SFBAAB), which is comprised of Alameda, Contra Costa, Marin, Napa, San Francisco, San Mateo, Santa Clara, southwestern Solano, and southern Sonoma Counties. SFBAAB covers approximately 5,540 square miles of complex terrain, consisting of coastal mountain ranges, inland valleys, and the San Francisco Bay. The SFBAAB is generally bounded on the west by the Pacific Ocean, on the north by the Coast Ranges, and on the east and south by the Diablo Range.

The climate within the SFBAAB is dominated by a strong, semi-permanent, subtropical high-pressure cell over the northeastern Pacific Ocean. Climate is also affected by the adjacent oceanic heat reservoir’s moderating effects. Mild summers and winters, moderate rainfall and humidity, and daytime onshore breezes characterize regional climatic conditions in the San Francisco Bay Area (Bay Area). In summer, when the high-pressure cell is strongest and farthest north, fog forms in the morning and temperatures are mild. In winter, when the high-pressure cell is weakest and farthest south, occasional rainstorms occur.

Winter daytime temperatures in the SFBAAB typically average in the mid-50s, with nighttime temperatures averaging in the low 40s. Summer daytime temperatures typically average in the 70s, with nighttime temperatures averaging in the 50s. Precipitation varies in the region, but in general, annual rainfall is lowest in the coastal plain and inland valley, higher in the foothills, and highest in the mountains.
b. Air Pollutants of Primary Concern
Criteria air pollutants are defined as those pollutants for which the federal and state governments have established air quality standards for outdoor or ambient concentrations to protect public health with a determined margin of safety. Ozone (O3) is generally considered to be regional pollutants because they or their precursors affect air quality on a regional scale. Pollutants such as carbon monoxide (CO), nitrogen dioxide (NO2), and sulfur dioxide (SO2) are considered local pollutants because they tend to accumulate in the air locally. Coarse particulate matter (PM10) and fine particulate matter (PM2.5) are considered both regional and local pollutants. 311
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Ozone
O3 is a highly oxidative unstable gas, produced by a photochemical reaction (triggered by sunlight) between NOX and reactive organic gas (ROG)/volatile organic compounds (VOC).1 ROG are
composed of non-methane hydrocarbons (with some specific exclusions), and NOX is composed of different chemical combinations of nitrogen and oxygen, mainly nitric oxide and NO2. NOX is formed during the combustion of fuels, while ROG are formed during combustion and evaporation of organic solvents. As a highly reactive molecule, O3 readily combines with many different components of the atmosphere. Consequently, high levels of O3 tend to exist only while high ROG and NOX levels are present to sustain the O3 formation process. Once the precursors have been depleted, O3 levels rapidly decline. Because these reactions occur on a regional rather than local scale, O3 is considered a regional pollutant. Groups most sensitive to O3 include children, the elderly, people with respiratory disorders, and people who exercise strenuously outdoors (United States Environmental Protection Agency [USEPA] 2022a). Depending on the level of exposure, O3 can result in the following:
 Cause coughing and sore or scratchy throat;
 Make it more difficult to breathe deeply and vigorously and cause pain when taking a deep breath;
 Inflame and damage the airways;
 Make the lungs more susceptible to infection;
 Aggravate lung diseases such as asthma, emphysema, and chronic bronchitis; and/or  Increase the frequency of asthma attacks.

Carbon Monoxide
CO is a localized pollutant that is found in high concentrations only near its source. The major source of CO, a colorless, odorless, poisonous gas, is the incomplete combustion of petroleum fuels by automobile traffic. Therefore, elevated concentrations are usually only found near areas of high traffic volumes. Other sources of CO include the incomplete combustion of petroleum fuels at power plants and fuel combustion from wood stoves and fireplaces during the winter. When CO levels are elevated outdoors, they can be of particular concern for people with some types of heart disease. People with heart disease have restricted blood flow which results in a lack of oxygen to the heart muscle. These people are especially vulnerable to the effects of CO when exercising or under increased stress, when the heart needs more oxygen than usual. In these situations, short-term exposure to elevated CO may result in reduced oxygen to the heart accompanied by chest pain also known as angina (USEPA 2022b).

Nitrogen Dioxide
NO2 is a by-product of fuel combustion; the primary sources are motor vehicles and industrial boilers and furnaces. The principal form of NOx produced by combustion is nitric oxide, but nitric oxide reacts rapidly to form NO2, creating the mixture of nitric oxide and NO2, commonly called NOx.

NO2 is a reactive, oxidizing gas and an acute irritant capable of damaging cell linings in the respiratory tract. Such exposures over short periods can aggravate respiratory diseases, particularly 1 The California Air Resources Board defines VOC and ROG similarly as, “any compound of carbon excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate,” with the exception that VOC are compounds that participate in atmospheric photochemical reactions. For the purposes of this analysis, ROG and VOC are considered comparable in terms of mass emissions, and the term ROG is used in this environmental impact report. 312
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asthma, leading to respiratory symptoms (such as coughing, wheezing, or difficulty breathing), and increase hospital admissions and visits to emergency rooms. Longer exposures to elevated concentrations of NO2 may contribute to the development of asthma and potentially increase susceptibility to respiratory infections. People with asthma, as well as children and the elderly are generally at greater risk for the health effects of NO2 (USEPA 2022c). NO2 absorbs blue light and causes a reddish-brown cast to the atmosphere and reduced visibility. It can also contribute to the formation of O3/smog and acid rain.

Sulfur Dioxide
SO2 is included in a group of highly reactive gases known as “oxides of sulfur.” The largest sources of SO2 emissions are from fossil fuel combustion at power plants (73 percent) and other industrial facilities (20 percent). Smaller sources of SO2 emissions include industrial processes such as extracting metal from ore and burning fuels with a high sulfur content by locomotives, large ships, and off-road equipment. Short-term exposures to SO2 can harm the human respiratory system and make breathing difficult. People with asthma, particularly children, are sensitive to these effects of SO2 (USEPA 2022d).

Particulate Matter
Suspended atmospheric PM10 and PM2.5 is comprised of finely divided solids and liquids such as dust, soot, aerosols, fumes, and mists. Both PM10 and PM2.5 are directly emitted into the atmosphere as by-products of fuel combustion and wind erosion of soil and unpaved roads.

Particulate matter is also created in the atmosphere through chemical reactions. The characteristics, sources, and potential health effects associated with PM10 and PM2.5 can be very different. PM10 is generally associated with dust mobilized by wind and vehicles while PM2.5 is generally associated with combustion processes as well as formation in the atmosphere as a secondary pollutant through chemical reactions. PM10 can cause increased respiratory disease, lung damage, cancer, premature death, reduced visibility, surface soiling. For PM2.5, short-term exposures (up to 24-hours duration) have been associated with respiratory issues such as acute bronchitis and asthma attacks. In addition, PM2.5 can cause premature mortality, increased hospital admissions for heart or lung issues, and restricted activity days. These adverse health effects have been reported primarily in infants, children, and older adults with preexisting heart or lung diseases (California Air Resources Board [CARB] 2022a).

Toxic Air Contaminants
Toxic air contaminants (TACs) are a diverse group of air pollutants that may cause or contribute to an increase in deaths or serious illness, or that may pose a present or potential hazard to human health. TACs include both organic and inorganic chemical substances that may be emitted from a variety of common sources, including gasoline stations, motor vehicles, dry cleaners, industrial operations, painting operations, and research and teaching facilities. One of the main sources of TACs in California is diesel engine exhaust that contains solid material known as diesel particulate matter (DPM). More than 90 percent of DPM is less than one micron in diameter (about 1/70th the diameter of a human hair) and thus is a subset of PM2.5. Because of their extremely small size, these particles can be inhaled and eventually trapped in the bronchial and alveolar regions of the lungs (CARB 2022b).

TACs are different than criteria pollutants because ambient air quality standards have not been established for TACs. TACs occurring at extremely low levels may still cause health effects and it is 313
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typically difficult to identify levels of exposure that do not produce adverse health effects. TAC impacts are described by carcinogenic risk and by chronic (i.e., long duration) and acute (i.e., severe but of short duration) adverse effects on human health.

TACs include both organic and inorganic chemical substances. While DPM is a main source, TACs may be emitted from a variety of common sources, including gasoline stations, motor vehicles, dry cleaners, industrial operations, painting operations, and research and teaching facilities. People exposed to toxic air pollutants at sufficient concentrations and durations may have an increased chance of developing cancer or experiencing other serious health effects. These health effects can include damage to the immune system, as well as neurological, reproductive (e.g., reduced fertility), developmental, respiratory, and other health problems (USEPA 2020). c. Air Quality Standards and Attainment
The federal and state governments have authority under the federal and state Clean Air Acts (CAA) to regulate emissions of airborne pollutants and have established ambient air quality standards (AAQS) for the protection of public health. An air quality standard is defined as “the maximum amount of a pollutant averaged over a specified period of time that can be present in outdoor air without harming public health” (CARB 2019a). The USEPA is the federal agency designated to administer air quality regulation, while CARB is the state equivalent in California. Federal and state AAQS have been established for six criteria pollutants: O3, CO, NO2, SO2, PM10, PM2.5, and lead. AAQS are designed to protect those segments of the public most susceptible to respiratory distress, such as children under the age of 14, the elderly (over the age of 65), persons engaged in strenuous work or exercise, and people with cardiovascular and chronic respiratory diseases (USEPA 2016). In addition to the federal criteria pollutants, the California Ambient Air Quality Standards (CAAQS) also specify standards for visibility-reducing particles, sulfates, hydrogen sulfide, and vinyl chloride (CARB 2019b). Table 4.3-1 lists the current National Ambient Air Quality Standards (NAAQS) as well as the CAAQS for regulated pollutants.

USEPA and CARB designate air basins or portions of air basins and counties as being in “attainment” or “nonattainment” for each of the criteria pollutants. Areas that do not meet the AAQS standards are classified as nonattainment areas. The NAAQS (other than O3, PM10, PM2.5, and those based on annual averages or arithmetic mean) are not to be exceeded more than once per year. The NAAQS for O3, PM10, and PM2.5 are based on statistical calculations over one- to three-year periods, depending on the pollutant. The CAAQS are not to be exceeded during a three-year period. The attainment status for Napa County is included in Table 4.3-2.

Pursuant to the CAA, USEPA designates areas as attainment, nonattainment, or maintenance for each criteria pollutant based on whether the NAAQS have been achieved. Whether an area meets the state and federal standards is based on air quality monitoring data. Areas that are unclassified have insufficient monitoring data for a specific pollutant to determine attainment or nonattainment status, although unclassified areas are typically treated as attainment for a specific pollutant. Since attainment and nonattainment designation is pollutant-specific, an area may be classified as nonattainment for one pollutant and attainment for another. Similarly, because the state and federal standards differ, an area could be classified as attainment for the federal standards of a pollutant and as nonattainment for the state standards of the same pollutant. The region is designated as a nonattainment area for the federal and state Ozone standards and the State PM10 and PM2.5 standards. The region is designated unclassified or attainment for all other ambient air quality standards (BAAQMD 2017a).
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Table 4.3-1 Federal and State Ambient Air Quality Standards Pollutant Averaging Time NAAQS CAAQS
Ozone 1-Hour – 0.09 ppm
8-Hour 0.070 ppm 0.070 ppm
Carbon Monoxide 8-Hour 9.0 ppm 9.0 ppm
1-Hour 35.0 ppm 20.0 ppm
Nitrogen Dioxide Annual 0.053 ppm 0.030 ppm
1-Hour 0.100 ppm 0.18 ppm
Sulfur Dioxide Annual − −
24-Hour − 0.04 ppm
1-Hour 0.075 ppm 0.25 ppm
PM10 Annual − 20 µg/m3
24-Hour 150 µg/m3 50 µg/m3
PM25 Annual 12 µg/m3 12 µg/m3
24-Hour 35 µg/m3 −
Lead 30-Day Average − 1.5 µg/m3
3-Month Average 0.15 µg/m3 −
NAAQS = National Ambient Air Quality Standards; CAAQS = California Ambient Air Quality Standards; ppm = parts per million; µg/m3 = micrograms per cubic meter
Source: CARB 2016; USEPA 2016
Table 4.3-2 Attainment Status of Criteria Pollutants in Napa County Pollutant State Designation Federal Designation
O3 Nonattainment Nonattainment
PM10 Nonattainment Unclassified
PM2.5 Nonattainment Unclassified/Attainment
CO Attainment Attainment
NO2 Attainment Unclassified/Attainment
SO2 Attainment Attainment
Sources: BAAQMD 2017a
d. Current Ambient Air Quality
The project is located in Napa County which is under the jurisdiction of the Bay Area Air Quality Management District (BAAQMD). BAAQMD is responsible for achieving and maintaining the state and federal Ambient Air Quality Standards (AAQS) within its jurisdiction. BAAQMD operates a network of air quality monitoring stations throughout the San Francisco Bay Area Air Basin (SFBAAB). The monitoring stations aim to measure ambient concentrations of pollutants and determine whether ambient air quality meets the state and federal standards. The monitoring station closest to the project site is the Vallejo – 304 Tuolumne Street Station, approximately 5.4 miles south of the project site. This station measures 8-hour O3, hourly O3, PM2.5, and NOX. The Napa – Valley College air monitoring station (located at Magnolia Drive and Route 221) in Napa is the closest air monitoring station to the project site that measures PM10. This station is approximately 315
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6.5 miles north of the site. Table 4.3-3 indicates the number of days each federal and state standard was exceeded at the Vallejo – 304 Tuolumne Street and Napa – Valley College air monitoring stations. As shown in Table 4.3-3, O3 measurements exceeded federal or state O3 standards in all three observation years. PM10 measurements exceeded the State standard in 2020. PM2.5 measurements exceeded federal PM2.5 standards in 2020. No other state or federal standards were exceeded at these air monitoring stations.

Table 4.3-3 Ambient Air Quality Data
Pollutant 2019 2020 2021
8 Hour Ozone (ppm), 8-Hour Average1 0.076 0.077 0.072
Number of Days of state exceedances (>0.070 ppm) 1 1 1
Number of days of federal exceedances (>0.070 ppm) 1 1 1 Ozone (ppm), Worst Hour1 0.092 0.096 0.099
Number of days of state exceedances (>0.09 ppm) 0 1 1
Carbon Monoxide (ppm), Worst-Hour * * *
Number of days of state exceedances (>20.0 ppm) * * *
Nitrogen Dioxide (ppm) - Worst Hour1 0.053 0.048 0.041
Number of days of state exceedances (>0.18 ppm) 0 0 0
Number of days of federal exceedances (>0.10 ppm) 0 0 0 Particulate Matter 10 microns, µg/m3, Worst 24 Hours2 37.5 122.9 22.9 Number of days of state exceedances (>50 µg/m3) 0 12 0
Number of days above federal standard (>150 µg/m3) 0 0 0 Particulate Matter <2.5 microns, µg/m3, Worst 24 Hours1 30.5 152.7 32.0 Number of days above federal standard (>35 µg/m3) 0 12 0 1 Measurements were taken from the Vallejo – 304 Tuolumne Street Station 2 Measurements taken from the Napa – Valley College Station. *Insufficient data available to determine the value.

Bold lettering indicates an exceedance of applicable AAQS.

Source: CARB 2022c
e. Sensitive Receptors
Sensitive receptors are facilities or land uses that include members of the population who are particularly sensitive to the effects of air pollutants, such as children, the elderly, and people with illnesses. According to BAAQMD, sensitive receptors are defined as facilities or land uses that include members of the population that are particularly sensitive to the effects of air pollutants, such as children, the elderly, and people with illnesses. Examples include schools, hospitals and residential areas (BAAQMD 2017b). The nearest sensitive receivers are residences. There are residences whose property lines are adjacent to the area that would be pre-zoned as Paoli Light Industrial and Paoli Light Industrial with Paoli Commercial Overlay. In addition, the residential structures on these properties are approximately 500 feet from the area that would be pre-zoned as Paoli Light Industrial and Paoli Light Industrial with Paoli Commercial Overlay. There is one residence located approximately 850 feet from where the Newell Drive Extension would be located. 316
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4.3.2 Regulatory Setting
a. Federal
Federal Clean Air Act
The Federal Clean Air Act (CAA) governs air quality in the United States. The CAA is administered by United States Environmental Protection Agency (USEPA) at the federal level, California Air Resources Board (CARB) at the State level, and by the Air Quality Management Districts at the regional and local levels. The CAA of 1970 and the CAA Amendments of 1971 required the USEPA to establish the National Ambient Air Quality Standards (NAAQS), with states retaining the option to adopt more stringent standards or to include other specific pollutants. On April 2, 2007, the Supreme Court found that CO2 is an air pollutant covered by the CAA; however, no NAAQS have been established for CO2.

The USEPA is responsible for enforcing the federal CAA. The USEPA is also responsible for establishing NAAQS. NAAQS are required under the 1977 CAA and subsequent amendments. The USEPA regulates emission sources that are under the exclusive authority of the federal government, such as aircraft, ships, and certain types of locomotives. The agency has jurisdiction over emission sources outside State waters (e.g., beyond the outer continental shelf) and establishes various emission standards, including those for vehicles sold in states other than California. Automobiles sold in California must meet the stricter emission standards established by CARB.

USEPA Emission Standards for New Off-road Equipment
Before 1994, there were no standards to limit the amount of emissions from off-road equipment. In 1994, USEPA established emission standards for hydrocarbons, NOx, CO, and PM to regulate new pieces of off-road equipment. These emission standards came to be known as Tier 1. Since that time, increasingly more stringent Tier 2, Tier 3, and Tier 4 (interim and final) standards were adopted by USEPA, as well as by CARB. Each adopted emission standard was phased in over time.

New engines built in and after 2015 across all horsepower sizes must meet Tier 4 final emission standards. In other words, new manufactured engines cannot exceed the emissions established for Tier 4 final emissions standards.
b. State
California Clean Air Act
The California CAA allows the state to adopt ambient air quality standards and other regulations provided that they are at least as stringent as federal standards. CARB, a part of the California Environmental Protection Agency (CalEPA), is responsible for the coordination and administration of both federal and state air pollution control programs within California, including setting the CAAQS.

CARB also conducts research, compiles emission inventories, develops suggested control measures, and provides oversight of local programs. CARB establishes emissions standards for motor vehicles sold in California, consumer products (such as hairspray, aerosol paints, and barbecue lighter fluid), and various types of commercial equipment. It also sets fuel specifications to further reduce vehicular emissions. CARB also has primary responsibility for the development of California’s State Implementation Plan (SIP), for which it works closely with the federal government and the local air districts.
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California State Implementation Plan
The SIP is a living document that is periodically modified to reflect the latest emissions inventories, plans, and rules and regulations of air basins, as reported by the agencies with jurisdiction over them. The CAA Amendments dictate that states containing areas violating the NAAQS revise their SIPs to include extra control measures to reduce air pollution. The SIP includes strategies and control measures to attain the NAAQS. The USEPA has the responsibility to review all SIPs to determine if they conform to the requirements of the CAA.

State law makes CARB the lead agency for all purposes related to the SIP. Local air districts and other agencies prepare SIP elements and submit them to CARB for review and approval. CARB then forwards SIP revisions to the USEPA for approval and publication in the Federal Register. The BAAQMD 2017 Clean Air Plan is the SIP for the SFBAAB. The 2017 Clean Air Plan accommodates growth by projecting the growth in emissions based on different indicators. For example, population forecasts adopted by the Association of Bay Area Governments (ABAG) are used to forecast population-related emissions. Through the planning process, emissions growth is offset by basinwide controls on stationary, area, and transportation sources of air pollution.

California Low-Emission Vehicle Program
CARB first adopted Low-Emission Vehicle (LEV) program standards in 1990. These first LEV standards ran from 1994 through 2003. LEV II regulations, running from 2004 through 2010, represent continuing progress in emission reductions. As the State’s passenger vehicle fleet continues to grow and more sport utility vehicles and pickup trucks are used as passenger cars rather than work vehicles, the more stringent LEV II standards were adopted to provide reductions necessary for California to meet federally mandated clean air goals outlined in the 1994 SIP. In 2012, CARB adopted the LEV III amendments to California’s LEV regulations. These amendments, also known as the Advanced Clean Car Program, include more stringent emission standards for model years 2017 through 2025 for both criteria pollutants and greenhouse gas (GHG) emissions for new passenger vehicles.

California On-Road Heavy-Duty Vehicle Program
CARB has adopted standards for emissions from various types of new on-road heavy-duty vehicles.

Section 1956.8, Title 13, California Code of Regulations contains California’s emission standards for on-road heavy-duty engines and vehicles, and test procedures. CARB has also adopted programs to reduce emissions from in-use heavy-duty vehicles including the Heavy-Duty Diesel Vehicle Idling Reduction Program, the Heavy-Duty Diesel In-Use Compliance Program, the Public Bus Fleet Rule and Engine Standards, and the School Bus Program and others.

California Airborne Toxics Control Measure for Asbestos CARB has adopted Airborne Toxics Control Measures for sources that emit a particular TAC. If there is a safe threshold for a substance at which there is no toxic effect, the control measure must reduce exposure below that threshold. If there is no safe threshold, the measure must incorporate Best Available Control Technology to minimize emissions. In July 2001, CARB approved an Air Toxic Control Measure for construction, grading, quarrying and surface mining operations to minimize emissions of naturally occurring asbestos. The regulation requires application of best management practices (BMPs) to control fugitive dust in areas known to have naturally occurring asbestos and requires notification to the local air district prior to commencement of ground-disturbing activities. 318
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The measure establishes specific testing, notification and engineering controls prior to grading, quarrying, or surface mining in construction zones where naturally occurring asbestos is located on projects of any size. There are additional notification and engineering controls at work sites larger than one acre in size. These projects require the submittal of a “Dust Mitigation Plan” and approval by the air district prior to the start of a project.

Construction sometimes requires the demolition of existing buildings where construction occurs.

Buildings often include materials containing asbestos. Asbestos is also found in a natural state, known as naturally occurring asbestos. Exposure and disturbance of rock and soil that naturally contain asbestos can result in the release of fibers into the air and consequent exposure to the public. Asbestos most commonly occurs in ultramafic rock that has undergone partial or complete alteration to serpentine rock (serpentinite) and often contains chrysotile asbestos. In addition, another form of asbestos, tremolite, can be found associated with ultramafic rock, particularly near faults. Sources of asbestos emissions include unpaved roads or driveways surfaced with ultramafic rock, construction activities in ultramafic rock deposits, or rock quarrying activities where ultramafic rock is present. The project site is not located in an area likely to contain naturally occurring asbestos (California Department of Conservation 2000).

Verified Diesel Emission Control Strategies
USEPA and CARB tiered off-road emission standards only apply to new engines and off-road equipment can last several years. CARB has developed Verified Diesel Emission Control Strategies (VDECS), which are devices, systems, or strategies used to achieve the highest level of pollution control from existing off-road vehicles, to help reduce emissions from existing engines. VDECS are designed primarily for the reduction of diesel PM emissions and have been verified by CARB. There are three levels of VDECS, the most effective of which is the Level 3 VDECS. Tier 4 engines are not required to install VDECS because they already meet the emissions standards for lower tiered equipment with installed controls.

California Diesel Risk Reduction Plan
CARB Diesel Risk Reduction Plan has led to the adoption of new state regulatory standards for all new on-road, off-road, and stationary diesel-fueled engines and vehicles to reduce DPM emissions by about 90 percent overall from year 2000 levels. The projected emission benefits associated with the full implementation of this plan, including federal measures, are reductions in DPM emissions and associated cancer risks of 75 percent by 2010, and 85 percent by 2020.

Tanner Air Toxics Act and Air Toxics Hot Spots Information and Assessment Act
Toxic Air Contaminants (TACs) in California are primarily regulated through the Tanner Air Toxics Act (AB 1807) and the Air Toxics Hot Spots Information and Assessment Act of 1987 (AB 2588), also known as the Hot Spots Act. To date, CARB has identified more than 21 TACs and has adopted the USEPA list of Hazardous Air Pollutants (HAPs) as TACs.

Carl Moyer Memorial Air Quality Standards Attainment Program The Carl Moyer Memorial Air Quality Standards Attainment Program (Carl Moyer Program), a partnership between the CARB and local air districts, issues grants to replace or retrofit older engines and equipment with engines and equipment that exceed current regulatory requirements 319
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to reduce air pollution. Money collected through the Carl Moyer Program complements California’s regulatory program by providing incentives to effect early or extra emission reductions, especially from emission sources in environmental justice communities and areas disproportionately affected by air pollution.

The program has established guidelines and criteria for the funding of emissions reduction projects.

Within the San Francisco Bay Area Air Basin (Air Basin), the BAAQMD administers the Carl Moyer Program. The program has established guidelines and criteria for the funding of emissions reduction projects. Within the Air Basin, the BAAQMD administers the Carl Moyer Program. The program establishes cost-effectiveness criteria for funding emission reductions projects, which under the final 2017 Carl Moyer Program Guidelines are $30,000 per weighted ton of NOX, ROG, and PM. c. Regional and Local Regulations
Bay Area Clean Air Plan
The BAAQMD is responsible for assuring that the federal and state ambient air quality standards are attained and maintained in the Bay Area. BAAQMD is also responsible for adopting and enforcing rules and regulations concerning air pollutant sources, issuing permits for stationary sources of air pollutants, inspecting stationary sources of air pollutants, responding to citizen complaints, monitoring ambient air quality and meteorological conditions, awarding grants to reduce motor vehicle emissions, conducting public education campaigns, as well as many other activities.

BAAQMD adopted the Bay Area Clean Air Plan: Spare the Air, Cool the Climate (Bay Area Clean Air Plan) on April 19, 2017, as an update to the 2010 Clean Air Plan. The BAAQMD prepared the 2017 Clean Air Plan in cooperation with the Metropolitan Transportation Commission (MTC) and the ABAG. The goals of the 2017 Clean Air Plan are to reduce regional air pollutants and climate pollutants to improve the health of Bay Area residents for the next decades. The 2017 Clean Air Plan aims to lead the region into a post-carbon economy, continue progress toward attaining all State and federal air quality standards, and eliminate health risk disparities from air pollution exposure in Bay Area communities. The 2017 Clean Air Plan defines an integrated, multi-pollutant control strategy that includes 85 distinct feasible control measures to reduce emissions for four categories:
ground-level ozone and its precursors, ROG and NOX; PM (primarily PM2.5, and precursors to secondary PM2.5); TACs, and greenhouse gas emissions. The control measures are categorized based on the economic sector framework and include stationary sources, transportation, energy, buildings, agriculture, natural and working lands, waste management, and water. To protect public health, the control strategy will decrease population exposure to PM and TACs in communities that are most impacted by air pollution with the goal of eliminating disparities in exposure to air pollution between communities. The control strategy will also protect the climate by reducing greenhouse gas emissions and developing a long-range vision of how the Bay Area could look and function in a year 2050 post-carbon economy.

The focus of control measures includes aggressively targeting the largest source of GHG, ozone pollutants, and PM emissions: transportation. This includes more incentives for electric vehicle infrastructure, off-road electrification projects such as Caltrain and shore power at ports, and reducing emissions from trucks, school buses, marine vessels, locomotives, and off-road equipment.

Additionally, the BAAQMD will continue to work with regional and local governments to reduce Vehicle Miles Traveled (VMT) through the further funding of rideshare, bike and shuttle programs. 320
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BAAQMD Particulate Matter Plan
To fulfill federal air quality planning requirements, BAAQMD adopted a 2010 PM2.5 emissions inventory in 2012. The Bay Area Clean Air Plan also included several measures for reducing PM emissions from stationary sources and wood burning. In 2013, USEPA issued a final rule determining that the Bay Area has attained the 24-hour PM2.5 NAAQS, suspending federal SIP planning requirements for the SFBAAB. Despite this USEPA action, the SFBAAB will continue to be designated as nonattainment for the national 24-hour PM2.5 standard until BAAQMD submits a redesignation request and a maintenance plan to USEPA, and USEPA approves the proposed redesignation.

The SFBAAB is in nonattainment for the federal PM10 and federal PM2.5 standards. USEPA lowered the 24-hour PM2.5 standard from 65 micrograms per cubic meter (µg/m3 ) to 35 µg/m3 in 2006, and
designated the Air Basin as nonattainment for the new PM2.5 standard effective December 14, 2009.

BAAQMD believes that it would be premature to submit a redesignation request and PM2.5 maintenance plan at this time. Therefore, BAAQMD will prepare a “clean data” SIP to address the required elements, including:
 An emission inventory for primary PM2.5, as well as precursors to secondary PM formation; and  Amendments to the BAAQMD’s New Source Review regulation to address PM2.5.

The SFBAAB will continue to be designated as nonattainment for the 24-hour PM2.5 NAAQS until the Air District elects to submit, and the EPA approves, a redesignation request and maintenance plan.

At this time, BAAQMD does not have an applicable SIP with which the project would be required to comply. However, development facilitated by the project would be subject to the Bay Area Clean Air Plan, in addition to regulations set forth by BAAQMD as discussed in the following section.

BAAQMD Regulations
Regulation 2, Rule 1 (Permits–General Requirements)
The BAAQMD regulates new sources of air pollution and the modification and operation of existing sources through the issuances of authorities to construct and permits to operate. Regulation 2, Rule 1 provides an orderly procedure which the project would be required to comply with to receive authorities to construct or permits to operate from the BAAQMD, for new sources of air pollutants, as applicable.

Regulation 2, Rule 5 (New Source Review Permitting)
The BAAQMD regulates backup emergency generators, fire pumps, and other sources of TACs through its New Source Review (Regulation 2, Rule 5) permitting process. Although emergency generators are intended to be used only during periods of power outages, monthly testing of each generator is required. BAAQMD limits testing to no more than 50 hours per year. Each emergency generator installed is assumed to meet a minimum of Tier 2 emission standards (before control measures). As part of the permitting process, the BAAQMD limits the excess cancer risk from any facility to no more than 10 per 1-million-population for any permits that are applied for within a 2‐ year period, and would require any source that would result in an excess cancer risk greater than 1 per 1 million to install Best Available Control Technology for Toxics. 321
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Regulation 6, Rule 1 (Particulate Matter–General Requirements) The BAAQMD regulates PM emissions through Regulation 6 by means of establishing limitations on emission rates, emissions concentrations, and emission visibility and opacity. Regulation 6, Rule 1 provides existing standards for PM emissions that could result during project construction or operation that the project would be required to comply with, as applicable, such as the prohibition of emissions from any source for a period or aggregate periods of more than 3 minutes in any hour which are equal to or greater than 20 percent opacity.

Regulation 6, Rule 6, (Particulate Matter–Prohibition of Trackout) One rule by which the BAAQMD regulates PM includes Regulation 6, Rule 6, which prohibits PM trackout during project construction and operation. Regulation 6, Rule 6 requires the prevention or timely cleanup of trackout of solid materials onto paved public roads outside the boundaries of large bulk material sites, large construction sites, and large disturbed surface sides such as landfills.

Regulation 8, Rule 3 (Architectural Coatings)
This rule governs the manufacture, distribution, and sale of architectural coatings and limits the reactive organic gases content in paints and paint solvents. Although this rule does not directly apply to the project, it does dictate the ROG content of paint available for use during the construction.

Regulation 8, Rule 15 (Emulsified and Liquid Asphalts)
Although this rule does not directly apply to the project, it does dictate the reactive organic gases content of asphalt available for use during construction by regulating the sale and use of asphalt and limiting the ROG content in asphalt.

Regulation 1, Rule 301 (Odorous Emissions)
BAAQMD enforces odor control by helping the public to document a public nuisance. Upon receipt of a complaint, BAAQMD sends an investigator to interview the complainant and to locate the odor source if possible. BAAQMD typically brings a public nuisance court action when there are a substantial number of confirmed odor events within a 24-hour period. An odor source with five or more confirmed complaints per year averaged over 3 years is considered to have a substantial effect on receptors. Several BAAQMD regulations and rules apply to odorous emissions. Regulation 1, Rule 301 is the nuisance provision that states that sources cannot emit air contaminants that cause nuisance to a number of persons. Regulation 7 specifies limits for the discharge of odorous substances where BAAQMD receives complaints from 10 or more complainants within a 90-day period. Regulation 7 also precludes discharge of an odorous substance that causes the ambient air at or beyond the property line to be odorous after dilution with 4 parts of odor-free air, and specifies maximum limits on the emission of certain odorous compounds.

Regulation 9, Rule 8 (Inorganic Gaseous Pollutants–Nitrogen Oxides and Carbon Monoxide from Stationary Internal Combustion Engines)
Under Regulation 9, Rule 8, the BAAQMD regulates the emissions of nitrogen oxides and carbon monoxide from stationary internal combustion engines with an output rated by the manufacturer at more than 50 brake horsepower. As such, any proposed stationary source equipment (e.g., backup generators, fire pumps) which would be greater than 50 horsepower would require a BAAQMD permit under Regulation 9, Rule 8 to operate.
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Regulation 11, Rule 2 (Hazardous Pollutants–Asbestos Demolition, Renovation, and Manufacturing)
Under Regulation 11, Rule 2, the BAAQMD regulates emissions of asbestos to the atmosphere during demolition, renovation, milling, and manufacturing and establishes appropriate waste disposal procedures. Any of these activities which pose the potential to generate emissions of airborne asbestos are required to comply with the appropriate provisions of this regulation.

Plan Bay Area
On October 2021, the MTC approved Plan Bay Area 2050. Plan Bay Area includes integrated land use and transportation strategies for the region and was developed through OneBayArea, a joint initiative between ABAG, BAAQMD, MTC, and the San Francisco Bay Conservation and Development Commission. Plan Bay Area is also considered the ABAG/MTC Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS). In accordance with SB 743, Plan Bay Area included elements designed to encourage the type of land-use development to meet three primary objectives. First, Roadway Level of Service (LOS) could not be considered an environmental impact under the California Environmental Quality Act (CEQA). Second, it introduced changes to Vehicle Miles Traveled (VMT) per capita as a determinant of environmental impact. Third, the use of VMT as an environmental impact in CEQA is considered a mechanism for achieving State and regional GHG reduction goals. As a regional land use plan, Plan Bay Area aims to reduce per-capita GHG emissions through the promotion of more compact, mixed-use residential and commercial neighborhoods located near transit (ABAG; MTC 2021).

American Canyon General Plan
The current American Canyon General Plan contains objectives and policies that help address air quality and reduce the community’s vulnerability to air pollution. The following objectives and policies from the City’s General Plan are relevant to air quality and apply to the project:

Goal 8F: Reduce consumption of nonrenewable energy sources and support the development and utilization of new energy sources.

Objective 8.22: Minimize transportation-related energy consumption.

Policy 8.22.1: Encourage the development of mixed use, pedestrian friendly employment/residential centers that help minimize vehicle trips in American Canyon and contribute to a reduction in energy consumption.

Policy 8.22.3: Require that Development Plans provide for linkages between bicycle and pedestrian circulation systems and transit and employment centers, in accordance with established areawide plans.

Policy 8.22.4: Maintain a system of traffic signals and controls that minimizes waiting time and vehicle speed changes through routes.

Policy 8.22.5: Require that Development Plans provide for High-Occupancy Vehicles (HOV) and public transportation, where feasible, through the provision of appropriate transit areas and park-and-ride locations along public transportation routes. 323
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Objective 8.23: Reduce Energy consumption in buildings.

Policy 8.23.1: Require that developers employ energy-efficient subdivision and site planning methods as well as building design. Measures to be considered include building orientation and shading, landscaping, building reflectance, use of active and passive solar heating and hot water system, etc. In establishing these energy related design requirements, the City shall balance energy-efficient design with good planning principles.

Objective 1.37: Consider initiatives to reduce direct and indirect greenhouse gas (GHG) emissions from transportation sources, and from new, renovated, and existing development in the City.

Policy 1.37.6: Reduce vehicle engine idling in American Canyon by educating the broader community (i.e., businesses, commuters, residents) on the greenhouse gas impacts caused by engine idling, and implementing feasible commercial vehicle regulations.

4.3.3 Impact Analysis
a. Significance Thresholds and Methodology
Significance Thresholds
Based on Appendix G of the CEQA Guidelines a project may be deemed to have a significant impact on air quality if it would:

Conflict with or obstruct implementation of the applicable air quality plan; Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard; Expose sensitive receptors to substantial pollutant concentrations; or Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

This analysis uses the BAAQMD 2017 CEQA Air Quality Guidelines to evaluate air quality.

Construction Criteria Pollutant and TAC Emissions
Construction-related emissions are limited in duration but may still cause adverse air quality impacts. Construction would generate emissions from three primary sources: the operation of construction vehicles (e.g., scrapers, loaders, dump trucks, etc.); ground disturbance during site preparation and grading, which creates fugitive dust; and the application of asphalt, paint, or other oil-based substances.

At this time, the pace, location, and duration associated with construction are not sufficiently detailed to quantify a specific emission impact, and thus it would be speculative to do so. Rather, construction criteria pollutant and TAC emissions impacts for the project are discussed qualitatively, pursuant to the BAAQMD 2017 CEQA Air Quality Guidelines.

Operation Criteria Pollutant and TAC Emissions
Based on plan-level guidance from the BAAQMD 2017 CEQA Air Quality Guidelines, long-term operational criteria pollutant and TAC emissions associated with implementation of the project are discussed qualitatively by comparing the project to the 2017 Clean Air Plan goals, policies, and 324
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control measures. In addition, comparing the rate of increase of plan VMT and population is recommended by BAAQMD for determining significance of criteria pollutants. If the project does not meet either criterion, then impacts would be potentially significant.

Odors
The impact analysis qualitatively evaluates the types of land uses facilitated by the project to evaluate whether major sources of anticipated odors would be present and, if so, whether those sources would likely generate objectionable odors. According to the BAAQMD 2017 CEQA Air Quality Guidelines, the project-level threshold for odor sources is if they result in five confirmed complaints per year averaged over three years within the screening distance for land uses shown in Table 3-3 of the guidelines (BAAQMD 2017b). The plan-level threshold states to identify the location and include policies to reduce the impacts of existing or planned sources of odors. None of the land uses identified as odor sources in the 2017 guidelines are planned as part of the project. The significance thresholds for odor impacts are qualitative in nature. Specifically, an odor-generating source with five or more confirmed complaints in the new source area per year averaged over three years is considered to have a significant impact on receptors within the screening distances provided in the guidelines.

Methodology
Consistency with Air Quality Plan
The applicable air quality plan is the BAAQMD 2017 Bay Area Clean Air Plan, which identifies measures to:
 Reduce emissions and reduce ambient concentrations of air pollutants; and  Safeguard public health by reducing exposure to the air pollutants that pose the greatest health risk, with an emphasis on protecting the communities most heavily affected by air pollution.

The project would be consistent with the Bay Area Clean Air Plan if it would support the Clean Air Plan goals, include applicable control measures, and not disrupt or hinder implementation of Clean Air Plan. Consistency with the Clean Air Plan is the basis for determining whether the project would conflict with or obstruct implementation of an applicable air quality plan.

Construction Criteria Pollutant and TAC Emissions Thresholds BAAQMD’s 2017 CEQA Air Quality Guidelines have no plan-level significance thresholds for construction air pollutants emissions. However, they do include the individual project-level thresholds for construction-related and long-term operational emissions of air pollutants. These thresholds represent the levels at which a project’s individual emissions of criteria air pollutants or precursors would result in a cumulatively considerable contribution to the SFBAAB‘s existing air quality conditions. Construction emissions associated with implementation of the project are discussed qualitatively to evaluate potential air quality impacts.

For health risks associated with TAC and PM2.5 emissions, the BAAQMD 2017 CEQA Air Quality Guidelines state a project would result in a significant impact if the any of the following thresholds are exceeded:
 Non-compliance with Qualified Community Risk Reduction Plan;  Increased cancer risk of > 10.0 in a million;
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 Increased non-cancer risk of > 1.0 Hazard Index (Chronic or Acute); or  Ambient PM2.5 increase of > 0.3 µg/m3 annual average
In addition, a project would have a cumulatively considerably impact associated with health risks from TAC and PM2.5 emissions if the aggregate total emissions of all past, present, and foreseeable future sources within a 1,000-foot radius of the fenceline of the source plus the project’s contribution exceed any of the following thresholds:
 Non-compliance with Qualified Community Risk Reduction Plan;  Increased cancer risk of > 100.0 in a million;
 Increased non-cancer risk of > 10.0 Hazard Index (Chronic or Acute); or  Ambient PM2.5 increase of > 0.8 µg/m3 annual average
Operational Criteria Pollutant and TAC Emissions Thresholds BAAQMD’s 2017 CEQA Air Quality Guidelines contain specific operational plan-level significance thresholds for criteria air pollutants. Plans must show the following over the planning period:
 Consistency with current air quality plan control measures  VMT or vehicle trips increase is less than or equal to the plan’s projected population increase If a plan can demonstrate consistency with both of these criteria, then impacts are considered less than significant. The same thresholds listed above for construction health risks from TAC and PM2.5 would apply to operation.
b. Project Impacts and Mitigation Measures
Threshold 1: Would the project conflict with or obstruct implementation of the applicable air quality plan?
Impact AQ-1 THE PROJECT WOULD BE CONSISTENT WITH THE BAAQMD’S 2017 CLEAN AIR PLAN.

IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Under BAAQMD’s methodology, a determination of consistency with CEQA Guidelines thresholds should demonstrate that a project:
 Supports the primary goals of the 2017 Clean Air Plan;  Includes applicable control measures from the 2017 Clean Air Plan; and  Does not disrupt or hinder implementation of any 2017 Clean Air Plan control measures.

The following includes a discussion of consistency with these criteria for the project. The 2017 Clean Air Plan contains 85 control measures aimed at reducing air pollution and protecting the climate in the Bay Area. For consistency with climate planning efforts at the State level, the control strategies in the 2017 Clean Air Plan are based on the same economic sector framework used by CARB, which encompass stationary sources, transportation, energy, buildings, agriculture, natural and working lands, waste management, water, and super-GHG pollutants (such as methane and hydrofluorocarbons). Table 4.3-4 identifies applicable control measures and discusses project consistency with the 2017 Clean Air Plan.
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Table 4.3-4 Clean Air Plan Control Measures Consistency Analysis Control Measures Consistency
Stationary Sources
SS18: Basin-Wide Combustion Strategy. Stabilize and
then reduce emissions of GHGs, criteria air pollutant and toxic emissions from stationary combustion sources
throughout the Air District by first establishing carbon intensity caps on major GHG sources, and then adopting
new rules to (1) reduce fuel use on a source-type by
source-type basis, and (2) evaluate alternatives to
decarbonize abatement devices.

SS21: New Source Review for Air Toxics. Propose
revisions to Air District Rule 2-5, New Source Review of Toxic Air Contaminants, based on OEHHA’s 2015 Health
Risk Assessment Guidelines and CARB/ CAPCOA’s 2015
Risk Management Guidance. Revise the Air District’s
health risk assessment trigger levels for each toxic air contaminant using the 2015 Guidelines and most recent
health effects values.

Consistent. Stationary sources are regulated directly by BAAQMD, which routinely adopts/revises rules or
regulations to implement the Stationary Source control
measures to reduce stationary source emissions.

Therefore, any new stationary sources associated with the project would be required to comply with BAAQMD’s
regulations.

Transportation
TR2: Trip Reduction Programs. Implement the regional
Commuter Benefits Program (Rule 14-1) that requires
employers with 50 or more Bay Area employees to
provide commuter benefits. Encourage trip reduction
policies and programs in local plans, e.g., general and specific plans, while providing grants to support trip
reduction efforts. Encourage local governments to require mitigation of vehicle travel as part of new development approval, to adopt transit benefits ordinances in order to reduce transit costs to employees, and to develop
innovative ways to encourage rideshare, transit, cycling, and walking for work trips. Fund various employer-based trip reduction programs.

Consistent: Development facilitated by the project would promote compatible land uses resulting in City residents living and working in closer proximity to each other.

Parcels designated as Paoli Light Industrial and Paoli
Commercial Overlay District would allow for commercial
and commercially-related uses that would facilitate
vehicle access and proximity of jobs near housing within the City. The project would be consistent with the buildout street network envisioned by the American Canyon General Plan Circulation Element, and the bikeway
network envisioned by the American Canyon Bicycle Plan, that includes the extension of Newell Drive north from its current terminus concurrent with future development,
including the project site. As envisioned, Newell Drive would eventually connect American Canyon Boulevard in
the south with SR 29 at Green Island Road, at the
northwest corner of the project site. The future extension would be a 2-lane collector with one motor vehicle lane in each direction, bicycle lanes and sidewalks. The project would not preclude the future provision of bicycle paths along the Union Pacific Railroad tracks, consistent with the American Canyon Bicycle Plan. In addition, Mitigation
Measure GHG-1 (see Section 4.8, Greenhouse Gas
Emissions) would require that industrial and commercial operators establish and promote a rideshare program that discourages single-occupancy vehicle trips and provides financial incentives for alternate modes of transportation including carpooling, public transit, and biking.

TR13: Parking Policies. Encourage parking policies and
programs in local plans, e.g., reduce minimum parking
requirements; limit the supply of off-street parking in transit-oriented areas; unbundle the price of parking
spaces; support implementation of demand-based pricing
(such as “SF Park”) in high-traffic areas.

Consistent: Future development would be required to
comply with existing City parking standards. In addition, per Mitigation Measure GHG-1, the project would achieve compliance with off-street Tier 2 EV parking requirements by land use type in the most recently adopted version of CALGreen. Additionally, Mitigation Measure GHG-1 would
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Control Measures Consistency
and promote a rideshare program that discourages singleoccupancy vehicle trips and provides financial incentives for alternate modes of transportation including
carpooling, public transit, and biking.

Energy
EN1: Decarbonize Electricity Production. Engage with
PG&E, municipal electric utilities and CCEs to maximize the amount of renewable energy contributing to the
production of electricity within the Bay Area as well as electricity imported into the region. Work with local
governments to implement local renewable energy
programs. Engage with stakeholders including dairy farms, forest managers, water treatment facilities, food
processors, public works agencies and waste management
to increase use of biomass in electricity production.

EN2: Decrease Electricity Demand. Work with local
governments to adopt additional energy-efficiency
policies and programs. Support local government energy
efficiency program via best practices, model ordinances, and technical support. Work with partners to develop
messaging to decrease electricity demand during peak
times.

Consistent. Measures EN1 and EN2 are intended to
decrease energy use as a means of reducing adverse air
quality emissions. Additionally, buildings developed as part of the project would comply with 2022 Building
Energy Efficiency Standards (or most recent version of the California Building Code) requirements that commercial
buildings be electric-ready and standards for expanded
solar and battery storage. The Building Energy Efficiency Standards are updated every three years and the project would be subject to the 2022 California Building Standards when they go into effect on January 1, 2023.

Buildings
BL1: Green Buildings. Collaborate with partners such as KyotoUSA to identify energy-related improvements and
opportunities for on-site renewable energy systems in
school districts; investigate funding strategies to
implement upgrades. Identify barriers to effective local implementation of the CALGreen (Title 24) statewide
building energy code; develop solutions to improve
implementation/enforcement. Work with ABAG’s BayREN
program to make additional funding available for energyrelated projects in the buildings sector. Engage with additional partners to target reducing emissions from
specific types of buildings.

BL2: Decarbonize Buildings. Explore potential Air District rulemaking options regarding the sale of fossil fuel-based space and water heating systems for both residential and commercial use. Explore incentives for property owners to replace their furnace, water heater or natural-gas
powered appliances with zero-carbon alternatives. Update Air District guidance documents to recommend that
commercial and multi-family developments install ground source heat pumps and solar hot water heaters.

Consistent: Measures BL1 and BL2 focus on working with
local governments to adopt the best GHG emissions
control practices and policies. As discussed above for the Energy and Climate control measures, buildings developed as part of the project would comply with 2022 Building
Energy Efficiency Standards’ (or most recent version of the California Building Code) requirements that commercial
buildings be electric-ready and standards for expanded
solar and battery storage. The Building Energy Efficiency Standards are updated every three years and the project would be subject to the 2022 California Building Standards when they go into effect on January 1, 2023.

Waste Management Control Measures
WA4: Recycling and Waste Reduction. Develop or identify and promote model ordinances on community-wide zero
waste goals and recycling of construction and demolition materials in commercial and public construction projects Consistent. Measure WA4 include strategies to increase
waste diversion rates through efforts to reduce, reuse, and recycle. Development under the project would
comply with Assembly Bill (AB) 341, which requires
mandatory commercial recycling for businesses that
generate four cubic yards or more of commercial solid
waste per week. For further discussion of waste diversion, please refer to Section 4.17, Utilities and Service Systems. 328
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BAAQMD has identified examples of how a project or plan may disrupt or delay local government implementation of these control measures, such as a project that may preclude an extension of a transit line or bike path, or that propose excessive parking beyond parking requirements.

Development within the project area would not disrupt or delay local government implementation of control measures. The future Newell Drive extension would be a 2-lane collector with one motor vehicle lane in each direction, bicycle lanes, and sidewalks. The project would not preclude the future provision of bicycle paths along the Union Pacific Railroad tracks, consistent with the American Canyon Bicycle Plan.

Overall, the project would be consistent with the three criteria for evaluating consistency with the 2017 Clean Air Plan. As such, the project would not conflict with or obstruct implementation of the applicable air quality plan, and this impact would be less than significant.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

Threshold 2: Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
Impact AQ-2 THE PROJECT WOULD NOT RESULT IN A CUMULATIVELY CONSIDERABLE NET INCREASE OF OPERATIONAL CRITERIA POLLUTANTS. IMPACTS FROM CONSTRUCTION WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION. IMPACTS FROM OPERATION WOULD BE LESS THAN SIGNIFICANT.

Construction
The project would involve activities that result in air pollutant emissions. Specifically, construction activities such as demolition, grading, construction worker travel, delivery and hauling of construction supplies and debris, and fuel combustion by on-site construction equipment would generate pollutant emissions. These construction activities would create emissions of dust, fumes, equipment exhaust, and other air contaminants, particularly during site preparation and grading.

The extent of daily emissions, particularly ROGs and NOX emissions, generated by construction equipment, would depend on the quantity of equipment used and the hours of operation for each project. The extent of PM2.5 and PM10 emissions would depend upon the following factors: 1) the amount of disturbed soils; 2) the length of disturbance time; 3) whether existing structures are demolished; 4) whether excavation is involved; and 5) whether transporting excavated materials offsite is necessary. Dust emissions can lead to both nuisance and health impacts. According to the 2017 BAAQMD CEQA Air Quality Guidelines, PM2.5 is the greatest pollutant of concern during construction.

The BAAQMD 2017 CEQA Air Quality Guidelines have no plan-level significance thresholds for construction air pollutant emissions that would apply to the project. However, the guidelines include project-level thresholds for construction emissions. If an individual project’s construction emissions fall below the project-level thresholds, the project’s impacts on regional air quality would be individually and cumulatively less than significant. The BAAQMD has also identified feasible fugitive dust control measures for construction activities. These Basic Construction Mitigation 329
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Measures are recommended for all projects. In addition, the BAAQMD and CARB have regulations that address the handling of hazardous air pollutants such as lead and asbestos, which could be aerially disbursed during demolition activities. BAAQMD rules and regulations address both the handling and transport of these contaminants. Construction of development facilitated by the project would temporarily increase air pollutant emissions, possibly creating localized areas of unhealthy air pollution concentrations or air quality nuisances, resulting in a potentially significant impact.

However, implementation of the BAAQMD Basic Construction Mitigation Measures, which would be required with implementation of Mitigation Measures AQ-1, during future project-level construction would reduce fugitive dust emissions from construction activities. Actions include watering onsite and reducing vehicle speed on unpaved roads to limit the amount of soil and dust disturbed. With implementation of Mitigation Measure AQ-1, cumulative construction impacts associated with violating an air quality standard or contributing substantially to an existing or projected air quality violation in terms of criteria air pollutant emissions would be less than significant with mitigation.

Operation
The greatest source of criteria pollutants in American Canyon is and would continue to be from transportation sources, specifically mobile emissions from roadway traffic. The project emphasizes reducing VMT on area roadways through emphasizing greater mixed use in the area and proximity of residents to jobs. According to the BAAQMD 2017 CEQA Air Quality Guidelines, the threshold for criteria air pollutants and precursors requires a comparison of the percent increase in VMT and population. Table 4.3-5 summarizes the net increase in population versus VMT for cumulative plus project buildout conditions based on data provided by GHD (2022).

Table 4.3-5 Comparison of VMT and Population Increase due to the Project Scenario Existing Cumulative Plus Project Buildout a Net Increase Population 22,959 29,001 6,042
Percentage change 26%
VMT 562,492 568,813 6,321
Percentage change 1%
Note:
a. Cumulative Conditions with the project is based on Year 2045 citywide residential and commercial growth, as well as projected regional land use growth
Source: GHD 2022
The project emphasizes changing land uses to concentrate growth and jobs and services near residences to reduce singular vehicle trips. As shown in Table 4.3-5, the City’s population increase would be proportionately greater than the VMT increase. If a plan’s VMT increase, under the cumulative condition, is less than or equal to the plan’s projected population increase, impacts to operational criteria pollutant emissions would be less than significant. As such, impacts from project operation would be less than significant.
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Mitigation Measures
AQ-1 Implement BAAQMD Basic Construction Mitigation Measures To reduce fugitive dust emissions from the construction of individual projects, the applicant shall implement the BAAQMD Basic Construction Mitigation Measures. The BAAQMD Basic Construction Mitigation Measures are listed below:

All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times a day.

All haul trucks transporting soil, sand, or other loose material off-site shall be covered.

All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.

All vehicle speeds on unpaved roads shall be limited to 15 miles per hour.

All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible.

Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.

Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to five minutes (as required by the California Airborne Toxics Control Measure Title 13, Section 2485 of California Code of Regulations). Clear signage shall be provided for construction workers at all access points.

All construction equipment shall be maintained and properly tuned in accordance with manufacture’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper conditions prior to operation.

Post a publicly visible sign with the telephone number and person to contact at the City of American Canyon regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s number shall also be visible to ensure compliance with applicable regulations.

Significance After Mitigation
Impacts on criteria air pollutants during construction would be less than significant after implementation of Mitigation Measure AQ-1.

Threshold 3: Would the project expose sensitive receptors to substantial pollutant concentrations?
Impact AQ-3 CONSTRUCTION ACTIVITIES FOR FUTURE INDIVIDUAL PROJECTS LASTING LONGER THAN TWO MONTHS OR LOCATED WITHIN 1,000 FEET OF SENSITIVE RECEPTORS COULD EXPOSE SENSITIVE RECEPTORS TO SUBSTANTIAL POLLUTANT CONCENTRATIONS. IMPLEMENTATION OF THE PROJECT MAY ALSO EXPOSE SENSITIVE RECEPTORS TO OPERATIONAL SOURCES OF TOXIC AIR CONTAMINANTS. IMPACTS WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION.

Construction
The project would result in Diesel particulate matter (DPM) exhaust emissions from off-road, heavyduty diesel equipment associated with site preparation (e.g., excavation, grading, clearing), building 331
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construction, and other miscellaneous construction activities. The potential cancer risk from inhaling DPM, as discussed below, outweighs the potential non-cancer2 health impacts (CARB 2022b).

Generation of DPM from construction typically occurs in a single area for a short period. Project construction would occur over approximately seven years (assuming a buildout year of 2030), but use of diesel-powered construction equipment in any one area would likely occur for no more than a few years for an individual project and would cease when construction is completed in that area. It is impossible to quantify risk without identified specific project details and locations.

The dose to which the receptors are exposed is the primary factor used to determine health risk.

Dose is a function of the concentration of a substance or substances in the environment and the extent of exposure that person has with the substance. Dose is positively correlated with time, meaning that a longer exposure period would result in a higher exposure level for the Maximally Exposed Individual. The risks estimated for a Maximally Exposed Individual are higher if a fixed exposure occurs over a longer period. According to the California Office of Environmental Health Hazard Assessment (OEHHA), health risk assessments, which determine the exposure of sensitive receptors to toxic emissions, should be based on a 70-year exposure period; however, such assessments should be limited to the period/duration of activities associated with the development (OEHHA 2015). BAAQMD uses an exposure period of 30 years (BAAQMD 2016).

The maximum PM10 and PM2.5 emissions would occur during demolition, site preparation and grading activities, which would only occur for a portion of the overall estimated timeframe of seven years for individual project construction. These activities would typically last for approximately two weeks to two years, depending on the extent of grading and excavation required (e.g., projects with subterranean parking structures or geological constraints require additional grading as compared to those without). PM10 and PM2.5 emissions would decrease for the remaining construction period because construction activities such as building construction and architectural coating would require less intensive construction equipment. While the maximum DPM emissions associated with demolition, site preparation, and grading activities would only occur for a portion of the overall construction period, these activities represent the worst-case condition for the total construction period. This would represent between 0.1 to 7 percent of the total 30-year exposure period for health risk calculation.

Future development facilitated by the project would also be required to be consistent with the applicable 2017 Clean Air Plan, BAAQMD regulatory requirements and control strategies, and the CARB In-Use Off-Road Diesel Vehicle Regulation, which are intended to reduce emissions from construction equipment and activities. Additionally, future development facilitated by the project would be required to comply with Mitigation Measure AQ-1 requiring implementation of construction emission measures which would reduce construction-related TACs. According to the OEHHA, construction of individual projects lasting longer than two months or placed within 1,000 feet of sensitive receptors could potentially expose nearby sensitive receptors to substantial pollutant concentrations and therefore could result in potentially significant risk impacts. These future projects could exceed BAAQMD’s thresholds of an increased cancer risk of greater than 10.0 in a million and an increased non-cancer risk of greater than 1.0 Hazard Index (Chronic or Acute).

Therefore, construction impacts from TAC emissions would be potentially significant. However, implementation of Mitigation Measure AQ-2 would require the preparation of a Construction 2 Non-cancer risks include premature death, hospitalizations and emergency department visits for exacerbated chronic heart and lung disease, including asthma, increased respiratory symptoms, and decreased lung function (CARB 2021a). 332
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Health Risk Assessment for new projects and the Newell Drive Extension and would mitigate potential construction-related TACs exposure impacts to a less than significant level.

Operation
Buildout facilitated by the project would potentially site land uses that typically generate TAC, such as industrial land uses, in proximity to residential land uses. Additionally, if the proposed commercial uses site a new stationary TAC source, like an emergency generator, then said stationary source would be required to receive a permit from BAAQMD. The permitting process would ensure that the stationary source does not present a health risk to existing nearby sensitive receptors.

New industrial or warehousing operations could generate substantial DPM emissions from off-road equipment use and truck idling. In addition, some warehousing and industrial facilities may include use of Transport Refrigeration Units for cold storage. Such potential future uses could generate an increase in DPM that would contribute to cancer and noncancer health risk at nearby sensitive receptors. Without project-specific analysis health risk impactsfrom nonpermitted sources associated with development of industrial and commercial land uses are considered significant.

Implementation of Mitigation Measure AQ-3, which would require the preparation of an Operational Health Risk Assessment would reduce this impact to a less than significant level.

In addition, the proposed extension of Newell Drive would add a new source of TAC emissions to the project area that could adversely affect sensitive receptors residing in close proximity. For roadways, BAAQMD has developed a Roadway Screening Analysis Calculator to assess whether new roadways with traffic volumes over 10,000 vehicles per day may have a potentially significant impact. Project-specific data was input to the screening calculator such as the county, roadway direction, and future vehicle volume. Based on traffic data, under cumulative plus project conditions, the Newell Drive extension is estimated to have up to 28,072 vehicles per day (GHD 2022). The nearest off-site sensitive receptor to the proposed extension is a residence located approximately 850 feet to the south on Watson Lane. At this distance, the increased cancer risk at the nearest off-site residence would be up to 1.6 in one million, which would not exceed the BAAQMD significance threshold of 10 in one million increased cancer risk. The annual PM2.5 concentration would be up to 0.04 ug/m3
, which would not exceed the BAAQMD significance
threshold of 0.3 ug/m3
. Therefore, community health risk impacts from the proposed Newell Drive Extension would be less than significant.

Mitigation Measures
AQ-2 Conduct Construction Health Risk Assessment
Prior to issuance of a grading or building permit, whichever occurs first, the applicant shall submit to the City a construction health risk assessment (HRA) in accordance with BAAQMD recommendations for any development project (including the proposed Newell Drive extension) that has at least one the following characteristics:
 The project is located within 1,000 feet of sensitive receptors.  Project construction would last longer than two months.  Project construction would not utilize equipment rated USEPA Tier 4 (for equipment of 50 horsepower or more); construction equipment fitted with Level 3 Diesel Particulate Filters (for all equipment of 50 horsepower or more); or alternative fuel construction equipment. 333
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If the HRA determines that construction will exceed BAAQMD significance thresholds, the HRA shall provide mitigation measures to reduce the impact to less than significant, including but not limited to requiring the use of Tier 4 engines, Level 3 Diesel Particulate Filters, and/or alternative fuel construction equipment.

AQ-3 Conduct Operational Health Risk Assessment
Prior to submittal of a subsequent discretionary development permit application for industrial, warehousing, or commercial land uses that would generate at least 100 diesel trucks per day or 40 or more trucks with diesel-powered transport refrigeration units per day, the applicant shall submit an operational health risk assessment (HRA) or submit proof that an HRA is not required in accordance with BAAQMD thresholds. If required, the operational HRA shall be prepared in accordance with the Office of Environmental Health Hazard Assessment and BAAQMD requirements, and mitigated to an acceptable level. Typical measures to reduce risk impacts may include, but are not limited to:
 Restricting idling on-site beyond Air Toxic Control Measures idling restrictions, as feasible.  Electrifying warehousing docks.
 Truck Electric Vehicle (EV) Capable trailer spaces.
 Requiring use of newer equipment and/or vehicles.
 Restricting off-site truck travel through the creation of truck routes.

The operational HRA shall be provided to the City for review and concurrence prior to project approval.

Significance After Mitigation
Construction and operational related TACs exposure impacts would be less than significant with implementation of Mitigation Measures AQ-2 and AQ-3.

Threshold 4: Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Impact AQ-4 THE PROJECT WOULD NOT CREATE OBJECTIONABLE ODORS THAT COULD ADVERSELY AFFECT A SUBSTANTIAL NUMBER OF PEOPLE. IMPACTS RELATED TO ODORS WOULD BE LESS THAN SIGNIFICANT.

Construction of the project would require the operation of construction equipment and asphalt paving, which could generate oil, diesel fuel, and asphalt odors. The odors would be limited to the construction period and would be temporary. Therefore, odors emitted from the construction of individual future projects under the project would be less than significant.

As stated in the BAAQMD CEQA Guidelines, land uses typically producing objectionable odors include agricultural uses, wastewater treatment plants, food manufacturing plants, chemical plants, composting, refineries, landfills, and confined animal facilities. Development facilitated by the project would include commercial and light industrial uses, such as research & development. These land uses typically do not produce objectionable odors. Odors from new developments proposed under the project would also be evaluated under BAAQMD Regulation 7: Odorous Substances, the standard BAAQMD odor complaint procedures, and would be required to implement applicable best management practices that would limit exposure of new sensitive receptors to odors. Other odors from buildout of the project would be limited to odors associated with vehicle and engine exhaust 334
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and idling; however, odors from vehicles are not stationary and are dispersed throughout the roadway network. Therefore, operational odor impacts would be less than significant.

Mitigation Measures
No mitigation measures would be required.

Leve of Significance
Impacts would be less than significant without mitigation.

4.3.4 Cumulative Impacts
The geographic scope of the cumulative air quality analysis is the regional air basin, specifically the SFBAAB. The cumulative analysis considers the nearby past, present, and reasonably foreseeable future plans and projects within the City in addition to proposed plans.

Criteria Air Pollutants
The SFBAAB is in non-attainment for federal standards of ozone and PM2.5 and in non-attainment for the State standard for ozone, PM2.5, and PM10. The SFBAAB is in attainment of all other federal and State standards. Development facilitated by the project would generate particulate matter and the ozone precursors (ROG and NOX) in the area during construction and operation. As described under Impact AQ-1, the project would be inconsistent with the overall goal of the 2017 Clean Air Plan control measures as development facilitated by the project would potentially include light industrial land uses. However, future projects would comply with the latest Title 24 regulations and would increase density in urban areas in proximity to transit, allowing for greater use of alternative modes of transportation. Development facilitated by the project does not contain elements that would disrupt or hinder implementation of any 2017 Clean Air Plan control measures. In addition, the project would support the primary goals of the 2017 Clean Air Plan. Discussion of these impacts considers the cumulative nature of criteria pollutants in the region. Therefore, project would not result in a cumulatively considerable contribution to a conflict with or obstruction of implementation of the applicable air quality plan.

As described under Impact AQ-2, future construction facilitated by the project would temporarily increase air pollutant emissions, possibly creating localized areas of unhealthy air pollution levels or air quality nuisances. BAAQMD has identified feasible fugitive dust control measures for construction activities because fugitive PM10 and PM2.5 is of concern. These temporary impacts would be mitigated with Mitigation Measure AQ-1. Discussion of these impacts considers the cumulative nature of criteria pollutants in the region; therefore, with mitigation the project would not result in a cumulatively considerable net increase of a criteria pollutant from construction emissions.

In addition, as described under Impact AQ-2, the cumulative plus project scenario would result in an increase of population that would proportionally exceed the projected VMT increase. Therefore, per the BAAQMD CEQA Air Quality Guidelines for operational emissions from plans, impacts from operational criteria pollutants would be cumulatively less than significant.

Toxic Air Contaminants
As identified under Impact AQ-3, development facilitated by the project would not have a significant impact from CO hotspots or TACs. Discussion of these impacts considers the cumulative nature of 335
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the pollutants in the region. In other words, the cancer risk and non-cancer risk thresholds have been set per existing cancer risks in the area and exceeding those thresholds would be considered a cumulative impact. As implementation of the project would not exceed those thresholds with identified mitigation, it would not expose sensitive receptors to a cumulatively considerable amount of substantial pollutant concentrations from CO hotspots or TACs. Therefore, the cumulative impact related to toxic air contaminants would be less than significant with mitigation.

Odors
As identified under Impact AQ-4, development facilitated by the project would not have a significant impact from odor emissions. Construction emissions would disperse rapidly with distance, and therefore construction projects near one another would not result in combined odors above those analyzed. In addition, development would not contain uses known to result in objectionable odors and therefore cumulative odor impacts from multiple development would not result in a cumulatively considerable increase in odors. Therefore, the cumulative impact related to odors would be less than significant.
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4.4 Biological Resources
This section analyzes potential effects on biological resources related to implementation of the project. In October 2022, Rincon Consultants, Inc. prepared a Biological Resources Assessment (BRA), including a literature review and field reconnaissance survey to document existing site conditions, the potential presence of special-status biological resources (including plant and wildlife species), observed plant communities, waters and wetlands, and habitat for nesting birds. The following summarizes the findings of the assessment. The complete BRA is provided in Appendix B of this document.

4.4.1 Setting
a. Land Cover
The natural community/landcover descriptions listed below are based on the California Department of Fish and Wildlife (CDFW) California Wildlife Habitat Relationships classification scheme (CWHR) (Mayer and Laudenslayer 1988). Figure 4.4-1 shows the vegetation communities and land covers in the project site.

Non-Native Annual Grassland
Annual grasslands are herbaceous communities composed primarily of annual grass and forb species. This vegetation community exists throughout the project site, where introduced annual grasses are the dominant plant species. The dominant species observed included slender wild oats (Avena barbata), ripgut brome (Bromus diandrus), Italian rye grass (Festuca perennis), false barley (Hordeum murinum), yellow-star thistle (Centaurea solstitialis), black mustard (Brassica nigra), fennel (Foeniculum vulgare).

Waters
The North Slough and its surrounding area include annual grassland, primarily dominated by nonnative annual grasses with some coyote brush (Baccharis pilularis) in the uplands. The North Slough channel is mainly devoid of vegetation, though scattered patches of facultative hydrophytic species such as curly dock (Rumex crispus) were observed, and concrete lining is present in the channel near a wooden bridge over the North Slough. In addition, based on review of the U.S. Fish and Wildlife Service (USFWS) National Wetland Inventory, aerial imagery, and a site visit, there are some areas that drain to North Slough to the east of North Slough. These areas are covered with non-native annual grasses including scattered patches of Harding grass (Phalaris aquatica), pepperweed (Lepidium latifolium) and curly dock (Rumex crispus) interspersed with the grasses. It is not currently known whether these areas are jurisdictional features and as discussed further in Impact BIO-3, an evaluation as to whether these features are jurisdictional will be conducted in the future. North Slough is part of the Napa River watershed and drain runoff from the lands within and surrounding the project site.

The potential jurisdictional features have been historically diverted from their natural topographic drainages (i.e., the typical gradient being downhill and flowing north to south or east to west). The potential jurisdictional features originate on properties with vineyards to the east and are diverted through a system of culverts and ditches onto and through the project site, flowing into North Slough. The northern potential jurisdictional feature drains properties with vineyards to the east 337
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Figure 4.4-1 Landcover Types within the Project Boundary 338
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and is piped approximately 0.25 mile under vineyards and Watson Lane, where it outfalls along the east side of the railroad tracks and flows through a culvert underneath the railroad tracks through the project site toward North Slough. The southern potential jurisdictional feature is more substantially and circuitously modified, originating as a natural topographic drainage on the property with vineyards to the southeast where it is diverted into a French drain and culvert system departing from its natural topographic drainage, running diagonally to the northwest under approximately 0.25 mile of vineyards. It outfalls out of a culvert into a ditch along the east side of Watson Lane where it flows south to north along Watson Lane, under Watson Lane through an eastwest culvert system, continuing to the west in a linear ditch, then changing direction running south to north along the east side of the railroad tracks before it changes direction once more, flowing under the railroad tracks in an east-west facing culvert through the project site toward North Slough.

Urban
The urban land cover is completely anthropogenic and is composed of residential, commercial, and industrial development. Plant species within urban areas are typically comprised of ornamental plants and non-native invasive plant species, with large developed areas lacking vegetation. b. Special-Status Species
For the purposes of this analysis, special-status species include the following:
 Species listed as threatened or endangered under the Federal Endangered Species Act (FESA), including proposed and candidate species.
 Species listed as candidate, threatened, or endangered under the California Endangered Species Act (CESA).
 Species designated as Fully Protected by the California Fish and Game Code (CFGC), and Species of Special Concern or Watch List by CDFW.
 Plant species protected by the Native Plant Protection Act (NPPA) (State Rare).  Plant species with California Native Plant Society (CNPS) California Rare Plant Ranks (CRPR) 1A, 1B, 2A and 2B.
 Species designated as locally important by the Local Agency and/or otherwise protected through ordinance, local policy, or HCPs/NCCPs.

Queries of the USFWS Information, Planning, and Conservation System (IPaC) (USFWS 2022a), California Natural Diversity Database (CNDDB) (CDFW 2022a), and California Native Plant Society (CNPS) online Inventory of Rare and Endangered Plants of California (CNPS 2022) were conducted to obtain comprehensive information regarding special-status species and sensitive vegetation communities known or with potential to occur in the project site. Query of the CNPS inventory and CNDDB database included the Cordelia and Cuttings Wharf U. S. Geological Service (USGS) 7.5- minute topographic quadrangle and surrounding 10 quadrangles (Napa, Mt. George, Fairfield North, Fairfield South, Vine Hill, Benicia, Mare Island, Petaluma Point, Sears Point, and Sonoma). The results of these scientific database queries are compiled in the BRA, which is provided as Appendix B of this EIR (see Appendix D of the BRA). A query of the USFWS’ Critical Habitat Portal (USFWS 2022b) was conducted to determine if any USFWS-designated critical habitat occurs in the project site.

A total of 73 special-status plants and 54 special-status animals were identified within the 12 quadrangles queried (CNPS 2022 and CDFW 2022a). For the purposes of this analysis, special-status 339
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species with low potential to occur will not be addressed further because these species have a low likelihood of being present within the vicinity of the project site. None of the special status plant species were determined to have a moderate or greater potential to occur within the project site.

Of the 54 special-status wildlife species evaluated, three species, western burrowing owl (Athene cunicularia), Swainson’s hawk (Buteo swainsoni), and white-tailed kite (Elanus leucurus), have a moderate potential to occur and are discussed further below. One species has a low potential to occur within the project site: American badger (Taxidea taxus). This species was determined to have a low potential to occur because the surrounding land is active agriculture and the railroad tracks, along with roads create a barrier to individuals dispersing into the project site. The remaining 50 special-status species are not expected to occur in the project site due to a lack of species-specific habitat requirements, the overall lack of suitable habitat such as natural vegetation communities or natural wetland habitats (e.g., marshes or seeps), and/or because the range of the species does not overlap with the project site. No federal or state-listed or other special-status wildlife species were observed during the field survey.

Western burrowing owl
Western burrowing owl is a CDFW Species of Special Concern that occupies open, treeless areas within grassland, low-density scrub, and desert biomes. This species generally inhabits gently sloping areas, characterized by low, sparse vegetation, and is often associated with high densities of burrowing mammals (Poulin et al. 2011). Western burrowing owl often uses relatively disturbed areas such as agricultural fields, golf courses, cemeteries, and vacant urban lots in addition to natural breeding habitats. Nests are most often in fossorial animal burrows, such as California ground squirrel or American badger, but atypical nests such as culverts or rubble piles may also be used. Nest sites are typically selected in an area with a high density of burrows.

There are nine occurrences within five miles of the project site, with the closest occurrence approximately 2 miles to the south. Suitable habitat is present throughout the project site within the nonnative annual grassland. Suitable burrows were observed throughout the project site. This species is known to occur throughout the region and is determined to have a moderate potential to occur within the project site.

Swainson’s hawk
Swainson’s hawk is listed as a state threatened species. The historical breeding range of Swainson’s hawk in California included the Great Basin, Sacramento and San Joaquin Basins, the coast from Marin County to San Diego County, and scattered sites in the Mojave and Colorado Deserts (Bechard et al., 2020). The species continues to breed across its entire historical range, but in significantly lower numbers than historical numbers. Throughout most of its range, much of the native habitat has been converted to agricultural and urban uses, thereby limiting nesting and foraging opportunities for Swainson’s hawk. This species is often found nesting in trees associated with scattered rural residences, particularly in relation to grasslands or dry-land grain fields.

Throughout its range, the species nests almost exclusively in trees, typically on the edges of woodland adjacent to grass or shrubland habitat (Bechard et al. 2020).

There are several records of Swainson’s hawks nesting within five miles of the project site, with the last record from 2013. No Swainson’s hawks were observed during the reconnaissance survey.

There is suitable nesting and foraging habitat within the project site. The nesting habitat in the project site is limited to eucalyptus trees and ornamental trees within the low-density housing area.

Swainson’s hawk has a moderate potential to forage and nest within the project site. 340
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White-tailed kite
White-tailed kite is a CDFW fully protected species. A yearlong resident in coastal and valley lowlands, the species inhabits a wide range of habitats, mostly in cismontane California. The species prefers trees with dense canopies for cover. Their diet consists mostly of voles and other small, diurnal mammals, but the species occasionally feeds on birds, insects, reptiles, and amphibians.

Typical foraging habitat is undisturbed, open grasslands, meadows, farmlands, and emergent wetlands. Nesting is typically near the top of dense oak, willow, or other tree stands, located near foraging areas. This species preferentially selects herbaceous lowlands with a range of woodland structure, and high density of voles (Zeiner et al. 1990), and substantial groves of dense, broadleafed deciduous trees for nesting and roosting (Zeiner et. al. 1990).

The CNDDB contains no occurrence records for white-tailed kite within five miles of the project site.

Ebird (eBird 2022) contains multiple records for white-tailed kite within five miles of the project site.

The grassland areas within the project site provide foraging habitat and suitable nesting habitat is present in the project site.
c. Nesting Birds
Suitable nesting sites for avian species protected by the federal Migratory Bird Treaty Act (MBTA) and California Fish and Game Code (CFGC), including shrubs, trees, man-made structures, and the ground surface occur throughout the project site. Some species prefer vegetation for nesting, including ornamental vegetation and some species can be found nesting in man-made structures, such as power poles or the eaves of buildings. Nesting birds may occur during the breeding season (generally February 1 through August 31 but beginning January 1 for some raptor species). d. Sensitive Vegetation Communities and Critical Habitat The following five sensitive natural communities occur within the 12 quad search range (CDFW 2022a):
 Coastal Brackish Marsh
 Northern Coastal Salt Marsh
 Northern Vernal Pool
 Northern Claypan Vernal Pool
 Serpentine Bunchgrass
No natural vegetation communities considered sensitive by the CDFW occur in the project site.

Critical habitat for the following nine species occurs within the 12 quad search region (USFWS 2022b):
 Alameda Whipsnake (Masticophis lateralis)
 California red-legged frog (Rana draytonii)
 Chinook Salmon (Oncorhynchus tshawytscha)
 Green sturgeon (Acipenser medirostris)
 Western Snowy Plover
 vernal pool fairy shrimp
 Contra Costa goldfields
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 Delta Smelt
 Northern Spotted Owl
No USFWS-designated critical habitat occurs in the project site. e. Wildlife Movement Corridors
Wildlife movement corridors, or habitat linkages, are generally defined as connections between habitat patches that allow for physical and genetic exchange between otherwise isolated animal populations. Such linkages may serve a local purpose, such as providing a linkage between foraging and denning areas, or they may be regional in nature. Some habitat linkages may serve as migration corridors, wherein animals periodically move away from an area and then subsequently return.

Others may be important as dispersal corridors for young animals. A group of habitat linkages in an area can form a wildlife corridor network.

The habitats within the linkages do not necessarily need to be the same or of the same quality as the habitats that are being linked. Rather, the linkage merely needs to contain sufficient cover and forage to allow temporary inhabitation by ground-dwelling species. Typically, habitat linkages are contiguous strips of natural areas, though dense plantings of landscape vegetation can be used by certain disturbance-tolerant species. Depending upon the species using a corridor, specific physical resources (such as rock outcroppings, vernal pools, or oak trees) may need to be located within the habitat link at certain intervals to allow slower-moving species to traverse the link. For highly mobile or aerial species, habitat linkages may be discontinuous patches of suitable resources spaced sufficiently close together to permit travel along a route in a short period of time.

Wildlife movement corridors can be both large and small scale. One essential connectivity area (ECA) is mapped by the California Essential Habitat Connectivity Project (CEHCP) along the eastern border of the project site (Spencer et.al 2010). The corridor connects natural landscape blocks east of American Canyon along the Howell Mountain range. From the hills north of the cities of Vallejo and Benicia it extends northwest, parallel with Napa Valley to the Lake County border. This ECA may serve as a movement corridor for the state provisionally protected Southern California/Central Coast Evolutionarily Significant Unit of mountain lion. CDFW characterizes the value of ECAs based on permeability to wildlife movements. As mapped by CEHCP, the edges of the nearest connectivity area become increasingly less suitable as they extend toward American Canyon.

4.4.2 Regulatory Setting
a. Federal Regulations
Federal Endangered Species Act
The Federal Endangered Species Act of 1973 (FESA) and subsequent amendments provide for the conservation of endangered and threatened species, and the ecosystems upon which they depend.

FESA is intended to prevent the unlawful “take” of listed fish, wildlife, and plant species. Section 9(a)(1)(B) specifically states take of species listed as threatened or endangered is unlawful. Take is defined as any action that would harass, harm, pursue, hunt, wound, shoot, kill, trap, capture, or collect any threatened or endangered species. Section 10 of the FESA allows the USFWS to issue incidental take permits if take of a listed species may occur during otherwise lawful activities.

Section 10(a)(1)(B) requires a Habitat Conservation Plan for an incidental take permit on non-federal lands. Section 7 of the FESA requires federal agencies to aid in the conservation of listed species, 342
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and to ensure that the activities of federal agencies will not jeopardize the continued existence of listed species or adversely modify designated critical habitat. The USFWS and the National Oceanic and Atmospheric Administration (NOAA) are responsible for administration of the FESA and have regulatory authority over federally listed species.

Migratory Bird Treaty Act
The Migratory Bird Treaty Act (MBTA) makes it unlawful at any time, by any means or in any manner, to pursue, hunt, take, capture, or kill migratory birds, and prohibits the removal of nests occupied by migratory birds. The USFWS has regulatory authority for the MBTA.

Clean Water Act
The United States Army Corps of Engineers (USACE), under provisions of Section 404 of the Clean Water Act (CWA) and USACE implementing regulations, has jurisdiction over the placement of dredged or fill material into “waters of the United States.” Congress enacted the CWA “to restore and maintain the chemical, physical, and biological integrity of the Nation's waters.” In practice, the boundaries of certain waters subject to USACE jurisdiction under Section 404 have not been fully defined. Previous regulations codified in 1986 defined “waters of the United States” as traditional navigable waters, interstate waters, all other waters that could affect interstate or foreign commerce, impoundments of waters of the United States, tributaries, the territorial seas, and adjacent wetlands.

USACE jurisdictional limits are typically identified by the Ordinary High Water Mark (OHWM) or the landward edge of adjacent wetlands (where present). The OHWM is the “line on the shore established by the fluctuations of water and indicated by physical characteristics such as a clear, natural line impressed on the bank, shelving, changes in the character of soil, destruction of terrestrial vegetation, the presence of litter and debris, or other appropriate means that consider the characteristics of the surrounding area” (33 Code of Federal Regulations 328.3).

The USACE defines wetlands as “those areas that are inundated or saturated by surface or groundwater at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions” (33 CFR 328.3). The USACE’s delineation procedures identify wetlands in the field based on indicators of three wetland parameters: hydrophytic vegetation, hydric soils, and wetland hydrology.

Fish and Wildlife Coordination Act
The USFWS also has responsibility for project review under the Fish and Wildlife Coordination Act.

This statute requires that all federal agencies consult with USFWS, NOAA Fisheries, and the State’s wildlife agency (CDFW) for activities that affect, control, or modify streams and other water bodies.

Under the authority of the Fish and Wildlife Coordination Act, USFWS, NOAA Fisheries, and the CDFW review applications for permits issued under Section 404 and provide comments to the USACE about potential environmental impacts.
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b. State Regulations
California Endangered Species Act
The CDFW is responsible for administration of CESA. For projects that may affect both a State and federal listed species, compliance with the FESA will satisfy the CESA, provided the CDFW determines that the federal incidental take authorization is consistent with the CESA.

Take is defined in CFGC Section 86 as “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill.” The CESA allows for take incidental to otherwise lawful activities under CFGC Section 2081. Project proponents wishing to obtain incidental take permits can do so through a permitting process outlined in California Code of Regulations (CCR) Section 783.

Additionally, some sensitive mammals and birds are protected by the state as Fully Protected Mammals or Fully Protected Birds, as described in the CFGC, Sections 4700 and 3511, respectively.

Projects that may result in a take of a California listed species require a take permit under the CESA.

The federal and State acts lend protection to species considered rare enough by the scientific community and trustee agencies to warrant special consideration, particularly with regard to protection of isolated populations, nesting or den locations, communal roosts, and other essential habitat. Unlike the FESA, the CESA prohibits the take of not just listed endangered or threatened species, but also candidate species (species petitioned for listing).

The CESA defines an endangered species as:
…a native species or subspecies of a bird, mammal, fish, amphibian, reptile, or plant which is in serious danger of becoming extinct throughout all, or a significant portion, of its range due to one or more causes, including loss of habitat, change in habitat, overexploitation, predation, competition, or disease.

A threatened species is defined as:
…a native species or subspecies of a bird, mammal, fish, amphibian, reptile, or plant that, although not presently threatened with extinction, is likely to become an endangered species in the foreseeable future in the absence of the special protection and management efforts required by this chapter. Any animal determined by the commission as rare on or before January 1, 1985 is a threatened species.

Candidate species are defined as:
…a native species or subspecies of a bird, mammal, fish, amphibian, reptile, or plant that the commission has formally noticed as being under review by the department for addition to either the list of endangered species or the list of threatened species, or a species for which the commission has published a notice of proposed regulation to add the species to either list.

Candidate species may be afforded temporary protection as though they were already listed as threatened or endangered at the discretion of the Fish and Game Commission. Unlike the FESA, CESA does not include listing provisions for invertebrate species. Article 3, Sections 2080 through 2085, of the CESA addresses the taking of threatened or endangered species by stating:
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…no person shall import into this State, export out of this State, or take, possess, purchase, or sell within this State, any species, or any part or product thereof, that the commission determines to be an endangered species or a threatened species, or attempt any of those acts, except as otherwise provided.

California Fish and Game Code - Nesting Bird Protection According to CFGC Section 3503, it is unlawful to take, possess, or needlessly destroy the nest or eggs of any bird [except English sparrows (Passer domesticus) and European starlings (Sturnus vulgaris)]. Sections 3503 and 3513 prohibit the taking of specific birds, their nests, eggs, or any portion thereof during the nesting season. Section 3503.5 specifically protects birds in the orders Falconiformes and Strigiformes (birds-of-prey). Section 3513 essentially overlaps with the federal MBTA, prohibiting the take or possession of any migratory nongame bird.

California Native Plant Protection Act
The California Native Plant Protection Act (NPPA) was enacted in 1977 and allows the California Fish and Wildlife Commission to designate plants as rare or endangered. Currently, 64 species, subspecies, and varieties of plants are protected as rare under the NPPA. The NPPA prohibits take of endangered or rare native plants but includes some exceptions for agricultural and nursery operations; emergencies; and after properly notifying CDFW for vegetation removal from canals, roads, and other sites; changes in land use; and in certain other situations. Effective in 2015, CDFW promulgated regulations (14 CCR 786.9) under the authority of the NPPA, establishing that the CESA permitting procedures (CFG Code Section 2081) would be applied to plants listed under the NPPA as "Rare." With this change, there is little practical difference between regulations and protocols for plants listed under CESA and those listed under the NPPA.

Clean Water Act Section 401, Porter-Cologne Water Quality Control Act The State Water Resources Control Board (SWRCB) and nine Regional Water Quality Control Boards (RWQCBs) have jurisdiction over “waters of the State,” which are defined as any surface water or groundwater, including saline waters, within the boundaries of the state (California Water Code sec. 13050(e)). These agencies also have responsibilities for administering Section 401 of the CWA. In addition, where Federal jurisdiction is not asserted (for example, due to a lack of connectivity to a Relatively Permanent Waters [RPW] and Traditional Navigable Waters [TNW]), RWQCB assert jurisdiction over “waters of the State” pursuant to Section 13263 of the Porter-Cologne Water Quality Control Act, which are defined as any surface water or groundwater, including saline waters, within the boundaries of the State. In this event, the SWRCB may issue general Waste Discharge Requirements (WDRs) regarding discharges to “isolated” waters of the State if limiting criteria are not exceeded (Water Quality Order No. 2004-0004-DWQ, Statewide General Waste Discharge Requirements for Dredged or Fill Discharges to Waters Deemed by the USACE to be Outside of Federal Jurisdiction) or project-specific WDRs.

The SWRCB and RWQCBs have not established regulations for field determinations of waters of the state except for wetlands. In many cases the RWQCBs interpret the limits of waters of the State to be bounded by the OHWM unless isolated conditions or ephemeral waters are present. However, in the absence of statewide guidance, each RWQCB may interpret jurisdictional boundaries within their region and the SWRCB has encouraged applicants to confirm jurisdictional limits with their RWQCB before submitting applications. As determined by the RWQCB, waters of the State may 345
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include riparian areas or other locations outside the OHWM, leading to a larger jurisdictional area over a given water body compared to the USACE.

Procedures for defining wetland waters of the State pursuant to the SWRCB’s State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State went into effect May 28, 2020. The SWRCB defines an area as wetland if, under normal circumstances:
the area has continuous or recurrent saturation of the upper substrate caused by groundwater, or shallow surface water, or both; the duration of such saturation is sufficient to cause anaerobic conditions in the upper substrate; and the area’s vegetation is dominated by hydrophytes or the area lacks vegetation.

The SWRCB’s Implementation Guidance for the Wetland Definition and Procedures for Discharges of Dredge and Fill Material to Waters of the State (2020), states that waters of the U.S. and waters of the State should be delineated using the standard USACE delineation procedures, taking into consideration that the methods shall be modified only to allow for the fact that a lack of vegetation does not preclude an area from meeting the definition of a wetland.

California Fish and Game Code Section 1600 et seq.

Pursuant to CFGC Section 1600, CDFW has authority over all perennial, intermittent, and ephemeral rivers, streams, and lakes in the state, and requires any person, state or local governmental agency, or public utility to notify the CDFW before beginning any activity that would “substantially divert or obstruct the natural flow of, 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” that supports fish or wildlife resources.

A stream is defined as a “body of water that flows at least periodically or intermittently through a bed or channel having banks and supports fish or other aquatic life. This includes watercourses having a surface or subsurface flow that supports or has supported riparian vegetation” (California Code of Regulations, Title 14 Section 1.72). A Lake or Streambed Alteration Agreement may be required for any project that would result in an adverse impact to a river, stream, or lake. CDFW jurisdiction typically extends to the top of the bank and out to the outer edge of adjacent riparian vegetation if present. However, CDFW can take jurisdiction over a body of flowing water and the landform that conveys it, including water sources and adjoining landscape elements that are byproducts of and affected by interactions with flowing water without regard to size, duration, or the timing of flow.

CDFW Special Animals List
Special-status wildlife species are those species included on the CDFW “Special Animals” list (CDFW 2020). “Special Animal” is a general term that refers to all the taxa the CNDDB is interested in tracking, regardless of their legal or protection status. The CDFW considers the taxa on this list to be those of greatest conservation need. The species on this list generally fall into one or more of the following categories:
 Officially listed or proposed for listing under the CESA and/or FESA  State or Federal candidate for possible listing
 Taxa that meet the criteria for listing, even if not currently included on any list, as described in CEQA Guidelines Section 15380
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 Taxa considered by the Department to be a Species of Special Concern  Taxa that are biologically rare, very restricted in distribution, declining throughout their range, or have a critical vulnerable stage in their life cycle that warrants monitoring  Populations in California that may be on the periphery of a taxon’s range but are threatened with extirpation in California
c. Local Regulations
American Canyon General Plan
The Land Use Element and Natural and Historic/Cultural Resources Element of the American Canyon General Plan set the guidelines to protect and preserve significant flora and fauna along with significant habitats that exist within the City of American Canyon and its planning area. The objectives within the natural and historic/cultural resources element facilitate protection of sensitive habitats including vernal pool, natural drainages, and riparian habitats among other habitats. The following policies contained within the General Plan provide for resource conservation and the appropriate management of development.

Goal 8: Protect and preserve the significant habitats, plants and wildlife that exist in the City and its Planning Area.

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.

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.

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.

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.

Policy 8.2.1: Land use applications for developments located within sensitive habitats, including coastal saltmarsh, mixed hardwood forest, oak savanna, and riparian habitats (see Figure 8-1) [General Plan], or with areas potentially occupied by vernal pools (see Figure 8-2) [General Plan] 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 [General Plan] 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 on-site, in instances where the potential for significant impacts exists, the applicant must submit a Biological Assessment Report prepared by a qualified professional.
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Objective 8.3: Protect natural drainages and riparian corridors within the American Canyon Planning Area.

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” (below). 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 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 Wildlife and/or United States Army Corps 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 affected, 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 8.3.5: 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.

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 and greenbelts along their lengths throughout the City.

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

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.
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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.

Policy 8.4.3: Encourage activities that improve the biological value and integrity of the City’s natural resources through vegetation restoration, control of alien plants and animals, and landscape buffering.

4.4.3 Impact Analysis
a. Significance Thresholds and Methodology
Significance Thresholds
Based on Appendix G of the CEQA Guidelines a project may be deemed to have a significant impact on biological resources if it would:

Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service;
Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service;
Have a substantial adverse effect on State or Federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means;
Interfere substantially (i.e., direct/indirect reduction) with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites; Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance; or
Conflict with the provisions of an adopted Habitat Preservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan.

Methodology
The impact analysis is based on a review of available literature and of existing biological conditions within the proposed annexation area. Impacts to biological resources were assessed using the significance thresholds described above. Impacts to flora and fauna may be determined to be significant even if they do not directly affect rare, threatened, or endangered species because development by the project may result in indirect impacts to species. Potential impacts to special status species due to future specific development within the project site will be determined during each projects’ development. Impacts to sensitive biological resources are analyzed accordingly here and are not considered as permanent or temporary impacts to the entire annexation area. Potential for the project to result in significant impacts to special status biological resources is addressed below.
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Threshold 1: Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? Impact BIO-1 THE PROJECT MAY RESULT IN DIRECT OR INDIRECT IMPACTS TO SPECIAL-STATUS SPECIES, THEIR ASSOCIATED HABITATS, AND NESTING BIRDS. THIS IMPACT WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION.

A total of 54 special-status wildlife and 73 special-status plant species are known to occur within the 12 quad search area. Of these species, three special-status wildlife species have a moderate or greater potential to occur within the project site. This includes western burrowing owl, Swainson’s hawk, and white-tailed kite. In addition, nesting migratory birds may occur within the project site.

Migratory birds nest within a variety of habitats such as gravel, grasses, bushes, or trees.

Construction of future development and the extension of Newell Drive could result in direct impacts to migratory birds, Swainson’s hawk, and white-tailed kite. Impacts to these species may include injury, mortality, or nest abandonment due to construction activities, noise, and/or dust. Impacts to active nests would be considered significant.

Suitable western burrowing owl habitat is present in annual grassland, and ruderal habitats throughout the project site. Suitable burrows were observed during the reconnaissance survey; therefore, the species is determined to have a moderate potential to occur within the proposed annexation. Impacts to western burrowing owls would be limited to project activity that would directly affect an occupied burrow (temporarily or permanently damage or destroy the burrow), or project activity that would disrupt active breeding or wintering owls within 500 feet of construction activity. Owls can be disturbed by construction noise and human activity and may abandon active burrows, including during breeding. Impacts to active western burrowing owl burrows would be considered significant. Implementation of the mitigation measures below would avoid and minimize potential impacts to western burrowing owl, Swainson’s hawk, white-tailed kite, and other nesting birds during construction.

Impacts from the operation of the Newell Drive Extension, including vehicle collisions to individuals of the aforementioned species are unlikely to be substantial. These impacts would be less than significant.

Mitigation Measure
BIO-1 Site-Specific Biological Resources Assessment
The City shall implement the following measures during environmental review of future development within the project site. On a project-by-project basis, a preliminary biological resource screening shall be performed to determine whether a specific project has the potential to impact biological resources. If it is determined that the project has no potential to impact biological resources, no further action is required. If the project would have the potential to impact biological resources, prior to construction, a qualified biologist shall conduct a biological resources assessment (BRA) or similar type of study to document the existing biological resources within the project footprint plus an appropriate buffer determined by a qualified biologist and to determine the potential impacts to those resources. The BRA shall evaluate the potential for impacts to all sensitive biological resources including, but not limited to special-status species, nesting birds, wildlife movement, sensitive plant communities/critical habitat and other resources judged to be 350
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sensitive by local, state, and/or federal agencies. Pending the results of the BRA, design alterations, further technical studies (i.e., protocol surveys) and/or consultations with the USFWS, CDFW and/or other local, state, and federal agencies may be necessary. The City shall review and approve the BRA prior to project approval.

BIO-2 Pre-construction Surveys for Swainson’s Hawk, Other Raptors and Nesting Birds
Ground disturbance and vegetation removal activities shall be restricted to the non-breeding season (September 16 to January 31), when feasible. If construction activities occur during the nesting bird season (February 1 to September 15), the following mitigation measures are recommended to reduce impacts to Swainson’s hawk, protected raptor species, and other nesting birds protected by the MBTA and CFGC.

A qualified biologist shall conduct surveys for Swainson’s hawk between January 1 and March 20. A preconstruction survey for other raptors and nesting birds shall be conducted no more than seven days prior to initiation of ground disturbance and vegetation removal. The survey shall be conducted within the project site and include a 150-foot buffer for passerines, 500-foot buffer for other raptors, and 0.5 mile buffer for active Swainson’s hawk nests. The surveys shall be conducted by a biologist familiar with the identification of avian species known to occur in the region. It is recommended that surveys follow the Swainson’s Hawk Technical Advisory Committee’s Recommended Timing and Methodology for Swainson’s Hawk Nesting Surveys in California’s Central Valley. If a Swainson’s hawk or white-tailed kite nest is found, the biologist shall set up appropriate buffers in consultation with CDFW.

If the nesting bird survey results are negative, no further action is required. If nests are found, the biologist shall determine and demarcate an appropriate avoidance buffer with high visibility material. For Swainson’s hawk nests, the biologist shall establish an avoidance buffer of up to 0.5 mile based on the nest location in relation to the construction activity, the line-of-sight from the nest to the construction activity, and observed hawk behavior at the nest.

The qualified biologist shall notify all construction personnel of the buffer zones and to avoid entering buffer zones during the nesting season. No ground disturbing activities shall occur within the buffer until the biologist has confirmed that breeding/nesting is complete, and the young have fledged the nest. Encroachment into the buffer shall occur only at the discretion of the biologist.

Results of the preconstruction nesting bird survey shall be submitted to the City in a brief letter report no more than 30 days after completion of the survey.

BIO-3 Pre-construction Surveys for Western Burrowing Owl Prior to ground disturbance activities, a qualified biologist shall conduct pre-construction clearance surveys within suitable natural habitats and ruderal areas throughout the project site, to confirm the presence/absence of active western burrowing owl burrows. The surveys shall be consistent with the recommended survey methodology provided by CDFW’s Staff Report on Burrowing Owl Mitigation. Clearance surveys shall be conducted within 30 days prior to construction and ground disturbance activities. If no western burrowing owls are observed, no further actions are required. If western burrowing owls are detected during the pre-construction clearance surveys, the following measures shall apply:
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 Avoidance buffers during the breeding and non-breeding season shall be implemented in accordance with the CDFW’s Staff Report on Burrowing Owl Mitigation minimization mitigation measures.
 If avoidance of western burrowing owls is not feasible, then additional measures such as passive relocation during the nonbreeding season and construction buffers of 200 feet during the breeding season shall be implemented, in consultation with CDFW. In addition, a Western Burrowing Owl Exclusion Plan and Mitigation and Monitoring Plan shall be developed by a qualified biologist in accordance with the CDFW (2012) and Burrowing Owl Consortium (1993).

Project applicants shall submit evidence of clearance surveys, avoidance buffers or additional measures to the City as required.

BIO-4 Worker Environmental Awareness Program
Prior to initiation of construction activities (including staging and mobilization), all personnel associated with project construction shall attend Worker Environmental Awareness Program training, conducted by a qualified biologist, to aid workers in recognizing special status resources that may occur in the project site. The program shall include identification of the sensitive species and habitats, a description of the regulatory status and general ecological characteristics of sensitive resources, and review of the limits of construction and mitigation measures required to reduce impacts to biological resources within the work area. A fact sheet conveying this information shall also be prepared for distribution to all contractors, their employers, and other personnel involved with construction. All employees shall sign a form documenting attendance at the Worker Environmental Awareness Program and that they understand the information presented to them.

The form shall be submitted to the City to document compliance.

Significance After Mitigation
With implementation of Mitigation Measures BIO-1, BIO-2, BIO-3, and BIO-4, impacts from the project on special status species, nesting birds, and associated habitats would be mitigated to a less than significant level.

Threshold 2: Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
Impact BIO-2 NO RIPARIAN HABITAT OR SENSITIVE NATURAL COMMUNITIES ARE PRESENT IN THE PROJECT SITE. NO IMPACT WOULD OCCUR.

The northern portion of the project site is bisected by North Slough, flowing north to south. The slough and the rest of the project site do not contain riparian habitat or other sensitive natural communities even though they are potentially jurisdictional and subject to USACE, RWQCB, and CDFW oversight (see Appendix B). Impacts on jurisdictional waters are addressed in Impact BIO-3.

Because there is no riparian habitat or other sensitive natural communities on the project site, development within the project site would not have a substantial adverse impact on any riparian habitat or other sensitive natural community, including protected wetlands; therefore, there would be no impact.
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Mitigation Measure
No mitigation measures would be required.

Significance After Mitigation
There would be no impact and no mitigation would be required.

Threshold 3: Would the project have a substantial adverse effect on state or federally protected wetlands (including but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? Impact BIO-3 IMPLEMENTATION OF THE PROJECT MAY RESULT IN IMPACTS TO STATE OR FEDERALLY PROTECTED WATERS. THIS IMPACT WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION.

The northern portion of the project site includes the North Slough, which is characterized as unvegetated waters and are potentially state and federally jurisdictional (Appendix B). In addition, the area east of the project site includes areas that drain to North Slough and may be potentially jurisdictional. The potential jurisdictional features have been historically diverted from their natural topographic drainages (i.e., the typical gradient being downhill and flowing north to south or east to west) and redirected through a system of culverts and ditches onto and through the project site, flowing into North Slough.

There are several components of the project that cross these potentially jurisdictional areas, including the following:
 A portion of the Newell Drive Extension and areas with new pre-zoning (Residential Estate, Paoli Light Industrial, Paoli Light Industrial: Commercial Overlay) would cross the North Slough.  An area pre-zoned as Paoli Light Industrial would cross an area that drains to North Slough.  A portion of the Newell Drive Extension along the northern portion of the annexation area would cross an area that drains to North Slough.

No development is being proposed in the areas pre-zoned as Residential Estate. As such, there would be no impact to the portion of North Slough in the Residential Estate pre-zoning. Future development could occur in the proposed Paoli Light Industrial and Paoli Light Industrial:

Commercial Overlay pre-zoning. Construction of future development, including upgrades to utilities and stormwater drainage, may require work within the North Slough and the area that drains to North Slough, including dredge or fill within potential jurisdictional waters. The southern potential jurisdictional feature has been substantially diverted from its natural topographic course (i.e., the typical gradient being downhill and flowing north to south or east to west) and redirected through a system of culverts and ditches, and ultimately through the project site toward North Slough.

Because the project could impact these potentially jurisdictional features, impacts would be potentially significant.

In addition, the City has identified that the Newell Drive Extension would align with the northern boundary of the project site. The Newell Drive Extension would cross the North Slough with a clear span overcrossing. There would be no impact to the North Slough due to the Newell Drive Extension. A section of the northern potential jurisdictional feature would be directly impacted due to the road alignment. The northern potential jurisdictional feature also contains concentrated runoff that is diverted through the project site. Because the northern potential jurisdictional feature is a potentially jurisdictional water, impacts would be potentially significant. 353
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For development that would occur in these areas, permitting pursuant to Section 404/401 of the CWA Section, and Section 1600 et seq. of the CFGC would be required. Actual jurisdictional areas are determined by the State and federal authorities at the time that permits are requested, and the agencies are responsible for describing avoidance, minimization, and mitigation measures, if required. Mitigation Measure BIO-5 would require that future applicants prepare an aquatic resources delineation and preliminary jurisdictional determination report, either to ensure avoidance of potentially jurisdictional waters or for submittal to the agencies for verification of their jurisdictions. Mitigation Measure BIO-6 would require setbacks around the North Slough to avoid impacts to that feature. Nonetheless, even with these measures, there is still the potential that the project could result in the permanent loss of a jurisdictional feature. As such, Mitigation Measure BIO-7 would require mitigation to compensate for the loss of jurisdictional water features.

Mitigation Measures
BIO-5 Aquatic Resources Delineation
A qualified biologist shall complete an aquatic resources delineation survey that establishes the extent of the waters of the U.S. and State and identify the potential jurisdictional limits of USACE, RWQCB, and CDFW. The delineation shall be conducted in accordance with the requirement set forth by each agency and the results presented in a report that shall be submitted to the City, USACE, RWQCB, and CDFW, as appropriate, for review and approval. If the USACE asserts its authority, then a permit pursuant to Section 404 of the CWA would be required. If jurisdictional areas are expected to be impacted, then the RWQCB would require a Section 401 Water Quality Certification and/or Waste Discharge Requirement permit (depending upon whether the feature falls under federal jurisdiction or not). If CDFW asserts its jurisdictional authority, then a Lake or Streambed Alteration Agreement pursuant to Section 1600 et seq. of the CFGC would also be required prior to construction within the areas of CDFW jurisdiction.

BIO-6 General Avoidance and Minimization
Development shall be designed to avoid potentially jurisdictional features identified in aquatic resources delineation reports (Mitigation Measure BIO-4), to the extent feasible. No development shall occur within 50 feet of the top of bank for North Slough. Projects with potentially jurisdictional features shall provide the City with a report detailing how all identified aquatic features will be avoided, including groundwater draw down, prior to project approval.

BIO-7 Restoration for Impacts to Waters and Wetlands
If the project cannot be designed to avoid impacts to waters and wetlands (as described in Mitigation Measure BIO-6), then impacts shall be fully mitigated at an appropriate ratio, as determined by a qualified biologist and in accordance with regulatory agency requirements.

Mitigation can be achieved through the setting aside or acquisition and in-perpetuity management of similar habitat on-site (this can include restoration of jurisdictional features within the project site) or as close to the impact habitat as possible. Mitigation lands must be placed into a conservation easement or other covenant restricting future development. A mitigation and monitoring plan consistent with regulatory agency requirements shall be developed by a qualified biologist and submittal to the regulatory agency overseeing the project for approval. Alternatively, mitigation shall be accomplished through purchase of credits from an approved mitigation bank.

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1:1 ratio for impacted lands, comparable to habitat to be impacted by individual project activity. The City shall review and approve the plan before submittal to the agencies.

Significance After Mitigation
With implementation of Mitigation Measures BIO-5, BIO-6, and BIO-7, impacts to state or federally protected waters and wetlands from development facilitated by the project would be minimized.

This impact would be less than significant after mitigation.

Threshold 4: Would the project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? Impact BIO-4 IMPLEMENTATION OF THE PROJECT WOULD NOT SUBSTANTIALLY IMPEDE THE MOVEMENT

OF NATIVE RESIDENT OR MIGRATORY FISH OR WILDLIFE SPECIES OR WITH ESTABLISHED NATIVE RESIDENT OR MIGRATORY WILDLIFE CORRIDORS AFTER THE IMPLEMENTATION OF MITIGATION MEASURE BIO-6. THIS IMPACT WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION.

The project site is not within a designated ECA and does not function as a significant regional or local wildlife movement corridor. North Slough, which bisects the northern portion of the project site may provide a natural movement corridor for wildlife through the project site. As such impacts on the North Slough would result in potentially significant impacts on wildlife movement.

Nonetheless, impacts on North Slough would be avoided by implementing Mitigation Measure BIO6. The Newell Drive Extension over North Slough is unlikely to impact the movement of wildlife through North Slough because it would be an overcrossing. Wildlife movement is likely to be concentrated along North Slough; therefore, the project would be unlikely to impact the movement of wildlife across the landscape as the overcrossing would provide wildlife with an unobstructed natural movement corridor.

Filling of the areas that drain to North Slough would be unlikely to impact the movement of wildlife beyond the project area. This is because the existing Union Pacific Railroad tracks bisect the area that drains to North Slough. This area, therefore, does not serve as a significant movement corridor for wildlife. As such, the impacts on wildlife movement from filling the area that drains to North Slough would be less than significant.

Mitigation Measures
Mitigation Measure BIO-6 (see Impact BIO-3).

Significance After Mitigation
With implementation of Mitigation Measure BIO-6, impacts to wildlife movement would be minimized through the protection of North Slough, which can be used by wildlife for movement.

This impact would be less than significant after mitigation. 355
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Threshold 5: Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? Impact BIO-5 IMPLEMENTATION OF THE PROJECT COULD CONFLICT WITH LOCAL POLICIES OR ORDINANCES PROTECTING BIOLOGICAL RESOURCES, SUCH AS A TREE PRESERVATION POLICY OR ORDINANCE.

HOWEVER, THIS IMPACT WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION.

The project, when annexed would fall under the jurisdiction of the City of American Canyon, which provides protection for biological resources through the implementation of its General Plan and Zoning Code. The American Canyon General Plan includes policies to guide decisions on future growth, development, and conservation of resources. This includes the Natural and Historic/Cultural Resources Element, which aim to preserve the natural and scenic resources (American Canyon 1994).

The Natural and Historic/Cultural Resources Element includes an objective to protect natural drainages (Objective 8.3) and a policy to review proposed developments in wetlands, require preservation of watercourses as feasible, and require mitigation for impacts on waters (Policy 8.3.1).

As described in Impact BIO-3, there would be a potentially significant impact on waters (i.e., potentially jurisdictional features); however, these impacts would be mitigated to a less than significant level through the implementation of Mitigation Measures BIO-5, BIO-6, and BIO-7. The project could potentially result in a conflict with a policy protecting biological resources; however, implementation of Mitigation Measures BIO-5, BIO-6, and BIO-7 would ensure that the project is consistent with the policy and impacts would be less than significant with mitigation.

Mitigation Measures
Mitigation Measures BIO-5, BIO-6, and BIO-7 (see Impact BIO-3).

Significance After Mitigation
Impacts would be less than significant with mitigation.

Threshold 6: Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
Impact BIO-6 IMPLEMENTATION OF THE PROJECT WOULD NOT CONFLICT WITH THE PROVISIONS OF AN

ADOPTED HABITAT CONSERVATION PLAN, NATURAL COMMUNITY CONSERVATION PLAN, OR OTHER APPROVED LOCAL, REGIONAL, OR STATE HABITAT CONSERVATION PLAN. NO IMPACT WOULD OCCUR.

There are no habitat conservation plans, natural community conservation plans, or other approved local, regional, or state habitat conservation plans in the project site. Therefore, future development on the project site and the extension of Newell Drive would not conflict with such plans. No impact would occur.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
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4.4.4 Cumulative Impacts
The geographic scope for cumulative biological resources impacts includes the City and adjacent projects in Napa County. This geographic scope is appropriate for biological resources because it encompasses a variety of land cover and habitat types (and associated biological resources) affected by the project, including primarily urban development with areas of natural habitats.

Because the project would have no impact related to riparian habitat or other sensitive natural community and because the project would have no impact from conflicts with a habitat conservation plans, natural community conservation plans, or other approved local, regional, or state habitat conservation plans, the project would not contribute to a cumulative impact. As such, there would be no cumulative impact to these resources, and they are not discussed further.

Cumulative development may also affect western burrowing owl, Swainson’s hawk, white-tailed kite, and nesting birds during construction. However, because the project would implement mitigation measures (BIO-1 through BIO-4), which would minimize impacts to these species during construction, the project’s contribution to a cumulative impact would be less than considerable. In addition, cumulative development could also result in the loss of foraging and breeding habitat for these species. Although the project could permanently remove nonnative grasslands that are used by western burrowing owl, Swainson’s hawk, white-tailed kite, and nesting birds, nearby habitat would remain in the area that could be used by the species, including at the Newell Open Space Preserve. In fact, as a part of the Watson Ranch Project, the City would include conservation easement areas to provide habitat for special-status species (City of American Canyon 2018). As such, cumulative impacts on special-status species would be less than significant.

As described in Impacts BIO-3 and BIO-5, the project could result in impacts to aquatic resources, as well as a conflict with a policy protecting aquatic resources; however, project impacts would be less than significant through the application of mitigation (Mitigation Measures BIO-5, BIO-6, and BIO-7).

A cumulative impact could occur if cumulative projects also result in impacts to aquatic resources.

Other cumulative projects would be required to comply with existing regulations, as summarized in Section 4.4.2, Regulatory Setting, which include requirements to protect aquatic resources.

Cumulative projects in the City of American Canyon would be required to comply with Policy 8.3.1 in the General Plan, which includes requirements to review projects in wetlands and riparian habitats, protection of aquatic resources, and if needed compensatory mitigation. Because cumulative projects would be required to adhere to existing regulations that protect aquatic resources, cumulative impacts on aquatic resources and conflicts with policies would be less than significant.

As described in Impact BIO-4, wildlife movement in the project site would be concentrated along the North Slough and implementation of Mitigation Measure BIO-6 would ensure that wildlife movement would be maintained. Other cumulative projects could result in an impact on wildlife movement if they resulted in impacts to natural areas where wildlife movement occurs. However, because the project would maintain wildlife movement in the project site, the project’s contribution to a cumulative impact would be less than considerable. 357
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4.5 Cultural Resources
This section analyzes the potential effects on cultural resources related to implementation of the project.

4.5.1 Setting
a. Cultural Setting
The cultural setting for the project site is presented broadly in three overviews: Prehistoric, Ethnographic, and Historic. The prehistoric and historic overviews describe human occupation before and after European contact. The ethnographic overview in the Section 4.16, Tribal Cultural Resources provides a synchronic “snapshot” of traditional Native American culture.

Prehistory
The project site lies in the San Francisco Bay Area archaeological region (Milliken et al. 2007, Moratto 1984). Milliken et al. (2007) generally divided the prehistoric chronology of the Bay Area into five periods: The Early Holocene (8,000-3,500 before common era [BCE]), Early Period (3,500- 500 BCE), Lower Middle Period (500 BCE to CE 430 common era [CE]), the Upper Middle Period (430-1050 CE), and the Late Period (1050 CE-contact).

It is presumed that early Paleoindian groups lived in the area prior to 8,000 BCE; however, no evidence for this period has been discovered in the San Francisco Bay Area (Milliken et al. 2007).

Sites dating to this period may be submerged or deeply buried as a result of rising sea levels and widespread sediment deposition that has occurred since the Terminal Pleistocene (Byrd et al. 2017).

For this reason, the Terminal Pleistocene Period (ca. 11,700-8,000 BCE) is not discussed here.

The earliest intensive study of the archaeology of the San Francisco Bay Area began with N.C. Nelson of the University of California, Berkeley, between 1906 and 1908. He documented over 400 shell mounds throughout the area. Nelson was the first to identify the Bay Area as a discrete archaeological region (Moratto 1984).

Early Holocene (8,000-3,500 BCE)
Archaeological evidence from the early Holocene is limited as sites dating to this period are likely buried under Holocene alluvial deposits (Moratto 1984; Ragir 1972). The available data suggests that the Early Holocene in the San Francisco Bay Area is characterized by a mobile forager pattern and the presence of millingslabs, handstones, and a variety of leaf-shaped projectile points. Two archaeological sites (CA-CCO-696 and CA-CCO-637) dating to this period have been identified in Contra Costa County at the Los Vaqueros Reservoir. The earliest date for the Early Holocene comes from the CA-CCO-696, dating to approximately 7000 BCE (Milliken et al. 2007).

Early Period (3,500-600 BCE)
The Early Period saw increased sedentism with the introduction of new ground stone technologies (i.e., mortar and pestle), an increase in regional trade, and the first cut shell beads. The earliest evidence for the use of the mortar and pestle in the San Francisco Bay Area dates to 3800 BCE and comes from archaeological site CA-CCO-637. By 1500 BCE, mortars and pestles had almost completely replaced millingslabs and handstones, indicating a greater reliance on processing nuts, 359
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especially acorns. Faunal evidence from various sites during this person indicate a diverse faunal exploitation pattern based on the presence mussel and other shellfish, marine mammals, terrestrial mammals, and birds within sites dating to this period (D’Oro 2009).

The earliest cut bead horizon is also associated with this period. Rectangular Haliotis spp. (abalone) and Callianax biplicate (formerly Olivella biplicata) (Vellanoweth et al. 2014) (snail) beads have been identified at several Early Period sites, including CA-CCO-637, CA-SCL-832 in Sunnyvale, and CA-ALA307 in Berkeley (Milliken et al. 2007). These early examples of cut beads were recovered from mortuary contexts.

Lower Middle Period (500 BCE-CE 430)
The Lower Middle Period saw numerous changes from the previous period. The presence of chipped stone points and bone tools became typical. Rectangular shell beads (common during the Early Period) disappear completely and are replaced by split-beveled and saucer Olivella beads. Haliotis spp. ornaments, bone tools and ornaments, and basketry awls also became typical, indicating the development of coiled basketry technology. Mortars and pestles continued to be the dominant grinding tool (Luby and Gruber 1999; Milliken et al. 2007).

Evidence for the Lower Middle Period in the Bay Area comes from sites such as the Emeryville shell mound (CA-ALA-309) and Ellis Landing (CA-CCO-295). The Emeryville shell mound (CA-ALA-309) is one of the largest shell mounds in the San Francisco Bay Area and contains multiple cultural sequences. The lower levels of the site, which date to the Middle Period, contain flexed burials with bone implements, chert bifaces, charmstones, and oyster shells (Moratto 1984).

Upper Middle Period (CE 430-1050)
Around CE 430, Olivella saucer bead trade networks that had been established during earlier periods collapsed and over half of known sites occupied during the Lower Middle Period were abandoned.

Olivella saucer beads were replaced with Olivella saddle beads. New types of material culture appear within these sites, including elaborate, decorative blades, fishtail charmstones, new Haliotis spp. ornament forms, and mica ornaments. Sea otter bones became more abundant, while salmon and other fish became less so, suggesting changes in faunal exploitation patterns from earlier periods (Milliken et al. 2007; Simons and Carpenter 2009). Excavations at archaeological site CAALA-309 indicate that a shift from mussels to oysters, and oysters to clams may have occurred (Gifford 1916). Isotopic analysis confirms that San Francisco Bay Area individuals shifted from hunting higher-trophic-level foods in the Early Period to gathering foods like plants and shellfish in the Middle and Upper Periods (Burns et. al 2012). Subsistence analyses at various sites dating to this period indicate a diverse diet that included numerous species of fish, mammals, birds, shellfish, and plant resources that varied by location in the San Francisco Bay Area (Hylkema 2002).

Late Period (CE 1050-contact)
The Late Period saw an increase in social complexity, indicated by differences in burials and an increased level of sedentism relative to preceding periods, evidenced by mortars weighing up to

90.7 kilograms (Lentz 2012). An increase in imported Napa Valley obsidian occurred during this time for the production of smaller points, preforms and simple flake tools. Small, finely worked projectile points of the Stockton Serrated series associated with bow and arrow technology appear around CE 1250. Olivella shell beads disappeared and were replaced with Olivella lipped and spire -lopped beads in the South Bay and clamshell disk beads in the North Bay. Thicker and larger beads indicated higher affluence. The toggle harpoon, hopper mortar, and magnesite tube beads also 360
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appeared during this period (Milliken et al. 2007; Lentz 2012; Von Der Porten et al. 2014), as did an increase in the intensity of resource exploitation that correlates with an increase in population (Moratto 1984). Many of the well-known sites of earlier periods, such as the Emeryville shell mound (CA-ALA-309) and the West Berkeley site (CA-ALA-307) were abandoned, as indicated by the lack of Late Period elements. Researchers have suggested that the abandonment of these sites may have resulted from fluctuating climates and drought that occurred throughout the Late Period (Lightfoot and Luby 2002).
b. Historic Context
The Post-European contact history of California is generally divided into three periods: the Spanish Period (1769–1822), the Mexican Period (1822–1848), and the American Period (1848–present).

Each of these periods is briefly described below.

Spanish Period (1769 – 1822)
For more than 200 years, Cabrillo and other Spanish, Portuguese, British, and Russian explorers sailed the Alta (upper) California coast and made limited inland expeditions, but they did not establish permanent settlements (Bean 1968; Rolle 2003). Explorers such as Francis Drake and Sebastian Cermeno explored the San Francisco Bay area in the late 1500s (Bean 1968). Gaspar de Portolá and the Franciscan Father Junípero Serra established the first Spanish settlement in Alta California at Mission San Diego de Alcalá in 1769, the first of 21 missions erected by the Spanish.

Portolá continued north, reaching the San Francisco Bay later that year. Pedro Fages’ expedition also explored the region in 1772 (Cook 1957). Mission San Francisco de Asis and the San Francisco presidio (military fort) were founded in 1776, and Mission San Rafael Arcangel was built in 1817, all within about 30 miles of the project site (Presidio Trust 2020; California Missions Foundation, N.D.).

Mexican Period (1822 – 1848)
The Mexican Period commenced when news of the success of the Mexican Revolution (1810-1821) against the Spanish crown reached California in 1822. This period saw the federalization of mission lands in California with the passage of the Secularization Act of 1833. This Act enabled Mexican governors in California to distribute former mission lands to individuals in the form of land grants.

Successive Mexican governors made more than 700 land grants between 1822 and 1846, putting most of the state’s lands into private ownership for the first time (Shumway 2007). The approximately 80,000-acre Rancho Suscol or Soscol was acquired by General Vallejo in 1843; which encompasses the project site (City of Sonoma, N.D.).

The Mexican period saw an increased importance of sea trade and an influx of American settlers, which motivated the United States to expand their territory into California. The United States supported a small group of insurgents from Sonoma during the Bear Flag Revolt. The Bear Flaggers captured Sonoma in June of 1846. The next month, Commodore John Drake Sloat landed in Monterey and proceeded to take Yerba Buena, Sutter’s Fort, Bodega Bay, and Sonoma. Fighting between American and Mexican forces continued until Mexico surrendered in 1847 (Rolle 2003).

American Period (1848 – Present)
The American Period began with the signing of the Treaty of Guadalupe Hidalgo in 1848, in which the United States agreed to pay Mexico $15 million for the conquered territory, including California, Nevada, Utah, and parts of Colorado, Arizona, New Mexico, and Wyoming. Settlement of California continued to increase during the early American Period. Many ranchos were sold or otherwise 361
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acquired by Americans, and most were subdivided into agricultural parcels or towns. California’s population grew exponentially with the discovery of gold in 1848. San Francisco grew from a population of 812 to 25,000 in only a few years and became California’s first city (Rolle 2003).

The City of Vallejo, located approximately 5 miles south of the project site, was founded on what was once General Vallejo’s rancho land, and thus was named after him. After the state of California was admitted to the Union, he donated 156 acres of land and offered funding to establish a new state capital. The town of Vallejo briefly became the site of the state capitol in 1852, and it served as the capital again in 1853 for approximately one month. Vallejo’s son-in-law, John B. Frisbie, is generally credited with the founding of the city and helping to establish its government (Vallejo Convention and Visitors Bureau 2019; Vallejo Chamber of Commerce 2020).

Although the town lost the government center, a naval shipyard was established there in 1854 which furthered development of the town. Mare Island Naval Shipyard, also located approximately 5-miles south of the project site, became the first United States Navy installation on the Pacific Coast, and Vallejo developed into an important shipping center with ferry transportation serving passengers, railroads, and the Pony Express (Vallejo Convention and Visitors Bureau 2019). The Mare Island Naval Shipyard had an immense impact on the population of Vallejo and surrounding areas. It was known in the 1920s for the development of submarines, and its peak production period for shipbuilding, repair, and maintenance occurred during World War II. Correspondingly, the population in the areas greatly expanded during the war years. Mare Island continued to be a primary station for the construction and development of the Navy’s pacific fleet of submarines in the years that followed. At the time, the base encompassed 5,200 acres (Vallejo Chamber of Commerce 2020). The area flourished as well, in part due to the Navy’s presence which attracted countless military and civilian personnel from various parts. In the 1920s many Filipinos settled in the area following the Spanish-American War and the Filipino Insurrection, making the area one of the most diverse areas in northern California.

With the end of the Cold War, Mare Island Naval Shipyard’s budget was reduced and the shipyard was closed in 1996, dramatically affecting the surrounding areas. The municipality underwent a bankruptcy in 2008, and efforts afterwards focused on drawing new investment to the area (Felix 2013). Various industrial, educational, recreational and historical areas have been developed as part of evolving the property for new uses (Gase 2019). Today, the waterfront area has become a focus for redevelopment to generate economic growth (City of Vallejo 2018).

City of American Canyon
The area now comprising Napa County was subject to European exploration as early as 1823, when Francisco Castro, Father Jose Altamira, and Jose Sanchez led an expedition though the area to find a site for a new mission. However, despite this incursion, European-American settlement of what is now American Canyon did not begin until two years after California was admitted to the United States (FirstCarbon Solutions 2016). In 1852, American Simpson Thompson purchased lands from General Mariano Guadalupe Vallejo and General J.B. Frisbie to establish a ranch. Thompson earned fame as one of the area’s earliest fruit growers, but also grew grains on his land. In 1869, a railroad servicing the Napa Valley was developed, with a stop at Napa Junction (the original name for American Canyon), from which another line went east into the interior of California (ACHC n.d.). The area maintained a predominantly agricultural character until around 1900, when Augustus Watson established a limestone quarry. By 1902, Watson sold the quarry to the Standard Portland Cement Company, which supplemented the quarry with a new cement plant. Central to the local economy, the plant employed 200 and produced more than 2,000 barrels of cement a day, on average. The 362
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plant continued producing cement until the 1920s or 1930s, when the local supply of limestone was exhausted. By 1946, the Basalt Rock Company repurposed the facility for the production of aggregate (FirstCarbon Solutions 2016).

Residential development of the area began after World War II. American Canyon’s first subdivision, McKnight Acres was completed in 1948 and the Rancho Del Mar subdivision was built in 1952.

Throughout the 1950s and 1960s, the community established new institutions and municipal services, such as the American Canyon Fire Protection District and the American Canyon Water District, in addition to expansions of the sewer and parks systems. A multi-decade campaign resulted in the incorporation of American Canyon in 1992, confirming the community’s separate identity from neighboring Vallejo and Napa (ACHC n.d.). The city has grown steadily since its incorporation, expanding from about 7,000 in 1990 to approximately 21,658 residents in 2022 (see Section 4.13, Population and Housing).
c. Historical and Archaeological Resources in the Project Site Rincon Consultants, Inc. completed background research in August of 2022 in support of the project.

The research consisted of a California Historical Resources Information System (CHRIS) records search at the Northwest Information Center (NWIC) of the project site and a surrounding 0.5-mile radius, as well as a Native American Heritage Commission (NAHC) Sacred Lands File (SLF) search and historical map and aerial photograph review.

The CHRIS search identified 14 previously recorded resources within 0.5 mile of the project site, none of which are located within the project site. Of these 14 previously recorded resources, one is a prehistoric site, one is a prehistoric isolate, three are historic-period archaeological resources, and nine are historic-period built environment resources. The SLF search request was sent out on August 5, 2022. On October 11, 2022, the results of the SLF search were received and the NAHC stated that the results were positive. The results letter also stated that the City should contact the MishewalWappo Tribe of Alexander Valley along with 12 additional Tribes who may also have knowledge of cultural resources in the area. On November 4, 2022, the City mailed and emailed letters to all 13 Tribes provided by the NAHC. On November 18, 2022, a representative from the Yocha Dehe Wintun Nation responded to the City and requested a copy of the cultural resources study for the project, as well as project information. The City conducted a consultation meeting with the Yocha Dehe Wintun Nation on February 8, 2023. For a summary of the consultation meeting, refer to the discussion in Impact TCR-1 in Section 4.16, Tribal Cultural Resources.

Review of the historical maps and aerial photographs revealed that there were several buildings and structures (i.e., farmhouses, outbuildings, residences, railroad, roads, etc.) located within and immediately adjacent to the project site as early as 1948, most, if not all of which are still present today. Most of the additional building and structures present within the project site today were present by at least 1968 (NETR Online 2021).

To identify known historical resources within the annexation site, background research included a review of the NRHP, CRHR, and the California Office of Historic Preservation Built Environment Resource Directory (BERD). No known historical resources were identified within the annexation site. A review of parcel data for properties within the annexation site, however, found eight properties which have not been subject to previous historical resources evaluation, but which currently meet the 45-year threshold recommended for recordation by the California Office of Historic Preservation. Additionally, a portion of the Union Pacific Railroad is also within the annexation site. Pending further analysis there is a potential for these previously unevaluated 363
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properties to qualify as historical resources pursuant to CEQA. Table 4.5-1 includes a full list of ageeligible properties, and those properties are mapped on Figure 4.5-1.

Table 4.5-1 Properties with Age-Eligible Buildings
Site ID APN Building Age Age-Eligible?
A 059-020-036 NA No
B 057-120-014 1956 Yes
C 057-120-015 1948 Yes
D 057-120-017 NA No
E 057-120-028 1976 Yes
F 057-120-034 1946/1950 Yes
G 057-120-036 1966 Yes
H 057-120-041 2000 No
I 057-120-045 1989 No
J 057-120-047 NA No
K 057-120-048 1960 Yes
L 057-120-049 1988 No
M 057-120-050 NA No
N 057-120-051 2005 No
O 057-180-014 1954 Yes
P 057-180-015 1956/1990 Yes
Q UPRR N/A No
In addition, the current City of American Canyon General Plan states that the Napa County Department of Conservation currently maintains data on cultural resources within the County.

Affected properties which have cultural resources are listed by assessor parcel number and are available to individual property owners. In addition, the City maintains a citywide cultural resource database to ensure that cultural resources throughout the community are not significantly impacted by future development. As a result, the City maintains a map with “Archaeologically Sensitive Areas” to determine the sensitivity of an area for new development. 364
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Figure 4.5-1 Age Eligible Properties Map
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4.5.2 Regulatory Setting
a. Federal Regulations
National Register of Historic Places
Although the project does not have a federal nexus, properties which are listed in or have been formally determined eligible for listing in the National Register of Historic Places (NRHP) are automatically listed in the California Register of Historical Resources (CRHR). The following is therefore presented to provide applicable regulatory context. The NRHP was authorized by Section 101 of the National Historic Preservation Act and is the nation’s official list of cultural resources worthy of preservation. The NRHP recognizes the quality of significance in American, state, and local history, architecture, archaeology, engineering, and culture is present in districts, sites, buildings, structures, and objects. Pursuant to 36 Code of Federal Regulations (CFR) Part 60.4, a property is eligible for listing in the NRHP if it meets one or more of the following criteria:

Criterion A: Are associated with events that have made a significant contribution to the broad patterns of our history.

Criterion B: Are associated with the lives of persons significant in our past.

Criterion C: Embody the distinctive characteristics of a type, period, or method of installation, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction.

Criterion D: Have yielded, or may be likely to yield, information important in prehistory or history.

In addition to meeting at least one of the above designation criteria, resources must also retain integrity. The National Park Service recognizes seven aspects or qualities that, considered together, define historic integrity. To retain integrity, a property must possess several, if not all, of these seven qualities, defined as follows:
 Location: The place where the historic property was constructed or the place where the historic event occurred.
 Design: The combination of elements that create the form, plan, space, structure, and style of a property.
 Setting: The physical environment of a historic property.  Materials: Materials are the physical elements that were combined or deposited during a particular period of time and in a particular pattern or configuration to form a historic property.  Workmanship: The physical evidence of the crafts of a particular culture or people during any given period in history or prehistory.
 Feeling: A property’s expression of the aesthetic or historic sense of a particular period of time.  Association: The direct link between an important historic event or person and a historic property.

Certain properties are generally considered ineligible for listing in the NRHP, including cemeteries, birthplaces, graves of historical figures, properties owned by religious institutions, relocated structures, or commemorative properties. Additionally, a property must be at least 50 years of age to be eligible for listing in the NRHP. The National Park Service states that 50 years is the general 366
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estimate of the time needed to develop the necessary historical perspective to evaluated significance (National Park Service 1983). Properties which are less than 50 years must be determined to have “exceptional importance” to be considered eligible for NRHP listing. b. State Regulations
California Environmental Quality Act
California Public Resources Code (PRC) Section 21804.1 requires lead agencies determine if a project could have a significant impact on historical or unique archaeological resources. As defined in PRC Section 21084.1, a historical resource is a resource listed in, or determined eligible for listing in, the CRHR; a resource included in a local register of historical resources or identified in a historical resources survey pursuant to PRC Section 5024.1(g); or any object, building, structure, site, area, place, record, or manuscript that a lead agency determines to be historically significant. PRC Section 21084.1 also states resources meeting the above criteria are presumed to be historically or cultural significant unless the preponderance of evidence demonstrates otherwise. Resources listed in the NRHP are automatically listed in the CRHR and are, therefore, historical resources under CEQA.

Historical resources may include eligible built environment resources and archaeological resources of the precontact or historic periods.

CEQA Guidelines Section 15064.5(c) provides further guidance on the consideration of archaeological resources. If an archaeological resource does not qualify as a historical resource, it may meet the definition of a “unique archaeological resource” as identified in PRC Section 21083.2.

PRC Section 21083.2(g) defines a unique archaeological resource as an artifact, object, or site about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it meets any of the following criteria:

It contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information;
Has a special and particular quality such as being the oldest of its type or the best available example of its type; or
Is directly associated with a scientifically recognized important prehistoric or historic event or person.

If an archaeological resource does not qualify as a historical or unique archaeological resource, the impacts of a project on those resources will be less than significant and need not be considered further (CEQA Guidelines Section 15064.5[c][4]). CEQA Guidelines Section 15064.5 also provides guidance for addressing the potential presence of human remains, including those discovered during the implementation of a project.

According to CEQA, an impact that results in a substantial adverse change in the significance of a historical resource is considered a significant impact on the environment. A substantial adverse change could result from physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of the historical resource would be materially impaired (CEQA Guidelines Section 15064.5 [b][1]). Material impairment is defined as demolition or alteration in an adverse manner [of] those characteristics of a historical resource that convey its historical significance and that justify its inclusion in, or eligibility for inclusion in, the CRHR or a local register (CEQA Guidelines Section 15064.5[b][2][A]). 367
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If it can be demonstrated that a project will cause damage to a unique archaeological resource, the lead agency may require reasonable efforts be made to permit any or all these resources to be preserved in place or left in an undisturbed state. To the extent that resources cannot be left undisturbed, mitigation measures are required (PRC Section 21083.2[a], [b]).

CEQA Guidelines Section 15126.4 stipulates an EIR shall describe feasible measures to minimize significant adverse impacts. In addition to being fully enforceable, mitigation measures must be completed within a defined time period and be roughly proportional to the impacts of the project.

Generally, a project which is found to comply with the Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings (the Standards) is considered to be mitigated below a level of significance (CEQA Guidelines Section 15126.4 [b][1]). For historical resources of an archaeological nature, lead agencies should also seek to avoid damaging effects where feasible. Preservation in place is the preferred manner to mitigate impacts to archaeological sites; however, data recovery through excavation may be the only option in certain instances (CEQA Guidelines Section 15126.4[b][3]).

California Register of Historical Resources
The CRHR was established in 1992 and codified by PRC Sections 5024.1 and 4852. The CRHR is an authoritative listing and guide to be used by State and local agencies, private groups, and citizens in identifying the existing historical resources of the State and to indicate which resources deserve to be protected from substantial adverse change to the extent prudent and feasible (Public Resources Code, 5024.1(a)). The criteria for eligibility for the CRHR are consistent with the NRHP criteria but have been modified for state use to include a range of historical resources that better reflect the history of California (Public Resources Code, 5024.1(b)). Unlike the NRHP, the CRHR does not have a defined age threshold for eligibility; rather, a resource may be eligible for the CRHR if it can be demonstrated sufficient time has passed to understand its historical or architectural significance (California Office of Historic Preservation 2006). Further, resources may still be eligible for listing in the CRHR even if they do not retain sufficient integrity for NRHP eligibility (California Office of Historic Preservation 2006). Generally, the California Office of Historic Preservation recommends resources over 45 years of age be recorded and evaluated for historical resources eligibility (California Office of Historic Preservation 1995:2).

Properties are eligible for listing in the CRHR if they meet one of more of the following criteria:

Criterion 1: Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage.

Criterion 2: Is associated with the lives of persons important to our past.

Criterion 3: Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values.

Criterion 4: Has yielded, or may be likely to yield, information important in prehistory or history.

California Health and Safety Code Section 7050.5
California Health and Safety Code Section 7050.5 states that in the event of discovery or recognition of any human remains in any location other than a dedicated cemetery, there shall be no further excavation or disturbance of the site, or any nearby area reasonably suspected to overlie adjacent 368
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remains, until the coroner of the county in which the remains are discovered has determined if the remains are subject to the coroner’s authority. If the human remains are of Native American origin, the coroner must notify the NAHC within 24 hours of this identification.

California Public Resources Code Section 5097.98
California Public Resources Code Section 5097.98 states that the NAHC, upon notification of the discovery of Native American human remains pursuant to Health and Safety Code Section 7050.5, shall immediately notify those persons it believes to be descended from the deceased (i.e., the Most Likely Descendant or “MLD”). With permission of the landowner or a designated representative, the MLD may inspect the remains and any associated cultural materials and make recommendations for treatment or disposition of the remains and associated grave goods. The MLD shall provide recommendations or preferences for treatment of the remains and associated cultural materials within 48 hours of being granted access to the site.
c. Local Regulations
City of American Canyon General Plan
The current City of American Canyon General Plan contains goals and policies to avoid potential impacts to cultural resources. These goals and policies were created to ensure that the City’s culturally significant resources are protected through the following:
 Conducting a comprehensive archaeological and cultural resources and historic vegetation survey in the City and Sphere of Influence;
 Adopting an Ordinance authorizing the City to designate appropriate vegetation or archaeological sites as American Canyon City Historic Points, Sites, or Districts as approved by the State Historic Office of Preservation;
 Exploring methods for the future preservation of historic vegetation and archaeological and cultural resources;
 Requiring all City-owned properties designated as historic resources are maintained in a manner that is aesthetically and/ or functionally compatible with the resources;  Establishing a program of historic preservation incentives;  Considering waiving building permit fees for small property owners with historic resources for the purpose of renovation/ preservation of that resource;  Considering allowing flexibility in the building code requirements for rehabilitation of historic structures;
 Encouraging appropriate adaptive reuse of historic resources;  Promoting the formation of neighborhood conservation organizations; and  Encouraging the Chamber of Commerce to promote the City’ s historic resources in visitor and tourist oriented materials (City of American Canyon General 2019).

The goals and policies from the General Plan relevant to cultural resources are identified below:

Goal 8E: To Promote the preservation and restoration of the sites, structures and districts that have architectural, historical, archaeological and/or cultural significance to the City of American Canyon.

Objective 8.19: Ensure that the City’s historically and archaeologically significant resources are protected in a manner that preserves and/or enhances the resources’ inherent historic value. 369
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Policy 8.19.1: Conduct a comprehensive survey of archaeological and cultural resources and historic vegetation that is based on established criteria and encompasses the entire City and its Sphere of Influence.

Policy 8.19.2: Adopt a Preservation Ordinance that will authorize the City to designate appropriate vegetation or archaeological sites deemed to be of historic, archaeological, or cultural significance an American Canyon City Historic Point, Site or District. Such an ordinance shall conform to state and federal criteria for establishing a preservation ordinance.

Policy 8.19.3: Explore various methods for the future preservation of historic vegetation and archaeological and cultural resources. For example, consider establishing “receiver site” and “adopt a building” programs to preserve historic structures that must be removed from their sites. Additionally, consider utilizing the Secretary of the Interior Standards for Historic Rehabilitation and standards and guidelines prescribed by the State Office of Historic Preservation as the architectural and landscape design standards for rehabilitation, alteration, or additions to sites containing historic resources in order to preserve these structures in a manner consistent with the sites’ architectural and historic integrity.

Policy 8.19.4: Though the design review process, encourage compatibility between new development and existing adjacent historic structures in terms of scale, massing, building materials and general architectural treatment.

Policy 8.19.5: Require that all City- owned properties designated as historic resources are maintained in a manner that is aesthetically and/or functionally compatible with such resources.

Objective 8.20: Provide incentives to private owners of historic resources to maintain and/ or enhance their properties in a manner that will conserve the integrity of such resources in the best possible condition.

Policy 8.20.1: Establish a program of historic preservation incentives that incorporates elements such as tax benefits provided by the 1981 Tax Revenue Act or any amended version of said act; the waiver of building permit fees for small property owners of historic resources; and flexible building code requirements.

Policy 8.20.2: Consider the waiver of building permit fees for small property owners with historic resources who are unable to benefit from other government programs for the rehabilitation, alteration, or reuse of their structure(s), provided that they rehabilitate their historic resources in accordance with established historic preservation guidelines.

Policy 8.20.3: Consider allowing flexibility in building code requirements for the rehabilitation of historic structures as specified in State Historical Building Code Part 8, Title 24 if these structures are rehabilitated in accordance with established historic preservation guidelines.

Policy 8.20.4: Prohibit demolitions if other alternatives exist that enable a property owner to sensitively add to the existing structure, or develop an accompanying building on the site that allows property development rights to be realized. Variances of setbacks, heights and parking requirements should be given to make the preservation of an existing historic building feasible when no other reasonable alternative exists.

Policy 8.20.5: Encourage appropriate adaptive reuse of historic resources such as the Basalt Plant in order to prevent misuse, disrepair and demolition, taking care to protect surrounding neighborhoods and/or agricultural land from incompatible uses. 370
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Objective 8.21: Promote community appreciation of American Canyon’s unique history and community involvement in its retention and preservation.

Policy 8.21.1: Promote the formation and maintenance of neighborhood organizations and foster the creation of neighborhood conservation programs, giving special attention to transitional areas.

Policy 8.21.2: Encourage the creation of a Chamber of Commerce to promote the City’s historic resources in visitor and tourist oriented brochures as the City grows and develops.

4.5.3 Impact Analysis
a. Significance Thresholds and Methodology
Significance Thresholds
Based on Appendix G of the CEQA Guidelines a project may be deemed to have a significant impact on cultural resources if it would:

Cause a substantial adverse change in the significance of a historic resource pursuant to Section 15064.5
Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5
Disturb any human remains, including those interred outside of formal cemeteries Methodology
If a project may cause a substantial adverse change in the characteristics of a resource that convey its significance or justify its eligibility for inclusion in the CRHR, either through demolition, destruction, relocation, alteration, or other means, then the project would have a significant effect on the environment (CEQA Guidelines Section 15064.5[b]).

Direct impacts can be assessed by identifying the types and locations of proposed development, determining the exact locations of cultural resources within the project site, assessing the significance of the resources that may be affected, and determining the appropriate mitigation.

Removal, demolition, or alteration of historical resources can permanently impact the historic fabric of an archaeological site, building or structure, or historic district.

The State Legislature, in enacting the CRHR, amended CEQA to clarify which properties are significant, as well as which project impacts are considered significantly adverse. A project with an effect that may cause a substantial adverse change in the significance of a historical resource is a project that may have significant effect on the environment (CEQA Guidelines Section 150645[b]). A substantial adverse change in the significance of a historical resource means demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of a historical resource would be materially impaired (CEQA Guidelines Section 150645[b][1]).

The CEQA Guidelines further state that “[t]he significance of an historical resource is materially impaired when a project… [d]emolishes or materially alters in an adverse manner those physical characteristics of an historical resource that convey its historical significance and that justify its inclusion in the California Register … local register of historic resources… or its identification in an historic resources survey.” As such, the consideration for determining whether the project will have 371
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a significant impact on identified historic resources is whether it will materially impair the physical integrity of the historic resource, such that it could no longer be listed in the CRHR or a local landmark program.

Threshold 1: Would the project cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5?
Impact CUL-1 THE PROJECT COULD ADVERSELY AFFECT PREVIOUSLY UNIDENTIFIED HISTORIC-PERIOD RESOURCES. IMPACTS TO HISTORIC-PERIOD RESOURCES WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION.

No previously recorded cultural resources are located within the projects site. However, review of historical maps and aerial photographs and review of available parcel data revealed there are several historic-aged buildings or structures located within and immediately adjacent to the project site. Currently there are no specific development plans within the project site; however, the project envisions development on parcels containing buildings that meet the age threshold for potential historical resources pursuant to CEQA.

Development facilitated by the project could result in material impairment of historical resources, which CEQA Guidelines Section 15064.5[b][2][A] defines as the demolition or alteration in an adverse manner [of] those characteristics of a historical resource that convey its historical significance and that justify its inclusion in, or eligibility for inclusion in, the CRHR or a local register.

The City of American Canyon currently has provisions under Goal 8E within its General Plan (described above in Section 4.5.2, Regulatory Setting) that address the identification and treatment of historical resources. These policies would help reduce impacts; however, they do not currently require formal historical resource evaluations or the consideration of measures to mitigate any potential impacts. As such, additional measures would be required to identify and mitigate impacts to historical resources to a less than significant level.

The implementation of Mitigation Measure CUL-1 would reduce impacts on historical resources by requiring evaluations for age-eligible buildings within the project site and avoiding impacts on any identified potential historical resources. This impact would be less than significant at the programmatic level with implementation of this mitigation measure.

Mitigation Measures
CUL-1 Historical Built Environment
Prior to project approval, the applicant shall submit a report to the City that identifies any historicage features (i.e., structures over 45 years of age) proposed to be altered or demolished. If historical-age features are present, the applicant shall submit a historical resources evaluation to the City prepared in areas that contains buildings, structures, objects, sites, landscape/site plans, or other features that are 45 years of age or older, by a qualified architectural historian or historian who meets the Secretary of the Interior’s Professional Qualifications Standards (PQS) in architectural history or history (36 CFR Part 61). The evaluation shall include an intensive-level evaluation, in accordance with the guidelines and best practices meeting the State Office of Historic Preservation guidelines. All evaluated properties shall be documented on Department of Parks and Recreation Series 523 Forms. The report shall be submitted to the City for review and approval.

If historical resources are identified through the survey and evaluation, efforts shall be made by the applicant to ensure that the relocation, rehabilitation, or alteration of the resource is consistent with the Secretary of the Interior’s Standards for the Treatments of Historic Properties (Standards). 372
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The applicant shall submit a report to the City that identifies and specifies the treatment of character-defining features and construction activities, and demonstrates how the project complies with the Standards and avoids the substantial adverse change in the significance of the historical resource as defined by CEQA Guidelines Section 15064.5(b). The report shall be prepared by an architectural historian or historical architect meeting the PQS as defined by 36 CFR Part 61 and provided to the City for review and concurrence prior to project approval.

Significance After Mitigation
Mitigation Measure CUL-1 would ensure a historical resource evaluation is conducted for sites with age-eligible resources within the project site and require measures to reduce impacts to historical resources to less than significant.

Threshold 2: Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5?
Impact CUL-2 THE PROJECT COULD ADVERSELY AFFECT PREVIOUSLY UNIDENTIFIED ARCHAEOLOGICAL RESOURCES. IMPACTS WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION.

No previously record cultural resources are located within the project site. However, ground disturbance into native soils in any areas within the project site could contain previously unknown prehistoric or historic-period resources. According to the Final EIR for the 2002 General Plan the northern half of the project site is an area designated “Archaeologically Sensitive Area” (City of American Canyon 2019). As a result, the potential to encounter unidentified archaeological resources within the project site, is moderate to high. Undeveloped areas, especially in the northern half of the project site have a higher probability of containing previously unidentified archaeological resources, given the City’s known sensitivity of that area and probable lack of previous grounddisturbing activities in those areas.

Many portions of the project site have been previously developed for various purposes and uses.

Nonetheless, there is the potential for both historic and prehistoric archaeological resources to exist surficially and below the ground surface throughout the project site, which could be disturbed by grading and excavation activities. Therefore, individual development projects within the project site that involve ground disturbance activities, including the Newell Drive Extension, would have the potential to damage or destroy archaeological resources, especially if they occur below the existing road base or in less disturbed sediments. Consequently, impacts would be potentially significant, and mitigation would be required for projects involving ground disturbance activities.

Mitigation Measures
CUL-2 Archaeological Resources Assessment
Prior to submittal of any discretionary development application that involves ground disturbance activities (that may include but are not limited to, pavement removal, potholing, grubbing, tree removal, and grading), the applicant shall submit an archaeological resources assessment prepared by a qualified archaeologist who meets the Secretary of the Interior’s Professional Qualifications Standards in either prehistoric or historic archaeology. Assessments shall include a CHRIS records search at the NWIC and a SLF Search from the NAHC. The records searches shall characterize the results of previous cultural resource surveys and disclose any cultural resources that have been recorded and/or evaluated in and around the development site. If the assessment begins on or 373
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before 2027, the results of the NWIC and SLF search for this EIR can be summarized as part of the assessment. A Phase I pedestrian survey shall be undertaken in future project areas that are undeveloped to locate any surface cultural materials. By performing a records search, a SLF search, and a Phase I survey, a qualified archaeologist shall be able to classify the future project area as having high, medium, or low sensitivity for archaeological resources.

If the Phase I archaeological survey identifies resources that may be affected by the future project, the archaeological resources assessment shall also include Phase II testing and evaluation. If resources are determined significant or unique through Phase II testing and site avoidance is not possible, appropriate site-specific mitigation measures shall be identified in the Phase II evaluation.

These measures may include, but would not be limited to, a Phase III data recovery program, avoidance, or other appropriate actions to be determined by a qualified archaeologist. If significant archaeological resources cannot be avoided, impacts may be reduced to less than significant level by filling on top of the sites rather than cutting into the cultural deposits. Alternatively, and/or in addition, a data collection program may be warranted, including mapping the location of artifacts, surface collection of artifacts, or excavation of the cultural deposit, to characterize the nature of the buried portions of sites. Curation of the excavated artifacts or samples would occur as specified by the archaeologist. The archaeological resources assessment shall be reviewed and approved by the City prior to project approval.

CUL-3 Unanticipated Discoveries
An Archaeologist who meets the Secretary of the Interior’s Professional Qualification Standards for archaeology shall be present on-site during all earth disturbing activities. If cultural resources are encountered during ground-disturbing activities, work within 100 feet of the area shall be halted and the contractor shall contact an archaeologist meeting the Secretary of the Interior’s Professional Qualification Standards for archaeology in either prehistoric or historic archaeology immediately to evaluate the find. If necessary, the evaluation may require preparation of a treatment plan and archaeological testing for CRHR eligibility. If the discovery proves to be significant under CEQA and cannot be avoided by the project, additional work, such as excavating the cultural deposit to fully characterize its extent and collecting and curating artifacts may be warranted to mitigate any significant impacts to cultural resources. If archaeological resources of Native American origin are identified during construction, a qualified archaeologist will consult with the City to begin Native American consultation procedures. Periodic reports of the find and subsequent evaluations shall be submitted to the City during construction.

Significance After Mitigation
Mitigation Measures CUL-2 and CUL-3 would reduce potential impacts to a less than significant level by requiring the identification and evaluation of any archaeological resources that may be present prior to construction and by providing steps for the evaluation and protection of unanticipated finds encountered during construction.
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Threshold 3: Would the project disturb any human remains, including those interred outside of formal cemeteries?
Impact CUL-3 THE PROJECT COULD RESULT IN DAMAGE TO OR DESTRUCTION OF HUMAN BURIALS.

IMPACTS WOULD BE LESS THAN SIGNIFICANT THROUGH ADHERENCE TO EXISTING REGULATIONS AND WITH MITIGATION.

Human burials outside of formal cemeteries can occur in prehistoric archaeological contexts. While no known burial sites have been identified within the project site, excavations during construction activities could have the potential to disturb these resources, which could include Native American burial sites. Although it is unlikely that human remains are present, the project site has the possibility of containing previously unidentified human remains.

Human burials, in addition to being potential archaeological resources, have specific provisions for treatment in PRC Section 5097. The California Health and Safety Code (Section 7050.5, 7051, and 7054) has specific provisions for the protection of human burial remains. Existing regulations address the illegality of interfering with human burial remains, and protect them from disturbance, vandalism, or destruction. They also include established procedures to be implemented if Native American skeletal remains are discovered. PRC Section 5097.98 also addresses the disposition of Native American burials, protects such remains, and establishes the NAHC to resolve any related disputes.

Construction associated with the project, including new development and the Newell Drive Extension would be subject to State of California Health and Safety Code Section 7050.5, which states that if human remains are unearthed, no further disturbance can occur until the county coroner has made the necessary findings as to the origin and disposition of the remains, pursuant to PRC Section 5097.98. If the remains are determined to be of Native American descent, the coroner has 24 hours to notify the NAHC, which will determine and notify an MLD. The MLD shall complete the inspection of the site and make recommendations to the landowner within 48 hours of being granted access. Implementation of Mitigation Measures CUL-4 and CUL-5 would ensure that the appropriate protocols are followed if human remains are encountered and would reduce a potentially significant impact to a less than significant level.

Mitigation Measures
CUL-4 Human Remains
In the event of an accidental discovery or recognition of any human remains, CEQA Guidelines Section 15064.5, Health and Safety Code Section 7050.5, and Public Resources Code Sections 5097.94 and Section 5097.98 shall be followed. If during project construction, there is accidental discovery or recognition of any human remains, the following steps shall be taken:

There shall be no further excavation or disturbance within 100 feet of the remains until the County Coroner is contacted to determine whether the remains are Native American and if an investigation of the cause of death is required. If the Coroner determines the remains to be Native American, the Coroner shall contact the Native American Heritage Commission (NAHC) within 24 hours, and the NAHC shall identify the person or persons it believes to be the Most Likely Descendant (MLD) of the deceased Native American. The MLD may make recommendations to the landowner or the person responsible for the excavation work within 48 hours, for means of treating or disposing of, with appropriate dignity, the human remains, and any associated grave goods as provided in Public Resource Code Section 5097.98. 375
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Where the following conditions occur, the landowner or authorized representative shall rebury the Native American human remains and associated grave goods with appropriate dignity either in accordance with the recommendations of the MLD or on the project site in a location not subject to further subsurface disturbance:
 The NAHC is unable to identify an MLD or the MLD failed to make a recommendation within 48 hours after being notified by the commission.
 The descendant identified fails to make a recommendation.  The landowner or authorized representative rejects the recommendation of the descendant, and mediation by the NAHC fails to provide measures acceptable to the landowner.

Additionally, California Public Resources Code Section 15064.5 requires the following relative to Native American Remains:
 When an initial study identifies the existence of, or the probable likelihood of, Native American Remains within a project, a lead agency shall work with the appropriate Native Americans as identified by the NAHC as provided in Public Resources Code Section 5097.98. The applicant may each develop a plan with respect to their respective individual development proposals for treating or disposing of, with appropriate dignity, the human remains, and any items associated with Native American Burials with the appropriate Native Americans as identified by the NAHC.

CUL-5 Tribal Monitoring
A Tribal Monitor representing the Yocha Dehe Wintun Nation shall be present during all projectrelated ground disturbance. Additionally, the Yocha Dehe Wintun Nation’s Treatment Protocol (Protocol) shall be followed with respect to Tribal Cultural Resources (TCRs). The purpose of the protocol is to formalize procedures for the treatment of Native American human remains, grave goods, ceremonial items, and items of cultural patrimony, if any are found in conjunction with development, including archaeological studies, excavation, geotechnical investigations, grading, and any ground-disturbing activity. This Protocol also formalizes procedures for Tribal Monitoring during archaeological studies, grading, and ground-disturbing activities.

Cultural Affiliation: The Yocha Dehe Wintun Nation (Tribe) traditionally occupied lands in Yolo, Solano, Lake, Colusa, and Napa Counties. The Tribe has designated its Cultural Resources Committee (Committee) to act on the Tribe's behalf with respect to the provisions of this Protocol. Any human remains which are found in conjunction with projects on lands culturally affiliated with the Tribe shall be treated in accordance with Section III of this Protocol. Any other cultural resources shall be treated in accordance with Section IV of this Protocol.

Inadvertent Discovery of Native American Human Remains: Whenever Native American human remains are found during the course of a project, the determination of Most Likely Descendant (MLD) under California Public Resources Code Section 5097.98 will be made by the Native American Heritage Commission (NAHC) upon notification to the NAHC of the discovery of said remains at a project site. If the location of the site and the history and prehistory of thearea is culturally affiliated with the Tribe, the NAHC contacts the Tribe; a Tribal member will be designated by the Tribe to consult with the landowner and/or project proponents.

Should the NAHC determine that a member of an Indian tribe other than Yocha Dehe Wintun Nation is the MLD, and the Tribe agrees with this determination, the terms of this Protocol relating to the treatment of such Native American human remains shall not be applicable; however, that situation is very unlikely.
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Treatment of Native American Remains: In the event that Native American human remains are found during development of a project and the Tribe or a member of the Tribe is determined to be MLD pursuant to Section II of this Protocol, the following provisions shall apply. The Medical Examiner shall immediately be notified, ground-disturbing activities in that location shall cease and the Tribe shall be allowed, pursuant to California Public Resources Code Section 5097.98(a), to (1) inspect the site of the discovery and (2) make determinations as to how the human remains and grave goods shall be treated and disposed of with appropriate dignity. The Tribe shall complete its inspection and make its MLD recommendation within 48 hours of getting access to the site. The Tribe shall have the final determination as to the disposition and treatment of human remains and grave goods. Said determination may include avoidance of the human remains, reburial on-site, or reburial on tribal or other lands that will not be disturbed in the future. The Tribe may wish to rebury said human remains and grave goods or ceremonial and cultural items on or near the site of their discovery, in an area which will not be subject to future disturbances over a prolonged period of time. Reburial of human remains shall be accomplished in compliance with the California Public Resources Code Sections 5097.98(a) and (b). The term "human remains" encompasses more than human bones because the Tribe’s traditions call for the burial of associated cultural items with the deceased (funerary objects), and/or the ceremonial burning of Native American human remains, funerary objects, grave goods, and animals. Ashes, soils, and other remnants of these burning ceremonies, as well as associated funerary objects and unassociated funerary objects buried with or found near the Native American remains are to be treated in the same manner as bones or bone fragments that remain intact.

Non-Disclosure of Location of Reburials: Unless otherwise required by law, the site of any reburial of Native American human remains shall not be disclosed and will not be governed by public disclosure requirements of the California Public Records Act, California Government Code Section 6250 et seq. The Medical Examiner shall withhold public disclosure of information related to such reburial pursuant to the specific exemption set forth in California Government Code Section 6254(r). The Tribe will require that the location for reburial is recorded with the California Historic Resources Inventory System (CHRIS) on a form acceptable to the CHRIS center. The Tribe may also suggest the landowner enter into an agreement regarding the confidentiality of site information that will run with title on the property.

Treatment of Cultural Resources: Treatment of all cultural items, including ceremonial items and archaeological items will reflect the religious beliefs, customs, and practices of the Tribe. All cultural items, including ceremonial items and archaeological items, which may be found at a project site shall be turned over to the Tribe for appropriate treatment, unless ordered by a court or agency of competent jurisdiction. The project proponent shall waive any and all claims to ownership of Tribal ceremonial and cultural items, including archaeological items, which may be found on a project site in favor of the Tribe. If any intermediary, (for example, an Archaeologist retained by the project proponent) is necessary, said entity or individual shall not possess those items for longer than is reasonably necessary, as determined solely by the Tribe.

Inadvertent Discoveries: If additional significant sites or sites not identified as significant in a project environmental review process, but later determined to be significant, are located within a project impact area, such sites will be subjected to further archaeological and cultural significance evaluation by the project proponent, the Lead Agency, and the Tribe to determine whether additional mitigation measures are necessary to treat sites in a culturally appropriate manner consistent with CEQA requirements for mitigation of impacts to cultural resources. If 377
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there are human remains present that have been identified as Native American, all work will cease for a period of up to 30 days in accordance with Federal Law.

Significance After Mitigation
Mitigation Measures CUL-4 and CUL-5 would reduce potential impacts on human remains to a less than significant level by requiring the implementation of the appropriate protocols.

4.5.4 Cumulative Impacts
The potential for impacts to built environment historical resources from individual developments is site-specific and depends on the location and nature of each individual development proposal. All future development projects would continue to be subject to existing federal, State, and local requirements. At this time, it cannot be known whether each individual project would result in a significant impact on a historical resource. It should be noted that the closest and largest cumulative project (Watson Ranch Specific Plan) identified no impacts to a historical resource (City of American Canyon 2018). Nonetheless, there is still the potential for cumulative projects to alter or demolish a historical resource within the City, which could result in a significant cumulative impact. The project would implement Mitigation Measure CUL-1, which would result in the project resulting in a less than significant impact. As such, because the project would result in a less than significant impact on historical resources, the impacts from the project would be less than cumulatively considerable.

Cumulative development could potentially disturb areas that may contain archaeological resources.

While there is the potential for significant cumulative impacts to cultural resources, it is anticipated that potential impacts associated with individual development projects would be addressed on a case-by-case basis and would be subject to City policies and local and State regulations regarding the protection of such resources. It should be noted that the closest and largest cumulative project (Watson Ranch Specific Plan) identified that impacts on archaeological resources would be less than significant after application of mitigation requiring appropriate treatment of the unanticipated discovery of archaeological resources (City of American Canyon 2018). Similarly, the project would include Mitigation Measures CUL-2 and CUL-3, which would require the identification and evaluation of any archaeological resources prior to construction and would provide steps for the evaluation and protection of unanticipated finds encountered during construction. Implementation of these mitigation measures would ensure that the project’s contribution to a cumulative impact on archaeological resources would be less than considerable.

Cumulative projects could also result in impacts on human remains, if any human remains are found during construction. However, all cumulative development projects would be subject to the same regulations identified in Impact CUL-3 through CUL-5. Because cumulative projects would adhere to regulations that would protect human remains, impacts on human remains would be less than significant.
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4.6 Energy
This section analyzes the potential effects related to energy due to implementation of the project.

4.6.1 Setting
a. Energy Fundamentals
Energy is generally transmitted either in the form of electricity, measured in kilowatts (kW) or megawatts (MW); natural gas, measured in British thermal units (BTU), cubic feet, or therms; or fuel (such as gasoline or diesel), measured in gallons or liters. Electricity is used primarily for lighting, appliances, cooking purpose, heating, ventilation, and air conditioning equipment, and other uses associated with building and vehicle operations. Electricity sources range from renewable (e.g., hydroelectric, solar, wind, geothermal, biomass) to nonrenewable (e.g., natural gas, oil, nuclear, coal). Natural gas is used primarily for space and water heating, as well as cooking purposes and industrial processes. Natural gas is typically associated with building operations. Fuel is used primarily for powering on-road and off-road vehicles and equipment. Typical fuel types are diesel and gasoline.
b. Electricity Generation, Distribution, and Use
California
According to the California Energy Commission (CEC), California generated approximately 194,127 gigawatt-hours (GWh) of electricity in 2021. Approximately 50 percent of this electricity was sourced from natural gas, 35 percent from renewable sources, 6 percent from large hydroelectric sources, and the remaining 9 percent was sourced from coal, nuclear, oil, and other and unspecified sources. Specifically, 33.6 percent of California’s 2021 retail electric sales were served by renewable resources, including wind, solar, geothermal, biomass, and small hydroelectric. (CEC 2022a). Electricity is distributed through the various electric load-serving entities in California.

These entities include investor-owned utilities, publicly owned load-serving entities, rural electric cooperatives, community choice aggregators, and electric service providers (CEC 2022a). According to the U.S. Energy Information Administration (USEIA), total retail sale of electricity within California in 2021 was 247,250 GWh. California electricity consumption in 2021 represented approximately 6.5 percent of total U.S. electricity consumption in 2021 (USEIA 2022).

Napa County
Napa County consumed approximately 1,021 GWh of electricity in 2021 from residential and nonresidential uses (CEC 2022a). The project would be served electricity by Pacific Gas and Electric (PG&E). PG&E’s default power mix offers 29 percent renewable, and they offer customers options for 64 percent or 100 percent renewable power mixes (PG&E 2019). In conjunction with PG&E and other utility companies, the California Public Utilities Commission (CPUC) is involved in energy conservation programs. PG&E is the electricity provider for the City of American Canyon. Marin Clean Energy (MCE) is a community choice program, that allows users of electricity in the City of American Canyon to opt into its program, which provides renewable energy to its customers. 379
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c. Natural Gas Distribution and Use
California
According to the CPUC, natural gas from out-of-state production basins is delivered into California via the interstate natural gas pipeline system. The major interstate pipelines that deliver out-ofstate natural gas to California gas utilities are the Gas Transmission Northwest Pipeline, Kern River Pipeline, Transwestern Pipeline, El Paso Pipeline, Ruby Pipeline, Mojave Pipeline, and Tuscarora (CPUC 2022). Because natural gas is a dispatchable energy resource that provides load when the availability of hydroelectric power generation and/or other energy sources decrease, distribution varies greatly from year to year. The availability and distribution of hydroelectric-sourced energy, increasing renewable-source energy, and overall consumer demand shape the need for natural gas.

In 2021, total California natural gas demand for industrial, residential, commercial, and electric power generation was 11,923 million therms per year.

Napa County
Napa County consumed approximately 38 million therms of natural gas in 2021, in both residential and non-residential uses (CEC 2022b). PG&E is the natural gas provider for the City of American Canyon.
d. Fuel Distribution and Use
California
According to the 2015 CEC market share data, distributors of gasoline include companies or individuals who make the first distribution of gasoline in California. Aircraft manufacturers and certificated or licensed carriers by air may be included within the definition of distributor.

Distributors can also be "brokers," which includes every person, other than a distributor or a retailer, who deals in lots of 200 or more gallons of gasoline (CEC 2015).

Based on the California Transportation of Petroleum Second Northern California Refinery Safety Forum, output from the refineries is usually placed in intermediate tanks before blending finished products. Most gasoline is shipped from refinery by pipeline, which serves over 60 distribution terminals, which is then transported to retail and nonretail stations by tanker trucks (Schremp 2015).

The main category of fuel use in California is transportation fuel, specifically gasoline and diesel.

Gasoline is the most used transportation fuel in California: 97 percent of all gasoline sold in California is consumed by light-duty cars, pickup trucks, and sport utility vehicles. In 2021, an estimated 11,618 million gallons of gasoline annually were used (i.e., 32 million gallons gasoline per day) (CEC 2022c). Diesel is the second largest transportation fuel used in California. Many heavy duty-trucks, delivery vehicles, buses, trains, ships, boats and barges, farm, construction, and heavyduty military vehicles and equipment have diesel engines. According to the 2021 California Annual Retail Fuel Outlet Report Results (CEC-A15), in 2021, 1,611 million gallons of diesel annually (i.e., 4.4 million gallons of diesel per day), including off-road diesel were sold (CEC 2022d). 380
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Napa County
Gasoline is distributed throughout the County by retail and non-retail gas stations. In 2021, Napa County had an estimated total of 36 retail gasoline stations (CEC 2022d). According to the California Annual Retail Fuel Outlet Report Results (CEC-A15), retail gasoline sales in Napa County totaled approximately 47 million gallons, and retail diesel sales totaled approximately 6 million gallons in 2021 (CEC 2022d). As shown in Table 4.6-1, average per capita gasoline consumption in the County is approximately 342 gallons and average per capita diesel consumption in the County is approximately 44 gallons.

Table 4.6-1 Napa County 2021 Gasoline and Diesel Consumption Fuel Type
County Consumption
(gallons per year)
County
Population (2021)
County Per Capita
Consumption (gallons)
Gasoline 47,000,000 137,518 342
Diesel 6,000,000 137,518 44
Sources: DOF 2022; CEC 2022d

4.6.2 Regulatory Setting
Additional regulatory information related to energy efficiency standards is included throughout the other resource sections including Section 4.17, Utilities and Service Systems; Section 4.3, Air Quality; and Section 4.8, Greenhouse Gas Emissions.
a. Federal Regulations
Energy Policy and Conservation Act
Enacted in 1975, the Energy Policy and Conservation Act legislation established fuel economy standards for new light-duty vehicles (autos, pickups, vans, and sport-utility vehicles). The law placed responsibility on the National Highway Traffic and Safety Administration (NHTSA), a part of the U.S. Department of Transportation (USDOT), for establishing and regularly updating vehicle standards. The U.S. Environmental Protection Agency (USEPA) administers the Corporate Average Fuel Economy (CAFE) program, which determines vehicle manufacturers’ compliance with existing fuel economy standards. Since the inception of the program, the average fuel economy for new light-duty vehicles steadily increased from 13.1 miles per gallon (mpg) for the 1975 model year to

30.7 mpg for the 2014 model year, and may increase to 54.5 mpg by 2025.

On August 2, 2018, the NHTSA and USEPA, operating under the direction of the Trump Administration, proposed the Safer Affordable Fuel-Efficient Vehicles Rule (SAFE Rule). This rule addresses emissions and fuel economy standards for motor vehicles and is separated in two parts as described below.
 Part One, “One National Program” (84 Feder Register 51310) revokes a waiver granted by USEPA to the State of California under Section 209 of the Clean Air Act to enforce more stringent emission standards for motor vehicles than those required by USEPA for the explicit purpose of greenhouse gas (GHG) emission reduction, and indirectly, criteria air pollutants and ozone precursor emission reduction. This revocation became effective on November 26, 2019, potentially restricting the ability of the California Air Resources Board (CARB) to enforce more stringent GHG emission standards for new vehicles and set zero emission vehicle mandates in California.
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 Part Two addresses CAFE standards for passenger cars and light trucks for model years 2021 to 2026. This rulemaking proposes new CAFE standards for model years 2022 through 2026 and would amend existing CAFE standards for model year 2021. The proposal would retain the model year 2020 standards (specifically, the footprint target curves for passenger cars and light trucks) through model year 2026. The proposal addressing CAFE standards was jointly developed by NHTSA and USEPA, with USEPA simultaneously proposing tailpipe carbon dioxide standards for the same vehicles covered by the same model years.

The USEPA and NTHSA published final rules to amend and establish national carbon dioxide and fuel economy standards on April 30, 2020 (Part Two of the SAFE Vehicles Rule) (85 Federal Register 24174). On April 22, 2021, the Biden Administration formally proposed to roll back portions of the SAFE Rule, thereby restoring California’s right to enforce more stringent fuel efficiency standards (NHTSA 2022). Most recently, on December 21, 2021, the NHTSA finalized rules to repeal the SAFE I Rule. The final rule concludes the SAFE I Rule overstepped the agency’s legal authority and established overly broad prohibitions that did not account for a variety of important state and local interests. The final rule ensures the SAFE I Rule will no longer form an improper barrier to states exploring creative solutions to address their local communities’ environmental and public health challenges (NHTSA 2022).

Construction Equipment Fuel Efficiency Standard
USEPA sets emission standards for construction equipment. The first federal standards (Tier 1) were adopted in 1994 for all off-road engines over 50 horsepower (hp) and were phased in by 2000. A new standard was adopted in 1998 that introduced Tier 1 for all equipment below 50 hp and established the Tier 2 and Tier 3 standards. The Tier 2 and Tier 3 standards were phased in by 2008 for all equipment. The current iteration of emissions standards for construction equipment are the Tier 4 efficiency requirements, which are contained in 40 Code of Federal Regulations Parts 1039, 1065, and 1068 (originally adopted in 69 Federal Register 38958 [June 29, 2004] and most recently updated in 2014 [79 Federal Register 46356]). Emissions requirements for new off-road Tier 4 vehicles were completely phased in by the end of 2015.

Energy Independence and Security Act
The Energy Independence and Security Act of 2007 was designed to improve vehicle fuel economy and help reduce nationwide dependence on foreign oil. It expands the production of renewable fuels, reducing dependence on oil, and confronting global climate change. Specifically, it increases the supply of alternative fuel sources by setting a mandatory Renewable Fuel Standard, requiring fuel producers to use at least 36 billion gallons of biofuel in 2022, and reduces U.S. demand for oil by setting a national fuel economy standard of 35 mpg by 2020. The Act also set energy efficiency standards for lighting (specifically light bulbs) and appliances. The project would be required to install photosensors and energy-efficient lighting fixtures with the requirements of 42 United States Code Section 17001 et seq.

U.S. Executive Order 13693 (Energy Independence and Security Act Expansion)
In March 2015, Executive Order 13693 Planning for Federal Sustainability in the Next Decade was signed into action. The goal of this Executive Order is to expand on the Energy Independence and 382
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Security Act of 2007 and maintain federal leadership in sustainability and GHG emission reductions.

The Executive Order includes the following goals related to energy:
 25 percent reduction in energy use intensity (as compared to 2015 baseline)  30 percent of electricity supply from renewable energy by 2025  25 percent of total building energy (electric and alternative energy) from renewable energy by 2025
Energy Star Program
In 1992, the USEPA introduced Energy Star© as a voluntary labeling program designed to identify and promote energy-efficient products to reduce GHG emissions. The program applies to major household appliances, lighting, computers, and building components such as windows, doors, roofs, and heating and cooling systems. Under this program, appliances that meet specification for maximum energy use established under the program are certified to display the Energy Star© label.

In 1996, the USEPA joined with the United State Department of Energy to expand the program, which now also includes qualifying commercial and industrial buildings as well as homes. b. State Regulations
Additional State Regulations related to energy are provided in Section 4.8, Greenhouse Gas Emissions.

California Energy Action Plan
The CEC, in collaboration with CPUC, is responsible for preparing the California Energy Action Plan, which identifies emerging trends related to energy supply, demand, conservation, public health and safety, and maintenance of a healthy economy. The 2003 Energy Action Plan calls for the State to assist in transformation of the transportation system to improve air quality, reduce congestion, and increase efficient use of fuel supplies with the least environmental and energy costs. The Energy Action Plan identifies strategies, such as assistance to public agencies and fleet operators in implementing incentive programs for zero-emission vehicles and addressing their infrastructure needs, and encourages urban designs that reduce VMT and accommodate pedestrian and bicycle access. In the 2005 Energy Action Plan, the CEC and CPUC updated the energy policy vision by adding dimensions to the policy areas, such as information on the emerging importance of climate change, transportation-related energy issues, and research and development activities. The CEC adopted an update to the 2005 Energy Action Plan in 2008 that supplements the earlier Energy Action Plans and examines the State’s ongoing actions in the context of global climate change.

AB 1279 and 2022 Scoping Plan
AB 1279, “The California Climate Crisis Act,” was passed on September 16, 2022, and declares the State would achieve net zero GHG emissions as soon as possible, but no later than 2045, and to achieve and maintain net negative greenhouse gas emissions thereafter. In addition, the bill states that the State would reduce GHG emissions by 85 percent below 1990 levels no later than 2045. The 2022 Scoping Plan lays out a path to achieve AB 1279 targets (CARB 2022). The actions and outcomes in the 2022 Scoping Plan would achieve significant reductions in fossil fuel combustion by deploying clean technologies and fuels, further reductions in short-lived climate pollutants, support for sustainable development, increased action on natural and working lands to reduce emissions and sequester carbon, and the capture and storage of carbon. 383
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Senate Bills 350, 100, and 1020
The Clean Energy and Pollution Reduction Act of 2015 (Senate Bill [SB] 350) requires the amount of electricity generated and sold to retail customers per year from eligible renewable energy resources to be increased to 50 percent by December 31, 2030. This act also requires doubling of the energy efficiency in existing buildings by 2030.

Adopted on September 10, 2018, SB 100 supports the reduction of GHG emissions from the electricity sector by accelerating the State’s Renewables Portfolio Standard Program (last updated by SB 350). SB 100 requires electricity providers to increase procurement from eligible renewable energy resources to 33 percent of total retail sales by 2020, 44 percent by 2024, 60 percent by 2030, and 100 percent by 2045.

Senate Bill 1020 (SB 1020), signed into law on September 16, 2022, requires renewable energy and zero-carbon resources to supply 90 percent of all retail electricity sales by 2035, 95 percent by 2040, and 100 percent by 2045. All State agencies facilities must be served by 100 percent renewable and zero-carbon resources by 2030. SB 1020 also requires the CPUC, CEC, and CARB to issue a joint progress report outlining the reliability of the electrical grid with a focus on summer reliability and challenges and gaps. Additionally, SB 1020 requires the CPUC to define energy affordability and use energy affordability metrics to develop protections, incentives, discounts, or new programs for residential customers facing hardships due to energy or gas bills.

Assembly Bill 1007
Assembly Bill 1007 (Chapter 371, Statutes of 2005) required the CEC to prepare a State plan to increase the use of alternative fuels in California. The CEC prepared the State Alternative Fuels Plan (SAF Plan) in partnership with CARB and in consultation with other federal, state, and local agencies.

The SAF Plan presents strategies and actions California must take to increase the use of alternative non-petroleum fuels in a manner that minimizes costs to California and maximizes the economic benefits of in-state production. The SAF Plan assessed various alternative fuels and developed fuel portfolios to meet California’s goals to reduce petroleum consumption, increase alternative fuels use, reduce GHG emissions, and increase in-state production of biofuels without causing a significant degradation of public health and environmental quality. c. Local Regulations
City of American Canyon Energy Efficiency Climate Action Plan The City of American Canyon Energy Efficiency Climate Action Plan (EECAP) was adopted to develop a coordinated approach to energy efficiency and GHG reductions within the community and local government. The EECAP provides feasible strategies and measures that cost-effectively reduce energy related and GHG emissions. The following strategies and measures would be relevant to future development facilitated by the project:
 Community Strategy 3. New Development – Non-residential: Ensure new development exceeds California’s Title 24 energy efficiency standard by 15 percent or more.  Measure C-6: Savings By Design for New Non-Residential Construction. Savings By Design is a statewide program offered by PG&E to encourage high-performance new building design and construction for commercial buildings. The program offers building owners and their design teams a wide range of services, such as Design Assistance, Design Team Incentives, 384
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Owner Incentives, and educational resources such as Energy Design Resources (EDR) and Zero Net Energy.
 Community Strategy 6. Renewable Energy: Increase the number of distributed renewable energy installations on residential and Non-Residential properties to 3 new non-residential sites/year and 15 residential sites/year by 2020.
 Measure C-11: Solar Ready Roofs for New Construction. For all new construction starting in 2014, building roofs must be constructed to readily accommodate the installation of installation of solar PV panels and solar water heating systems, including all necessary conduit, chases, roof penetrations, roof pitch, and roof orientation.

City of American Canyon General Plan
The current City of American Canyon General Plan contains the following objectives and policies that help address energy use at the local level and improve energy efficiency and conservation:

Objective 8.22: Minimize transportation-related energy consumption.

Policy 8.22.1: Encourage the development of mixed use, pedestrian friendly employment/ residential centers that help minimize vehicle trips in American Canyon and contribute to a reduction in energy consumption.

Policy 8.22.2: Encourage the clustering of residential structures.

Policy 8.22.3: Require that Development Plans provide for linkages between bicycle and pedestrian circulation systems and transit and employment centers, in accordance with established areawide plans.

Policy 8.22.4: Maintain a system of traffic signals and controls that minimizes waiting time and vehicle speed changes through routes.

Policy 8.22.5: Require that Development Plans provide for High-Occupancy Vehicles (HOV) and public transportation, where feasible, through the provision of appropriate transit areas and park-and-ride locations along public transportation routes.

Objective 8.23: Reduce Energy consumption in buildings.

Policy 8.23.1: Require that developers employ energy-efficient subdivision and site planning methods as well as building design. Measures to be considered include building orientation and shading, landscaping, building reflectance, use of active and passive solar heating and hot water system, etc. In establishing these energy related design requirements, the City shall balance energy-efficient design with good planning principles.

Policy 8.23.2: Require that new City buildings be energy efficient.

Objective 8.24: Increase public awareness of energy conservation needs and means in order to encourage informed choices about energy conservation by the general public.

Policy 8.24.1: Cooperate with local utilities to provide energy conservation information to the public.

Policy 8.24.2: Develop public and/or public-private energy conservation educational programs for City employees and the public.
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Objective 8.25: Increase the energy efficiency of City operations to save energy, reduce municipal costs, and provide an example to the private sector.

Policy 8.25.1: Introduce concepts of energy efficiency and lifecycle costing to City planning and operating decisions and to the design of all major City facilities.

Policy 8.25.2: Work with other agencies and utility companies to develop safe, economical and renewable energy resources.

Policy 8.25.3: Consider participating in energy conservation demonstration projects and promoting the use of treatment technologies that provide for the reuse of waste and water treatment by products, such as sludge and methane gas.

4.6.3 Impact Analysis
a. Significance Thresholds and Methodology
Significance Thresholds
Based on Appendix G of the CEQA Guidelines a project may be deemed to have a significant impact on energy if it would:

Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? Conflict with or obstruct a state or local plan for renewable energy or energy efficiency? Methodology
The approach to analyzing energy impacts is based on Public Resources Code Section 21100(b)(3), which states an EIR shall include “mitigation measures proposed to minimize significant effects on the environment, including, but not limited to, measures to reduce the wasteful, inefficient, and unnecessary consumption of energy.” Guidance for implementing this section is provided in CEQA Guidelines Appendix F (Energy Conservation). CEQA Guidelines Section 15126.2(b) further explains, “This [energy] analysis may be included in related analyses of air quality, GHG emissions, transportation or utilities in the discretion of the lead agency.” Consistent with that approach, additional discussion of the physical environmental impacts associated with production of energy is also included in the other resource chapters of this EIR included but not limited to Section 4.3, Air Quality, Section 4.8, Greenhouse Gas Emissions, Section 4.15, Transportation, and Section 4.17, Utilities and Service Systems.

Energy consumption is analyzed herein in terms of construction and operational energy.

Construction energy demand accounts for anticipated energy consumption during construction of development facilitated by the project or the Newell Drive Extension, such as fuel consumed by construction equipment and construction workers’ vehicles traveling to and from the construction site. Operational energy demand accounts for the anticipated energy consumption during operation of the development facilitated by the project, such as fuel consumed by cars, trucks, and public transit; natural gas consumed for on-site power generation and heating building spaces; and electricity consumed for building power needs, including, but not limited to lighting, water conveyance, and air conditioning. This analysis considers the equipment and processes employed during construction and operation of future project development to qualitatively determine whether energy consumed during construction and operation would be wasteful, inefficient, or unnecessary.
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a. Project Impacts and Mitigation Measures
Threshold 1: Would the project result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Impact E-1 THE PROJECT WOULD NOT RESULT IN THE WASTEFUL, INEFFICIENT, OR UNNECESSARY CONSUMPTION OF ENERGY AND IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Construction
Project construction would require demolition, including hauling material off-site; site preparation and grading; pavement and asphalt installation; building construction; architectural coating; and landscaping and hardscaping. During project construction, energy would be consumed in the form of petroleum-based fuels used to power off-road construction vehicles and equipment, construction worker travel to and from the construction site, and vehicles used to deliver materials to the site.

Energy use during construction would be temporary in nature, and construction equipment used would be typical of similar-sized construction projects in the region. In addition, construction contractors would be required to comply with the provisions of California Code of Regulations Title 13 Sections 2449 and 2485, which prohibit diesel-fueled commercial motor vehicles and offroad diesel vehicles from idling for more than five minutes and would minimize unnecessary fuel consumption. Construction equipment would be subject to the USEPA Construction Equipment Fuel Efficiency Standard, which would also minimize inefficient, wasteful, or unnecessary fuel consumption. Furthermore, pursuant to applicable regulatory requirements such as 2022 CALGreen, the project would comply with construction waste management practices to divert a minimum of 65 percent of construction debris. These practices would result in efficient use of energy necessary to construct the project. In the interest of cost-efficiency, construction contractors also would not utilize fuel in a manner that is wasteful or unnecessary.

On-site construction equipment may include alternatively fueled vehicles where feasible.

Furthermore, the selected construction contractors would use the best available engineering techniques, construction and design practices, and equipment operating procedures, thereby ensuring that the wasteful consumption of fuels and use of energy would not occur. Energy efficiency is also expected for the off-site production of construction materials, based on the economic incentive for efficiency and cost savings. Furthermore, such construction energy expenditures are necessary to implement the project and meet the project objectives. Therefore, project construction would not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, and impacts would be less than significant.

Operations
Operations of the project would contribute to regional energy demand by consuming electricity, gasoline, diesel, and potentially natural gas. Electricity would be used for lighting, appliances, and water and wastewater conveyance, among other purposes. Gasoline and diesel consumption would be associated with vehicle trips generated by visitors and employees of future development. Natural gas could be utilized for heating and cooling systems, and other purposes; however, it is not certain at this time whether natural gas would be used.
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The project would be required to comply with all standards set in the latest iteration of the California Building Standards Code (California Code of Regulations Title 24), which would minimize the wasteful, inefficient, or unnecessary consumption of energy resources by the buildings during operation. California’s CALGreen standards (California Code of Regulations Title 24, Part 11) require implementation of energy-efficient light fixtures and building materials into the design of new construction projects. In addition, the 2022 Building Energy Efficiency Standards (California Code of Regulations Title 24, Part 6) require newly constructed buildings to meet energy performance standards set by the CEC. These standards are specifically crafted for new buildings to result in energy efficient performance so that the buildings do not result in wasteful, inefficient, or unnecessary consumption of energy. Pursuant to CALGreen, all plumbing fixtures used in future developments facilitated by the project would be high-efficiency fixtures, which would minimize the potential for the inefficient or wasteful consumption of energy related to water and wastewater.

Furthermore, as discussed in Section 4.15, Transportation, the project would result in a less than significant VMT impact. Therefore, project operation would not result in potentially significant environmental effects due to the wasteful, inefficient, or unnecessary consumption of energy, and impacts would be less than significant.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

Threshold 2: Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Impact E-2 THE PROJECT WOULD NOT CONFLICT WITH OR OBSTRUCT A STATE OR LOCAL PLAN FOR

RENEWABLE ENERGY OR ENERGY EFFICIENCY BECAUSE THE PROJECT WOULD REQUIRE MITIGATION MEASURES THAT REQUIRE ADVANCED ENERGY EFFICIENCY AND THE USE OF CARBON-FREE ELECTRICITY SOURCES.

THEREFORE, IMPACTS WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION.

The building design standards pursuant to the CALGreen Code are required for new buildings and are specifically crafted for new buildings to result in energy-efficient performance, so the buildings do not result in inefficient consumption of energy. The standards are updated every three years, and each iteration is more energy efficient than the previous standards. For example, according to the CEC, nonresidential buildings built with the 2019 standards used about 30 percent less energy than buildings built with the 2016 standards due mainly to lighting upgrades (CEC 2021). The project would comply with Tier 2 advanced energy efficiency requirements of the Nonresidential Voluntary Measures of the CALGreen Code, as required by Mitigation Measure GHG-4 (see Section 4.8, Greenhouse Gas Emissions).

SB 100 mandates 100 percent clean electricity for California by 2045. Mitigation Measure GHG-5 requires new buildings to be supplied with 100 percent carbon-free electricity sources through the year 2045 with on-site photovoltaic solar (see Section 4.8, Greenhouse Gas Emissions).

Overall, implementation of Mitigation Measures GHG-4 and GHG-5 would ensure that any potentially significant impacts related to consistency with applicable state and local plans for increased energy efficiency and renewable energy use would be less than significant with mitigation.
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Mitigation Measures
Mitigation Measures GHG-4 and GHG-5 (see Section 4.8, Greenhouse Gas Emissions).

Significance After Mitigation
Impacts would be less than significant with mitigation.

4.6.4 Cumulative Impacts
The geographic scope for cumulative energy impacts is the entirety of California. Cumulative projects would be required to comply with the same regulations as the project to ensure that there is no wasteful, inefficient, or unnecessary consumption of energy or conflicts with state and local plans for increased energy efficiency and renewable energy use. 389
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4.7 Geology and Soils
This section analyzes the potential effects related to seismic hazards, underlying soil characteristics, slope stability, erosion, and paleontological resources related to implementation of the project.

4.7.1 Setting
a. Regional Geology
The City of American Canyon is in Napa County, which is located within the California Coast Range geomorphic province. This province is a geologically complex and seismically active region characterized by sub‐parallel northwest‐trending geological faults, mountain ranges, and valleys, with different bedrock and sedimentary units. The oldest bedrock units are the Jurassic‐Crustaceous Franciscan Complex and Great Valley sequence sediments originally deposited in a marine environment. Subsequently, younger rocks such as the Tertiary‐period Sonoma Volcanics group, the Plio‐Pleistocene‐age Clear Lake Volcanics, and sedimentary rocks such as the Guinda, Domengine, Petaluma, Wilson Grove, Cache, Huichica, and Glen Ellen formations were deposited throughout the province. Extensive folding and thrust faulting during the late Crustaceous through early Tertiary geologic time created complex geologic conditions that underlie the highly varied topography that exists today. In valleys, the bedrock is covered by thick alluvial soils (Napa County 2007). b. Local Geologic Setting
Soils
According to the US Department of Agriculture, Natural Resources Conservation Service (NRCS), two soils comprise the project site. Most of the soils are Clear Lake clay and a portion of the soils in the center of project site along with a small portion at the north is Haire loam. These are native soil types and do not account for placement of engineered fill, which is not always mapped or known by the NRCS.

Seismic Hazards
The City of American Canyon is subject to risks associated with potentially destructive earthquakes, like much of California. Earthquakes are most common along geologic faults, which are planes of weakness or fractures along which rocks have been displaced. The project site is near active faults, such as the Cuttings Wharf fault (approximately 0.3 mile west), West Napa fault (approximately 5.2 miles northwest), and Cordelia and Green Valley faults (approximately 5.4 miles east) (DOC 2021).

Regional hazards with respect to earthquakes are considered significant due to the City's proximity to major faults in the area (e.g., San Andreas and Hayward) and the project site’s proximity to minor faults listed above.

The probability of one or more earthquakes of magnitude 6.7 (Richter scale) or higher occurring in the San Francisco Bay Area has been evaluated by the U.S. Geological Survey (USGS). Based on the results of the USGS evaluation, there is a 63‐percent likelihood that such an earthquake event will occur in the Bay Area between 2007 and 2036. The faults with the greater probability of movement with a magnitude of 6.7 or higher earthquake are the Hayward Fault at 27 percent, the San Andreas Fault at 21 percent, and the Calaveras Fault at 11 percent (USGS 2007). 391
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Surface Rupture
Surface rupture represents the breakage of ground along the surface trace of a fault, which is caused by the intersection of the fault surface area ruptured in an earthquake with the earth's surface. Fault displacement occurs when material on one side of a fault moves relative to the material on the other side of the fault. This can have particularly adverse consequences when buildings are located within the rupture zone. It is not feasible from a structural or economic perspective to design and build structures that can accommodate rapid displacement involved with surface rupture. Amounts of surface displacement can range from a few inches to tens of feet during a rupture event.

Faults are geologic hazards because of surface fault displacement and seismic ground shaking, which are distinct but related properties. Surface fault displacement results when the fault plane ruptures and that rupture surface extends to or intersects the ground surface. Surface fault rupture can be very destructive to structures constructed across active faults. However, the zone of damage is limited to a relatively narrow area along either side of the fault as opposed to seismic ground shaking damage that can be widespread. Faults are categorized as active, potentially active, and inactive. A fault is classified as active if it has moved during the Holocene time, which consists of approximately the last 11,000 years. A fault is classified as potentially active if it has experienced movement within Quaternary time, which is during the last 1.8 million years. Faults that have not moved in the last 1.8 million years are generally considered inactive.

The closest faults are described above under the Seismic Hazards subheading. Figure 4.7-1 shows the project site in relation to nearby Quaternary faults. There are no Holocene faults or AlquistPriolo Fault Zones in or near the project site.

Regional Faults
San Andreas Fault Zone
The San Andreas is the longest, most active fault in California. It is a right -lateral, strike -slip fault that extends over 700 miles (1,120 km) from the Gulf of California to Cape Mendocino in northern California. There is abundant seismic and geomorphic evidence of earthquake and fault rupture potential. Historically, the San Andreas fault has produced earthquakes more than magnitude 8. The fault can be divided into several discrete segments along its length based on differing seismic characteristics. The fault segment which influences the seismic exposure of the project site is referred to as the San Andreas (northern) segment (from Point Arena to Woodside). The creeping segment extends to the south, from Woodside to the Mojave segment of the fault. The San Andreas fault (northern) is located approximately 28 miles to the west of the project site, and the creeping segment about 89 miles to the south- southeast (City of American Canyon 1994).

Hayward Fault Zone
The Hayward fault extends from San Jose (south) to the San Pablo Bay (north). The fault is about 45 miles in length and is capable of a magnitude 7.5 earthquake. Active tight lateral creep is occurring on the Hayward fault. The Hayward fault is approximately 10 miles south of the project site (City of American Canyon 1994).
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Figure 4.7-1 Fault Zones
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Healdsburg Rodgers Creek Fault Zone
The Rodgers Creek fault trends approximately parallel to and lies about 20 miles east of the San Andreas (northern) fault. Rodgers Creek possess sag ponds, offset streams, and hillside bench features, similar to the San Andreas fault. Researcher have determined that this active fault is linked to the Healdsburg and Wallace Creek faults. The epicenter of Santa Rosa’s 1969 earthquake was located on the Healdsburg fault. The earthquake had recorded magnitudes of 5.6 and 5.7. The Rodgers Creek fault is located approximately 10 miles to the west of the project site (City of American Canyon 1994).

Local Faults
West Napa Fault
The West Napa fault zone extends from approximately 5 miles north of the center of the City for 15 miles, to near Yountville. The West Napa fault is identified as an active fault and as an Alquist Priolo Special Study zone, from the Napa County Airport, along the east side of Oat Hill southeast to near the City boundary. The West Napa fault possesses evidence of strike-slip and right lateral fault movement. It is well defined south and east of the Napa River, by tonal contrasts and geomorphic features in the Holocene alluvium. Trenching studies have shown some evidence of Holocene activity from the airport and other sites. The fault appears capable of providing a 6.5 magnitude earthquake event (City of American Canyon 1994).

Cordelia and Green Valley Faults
The Cordelia and Green Valley faults trend north approximately 5 miles east of the project site and displays geomorphic evidence of recent fault movement, as well as earthquake concentrations.

Evidence of recent and bedrock geologic features indicate that the Green Valley fault possesses steeply dipping right lateral fault features. These faults can produce a 6.75 to 7 magnitude earthquakes (City of American Canyon 1994).

Recent Seismic Hazards
Napa County has been subject to numerous seismic events, originating both on faults within the county and in other parts of the region. Six major Bay Area earthquakes have occurred since 1800 that have affected the county, and at least two of the faults that produced them run through or into the county. These earthquakes and the originating faults include the 1836 and 1868 earthquakes on the Hayward-Rogers Creek Fault, and the 1861 earthquake on the Calaveras Fault. Three earthquakes in 1838, 1906, and 1989 originated on the San Andreas fault, west of the county near San Francisco or to the south.

The South Napa Earthquake of 2014 occurred on August 24 at 3:30 am. The earthquake had a magnitude of 6, which is generally a fairly substantial magnitude for an earthquake, with the largest earthquakes in the world reaching up to a magnitude of 9. The South Napa earthquake resulted in various aftershocks of lower magnitudes for the next couple of months. This earthquake occurred on the West Napa Fault Zone. It also had recordings of subparallel fault traces. The West Napa Fault Zone’s slip rate is believed to be approximately 0.2 millimeter to 1 millimeter per year, which is considered low for a slip rate. The slip rate refers to the rate at which the two faults are moving past one another. As for the South Napa earthquake, the slip is believed to be at a maximum of 1 meter.

The depth of the South Napa earthquake was approximately 9.8 kilometers. The earthquake also caused 12.5 kilometers of surface rupture. According to the United States Geological Survey, the 394
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2014 earthquake occurred because there was a rupture of a few of the small segments at the same time (UC Berkeley 2022).

The Yountville earthquake of 2000 that also occurred on the West Napa Fault Zone had a magnitude of 5. Unlike the South Napa Earthquake, the Yountville earthquake, which happened approximately 18 miles northwest of the project site did not rupture the surface (UC Berkeley 2022).

Ground Shaking
The major cause of structural damage from earthquakes is ground shaking. The intensity of ground motion expected at a particular site depends upon the magnitude of the earthquake, the distance to the epicenter, and the geology of the area between the epicenter and the property. Greater movement can be expected at sites located on poorly consolidated material such as alluvium, within close proximity to the ruptured fault, or in response to a seismic event of great magnitude.

Historically, the City of American Canyon has been impacted by ground shaking during major earthquakes in the seismically active Northern California region and is likely to experience ground shaking from major earthquakes in the future.

Liquefaction
Liquefaction is a seismic phenomenon in which loose, saturated granular and non-plastic finegrained soils lose their structure/strength when subjected to high-intensity ground shaking.

Liquefaction occurs when three general conditions exist: 1) shallow groundwater within the top 50 feet of the ground surface; 2) low-density non-plastic soils; and 3) high-intensity ground motion.

Liquefaction risk is moderate in the project site, as shown in Figure 4.7-2.

Landslides and Slope Stability
Seismic ground shaking can also result in landslides and other slope instability issues. Landslides occur when slopes become unstable, and masses of earth material move downslope. Landslides are usually rapid events, often triggered during periods of rainfall or by earthquakes. Mudslides and slumps are a shallower type of slope failure. They typically affect the upper surficial soils horizons rather than bedrock features. Usually, mudslides and slumps occur during or soon after periods of rainfall, but they can be triggered by seismic shaking. The area’s most susceptible to landslides are shown on maps prepared by the California Division of Mines and Geology. Landslide susceptibility is grouped into classes ranging from zero to ten, which are calculated based upon a combination of rock strength and slope. Classes seven through ten indicate very high landslide susceptibility and include both very steep slopes in hard rocks and moderate to very steep slopes in weak rocks (CGS 2011). In addition, landslides occur where faults have fractured rock and along the base of slopes or cliffs where supporting material has been removed by stream or wave erosion, or human activities.

Heavy rainfall, human actions, or earthquakes can trigger landslides. They may take the form of a slow continuous movement such as a slump or may move very rapidly as a semi-liquid mass such as a debris flow or avalanche. As shown in Figure 4.7-3 there is scattered landslide susceptibility in the eastern and southern portions of the project site.
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Figure 4.7-2 Liquefaction Risk
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Figure 4.7-3 Landslide Zones1
1 Note: Landslide susceptibility would be confirmed as part of the Geotechnical Report that will be developed for future development. As described in further detail in Impact GEO-2, a geotechnical report would be required by Mitigation Measure GEO-1. 397
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Subsidence
Subsidence or settlement can occur from immediate settlement, consolidation, shrinkage of expansive soil, and liquefaction. Immediate settlement occurs when a load from a structure or placement of new fill material is applied, causing distortion in the underlying materials. This settlement occurs quickly and is typically complete after placement of the final load. Consolidation settlement occurs in saturated clay from the volume change caused by squeezing out water from the pore spaces. Consolidation occurs over a period and is followed by secondary compression, which is a continued change in void ratio (ratio of the volume of voids to volume of solids) under the continued application of the load. Soils tend to settle at different rates and by varying amounts depending on the load weight or changes in properties over an area, which is referred to as differential settlement. Areas underlain by soft sediments or undocumented fills are most prone to settlement.

Expansive Soils
Expansive soils swell with increases in moisture content and shrink with decreases in moisture content. These soils usually contain high clay content. Foundations for structures constructed on expansive soils require special design considerations. Because expansive soils can expand when wet and shrink when dry, they can cause foundations, basement walls, and floors to crack, causing substantial structural damage. As such, structural failure due to expansive soils near the ground surface is a potential hazard. Expansive soils can be found throughout the project site.

Soil Erosion
Erosion refers to the removal of soil by water or wind. Factors that influence erosion include the amount of rainfall and wind, the length and steepness of the slope, and the amount and type of vegetative cover. Depending on how well protected the soil is from these forces, the erosion process can be very slow or rapid. Properties of the soil also contribute to how likely or unlikely it is to erode. Removal of natural or man-made protection can result in substantial soil erosion and excessive sedimentation and pollution problems in streams, lakes, and estuaries through a process called siltation.

Paleontological Resources
Paleontological resources, or fossils, are the evidence of once-living organisms preserved in the rock record. They include both the fossilized remains of ancient plants and animals and the traces thereof (e.g., trackways, imprints, burrows, etc.). Paleontological resources are not found in “soil” but are contained within the geologic deposits or bedrock that underlies the soil layer. Typically, fossils are greater than 5,000 years old (i.e., older than middle Holocene in age) and are usually preserved in sedimentary rocks. Although rare, fossils can also be preserved in volcanic rocks and low-grade metamorphic rocks under certain conditions (Society of Vertebrate Paleontology [SVP] 2010). Fossils occur in a non-continuous and often unpredictable distribution within some sedimentary units, and the potential for fossils to occur within sedimentary units depends on several factors. It is possible to evaluate the potential for geologic units to contain scientifically important paleontological resources. The geology of the region was mapped at a scale of 1:100,000 by Wagner and Gutierrez (2017), who identified three geologic units underlying the project site:
alluvial fan deposits, San Pablo Group (undivided), and the Jameson Shale Member of the Markley Sandstone (Figure 4.7-4).
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Figure 4.7-4 Geologic Map of the Annexation Area
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According to the SVP (2010) classification system, geologic units can be assigned a high, low, undetermined, or no potential for containing scientifically significant nonrenewable paleontological resources. Following the literature review, a paleontological sensitivity classification was assigned to each geologic unit mapped within the project site. This criterion is based on rock units within which vertebrate or significant invertebrate fossils have been determined by previous studies to be present or likely to be present. Overall, as described in further detail below, all three geologic units underlying the project site have a high paleontological sensitivity.

Alluvial Fan Deposits
Alluvial fan deposits underlie most of the project site (Figure 4.7-4). Alluvial fan deposits consist of relatively undissected surfaces of gravel, sand, silt, and clay, that is Holocene to late Pleistocene in age (Wagner and Gutierrez 2017). Some portions of alluvial fan deposits might be too young (i.e., less than 5,000 years old) to preserve paleontological resources, but early Holocene and late Pleistocene alluvial sediments are old enough to preserve such resources. Pleistocene alluvial sediments have produced significant paleontological resources in the northern San Francisco Bay Area (i.e., Marin, Napa, Solano, and Sonoma Counties), including taxa such as mammoth (Mammuthus), mastodon (Mammut), horse (Equus), bison (Bison), sloth (Paramylodon), rodents (Rodentia), and turtles (Testudines) (Jefferson 2010; Paleobiology Database [PBDB] 2022; Savage 1951; UCMP 2022). Therefore, alluvial fan deposits have high paleontological sensitivity.

San Pablo Group
The San Pablo Group underlies the northern part of the project site (Figure 4.7-4). The San Pablo Group consists of brown, gray, and white, shale, sandstone, and conglomerate that was deposited during the late Miocene in a marine setting (Wagner and Gutierrez 2017). In some areas, the San Pablo Group is split into the Briones Sandstone, Cierbo Sandstone, and Neroly Sandstone. Many significant terrestrial and marine fossils have been discovered from the San Pablo Group and its constituent formations including canids (Osteoborus), horses (Nannippus, Neohipparion, Pliohippus), marine mammals (Desmostylus), rodents, turtles, sharks, and invertebrates (Grant and Stevenson 1948; PBDB 2022; Stirton 1939; UCMP 2022). Given this fossil-producing history, the San Pablo Group has high paleontological sensitivity.

Jameson Shale Member of the Markley Sandstone
The Jameson Shale Member of the Markley Sandstone underlies the northeastern part of the project site (Figure 4.7-4). The Jameson Shale Member of the Markley Sandstone consists of brown, laminated, siliceous mudstone (Wagner and Gutierrez 2017). The Markley Sandstone has produced bony fish (Osteichthyes), gastropod, bivalve, and microfossils from both shale (i.e., Jameson Shale Member) and sandstone beds (Clark 1938; PBDB 2022; UCMP 2022). Given this fossil-producing history, the Jameson Shale Member of the Markley Sandstone has high paleontological sensitivity.

4.7.2 Regulatory Setting
a. Federal Regulations
U.S. Geological Survey Landslide Hazard Program
The USGS created the Landslide Hazard Program in the mid-1970s; the primary objective of the program is to reduce long-term losses from landslide hazards by improving our understanding of the 400
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causes of ground failure and suggesting mitigation strategies. The federal government takes the lead role in funding and conducting this research, whereas the reduction of losses due to geologic hazards is primarily a State and local responsibility. In Napa County, plans and programs designed for the protection of life and property are coordinated by the Napa County Office of Emergency Services.

Clean Water Act
Congress enacted the Clean Water Act (CWA), formerly the Federal Water Pollution Control Act of 1972, with the intent of restoring and maintaining the chemical, physical, and biological integrity of the waters of the United States. The CWA requires states to set standards to protect, maintain, and restore water quality through the regulation of point source and non-point source discharges to surface water. Those discharges are regulated by the National Pollutant Discharge Elimination System (NPDES) permit process (CWA Section 402). NPDES permitting authority is administered by the California State Water Resources Control Board (SWRCB) and its nine Regional Water Quality Control Boards (RWQCB). The City of American Canyon is located within the San Francisco Bay RWQCB jurisdiction.

Projects within the City and Napa County that disturb more than one acre are required to obtain NPDES coverage under the California General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities (Construction General Permit). The Construction General Permit (Order 2009-0009, as amended by Orders 2010-0014-DWQ and 2012-006-DWQ) requires the development and implementation of a Storm Water Pollution Prevention Plan (SWPPP) describing best management practices (BMPs) that the discharger would use to prevent and retain storm water runoff and to prevent soil erosion.

Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act) The Stafford Act (1988) provides the legal basis for state, tribal, and local governments to undertake risk-based approaches to reducing natural hazard risks through mitigation planning. Specifically, the Stafford Act requires state, tribal, and local governments to develop and adopt Federal Emergency Management Agency (FEMA)-approved hazard mitigation plans as a condition for receiving certain types of non-emergency disaster assistance. The Act also authorizes grants for pre- and postdisaster projects and planning.

Disaster Mitigation Act of 2000
Congress passed the Disaster Mitigation Act of 2000 to amend the Robert T. Stafford Disaster Relief and Emergency Assistance Act by invoking new and revitalized approaches to mitigation planning.

Section 322 of the Act emphasized the need for state and local government entities to closely coordinate on mitigation planning activities and makes the development of a hazard mitigation plan a specific eligibility requirement for local governments applying for federal mitigation grant funds.

Communities with an adopted and federally approved hazard mitigation plan thereby become prepositioned and more apt to receive available mitigation funds before and after the next declared disaster.

To implement the new Stafford Act provisions, FEMA published requirements and procedures for local hazard mitigation plans in the Code of Federal Regulations (CFR) at Title 44, Chapter 1, Part 201.6. These regulations specify minimum standards for developing, updating, and submitting local hazard mitigation plans for agency review and approval at least once every five years. 401
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National Historic Preservation Act of 1966 (16 USC 470) The National Historic Preservation Act (NHPA) applies to paleontological resources that are found in culturally related contexts; such related paleontological resources qualify as cultural resources.

Consequently, recovery and treatment protocols included in a project-specific Cultural Resources Management Plan should be followed for discoveries of paleontological resources in culturally related contexts.

Paleontological Resources Preservation Act of 2009
The Paleontological Resources Preservation Act (PRPA) is part of the Omnibus Public Land Management Act of 2009 (PL 111-011 Subtitle D). This act directs the Secretary of the Interior or the Secretary of Agriculture to manage and protect paleontological resources on federal land and to develop plans for inventorying, monitoring, and deriving the scientific and educational use of such resources. It prohibits the removal of paleontological resources from federal land without a permit issued under this act, establishes penalties for violation of this act, and creates a program to increase public awareness about these resources. A paleontological resource use permit is required to collect paleontological resources of scientific interest. The act requires that paleontological resources collected under a permit remain United States property, preserved for the public in an approved repository, and available for scientific research and public education. The act also requires that the nature and location of paleontological resources on public lands remain confidential as a means of protecting the resources from theft and vandalism. Section 6301 of the PRPA and Departmental Proposed Rule at 43 CFR Part 49 define a paleontological resource as:

Any fossilized remains, traces, or imprints of organisms, preserved in or on the earth’s crust, that are of paleontological interest and that provide information about the history of life on earth, except that the term does not include— (A) any materials associated with an archaeological resource… (B) any cultural item… (3) Resources determined in writing by the authorized officer to lack paleontological interest or not provide information about the history of life on earth, based on scientific and other management considerations.

Consistent with the definition of a paleontological resource under the PRPA, those paleontological resources that lack scientific interest (e.g., resources that are ubiquitous or do not provide information about the history of life on earth) are considered scientifically non-significant fossils. b. State Regulations
California Building Code
The California Building Code (CBC), Title 24, Part 2 provides building codes and standards for the design and construction of structures in California. The 2016 CBC is based on the 2015 International Building Code, with the addition of more extensive structural seismic provisions. Chapter 16 of the CBC contains definitions of seismic sources and the procedure used to calculate seismic forces on structures. The CBC requires addressing soil-related hazards, such as treating hazardous soil conditions involving removal, proper fill selection, and compaction. In cases where soil remediation is not feasible, the CBC requires structural reinforcement of foundations to resist the forces of expansive soils. The CBC includes requirements for geotechnical investigations (such as inclusion of a soil report), excavation, grading, and fills, load-bearing of soils, as well as foundations, shallow foundations, and deep foundations (Chapter 18). Chapter 18 also describes analysis of expansive 402
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soils, including conducting soil tests in areas likely to contain expansive soils. Soils are considered expansive if either items one through three are met or item four is met:

Plasticity index (PI) of 15 or greater, determined in accordance with ASTM D 4318; More than 10 percent of the soil particles pass a No. 200 sieve (75 micrometers), determined in accordance with ASTM D 422;
More than 10 percent of the soil particles are less than 5 micrometers in size, determined in accordance with ASTM D 422; and
Expansion index greater than 20, determined in accordance with ASTM D 4829.

Alquist-Priolo Earthquake Fault Zoning Act
The Alquist-Priolo Earthquake Fault Zoning Act of 1972 was passed into law following the destructive February 9, 1971 magnitude 6.6 San Fernando earthquake. The Act provides a mechanism for reducing losses from surface fault rupture on a statewide basis. The intent of the Act is to ensure public safety by prohibiting the siting of most structures for human occupancy across traces of active faults that constitute a potential hazard to structures from surface faulting or fault creep. This Act groups faults into categories of active, potentially active, and inactive. Historic and Holocene age faults are considered active, Late Quaternary and Quaternary age faults are considered potentially active, and pre-Quaternary age faults are considered inactive.

The Alquist-Priolo Earthquake Fault Zoning Act regulates development near the surface traces of active faults to mitigate the hazard of surface fault rupture. Essentially, this Act contains two requirements: (1) it prohibits the location of most structures for human occupancy across the trace of active faults; and (2) it establishes Earthquake Fault Zones and requires geologic/seismic studies of most proposed development within 50 feet of the zone. The Earthquake Fault Zones are delineated and defined by the State Geologist and identify areas where potential surface rupture along a fault could occur. According to CGS, there are no Earthquake Fault Zones in the project site (CGS 2022).

Seismic Hazards Mapping Act
The Seismic Hazards Mapping Act (the Act) of 1990 was passed into law following the destructive October 17, 1989, magnitude 6.9 Loma Prieta earthquake. The Act directs the CGS to delineate Seismic Hazard Zones. The purpose of the Act is to reduce the threat to public health and safety and to minimize the loss of life and property by identifying and mitigating seismic hazards, such as liquefaction, landslides, amplified ground shaking, and inundation by tsunami or seiche. Cities, counties, and State agencies are directed to use seismic hazard zone maps developed by CGS in their land-use planning and permitting processes. The Act requires that site-specific geotechnical investigations be performed prior to permitting most urban development projects within seismic hazard zones. CGS maintains these required maps. The project site is not in a CGS-mapped seismic hazard zone.

California Environmental Quality Act – Paleontological Resources Paleontological resources are protected under CEQA, which states in part a project will “normally” have a significant effect on the environment if it, among other things, will disrupt or adversely affect a paleontological site except as part of a scientific study. Specifically, in Section VII(f) of Appendix G of the CEQA Guidelines, the Environmental Checklist Form, the question is posed thus: “Will the project directly or indirectly destroy a unique paleontological resource or site or unique geologic 403
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feature.” To determine the uniqueness of a given paleontological resource, it must first be identified or recovered (i.e., salvaged). Therefore, CEQA mandates mitigation of adverse impacts, to the extent practicable, to paleontological resources.

CEQA does not define “a unique paleontological resource or site.” However, the Society of Vertebrate Paleontology (SVP) has defined a “significant paleontological resource” in the context of environmental review as follows:

Fossils and fossiliferous deposits, here defined as consisting of identifiable vertebrate fossils, large or small, uncommon invertebrate, plant, and trace fossils, and other data that provide taphonomic, taxonomic, phylogenetic, paleoecologic, stratigraphic, and/or biochronologic information. Paleontological resources are typically to be older than recorded human history and/or older than middle Holocene (i.e., older than about 5,000 radiocarbon years) (SVP 2010).

The loss of paleontological resources meeting the criteria outlined above (i.e., a significant paleontological resource) would be a significant impact under CEQA, and the CEQA lead agency is responsible for ensuring that impacts to paleontological resources are mitigated, where practicable, in compliance with CEQA and other applicable statutes.

California Public Resources Code
Section 5097.5 of the Public Resources Code states:

No person shall knowingly and willfully excavate upon, or remove, destroy, injure or deface any historic or prehistoric ruins, burial grounds, archaeological or vertebrate paleontological site, including fossilized footprints, inscriptions made by human agency, or any other archaeological, paleontological or historical feature, situated on public lands, except with the express permission of the public agency having jurisdiction over such lands. Violation of this section is a misdemeanor.

Here “public lands” means those owned by, or under the jurisdiction of, the state or a city, county, district, authority, or public corporation, or an agency thereof. Consequently, public agencies are required to comply with Public Resources Code Section 5097.5 for their own activities, including construction and maintenance, and for permit actions (e.g., encroachment permits) undertaken by others.
c. Local Regulations
Napa County Operational Area Multi-Jurisdictional Hazard Mitigation Plan In 2020, Napa County prepared an updated Multi-Jurisdictional Hazard Mitigation Plan (HMP) to guide County and city officials and special districts managers in protecting the people and property within the County from the effects of natural disasters and hazards events. The HMP provides an explanation of prevalent hazards within the County and how hazards may affect the County and participating cities and special districts differently based upon proximities to natural hazards. The HMP also identifies risks to vulnerable assets, both people and property. Most importantly, the mitigation strategy presented in the HMP responds to the identified vulnerabilities within each community and provides prescriptions or actions to achieve the greatest risk reduction based upon available resources (Napa County 2020).
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American Canyon General Plan
The current City of American Canyon General Plan sets forth the following guiding and implementing policies relevant to geology, soils, and seismicity:

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.

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.

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.

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 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.

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.

Policy 9.1.3: Require that any building intended to have occupancy be located at least 50 feet from either side of an active or potentially active fault.

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.

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

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.

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.

Policy 9.3.2: Require the submittal of liquefaction mitigation plans for proposed developments located in areas determined to have a high level of liquefaction risk.

Policy 9.3.3: Require that natural gas, electric, water, sewer and communication systems located in areas of liquefaction risk be designed to mitigate potential hazards.

Objective 9.4: Protect life, ensure safety, and substantially reduce the potential level of property damage from landslides, mudflows, slope failures and soil hazards. Promote the collection and utilization of more complete information on slope instability potential throughout the City and Planning Area.
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Policy 9.4.1: Require the determination of the landslide, slope, instability, and erosion potential of all proposed development sites with a grade of 10 percent or greater and incorporate pertinent measures in the project design to mitigate this potential.

Policy 9.4.2: Require the determination of liquefaction (lateral spreading) potential for all development sites in coarse and medium-grained alluvium areas (Qhbm, Qham, and Qhac) of slopes with grades of less than 15 percent and incorporate pertinent measures in the project design to mitigate this potential.

Policy 9.4.4: Require an assessment of potential damage to essential lifelines (e.g., gas, water, electric, communication, sewer) due to landslides and implement appropriate mitigation measures.

Policy 9.4.5: Review proposals for new development and expansion of existing development in areas that are susceptible to collapsible or expansive soils and require adequate mitigation of these hazards.

Policy 9.4.6: Require that proposed developments in landslide hazard areas submit information regarding pertinent conditions prepared by a qualified geologist or civil engineer.

Policy 9.4.7: Require that proposed developments in landslide hazard areas submit plans to adequately stabilize slopes and unstable soils onsite and prevent impacts on adjacent properties.

Policy 9.4.8: Encourage the use of landscape materials in areas of landslide hazard and unstable soils that promote stability.

American Canyon Municipal Code
Various portions of the American Canyon Municipal Code also address geologic and soil conditions.

Relevant sections include:
 Chapter 16.02 adopts the 2019 California Building Code. All new construction within the city limits is required to adhere to seismic safety standards. The City of American Canyon Community Development Department is responsible for the administration and enforcement of the Building Code.
 Chapters 16.12.150, 16.12.210, and 16.12.230 provide specifications for slabs, footings, and foundations in areas of highly expansive soils.
 Chapter 16.14.090 requires the preparation of a soil management report to address soil attributes includes identification of thin, eroded, or erosion prone soils.  Chapter 16.14.120 requires preparation of a grading plan designed to minimize soil erosion.  Chapter 18.22.025 requires subdivision maps to include a statement and report on soil tests by a registered engineer and a geological report in areas so determined by the City engineer where there are known geologic hazards.
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4.7.3 Impact Analysis
a. Significance Thresholds and Methodology
Significance Thresholds
Based on Appendix G of the CEQA Guidelines a project may be deemed to have a significant impact on geology and soils if it would:

Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:

Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault;
Strong seismic ground shaking;
Seismic-related ground failure, including liquefaction; Landslides;
Result in substantial soil erosion or the loss of topsoil; Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on or off-site landslide, lateral spreading, subsidence, liquefaction or collapse;
Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirectly risks to life or property; Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater; or Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

Methodology
Impacts to geology and soils was determined by reviewing the existing setting for the project site, as summarized in Section 4.7.1, Setting, and analyzing the project’s potential to result in substantial adverse effects related to geological hazards. The paleontological sensitivity of the geologic units that underlie the project site were evaluated to assess the project’s potential for significant impacts to scientifically important paleontological resources. The analysis was based on the results of a review of existing information in the scientific literature regarding known fossils within geologic units mapped in the annexation area. According to the SVP (2010) classification system, geologic units can be assigned a high, low, undetermined, or no potential for containing scientifically significant nonrenewable paleontological resources. Following the literature review, a paleontological sensitivity classification was assigned to each geologic unit mapped within the project site. This criterion is based on rock units within which vertebrate or significant invertebrate fossils have been determined by previous studies to be present or likely to be present. The analysis of impacts focuses on unspecified future construction that could occur in the project site relative to geologic units because paleontological resources would only be impacted during constructionrelated ground disturbing activities. 407
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b. Project Impacts and Mitigation Measures
Threshold 1a: Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault?
Impact GEO-1 THE PROJECT WOULD NOT BE SUBJECT TO RUPTURE OF A KNOWN EARTHQUAKE FAULT.

THERE WOULD BE NO IMPACT.

As shown in Figure 4.7-1, there are no Alquist Priolo Earthquake Fault Zones in the project site. As such, the project would not directly or indirectly cause substantial adverse effects involving rupture of a known earthquake fault. There would be no impacts related to rupture of a known earthquake fault.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
There would be no impact and no mitigation would be required.

Threshold 1b: Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking? Threshold 1c: Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction?
Threshold 1d: Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides? Impact GEO-2 FOLLOWING PROJECT IMPLEMENTATION, FUTURE STRUCTURES, ROADWAYS, AND

OCCUPANTS COULD BE LOCATED IN AREAS THAT WOULD BE EXPOSED TO SEISMIC EVENTS, INCLUDING GROUND SHAKING, LIQUEFACTION, AND LANDSLIDES, CREATING THE RISK FOR DAMAGE OR INJURY. COMPLIANCE WITH THE CBC, THE CITY’S MUNICIPAL CODE, AND MITIGATION MEASURE GEO-1 WOULD MINIMIZE GROUND SHAKING, LIQUEFACTION, AND LANDSLIDE HAZARDS. IMPACTS WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION.

Future commercial, industrial, and visitor-serving/hotel uses would introduce structures, workers, and visitors to the project site. These structures and people would be potentially exposed to the effects of seismic ground shaking, liquefaction, and landslides from local and regional earthquakes.

Structures built in landslide zones would be exposed to an existing risk of landslide or, if improperly constructed could exacerbate existing landslide conditions, particularly in the areas shown in Figure

4.7-3, which are vulnerable to landslide hazard. New structures throughout the project site would also be exposed to moderate susceptibility risk to liquefaction in the event of a seismic event.

Additionally, the Newell Drive extension would occur in a landslide and liquefaction zone and users could be exposed to the effects of seismic ground shaking. 408
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Future structures and roadways in the project site would follow current seismic standards to better withstand damage from strong ground shaking. Potential structural damage and the exposure of people to the risk of injury or death from structural failure would be minimized by required compliance with CBC engineering design and construction measures. Foundations and other structural support features would be required to be designed to resist or absorb damaging forces from strong ground shaking and liquefaction.

Future grading within the project site would create artificial slopes that could fail during strong seismic shaking if improperly constructed. However, compliance with CBC requirements (as codified in American Canyon Municipal Code Chapter 16.02) requires structures be designed to accommodate ground accelerations expected from known active faults. As required under Chapter 18 of the CBC and Chapter 18.22.025 of the American Canyon Municipal Code, geotechnical investigations prepared by a California registered Geotechnical Engineer or Engineering Geologist would be required for the project site and would include final design parameters for the walls, foundations, foundation slabs, and surrounding related improvements (utilities, roadways, parking lots and sidewalks). A geotechnical investigation would likewise be required for the Newell Drive Extension. The final design level geotechnical report would be reviewed and approved by the City Building Department prior to issuance of a building permit ensuring that seismic design requirements are incorporated into construction specifications.

Further reducing impacts, American Canyon, Municipal Code Chapter 16.14 requires preparation of a soil management plan and grading plan in water-efficient landscaped areas. Compliance with provisions of American Canyon Municipal Code Chapter 16.14 would reduce potential impacts related to seismic hazards ground failure on graded or constructed slopes within landscaped areas.

Furthermore, Mitigation Measure GEO-1 would require the applicant to submit a Geotechnical Investigation to the City of American Canyon for review and approval. Standard soil engineering and building design practices would include standards for foundations and structural support of buildings to ensure that they withstand strong ground shaking during a seismic event and avoid the exacerbation of exposure to such hazards. The implementation of this mitigation measure would ensure that the project is not exposed to strong ground shaking hazards, liquefaction, and landslides, and would reduce potentially significant impacts to a less than significant level.

Mitigation Measure
GEO-1 Geotechnical Investigation
Prior to the issuance of improvement plans and building permits, the project applicant shall submit a design-level Geotechnical Investigation to the City of American Canyon for review and approval.

The investigation shall be prepared by a qualified engineer and identify grading and building practices necessary to achieve compliance with the latest adopted edition of the California Building Standards Code (CBC) geologic, soils, and seismic requirements, including abatement of expansive soil conditions. The report shall also determine the final design parameters for walls, foundations, foundation slabs, and surrounding related improvements (e.g., utilities roadways, parking lots, and sidewalks). The measures identified in the approved report shall be incorporated into the project plans and all applicable construction related permits.
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Significance After Mitigation
Implementation of Mitigation Measure GEO-1 would reduce impacts related to strong seismic ground shaking, liquefaction, and landslides. With implementation of Mitigation Measure GEO-1, impacts would be less than significant.

Threshold 2: Would the project result in substantial soil erosion or the loss of topsoil? Impact GEO-3 THE PROJECT COULD RESULT IN SOIL EROSION OR THE LOSS OF TOPSOIL. ADHERENCE TO PERMIT REQUIREMENTS AND MITIGATION MEASURE HYD-1 WOULD REDUCE THIS IMPACT TO A LESS THAN SIGNIFICANT LEVEL. IMPACTS WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION.

There are no specific development plans within the project site, but there are pre-zoned areas that would or could eventually be developed with commercial, industrial, and visitor-serving/hotel uses, as well as construction of the Newell Drive extension. Construction of these uses and roadways would involve activities such as stockpiling, grading, excavation, paving, and other earth-disturbing activities. Loose and disturbed soils are more prone to erosion and loss of topsoil by wind and water. Therefore, the project could result in soil erosion or loss of topsoil.

Construction activities that disturb one or more acres of land are subject to the Construction General Permit. Compliance with the permit requires each qualifying development project to file a Notice of Intent with the SWRCB. Permit conditions require preparation of a SWPPP, which must describe the site, the facility, erosion and sediment controls, runoff water quality monitoring, means of waste disposal, implementation of approved local plans, control of construction sediment and erosion control measures, maintenance responsibilities, and non-storm water management controls. As described in Section 4.10, Hydrology and Water Quality, development in the project site would be subject to the applicable NPDES Municipal Regional Stormwater Permit (Order R4-2021- 0105; NPDES Permit No. CAS000004), which requires measures to reduce and eliminate stormwater pollutants, installation of appropriate BMPs to control stormwater runoff from construction sites, and that grading and drainage permits be obtained prior to construction. Grading and drainage plans accompanying the permit application must include BMPs for erosion prevention and sediment control, fencing at waterways and in sensitive areas, and limitation of disturbed areas. Other examples of BMPs typical of a SWPPP include covering soil stockpiles during construction and putting temporary barriers around storm-drain inlets. The permit applications must also demonstrate compliance with NPDES permit provisions. Mandatory compliance with these permit requirements would reduce soil erosion and the potential for soil loss.

Furthermore, Mitigation Measure HYD-1 would require the implementation of stormwater quality control measures during construction activities to prevent pollutants from entering downstream waterways. Standard stormwater pollution prevention measures would include implementing structural and nonstructural control measures within and around disturbed areas to prevent soil and pollutants from leaving the project site. Impacts would be less than significant. Implementation of Mitigation Measure HYD-1, as well as regulatory requirements, would minimize potentially significant erosions impacts to a less than significant level.

Mitigation Measures
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Significance After Mitigation
Implementation of Mitigation Measure HYD-1 would ensure that erosion impacts are minimized.

With implementation of Mitigation Measure HYD-1, impacts would be less than significant.

Threshold 3: Would the project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse? Threshold 4: Would the project be located on expansive soil, as defined in Table 1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property?
Impact GEO-4 THE PROJECT COULD RESULT IN ON- OR OFF-SITE LANDSLIDE, LATERAL SPREADING, SUBSIDENCE, LIQUEFACTION, OR COLLAPSE. COMPLIANCE WITH CBC REQUIREMENTS WOULD REDUCE HAZARDS RESULTING FROM EXPANSIVE SOILS AND IMPACTS WOULD BE LESS THAN SIGNIFICANT.

There are no specific development plans within the project site, but there are pre-zoned areas that would or could eventually be developed with commercial, industrial, and visitor-serving/hotel uses, in addition to the Newell Drive extension. Future structures associated with these uses and the Newell Drive extension could be located on expansive soils and be subject to damage (see Section

4.7.1, Setting). The project site has minimal landslide susceptibility in the eastern and southern sections, but the entirety of the area is in moderate susceptibility liquefaction zones. The adverse effects of expansive soils can be avoided through proper subsoil preparation, drainage, and foundation design. To design an adequate foundation or roadway, it must be determined if the site contains expansive soils through appropriate soil sampling and laboratory soils testing. Expansive soils are identified through expansion tests of samples of soil or rock, or by means of the interpretation of a standard soils testing procedure. The CBC includes requirements to address soilrelated hazards, including testing to identify expansive soils and design specifications where structures are to be constructed on expansive soils. CBC Chapter 18 provides requirements for geotechnical reports to address soils that are found incapable of supporting structures or roadways.

Placement of structures or roads can represent new loadings on natural soils or artificial fills that could compress over time.

The required geotechnical report for new development would determine the susceptibility of the project site to settlement from compressible soils and prescribe appropriate engineering techniques for reducing its effects. Typical measures to treat expansive soil conditions involve removal, proper fill selection, and compaction. In cases where soil remediation is not feasible, the CBC requires structural reinforcement of foundations to resist the forces of expansive soils.

The design-level Geotechnical Investigation, which would be required by Mitigation Measure GEO-1, would outline standard grading and soil engineering practices to abate potential hazards. Standard grading and soil engineering practices would include replacing native soils with engineered fill that would not possess expansive characteristics. These grading and soil engineering practices would ensure that the project does not exacerbate the existing expansive soil conditions. Implementation of Mitigation Measure GEO-1 would minimize potentially significant impacts related to landslide, lateral spreading, subsidence, liquefaction, or collapse, to a less than significant level.

Mitigation Measures
Mitigation Measure GEO-1 (see Impact GEO-2).
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Significance After Mitigation
Implementation of Mitigation Measure GEO-1 would reduce impacts related to landslide, lateral spreading, subsidence, liquefaction, or collapse. With implementation of Mitigation Measure GEO-1, impacts would be less than significant.

Threshold 5: Would the project have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?
Impact GEO-5 THE PROJECT WOULD BE SERVED BY SANITATION INFRASTRUCTURE. NO SEPTIC TANKS OR ALTERNATIVE WASTEWATER DISPOSAL SYSTEMS WOULD BE USED; THEREFORE, THERE WOULD BE NO IMPACT.

There exists development and associated wastewater utilities in the southern portion of the project site; however, the northern portion of the project site where development would occur is undeveloped and does not have connections to wastewater facilities. Future development at the project site would extend existing sewer infrastructure to serve the site consistent with Municipal Code Section 14.12.160. No septic tanks or alternative wastewater disposal systems would be installed for future developments. As such, there would be no impact.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
There would be no impact and no mitigation would be required.

Threshold 6: Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Impact GEO-6 DEVELOPMENT FACILITATED BY THE PROJECT HAS THE POTENTIAL TO IMPACT PALEONTOLOGICAL RESOURCES. IMPACTS WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED.

The potential for impacts to significant paleontological resources is based on the potential for ground disturbance to directly impact paleontologically sensitive geologic units. As described in the Paleontological Resources subsection of Section 4.7.1, Setting, there are three geologic units on the project site (alluvial fan deposits, the San Pablo Group, and the Jameson Shale Member of the Markley Sandstone) and all three have high paleontological sensitivity.

Potentially significant impacts to paleontological resources can only be determined once a specific project has been proposed because the effects are highly dependent on both the individual project site conditions and the characteristics of the proposed ground‐disturbing activity. Ground disturbing activities in areas of high paleontological sensitivity and particularly in areas that have not been previously developed with urban uses have the potential to damage or destroy paleontological resources that may be present on or below the ground surface. Ground disturbance associated with future development, as well as construction of the Newell Drive Extension could result in damage to or destruction of fossils, resulting in a potentially significant impact. Mitigation Measure GEO-2 would require that future projects be assessed for its potential to significantly impact paleontological resources.
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Mitigation Measure
GEO-2 Retention of Qualified Professional Paleontologist Prior to submittal of a discretionary development application, the project applicant shall retain a Qualified Professional Paleontologist, as defined by SVP (2010), to determine the project’s potential to significantly impact paleontological resources according to SVP (2010) standards. If necessary, the Qualified Professional Paleontologist shall direct mitigation measures to reduce potential impacts to paleontological resources to a less than significant level. The City shall review and approve the Qualified Professional Paleontologist’s findings and recommendation. All recommendations shall be incorporated into the project plans prior to issuance of a grading permit.

Significance After Mitigation
Mitigation Measure GEO-2 would reduce potential impacts to paleontological resources to a less than significant level.

4.7.4 Cumulative Impacts
The geographic scope of the cumulative geology and soils analysis is the City of American Canyon and the surrounding vicinity. Adverse effects associated with many geology and soils impacts tend to be localized; therefore, an area generally within a 0.25-mile radius would be the area most affected by activities in combination with the project. In addition, adverse effects associated with paleontological 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.

Because the project would have no impact related to rupture of a known earthquake fault or installation of alternative wastewater systems, the project would not contribute to a cumulative impact. Therefore, cumulative impacts related to rupture of a known earthquake fault or installation of alternative wastewater systems are not discussed further.

Cumulative projects have the potential to experience strong to violent ground shaking from earthquakes. Cumulative projects would be exposed to the same ground shaking hazards and likewise would be subject to the same requirements. All cumulative projects would adhere to the provisions of the CBC; American Canyon Municipal Code; and Napa County Municipal Code, which would reduce the potential hazards associated with seismic ground shaking and ground failure.

Therefore, the cumulative impact related to seismic-related hazards would be less than significant.

Soil conditions associated with the project, such as expansive soils or unstable geologic units or soils that may result in impacts to erosion, landslide, lateral spreading, subsidence, liquefaction, or collapse, are specific to the project site and generally do not contribute to a cumulative effect. Some or all other cumulative projects may have similar conditions, but they also would not contribute to a general geologic or soil cumulative effect. The project would be subject to the requirements in the American Canyon Municipal Code and CBC, which would reduce soil-related hazard impacts. Other current and future development/redevelopment projects in the City and vicinity would similarly be required to adhere to standards and practices that include stringent geologic and soil-related hazard mitigations. Therefore, the cumulative impact related to soil-related hazards would be less than significant.

Construction activities associated with development of cumulative plans and projects in or within the vicinity of the project site may have the potential to encounter undiscovered paleontological 413
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resources. Cumulative development would be required to minimize impacts through compliance with applicable federal and State laws governing geologic resources and paleontological resources.

The closest and largest cumulative project would be the Watson Ranch Project, which includes mitigation for unanticipated discovery of paleontological resources (City of American Canyon 2018).

Nonetheless, it is possible that geologic resources and paleontological resources are present on the cumulative project sites and could be encountered by subsurface earthwork activities. Given the potential for cumulative construction-related soil disruption, cumulative projects could result in a potentially significant cumulative impact related to unique geologic and paleontological resources.

However, the project itself would not contribute considerably to this cumulative impact because implementation of Mitigation Measure GEO-2 would ensure that undiscovered geologic and paleontological resources are not adversely affected by project-related construction activities and would prevent the destruction or degradation of potentially significant paleontological resources. 414
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4.8 Greenhouse Gas Emissions
This section summarizes the setting for greenhouse gas (GHG) emissions and climate change and analyzes the impacts related to GHG emissions and climate change due to the project.

4.8.1 Setting
Gases that absorb and re-emit infrared radiation in the atmosphere are called GHGs. The gases that are widely seen as the principal contributors to human-induced climate change include carbon dioxide (CO2); methane (CH4); nitrous oxides (N2O); fluorinated gases such as hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs); and sulfur hexafluoride (SF6). Water vapor is excluded from the list of GHGs because it is short-lived in the atmosphere and its atmospheric concentrations are largely determined by natural processes, such as oceanic evaporation.

Different types of GHGs have varying global warming potentials (GWP). The GWP of a GHG is the potential of a gas or aerosol to trap heat in the atmosphere over a specified timescale (generally, 100 years). Because GHGs absorb different amounts of heat, a common reference gas (CO2) is used to relate the amount of heat absorbed to the amount of the gas emitted, referred to as “carbon dioxide equivalent” (CO2e), which is the amount of GHG emitted multiplied by its GWP. Carbon dioxide has a 100-year GWP of one. By contrast, methane has a 100-year GWP of 30, meaning its global warming effect is 30 times greater than CO2 on a molecule per molecule basis (United Nations Intergovernmental Panel on Climate Change [IPCC] 2021).1 GHGs are emitted by natural processes and human activities. Of these gases, CO2 and CH4 are emitted in the greatest quantities from human activities. Emissions of CO2 are usually by-products of fossil fuel combustion, and CH4 results from off-gassing associated with agricultural practices and landfills. Human-made GHGs, many of which have greater heat-absorption potential than CO2, include fluorinated gases and SF6 (United States Environmental Protection Agency [USEPA] 2022a).

Climate change is the observed increase in the average temperature of the Earth’s atmosphere and oceans along with other substantial changes in climate (such as wind patterns, precipitation, and storms) over an extended period. The term “climate change” is often used interchangeably with the term “global warming,” but climate change is preferred because it conveys that other changes are happening in addition to rising temperatures. The baseline against which these changes are measured originates in historical records that identify temperature changes that occurred in the past, such as during previous ice ages. The global climate is changing continuously, as evidenced in the geologic record, which indicates repeated episodes of substantial warming and cooling. The rate of change has typically been incremental, with warming or cooling trends occurring over the course of thousands of years. The past 10,000 years have been marked by a period of incremental warming, as glaciers have steadily retreated across the globe. However, scientists have observed acceleration in the rate of warming over the past 150 years. The IPCC expressed in their Sixth Assessment Report that the rise and continued growth of atmospheric CO2 concentrations is unequivocally due to human activities (IPCC 2021). Human influence has warmed the atmosphere, ocean, and land, which has led the climate to warm at an unprecedented rate in the last 2,000 years. It is estimated that between the period of 1850 through 2019, a total of 2,390 gigatons of anthropogenic CO2 was emitted. It is likely that anthropogenic activities have increased the global 1 The Intergovernmental Panel on Climate Change’s (2021) Sixth Assessment Report determined that methane has a GWP of 30. However, the 2017 Climate Change Scoping Plan published by the California Air Resources Board uses a GWP of 25 for methane, consistent with the Intergovernmental Panel on Climate Change’s (2007) Fourth Assessment Report. Therefore, this analysis utilizes a GWP of 25. 415
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surface temperature by approximately 1.07 degrees Celsius between the years 2010 through 2019 (IPCC 2021).

The accumulation of GHGs in the atmosphere regulates the earth’s temperature. Without the natural heat-trapping effect of GHGs, the earth’s surface would be about 33 degrees Celsius (°C) cooler (World Meteorological Organization 2013). However, since 1750, estimated concentrations of CO2, CH4, and N2O in the atmosphere have increased by 47 percent, 156 percent, and 23 percent, respectively, primarily due to human activity (IPCC 2021). GHG emissions from human activities, particularly the consumption of fossil fuels for electricity production and transportation, are believed to have elevated the concentration of these gases in the atmosphere beyond the level of concentrations that occur naturally.
a. Greenhouse Gas Emissions Inventory
Global Emissions Inventory
Worldwide anthropogenic GHG emissions totaled 47,000 million metric tons (MT) of CO2e in 2015, which is a 43 percent increase from 1990 GHG levels (USEPA 2022b). Specifically, 34,522 million metric tons (MMT) of CO2e of CO2, 8,241 MMT of CO2e of CH4, 2,997 MMT of CO2e of N2O, and 1,001 MMT of CO2e of fluorinated gases were emitted in 2015. The largest source of GHG emissions were energy production and fuel use from vehicles and buildings, which accounted for 75 percent of the global GHG emissions. Agriculture uses and industrial processes contributed 12 percent and six percent, respectively. Waste sources contributed three percent and international transportation sources contributed two percent. These sources account for approximately 98 percent because there was a net sink of two percent from land-use change (including afforestation/reforestation and emissions removals by other land use activities) (USEPA 2022b).

United States Emissions Inventory
Total United States (U.S.) GHG emissions were 6,558 MMT of CO2e in 2019. Emissions decreased by

1.7 percent from 2018 to 2019. Since 1990, total U.S. emissions have increased by an average annual rate of 0.06 percent for a total increase of 1.8 percent between 1990 and 2019. The decrease from 2018 to 2019 reflects the combined influences of several long-term trends, including population changes, economic growth, energy market shifts, technological changes such as improvements in energy efficiency, and decrease carbon intensity of energy fuel choices. In 2019, the industrial and transportation end-use sectors accounted for 30 percent and 29 percent, respectively, of nationwide GHG emissions; while the commercial and residential end-use sectors accounted for 16 percent and 15 percent of nationwide GHG emissions, respectively, with electricity emissions distributed among the various sectors (USEPA 2022c).

California Emissions Inventory
Based on the California Air Resources Board (CARB) California Greenhouse Gas Inventory for 2000- 2019, California produced 418.2 MMT of CO2e in 2019, which is 7.2 MMT of CO2e lower than 2018 levels. The major source of GHG emissions in California is the transportation sector, which comprises 40 percent of the state’s total GHG emissions. The industrial sector is the second largest source, comprising 21 percent of the state’s GHG emissions, while electric power accounts for approximately 14 percent (CARB 2021a). The magnitude of California’s total GHG emissions is due in part to its large size and large population compared to other states. However, its relatively mild climate is a factor that reduces California’s per capita fuel use and GHG emissions as compared to 416
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other states. In 2016, the State of California achieved its 2020 GHG emission reduction target of reducing emissions to 1990 levels, as emissions fell below 431 MMT of CO2e (CARB 2021).

Local Emissions Inventory
Based on the City of American Canyon’s 2012 Energy Efficiency Climate Action Plan (EECAP), the City generated approximately 120,201 MT of CO2e in 2010 (City of American Canyon 2012). On-road transportation was the major source accounting for 39.9 percent of the total, largely due to passenger vehicles, but also commercial trips and buses. Commercial/industrial energy was the second largest source of emissions at 27 percent. Residential energy usage represented 18 percent, and solid waste and wastewater represented 7 percent each. Off-road transportation accounted for 2 percent. Agriculture accounted for less than 1 percent of emissions (City of American Canyon 2012).
b. Potential Effects of Climate Change
Globally, climate change has the potential to affect numerous environmental resources through potential impacts related to future air temperatures and precipitation patterns. Scientific modeling predicts that continued GHG emissions at or above current rates would induce more extreme climate changes during the 21st century than were observed during the 20th century. Each of the past three decades has been warmer than all the previous decades on record, and the decade from 2000 through 2010 has been the warmest. The observed global mean surface temperature from 2015 to 2017 was approximately 1.0°C higher than the average global mean surface temperature over the period from 1880 to 1900 (National Oceanic and Atmospheric Administration 2020).

Furthermore, several independently analyzed data records of global and regional Land-Surface Air Temperature obtained from station observations jointly indicate that Land-Surface Air Temperature and sea surface temperatures have increased.

According to California’s Fourth Climate Change Assessment, statewide temperatures from 1986 to 2016 were approximately 0.6 to 1.1°C higher than those recorded from 1901 to 1960. Potential impacts of climate change in California may include reduced water supply from snowpack, sea level rise, more extreme heat days per year, larger forest fires, and more drought years (State of California 2018). In addition to statewide projections, California’s Fourth Climate Change Assessment includes regional reports that summarize climate impacts and adaptation solutions for nine regions of the state and regionally specific climate change case studies (State of California 2018). However, while there is growing scientific consensus about the possible effects of climate change at a global and statewide level, current scientific modeling tools are unable to predict what local impacts may occur with a similar degree of accuracy. A summary follows of some of the potential effects that could be experienced in California because of climate change.

Air Quality
Scientists project that the annual average maximum daily temperatures in California could rise by

2.4 to 3.2°C in the next 50 years and by 3.1 to 4.9°C in the next century (State of California 2018).

Higher temperatures are conducive to air pollution formation, and rising temperatures could therefore result in worsened air quality in California. As a result, climate change may increase the concentration of ground-level ozone. The magnitude of the effect of the increased concentration of ground-level ozone, and therefore its indirect effects, are uncertain. In addition, as temperatures have increased in recent years, the area burned by wildfires throughout the state has increased, and wildfires have occurred at higher elevations in the Sierra Nevada Mountains (State of California 417
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2018). If higher temperatures continue to be accompanied by an increase in the incidence and extent of large wildfires, air quality could worsen. Severe heat accompanied by drier conditions and poor air quality could increase the number of heat-related deaths, illnesses, and asthma attacks throughout the state. However, if higher temperatures are accompanied by wetter, rather than drier conditions, the rains could tend to temporarily clear the air of particulate pollution, which would effectively reduce the number of large wildfires and thereby ameliorate the pollution associated with them (California Natural Resources Agency 2009).

Water Supply
Analysis of paleoclimatic data (such as tree-ring reconstructions of stream flow and precipitation) indicates a history of naturally and widely varying hydrologic conditions in California and the west, including a pattern of recurring and extended droughts. Uncertainty remains with respect to the overall impact of climate change on future precipitation trends and water supplies in California.

Year-to-year variability in statewide precipitation levels has increased since 1980, meaning that wet and dry precipitation extremes have become more common (California Department of Water Resources 2018). This uncertainty regarding future precipitation trends complicates the analysis of future water demand, especially where the relationship between climate change and its potential effect on water demand is not well understood. The average early spring snowpack in the western U.S., including the Sierra Nevada Mountains, decreased by about 10 percent during the last century.

During the same period, sea level rose over 0.15 meter along the central and southern California coasts (State of California 2018). The Sierra snowpack provides most of California's water supply as snow that accumulates during wet winters is released slowly during the dry months of spring and summer. A warmer climate is predicted to reduce the fraction of precipitation that falls as snow and the amount of snowfall at lower elevations, thereby reducing the total snowpack (State of California 2018). Projections indicate that average spring snowpack in the Sierra Nevada and other mountain catchments in central and northern California will decline by approximately 66 percent from its historical average by 2050 (State of California 2018).

Hydrology and Sea Level Rise
Climate change could affect the intensity and frequency of storms and flooding (State of California 2018). Furthermore, climate change could induce substantial sea level rise in the coming century.

Rising sea level increases the likelihood of and risk from flooding. The rate of increase of global mean sea levels between 1993 to 2022, observed by satellites, is approximately 3.5 millimeters per year, double the twentieth century trend of 1.6 millimeters per year (World Meteorological Organization 2013; National Aeronautics and Space Administration 2022). Sea levels are rising faster now than in the previous two millennia, and the rise will probably accelerate, even with robust GHG emission control measures. While the City is no close to the Pacific coast, sea level rise may jeopardize California’s water supply due to saltwater intrusion and induce groundwater flooding and/or exposure of buried infrastructure (State of California 2018).

Agriculture
California has an over $50 billion annual agricultural industry that produces over a third of the country’s vegetables and two-thirds of the country’s fruits and nuts (California Department of Food and Agriculture 2020). Higher CO2 levels can stimulate plant production and increase plant wateruse efficiency. However, if temperatures rise and drier conditions prevail, certain regions of agricultural production could experience water shortages of up to 16 percent, which would increase 418
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water demand as hotter conditions lead to the loss of soil moisture. In addition, crop yield could be threatened by water-induced stress and extreme heat waves, and plants may be susceptible to new and changing pest and disease outbreaks (State of California 2018). Temperature increases could also change the time of year certain crops, such as wine grapes, bloom or ripen, and thereby affect their quality (California Climate Change Center 2006).

Ecosystems
Climate change and the potential resultant changes in weather patterns could have ecological effects on the global and local scales. Soil moisture is likely to decline in many regions because of higher temperatures, and intense rainstorms are likely to become more frequent. Rising temperatures could have four major impacts on plants and animals: timing of ecological events; geographic distribution and range of species; species composition and the incidence of nonnative species within communities; and ecosystem processes, such as carbon cycling and storage (Parmesan 2006; State of California 2018).

4.8.2 Regulatory Setting
a. International
United Nations Climate Change Framework Convention
On March 21, 1994, the United States joined a number of countries around the world in signing the United Nations Climate Change Framework Convention. Under the Convention, governments agreed to gather and share information on GHG emissions, national policies, and best practices; launch national strategies for addressing GHG emissions and adapting to expected impacts, including the provision of financial and technological support to developing countries; and cooperate in preparing for adaptation to the impacts of climate change. b. Federal Regulations
Federal Clean Air Act
The U.S. Supreme Court determined in Massachusetts et al. v. Environmental Protection Agency et al. ([2007] 549 U.S. 05-1120) that the USEPA has the authority to regulate motor vehicle GHG emissions under the federal Clean Air Act. The USEPA issued a Final Rule for mandatory reporting of GHG emissions in October 2009. This Final Rule applies to fossil fuel suppliers, industrial gas suppliers, direct GHG emitters, and manufacturers of heavy-duty and off-road vehicles and vehicle engines and requires annual reporting of emissions. In 2012, the USEPA issued a Final Rule that established the GHG permitting thresholds that determine when Clean Air Act permits under the New Source Review Prevention of Significant Deterioration and Title V Operating Permit programs are required for new and existing industrial facilities.

In Utility Air Regulatory Group v. Environmental Protection Agency (134 Supreme Court 2427 [2014]), the U.S. Supreme Court held the USEPA may not treat GHGs as an air pollutant for purposes of determining whether a source can be considered a major source required to obtain a Prevention of Significant Deterioration or Title V permit. The Court also held that Prevention of Significant Deterioration permits otherwise required based on emissions of other pollutants may continue to require limitations on GHG emissions based on the application of Best Available Control Technology. 419
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Safer Affordable Fuel-Efficient Vehicles Rule
On September 27, 2019, the USEPA and the National Highway Traffic Safety Administration published the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule Part One: One National Program.

The SAFE Rule Part One revokes California’s authority to set its own GHG emissions standards and to adopt its own zero-emission vehicle mandates. On April 30, 2020, the USEPA and the National Highway Traffic Safety Administration published Part Two of the SAFE Vehicles Rule, which revised corporate average fuel economy and CO2 emissions standards for passenger cars and trucks of model years 2021-2026, such that the standards increase by approximately 1.5 percent each year through model year 2026, as compared to the approximately 5 percent annual increase required under the 2012 standards (National Highway Traffic Safety Administration 2022).

Construction Equipment Fuel-Efficiency Standard
USEPA sets emission standards for construction equipment. The first federal standards (Tier 1) were adopted in 1994 for all off-road engines over 50 horsepower (hp) and were phased in by 2000. A new standard was adopted in 1998 that introduced Tier 1 for all equipment below 50 hp and established the Tier 2 and Tier 3 standards. The Tier 2 and Tier 3 standards were phased in by 2008 for all equipment. The current iteration of emissions standards for construction equipment are the Tier 4 efficiency requirements, which are contained in 40 Code of Federal Regulations Parts 1039, 1065, and 1068 (originally adopted in 69 Federal Register 38958 [June 29, 2004] and most recently updated in 2014 [79 Federal Register 46356]). Emissions requirements for new off-road Tier 4 vehicles were completely phased in by the end of 2015.
a. State Regulations
CARB is responsible for the coordination and oversight of State and local air pollution control programs in California. There are numerous regulations aimed at reducing the state’s GHG emissions. These initiatives are summarized below.

California Advanced Clean Cars Program
Assembly Bill (AB) 1493 (2002), California’s Advanced Clean Cars program (referred to as “Pavley”), requires CARB to develop and adopt regulations to achieve “the maximum feasible and costeffective reduction of GHG emissions from motor vehicles.” On June 30, 2009, the USEPA granted the waiver of Clean Air Act preemption to California for its GHG emission standards for motor vehicles, beginning with the 2009 model year, which allows California to implement more stringent vehicle emission standards than those promulgated by the USEPA. Pavley I regulates model years from 2009 to 2016 and Pavley II, now referred to as “LEV (Low Emission Vehicle) III GHG,” regulates model years from 2017 to 2025. The Advanced Clean Cars program coordinates the goals of the LEV, Zero Emissions Vehicles (ZEV), and Clean Fuels Outlet programs and would provide major reductions in GHG emissions. By 2025, the rules will be fully implemented, and new automobiles will emit 34 percent fewer GHGs and 75 percent fewer smog-forming emissions from their model year 2016 levels (CARB 2011).

California Advanced Clean Trucks Program
In June 2020, CARB approved the Advanced Clean Trucks regulation, which requires manufacturers who certify Class 2b-8 chassis or complete vehicles with combustion engines to sell zero-emission trucks as an increasing percentage of their annual California sales from 2024 to 2035. In addition, 420
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the regulation requires company and fleet reporting for large employers and fleet owners with 50 or more trucks. By 2045, all new trucks sold in California must be zero-emission. Implementation of this regulation would reduce consumption of nonrenewable transportation fuels as trucks transition to alternative fuel sources.

Executive Order B-48-18: Zero-Emission Vehicles
On January 26, 2018, Governor Brown signed Executive Order B-48-18 requiring all State entities to work with the private sector to have at least 5 million ZEVs on the road by 2030, as well as install 200 hydrogen fueling stations and 250,000 electric vehicle (EV) charging stations by 2025. It specifies that 10,000 of the EV charging stations should be direct current fast chargers. This order also requires all State entities to continue to partner with local and regional governments to streamline the installation of ZEV infrastructure. The Governor’s Office of Business and Economic Development is required to publish a Plug-in Charging Station Design Guidebook and update the 2015 Hydrogen Station Permitting Guidebook to aid in these efforts. All State entities are required to participate in updating the 2016 ZEV Action Plan, along with the 2018 ZEV Action Plan Priorities Update, which includes and extends the 2016 ZEV Action Plan (Governor’s Interagency Working Group on Zero-Emission Vehicles 2016, 2018) to help expand private investment in ZEV infrastructure with a focus on serving low-income and disadvantaged communities.

Executive Order N-79-20
Governor Gavin Newsom signed Executive Order N-79-20 in September 2020, which sets a Statewide goal that 100 percent of all new passenger car and truck sales in the State will be zeroemissions by 2035. It also sets a goal that 100 percent of statewide new sales of medium- and heavy-duty vehicles will be zero emissions by 2045, where feasible, and for all new sales of drayage trucks to be zero emissions by 2035. Additionally, the Executive Order targets 100 percent of new off-road vehicle sales in the State to be zero emission by 2035. CARB is responsible for implementing the new vehicle sales regulation.

California Global Warming Solutions Act of 2006 (Assembly Bill 32, Senate Bill 32, and Assembly Bill 1279)
The “California Global Warming Solutions Act of 2006,” (AB 32), outlines California’s major legislative initiative for reducing GHG emissions. AB 32 codifies the statewide goal of reducing GHG emissions to 1990 levels by 2020 and requires CARB to prepare a Scoping Plan that outlines the main state strategies for reducing GHG emissions to meet the 2020 deadline. In addition, AB 32 requires CARB to adopt regulations to require reporting and verification of statewide GHG emissions. Based on this guidance, CARB approved a 1990 statewide GHG level and 2020 target of 431 MMT of CO2e, which was achieved in 2016. CARB approved the Scoping Plan on December 11, 2008, which included GHG emission reduction strategies related to energy efficiency, water use, and recycling and solid waste, among others (CARB 2008).

The CARB approved the 2013 Scoping Plan update in May 2014. The update defined the CARB’s climate change priorities for the next five years, set the groundwork to reach post-2020 statewide goals, and highlighted California’s progress toward meeting the “near-term” 2020 GHG emission reduction goals defined in the original Scoping Plan.

On September 8, 2016, the governor signed Senate Bill (SB) 32 into law, extending the California Global Warming Solutions Act of 2006 by requiring the state to further reduce GHG emissions to 40 421
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percent below 1990 levels by 2030 (the other provisions of AB 32 remain unchanged). On December 14, 2017, the CARB adopted the 2017 Scoping Plan, which provides a framework for achieving the 2030 target. The 2017 Scoping Plan relies on the continuation and expansion of existing policies and regulations, such as the Cap-and-Trade Program, and implementation of recently adopted policies and legislation, such as SB 1383 and SB 100 (discussed below). The 2017 Scoping Plan also puts an increased emphasis on innovation, adoption of existing technology, and strategic investment to support its strategies.

AB 1279, “The California Climate Crisis Act,” was passed on September 16, 2022 and declares the State would achieve net zero greenhouse gas emissions as soon as possible, but no later than 2045, and to achieve and maintain net negative greenhouse gas emissions thereafter. In addition, the bill states that the State would reduce GHG emissions by 85 percent below 1990 levels no later than 2045. The 2022 Scoping Plan lays out a path to achieve AB 1279 targets (CARB 2022). The actions and outcomes in the 2022 Scoping Plan would achieve significant reductions in fossil fuel combustion by deploying clean technologies and fuels, further reductions in short-lived climate pollutants, support for sustainable development, increased action on natural and working lands to reduce emissions and sequester carbon, and the capture and storage of carbon.

Senate Bill 375
The Sustainable Communities and Climate Protection Act of 2008 (SB 375), signed in August 2008, enhances the state’s ability to reach AB 32 goals by directing the CARB to develop regional GHG emission reduction targets to be achieved from passenger vehicles by 2020 and 2035. SB 375 aligns regional transportation planning efforts, regional GHG reduction targets, and affordable housing allocations. Metropolitan Planning Organizations (MPOs) are required to adopt a Sustainable Communities Strategy (SCS), which allocates land uses in the MPO’s Regional Transportation Plan (RTP). Qualified projects consistent with an approved SCS or Alternative Planning Strategy (categorized as “transit priority projects”) can receive incentives to streamline CEQA processing.

The City of American Canyon is within the planning area of the Association of Bay Area Governments (ABAG). ABAG was assigned targets of a 10 percent reduction in GHGs from transportation sources by 2020 and a 19 percent reduction in GHGs from transportation sources by 2035 (CARB 2022b).

Assembly Bill 1493 (Reduce GHG Emissions from Vehicle Use) AB 1493 (Chapter 200, Statutes of 2002), known as the Pavley Bill, amended Health and Safety Code Sections 42823, and added Section 43018.5 requiring CARB to develop and adopt regulations that achieve maximum feasible and cost-effective reduction of GHG emissions from passenger vehicles, light-duty trucks, and other vehicles used for noncommercial personal transportation in California.

Assembly Bill 1007 (State Alternative Fuels Plan)
AB 1007 (Chapter 371, Statutes of 2005) required the California Energy Commission (CEC) to prepare a State plan to increase the use of alternative fuels in California. The CEC prepared the State Alternative Fuels Plan (SAF Plan) in partnership with CARB and in consultation with other federal, State, and local agencies. The SAF Plan presents strategies and actions California must take to increase the use of alternative non-petroleum fuels in a manner that minimizes costs to California and maximizes the economic benefits of in-state production. The SAF Plan assessed various alternative fuels and developed fuel portfolios to meet California’s goals to reduce petroleum consumption, increase alternative fuels use, reduce GHG emissions, and increase in-State 422
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production of biofuels without causing a significant degradation of public health and environmental quality.

CARB In-Use On-Road and Off-Road Diesel Rules
The CARB rule imposes limits on idling, restricts the addition of older vehicles, and requires the retirement or replacement of older engines depending on their fleet size category. This policy indirectly impacts energy consumption.

More specifically, CARB is also charged with developing air pollution control regulations based upon the best available control measures and implementing feasible control measures under the State and Federal Clean Air Act (Health & Safety Code, Sections 39602.5, 39667, 43013, subdivisions (a) and (h), 43018, 40600, 40601, 40612(a)(2) and (c)(1)(A)). Pursuant to these statutory authorities, more stringent emission standards were adopted in 2004 for off-road construction equipment (i.e. “Tier 4” standards) (40 Code of Federal Regulations Parts 1039, 1065, and 1068; California Code of Regulations, title 13, Section 2025; AR 2854). CARB also adopted emission standards for on-road heavy duty diesel vehicles (i.e., haul trucks). (California Code of Regulations, title 13, Section 1956.8.) These haul truck regulations mandate fleet turn-over to ensure that by January 1, 2023, nearly all on-road diesel trucks will have 2010 model year engines or equivalent [i.e., Tier 4]. In addition, interim steps are incorporated into the regulations (e.g., vehicles older than 1999 will be replaced with newer engines by 2020).

California Integrated Waste Management Act (Assembly Bill 341)/Assembly Bill 1826 (Mandatory Recycling/Composting)
The California Integrated Waste Management Act of 1989, as modified by AB 341, requires each jurisdiction’s source reduction and recycling element to include an implementation schedule that shows diversion away from landfills of 75 percent of all solid waste by 2020 and annually thereafter.

AB 1826 requires recycling of organic waste (i.e., composting). All businesses and public entities that generate four or more cubic yards of solid waste per week and multi-family residential dwellings that have five or more units are required to recycle and compost.

Senate Bill 1383
Adopted in September 2016, SB 1383 requires CARB to approve and begin implementing a comprehensive strategy to reduce emissions of short-lived climate pollutants. SB 1383 requires the strategy to achieve the following reduction targets by 2030:
 Methane – 40 percent below 2013 levels
 Hydrofluorocarbons – 40 percent below 2013 levels
 Anthropogenic black carbon – 50 percent below 2013 levels SB 1383 also requires the California Department of Resources Recycling and Recovery (CalRecycle), in consultation with the CARB, to adopt regulations that achieve specified targets for reducing organic waste in landfills.

Senate Bill 100
Adopted on September 10, 2018, SB 100 supports the reduction of GHG emissions from the electricity sector by accelerating the state’s Renewables Portfolio Standard (RPS) Program, which was last updated by SB 350 in 2015. SB 100 requires electricity providers to increase procurement 423
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from eligible renewable energy resources to 33 percent of total retail sales by 2020, 60 percent by 2030, and 100 percent by 2045. The 2020 goal was met, with approximately 36 percent of electricity coming from renewable sources in March 2021 (CARB 2021b).

Executive Order B-55-18
On September 10, 2018, the former Governor Brown issued Executive Order B-55-18, which established a new statewide goal of achieving carbon neutrality by 2045 and maintaining net negative emissions thereafter. This goal is in addition to the existing statewide GHG reduction targets established by SB 375, SB 32, SB 1383, and SB 100.

California Refrigerant Management Program
California’s Refrigerant Management Program (RMP) regulates refrigerants used in larger facilities, primarily industrial and supermarket land uses. Refrigerants regulated under the RMP include any refrigerant that is an ozone depleting substance as defined in Title 40 of the Code of Federal Regulation, Part 82, and any compound with a GWP value equal to or greater than 150 according to the GWPs specified in the IPCC Fourth Assessment Report of 2007. According to the RMP, all supermarket and industrial refrigeration systems with a full recharge capacity of 50 pounds (22.7 kilograms) or greater will be required to limit the refrigerants used to no greater than 150 GWP beginning in 2022. Similarly, according to the RMP, all room air conditioning unit systems with a full recharge capacity of 50 pounds or greater will be required to limit the refrigerants used to no greater than 750 GWP beginning in 2023.

Senate Bill 1020
Senate Bill 1020 (SB 1020), signed into law on September 16, 2022, requires renewable energy and zero-carbon resources to supply 90 percent of all retail electricity sales by 2035, 95 percent by 2040, and 100 percent by 2045. All State agencies facilities must be served by 100 percent renewable and zero-carbon resources by 2030. SB 1020 also requires the Public Utilities Commission, Energy Commission, and CARB to issue a joint progress report outlining the reliability of the electrical grid with a focus on summer reliability and challenges and gaps. Additionally, SB 1020 requires the Public Utilities Commission to define energy affordability and use energy affordability metrics to develop protections, incentives, discounts, or new programs for residential customers facing hardships due to energy or gas bills.

CARB Gas Appliances Sales Ban
As part of the 2022 State Implementation Plan, CARB adopted a ban on new sales of natural gas heaters, water heaters, and furnaces by 2030 in September of 2022. This new measure is intended to reduce emissions from new residential and commercial space and water heaters sold in the State.

An emission standard for space and water heaters will go into effect in 2030. Beginning in 2030, 100 percent of the sales of new natural gas-powered heaters and water heaters would need to comply with the emission standard, such as putting in electric heaters or other zero-emission options.

California Building Standards Code
The California Code of Regulations (CCR) Title 24 is referred to as the California Building Standards Code. It consists of a compilation of several distinct standards and codes related to building construction, including plumbing, electrical, interior acoustics, energy efficiency, and accessibility for persons with physical and sensory disabilities. The California Building Standards Code’s energy424 Environmental Impact Analysis
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efficiency and green building standards are outlined below. These standards are updated every three years and the project would be subject to the 2022 California Building Standards when they go into effect on January 1, 2023.

Part 6 – Building Energy Efficiency Standards/Energy Code CCR Title 24, Part 6 is the Building Energy Efficiency Standards or California Energy Code. This code, originally enacted in 1978, establishes energy-efficiency standards for residential and nonresidential buildings to reduce California’s energy demand. New construction and major renovations must demonstrate their compliance with the current Energy Code through submittal and approval of a Title 24 Compliance Report to the local building permit review authority and the CEC. The current iteration is the 2019 Title 24 standards. The California Building Standards Code’s energyefficiency and green building standards are outlined below. The 2022 Standards have been adopted and will come into effect January 1, 2023.

Part 11 – California Green Building Standards
The California Green Building Standards Code, referred to as CALGreen, was added to Title 24 as Part 11, first in 2009 as a voluntary code, which then became mandatory effective on January 1, 2011 (as part of the 2010 California Building Standards Code). The 2022 CALGreen includes mandatory minimum environmental performance standards for all ground-up new construction of residential and non-residential structures. It also includes voluntary tiers with stricter environmental performance standards for these same categories of residential and non-residential buildings. Local jurisdictions must enforce the minimum mandatory CALGreen standards and may adopt additional amendments for stricter requirements.

The mandatory standards require:
 Minimum 20 percent reduction in indoor water use relative to specified baseline levels;2  Waste Reduction:

Minimum 65 percent non-hazardous construction/demolition waste diverted from landfills; Non-residential and Multifamily dwellings with 5 or more units shall provide readily accessible areas identified for the depositing, storage and collection of nonhazardous materials for recycling including (at a minimum) paper, corrugated cardboard, glass, plastic, organic waste, and metals;
Nonresidential: 100 percent of trees, stumps, rocks and associated vegetation soils resulting from primary land clearing shall be reused or recycled.  Inspections of energy systems to ensure optimal working efficiency;  Electric Vehicle (EV) Charging for New Construction:3 2 Similar to the compliance reporting procedure for demonstrating Energy Code compliance in new buildings and major renovations, compliance with the CALGreen water reduction requirements must be demonstrated through completion of water use reporting forms.

Buildings must demonstrate a 20 percent reduction in indoor water use by either showing a 20 percent reduction in the overall baseline water use as identified in CALGreen or a reduced per-plumbing-fixture water use rate. 3 EV Capable = a vehicle space with electrical panel space and load capacity to support a branch circuit and necessary raceways to support EV charging. EV Ready = a vehicle space which is provided with a branch circuit and any necessary raceways to accommodate EV charging stations including a receptacle for future installation of a charger. See 2022 California Green Building Standard Code, Title 24 Part 11 for full explanation of mandatory measures including exceptions. 425
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Multifamily dwellings, hotels/motels with less than 20 units/rooms: Designation of at least 10 percent of the total number of parking spaces shall be EV capable and at least 25 percent of the total number of parking spaces shall be EV Ready.

Multifamily dwellings, hotels/motels with greater than 20 units/rooms: Designation of at least 10 percent of the total number of parking spaces shall be EV capable, at least 25 percent of the total number of parking spaces shall be EV Ready, and at least 5 percent of the total number of parking spaces shall be equipped with a Level 2 Charging Station.

Non-residential land uses shall comply with the following EV charging requirements based on the number of passenger vehicle parking spaces:
− 0-9: no EV capable spaces or charging stations required; − 10 – 25: 4 EV capable spaces but no charging stations required; − 26 – 50: 8 EV capable spaces of which 2 must be equipped with charging stations; − 51 – 75: 13 EV capable spaces of which 3 must be equipped with charging stations; − 76 – 100: 17 EV capable spaces of which 4 must be equipped with charging stations; − 101 – 150: 25 EV capable spaces of which 6 must be equipped with charging stations; − 151 – 200: 35 EV capable spaces of which 9 must be equipped with charging stations; − >200: 20 percent of the total available parking spaces of which 25 percent must be equipped with charging stations;
Non-residential land uses shall comply with the following EV charging requirements for medium-duty and heavy-duty vehicles: Warehouses, grocery stores, and retail stores with planned off-street loading spaces shall install EV supply and distribution equipment, spare raceway(s) or busway(s) and adequate capacity for transformer(s), service panel(s), or subpanel(s) at the time of construction based on the number of off-street loading spaces as indicated in Table 5.106.5.4.1 of the California Green Building Standards.  Bicycle Parking:

Non-residential short term bicycle parking for projects anticipated to generate visitor traffic:
permanently anchored bicycle racks within 200 feet of visitor entrance for 5 percent of new visitor motorized vehicle parking spaces with a minimum of one two-bike capacity rack.

Non-residential buildings with tenant spaces of 10 or more employees/tenant-occupants:

Secure bicycle parking for 5 percent of the employee/tenant-occupant vehicle parking spaces with a minimum of one bicycle parking facility.
 Shade Trees (Non-Residential):

Surface parking: Minimum No. 10 container size or equal shall be installed to provide shade over 50 percent of the parking within 15 years (unless parking area covered by appropriate shade structures and/or solar);
Landscape areas: Minimum No. 10 container size or equal shall be installed to provide shade of 20 percent of the landscape area within 15 years;
Hardscape areas: Minimum No. 10 container size or equal shall be installed to provide shade of 20 percent of the landscape area within 15 years (unless covered by applicable shade structures and/or solar or the marked area is for organized sports activities). 426
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The CALGreen voluntary standards are only mandatory if a local ordinance requires them. Since the City has not made any of the voluntary measures mandatory, the following voluntary standards would not be applicable to the project:
 Deconstruct existing buildings and reuse applicable salvaged materials;  Residential Bicycle Parking:

Multifamily/hotel/motel short-term parking: Provide permanently anchored bicycle racks within 100 feet of visitor’s entrance for 5 percent of visitor motorized vehicle parking capacity (minimum 1 two-bile capacity rack);
Hotel/Motel long-term parking: Provide one acceptable on-site bicycle parking space for every 25,000 square feet but not less than two spaces;
The CALGreen voluntary standards are divided into two tiers. Tier 1 adds additional requirements beyond the mandatory measures, whereas Tier 2 further increases the requirements.  Tier I:

Stricter energy efficiency requirements;
Stricter water conservation requirements for specific fixtures; Minimum 65 percent reduction in construction waste with third-party verification, Minimum 10 percent recycled content for building materials; Minimum 20 percent permeable paving;
Minimum 20 percent cement reduction;
Multifamily developments/hotels/motels: Minimum 35 percent of total parking spaces shall be EV ready and for projects with 20 or more dwelling units/rooms a minimum of 10 percent of the total number of parking spaces shall be equipped with EV charging stations;  Tier II:

Stricter energy efficiency requirements,
Stricter water conservation requirements for specific fixtures; Minimum 75 percent reduction in construction waste with third-party verification, Minimum 15 percent recycled content for building materials; Minimum 30 percent permeable paving;
Minimum 25 percent cement reduction;
Multifamily developments/hotels/motels: Minimum 40 percent of total parking spaces shall be EV ready and for projects with 20 or more dwelling units/rooms a minimum of 15 percent of the total number of parking spaces shall be equipped with EV charging stations. b. Regional and Local Regulations
Plan Bay Area 2050
Plan Bay Area 2050 is a State-mandated, integrated long-range transportation, land-use, and housing plan, known as an RTP/SCS, that would support a growing economy, provide more housing and transportation choices and reduce transportation-related pollution in the nine-county San Francisco Bay Area. Plan Bay Area 2050 builds on earlier efforts to develop an efficient transportation network and grow in a financially and environmentally responsible way. Plan Bay 427
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Area 2050 focuses on advancing equity and improving resiliency in the Bay Area by creating strategies in the following four elements: Housing, Economy, Transportation, and Environment. The Plan discusses how the future is uncertain due to anticipated employment growth, lack of housing options, and outside forces, such as climate change and economic turbulence. These uncertainties will impact growth in the Bay Area and exacerbate issues for those who are historically and systemically marginalized and underserved and excluded. Thus, Plan Bay Area 2050 has created strategies and considered investments that will serve those systemically underserved communities and provide equitable opportunities. The Plan presents a total of 35 strategies to outline how the $1.4 trillion dollar investment would be utilized. The strategies include, but are not limited to, the following: providing affordable housing, allowing higher-density in proximity to transit-corridors, optimizing the existing roadway network, creating complete streets, providing subsides for public transit, reducing climate emissions, and expanding open space area. To bring these strategies to fruition, it will require participation by agencies, policymakers, and the public. An implementation plan is also included as part of the Plan to assess the requirements needed to carry out the strategies, identify the roles of pertinent entities, create an appropriate method to implement the strategies, and create a timeline for implementation.

Napa Valley Transportation Authority
The Napa Valley Transportation Authority (NVTA) is a Congestion Management Agency (CMA) formed in 1998 as a joint power authority between the cities of American Canyon, Calistoga, Napa, St. Helena, the town of Yountville, and the County of Napa. NVTA serves as the countywide transportation planning agency. NVTA also develops the long-range county transportation plan, which (along with similar plans from the other eight Bay Area counties) forms the “primary basis” for the RTP/SCS adopted by the Metropolitan Transportation Commission. In turn, the county transportation plan must consider the most recently adopted RTP/SCS to assure that the county transportation plans and the regional plan employ a common planning framework.

City of American Canyon Energy Efficiency Climate Action Plan The City of American Canyon Energy Efficiency Climate Action Plan (EECAP) was adopted to develop a coordinated approach to energy efficiency and GHG reductions within the community and local government. The EECAP provides feasible strategies and measures that cost-effectively reduce energy-related and GHG emissions. Additionally, the EECAP includes an inventory of GHG emissions from all sectors in the community for years 2005 and 2010, as well as forecasts of anticipated GHG emissions for years 2020 and 2035 under a business-as-usual scenario that takes into consideration current consumption patterns, as well as population and job projections.

City of American Canyon General Plan
The City of American Canyon adopted its General Plan in 1994, which contains objectives and policies that help address climate change and reduce the community’s GHG emissions at the local level and improve energy efficiency and conservation. Under Resolution 2021-60, the General Plan was updated September 7, 2021, to include additional climate change and adaptation policies. The following objectives and policies from the City’s General Plan are relevant to GHG emissions and energy conservation:
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Objective 1.37: Consider initiatives to reduce direct and indirect greenhouse gas (GHG) emissions from transportation sources, and from new, renovated, and existing development in the City.

Policy 1.37.6: Reduce vehicle engine idling in American Canyon by educating the broader community (i.e.: businesses, commuters, residents) on the greenhouse gas impacts caused by engine idling and implementing feasible commercial vehicle regulations.

Goal 8F: Reduce consumption of nonrenewable energy sources and support the development and utilization of new energy sources.

Objective 8.22: Minimize transportation-related energy consumption.

Policy 8.22.1: Encourage the development of mixed use, pedestrian friendly employment/residential centers that help minimize vehicle trips in American Canyon and contribute to a reduction in energy consumption.

Policy 8.22.2: Encourage the clustering of residential structures.

Policy 8.22.3: Require that Development Plans provide for linkages between bicycle and pedestrian circulation systems and transit and employment centers, in accordance with established areawide plans.

Policy 8.22.4: Maintain a system of traffic signals and controls that minimizes waiting time and vehicle speed changes through routes.

Policy 8.22.5: Require that Development Plans provide for High-Occupancy Vehicles (HOV) and public transportation, where feasible, through the provision of appropriate transit areas and park-and-ride locations along public transportation routes.

Objective 8.23: Reduce Energy consumption in buildings.

Policy 8.23.1: Require that developers employ energy-efficient subdivision and site planning methods as well as building design. Measures to be considered include building orientation and shading, landscaping, building reflectance, use of active and passive solar heating and hot water system, etc. In establishing these energy related design requirements, the City shall balance energy-efficient design with good planning principles.

Policy 8.23.2: Require that new City buildings be energy efficient.

Objective 8.24: Increase public awareness of energy conservation needs and means in order to encourage informed choices about energy conservation by the general public.

Policy 8.24.1: Cooperate with local utilities to provide energy conservation information to the public.

Policy 8.24.2: Develop public and/or public-private energy conservation educational programs for City employees and the public.

Objective 8.25: Increase the energy efficiency of City operations to save energy, reduce municipal costs, and provide an example to the private sector.

Policy 8.25.1: Introduce concepts of energy efficiency and lifecycle costing to City planning and operating decisions and to the design of all major City facilities. 429
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Policy 8.25.2: Work with other agencies and utility companies to develop safe, economical and renewable energy resources.

Policy 8.25.3: Consider participating in energy conservation demonstration projects and promoting the use of treatment technologies that provide for the reuse of waste and water treatment by products, such as sludge and methane gas.

In addition to the above General Plan policies related to GHG emissions and energy consumption, the City adopted a Climate Emergency Proclamation on November 16, 2021.

4.8.3 Impact Analysis
a. Significance Thresholds and Methodology
Significance Thresholds
Based on Appendix G of the CEQA Guidelines a project may be deemed to have a significant impact on GHG emissions if it would:

Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment; or
Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

Most individual projects do not generate sufficient GHG emissions to create a project-specific impact through a direct influence on climate change. However, physical changes caused by a project can contribute incrementally to cumulative effects that are significant, even if individual changes resulting from a project are limited. The issue of climate change typically involves an analysis of whether a project’s contribution towards an impact is cumulatively considerable. “Cumulatively considerable” means that the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, other current projects, and probable future projects (CEQA Guidelines, Section 15064[h][1]). The 2022 BAAQMD CEQA Air Quality Guidelines provides two plan level thresholds for determining the significance of GHGs. The two approaches are as follows:

Consistency with a qualified GHG reduction plan
Meets the State’s goals to reduce emissions to 40 percent below 1990 levels by 2030 and carbon neutrality by 2045
The City of American Canyon’s EECAP is not a qualified GHG reduction plan, since it contains targets only for 2020 and was adopted prior to the adoption of new targets contained in the 2017 Scoping Plan; therefore, the first approach is not feasible. As such, the City uses the second approach to determine the significance of GHGs for development facilitated by the project.

Methodology
Based on plan-level guidance from the 2022 BAAQMD CEQA Thresholds for Evaluating the Significance of Climate Impacts From Land Use Projects and Plans, GHG emissions associated with project implementation is discussed qualitatively by comparing the project to the 2022 BAAQMD GHG thresholds, namely whether policies work towards achieving carbon neutrality by 2045. In 430
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addition, the project is qualitatively compared to other applicable plans, policies, and regulations adopted for the purpose of reducing the emissions of GHGs.

In developing its 2022 GHG significance thresholds, BAAQMD analyzed what new land use development projects will require to achieve California’s long-term climate goal of carbon neutrality by 2045, thereby better representing what design elements new land use development projects need to incorporate to sufficiently contribute to achieving the State’s goal. As GHG emissions from the land use sector come primarily from building energy use and from transportation, these are the areas that need to be evaluated to determine whether the project can or will be carbon neutral.

With respect to building energy use, this can be achieved by replacing natural gas with electric power and by eliminating inefficient or wasteful electricity usage. These strategies will support California’s transition away from fossil fuel-based energy sources and will bring the project’s GHG emissions associated with building energy use down to zero because SB 100 incrementally requires greater proportions of in-state sales of electricity to be generated from renewable and carbon-free sources, ultimately requiring 100 percent of in-state electricity sales to be generated from carbonfree sources by 2045. With respect to transportation, projects need to be designed to reduce project-generated VMT and to provide sufficient EV charging infrastructure to support the adoption of EVs. BAAQMD’s 2022 significance thresholds for project design elements are listed below. If a land use development project cannot demonstrate consistency, then that project would result in a potentially significant impact related to GHG emissions.

Buildings:
i. The project will not include natural gas appliances or natural gas plumbing (in both residential and nonresidential development).
ii. The project will not result in any wasteful, inefficient, or unnecessary electrical usage as determined by the analysis required under CEQA Section 21100(b)(3) and Section 15126.2(b) of the State CEQA Guidelines.

Transportation:
i. Achieve compliance with off-street EV requirements in the most recently adopted version of CALGreen Tier 2.
ii. Achieve a 15 percent reduction in project-generated VMT per employee rate below the existing American Canyon rate.

As discussed in Chapter 4.15, Transportation, project-generated traffic is evaluated for whether it would conflict or be inconsistent with CEQA Guidelines Section 15064.3(b), which describes specific considerations for analyzing transportation impacts as amended on July 1, 2020, pursuant to SB 375.

SB 375 aims to better promote statewide policies that (a) combat climate change by reducing greenhouse gas emissions and particulates; (b) encourage infill development and a diversity of uses instead of sprawl; and (c) promote multi-modal transportation networks, providing clean, efficient access to destinations and improving public health through active transportation. Section 15064.3(b) states that VMT is “generally” the most appropriate measure of transportation impacts.

No particular methodology or metric is mandated by section 15064.3(b) and the methodology or metric is left to the lead agency, bearing in mind the criteria the legislature had in mind for determining the significance of transportation impacts in SB-743. These were expressed in Public Resource Code section 21099(b)(1), which states: “[t]hose criteria shall promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses.” The project’s VMT assessment utilized the American Canyon travel demand model to 431
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forecast the rate of VMT per employee for the project land uses at buildout under the following two scenarios:
 Scenario A: Existing plus Project Conditions
 Scenario B: Cumulative Conditions (with the project) based on Year 2045 citywide residential and commercial growth as well as projected regional land use growth The American Canyon travel demand model is a trip-based model. Therefore, VMT per employee was estimated based on the VMT associated with home-based work trips. VMT impacts would be considered potentially significant under either scenario if the forecasted rate of VMT per employee for the project were to exceed 85 percent of the existing rate of VMT per employee for jobs in American Canyon, based on the American Canyon travel demand model.

In terms of the potential for wasteful, inefficient, or unnecessary electrical usage as determined by the analysis required under CEQA Section 21100(b)(3) and CEQA Guidelines Section 15126.2(b), project energy impacts are addressed in Chapter 4.6, Energy. b. Project Impacts and Mitigation Measures
Threshold 1: Would the project generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment?
Threshold 2: Would the project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases? Impact GHG-1 THE PROJECT WOULD BE CONSISTENT WITH BAAQMD THRESHOLDS AFTER IMPLEMENTATION OF MITIGATION MEASURES GHG-1 THROUGH GHG-5. THIS IMPACT WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION.

Construction
Construction of the project would result in GHG emissions during construction, primarily from fuel consumption associated with heavy equipment, light-duty vehicles, machinery, and generators for lighting. Temporary grid power may also be provided to construction trailers or electric construction equipment that may result in indirect GHG emissions from energy generation. The project would utilize construction contractors that would be required to comply with applicable CARB regulations, such as accelerated retrofitting, repowering, or replacement of heavy-duty diesel on-road and offroad equipment. Construction contractors are required to comply with the provisions of CCR Title 13, sections 2449 and 2485, and CARB regulations, which prohibit diesel-fueled commercial and offroad vehicles from idling for more than five minutes, minimizing unnecessary GHG emissions.

Construction equipment would be subject to the USEPA Construction Equipment Fuel Efficiency Standard, which would minimize inefficient fuel consumption and thus GHG emissions. These construction equipment standards (i.e., Tier 4 efficiency requirements) are contained in 40 Code of Federal Regulations Parts 1039, 1065, and 1068. Pursuant to applicable regulatory requirements of CALGreen, the project would comply with construction waste management practices to divert construction and demolition debris from landfills. These practices would result in efficient use of energy during construction and, therefore, would minimize unnecessary GHG emissions.

Furthermore, in the interest of cost efficiency, construction contractors would not utilize fuel in a manner that is wasteful or unnecessary, which would also have the effect of minimizing GHG emissions.
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The use of GHG-reducing construction Best Management Practices (BMPs) is considered by the City to be a pragmatic and effective approach for the control of construction-related GHG emissions. The BAAQMD, in their 2017 CEQA Air Quality Guidelines, recommend that following construction BMPs for reducing GHG emissions:
 The use of alternative fueled construction vehicles and equipment for at least 15 percent of the fleet.
 The use of local building materials for at least 10 percent of materials.  The recycling and reuse of at least 50 percent of construction and demolition waste materials.

Pursuant to the 2022 BAAQMD CEQA Thresholds for Evaluating the Significance of Climate Impacts From Land Use Projects and Plans, BAAQMD does not recommend a construction-related climate impact threshold. According to BAAQMD, GHG emissions from construction represent a very small portion of a project’s lifetime GHG emissions. However, incorporation of feasible and applicable GHG-reducing construction BMPs serves herein as the basis for whether project construction would contribute its "fair share" of GHG emission reductions consistent with the legislative reduction targets codified by SB 32 and the State’s long-term climate goal of carbon neutrality by 2045. The California Supreme Court, in Center for Biological Diversity v. Department of Fish & Wildlife (2015) (62 Cal.4th 204, 220-223), explained that an approach by which a lead agency ascertains a proposed project’s “fair share” of required Statewide GHG reductions is a legitimate approach for formulating significance thresholds for GHG emissions. Under this approach, which here is focused on the project incorporating BAAQMD-recommended BMPs for construction-related emissions, the project would be considered to result in a potentially significant impact if project construction would not incorporate feasible and applicable GHG reducing construction BMPs including, at a minimum, those listed above. Mitigation Measure GHG-1 would require the implementation of BMPs during construction, including those identified by BAAQMD. As such, potentially significant construction impacts would be reduced to a less than significant level with Mitigation Measure GHG-1.

The proposed thresholds for land use projects are designed to address operational GHG emissions that represent the vast majority of project GHG emissions. Therefore, the primary evaluation of GHG emissions impacts associated with project implementation is focused on operational emissions, discussed below.

Operations
The project would result in GHG emissions during operation. The nature of GHG emissions would be typical of those associated with light industrial, commercial, and hotel uses. GHG emissions would result primarily from building energy usage and fuel consumption associated with vehicle trips.

Operational buildout is expected to be 2030.

Transportation
On-road transportation sources are based on passenger vehicle and truck trip generation rates and VMT (See Section 4.15, Transportation), including the proposed Newell Drive Extension. According to the VMT information, which is based on American Canyon travel demand model, the project would generate 25.2 VMT per employee under Existing plus Project conditions and 13.8 VMT per employee under Cumulative plus Project conditions, which would not exceed the established VMT threshold of 29.0 VMT per employee and VMT impacts would be less than significant. 433
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However, without requirements for electric vehicles and electric vehicle parking, the project would conflict with the BAAQMD threshold to meet CALGreen Tier 2 EV parking. Implementation of Mitigation Measure GHG-2 would ensure that CALGreen Tier 2 EV parking levels are provided, and that heavy-duty vehicles and off-road equipment associated with the industrial uses are electric.

Buildings
Future buildings developed under the project would be served by PG&E, which is required to increase its renewable energy procurement in accordance with SB 100 targets. SB 100 supports the reduction of GHG emissions from the electricity sector by accelerating the state’s Renewables Portfolio Standard Program. It requires electricity providers to increase procurement from eligible renewable energy resources to 33 percent of total retail sales by 2020, 60 percent by 2030, and 100 percent by 2045.

Pursuant to the BAAQMD thresholds, projects that include natural gas appliances or natural gas plumbing (in both residential and nonresidential development) would result in a potentially significant GHG impact. Implementation of Mitigation Measure GHG-3 would require that all new buildings include all-electric appliances and water heaters. In addition, Mitigation Measure GHG-4 would require that buildings be designed to meet the Tier 2 advanced energy efficiency requirements in the California Green Building Standards Code. Furthermore, Mitigation Measure GHG-5 would require that electricity for future buildings be supplied with 100 percent carbon-free electricity sources through the year 2045 with on-site photovoltaic solar.

Consistency with State GHG Reduction Plans
The project is a program-level document that guides land use and development within the project site. The CARB 2017 Climate Change Scoping Plan outlines a pathway to achieving the 2030 reduction targets set under SB 32, which are considered interim targets toward meeting the longterm 2045 carbon neutrality goal established by California Executive Order B-55-18. The CARB 2022 Scoping Plan outlines a path to achieving carbon neutrality, in addition to outlining a pathway to reduce anthropogenic GHG emissions by 85 percent below 1990 levels by 2045, set under AB 1279.

As described in the Methodology subsection in Section 4.8.3, Impact Analysis, GHG emissions associated with project implementation is discussed qualitatively by comparing the project to the 2022 BAAQMD GHG thresholds, namely whether policies work towards achieving carbon neutrality by 2045. Without mitigation, the project would not be consistent with the 2022 BAAQMD GHG thresholds and impacts would be potentially significant. However, as described below, with implementation of mitigation, the project would be consistent with the 2022 BAAQMD GHG thresholds, resulting in a less than significant impact after mitigation:
 The project would not include natural gas appliances or natural gas plumbing, after implementation of Mitigation Measure GHG-3
 The project would not result in wasteful, inefficient, or unnecessary electrical usage after implementation of Mitigation Measures GHG-4 and GHG-5.
 The project would achieve compliance with off-street EV requirements after implementation of Mitigation Measure GHG-2.
 The project would achieve a 15 percent reduction in project-generated VMT per employee rate below the existing American Canyon rate (see Section 4.15, Transportation). 434
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Mitigation Measures
GHG-1 Construction BMPs
Prior to the issuance of any grading permits, the project applicant shall provide the City of American Canyon with documentation (e.g., site plans) demonstrating project construction will include the following construction Best Management Practices (BMPs):
 At least 15 percent of the construction fleet for each project phase shall be alternatively fueled or electric.
 At least 10 percent of building materials used for project construction shall be sourced from local suppliers.
 At least 65 percent of construction and demolition waste materials shall be recycled or reused.  At least one contractor that has a business location in American Canyon shall be contracted for project construction.
 All construction contracts shall include language that requires all off-road equipment with a power rating below 19 kilowatts (e.g., plate compactors, pressure washers) using during construction be electrically powered.
 Architectural coatings used for project construction shall be “Low-VOC,” containing no greater than 50 grams of volatile organic compounds (VOC) per liter of product.  Project construction shall prohibit the use of generators and shall establish grid power connection to electrical equipment needs.
 Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes (as required by the California Airborne Toxics Control Measure [ATCM] Title 13, Section 2485 of California Code of Regulations). Clear signage regarding idling restrictions shall be provided for construction workers at all access points.  All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation.  The prime construction contractor shall post a publicly visible sign with their telephone number and contractor to contact. The construction contractor shall take corrective action within 48 hours. The BAAQMD’s phone number shall also be identified and visible to ensure compliance with applicable regulations.

GHG-2 Electric Vehicle Charging Stations
Prior to issuance of any building permits, the project applicant shall demonstrate to the satisfaction of the City (e.g., shown on-site plans), that the proposed parking areas for passenger automobiles and trucks are designed and will be built to accommodate electric vehicle (EV) charging stations. At a minimum, the parking shall be designed to accommodate EV charging stations equal to the Tier 2 Nonresidential Voluntary Measures of the California Green Building Standards Code, Section A5.106.5.3.2.

Prior to the issuance of any building permits, the project applicant shall demonstrate to the satisfaction of the City (e.g., shown on-site plans), that each loading dock is outfitted with at least one 240-volt outlet to accommodate truck and Transport Refrigeration Unit (TRU) charging and/or electrical power connection while trucks are loading and unloading goods. 435
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GHG-3 All Electric Buildings
Prior to the issuance of any building permits, the project applicant shall provide the City with documentation (e.g.,site plans) demonstrating the project is designed without the use of any natural gas-fueled appliances or natural gas plumbing.

GHG-4 Tier 2 Advanced Energy Efficiency Requirements
Prior to issuance of any building permits, the project applicant shall demonstrate to the satisfaction of the City (e.g., shown on-site plans), that the proposed buildings are designed and will be built to, at a minimum, the Tier 2 advanced energy efficiency requirements of the Nonresidential Voluntary Measures of the California Green Building Standards Code, Division A5.2, Energy Efficiency, as outlined under Section A5.203.1.2.2.

GHG-5 Carbon-Free Electricity Sources
Prior to the issuance of any building permit for the project, the project applicant shall provide the City with documentation (e.g., site plans) demonstrating to the City’s satisfaction that electricity demand will be supplied with 100 percent carbon-free electricity sources through the year 2045 with on-site photovoltaic solar.

Significance After Mitigation
Implementation of Mitigation Measures GHG-1 through GHG-5 would ensure that GHG impacts would be less than significant.

4.8.4 Cumulative Impacts
“Cumulatively considerable” means that the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, other current projects, and probable future projects (CEQA Guidelines Section 15355). Most projects do not generate sufficient GHG emissions to create a project-specific impact through a direct influence on climate change.

Therefore, climate change analysis for the project involved an analysis of whether the project’s contribution toward an impact would be cumulatively considerable. In addition, the project is cumulative in nature as it represents growth through the annexed area because of future development. The project is not one individual project. A number of as yet undefined future projects may occur due to the annexation associated with the project. Therefore, cumulative impacts with respect to GHG emissions represents emissions associated with buildout of individual projects and thus cumulative emissions. Because emissions facilitated by the project would be consistent with BAAQMD GHG thresholds, it would be consistent with State GHG reduction plans.

Therefore, the project’s contribution to cumulative impacts with respect to GHG emissions would be less than cumulatively considerable.
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4.9 Hazards and Hazardous Materials
This section analyzes potential impacts relating to hazards and hazardous materials in the soil, groundwater, and existing structures associated with development facilitated by the project.

Geologic hazards are discussed in Section 4.7, Geology and Soils.

4.9.1 Setting
a. Hazardous Materials
A material is considered hazardous if it appears on a list of hazardous materials from a federal, State, or local agency, or if it has characteristics defined as hazardous by an agency. A hazardous waste is defined in Title 22, Section 66261.10 of the California Code of Regulations (CCR) as one that has a characteristic that may:

Cause, or significantly contribute to, an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness; or pose a substantial present or potential hazard to human health or the environment when it is improperly treated, stored, transported, disposed of or otherwise managed.

Chemical and physical properties cause a substance to be considered hazardous. Such properties include toxicity, ignitability, corrosiveness, and reactivity. Sections 66261.20 through 66261.24 of Title 22 of the CCR defines the properties for hazardous waste and may be used to define characteristics of a hazardous material. The release of hazardous materials or hazardous wastes into the environment can contaminate soils, surface water, and groundwater supplies. The types of hazardous materials are defined below:
 Toxic Substances. Toxic substances may cause short-term or long-lasting health effects, ranging from temporary effects to permanent disability, or even death. For example, such substances can cause disorientation, acute allergic reactions, asphyxiation, skin irritation, or other adverse health effects if human exposure exceeds certain levels (the level depends on the substances involved and is chemical-specific). Carcinogens, substances that can cause cancer, are a special class of toxic substances. Examples of toxic substances include benzene (a component of gasoline and suspected carcinogen) and methylene chloride (a common laboratory solvent and a suspected carcinogen).
 Ignitable Substances. Ignitable substances are hazardous because of their ability to burn.

Gasoline, hexane, and natural gas are examples of ignitable substances.  Corrosive Materials. Corrosive materials can cause severe burns. Corrosives include strong acids and bases such as sodium hydroxide (lye) or sulfuric acid (battery acid).  Reactive Materials. Reactive materials may cause explosions or generate toxic gases. Explosives, pure sodium or potassium metals (which react violently with water), and cyanides are examples of reactive materials.

Soil and groundwater can become contaminated by hazardous material releases in a variety of ways, including permitted or illicit use and accidental or intentional disposal or spillage. Before the 1980s, most land disposal of chemicals was unregulated, resulting in numerous industrial properties and public landfills becoming dumping grounds for unwanted chemicals. The largest and most contaminated of these sites became Superfund sites, named for their eligibility to receive cleanup 437
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money from a federal fund established under the Comprehensive Environmental Response, Compensation, and Liability Act. The National Priorities List (NPL) is the list of national priorities among the known releases or threatened releases of hazardous substances, pollutants, or contaminants throughout the United States and its territories. The NPL is intended primarily to guide the U.S. Environmental Protection Agency (USEPA) in determining which sites warrant further investigation. Sites are added to the NPL following a hazard ranking system.

Numerous smaller properties have been designated as contaminated sites. Often these are gas station sites where leaking underground storage tanks (LUSTs) were upgraded under a federal requirement in the late 1980s. Another category of sites that may have some overlap with the types already mentioned is “brownfields” – previously used, often abandoned, sites that due to actual or suspected contamination are undeveloped or underused. Both the USEPA and California Department of Toxic Substances Control (DTSC) maintain lists of known brownfields sites. These sites are often difficult to inventory due to their owners’ reluctance to publicly label their property as potentially contaminated. The known hazardous materials release sites pertinent to the project are described in the Hazardous Materials Sites section below.

Asbestos Containing Materials
Asbestos is a naturally occurring fibrous material that was widely used in structures built between 1945 and 1978 for its fireproofing and insulating properties. Asbestos-containing materials (ACM) were banned by the USEPA between the early 1970s and 1991 under the authority of the federal Clean Air Act (CAA) and the Toxic Substances Control Act (TSCA) due to their harmful health effects.

Exposure to asbestos increases risk of developing lung disease, such as lung cancer, mesothelioma, or asbestosis (USEPA 2022a). Common ACMs include vinyl flooring and associated mastic, wallboard and associate joint compound, plaster, stucco, acoustic ceiling spray, ceiling tiles, heating system components, and roofing materials. Pre-1973 commercial and industrial structures are required to implement asbestos regulations if damage occurs, or if remodeling, renovation, or demolition activities disturb ACMs.

Lead and Lead-Based Paint
Lead is a naturally occurring metallic element. Because of its toxic properties, lead is regulated as a hazardous material. Excessive exposure to lead can result in the accumulation of lead in the blood, soft tissues, and bones. Children are particularly susceptible to potential lead-related health problems because it is easily absorbed into developing systems and organs. Lead can affect almost every organ and system in the body. In children, lead can cause behavior and learning problems, lower IQ and hyperactivity, hearing problems, and anemia. In adults, lead can cause cardiovascular effects, decreased kidney function, and reproductive problems. In addition, lead can result in serious effects to the developing fetus and infant for pregnant women (USEPA 2022b). Among its numerous uses and sources, lead can be found in paint, water pipes, solder in plumbing systems, and in soils surrounding buildings and structures that are painted with lead-based paint (LBP). LBP was primarily used during the same period as ACMs. Pre-1978 commercial and industrial structures are required to implement LBP regulations if the paint is in a deteriorated condition or if remodeling, renovation, or demolition activities disturb LBP surfaces.

Agricultural Chemicals
Many farms use agricultural chemicals such as pesticides and inorganic fertilizers. Sensitive receptors such as residential or school uses in proximity to agricultural uses that use pesticides may 438
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be exposed to increased health risks. Regulated commercial applications of pesticides are documented in an annual report submitted to Napa County. Disturbance of soils with residual quantities of agricultural chemicals due to historic agricultural use can also pose health threats. The northern portion of the project site has previously been in agricultural use. b. Existing Conditions
Hazardous Materials Sites
The locations where hazardous materials are used, stored, treated and/or disposed of comes to the attention of regulatory agencies through various means, including licensing and permitting, enforcement actions, and anonymous tips. To the extent possible, the locations of these businesses and operations are recorded in database lists maintained by various State, federal, and local regulatory agencies. In addition, federal, State, and local agencies enforce regulations applicable to hazardous waste generators and users, and the Napa County Environmental Health Division tracks and inspect hazardous materials handlers to ensure appropriate reporting and compliance.

Permitted uses of hazardous materials include those facilities that use hazardous materials or handle hazardous wastes in accordance with current hazardous materials and hazardous waste regulations. The use and handling of hazardous materials from these sites is considered low risk, although there can be instances of unintentional chemical releases. In such cases, the site would be tracked in the environmental databases as an environmental case. Permitted sites without documented releases are, nevertheless, potential sources of hazardous materials in the soil and/or groundwater due to accidental spills, incidental leakage, or spillage that may have gone undetected.

Some facilities are permitted for more than one hazardous material use and, therefore, could appear in more than one database.

The potential to encounter hazardous materials in soil and groundwater in the city is based on federal, State, and local regulatory databases that identify permitted hazardous materials uses, environmental cases, and spill sites. The DTSC EnviroStor database contains information on properties in California where hazardous substances have been released or where the potential for a release exists. The California State Water Resources Control Board (SWRCB) GeoTracker database contains information on properties in California for sites that require cleanup, such as LUST sites, which may impact water quality, including groundwater.

According to databases of hazardous material sites maintained by the DTSC (EnviroStor) and the SWRCB (GeoTracker), there are no sites within the project site that are still active or need further investigation (DTSC 2022; SWRCB 2022). The nearest registered DTSC or SWRCB site is located approximately 350 feet south of the project site at Napa Junction Road and is an active voluntary cleanup called Canyons Crossing (DTSC 2022).

Use, Transport, and Abatement of Hazardous Materials
The use of hazardous materials is typically associated with industrial land uses. Activities such as manufacturing, plating, cleaning, refining, and finishing frequently involve chemicals that are considered hazardous when accidentally released into the environment.

To a lesser extent, hazardous materials may also be used by various commercial enterprises, as well as residential uses. In particular, dry cleaners use cleaning agents considered to be hazardous materials. Hardware stores typically stock paints and solvents, as well as fertilizers, herbicides, and pesticides. Swimming pool supply stores stock acids, algaecides, and caustic agents. Most 439
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commercial businesses occasionally use commonly available cleaning supplies that, when used in accordance with manufacturers’ recommendations, are considered safe by the State of California, but when not handled properly can be considered hazardous. Private residences also use and store commonly available cleaning materials, paints, solvents, swimming pool and spa chemicals, as well as fertilizers, herbicides, and pesticides.

If improperly handled, hazardous materials can result in public health hazards through human contact with contaminated soils or groundwater, or through airborne releases in vapors, fumes, or dust. There is also the potential for accidental or unauthorized releases of hazardous materials that would pose a public health concern. The use, transport, and disposal of hazardous materials and wastes are required to occur in accordance with federal, State, and local regulations. In accordance with such regulations, the transport of hazardous materials and wastes can only occur with transporters who have received training and appropriate licensing. Additionally, hazardous waste transporters are required to complete and carry a hazardous waste manifest, which includes forms, reports, and procedures designed to seamlessly track hazardous waste.

Hazardous materials used and generated in the project site and their waste would be transported via major regional routes, such as State Route (SR) 29, SR 12, SR 37, and Interstate 80. The City does not have direct authority over the transport of hazardous materials on the major roads. Instead, the US Department of Transportation (DOT) and California Highway Patrol (CHP) regulate transportation of hazardous materials by truck.

Schools
School locations require consideration because children are particularly sensitive to hazardous materials exposure. Additional protective regulations apply to projects that could use or disturb potentially hazardous products near or at schools. The California Public Resources Code requires projects that would be located within 0.25 mile of a school and might reasonably be expected to emit or handle hazardous materials to consult with the school district regarding potential hazards.

There are no schools within 0.25 mile of the project site. The nearest school, Napa Junction Magnet Elementary School, is approximately 1 mile southwest of the project site.

Aviation Hazards
There are no public or private airports in American Canyon; however, the Napa County Airport is located approximately 1.2 miles northwest of the project site. The project site is mostly in Zone D of the Napa County Airport’s sphere of influence. All residential uses and uses hazardous to flight are prohibited in Zone D. A small portion of the southern part of the project site is in Zone E, which prohibits noise-sensitive outdoor uses. Figure 4.9-1 shows the Napa County Airport’s sphere of influence zones. The Napa County Airport and its Airport Land Use Compatibility Plan (ALUCP) is discussed further in Section 4.9.2, Regulatory Setting.

Landfills
No active landfills exist within the city (California Department of Resources, Recycling, and Recovery [CalRecycle] 2022). American Canyon Sanitary Landfill, located just west of the city, was closed in 1995. The closest active landfill to the city is the Potrero Hills Compost Facility (SWIS Number 48-AA0084), located approximately 15 miles east of the project site (CalRecycle 2022). 440
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Figure 4.9-1 Napa County Airport Compatability Zones
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4.9.2 Regulatory Setting
a. Federal Regulations
Toxic Substances Control Act (1976) and the Resource Conservation and Recovery Act of 1976 (RCRA)
These acts established a program administered by the USEPA for the regulation of the generation, transportation, treatment, storage, and disposal of hazardous waste. RCRA was amended in 1984 by the Hazardous and Solid Waste Act, which affirmed and extended the “cradle to grave” system of regulating hazardous wastes. Among other items, the use of certain techniques for the disposal of some hazardous wastes was specifically prohibited by the Hazardous and Solid Waste Act.

Comprehensive Environmental Response, Compensation, and Liability Act The Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) introduced active federal involvement to emergency response, site remediation, and spill prevention, most notably the Superfund program. The Act was intended to be comprehensive in encompassing both the prevention of and response to uncontrolled hazardous substances releases.

The Act deals with environmental response, providing mechanisms for reacting to emergencies and to chronic hazardous material releases. In addition to establishing procedures to prevent and remedy problems, it establishes a system for compensating appropriate individuals and assigning appropriate liability. It is designed to plan for and respond to failure in other regulatory programs and to remedy problems resulting from action taken before the era of comprehensive regulatory protection.

Transportation of Hazardous Materials
The Hazardous Materials Transportation Act of 1974, as amended, is the basic statute regulating hazardous materials transportation in the United States. Transportation of hazardous materials is regulated by the United States Department of Transportation (USDOT) Office of Hazardous Materials Safety. The Office of Hazardous Materials Safety formulates, issues, and revises hazardous materials regulations under the Federal Hazardous Materials Transportation Law. The hazardous materials regulations cover hazardous materials definitions and classifications, hazard communications, shipper and carrier operations, training and security requirements, and packaging and container specifications. The hazardous materials transportation regulations are codified in 49 Code of Federal Regulations Parts 100-185.

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.
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Lead-Based Paint Elimination Final Rule (24 Code of Federal Regulations) Governed by the U.S. Housing and Urban Development, regulations for LBP are contained in the Lead-Based Paint Elimination Final Rule 24 Code of Federal Regulations (CFR) 33, which requires sellers and lessors to disclose known LBP and LBP hazards to perspective purchasers and lessees.

Additionally, all LBP abatement activities must follow California and federal occupational safety and health administrations. Administrators in California are the California Occupational Safety and Health Administration (CalOSHA) and California Department of Health Services. The federal administrator is the Occupational Safety and Health Administration (OSHA). Only LBP trained and certified abatement personnel can perform abatement activities. All LBP removed from structures must be hauled and disposed of by a transportation company licensed to transport this type of material at a landfill or receiving facility licensed to accept the waste.

Regulations to manage and control exposure to LBP are also described in CFR Title 29, Section 1926.62; and CCR Title 8 Section 1532.1. These regulations cover the demolition, removal, cleanup, transportation, storage, and disposal of lead-containing material. The regulations outline the permissible exposure limit, protective measures, monitoring, and compliance to ensure the safety of construction workers exposed to lead-based materials. CalOSHA’s Lead in Construction Standard requires project proponents to develop and implement a lead compliance plan when LBP would be disturbed during construction. The plan must describe activities that could emit lead, methods for complying with the standard, safe work practices, and a plan to protect workers from exposure to lead during construction activities. CalOSHA requires 24-hour notification if more than 100 square feet of LBP would be disturbed.

U.S. Environmental Protection Agency
The USEPA is the agency primarily responsible for enforcement and implementation of federal laws and regulations pertaining to hazardous materials. Applicable federal regulations pertaining to hazardous materials are contained in the CFR Titles 29, 40, and 49. Hazardous materials, as defined in the CFR, are listed in 49 CFR 172.101. The management of hazardous materials is governed by the following laws:

1. RCRA of 1976 (42 USC [US Code] 6901 et seq.); Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (also called the Superfund Act) (42 USC 9601 et seq.)

2. Federal Insecticide, Fungicide, and Rodenticide Act (7 USC 136 et. Seq.)

3. Superfund Amendments and Reauthorization Act of 1986 (Public Law 99 499) These laws and associated regulations include specific requirements for facilities that generate, use, store, treat, and/or dispose of hazardous materials. USEPA provides oversight and supervision for federal Superfund investigation/remediation projects, evaluates remediation technologies, and develops hazardous materials disposal restrictions and treatment standards.

Asbestos Regulations
The USEPA regulations under Title 40 CFR Part 61 regulate the removal and handling of ACMs. The statute is implemented by the Bay Area Air Quality Management District (BAAQMD). The federal Occupational Safety and Health Administration also has a survey requirement under Title 29 CFR that is implemented by CalOSHA under Title 8 California Code Regulations. These regulations require facilities to take all necessary precautions to protect employees and the public from exposure to asbestos.
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b. State Regulations
At the State level, agencies such as CalOSHA, the Office of Emergency Services (OES), and the Department of Health Services (DHS) have rules governing the use of hazardous materials that parallel federal regulations and are sometimes more stringent. DTSC is the primary State agency governing the storage, transportation, and disposal of hazardous wastes. DTSC is authorized by the USEPA to enforce and implement federal hazardous materials laws and regulations. DTSC has oversight of Annual Work Plan sites (commonly known as State Superfund sites), sites designated as having the greatest potential to affect human health and the environment.

The primary California State laws for hazardous waste are the California Hazardous Waste Control Law, which is the State equivalent of the Resource Conservation and Recovery Act, and the Carpenter-Presley-Tanner Hazardous Substance Account Act, which is the State equivalent of Comprehensive Environmental Response, Compensation, and Liability Act. State hazardous materials and waste laws are in the CCR Titles 22 and 26. The State regulation concerning the use of hazardous materials in the workplace is included in Title 8 of the California Code Regulations.

Cortese List
Government Code Section 65962.5 requires the DTSC, the State Department of Health Services, the SWRCB, and CalRecycle to compile and annually update lists of hazardous waste sites and land designated as hazardous waste sites throughout the state. The Secretary for Environmental Protection consolidates the information submitted by these agencies and distributes it to each city and county where sites on the lists are located. Before the lead agency accepts an application for any development project as complete, the applicant must consult these lists to determine if the site at issue is included.

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).

Hazardous Materials Worker Safety
Cal/OSHA and the Federal 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 Sections 337-340, Chapter 3.2). The regulations specify requirements for employee training, availability of safety equipment, accident prevention programs, and hazardous substance exposure warnings.

Department of Toxic Substances Control
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identifies ways to reduce hazardous waste produced in California. DTSC regulates hazardous waste in California primarily under the authority of RCRA and the California Health and Safety Code.

DTSC also administers the California Hazardous Waste Control Law (HWCL) to regulate hazardous wastes. While the HWCL is generally more stringent than RCRA, until the USEPA approves the California program, both 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.

If any soil is excavated from a site containing hazardous materials, it would be considered a hazardous waste if it exceeded specific criteria identified by the DTSC in Title 22, Division 4.5 Section 66261.10 of the CCR. Remediation of hazardous wastes found at a site may be required if excavation of these materials is performed, or if other soil disturbing activities would occur. Even if soil or groundwater at a contaminated site does not have the characteristics required to be defined as hazardous waste, remediation of the site may be required by regulatory agencies subject to jurisdictional authority. Cleanup requirements are determined on a case-by-case basis by the agency taking jurisdiction.

California Fire Code
CCR Title 24, also known as the California Building Standards Code, contains the California Fire Code (CFC), included as Part 9 of that Title. Updated every three years, the CFC 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 Pesticide Regulation, Department of Food and Agriculture, and the Department of Public Health
The California Department of Pesticide Regulations, a division of the California Environmental Protection Agency, in coordination with the California Department of Food and Agriculture, and the California Department of Public Health have the primary responsibility to regulate pesticide use, vector control, food, and drinking water safety. The Department of Pesticide Regulations registers pesticides, and pesticide use is tracked by the County. Title 22 is used to regulate both small and large California Department of Public Health water systems.

Handling and Storage of Hazardous Waste
The handling and storage of hazardous materials is regulated on the federal level by the United States Environmental Protection Agency 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 through 25543.3, facilities handling 445
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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 required to prepare a Risk Management Plan and California Accidental Release Plan, which provide information on the potential impact zone of a worst-case release and requires plans and programs designed to minimize the probability of a release and mitigate potential impacts.

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 DTSC. Unless specifically exempt, 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 Regional Water Quality Control Boards (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 hazardous materials in USTs is regulated by the State Water Board, which oversees the nine RWQCBs.
c. Local Regulations
Napa County Division of Environmental Health
The Napa County Division of Environmental Health (NCDEH) is the Certified Unified Program Agency (CUPA) for pollution prevention in all cities, towns and areas of Napa County including American Canyon. The NCDEH provides regulatory oversight over hazardous materials and hazardous waste programs in the city, unincorporated areas and other cities in Napa County. As the CUPA, the NCDEH operates the following programs: Hazardous Waste Generator, Underground Storage Take (UST), Aboveground Petroleum Act (APSA), Hazardous Materials Business Plan (HMBP)/Hazardous Materials Inventory Statement, California Accidental Release Prevention Program, Technical Reference for Emergency Response, Napa County Area Plan, Methamphetamine Contaminated Property Cleanup Act of 2005, Stormwater Management & Control, Abandoned Vehicle Abatement, Remediation Oversight of Contaminated Properties, and Safe Drinking Water and Toxic Enforcement Act of 1986 (Napa County 2022).
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Napa County Airport Land Use Compatibility Plan
The ALUCP governs land use around Napa County Airport. 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 of 35 feet above the ground for objects located within Zone D. Additional height may be permitted under Special Use Permit procedures and approval from the Napa County Airport Land Use Commission (ALUC) as provided for in the Napa County Airport Safety Ordinance 416. 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 The ALUCP follows Noise Compatibility Guidelines, as included in Table 2-1 of the ALUCP (Napa County ALUC 1991). New residential uses are not permitted within Zone D without ALUC review.

However, the City entered a Settlement Agreement with the ALUC on May 3, 2022. The Settlement Agreement provides that the City will not recommend for approval any application for a residential use in Zone D until an amendment to the ALUCP has been approved or December 31, 2023, whichever occurs first. The Settlement Agreement does not prohibit the City from processing an application for a residential proposal within Zone D.

Napa County Operational Area Multi-Jurisdictional Hazard Mitigation Plan In 2020, the Napa County prepared an updated Multi-Jurisdictional Hazard Mitigation Plan (HMP) to guide County and City Officials and Special Districts Managers in protecting the people and property within the County from the effects of natural disasters and hazards events. The HMP provides an explanation of prevalent hazards within the County and how hazards may affect the County and participating cities and special districts differently based upon proximities to natural hazards. The HMP also identifies risks to vulnerable assets, both people and property. Most importantly, the mitigation strategy presented in the HMP responds to the identified vulnerabilities within each community and provides prescriptions or actions to achieve the greatest risk reduction based upon available resources.

Napa County Emergency Operations Plan
Napa County updated its Emergency Operations Plan (EOP) in 2017 in coordination with the City of American Canyon, City of Calistoga, and Town of Yountville. The EOP addresses the County’s planned response to extraordinary emergency situations associated with natural disasters, technological incidents, and national security emergencies. The EOP is comprised of two main components that 1) describe the overall organizational and operational concepts relative to response and recovery and provide an overview of potential hazards and 2) describe the emergency response organization, action checklists, and reference material. The EOP addresses the following topics: active shooter, civil unrest, dam inundation and earthquakes, flooding, hazardous materials, landslides, major air crash, public health emergencies, terrorism, transportation- trucking, and wildfires and windstorms.
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City of American Canyon General Plan
The City of American Canyon General Plan (1994) 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 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 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.

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.

American Canyon Municipal Code
The Municipal Code affirms the City’s use of uniform standards, which contain provisions such as the Uniform Fire Code, California Health and Safety Code, and Uniform Building Code, and that regulations are administered by appropriate local agencies.

4.9.3 Impact Analysis
a. Significance Thresholds and Methodology
Significance Thresholds
In accordance with Appendix G of the CEQA Guidelines, hazards and hazardous materials impacts from development facilitated by the project would be significant if the development would:

Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials;
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;
Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school; 448
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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 create a significant hazard to the public or the environment;
For a project located within 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, result in a safety hazard or excessive noise for people residing or working in the project area; or Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan.

Appendix G of the CEQA Guidelines also includes the question regarding if the project would expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires. This potential impact is addressed in Section 4.18, Wildfire.

Methodology
This section describes the potential environmental impacts of the project, relevant to hazards and hazardous materials. The impact analysis is based on an assessment of baseline conditions, including locations of hazardous materials, existing contaminated sites, and emergency response and evacuation plan requirements. This analysis identifies potential impacts based on the predicted interaction between the affected environment and construction, operation, and maintenance activities related to the development that would be facilitated by the project. However, the precise increase in hazardous materials transported within the project site and the greater region in and around the City of American Canyon, as a result of buildout of the project cannot be predicted because specific development projects are not yet identified at a level of detail allowing such analysis. This analysis focuses on the potential nature and magnitude of risks associated with the accidental release, storage, transportation, and use of hazardous materials during operations of typical industrial, commercial, and visitor-serving/hotel development projects. b. Project Impacts and Mitigation Measures
Threshold 1: Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Threshold 2: Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
Impact HAZ-1 DEVELOPMENT FACILITATED BY THE PROJECT COULD INVOLVE THE USE, STORAGE, DISPOSAL, OR TRANSPORTATION OF HAZARDOUS MATERIALS. UPSET OR ACCIDENT CONDITIONS IN THE PROJECT SITE COULD INVOLVE THE RELEASE OF HAZARDOUS MATERIALS INTO THE ENVIRONMENT. HOWEVER, IMPLEMENTATION OF MITIGATION MEASURE HAZ-1 WOULD ENSURE THAT IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Construction
Development facilitated by the project could include new buildings, as well as improvements in the public realm, such as street, sidewalk, and the Newell Drive Extension. The following discussion addresses the use of hazardous materials during construction activities; the potential for release of 449
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existing contaminated materials during construction; and the potential for release of LBP or ACM during demolition or construction.

Use of Hazardous Materials During Construction
Development facilitated by the project may include the temporary transport, storage, and use of potentially hazardous materials including fuels, lubricating fluids, cleaners, or solvents. If spilled, these substances could pose a risk to the environment and to human health. However, the transport, storage, use, or disposal of hazardous materials would be subject to federal, State, and local regulations pertaining to the transport, use, storage, and disposal of hazardous materials, which would assure that risks associated with hazardous materials are minimized. The transport of hazardous materials would be subject to federal, State, and local regulations such as the Toxic Substances Control Act and the Resource Conversation and Recovery Act, Hazardous Waste Control Act, and the Napa County Operational Area Multi-Jurisdictional HMP, as discussed in Section 4.9.2, Regulatory Setting. Compliance with these regulations would assure that risks associated with the transport of hazardous materials are minimized and impacts associated with the use of hazardous materials during construction would be less than significant.

Release of Contaminated Materials During Construction
Potential health and environmental impacts related to contaminated groundwater and soil, such as those contaminated by pesticides from historic agricultural uses, may occur during excavation and dewatering for new construction throughout the project site. Development facilitated by the project would require project review by the City prior to issuance of grading and building permits. Upon project review, the City would determine if any special requirements apply based on site conditions.

In addition, development facilitated by the project would be subject to regulatory programs such as those overseen by the RWQCB and the DTSC. These agencies require applicants for development on potentially contaminated properties to perform investigation and cleanup if the properties are contaminated with hazardous substances. It is not currently known whether there is any contaminated groundwater or soil; however, due to the history of agricultural use, as well as its proximity to a railroad, there is some potential for contamination to be present. A potentially significant impact hazard could occur if any contaminated soil or groundwater is present on the project site. As such, Mitigation Measure HAZ-1 would be required to address this impact and would require the project applicants for future development, as well as the development of the Newell Drive Extension to implement a Phase I Environmental Site Assessment (ESA) and if necessary, a Phase II ESA. Implementation of a Phase I and Phase II ESA would ensure that any potential impacts from hazardous materials or contaminants are addressed prior to construction.

Grading or excavation on sites with existing contamination may also result in the transport and disposal of hazardous materials if they are unearthed and removed from the site. However, the transport, storage, use, or disposal of hazardous materials would be subject to federal, State, and local regulations pertaining to the transport, use, storage, and disposal of hazardous materials, such as the Toxic Substances Control Act and the Resource Conversation and Recovery Act, Hazardous Waste Control Act, and the Napa County Operational Area Multi-Jurisdictional HMP, as discussed in Section 4.9.2, Regulatory Setting. Compliance with these regulations would assure that risks associated with hazardous materials are minimized and impacts would be less than significant. 450
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Asbestos and Lead
The project site has the potential to contain buildings that, due to their age, may contain asbestos and/or LBP. Demolition or redevelopment of these structures could result in health hazard impacts to workers if not remediated prior to construction activities. Lead-based materials and asbestos exposure are regulated by CalOSHA. CCR Section 1532.1 requires testing, monitoring, containment, and disposal of lead-based materials, such that exposure levels do not exceed CalOSHA standards.

Under this rule, construction workers (and by extension, neighboring properties) may not be exposed to lead at concentrations greater than 50 micrograms per cubic meter of air averaged over an eight-hour period, and exposure must be reduced to lower concentrations if the workday exceeds eight hours. Similarly, CCR Section 1529 sets requirements for asbestos exposure assessments and monitoring, methods of complying with exposure requirements, safety wear, communication of hazards, and medical examination of workers.

The control of ACM during demolition or renovation of buildings is regulated under the Federal Clean Air Act. The Federal Clean Air Act requires a thorough inspection for asbestos where demolition will occur and specifies work practices to control emissions, such as removing all asbestos-containing materials, adequately wetting all regulated asbestos-containing materials, sealing the material in leak tight containers, and disposing of the asbestos-containing waste material as expediently as practicable (USEPA 2022c).

Friable ACMs are regulated as a hazardous air pollutant under the Clean Air Act. As a worker safety hazard, they are also regulated under the authority of CalOSHA and by BAAQMD. In structures that would be demolished, any ACMs would be abated in accordance with State and Federal regulations prior to the start of demolition or renovation activities, and in compliance with all applicable existing rules and regulations, including BAAQMD rules. These programs would ensure that asbestos removal would not result in the release of hazardous materials to the environment that could impair human health.

Development facilitated by the project would also be required to adhere to BAAQMD Regulation 11, Rule 2, which governs the proper handling and disposal of ACM for demolition, renovation, and manufacturing activities in the Bay Area, and CalOSHA regulations regarding lead-based materials.

CCR Section 1532.1, requires testing, monitoring, containment, and disposal of lead-based materials, such that exposure levels do not exceed CalOSHA standards. With adherence to standard conditions of approval, BAAQMD, and CalOSHA policies regarding ACM and LBP, impacts would be less than significant.

Operation
Development facilitated by the project could involve the use, storage, disposal, or transportation of hazardous materials. Some of the potential commercial uses and visitor-serving/hotel uses do not generally involve the use, storage, disposal, or transportation of significant quantities of hazardous materials. They may involve use and storage of some materials considered hazardous, though these materials would be primarily limited to solvents, paints, chemicals used for cleaning and building maintenance, and landscaping supplies. These materials would not be different from household chemicals and solvents already in wide use throughout the city and project site. Residents and workers are anticipated to use limited quantities of products that could contain hazardous materials routinely for periodic cleaning, repair, and maintenance, or for landscape maintenance/pest control.

Those using such products would be required to comply with all applicable regulations regarding the disposal of household waste.
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The Newell Drive Extension may be used to transport hazardous materials. Nonetheless, the transport of hazardous materials would be subject to federal, State, and local regulations, including the Toxic Substances Control Act and the Resource Conversation and Recovery Act, Hazardous Waste Control Act, and the Napa County Operational Area Multi-Jurisdictional HMP, as discussed in Section 4.9.2, Regulatory Setting.

The proposed pre-zoning for sites in the project site includes industrial uses. The project could, therefore, introduce new manufacturing, warehouse, or industrial uses that would sell, use, store, transport, or release substantial quantities of hazardous materials. Businesses that handle certain chemicals over threshold quantities are required to abide by NCDEH programs, such as preparation of a HMBP/Hazardous Materials Inventory Statement. The HMBP consists of general business information; basic information on the location, type, quantity, and health risks of hazardous materials; and emergency response and training plans. Hazardous materials must be reported in a HMBP if they are handled in quantities equal or greater than 55 gallons of a liquid, 200 standard cubic feet of a compressed gas, or 500 pounds of a solid. Mandatory reporting in HMBPs would reduce the potential hazard to workers and the general public near industrial development from reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. Similarly, the HMBP would prevent or significantly reduce risks other uses located within proximity to industrial development facilitated by the project.

For those employees that would work with hazardous materials, the amounts of hazardous materials that are handled at any one time are generally small, reducing the potential consequences of an accident during handling. Business-specific practices would be required to comply with federal and State laws to eliminate or minimize the potential consequence of hazardous materials accidents. For example, employees who would work around hazardous materials are required to wear appropriate protective equipment, and safety equipment is routinely available in all areas where hazardous materials are used. California Building and Fire Code requirements detail standards for the safe management of materials that present a moderate explosion hazard, high fire or physical hazard, or health hazards. Compliance with all applicable federal, State and local requirements related to the storage of hazardous materials would maximize containment through safe handling and storage practices described above and provide for prompt and effective cleanup if an accidental release occurs.

Overall, the numerous hazardous material regulations detailed in Section 4.9.2, Regulatory Setting, would minimize impacts related to hazardous materials in the project site. Hazardous materials would be required to be transported under DOT regulations. Compliance with existing laws and regulations governing the transport, use, storage, disposal, or release of hazardous materials/wastes would reduce impacts related to exposure of the public or environment to hazardous materials to less than significant.

Mitigation Measures
HAZ-1 Property Assessment – Phase I and II Environmental Site Assessments Prior to submittal of a discretionary development application or engineering plans for the Newell Drive Extension, the project applicant shall retain a qualified environmental professional, as defined by ASTM E-1527 to prepare a project area Phase I Environmental Site Assessment (ESA) in accordance with standard ASTM methodologies, to assess the land use history of the project site that will be affected.
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After the site-specific Phase I ESA has been completed, the determination of specific areas that require a Phase II ESA (i.e., soil, groundwater, soil vapor subsurface investigations) shall be evaluated by the project applicant. The Phase II ESA shall be completed prior to construction and shall be based on the results of the Phase I ESA. Specifically, if the Phase I ESA identifies recognized environmental conditions or potential concern areas, the project applicant shall retain a qualified environmental consultant, California Professional Geologist or California Professional Engineer, to prepare a Phase II ESA of the project site to determine whether the soil, groundwater, and/or soil vapor has been impacted at concentrations exceeding regulatory screening levels for commercial/industrial land uses.

As part of the Phase II ESA, the qualified environmental consultant shall screen the analytical results against the San Francisco Regional Water Quality Control Board environmental screening levels (ESL). These ESLs are risk-based screening levels for direct exposure of a construction worker under various depth and land use scenarios.

If the Phase II ESA for the development site indicates that contaminants are detected in the subsurface at the project site, the project applicant shall take appropriate steps to protect site workers and the public. This may include the preparation of a Soil Management Plan for Impacted Soils prior to project construction.

If the Phase II ESA for the contaminant site indicates that contaminants are present at concentrations exceeding hazardous waste screening thresholds for contaminants in soil and/or groundwater (CCR Title 22, Section 66261.24 Characteristics of Toxicity), the project applicant shall take appropriate steps to protect site workers and the public. This may include the completion of remediation at the project prior to onsite construction. The City shall review and approve the Phase I ESA and Phase II ESA prior to construction (i.e., demolition and grading).

Significance After Mitigation
Mitigation Measure HAZ-1 would ensure that hazardous materials are identified and remediated prior to construction. Impacts would be less than significant after implementation of Mitigation Measure HAZ-1.

Threshold 3: Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school?
Impact HAZ-2 DEVELOPMENT FACILITATED BY THE PROJECT WOULD NOT RESULT IN THE RELEASE OF POTENTIALLY HAZARDOUS MATERIALS WITHIN 0.25 MILE OF A SCHOOL. THERE WOULD BE NO IMPACT.

There are no schools within 0.25 mile of the project site. The nearest school (Napa Junction Magnet Elementary School) is approximately 1 mile southwest of the project site. The project would, therefore, not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school. There would be no impact.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
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Threshold 4: Would the project be located on a site that is included on a list of hazardous material 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? Impact HAZ-3 DEVELOPMENT FACILITATED BY THE PROJECT WOULD NOT BE LOCATED ON A SITE

INCLUDED ON A LIST OF HAZARDOUS MATERIAL SITES COMPILED PURSUANT TO GOVERNMENT CODE SECTION 65962.5. HOWEVER, IMPACTS COULD OCCUR FROM UNKNOWN HAZARDOUS MATERIALS. COMPLIANCE WITH MITIGATION MEASURE HAZ-1 WOULD MINIMIZE IMPACTS FROM DEVELOPMENT ON PREVIOUSLY UNKNOWN CONTAMINATED SITES AND IMPACTS WOULD BE LESS THAN SIGNIFICANT AFTER MITIGATION.

There are no known LUST sites or DTSC listed cleanup sites in the project site (SWRCB 2022, DTSC 2022). Furthermore, there are no Superfund or other State Responsibility sites in the project site.

Nonetheless, it is possible that USTs (which were in use prior to permitting and records being kept) are present in the project site. Tank removal activities could pose both health and safety risks to workers, tank handling personnel, and the public from tank contents or vapors. Potential risks, if any, posed by USTs could be minimized by managing the tank according to existing standards contained in California Health and Safety Code Division 20, Chapters 6.7 and 6.75 (UST Program), as enforced and monitored by the Environmental Programs Division. The extent to which groundwater may be affected by an UST or other potential contamination source depends on the type of contaminant, the amount released, the duration of the release, distance from source, and depth to groundwater. If contamination exceeds regulatory action levels, future developers would be required to undertake remediation procedures prior to grading and development under the supervision of the RWQCB, depending on the nature of any identified contamination.

It is currently unknown whether there are any USTs or other hazardous materials on the project site.

As such, if any hazardous materials were to be found on the project site, then there could be a potentially significant impact on the public or the environment. Mitigation Measure HAZ-1 would be implemented to address this potential impact and would require the project applicants for future development, as well as the development of the Newell Drive Extension to implement a Phase I ESA and if necessary, a Phase II ESA. Implementation of a Phase I and Phase II ESA would ensure that any potential hazardous materials, including a UST is identified and remediated prior to construction.

Mitigation Measures
Mitigation Measure HAZ-1 (see Impact HAZ-1).

Significance After Mitigation
Mitigation Measure HAZ-1 would ensure that hazardous materials are identified and remediated prior to construction. Impacts would be less than significant after implementation of Mitigation Measure HAZ-1.
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Threshold 5: For a project located within 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 result in a safety hazard or excessive noise for people residing or working in the project area?
Impact HAZ-4 DEVELOPMENT FACILITATED BY THE PROJECT WOULD OCCUR IN THE NAPA COUNTY AIRPORT LAND USE COMPATIBILITY ZONE D. DEVELOPMENT WOULD OCCUR IN COMPLIANCE WITH THE NAPA

COUNTY AIRPORT LAND USE COMPATIBILITY PLAN AND IMPACTS WOULD BE FURTHER REDUCED THROUGH ADHERENCE TO GENERAL PLAN POLICIES. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Napa County Airport is located approximately 1.2 miles northwest of the project site and development within the Napa County Airport’s sphere of influence is governed by the Napa County ALUCP. As shown in Figure 4.9-1, the southern portion of the project site is in Zone E; however, that area contains the Union Pacific Railroad right-of-way, and no development would occur in that area.

As such, no impacts would occur in this area and is not discussed further.

There are no specific development plans within the project site but there are pre-zoned areas that could eventually be developed with commercial, industrial, and visitor-serving/hotel uses that are in Zone D of the Napa County Airport’s sphere of influence (see Figure 4.9-1). Residential development is not permitted in Zone D, as discussed in Section 4.9.2, Regulatory Setting. There are no new residences proposed by the project; therefore, the uses proposed by the project are allowed in Zone D and the land uses would be consistent with the ALUCP allowable land uses.

In accordance with Public Utilities Code Section 21676, ALUCs must review general and specific plans, including amendments of local jurisdictions for consistency with the Napa County ALUCP.

Other uses proposed under the project, such as industrial and visitor-serving, would be reviewed by the Napa County ALUC for consistency with the Napa County ALUCP. The ALUC would review the project for consistency with the Noise Compatibility Guidelines provided in Table 2-1 of the ALUCP, which indicates that light industrial noise exposure is normally or clearly acceptable at under 65 dBA CNEL and marginally acceptable at under 75 dBA CNEL. Table 2-1 does not explicitly include visitorserving uses but establishes commercial uses to have the same acceptable noise exposure levels as light industrial. Safety hazards would be mitigated by adhering to the ALUCP’s sphere of influence zones (e.g., Zone D) through review of physical obstructions and land use characteristics. The ALUCP establishes a 35-foot height restriction for development within Zone D. Additional height may be permitted under stringent Special Use Permit procedures as provided for in the Airport Safety Ordinance #416. Building heights under the project are not currently known but may be proposed at heights greater than 35 feet. As discussed in Section 4.9.2, Regulatory Setting, a permit to exceed the height limit as qualified by Ordinance #416 may be obtained after a compatibility determination from the ALUC. Approval from the ALUC would ensure that safety hazards from building height would be resolved.

In addition to review by the Napa County ALUC, General Plan policies would limit the exposure of the public to high noise levels and safety hazards. Specifically, Policy 1.27.2 would support Goal 1N to ensure compatibility of development with the Napa County Airport by reviewing all applications for new development or expansion of existing uses for compliance with allowed uses within Napa County Airport Compatibility Zones. Compliance with the ALUCP, review by the ALUC when required, and General Plan Policy 1.27.2 would reduce airport hazards and excessive noise and impacts would be less than significant.
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Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

Threshold 6: Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Impact HAZ-5 DEVELOPMENT FACILITATED BY THE PROJECT WOULD NOT IMPAIR IMPLEMENTATION OF

OR PHYSICALLY INTERFERE WITH AN ADOPTED EMERGENCY RESPONSE PLAN OR EMERGENCY EVACUATION PLAN. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

The project would not impair or interfere with emergency response or emergency evacuation. There are no proposed physical changes to roadways or access points that would interfere or impair emergency response or evacuation. The proposed Newell Drive extension would connect SR 29 with Newell Drive, which would improve roadway connections and emergency evacuation. The project site is on existing parcels that are not dedicated to circulation or access, and the devotion of a portion of the project site to Newell Drive would improve emergency access to SR 29 by adding another emergency route. Additionally, the project proposes an overcrossing of the railroad at the northeastern corner of the project site, which would ensure that vehicle traffic on the Newell Drive extension would not be hindered by train traffic.

Development facilitated by the project would not result in population growth; however, the project would add employees, as well as hotel visitors. This increase in employment and visitors would result in additional vehicles in and around the project site. Despite the additional access to SR 29 through the Newell Drive extension, the increase in vehicles could result in incrementally higher congestion on evacuation routes in the city and place additional demand on adopted evacuation routes and other emergency response resources.

Management of emergency response and emergency evacuations plans includes regular updates to the Napa County Operational Area Multi-Jurisdictional HMP and Emergency Operations Plan that incorporate new or proposed developments, such as the development facilitated by the project.

Therefore, development facilitated by the project would be reflected in the regular and required updates of emergency and evacuation plans applicable to the City.

In addition, the City would review and approve future projects to ensure that emergency access meets City standards. Development facilitated by the project, as well as all development in the city, must comply with road standards, and are reviewed by the American Canyon Fire Protection District to ensure development would not interfere with evacuation routes or impede the effectiveness of evacuation plans. Compliance with General Plan policies identified in Section 4.9.2, Regulatory Setting, would further ensure that development facilitated by the project would not impair the implementation or physical interference with evacuation or emergency response plans. Policies

6.3.1 and 6.4.3 require growth in the city to remain commensurate with available emergency services, such as fire protection. Additionally, as discussed in Section 4.14, Public Services, development facilitated by the project would be required to pay an impact fee that is utilized for the provision of resources for the American Canyon Fire Department, which would help provide emergency services to the City.
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Therefore, for the reasons identified above, the project would not impair implementation of or physically interfere with evacuation or emergency response plans. The impact related to emergency response and evacuation plans would be less than significant.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

4.9.4 Cumulative Impacts
The geographic scope of the cumulative hazards and hazardous materials analysis is the City of American Canyon and the surrounding vicinity. Adverse effects associated with many hazards and hazardous materials impacts tend to be localized; therefore, an area generally within a 0.25-mile radius would be the area most affected by activities in combination with the project. Because the project would have no impact related to the release of hazardous materials within 0.25 mile of a school, the project would not contribute to a cumulative impact. Therefore, cumulative impacts related to the release of hazardous materials within 0.25 mile of a school are not discussed further.

Because cumulative projects would also transport, use, and dispose of hazardous materials (similar to the project) cumulative projects have the potential to create a significant hazard to the public through the routine transport, use, disposal of hazardous materials. Hazards related to transport of hazardous materials have a wider cumulative area, but are uniformly governed by federal, State, and local regulations, including the Toxic Substances Control Act, the Resource Conversation and Recovery Act, Hazardous Waste Control Act, and the Napa County Operational Area MultiJurisdictional HMP. Because all cumulative projects would be required to adhere to these regulations, cumulative impacts would be less than significant.

Cumulative projects may have a cumulative impact from the release of contaminated materials during construction (on sites that may contain hazardous materials, such as pesticides or unknown USTs) or because the cumulative project is listed as a hazardous material site pursuant to Government Code Section 65962.5. The project would mitigate this impact by requiring Mitigation Measure HAZ-1, which would remediate impacts prior to ground disturbance. Because the project would ensure that any hazards from hazardous materials on the project site are remediated, the project’s contribution to a cumulative impact would be less than considerable.

Cumulative projects within the Napa County Airport Influence Area are reviewed for consistency with the Napa County ALUCP at the time of discretionary entitlement. Because cumulative projects follow the Napa County ALUC procedures (summarized in Impact HAZ-4), cumulative impacts would be less than significant.

Cumulative projects have the potential to impair an emergency response/evacuation plan. All cumulative projects would adhere to the Napa County Operational Area Multi-Jurisdictional HMP and Napa County EOP. Prescriptions and actions to reduce risks from hazards in the Napa County Operational Area Multi-Jurisdictional HMP would reduce the cumulative impact of the project and cumulative projects by ensuring that Napa County is prepared to mitigate hazards, including emergency response. Similarly, the EOP includes details on countywide emergency response, including emergency access and evacuation, which would reduce the cumulative impact to 457
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emergency access and evacuation. Therefore, adherence to the plans would ensure that the cumulative impact to emergency response would be less than significant. 458
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4.10 Hydrology and Water Quality
This section summarizes the regional and local watershed characteristics, water quality, drainage and infiltration patterns, and flood hazards and analyzes the impacts on hydrology and water quality due to the project. Water supply and adequacy of wastewater conveyance and treatment are discussed in Section 4.17, Utilities and Service Systems. Impacts related to wetlands and waters of the U.S. are discussed in Section 4.4, Biological Resources.

4.10.1 Setting
a. Surface Hydrology
Natural Drainage Systems
The City of American Canyon is located along the alluvial marshlands of the east bank on the Napa River and the lower slopes of the Sulphur Springs Mountain Range. The watersheds within the City include tributary areas of five creeks. The creeks all drain in a westerly direction from the rolling hills in the east to the Napa River on the west. The existing drainage system in the City consists of natural creeks in the hilly areas, with improved channels in the upland areas and levied channels and sloughs in the lower marshlands near the Napa River.

Developed subdivisions in the City are served by piped drainage facilities that discharge into the creek channels. Watershed boundaries follow ridgelines in the upper elevations, and follow levees, roadways, and other manmade obstructions in the upland and lower watershed areas. The watershed drainages of the five primary creeks in the City are American Canyon Creek, Walsh Creek, North Slough, Fagan Creek, and Sheehy Creek. North Slough is located on the project site and is shown in Figure 4.4-1 in Section 4.4, Biological Resources. North Slough is part of the Napa River watershed and drain runoff from the lands within and surrounding the project site. Other potentially jurisdictional waters in the project site have been historically diverted from their natural topographic drainages (i.e., the typical gradient being downhill and flowing north to south or east to west). These potentially jurisdictional waters originate on the property with vineyards to the east and are diverted through a system of culverts and ditches onto and through the project site, flowing into North Slough.

Man-Made Drainage Systems
The City is served by an extensive man-made storm drainage system including pipe networks, ditches, and culverts. Major storm drainage infrastructure including drain pipes, concrete channels, culverts, and swales (which convey storm drainage to Rio Del Mar Creek, American Canyon Creek or North Slough, before conveying it to the Napa River and then to the San Francisco Bay) within the City is owned and operated by the City of American Canyon and maintained by the City’s Public Works Department. For further information on stormwater management infrastructure, see Section

4.17, Utilities and Service Systems.
b. Regional Groundwater
The project site is located within the 40,500-acre Napa-Sonoma Lowlands Groundwater Subbasin (Department of Water Resources [DWR] 2022a). The subbasin consists primarily of alluvium and alluvial fans that were deposited at and near the mouths of the Napa River and Sonoma Creek 459
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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.

The Sustainable Groundwater Management Act (SGMA) was enacted in 2014 as comprehensive legislation aimed at strengthening local control and management of groundwater basins throughout California. SGMA requires local groundwater sustainability agencies to be formed and groundwater management plans to be developed for all medium and high priority basins. The DWR considers the Napa-Sonoma Valley Lowlands Groundwater Subbasin a very low priority subbasin and it is not subject the rules and regulations of the SGMA including the adoption of a Groundwater Sustainability Plan (Napa County 2022).
c. 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).
d. 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 (American Canyon 2016). The City does not currently use groundwater as a source of water and the City did not pump groundwater at any time between 2011 and 2015. Previous studies of groundwater productivity in and near the City have indicated that: (1) usable groundwater resources in the City may be limited; (2) wells at depths up to 200 feet produce approximately 45 gallons per minute, with some not reliable in the dry months of the year; and (3) deeper wells (approximately 400 feet) have been found to be brackish and not sustainable (American Canyon 2015).
e. Potable Water Quality in the City of American Canyon According to American Canyon’s 2021 Annual Water Quality Report, contaminants that may be present in source water include:
 Microbial contaminants, such as viruses and bacteria which may come from sewage treatment plants, septic systems, agricultural livestock operations, and wildlife;  Inorganic contaminants, such as salts and metals, that can be naturally-occurring or result from urban stormwater runoff, industrial or domestic wastewater discharges, oil and gas production, mining, or farming;
 Pesticides and herbicides that may come from a variety of sources such as agriculture, urban stormwater runoff, and residential uses;
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 Organic chemical contaminants, including synthetic and volatile organic chemicals that are byproducts of industrial processes and petroleum production, and can also come from gas stations, urban stormwater runoff, agricultural application, and septic systems; and  Radioactive contaminants that can be naturally-occurring or be the result of oil and gas production and mining activities.

Continuous monitoring, physical barriers to runoff, and proper water treatment are used throughout the water treatment and water conveyance system to maintain water quality standards.

The City tests multiple water quality parameters of drinking water that cover both primary public health and secondary aesthetic (taste, odor, and color) requirements, and include testing of lead, fluoride, selenium, nitrate, and turbidity. Except for intermittent Total Trihalomethanes (TTHM), all required testing indicate that the City’s drinking water meets or exceeds all primary drinking water standards, which are set by the federal Safe Drinking Water Act, and the State Water Resource Control Board Division of Drinking Water (SWRCBDDW) (American Canyon 2022).

Section 303(d) of the 1972 Federal Clean Water Act requires that states develop a list of water bodies that do not meet water quality standards, establish priority rankings for waters on the list and develop action plans, called Total Maximum Daily Loads (TMDL), to improve water quality. The list of impaired water bodies is typically revised every two years. The Napa River is the only listed waterbody in the City. There are no listed waterbodies in the project site (United States Environmental Protection Agency [USEPA] 2022).
f. Flood Hazards
The Federal Emergency Management Agency (FEMA) delineates regional flooding hazards as part of the National Flood Insurance Program. FEMA identifies flood hazard risks through its Flood Insurance Rate Map (FIRM) program. Higher flood risk zones are called Special Flood Hazard Areas (SFHA); these areas have a 1 percent chance or greater of flooding in any given year (also called the 100-year flood). According to FEMA’s FIRM of the project site, the project site is not in a flood zone (FEMA 2016). According to the California Department of Conservation Tsunami Inundation Maps, the project site is not located within a Tsunami Inundation Zone. The nearest body of water that is subject to seiche is Lake Frey, located approximately 7 miles northeast of the project site.

4.10.2 Regulatory Setting
a. Federal Regulations
Federal Clean Water Act
In 1972, the 1948 Federal Water Pollution Control Act was amended to require that the discharge of pollutants into waters of the U.S. from any point source be effectively prohibited unless the discharge follows a National Pollutant Discharge Elimination System (NPDES) permit. This amendment became the basis for what was by 1977 referred to as the Clean Water Act (CWA). In 1987, the CWA was again amended to require that the USEPA establish regulations for the permitting of stormwater discharges (as a point source) by municipal and industrial facilities and construction activities under the NPDES permit program. The regulations require that discharges to 461
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surface waters from municipal separate storm sewer system (MS4)1 be regulated by an NPDES permit.

Regulations on storm water discharges from MS4s were implemented with a two-phased program.

Phase I, promulgated by USEPA in November 1990, requires NPDES permits for storm water discharges from MS4sserving populations of 100,000 or greater, construction sites disturbing greater than 5 acres of land, and ten categories of industrial activities. The USEPA recognized that smaller construction projects (disturbing less than 5 acres) and small MS4s (serving populations smaller than 100,000) were also contributing substantially to pollutant discharges nationwide.

Therefore, to further improve storm water quality, the USEPA promulgated the NPDES Phase II program (Federal Register Vol. 64, No. 235, December 8, 1999). The Phase II regulations became effective on February 7, 2000, and require NPDES permits for storm water discharges from regulated small MS4s and for construction sites disturbing between 1 acre and 5 acres of land.

CWA Section 208, Areawide Waste Treatment Management
Section 208 of the CWA required all states to address water quality degradation from nonpoint source pollution and to develop either regulatory or non-regulatory programs to control nonpoint source pollution. A state's Section 208 program must meet USEPA approval.

CWA Section 303, List of Water Quality Limited Segments Section 303 of CWA requires States to adopt water quality standards for water bodies and have those standards approved by USEPA. Water quality standards consist of designated beneficial uses for a particular water body (e.g., wildlife habitat, agricultural supply, and fishing), along with water quality criteria necessary to support those uses. Water quality criteria include quantitative set concentrations, levels, or loading rates of constituents—such as pesticides, nutrients, salts, suspended sediment, and fecal coliform bacteria—or narrative statements that represent the quality of water that support a particular use.

When designated beneficial uses of a particular water body are being compromised by water quality, Section 303(d) of the CWA requires identifying and listing that water body as impaired. Once a water body has been deemed impaired, a TMDL must be developed for each impairing water quality constituent. A TMDL is an estimate of the total load of pollutants from point, non-point, and natural sources that a water body may receive without exceeding applicable water quality standards (often with a “factor of safety” included, which limits the total load of pollutants to a level well below that which could cause the standard to be exceeded). Once established, the TMDL is allocated among current and future dischargers into the water body.

CWA Section 304(a), Water Quality Criteria
Section 304(a)(1) of the CWA requires the USEPA to develop, publish and periodically revise criteria for protection of water quality and human health that reflect the latest scientific knowledge. Water quality criteria developed under section 304(a) are based on data and scientific judgments on the relationship between pollutant concentrations and environmental and human health effects.

Section 304(a) also provides guidance to states in adopting water quality standards. 1 An MS4 is a conveyance or system of conveyances designed or used to collect or convey stormwater (e.g., storm drains, pipes, ditches) that are that owned by a state, city, town, or other public entity and discharge to waters of the United States. 462
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CWA Section 402, National Pollutant Discharge Elimination System Direct discharges of pollutants into waters of the U.S. are not allowed, except in accordance with the NPDES program established in Section 402 of the CWA. Non-point source discharges to stormwater are regulated under stormwater NPDES permits for municipal stormwater discharges, industrial activities, and construction activities. These permits require development of and adherence to a Stormwater Control Plan (SCP) or Storm Water Pollution Prevention Plan (SWPPP).

National Flood Insurance Program
Congress acted to reduce the costs of disaster relief by passing the National Flood Insurance Act of 1968 and the Flood Disaster Protection Act of 1973. The intent of these acts was to reduce the need for large, publicly funded flood control structures and disaster relief efforts by restricting development in floodplains. FEMA administers the National Flood Insurance Program (NFIP) to provide subsidized flood insurance to communities that comply with FEMA regulations limiting development in a floodplain. FEMA issues FIRMs of communities participating in the NFIP. These maps delineate flood hazard zones in the community.
b. State Regulations
Porter-Cologne Water Quality Control Act
The federal CWA places the primary responsibility for the control of water pollution and planning the development and use of water resources with the states, although it does establish certain guidelines for the states to follow in developing their programs. California’s primary statute governing water quality and water pollution is the Porter-Cologne Water Quality Control Act of 1969 (Porter-Cologne Act). The Porter-Cologne Act grants the State Water Resource Control Board (SWRCB) and the nine Regional Water Quality Control Board (RWQCBs) broad powers to protect water quality and is the primary vehicle for the implementation of California’s responsibility under the federal CWA. The Porter-Cologne Act grants the SWRCB and RWQCBs the authority and responsibility to adopt plans and policies, to regulate discharges to surface water and groundwater, to regulate waste disposal sites, and to require cleanup of discharges of hazardous materials and other pollutants. The Porter-Cologne Act also establishes reporting requirements for unintended discharges of any hazardous substance, sewage, oil, or petroleum product. Each RWQCB must formulate and adopt a water quality control plan for its region. The regional plans are to conform to the policies set forth in the Porter-Cologne Act and established by the SWRCB in its State water policy. The Porter-Cologne Act also provides that an RWQCB may include in its region a regional plan with water discharge prohibitions applicable to particular conditions, areas, or types of waste. The project site is within the jurisdictional boundaries of the San Francisco RWQCB (Region 2).

Phase II Municipal Storm Water Permit
The Municipal Storm Water Permitting Program regulates storm water discharges from MS4s. The NPDES MS4 permits in California are issued in two phases by the SWRCB and RWQCBs. Phase I MS4 permits are issued by the RWQCBs to medium (i.e., serving between 100,000 and 250,000 people) and large (i.e., serving more than 250,000 people) municipalities. Most of these permits are issued to a group of co-permittees encompassing an entire metropolitan area. The Phase II MS4 Permit is issued by the SWRCB and is applicable to smaller municipalities (i.e., populations of less than 100,000 people) and nontraditional small MS4s (e.g., military bases, public campuses, and prison and hospital complexes). The Phase II MS4 Permit (Waste Discharge Requirements [WDRs] for Storm 463
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Water Discharges from Small Municipal Separate Storm Sewer Systems [MS4s] General Permit], Order No. 2013-0001-DWQ, NPDES No. CAS000004) became effective on July 1, 2013 and covers Phase II permittees statewide. The Phase II MS4 Permit designated the City of American Canyon as a regulated small MS4 (Attachment A of the MS4 Permit).

The Napa Countywide Stormwater Pollution Prevention Program (NCSPPP) is a joint effort of the County of Napa, cities of American Canyon, Napa, St. Helena and Calistoga, and the Town of Yountville to comply with state and federal regulations including the Phase II MS4 Permit. Although the individual entities of NCSPPP carry out their own individual stormwater pollution prevention programs, the NCSPPP provides for the coordination and consistency of approaches between the individual participants and documents their efforts in annual reports. In addition, the Bay Area Stormwater Management Agencies Association (BASMAA) Design Guidance for Stormwater Treatment and Control for Projects in Marin, Sonoma, Napa and Solano Counties (Post-Construction Manual) provides a manual for future projects to use, in order to comply with the Phase II MS4 Permit requirements. As described in further detail below, in the Local Regulation subsection, the City of American Canyon requires that a SCP be required that meets the criteria of the BASMAA Post-Construction Manual for development projects subject to post construction requirements.

Sustainable Groundwater Management Act
The Sustainable Groundwater Management Act (SGMA) of 2014 is a comprehensive three-bill package that Governor Jerry Brown signed into California state law in September 2014. The SGMA provides a framework for sustainable management of groundwater supplies by local authorities, with a limited role for State intervention, if required to protect the resource. The plan is intended to ensure a reliable groundwater supply for California for years to come. The SGMA requires governments and water agencies of high- and medium-priority basins to halt overdrafts of groundwater basins. The SGMA requires the formation of local groundwater sustainability agencies (GSAs) that are required to adopt Groundwater Sustainability Plans (GSPs) to manage the sustainability of the groundwater basins.

The project site is in the Napa Sonoma Lowlands Subbasin of the Napa-Sonoma Valley Groundwater Basin (DWR 2022a). The Napa-Sonoma Lowlands Subbasin is classified as very low priority by the DWR (County of Napa 2022). Since the Napa Sonoma Lowlands Subbasin is designated as very low priority basin, the basin is not subject to SGMA.

General Construction Activity Storm Water Permit
The General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities, Order No. 2009-0009-DWQ, NPDES No. CAS000002, as amended by Order Nos. 2010- 0014-DWQ and 2012-0006-DWQ (Construction General Permit), adopted by the SWRCB, regulates construction activity that includes clearing, grading, and excavation resulting in soil disturbance of at least one acre of total land area. The Construction General Permit authorizes the discharge of stormwater to surface waters from construction activities. The Construction General Permit requires that all developers of land where construction activities will occur over more than 1 acre do the following:
 Complete a Risk Assessment to determine pollution prevention requirements pursuant to the three risk levels established in the General Permit;
 Eliminate or reduce non-stormwater discharges to storm sewer systems and other waters of the United States;
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 Develop and implement a construction SWPPP that specifies Best Management Practices (BMPs) that will reduce pollution in stormwater discharges to the Best Available Technology/ Economically Achievable/Best Conventional Pollutant Control Technology standards;  Perform inspections and maintenance of all BMPs; and
 Conduct stormwater sampling, if required based on risk level.

To obtain coverage under the Construction General Permit, a project applicant must electronically file all permit registration documents with the SWRCB prior to the start of construction. Permit registration documents must include a:
 Notice of Intent (NOI);
 Risk Assessment;
 Site map;
 Construction SWPPP;
 Annual fee; and
 Signed certification statement.

Typical BMPs contained in construction SWPPPs are designed to minimize erosion during construction, stabilize construction areas, control sediment, and control pollutants from construction materials. The construction SWPPP must also include a discussion of the program to inspect and maintain all BMPs.

General Permit for Stormwater Discharges Associated with Industrial Activities (Industrial General Permit)
Section 402 of the Federal Clean Water Act requires industries that fall under certain Standard Industrial Classification (SIC) codes and that discharge stormwater into a storm drain system or to surface waters, obtain an NPDES permit (SWRCB 2022). SIC Codes include manufacturing facilities; transportation facilities; hazardous waste treatment, storage, or disposal facilities; and recycling facilities. In California, these industrial facilities may comply with the Clean Water Act Section 402 by applying for coverage under the State's General Permit for Stormwater Discharges Associated with Industrial Activities (Industrial General Permit) or by applying for an individual NPDES Permit.

The Industrial General Permit is an NPDES permit that regulates stormwater discharges from any facility associated with 10 broad categories of industrial activities. These categories of industrial activities are based on the SIC codes. The SWRCB and RWQCB enforce the Industrial General Permit.

The Industrial General Permit requires the implementation of Best Available Technology Economically Achievable (BAT) and Best Conventional Pollutant Control Technology (BCT) to achieve performance standards, which include effluent limitations, as well as the development of an operational SWPPP and a monitoring plan. The Industrial General Permit set effluent limitations through numeric action levels and requires Exceedance Response Actions if there is exceedance of the numeric action levels. The operational SWPPP identifies the site-specific sources of pollutants and describes the best management practices implemented at the facility to prevent dry weather runoff and to reduce pollutants in storm water discharges.

Stormwater Guidance Publications
California Stormwater Quality Association (CASQA), a professional organization, has published guidance for stormwater management. The organization’s Stormwater Best Management Handbook 465
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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. c. Local Regulations
San Francisco Regional Water Quality Control Board
The San Francisco RWQCB issues Municipal Regional NPDES permits (Order No. R4-2021-0105) that allow the discharge of stormwater into local creeks and the Pacific Ocean. All municipalities within the San Francisco Bay Region which discharge wastewater to surface waters are currently regulated by NPDES permits issued by the Regional Water Board. Industrial, commercial, cleanup or other operations which discharge wastes directly into municipal, or other publicly owned wastewater collection systems, are not required to obtain an NPDES permit from the Regional Water Board but must comply with waste discharge requirements issued by the appropriate public entity.

City of American Canyon General Plan
The current City of American Canyon General Plan sets forth the following guiding and implementing policies relevant to hydrology and water quality:

Goal 10 : Protect the lives and property of American Canyon’s residents and visitors from 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.

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.

American Canyon Municipal Code
Chapter 14.28 of the American Canyon Municipal Code (Stormwater and Pollution Discharge Control Program) establishes local regulations to secure benefits from the use of stormwater as a resource and to protect and enhance watercourses, fish, and wildlife habitat. Specifically, the Municipal Code include the following requirements that would apply to the project. 466
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 Section 14.28.080 identifies requirements for construction, including requiring appropriate erosion and sedimentation controls in accordance with guidance provided in the “Standards for Erosion and Sedimentation Control” and the “Erosion and Sedimentation Control Handbook” published by the Association of Bay Area Governments (ABAG). This section also identifies that City Public Works may establish controls on the volume and rate of stormwater runoff from new developments and redevelopment, as appropriate, to minimize peak flows or total runoff volume.
 Section 14.28.081 identifies the BMPs that shall be implemented to prevent the discharge of sediment, construction wastes or contaminants from construction materials, tools and equipment from entering a city storm drain or watercourse. This section also identifies that an Erosion and Sediment Control Plan shall be required for certain projects.  Section 14.28.082 identifies that the City may establish volume and rate of stormwater controls from new developments and redevelopment as may be appropriate to minimize peak flows or total runoff volume, and to mimic the pre-development site hydrology. This section also includes the requirement that qualifying projects prepare a SCP that meets the criteria in the BASMAA Post Construction Manual. The SCP must include postconstruction stormwater treatment measures such as bioretention facilities and source control BMPs, and must also address ongoing maintenances of those facilities.

Stormwater Management
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 predevelopment runoff.

4.10.3 Impact Analysis
a. Significance Thresholds and Methodology
Significance Thresholds
Based on Appendix G of the CEQA Guidelines a project may be deemed to have a significant impact on hydrology and water quality if it would:

Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality;
Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin; Substantially alter the existing drainage pattern of the site or 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:
a. Result in substantial erosion or siltation on- or off-site; b. Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on-or off-site;
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c. 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
d. Impede or redirect flood flows.

In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation; or Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.

Methodology
The impact analysis is based on an assessment of baseline conditions for the project site, including topography, watersheds, surface waters, groundwater, and floodplains. This analysis identifies potential impacts based on the interaction between the existing environment and construction, operation, and maintenance activities related to project development. b. Project Impacts and Mitigation Measures
Threshold 1: Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? IMPACT HWQ-1 THE PROJECT WOULD NOT VIOLATE WATER QUALITY STANDARDS OR WASTE DISCHARGE REQUIREMENTS, OR OTHERWISE SUBSTANTIALLY DEGRADE SURFACE OR GROUNDWATER QUALITY. INDIVIDUAL

PROJECTS WOULD BE REQUIRED TO COMPLY WITH BMPS IN ACCORDANCE WITH STATE AND LOCAL REGULATIONS AND PERMIT REQUIREMENTS, AS WELL AS MITIGATION MEASURES HYD-1 AND HYD-2. IMPACTS WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION.

Construction
Construction activities associated with the project would include construction of new development and the Newell Drive Extension. Construction activities could result in soil erosion due to earthmoving activities such as excavation, grading, soil compaction and moving, and soil stockpiling. The project sites vary in elevation and slope. Types of pollutants contained in runoff may include sediment and other existing contaminants, such as nutrients, pesticides, herbicides, trace metals, trash, and hydrocarbons that can attach to sediment and be transported downstream through erosion via overland flow, ultimately entering nearby waterways and contributing to degradation of water quality.

Construction activities associated with the project could result in soil erosion during earth-moving activities, including excavation, grading, soil compaction and moving, and soil stockpiling.

Specific development facilitated by the project and the Newell Drive Extension would be required to comply with State and local water quality regulations designed to control erosion and protect water quality during construction. This includes compliance with the requirements of the Construction General Permit, which requires preparation and implementation of a construction SWPPP for projects that disturb one acre or more of land. The construction SWPPP would control the discharge of pollutants, including sediment, into local surface water drainages. The construction SWPPP would specify the storm water monitoring and construction BMPs required to minimize water quality degradation. Construction BMPs would include, but would not be limited to, Erosion Control and Sediment Control BMPs designed to minimize erosion and retain sediment on site, and Good 468
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Housekeeping BMPs to prevent spills, leaks, and off-site discharge of construction debris and waste.

BMPs may include measures such as the installation of silt fences to trap sediments, slope stabilization, and regular sweeping of construction sites to control dust. In addition, future projects would be required to comply with Section 14.28.080 of the American Canyon Municipal Code, which requires erosion and sediment control BMPs to reduce the discharge of sediment and other particulate matter into the City’s groundwater and surface water system. Implementation of the required BMPs associated with the Construction General Permit and the American Canyon Municipal Code would reduce the potential for eroded soil and any contaminants attached to that soil to contaminate a waterbody following a storm event.

In addition, construction activities could utilize hazardous materials such as diesel fuel, gasoline, lubricant oils, hydraulic fluid, antifreeze, transmission fluid, cement slurry, and other fluids required for the operation of construction vehicles or equipment. These types of hazardous materials are not acutely hazardous; and storage, handling, use, and disposal of these materials are regulated by county, State, and federal regulations and compliance with applicable standards identified in Section 4.10.2, Regulatory Setting, including the Construction General Permit. The Construction General Permit includes the implementation of the construction SWPPP, which would include Good Housekeeping BMPs to prevent spills, leaks, and off-site discharge of construction debris and waste.

Transport of these materials to and from construction sites would also be regulated under multiple authorities as discussed in Section 4.8, Hazards and Hazardous Materials. Direct contamination of surface water from construction runoff is unlikely given required adherence to relevant standards and regulations.

Compliance with existing regulations and implementation of the required construction SWPPP and construction BMPs discussed above would reduce the risk of water degradation from soil erosion and other pollutants related to construction activities. Furthermore, Mitigation Measure HYD-1 would require development and implementation of a SWPPP to outline site-specific stormwater quality control measures (such as BMPs) during construction activities to prevent pollutants from entering downstream waterways. Implementation of Mitigation Measure HYD-1, as well as regulatory requirements, would minimize potentially significant water quality impacts during construction to a less than significant level.

Operation
Runoff from operation of future development and the Newell Drive Extension would be regulated by Section 14.28 of the American Canyon Municipal Code, which ensure compliance with the Phase II MS4 Permit. Section 14.28.082 of the American Canyon Municipal Code would require an SCP that meets the criteria in the BASMAA Post Construction Manual for all future development and the Newell Drive Extension. The SCP must include site design measures and treatment facilities that would minimize impervious surfaces, retain or detain stormwater, slow runoff rates, and reduce pollutant in post-development runoff (BASMAA 2019). Implementation of the SCP would reduce impacts to water quality.

Development that includes industries that fall under certain SIC codes and that discharge stormwater into a storm drain system or to surface would need to comply with the Industrial General Permit, which requires the development of a site-specific operational SWPPP and monitoring plan. Implementation of the operational SWPPP would reduce the risk of water degradation on site and off site from soil erosion and other pollutants related to project operation because an operational SWPPP requires the design, installation, and maintenance of postconstruction stormwater controls. The operational SWPPP identifies the site-specific sources of 469
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pollutants and describes the best management practices implemented at the facility to prevent dry weather runoff and to reduce pollutants in storm water discharges. In addition, the Industrial General Permit requires the implementation of BAT and BCT to achieve performance standards.

Water quality performance standards would be established by the numeric action levels in the Industrial General Permit. The Industrial General Permit would require dischargers to develop and implement Exceedance Response Actions when a numeric action levels exceedance occurs during a reporting year.

Furthermore, Mitigation Measure HYD-2 would require the following: (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 longterm functionality of the stormwater controls. The various RWQCBs have evaluated the effectiveness of the types of BMPs required by Mitigation Measure HYD-2 and have determined that BMPs are effective in protecting receiving waters. Thus, there is a high degree of certainty that the project would not exacerbate the existing water quality status of the Napa River or any other water bodies. Impacts would be less than significant with implementation of Mitigation Measure HYD-2 and regulatory requirements.

Mitigation Measures
HYD-1 Water Pollution Prevention Plan
Prior to issuance of grading permits for the 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, street sweeping, routine inspection, etc.) are effective and result in the reduction or elimination of pollutants in stormwater discharges and authorized non-stormwater discharges from construction activity; and (4) stabilization BMPs are installed to reduce or eliminate pollutants after construction are completed. The SWPPP shall be prepared by a qualified SWPPP developer. The SWPPP shall include the minimum BMPs required for the identified Risk Level. BMP implementation shall be consistent with the BMP requirements in the most recent version of the California Stormwater Quality Association (CASQA) Stormwater Best Management Handbook– Construction or the California Department of Transportation (Caltrans) Stormwater Quality Handbook Construction Site BMPs Manual. The SWPPP shall be implemented during construction to the satisfaction of the City.

HYD-2 Stormwater Control Plan
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 470
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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.

Significance After Mitigation
Implementation of Mitigation Measure HYD-1 and HYD-2 would ensure that water quality impacts are minimized during construction and operation of the project. With implementation of Mitigation Measure HYD-1 and HYD-2, impacts would be less than significant Threshold 2: Would the project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
IMPACT HWQ-2 THE PROJECT WOULD NOT INTERFERE SUBSTANTIALLY WITH GROUNDWATER RECHARGE SUCH THAT SUSTAINABLE GROUNDWATER MANAGEMENT OF THE BASIN WOULD BE IMPEDED. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Development within the project site would be served with potable water service from the City. No groundwater wells would be drilled on-site; therefore, the project would not contribute to groundwater overdraft. In addition, the City of American Canyon’s primary water supply source is imported water; local groundwater is not used for municipal purposes. Therefore, no impacts associated with groundwater overdraft would occur.

Implementation of the project may interfere with groundwater recharge by introducing new impervious surfaces through the construction of structures, parking lots, and other paved areas.

However, Section 14.28.082 of the American Canyon Municipal Code would require an SCP that meets the criteria in the BASMAA Post Construction Manual for future development and the Newell Drive Extension. The SCP would reduce stormwater pollutant discharges through the construction, operation and maintenance of source control measures, LID, site design measures, stormwater treatment measures and hydromodification management measures. Implementation of the SCP would ensure that groundwater recharge would occur. As such, the project would not substantially decrease groundwater supply, interfere with groundwater recharge, or impede sustainable groundwater management of the basin. Impacts would be less than significant.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
Impacts would be less than significant without mitigation. 471
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Threshold 3a: Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on- or off-site?
IMPACT HWQ-3 THE PROJECT COULD ALTER DRAINAGE PATTERNS BUT WOULD NOT RESULT IN SUBSTANTIAL

EROSION OR SILTATION AFTER COMPLIANCE WITH EXISTING REGULATIONS AND IMPLEMENTATION OF MITIGATION MEASURES HYD-1 AND HYD-2. IMPACTS WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION.

The project could alter the existing drainage patterns on individual project sites with grading, changes in topography, and filling or diversion of potential jurisdictional features, all of which could result in erosion or siltation.

Construction
Chapter 14.28 of the American Canyon Municipal Code (Stormwater and Pollution Discharge Control Program) requires any construction activities in the City to implement appropriate BMPs to prevent the discharge of sediment. An Erosion and Sediment Control Plan would be required for any of the following:
 Project subject to a grading permit;
 Project subject to building permit that has the potential for significant erosion and/or significant non-stormwater discharges of sediment and/or construction site waste; or  Any other project as required by the authorized enforcement official considering factors such as whether the project involves hillside soil disturbance, rainy season construction, construction near a watercourse, or any other condition or construction site activity that could lead to a nonstormwater discharge to a storm drain.

In addition, future construction disturbing more than one acre would be required to comply with the NPDES program by obtaining project-specific coverage under the State's Construction General Permit. This would require development and implementation of a project-specific construction SWPPP, which would include BMPs to reduce siltation and erosion. Furthermore, Mitigation Measure HYD-1 would require development and implementation of a SWPPP to outline site-specific stormwater quality control measures (such as BMPs) during construction activities to minimize erosion and siltation. Implementation of Mitigation Measure HYD-1, as well as regulatory requirements, would minimize potentially significant erosion and siltation impacts during construction to a less than significant level.

Operation
Runoff from operation of future development and the Newell Drive Extension would be regulated by Section 14.28 of the American Canyon Municipal Code, which ensure compliance with the Phase II MS4 Permit. Section 14.28.082 of the American Canyon Municipal Code would require an SCP that meets the criteria in the BASMAA Post Construction Manual for all future development and the Newell Drive Extension. The SCP must include site design measures and treatment facilities that would minimize impervious surfaces, retain or detain stormwater, slow runoff rates, and reduce pollutant in post-development runoff (BASMAA 2019). Implementation of the SCP would reduce siltation and erosion.
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In addition, development subject to the Industrial General Permit would be required to implement erosion and sediment control measures for each erodible surface facility location identified in the operational SWPPP.

Future applicant would implement effective wind erosion controls; provide effective stabilization for inactive areas, finished slopes, and other erodible areas prior to a forecasted storm event; maintain effective perimeter controls and stabilize all site entrances and exits to sufficiently control discharges of erodible materials from discharging or being tracked off the site; divert run-on and storm water generated from within the facility away from all erodible materials. The Industrial General Permit also requires the implementation of BAT and BCT to achieve performance standards.

Water quality performance standards would be established by the numeric action levels in the Industrial General Permit. The Industrial General Permit would require dischargers to develop and implement Exceedance Response Actions when a numeric action levels exceedance occurs during a reporting year. The Industrial General Permit would also implement an operational SWPPP and a monitoring plan. The operational SWPPP identifies the site-specific sources of pollutants and describes the best management practices implemented at the facility to prevent dry weather runoff and to reduce pollutants in storm water discharges.

Furthermore, 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 HYD-2, the 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 erosion and siltation is minimized. Impacts would be less than significant with Mitigation Measure HYD-2.

Mitigation Measures
Mitigation Measures HYD-1 and HYD-2 (see Impact HYD-1)
Significance After Mitigation
Implementation of Mitigation Measures HYD-1 and HYD-2 would ensure that erosion and siltation impacts are minimized during construction and operation of the project. With implementation of Mitigation Measures HYD-1 and HYD-2, impacts would be less than significant. 473
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Threshold 3b: Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site?
Threshold 3c: Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner that would 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? IMPACT HWQ-4 THE PROJECT COULD ALTER DRAINAGE PATTERNS AND INCREMENTALLY INCREASE

OVERALL RUNOFF VOLUMES BUT WOULD NOT EXCEED THE CAPACITY OF EXISTING OR PLANNED STORMWATER

DRAINAGE SYSTEMS OR PROVIDE SUBSTANTIAL ADDITIONAL SOURCES OF POLLUTED RUNOFF DUE TO IMPLEMENTATION OF EXISTING REGULATIONS AND MITIGATION MEASURES HYD-1 AND HYD-2. IMPACTS WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION.

The project could alter the existing drainage patterns on individual project sites with grading, changes in topography, and filling or diversion of potential jurisdictional features, all of which could create or contribute runoff water.

Construction
Construction activities could involve stockpiling, grading, excavation, dredging, paving, and other earth-disturbing activities that could temporarily alter existing drainage patterns. As described in Impact HWQ-1, compliance with the Construction General Permit would reduce the risk of shortterm erosion and runoff due to drainage alterations during construction. Construction activities would also be required to comply with Chapter 14.28 of the American Canyon Municipal Code (Stormwater and Pollution Discharge Control Program), which requires any construction activities in the City to implement appropriate BMPs to prevent the discharge of sediment, construction wastes or contaminants from construction materials, tools, and equipment from entering a city storm drain or watercourse. Finally, Mitigation Measure HYD-1 would require the implementation of BMPs as part of the SWPPP. As such, through compliance with these regulations and mitigation, potentially significant short-term impacts from runoff during construction, including flooding and polluted runoff would be less than significant.

Operation
Runoff from operation of future development and the Newell Drive Extension would be regulated by Section 14.28 of the American Canyon Municipal Code, which ensure compliance with the Phase II MS4 Permit. Section 14.28.082 of the American Canyon Municipal Code would require an SCP that meets the criteria in the BASMAA Post Construction Manual for all future development and the Newell Drive Extension. The SCP would outline LID and other measures to minimize peak flows or total runoff volume from future development and the Newell Drive Extension. The SCP would be required to meet the criteria in the BASMAA Post Construction Manual, which outlines measures for projects to control pollutants in runoff from newly created or replaced impervious surfaces (BASMAA 2019). Implementation of these measures would ensure that future development and the Newell Drive Extension mimic the pre-development site hydrology. In addition, development subject to the Industrial General Permit would be required to implement BAT and BCT to reduce or prevent 474
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pollutants in storm water discharges. With implementation the SCP and the Industrial General Permit requirement, the project would not 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.

Furthermore, 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 HYD-2, the 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 project-related stormwater. Impacts would be less than significant with Mitigation Measure HYD-2.

Mitigation Measures
Mitigation Measures HYD-1 and HYD-2 (see Impact HYD-2)
Significance After Mitigation
Implementation of Mitigation Measures HYD-1 and HYD-2 would ensure that impacts related to runoff, including flooding and polluted runoff are minimized during construction and operation of the project. With implementation of Mitigation Measures HYD-1 and HYD-2, impacts would be less than significant.

Threshold 3d: Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would impede or redirect flood flows?
Threshold 4: In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to project inundation?
IMPACT HWQ-5 THE PROJECT SITE IS NOT WITHIN AN AREA AT RISK FROM INUNDATION BY FLOOD

HAZARD, SEICHE, OR TSUNAMI AND WOULD NOT RISK THE RELEASE OF POLLUTANTS DUE TO PROJECT INUNDATION. THE PROJECT IS NOT IN A FLOOD HAZARD ZONE AND WOULD NOT IMPEDE OR REDIRECT FLOOD FLOWS. THERE WOULD BE NO IMPACT.

As described in Section 4.10.1, Setting, the project site is not located in a flood zone or a tsunami inundation zone. The nearest body of water that is subject to seiche is Lake Frey, located approximately 7 miles northeast of the project site. Given the distance, the project would not be inundated from a seiche at Lake Frey. Since the project is not located in a flood hazard, tsunami, or seiche zones, the project would not risk release of pollutants due to project inundation and no impact would occur. In addition, because the project site is not in a flood hazard zone, the project would not impede or redirect flood flows and there would be no impact.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
There would be no impact and no mitigation would be required. 475
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Threshold 5: Would the project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
IMPACT HWQ-6 THE PROJECT WOULD NOT CONFLICT WITH OR OBSTRUCT IMPLEMENTATION OF A WATER QUALITY CONTROL PLAN OR SUSTAINABLE GROUNDWATER MANAGEMENT PLAN. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

The project site is in the Napa Sonoma Lowlands Subbasin of the Napa-Sonoma Valley Groundwater Basin (DWR 2022a). The Napa-Sonoma Lowlands Subbasin is classified as very low priority by the DWR (County of Napa 2022). SGMA requires local agencies to form groundwater sustainability agencies for the high and medium priority basins. Since the Napa Sonoma Lowlands Subbasin is designated as very low priority basin, the basin is not subject to a sustainable groundwater management plan. Therefore, the project would not conflict with or obstruct implementation of a sustainable groundwater management plan.

The project is subject to the requirements of the San Francisco RWQCB (RWQCB 2017). As described in Impact HWQ-1, the project would result in a less than significant impact on water quality through the implementation of State and local regulations, including the Construction General Permit, the Industrial General Permit, and Chapter 14.28 of the American Canyon Municipal Code. With implementation of these regulations, impacts associated with conflict within a water quality control plan would be less than significant.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

4.10.1 Cumulative Impacts
The geographic scope of the cumulative geology and soils analysis is the City of American Canyon and the surrounding vicinity (unincorporated Napa County).

Because the project would have no impact related to impeding or redirecting flood flows, as well as releasing pollutants due to project inundation, the project would not contribute to a cumulative impact. Therefore, cumulative impacts related to impeding or redirecting flood flows, as well as releasing pollutants due to project inundation are not discussed further.

Like the project, cumulative projects in the City are also expected to result in impacts on water quality; groundwater recharge; erosion, siltation, flooding, and polluted runoff from alteration of drainage patterns; and compliance with a water quality control plan. However, all these cumulative projects would be required to comply with similar regulations, including the Construction Genera Permit, the Industrial General Permit (for industrial projects), Section 14.28 of the American Canyon Municipal Code (for projects in the City of American Canyon), and Section 16.28 of the Napa County Municipal Code (for projects in unincorporated Napa County). Section 16.28 of the Napa County Municipal Code includes similar requirements as Section 14.28 of the American Canyon Municipal Code, including requiring an ECSP and an SCP that meets the standards in the BASMAA Manual. As such, cumulative impacts on water quality, groundwater recharge, and runoff-related impacts would be minimized through the implementation of regulations. As such, cumulative impacts on hydrology and water quality would be less than significant. 476
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4.11 Land Use and Planning
This section summarizes existing and planned land uses in the project site and analyzes the impacts on land use and planning due to the project. The physical environmental effects associated with the project, many of which pertain to issues of land use compatibility (e.g., noise, aesthetics, air quality) are evaluated in other sections of this EIR.

4.11.1 Setting
a. Existing Land Use Patterns
The project site contains a mix of undeveloped land, residential uses, outdoor storage, and Union Pacific Railroad (UPRR) right-of-way. The northern portion is largely undeveloped, except for a farmhouse and accessory outbuildings. The central and southern portion includes 13 residential lots, varying in size from 1 to 10 acres. The residential parcel in the southwest corner has a conditional use permit issued by the County for outdoor storage. The northeast portion to the east of the UPRR has outdoor truck and material storage. The UPRR right-of-way in the southeast portion is undeveloped. There is an auto-repair business adjacent to the western edge of the project site. b. General Plan Land Use Designations and Zoning
The project site currently has Agriculture, Residential Estate, and Town Center land use designations (see Figure 2-3 in Chapter 2, Project Description). The northeastern portion of the project-site is the only portion of the project site that is pre-zoned, and it is pre-zoned Town Center. c. Surrounding Land Uses
The annexation area is surrounded by either industrial, commercial, residential, or agricultural uses.

To the north and east are residential and agricultural lands. To the west are industrial uses beyond SR 29. Immediately to the south is vacant land, beyond which are residential/commercial uses. d. Pre-Annexation Agreement
In June 2019, the American Canyon City Council adopted Resolution 2019-44 to execute a First Amended Pre-Annexation Agreement for the annexation area. The resolution notes that the annexation area includes continuous parcels to avoid creating an “island” of unincorporated territory surrounded by the City. The islands being referred to include the UPRR right-of-way in the southeastern section of the annexation area and the area to the east of the UPRR. The resolution includes a clause that mentions the dedication of a public right-of-way for the extension of Newell Drive. Finally, the resolution grants City Council the right to consider amending the General Plan to change the designation of the northern portion of the annexation area from Industrial to Community Commercial.

4.11.2 Regulatory Setting
a. Federal
There are no federal regulations that pertain to land use and planning. 477
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b. 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.

Sustainable Communities and Climate Protection Act (SB 375) The Sustainable Communities and Climate Protection Act (SB 375) supports the State's climate goals by helping reduce greenhouse gas emissions through coordinated transportation, housing, and land use planning. Under SB 375, the California Air Resources Board (CARB) set targets for 2020 and 2035 for each of the 18 metropolitan planning organization regions in 2010 and updated them in 2018.

Each of the regions must prepare a Sustainable Communities Strategy (SCS), as an integral part of its regional transportation plan, that contains land use, housing, and transportation strategies that, if implemented, would allow the region to meet CARB’s targets. SB 375 establishes some incentives to encourage implementation of the development patterns and strategies included in an SCS.

Developers can get relief from certain environmental review requirements under the California Environmental Quality Act (CEQA) if their new residential and mixed-use projects are consistent with a regions SCS that meets the targets (see Public Resources Code Sections 21155, 21155.1, 21155.2, and 21159.28).

Government Code Section 65860(a)
State law requires that general law city or town zoning ordinances be consistent with the general plan. A zoning ordinance is consistent with an adopted general plan only if the various land uses authorized by the zoning ordinance “are compatible with the objectives, policies, general land uses, and programs specified in such a plan” (Government Code Section 65860(a)). State law also provides that in the event a zoning ordinance becomes inconsistent with a general plan by reason of amendment to such a plan, the zoning ordinance must be amended within a reasonable time so that it is consistent with the general plan as amended [Government Code Section 65860(a)]. The City of American Canyon is a general law city and is, therefore, required to have zoning consistency.

Cortese Knox Hertzberg Local Government Reorganization Act of 2000 The 2000 Cortese Knox Hertzberg Local Government Reorganization Act (CKH Act) established procedures for local agency changes of organization, including city incorporation, annexation to a city or special district, and consolidation of cities or special districts (Section 56000, et seq.). Local Agency Formation Commissions (LAFCOs) have numerous powers under the CKH Act, but the most important are the power to act on local agency boundary changes and to adopt sphere of influences (SOIs) for local agencies. The law states that to update an SOI, LAFCOs are required to first conduct a review of the municipal services provided by the local agency. The CKH Act requires LAFCOs to update SOIs for every city and special district every five years. The original deadline was January 2006, five years following the CHK Act becoming State law. That deadline was extended two years to January 2008. Every SOI update must be accompanied by an update of the municipal services review. American Canyon’s SOI is not being updated as a part of the project. 478
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c. Local
Association of Bay Area Governments 2021 Regional Transportation Plan/Sustainable Communities Strategy
The Association of Bay Area Governments (ABAG) is required by State and federal law to prepare, update, and adopt a Regional Transportation Plan (RTP) every four years. The most recent update to the RTP/SCS was completed by ABAG and the Metropolitan Transportation Commission in October 2021. The 2021 RTP/SCS, also known as Plan Bay Area 2050, builds on ABAG’s 2017 RTP/SCS and serves as the blueprint for the region’s transportation system over the next 30 years (ABAG 2021).

The 2021 RTP/SCS includes the following goals:
 Protect and preserve affordable housing.
 Spur housing production for residents of all income levels.  Create inclusive communities.
 Improve economic mobility.
 Shift the location of jobs.
 Maintain and optimize the existing transportation system.  Create healthy and safe streets.
 Build a next-generation transit network.
 Reduce risks from hazards.
 Expand access to parks and open space.
 Reduce climate emissions.

American Canyon General Plan
The City’s General Plan guides how land in the city may be developed and used by designating each parcel of land for a particular use or combination of uses and by establishing broad development policies. Land use designations identify both the types of development, such as residential, commercial, and industrial, that are permitted and the density or intensity of allowed development, such as the minimum or maximum number of housing units permitted on an acre of land or the amount of building square footage allowed. Some of the key goals related to land use are summarized in Table 4.11-2 in Impact LU-2 (American Canyon 1994). 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.

City of American Canyon Municipal Code
The Zoning Code (Title 19) of the City of American Canyon Municipal Code is the primary tool used by the City to carry out the goals, objectives, and policies of the American Canyon General Plan by classifying and regulating the uses of land and structures within the city, consistent with the General Plan. Zoning is the instrument that implements the land use designations of a general plan. In addition to establishing permitted uses, zoning may also establish development standards relating to issues such as intensity, setbacks, height, and parking. Projects submitted to the City for review and approval are generally evaluated for consistency with the zoning designations. There are 21 existing zoning districts established by the American Canyon Zoning Ordinance, and those relevant to the project are as follows (American Canyon 2015):
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 RE – Residential Estate
 TC – Town Center
Napa County Airport Land Use Compatibility Plan
The Napa County Airport Land Use Compatibility Plan (ALUCP) governs land use around Napa County Airport. 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 of 35 feet above the ground for objects located within Zone D.

Additional height may be permitted under stringent Special Use Permit procedures as provided for in the Airport Safety Ordinance No. 416 and be referred to the Napa County ALUC prior to final approval. 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 The ALUCP follows Noise Compatibility Guidelines, as included in Table 2-1 of the ALUCP (ALUC 1991). New residential uses are not permitted within Zone D without ALUC review. However, the City entered a Settlement Agreement with the ALUC on May 3, 2022. The Settlement Agreement provides that the City will not approve any application for a residential use in Zone D until an amendment to the ALUCP has been approved or December 31, 2023, whichever occurs first. The Settlement Agreement does not prohibit the City from processing an application for a residential proposal within Zone D.

4.11.3 Impact Analysis
a. Significance Thresholds and Methodology
Significance Thresholds
Based on Appendix G of the CEQA Guidelines a project may be deemed to have a significant impact on land use and planning if it would:

1. Physically divide an established community;

2. Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

Methodology
This section describes the potential environmental impacts of the project relevant to land use and planning. The potential impacts from the project were evaluated through a review of existing policies and plans in the region and City. A consistency analysis of the project with applicable regional and city policies adopted for the purposes of reducing or mitigating an environmental effect was completed to identify potential impacts.
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b. Project Impacts and Mitigation Measures
Threshold 1: Would the project physically divide an established community? Impact LU-1 THE PROJECT WOULD NOT PHYSICALLY DIVIDE AN ESTABLISHED COMMUNITY AND THERE WOULD BE NO IMPACT.

There is an established community of single-family residences located on the southern portion of the project site. This area is designated as Residential Estate and the project would not result in any changes to this community. On the northern portion of the project site, industrial, commercial, visitor serving uses, and the Newell Drive Extension are proposed. There are no established communities in the northern portion where development would be located. The project would not physically divide an established community and there would be no impact.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
There would be no impact and no mitigation would be required.

Threshold 2: Would the project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
Impact LU-2 THE PROJECT WOULD NOT RESULT IN A SIGNIFICANT ENVIRONMENTAL IMPACT DUE TO A

CONFLICT WITH A PLAN ADOPTED FOR THE PURPOSE OF AVOIDING OR MITIGATING AN ENVIRONMENTAL EFFECT. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Several regionally and locally adopted land use plans, policies, and regulations apply to the project.

These include the Plan Bay Area 2050, the Bay Area 2017 Clean Air Plan, the General Plan, and the ALUCP. Project consistency with the 2017 Clean Air Plan is discussed in Section 4.3, Air Quality.

Project consistency with applicable goals and policies of Plan Bay Area 2050 and the General Plan are identified below in Table 4.11-1 and Table 4.11-2. Consistency of the project with the ALUCP are described below, after Table 4.11-2.

The environmental analysis evaluates the project’s consistency with existing applicable land use plans to avoid or mitigate any potential significant environmental effects. The project is considered consistent with identified regional and local plans when it meets the applicable plan’s intent and there are no direct conflicts with applicable policies. The following principles are used in this analysis:
 A project need not be in perfect conformity with every policy, nor does state law require a proposed project to precisely conform with every policy or land use designation.  Courts have also acknowledged that general and specific plans attempt to balance a range of competing interests, and that it is nearly, if not absolutely, impossible for a project to perfectly conform with every policy set forth in the applicable plan.  In reaching a consistency conclusion, the City may also consider the consequences of project denial, which may cause an inconsistency with other policies. 481
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For an impact to be considered significant, an inconsistency would have to result in a significant adverse change in the environment not already addressed in the other resource chapters of this EIR.

The analysis below provides a discussion of the most relevant policies from applicable planning documents. However, the City’s consistency conclusions are based upon the planning documents as a whole.

Table 4.11-1 Project Consistency with the Plan Bay Area 2050 Plan Bay Area Goals Project Consistency
Environmental Strategies
EN4. Maintain urban growth boundaries. Using urban
growth boundaries and other existing environmental
protections, focus new development within the
existing urban footprint or areas otherwise suitable for growth, as established by local jurisdictions.

Consistent. The project site boundaries are consistent with the City’s Sphere of Influence and Urban Limit Line.

Economic Strategies
EC6. Retain and invest in key industrial lands.

Implement local land use policies to protect key
industrial lands, identified as Priority Production
Areas, while funding key infrastructure improvements
in these areas.

Consistent. The project is located in a proposed PPA. The proposed Industrial land use would provide funding for utility infrastructure, including the Newell Drive extension.

Table 4.11-2 Project Consistency with the City of American Canyon General Plan Goal, Policy, Objective Project Consistency
Land Use and Community Design Element
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
subregion; and (d) provide open space and aesthetic
relief from developed urban/suburban areas
Consistent. The project would allow multiple land uses in the project site including commercial, industrial, and residential.

The project’s industrial and commercial areas will provide employment opportunities for the City and surrounding
region.

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 quality of life in
American Canyon.

Consistent. As described in Section 4.14, Public Services and Recreation and Section 4.17, Utilities and Service Systems, there would be sufficient infrastructure for the 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.).

Consistent. As described in Section 4.14, Public Services and Recreation and Section 4.17, Utilities and Service Systems, there would be sufficient infrastructure for the project. 482
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Goal, Policy, Objective Project Consistency
Utilities Element
Goal 5A. 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. As described in Section 4.17, Utilities and Service Systems, the project would be required to implement the Zero Water Footprint policy, which would result in a no net
increase in potable water use in the City’s water distribution system. For this reason, there would be sufficient water supplies for the project.

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. Section 4.10, Hydrology and Water Quality
identifies regulations, as well as Mitigation Measures HYD-2, that the project would implement to minimize storm drainage impacts. Section 4.17, Utilities and Service Systems identifies that adequate storm drains would be provided.

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.

Consistent. As described in Section 4.17, Utilities and Service Systems, the City’s wastewater treatment facilities have adequate capacity for the incremental increase in demand resulting from this project.

Goal 5F. To provide for the collection and disposal of
solid waste while maximizing source reduction,
recycling and composting, within economic constrains.

Consistent. As described in Section 4.17, Utilities and Service Systems, future development at the project site would be required to comply with existing regulations related to reducing and recycling solid waste.

Public Services and Facilities Element
Objective 6.1. Provide adequate educational facilities
and programs that meet the needs of American
Canyon’s residents by coordination development
activities with the Napa Valley Unified School District.

Consistent. As described in Section 4.19, Effects Found Not to be Significant, the project would pay State-mandated school impact fees, which would ensure there are adequate
educational facilities to meet the additional demand from the project.

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

Consistent. As described in Section 4.14, Public Services and Recreation, implementation of Mitigation Measure PSR-1
would ensure that adequate measures are implemented to
ensure adequate emergency services. In accordance with
standard practices, American Canyon Fire Protection District would review project plans, for any future projects at the project site before permits are issued to ensure compliance with all applicable fire and building code standards and ensure adequate emergency access is provided to the site.

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

Consistent. As described in Section 4.14, Public Services and Recreation, the Police Department will have the opportunity to review and comment on security measures during the plan check review process for future development on the project site and the project would be expected to generate minimal calls for service.

Goal 6C. Ensure the enhanced provision of library
services for the City’s residents and businesses.

Consistent. As described in Section 4.14, Public Services and Recreation, the project would pay Civic Facilities Fees, a portion of which would provide funding to ensure there are adequate library resources to meet the project’s demand.

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

Consistent. As described in Section 4.4, Biological Resources, implementation of Mitigation Measures BIO-1 through BIO-7 would ensure that the project preserves habitat, plants, and wildlife.
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Goal, Policy, Objective Project Consistency
Goal 8A. Maintain the quality of surface and
subsurface water resources within the City of
American Canyon and its Planning Area.

Consistent. As described in Section 4.10, Hydrology and Water Quality, future development on the project site would adhere to existing regulations that would protect the quality of surface and subsurface water resources.

Goal 8B. Promote the preservation of American
Canyon’s soil resources by protecting areas that are
suitable for agricultural uses or buffer zones.

Consistent. As described in Section 4.2, Agriculture and Forestry Resources, the project would result in no impacts to agricultural resources.

Goal 8C. Maintain proper management of designated
mineral extraction areas to meet the needs of the City
while ensuring adequate reclamation of those sites.

Consistent. As described in Section 4.19, Effects Found Not to be Significant, project implementation would not affect mineral resources.

Goal 8D. Maintain the natural visual character of the
City.

Consistent. As described in Section 4.1, Aesthetics, the project would not significantly affect scenic resources within the City and would be consistent with the policies identified under Goal 8D.

Objective 8.19. Ensure that the City’s historically and archaeologically significant resources are protected in a manner that preserves and/or enhances the
resources’ inherent historic value.