Agenda packet — American Canyon City Council, November 19, 2024 (part 5 of 16)

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

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

Consistent: This Draft EIR evaluates
project impacts on the American
Canyon Police Department and
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concludes that no new or expanded
police facilities would be required.

Refer to Section 3.12, Public
Services, for further discussion.

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

Consistent: This Draft EIR evaluates
project impacts on the American
Canyon Police Department and
concludes that no new or expanded
police facilities would be required.

Refer to Section 3.12, Public
Services, for further discussion.

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

Consistent: This Draft EIR evaluates
project impacts on the American
Canyon Police Department and
concludes that no new or expanded
police facilities would be required.

Refer to Section 3.12, Public
Services, for further discussion.

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

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

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

Consistent: The proposed project
would provide low-profile, nonobtrusive landscaping to allow for adequate security surveillance.

Refer to Chapter 2, Project
Description, for discussion of the
proposed project’s landscaping.

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

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

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

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

Objective 8.1 Maintain data and information
regarding areas of significant biological
Consistent: This Draft EIR’s
evaluation of potential impacts on
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value within the Planning Area to
facilitate resource conservation and
the appropriate management of
development.
biological resources included
review of relevant databases of
biological information and field
surveys of the project site. The
findings thereof were used in
developing appropriate mitigation
for project impacts. This is
consistent with the objective of
using best available information to
facilitate resource conservation.

Refer to Section 3.3, Biological
Resources, for further discussion.

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

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

Policy 8.1.4 Regularly monitor and review
developments proposed within the
City’s Planning Area to assess their
impacts on local biological resources
and to recommend appropriate
mitigation measures that the
developer and/or government
agency can implement.

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

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

Consistent: The proposed project
site includes two isolated wetlands
that would be preserved. This is
consistent with the objective of
balancing the preservation of
natural habitat areas with new
development.

Policy 8.2.1 Land use applications for
developments located within sensitive
habitats, including coastal saltmarsh,
mixed hardwood forest, oak savanna,
and riparian habitats or with areas
potentially occupied by vernal pools
Consistent: The project site
contains two isolated wetlands.

This Draft EIR includes biological
and wetland analysis conducted by
FCS, a biological consulting firm.
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(see Figure 8-2) shall be accompanied
by sufficient technical background
data to enable an adequate
assessment of the potential for
impacts on these resources, and
possible measures to reduce any
identifiable impacts. In addition to
examining Figure 8-1 for information
on these sensitive habitats, an on-site
assessment shall be conducted by a
City approved qualified Biologist to
determine whether sensitive habitats
exist on-site.

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

Refer to Section 3.3, Biological
Resources, for further discussion.

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

Consistent: The proposed project
avoids any impacts to North
Slough, which is located west of the
project site. The on-site wetlands
would be preserved. This is
consistent with the objective of
protecting natural drainages and
riparian corridors.

Policy 8.3.1 Review proposed developments in
wetlands and riparian habitats to
evaluate their conformance with the
following policies and standards:
a. The development plan shall fully
consider the nature of existing
biological resources and all
reasonable measures shall be
taken to avoid significant impacts,
including retention of sufficient
natural open space and
undeveloped buffer zones.
b. Development shall be designed
and sited to preserve
watercourses, riparian habitat,
vernal pools, and wetlands in their
natural condition, unless these
actions result in an unfeasible
project, in which case habitat shall
be replaced in accord with
subsection “g.”
c. Where riparian corridors are
retained, they shall be protected
Consistent: The proposed project is
designed to preserve the two
isolated wetlands. The proposed
project would be required to obtain
approvals from United States Army
Corp of Engineers (USACE),
California Department of Fish and
Wildlife (CDFW), and Regional
Water Quality Control Board
(RWQCB) and adhere to all
provisions of those permits. For
these reasons, the proposed
project is consistent with the
provisions of this policy.
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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 Corp of
Engineers in order to account for
the potentially diminished habitat
values of replacement habitat.

Such replacement should occur on
the original development site,
whenever possible. Alternatively,
replacement can be effected,
subject to State and federal
regulatory approval, by creation or
restoration of replacement
habitats elsewhere (off-site but
preferably within the City’s
Planning Area), protected in
perpetuity by provision for an
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appropriate conservation
easement or dedication.

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

Development that is permitted
within Riparian Corridors shall:
a. minimize removal of vegetation,
erosion, sedimentation and runoff
by appropriate protection or
vegetation and landscape;
b. provide for sufficient passage of
native and anadromous fish;
c. minimize wastewater discharges
and entrapment;
d. prevent ground water depletion or
substantial interference with
surface and subsurface flows;
e. provide for natural vegetation
buffers;
f. minimize the channelization of
streams and other watercourses;
g. provide for the enhancement of
riparian corridors.

Consistent: The proposed project
avoids any impacts to North
Slough, which is located west of the
project site.

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

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

Consistent: The proposed project
avoids any impacts to North
Slough, which is located west of the
project site.

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

Consistent: The proposed project
preserves the two isolated
wetlands on the project site.

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

Consistent: Implementation of the
proposed project would require
compulsory compliance with the
latest adopted edition of the CBC to
reduce the potential level of death,
injury, property damage, and
economic and social dislocation to
acceptable levels. Refer to Section

3.6, Geology, Soils, and Seismicity,
for further discussion.

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

Consistent: Implementation of the
proposed project would require
compulsory compliance with the
latest adopted edition of the CBC to
ensure that seismic hazards are
properly mitigated or avoided
entirely prior to development.

Refer to Section 3.6, Geology, Soils,
and Seismicity, for further
discussion.

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

Consistent: Implementation of the
proposed project would require
compulsory compliance with the
latest adopted edition of the CBC to
protect life, ensure public safety,
and substantially reduce damage to
structures. Refer to Section 3.6,
Geology, Soils, and Seismicity, for
further discussion.
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Policy 9.1.1 Promote the collection of relevant
data on fault location and the history
of fault displacement as a basis for
future refinement of fault zone
policies and development standards.

Particular attention should be paid to
the West Napa Fault that is generally
depicted in Figure 9-1 and should be
evaluated in conjunction with
proposed development. Based on
predevelopment studies, limitations
on new development shall be
imposed if necessary in the identified
fault areas.

Consistent: The project site is not
located within the West Napa Fault
zone. Refer to Section 3.6, Geology,
Soils, and Seismicity, for further
discussion.

Policy 9.1.2 Implement mandatory development
restrictions and investigation
requirements (by the State, under
the Alquist-Priolo Act, or by the City)
on that portion of the West Napa
Fault zone located within American
Canyon and its Planning Area.

Consistent: The project site is not
located within the West Napa Fault
zone. Refer to Section 3.6, Geology,
Soils, and Seismicity, for further
discussion.

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

Consistent: Implementation of the
proposed project would require
compulsory compliance with the
latest adopted edition of the CBC to
ensure that strong seismic ground
shaking hazards are properly
mitigated. Refer to Section 3.6,
Geology, Soils, and Seismicity, for
further discussion.

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

Consistent: Implementation of the
proposed project would require
compulsory compliance with of the
latest adopted edition of the CBC
seismic design requirements. Refer
to Section 3.6, Geology, Soils, and
Seismicity, for further discussion.

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

Consistent: The risk of liquefaction
at the project site is low. Refer to
Section 3.6, Geology, Soils, and
Seismicity, for further discussion.

Policy 9.3.1 Avoid development in areas with
known liquefaction risk. If these
Consistent: The risk of liquefaction
at the project site is low. Refer to
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areas cannot be avoided, require a
qualified geologist, hydrologist, or
civil engineer to determine the
liquefaction potential at proposed
development sites.

Section 3.6, Geology, Soils, and
Seismicity, for further discussion.

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

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

Adherence to these standards would
minimize potential exposure to
disruptions associated with
earthquakes. Refer to Section 3.6,
Geology, Soils, and Seismicity for
further discussion.

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

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

3.9, Hydrology and Water Quality.

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

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

3.9, Hydrology and Water Quality.

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

Consistent: The proposed project
avoids any impacts to North
Slough, which is located west of the
project site.

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

Consistent: The proposed project’s
storm drainage system would be
designed in accordance with the
City’s peak flow design standards.

Refer to Section 3.9, Hydrology and
Water Quality.

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
Consistent: The project site is
located outside of a 100-year flood
hazard area. Therefore, the
proposed warehouse would not be
located within the 100-year
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one (1) foot above the 100-year flood
elevation, or by other means approved
by the City Engineer (see Figure 10-1).
floodplain. Refer to Section 3.9,
Hydrology and Water Quality.

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

Consistent: This Draft EIR includes
an evaluation of project-related
noise impacts. No mitigation is
necessary to achieve acceptable
noise levels. Refer to Section 3.11,
Noise, for further discussion.

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

Consistent: This Draft EIR includes an
evaluation of project-related noise
impacts including ambient and
stationary noise sources. Refer to
Section 3.11, Noise, for further
discussion.

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

Consistent: This Draft EIR includes
an evaluation of project-related
noise impacts and assesses noise
levels against the standards
identified in Figure 11-2 to
determine whether significant
impacts would occur. No mitigation
is necessary to achieve acceptable
noise levels. Refer to Section 3.11,
Noise, for further discussion.

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

Consistent: This Draft EIR includes
an evaluation of project-related
noise impacts including the analysis
of ambient and stationary noise
levels. Refer to Section 3.11, Noise,
for further discussion.

Policy 11.2.1 Require that new development for
locations in which the exterior or
interior noise levels indicated in
Figure 11-2 are likely to be exceeded,
Consistent: The project site is not
located in any “Sensitive Noise
Areas” depicted on Figure 11-2.

Regardless, a noise analysis was
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submit a noise attenuation study
prepared by a qualified acoustical
engineer in order to determine
appropriate mitigation measures.
prepared for the proposed project
and no mitigation is identified as
necessary. Refer to Section 3.11,
Noise, for further discussion.

Policy 11.2.4 Require that new industrial,
commercial and related land uses, or
the expansion of these existing land
uses, demonstrate that they would
not directly cause ambient noise
levels to exceed an exterior Ldn of 65
dB(A) in areas containing housing,
schools, health care facilities, or
other “noise-sensitive” land uses.

Additionally, require that potentially
significant noise generators, including
uses such as night clubs that cause
sporadic noise intensities, submit
noise analyses prepared by an
acoustical expert that include specific
recommendations for mitigation
when: a) the project is located in
close proximity to noise-sensitive
land uses or land that is planned for
noise-sensitive land uses, or b) the
proposed noise source could violate
the noise provisions of the General
Plan or City Noise ordinance.

Consistent: Noise-sensitive land
uses near the project site were
identified and analyzed as a part of
this Draft EIR. The proposed project
would not have the potential to
increase ambient noise levels
above 65 dBA Ldn. Refer to Section

3.11, Noise for further discussion.

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

Consistent: Trucks traveling to and
from the project site would use
Green Island Road to reach SR-29
and SR-12, which would avoid areas
designated for residential use by the
General Plan. Refer to Section 3.11,
Noise for further discussion.

Consistent: Trucks would use Green
Island Road to reach SR-29 and SR12 to reach the project site. This routing would avoid residential
areas and, therefore, would be
consistent with this policy. Refer to
Section 3.8, Hazards and Hazardous
Materials and Section 3.11, Noise,
for further discussion.
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c. Work closely with the State of
California Department of
Transportation (Caltrans) in the
early stages of highway
improvements and design
modifications to ensure that
proper consideration is given to
potential noise impacts on the City.

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

Consistent: Trucks traveling to and
from the project site would use
Green Island Road to reach SR-29
and SR-12, which would avoid areas
designated for residential use by the
General Plan as well as nearby
sensitive receptors. Refer to Section

3.11, Noise for further discussion.

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

Consistent: The project site is
located outside the 55 dBA CNEL
contour of Napa County Airport.

Regardless, the proposed project
consists of industrial uses which are
“normally acceptable” land use
activities within this noise contour.

Refer to Section 3.8, Hazards and
Hazardous Materials, and Section

3.11, Noise, for further discussion.

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

Consistent: The Napa County
ALUCP identifies aviation noise
levels between 60 and 65 dBA CNEL
as “normally acceptable” for
warehouse uses. As such, the
proposed project would be
consistent with the ALUCP noise
standards. Refer to Section 3.9,
Hazards and Hazardous Materials,
and Section 3.11, Noise, for further
discussion.

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

Consistent: The project site is in an
area that contains noise-tolerant
nonresidential uses. As such, the
proposed project would not have
the potential to cause “spillover”
noise into adjoining residential
neighborhoods or “noise-sensitive”
uses. Refer to Section 3.11, Noise,
for further discussion.
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Objective 11.7 Minimize the impacts of construction
noise on adjacent uses.

Consistent: The project site is in an
area that contains noise-tolerant
nonresidential uses. As such,
surrounding land uses would not
experience intrusive noise levels
during project-related construction
activities. Refer to Section 3.11,
Noise, for further discussion.

Source: City of American Canyon 2023; FirstCarbon Solutions (FCS) 2023.

Level of Significance Before Mitigation
Less than significant impact.

Mitigation Measures
No mitigation is necessary.

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

Impact Analysis
The proposed project would develop a 219,834-square-foot wine warehouse on the project site.

Per Municipal Code Section 19.15.020, winery related uses, including such activities as bottling, storage, logistics, distribution, wine packing and wine-related services, are conditionally permitted within the Recreation zone subject to approval of a use permit by the planning commission.

Therefore, the project’s proposed end uses would be consistent with the types of conditionally permitted uses set forth in the Zoning Ordinance for the Recreation zoning district.

The proposed project would also be consistent with the Municipal Code’s applicable development standards for the Recreation zone as outlined in Table 3.10-3.

Table 3.10-3: Development Standards Consistency
Development Standard Allowable Proposed Project
Maximum Site Coverage1,2 50% 49.6 (0.496 FAR)
Maximum Building Height 35 Feet 35 Feet
Minimum Building Setback from Local Streets 15 feet 63 Feet Minimum Building Setback–Interior Nonresidential–Side 35 Feet 65 Feet (minimum) Minimum Building Setback–Interior Nonresidential–Rear 35 Feet 88 Feet (minimum) 939
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Notes:
1 Outdoor winery related equipment such as tanks and crushing equipment customarily located outside of buildings are not included within the lot coverage standards. Note that no crushing is proposed. 2 Outdoor winery related equipment shall be screened from view of public streets, parks and trails with landscaping, opaque fence or wall. Note that no outdoor winery equipment is proposed.

Source: FirstCarbon Solutions (FCS) 2023. City of American Canyon Municipal Code 2023.

Impacts would be less than significant.

Level of Significance Before Mitigation
Less than significant impact.

Mitigation Measures
No mitigation is necessary.

Airport Land Use Compatibility Plan Consistency
Impact LU-3: The proposed project would not conflict with the applicable provisions of the Napa County Airport Land Use Compatibility Plan.

Impact Analysis
The project site falls within the Napa County ALUCP Area.

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

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

Uses with an outdoor component can have up to 150 per net acre. The ALUCP does not limit the number of people that can be clustered in any one acre of the parcel within Zone D. Net acreage is 940
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Additionally, the ALUCP prohibits residential uses and uses posing hazards to flight. Hazards to flight include objects that penetrate FAR Part 77 airspace surfaces, uses that would attract large numbers of birds, and uses that would create smoke, glare, distracting lights, or electronic interference.

The analysis that follows assesses the ALUCP density and airspace criteria that relate to the project site.

Maximum Density
The proposed project includes a single distribution warehouse for winery related functions. This land use is generally consistent with ALUCP criteria, provided that the uses do not attract large concentrations of people.

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

A total of 134 car and 23 truck parking spaces would be provided on-site. It is anticipated that approximately 35 full-time employees and up to 20 part-time employees would be on-site at any given time. The proposed uses would generate client or user trips and it is estimated that such trips would be limited to 2 or 4 occurrences per day. Therefore, an anticipated maximum persons on-site would be approximately 59 (employees plus maximum estimated client or user trips), which is far less than the density criterion of 100 people per net acre for Zone D. Conversely, if the parking space totals were used to estimate on-site density, the anticipated maximum persons on-site would be approximately 151, also far less than the density criterion of 100 people per net acre for Zone D.

Furthermore, an Avigation and Hazard Easement Deed extending over the whole of the property was executed by the landowner and recorded by Napa County on July 26, 2019. As such, the proposed project would be consistent with maximum allowable densities in Zone D. Impacts would be less than significant.

Wildlife Attractants
The two isolated wetlands would be preserved. Depending on their characteristics, wetlands can be avian attractants. Avian species are considered potential hazards to aviation activities due to the potential for bird strikes.

The isolated wetlands are small in comparison to adjacent available wetland areas and do not currently attract significant amounts of avian species. Upon project completion, the wetlands would be surrounded by pervious surfaces including buildings, parking areas, and drive aisles. These features would be expected to deter avian activity.
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3.10-48 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/EIR/2 - Screencheck EIR/edit/56390001 Sec03-10 Land Use.docx As such, the proposed project would not increase the avian attractant attributes of the project site or nearby areas under the Napa County Airport flight path compared to existing conditions. Impacts would be less than significant.

Light, Glare, Dust, Steam, and Other Aviation Hazards
The ALUCP Policy 3.3.5 states the following:

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

The proposed project’s end uses include warehouse and ancillary office operations, which are considered normally acceptable by the ALUCP as long as they do not create hazards. As indicated in Section 3.1, Aesthetics, the proposed project is not expected to result in significant impacts related to light and glare and would be required to abide by applicable Municipal Code Ordinances regarding light, glare and light spillage. As such, the proposed project would not create hazards to aviation.

Impacts would be less than significant.

Level of Significance Before Mitigation
Less than significant impact.

Mitigation Measures
No mitigation is necessary.

3.10.7 - Cumulative Impacts
The geographic scope of the cumulative land use analysis is the area within 1 mile of the project site.

Existing development in this area is predominantly industrial uses, including the airport. Projects under construction include the Napa Logistics Park Project, which is approved for warehouse and other similar uses. Foreseeable future development in the area includes SDG Commerce 217 and the Green Island Road Widening Project.

The proposed project would be consistent with the American Canyon General Plan, American Canyon Zoning Ordinance, and the Napa County ALUCP because its proposed uses are allowed under these plans. The existing uses in the area are generally industrial and related compatible uses.

Projects under consideration in the area and reasonably foreseeable future projects would also be required to be consistent with the General Plan, the City’s Zoning Ordinance, and the Airport Land Use Compatibility Plan. Additionally, the proposed project and other nearby development would be and have been required to implement wildlife management plans to ensure compatibility with airport operations. Consequently, the proposed project, in conjunction with past, present, and reasonably foreseeable development, would not result in a cumulatively significant land use impact. 942
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Less than significant impact.

Mitigation Measures
No mitigation is necessary.
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3.11 - Noise

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

The following public comments pertaining to noise were received in response to the Notice of Preparation (NOP):
• Notes that noise levels resulting from warehouse uses, such as truck traffic and loading activities, should be analyzed in the Draft EIR.
• States that noise impacts on sensitive receptors should be addressed in the Draft EIR. • States that the Draft EIR should analyze ways in which noise impacts could be reduced via physical, structural, and/or vegetative buffers.
• Requests that the Department of Justice Best Practices and Mitigation Measures for Warehouses1 be incorporated into the proposed project.
• States that construction noise should be addressed in the Draft EIR.

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

Sound is produced by the vibration of sound pressure waves in the air. Sound pressure levels are used to measure the intensity of sound and are described in terms of decibels. The decibel (dB) is a logarithmic unit, which expresses the ratio of the sound pressure level being measured to a standard reference level. The 0 point on the dB scale is based on the lowest sound level that the healthy, unimpaired human ear can detect. Changes of 3 dB or less are only perceptible in laboratory environments. Audible increases in noise levels generally refer to a change of 3 dB or more, as this level has been found to be barely perceptible to the human ear in outdoor environments. Only audible changes in existing ambient or background noise levels are considered potentially significant. 1 California Department of Justice. Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act. Website: https://oag.ca.gov/system/files/media/warehouse-best-practices.pdf. Accessed November 28, 2023.
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3.11-2 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/EIR/2 - Screencheck EIR/edit/56390001 Sec03-11 Noise.docx The human ear is not equally sensitive to all frequencies within the audible sound spectrum, so sound pressure level measurements can be weighted to better represent frequency-based sensitivity of average healthy human hearing. One such specific “filtering” of sound is called ”A-weighting.” Aweighted decibels (dBA) approximate the subjective response of the human ear to a broad frequency noise source by discriminating against very low and very high frequencies of the audible spectrum. They are adjusted to reflect only those frequencies that are audible to the human ear.

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

Noise Descriptors
There are many ways to rate noise for various intervals, but an appropriate rating of ambient noise affecting humans also accounts for the annoying effects of sound. Equivalent continuous sound level (Leq) is the total sound energy of time-varying noise over a sample period. However, the predominant rating scales for human communities in the State of California are the Leq and community noise equivalent level (CNEL) or the day-night average level (Ldn) based on dBA. CNEL is the time-varying noise over a 24-hour period, with a 5 dBA weighting factor applied to the hourly Leq for noises occurring from 7:00 p.m. to 10:00 p.m. (defined as relaxation hours) and a 10 dBA weighting factor applied to noise occurring from 10:00 p.m. to 7:00 a.m. (defined as sleeping hours). Ldn is similar to the CNEL scale but without the adjustment for events occurring during the evening hours. CNEL and Ldn are within one dBA of each other and are normally exchangeable. The noise adjustments are added to the noise events occurring during the more sensitive hours.

Other noise rating scales of importance when assessing the annoyance factor include the maximum noise level (Lmax), which is the highest exponential time-averaged sound level that occurs during a stated time period. The noise environments discussed in this analysis are specified in terms of maximum levels denoted by Lmax for short-term noise impacts. Lmax reflects peak operating conditions and addresses the annoying aspects of intermittent noise.

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

The attenuation or sound drop-off rate is dependent on the conditions of the land between the noise source and receiver. To account for this ground-effect attenuation (absorption), two types of site conditions are commonly used in noise models: soft-site and hard-site conditions. Soft-site conditions account for the sound propagation loss over natural surfaces such as normal earth and ground vegetation. For point sources, a drop-off rate of 7.5 dBA per each doubling of the distance 946
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Table 3.11-1: Sound Terminology
Term Definition
Sound A vibratory disturbance created by a vibrating object which, when transmitted by pressure waves through a
medium such as air, can be detected by a receiving
mechanism such as the human ear or a microphone.

Noise Sound that is loud, unpleasant, unexpected, or
otherwise undesirable.

Ambient Noise The composite of noise from all sources near and far in a given environment.

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

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

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

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

Day-Night Level (DNL or Ldn) The energy average of the A-weighted sound levels occurring during a 24-hour period, with 10 dB added
to the A-weighted sound levels occurring between
10:00 p.m. and 7:00 a.m. (nighttime).

Community Noise Equivalent Level (CNEL) The energy average of the A-weighted sound levels occurring during a 24-hour period, with 5 dB added to
the A-weighted sound levels occurring between 7:00
p.m. and 10:00 p.m. and 10 dB added to the Aweighted sound levels occurring between 10:00 p.m. and 7:00 a.m.

Source: Data compiled by FirstCarbon Solutions (FCS). 2023. 947
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The level of traffic noise depends on the three primary factors: (1) the volume of the traffic, (2) the speed of the traffic, and (3) the number of trucks in the flow of traffic. Generally, the loudness of traffic noise is increased by heavier traffic volumes, higher speeds, and greater number of trucks. Vehicle noise is a combination of the noise produced by the engine, exhaust, and tires. Because of the logarithmic nature of noise levels, a doubling of the traffic volume (assuming that the speed and truck mix do not change) results in a noise level increase of 3 dBA. Based on the Federal Highway Administration (FHWA) community noise assessment criteria, this change is “barely perceptible”; for reference, a doubling of perceived noise levels would require an increase of approximately 10 dBA. The truck mix on a given roadway also has an effect on community noise levels. As the number of heavy trucks increases and becomes a larger percentage of the vehicle mix, adjacent noise levels increase.

Stationary Noise
A stationary noise producer is any entity in a fixed location that emits noise. Examples of stationary noise sources include machinery, engines, energy production, and other mechanical or powered equipment and activities such as loading and unloading or public assembly that may occur at commercial, industrial, manufacturing, or institutional facilities. Furthermore, while noise generated by the use of motor vehicles over public roads is preempted from local regulation, the use of these vehicles is considered a stationary noise source when operated on private property such as at a construction site, a truck terminal, or warehousing facility. The emitted noise from the producer can be mitigated to acceptable levels either at the source or on the adjacent property through the use of proper planning, setbacks, block walls, acoustic-rated windows, or dense landscaping or by changing the location of the noise producer.

The effects of stationary noise depend on factors such as characteristics of the equipment and operations, distance and pathway between the generator and receptor, and weather. Stationary noise sources may be regulated at the point of manufacture (e.g., equipment or engines), with limitations on the hours of operation, or with provision of intervening structures, barriers, or topography.

Construction activities are a common source of stationary noise. Construction-period noise levels are higher than background ambient noise levels but eventually cease once construction is complete.

Construction is performed in discrete steps, each of which has its own mix of equipment and, consequently, its own noise characteristics. These various sequential phases would change the character of the noise generated on each construction site and, therefore, would change the noise levels as construction progresses. Despite the variety in the type and size of construction equipment, similarities in the dominant noise sources and patterns of operation allow construction-related noise ranges to be categorized by work phase. Table 3.11-2 shows typical noise levels of construction equipment as measured at a distance of 50 feet from the operating equipment. 948
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Specification Maximum Sound Levels for
Analysis (dBA at 50 feet)
Impact Pile Driver Yes 95
Auger Drill Rig No 85
Vibratory Pile Driver No 95
Jackhammers Yes 85
Pneumatic Tools No 85
Pumps No 77
Scrapers No 85
Cranes No 85
Portable Generators No 82
Rollers No 85
Bulldozers No 85
Tractors No 84
Front-End Loaders No 80
Backhoe No 80
Excavators No 85
Graders No 85
Air Compressors No 80
Dump Truck No 84
Concrete Mixer Truck No 85
Pickup Truck No 55
Notes:
dBA = A-weighted decibel
Source: Federal Highway Administration (FHWA). 2006. Highway Construction Noise Handbook. August.

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

Instead, if the difference between two noise sources is 10 dBA or more, the louder noise source will dominate, and the resultant noise level will be equal to the noise level of the louder source. In general, if the difference between two noise sources is 0–1 dBA, the resultant noise level will be 3 dBA higher than the louder noise source, or both sources if they are equal. If the difference between two noise sources is 2–3 dBA, the resultant noise level will be 2 dBA above the louder noise source. 949
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Characteristics of Vibration
Groundborne vibration consists of rapidly fluctuating motion through a solid medium, specifically the ground, which has an average motion of zero and in which the motion’s amplitude can be described in terms of displacement, velocity, or acceleration. The effect of groundborne vibration typically only causes a nuisance to people, but in extreme cases, excessive groundborne vibration has the potential to cause structural damage to buildings. Although groundborne vibration can be felt outdoors, it is typically only an annoyance to people indoors where the associated effects of the shaking of a building can be notable. Groundborne noise is an effect of groundborne vibration and only exists indoors, since it is produced from noise radiated from the motion of the walls and floors of a room and may also consist of the rattling of windows or dishes on shelves.

Several different methods are used to quantify vibration amplitude such as the maximum instantaneous peak in the vibrations velocity, which is known as the peak particle velocity (PPV) or the root mean square (rms) amplitude of the vibration velocity. Because of the typically small amplitudes of vibrations, vibration velocity is often expressed in decibels—denoted as LV—and is based on the reference quantity of 1 microinch per second. To distinguish vibration levels from noise levels, the unit is written as “VdB.”
Although groundborne vibration can be felt outdoors, it is typically only an annoyance to people indoors where the associated effects of the shaking of a building can be notable. When assessing annoyance from groundborne vibration, vibration is typically expressed as rms velocity in units of decibels of 1 microinch per second, with the unit written in VdB. Typically, developed areas are continuously affected by vibration velocities of 50 VdB or lower. Human perception of vibration starts at levels as low as 67 VdB. Annoyance due to vibration in residential settings starts at approximately 70 VdB.

Off-site sources that may produce perceptible vibrations are usually caused by construction equipment, steel-wheeled trains, and traffic on rough roads, while smooth roads rarely produce perceptible groundborne noise or vibration. Construction activities, such as blasting, pile driving, and operating heavy earthmoving equipment, are common sources of groundborne vibration. Construction vibration impacts on building structures are generally assessed in terms of PPV. Typical vibration source levels from construction equipment are shown in Table 3.11-3.

Table 3.11-3: Vibration Levels of Construction Equipment Construction Equipment PPV at 25 Feet (inches/second)
rms Velocity in Decibels (VdB)
at 25 Feet
Water Trucks 0.001 57
Scraper 0.002 58
Bulldozer (small) 0.003 58
Jackhammer 0.035 79
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rms Velocity in Decibels (VdB)
at 25 Feet
Concrete Mixer 0.046 81
Concrete Pump 0.046 81
Paver 0.046 81
Pickup Truck 0.046 81
Auger Drill Rig 0.051 82
Backhoe 0.051 82
Crane (mobile) 0.051 82
Excavator 0.051 82
Grader 0.051 82
Loader 0.051 82
Loaded Trucks 0.076 86
Bulldozer (large) 0.089 87
Caisson drilling 0.089 87
Vibratory Roller (small) 0.101 88
Compactor 0.138 90
Clam Shovel Drop 0.202 94
Vibratory Roller (large) 0.210 94
Pile Driver (impact-typical) 0.644 104
Pile Driver (impact-upper range) 1.518 112
Notes:

PPV = peak particle velocity
rms = root mean square
VdB = velocity in decibels
Source:

Federal Highway Administration (FHWA). 2006. Highway Construction Noise Handbook. August.

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

Among these factors that influence groundborne vibration, there are significant differences in the vibration characteristics when the source is underground compared to at the ground surface. In 951
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Vibration propagation through groundwater is more efficient than through sandy soils. There are three main types of vibration propagation: surface, compression, and shear waves. Surface waves, or Rayleigh waves, travel along the ground’s surface. These waves carry most of their energy along an expanding circular wave front, similar to ripples produced by throwing a rock into a pool of water. Pwaves, or compression waves, are body waves that carry their energy along an expanding spherical wave front. The particle motion in these waves is longitudinal (i.e., in a “push-pull” fashion). P-waves are analogous to airborne sound waves. S-waves, or shear waves, are also body waves that carry energy along an expanding spherical wave front. However, unlike P-waves, the particle motion is transverse, or side-to-side and perpendicular to the direction of propagation.

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

As stated above, this drop-off rate can vary greatly depending on the soil type, but it has been shown to be effective enough for screening purposes, in order to identify potential vibration impacts that may need to be studied through actual field tests. The vibration level (calculated below as “PPV”) at a distance from a point source can generally be calculated using the vibration reference equation:

PPV= PPVref * (25/D)^n (in/sec)
Where:

PPVref = reference measurement at 25 feet from vibration source D = distance from equipment to the receptor
n = vibration attenuation rate through ground
According to Chapter 12 of the Federal Transit Administration (FTA) Transit Noise and Vibration Impact Assessment Manual, an “n” value of 1.5 is recommended to calculate vibration propagation through typical soil conditions.2
Existing Noise Levels
The project site is located in the City of American Canyon (City), Napa County (County), California.

The project site is bounded by a eucalyptus grove, North Slough, and Napa River to the west; a parcel entitled for a wine distribution warehouse known as SDG Commerce 217 and other industrial development to the north; Commerce Court, beyond which is a paintball recreation area within a stand of eucalyptus trees to the east; and a wine distribution warehouse known as SDG Commerce 330 to the south beyond which is wetlands Edge Park; refer to Chapter 2, Project Description, Exhibit 2 Federal Transit Administration (FTA). 2006. Transit Noise and Vibration Impact Assessment Manual. May. 952
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Noise-Sensitive Land Uses
Noise-sensitive land uses generally consist of those uses where exposure to noise would result in adverse effects, as well as uses for which quiet is an essential element of their intended purpose.

Residential dwellings are of primary concern, because of the potential for increased and prolonged exposure of individuals to both interior and exterior noise levels. Other typical noise-sensitive land uses include hospitals, convalescent facilities, hotels, schools, religious institutions, libraries, and other uses where low noise levels are essential.

3.11.3 - Regulatory Framework
Federal
Currently, no federal noise standards regulate environmental noise associated with temporary construction activities or the long-term operations of development projects. As such, both temporary and long-term noise impacts result from the proposed project would be largely regulated or otherwise evaluated by State and local agency standards designed to protect public well-being and health.

Federal Transit Administration Standards and Guidelines Though not regulatory in nature, vibration impact criteria for buildings and other structures have been established by the FTA, as building and structural damages are generally the foremost concern when evaluating the impacts of construction-related vibrations. For the evaluation of the proposed project’s construction-related vibration impacts, the following FTA vibration impact criteria, shown in Table 3.11-4, are used given the absence of applicable federal, State, and City standards specific to temporary construction activities and their potential to result in building and structural damages.3

Table 3.11-4: Federal Transit Administration Construction Vibration Impact Criteria Building Category PPV (in/sec) Approximate VdB
I. Reinforced-Concrete, Steel or Timber (no plaster) 0.5 102 II. Engineered Concrete and Masonry (no plaster) 0.3 98 III. Non-engineered Timber and Masonry Buildings 0.2 94 IV. Buildings Extremely Susceptible to Vibration Damage 0.12 90 Notes:

PPV = peak particle velocity
VdB = velocity in decibels
Source:

Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual. September. 3 Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual. 953
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California General Plan Guidelines
The State of California’s General Plan Guidelines propose county and city standards for acceptable exterior noise levels based on land use. These standards are incorporated into land use planning processes to prevent or reduce noise and land use incompatibilities. The State’s suggested compatibility considerations between various land uses and exterior noise levels are not regulatory in nature but are recommendations intended to aid communities in determining their own noiseacceptability standards.

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

City of American Canyon
General Plan
The General Plan sets forth the following goal of ensuring that American Canyon’s existing and future residents, employees and employers, as well as visitors to the City, are protected from the adverse human health and environmental impacts of excessive noise levels created by stationary and ambient (intrusive) noise sources and conditions. The City takes all necessary and appropriate action to avoid or mitigate the detrimental effects of such excessive noise on the community. Exhibit 3.11-1 illustrates the acceptable noise-compatible land use relationships by implementing the noise standards identified in Figure 11-2 of the General Plan. The objectives and policies relevant to noise that are applicable to the proposed project are:

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

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

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

Objective 11.2 Protect residents, employees, and visitors to the community from excessive noise exposure. If possible, mitigate the adverse impacts of existing or unavoidable excessive noise on these same groups.
954
56390001 • 03/2024 | 3.11-1_noise_land_use_compatibility.cdr CITY OF AMERICAN CANYON SDG COMMERCE 220 PROJECT

ENVIRONMENTAL IMPACT REPORT
Exhibit 3.11-1
Noise Land Use Compatibility
Source: Napa County, 2004. The City of American Canyon General Plan.

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

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

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

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

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

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

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

Objective 11.7 Minimize the impacts of construction noise on adjacent uses. 957
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The Municipal Code establishes an exterior noise level criterion of 50 dBA for single- or multi-family residential land uses; 55 dBA for multi-family residential land uses from 10:00 p.m. to 7:00 a.m.; and 60 dBA for all residential land uses from 7:00 a.m. to 10:00 p.m. within outdoor activity areas of each residential land uses. Additionally, the City requires that cumulative noise exposure from exterior noise sources within noise-sensitive dwellings not exceed 55 dBA from 10:00 p.m. to 7:00 a.m. and 60 dBA from 7:00 a.m. to 10:00 p.m. The City establishes different exterior noise limits for construction noise impacts for residential land uses to be 75 dBA from 7:00 a.m. to 7:00 p.m. and 60 dBA from 7:00 p.m. to 7:00 a.m.

3.11.4 - Thresholds of Significance
The lead agency utilizes the criteria in the California Environmental Quality Act (CEQA) Guidelines Appendix G Environmental Checklist to determine whether noise impacts resulting from the implementation of the proposed project would be considered significant if the project would cause:
a) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
b) Generation of excessive groundborne vibration or groundborne noise levels? c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?

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

Substantial Noise Increase in Excess of Standards
Impact NOI-1: The proposed project would not generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.

Impact Analysis
Construction
For purposes of this analysis, a significant impact would occur if construction noise impacts were greater than 75 dBA between the hours of 7:00 a.m. and 7:00 p.m. or greater than 60 dBA from 7:00 p.m. to 7:00 a.m., per the City’s policies, and would result in a substantial temporary increase in ambient noise levels that could result in annoyance or sleep disturbance of nearby sensitive receptors.
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Noise impacts from construction activities associated with the proposed project would be a function of the noise generated by construction equipment, equipment location, sensitivity of nearby land uses, and the timing and duration of the construction activities. One type of short-term noise impact that could occur during project construction would result from the increase in traffic flow on local streets associated with the transport of workers, equipment, and materials to and from the project site. The transport of workers and construction equipment and materials to the project site would incrementally increase noise levels on access roads leading to the site. Because workers and construction equipment would use existing routes, noise from passing trucks would be similar to existing vehicle-generated noise on these local roadways. Typically, a doubling of the Average Daily Traffic (ADT) hourly volumes on a roadway segment is required in order to result in an increase of 3 dBA in traffic noise levels, which, as discussed in the characteristics of noise discussion above, is the lowest change that can be perceptible to the human ear in outdoor environments. Project-related construction trips would not be expected to double the hourly or daily traffic volumes along any roadway segment in the project vicinity. For this reason, short-term intermittent noise from construction trips would not be expected to result in a perceptible increase in hourly or daily average traffic noise levels in the project vicinity. Therefore, short-term construction-related noise impacts associated with the transportation of workers and equipment to the project site would be less than significant.

Construction Equipment Operational Noise
The second type of short-term noise impact is related to noise generated during construction on the project site. Construction is completed in discrete steps, each of which has its own mix of equipment and, consequently, its own noise characteristics. These various sequential phases would change the character of the noise generated on the site and, therefore, the noise levels surrounding the site as construction progresses. Despite the variety in the type and size of construction equipment, similarities in the dominant noise sources and patterns of operation allow construction-related noise ranges to be categorized by work phase. Table 3.11-2 lists typical construction equipment noise levels, based on a distance of 50 feet between the equipment and a noise receptor. Typical operating cycles for these types of construction equipment may involve 1 or 2 minutes of full power operation followed by 3 or 4 minutes at lower power settings. Impact equipment such as pile drivers are not expected to be used during construction of the proposed project.

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

Earthmoving equipment includes excavating machinery and compacting equipment, such as bulldozers, draglines, backhoes, front loaders, roller compactors, scrapers, and graders.

Construction of the project is expected to require the use of scrapers, bulldozers, water trucks, haul trucks, and pickup trucks. Based on the information provided in Table 3.11-2, the maximum noise level generated by each scraper is assumed to be 85 dBA Lmax at 50 feet from this equipment. Each bulldozer would also generate 85 dBA Lmax at 50 feet. The maximum noise level generated by graders is approximately 85 dBA Lmax at 50 feet. A characteristic of sound is that each doubling of sound sources with equal strength increases a sound level by 3 dBA. Assuming that each piece of 959
City of American Canyon—SDG Commerce 220 Distribution Center Project Noise Draft EIR

3.11-16 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/EIR/2 - Screencheck EIR/edit/56390001 Sec03-11 Noise.docx construction equipment operates at some distance from the other equipment, a reasonable worstcase combined noise level during this phase of construction would be 90 dBA Lmax at a distance of 50 feet from the acoustic center of a construction area. This would result in a reasonable worst-case hourly average of 86 dBA Leq. The acoustic center reference is used because construction equipment must operate at some distance from one another on a project site and the combined noise level as measured at a point equidistant from the sources (acoustic center) would be the worst-case maximum noise level. The effect on sensitive receptors is evaluated below.

The closest residential receptor to the project site’s construction footprint is the single-family residential unit located approximately 900 feet east of the project site. At this distance, and with the screening provided by the intervening brush and trees, construction noise levels would result in a relative worst-case hourly average of 45 dBA Leq at this receptor. These noise levels could occur temporarily under the reasonable worst-case scenario of multiple pieces of heavy construction equipment operating simultaneously in relatively the same locations at the nearest project boundary for an hour period. If these noise levels were to occur every hour from 7:00 a.m. to 7:00 p.m., they would result in a reasonable worst-case average noise level of 42 dBA Ldn as measured at this nearest receptor. The calculation spreadsheet with the detailed modeling assumptions is included in Appendix H.

The next closest sensitive receptor is the Napa Junction Magnet Elementary School located south of the project site, just north of Eucalyptus Drive. This receptor would be approximately 1,200 feet from the acoustic center of construction activity where multiple pieces of heavy construction equipment would operate simultaneously during construction of the proposed parking areas near the project’s southeastern boundary. At this distance, construction noise levels would result in a relative worst-case hourly average of 43 dBA Leq at this receptor. These noise levels could occur temporarily under the reasonable worst-case scenario of multiple pieces of heavy construction equipment operating simultaneously in relatively the same locations at the nearest project boundary for an hour-long period. If these noise levels were to occur every hour from 7:00 a.m. to 7:00 p.m., they would result in a reasonable worst-case average noise level of 40 dBA Ldn as measured at this nearest receptor. The calculation spreadsheet with the detailed modeling assumptions is included in Appendix H.

The proposed project would limit construction activity to the hours of 7:00 a.m. to 7:00 p.m. The calculated reasonable worst-case construction noise levels identified in the analyses above are within the construction noise limits established by the City of no greater than 75 dBA during the hours of 7:00 a.m. to 7:00 p.m. and no greater than 60 dBA during nighttime hours. Therefore, project construction activities would not generate a substantial temporary increase in ambient noise levels in the vicinity of the project in excess of City standards, and temporary construction noise impacts would be less than significant.

Operation
Implementation of the proposed project would result in mobile and stationary operational noise sources. Potential noise impacts with these project-related sources are analyzed below. 960
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A significant impact would occur if implementation of the proposed project would result in a substantial increase in traffic noise levels compared with traffic noise levels existing without the proposed project. The County does not define what is a substantial increase in traffic noise levels. As noted in the characteristics of noise discussion, audible increases in noise levels generally refer to a change of 3 dBA or more as this level has been found to be barely perceptible to the human ear in outdoor environments. A change of 5 dBA is considered the minimum readily perceptible change to the human ear in outdoor environments. Furthermore, a doubling of the ADT hourly volumes on a roadway segment is required in order to result in an increase of 3 dBA in traffic noise levels.

Therefore, for the purposes of this analysis, a doubling of the existing ADT volumes would result in a substantial permanent increase in traffic noise levels.

Based on the traffic analysis prepared by W-Trans for the proposed project, 4 the proposed project
would generate an estimated total of 372 average daily trips, with 35 trips occurring during the AM peak-hour and 27 trips occurring during the PM peak-hour. These traffic volumes would not result in a doubling of traffic on Commerce Boulevard, adjacent to the project site. For instance, the facility immediately south of the project site was analyzed and determined to generate 559 average weekday trips.
5 Therefore, project-related traffic would result in a less than 3 dBA increase in traffic noise levels on local access roadways in the project vicinity.

Therefore, the increase in hourly average or daily traffic noise levels resulting from project operations would not be perceptible along any roadway segment in the project vicinity.

Implementation of the project would not result in a substantial increase in traffic noise levels compared with traffic noise levels existing without the project and would represent a less than significant impact.

Stationary Source Operational Noise Impacts
A significant impact would occur if operational noise levels generated by stationary noise sources at the proposed project site would result in a substantial permanent increase in ambient noise levels in excess of the City’s noise performance standards. The City requires that new industrial, commercial, and related land uses demonstrate that they would not directly cause ambient noise levels to exceed an exterior Ldn of 65 dBA in areas containing housing, schools, health care facilities, or other “noisesensitive” land uses. Furthermore, the City has established an exterior noise level criterion of 50 dBA for single- or double-family residential land uses; 55 dBA for multi-family residential land uses from 10:00 p.m. to 7:00 a.m.; and 60 dBA for all residential land uses from 7:00 a.m. to 10:00 p.m. within outdoor activity areas of each residential land uses.

The proposed project would generate noise from parking lot activities, new exterior mechanical equipment sources, such as rooftop ventilation systems on proposed industrial uses, and truck loading and unloading activities. Potential impacts from these noise sources are discussed below. 4 W-Trans. 2023. 1055 Commerce Court Memorandum of Assumptions. April 26. 5 City of American Canyon. 2019. Final Initial Study for the SDG Commerce 330 Warehouse Project. January. 961
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Typical parking lot activities include people conversing, doors shutting, and vehicles idling, which generate noise levels ranging from approximately 60 dBA to 70 dBA Lmax at 50 feet. These activities are expected to occur sporadically throughout the day as visitors and staff arrive and leave the parking lot areas at the project site.

The closest residential receptor to the project site construction footprint is the single-family residential unit located approximately 900 feet east of the project site. With the distance attenuation and assuming minimal shielding from intervening brush and trees, noise levels associated with daily parking lot activities would attenuate to approximately 42 dBA Lmax at this façade. Assuming a reasonable worst-case scenario of one parking movement for every parking stall within a single hour would result in an hourly average noise level of 31 dBA Leq as measured at this nearest façade. If these noise levels were to occur every hour for a 24-hour period, they would result in a reasonable worst-case average noise level of 38 dBA Ldn as measured at this nearest receptor. The calculation spreadsheet with the detailed modeling assumptions is included in Appendix H.

The next closest noise-sensitive receptor is the Napa Junction Magnet Elementary School located south of the project site, just north of Eucalyptus Drive. The nearest façade of this receptor is located over 1200 feet south of the nearest proposed parking areas. With the distance attenuation and assuming minimal shielding from intervening structures and terrain, noise levels associated with daily parking lot activities would attenuate to approximately 39 dBA Lmax at this façade. Assuming a reasonable worst-case scenario of one parking movement for every parking stall within a single hour would result in an hourly average noise level of 27 dBA Leq as measured at this nearest façade. If these noise levels were to occur every hour for a 24-hour period, they would result in a reasonable worst-case average noise level of 34 dBA Ldn as measured at this nearest receptor. The calculation spreadsheet with the detailed modeling assumptions is included in Appendix H.

Therefore, the proposed project’s reasonable worst-case parking lot noise levels would not cause ambient noise levels to exceed an exterior Ldn of 65 dBA for receiving school land uses, nor would they exceed the City’s exterior noise level criterion of 50 dBA for receiving single-family residential land uses. Therefore, project parking lot activities would not result in a substantial permanent increase in ambient noise levels in the project vicinity, and the impact of noise produced by projectrelated parking lot activities to off-site sensitive receptors would be less than significant.

Mechanical Equipment Operations
The proposed project would include mechanical cooling system equipment that would be located in an enclosed mechanical area on the north side of the proposed building. In addition, the project would include a night air cooling system that consists of wall mounted intake fans covered by louvers. The loudest of these systems would be the mechanical cooling system compressor fans.

Typical mechanical equipment cooling system compressor fans have documented noise levels ranging from 50 dBA to 60 dBA Leq at a distance of 25 feet.

The closest residential receptor to the project site construction footprint is the single-family residential unit located approximately 900 feet east of the project site. At this distance, noise generated by the proposed mechanical cooling system compressor fans would attenuate to below 16 962
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The next closest noise-sensitive receptor is the Napa Junction Magnet Elementary School located south of the project site, just north of Eucalyptus Drive. The nearest façade of this receptor is located approximately 1,265 feet south of the nearest potential location for proposed mechanical cooling system compressor fans. At this distance, noise generated by the compressor fan equipment would attenuate to below 12 dBA Leq at the nearest façade. If these noise levels were to occur every hour for a 24-hour period, they would result in a reasonable worst-case average noise level of 18 dBA Ldn as measured at this nearest receptor. The calculation spreadsheet with the detailed modeling assumptions is included in Appendix H.

Therefore, the proposed project’s reasonable worst-case mechanical equipment operations noise levels would not cause ambient noise levels to exceed an exterior Ldn of 65 dBA for receiving school land uses, nor would they exceed the City’s exterior noise level criterion of 50 dBA for receiving single-family residential land uses. Therefore, project mechanical equipment operations would not result in a substantial permanent increase in ambient noise levels in the project vicinity, and the impact of noise produced by project-related mechanical equipment operations to off-site sensitive receptors would be less than significant.

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

The closest residential receptor to the project site construction footprint is a single-family residential land use east of the project site. The nearest façade of this receptor is located 1,030 feet from the nearest loading docks. Assuming a reasonable worst-case scenario of one truck loading operation for every loading dock within a single hour would result in an hourly average noise level of 28 dBA Leq as measured at this nearest receptor. If these noise levels were to occur every hour for a 24-hour period, they would result in a reasonable worst-case average noise level of 35 dBA Ldn as measured at this nearest receptor. The calculation spreadsheet with the detailed modeling assumptions is included in Appendix H.

The next closest noise-sensitive receptor is the Napa Junction Magnet Elementary School located south of the project site, just north of Eucalyptus Drive. The nearest façade of this receptor is located 1,280 feet from the nearest loading docks. Assuming a reasonable worst-case scenario of one truck loading operation for every loading dock within a single hour would result in an hourly average noise level of 27 dBA Leq as measured at this nearest receptor. If these noise levels were to occur every hour for a 24-hour period, they would result in a reasonable worst-case average noise level of 33 963
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Therefore, the proposed project’s truck loading/unloading activity noise levels would not cause ambient noise levels to exceed an exterior Ldn of 65 dBA for receiving school land uses, nor would they exceed the City’s exterior noise level criterion of 50 dBA for receiving single-family residential land uses. Therefore, project truck loading/unloading operations would not result in a substantial permanent increase in ambient noise levels in the project vicinity, and the impact of noise produced by project-related truck loading/unloading operations to off-site sensitive receptors would be less than significant.

Stationary Source Operational Noise Impact Conclusion
As shown in the analysis above, none of the proposed project’s stationary operational noise sources would result in an increase of 3 dBA or greater above the City’s performance threshold of 65 dBA Ldn for stationary noise sources as measured at the nearest sensitive receptor, nor would they exceed the City’s exterior noise level criterion of 50 dBA for receiving single-family residential land uses.

Therefore, noise impacts from stationary operational noise sources would be less than significant.

Level of Significance Before Mitigation
Less than significant impact.

Mitigation Measures
No mitigation is necessary.

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

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

Groundborne vibrations consist of rapidly fluctuating motions within the ground that have an average motion of zero. Vibrating objects in contact with the ground radiate vibration waves through various soil and rock strata to the foundations of nearby buildings. Groundborne noise is generated when vibrating building components radiate sound, or noise generated by groundborne vibration. In general, if groundborne vibration levels do not exceed levels considered perceptible, then groundborne noise levels would not be perceptible in most interior environments. Therefore, this analysis focuses on determining exceedances of groundborne vibration levels.

The City of American Canyon has not established quantitative groundborne vibration thresholds for construction or operation. Therefore, for the purposes of this analysis, the FTA’s vibration impact criteria are utilized to analyze vibration impacts. The FTA has established industry-accepted standards for vibration impact criteria and impact assessment. These guidelines are published in its 964
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Construction
A significant impact would occur if existing structures at the project site or in the project vicinity would be exposed to groundborne vibration levels in excess of levels established by the FTA’s Construction Vibration Impact Criteria for the listed type of structure, as shown in Table 3.11-4.

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

The nearest off-site receptor to the project construction footprint where the heaviest construction equipment would operate is the commercial building located south of the project site. The façade of this structure would be located approximately 130 feet from the nearest point on the project site where the heaviest construction equipment would potentially operate. At this distance, groundborne vibration levels would range up to 0.017 PPV from operation of the types of equipment that would produce the highest vibration levels, which is well below the FTA’s Construction Vibration Impact Criteria of 0.5 PPV for this type of structure, which is a building of reinforced-concrete, steel or timber (no plaster) construction. Therefore, the impact of short-term groundborne vibration associated with construction to off-site receptors would be less than significant.

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

For informational purposes, the Southern Pacific Railroad rail line is located over 3,000 feet northeast of the project site. At this distance potential groundborne vibration impacts would be less than significant for the proposed type of structure, based on FTA vibration screening criteria. There are no other existing significant permanent sources of groundborne vibration in the project vicinity to which the proposed project would be exposed.

Therefore, project operational groundborne vibration level impacts would be considered less than significant.

Level of Significance Before Mitigation
Less than significant impact.

Mitigation Measures
No mitigation is necessary.
6 Federal Transit Administration. 2018. Transit Noise and Vibration Impact Assessment Manual. September. 965
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Impact NOI-3: The proposed project would not expose people residing or working in the project area to excessive noise levels for a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport.

Impact Analysis
A significant impact would occur if the proposed project would expose people residing or working in the project area to excessive noise levels for a project located in the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within 2 miles of a public airport or public use airport. The City’s General Plan Policy 11.4.1 restricts the development of uses located within the 65 CNEL contour of Napa Airport to industrial, agricultural, or other open space uses; and General Plan Policy 11.4.2 requires that development in the vicinity of Napa Airport comply with the noise standards contained in the ALUCP.

The project site is not located within the vicinity of a private airstrip. However, the project site is located within 2 miles of a public airport; the Napa County Airport is located approximately 1.6 miles north of the project site. As such, the project site is located outside of the 55 dBA CNEL airport noise contours. Therefore, while aircraft noise is occasionally audible on the project site from aircraft flyovers, aircraft noise associated with nearby airport activity would not expose people residing or working near the project site to excessive noise levels. These noise levels are considered normally acceptable for new industrial land use development within the City as shown in Exhibit 3.11-1. On this basis, implementation of the project would not expose persons residing or working in the project vicinity to noise levels from airport activity that would be in excess of normally acceptable standards for the proposed land use development, and impacts would be less than significant.

Level of Significance Before Mitigation
Less than significant impact.

Mitigation Measures
No mitigation is necessary.

3.11.6 - Cumulative Impacts
The geographic scope for the cumulative analysis for noise and vibration impacts is limited to areas within 1,000 feet of the project site boundary for on-site noise sources because of the localized nature of noise and vibration impacts. This analysis first evaluates whether the impacts of cumulative development could result in a cumulatively significant noise or vibration impact. If there is a cumulative significant impact, this analysis then considers whether the incremental contribution of the impacts associated with the implementation of the proposed project would be cumulatively considerable. Both conditions must apply for the project’s cumulative effects to rise to the level of significance.
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As noted above, the geographic scope of the cumulative noise analysis is the project vicinity, including surrounding sensitive receptors. Noise impacts tend to be localized; therefore, the area surrounding the project site (approximately 1,000 feet) would be the area most affected by proposed project activities. Cumulative development would be required to comply with all applicable construction hour requirements and would also be anticipated to incorporate appropriate Best Management Practices (BMPs) to help reduce construction noise. Additionally, cumulative development would comply with design review regulations directing the siting, design, and insulation of new development and redevelopment and all applicable noise policies, standards, and requirements in the General Plan and Municipal Code, which would ensure that noise impacts are less than significant.

There is only one project on the cumulative projects list that is within 1,000 feet of the project site, the project immediately north of this project site. That project is currently under construction and will be completed before this project begins construction. Therefore, there would not be an existing cumulative construction noise impact condition.

Because there is not a cumulative significant construction noise impact to existing or planned land uses in the project vicinity, the incremental contribution of project construction noise would not be cumulatively considerable. Therefore, the proposed project would result in a less than significant cumulative impact related to construction noise.

Operational Traffic Noise
If there is an identified cumulative traffic noise impact in the project vicinity, and if the proposed project would result in an incremental contribution to an identified cumulative traffic noise impact, then the project’s impact would be cumulatively considerable.

Traffic noise levels along Commerce Boulevard adjacent to the project site do not exceed acceptable noise levels for the adjoining land uses. Therefore, there is not an existing cumulative traffic noise impact condition to which the proposed project could contribute. Because there is not a cumulative significant traffic noise impact along roadway segments to which project trips could contribute, the incremental contribution of project traffic noise would not be cumulatively considerable. Therefore, the proposed project would result in a less than significant cumulative impact related to traffic noise.

Operational Stationary Noise
For stationary operational noise sources, a significant impact would occur if the cumulative projects would cause the Ldn at noise-sensitive uses to increase by 3 dB or greater above the City’s performance threshold of 65 dBA Ldn or exceed the City’s exterior noise level criterion of 50 dBA for receiving single-family residential land uses.

As shown in the stationary source noise impact discussion above, project noise levels from projectrelated mechanical equipment operations would not exceed existing ambient noise levels as measured at the nearest off-site sensitive land uses and, therefore, would not result in any increase in ambient noise levels in the project vicinity and would not contribute to any cumulative stationary 967
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Construction Vibration
The geographic scope of the cumulative construction vibration analysis is the project vicinity, including surrounding sensitive receptors. Construction vibration impacts are very localized; therefore, the area surrounding the project site (approximately 100 feet) would be the area most affected by proposed project construction activities.

There is no cumulative project within 100 feet of the project site, and, therefore, there is no potential for the proposed project to contribute to a cumulative construction-related groundborne vibration impact in the project vicinity. Therefore, there is a less than significant cumulative impact related to construction vibration impacts in the project vicinity.

Operational Vibration
Because operational vibration impacts are very localized, the only potential sources of cumulatively considerable contribution to vibration conditions in the project vicinity would result from introduction of past, present, and reasonably foreseeable future permanent sources of groundborne vibration in the project site vicinity.

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

Therefore, implementation of the proposed project would not result in a cumulatively considerable contribution to vibration conditions in the project vicinity. This impact would be less than significant.

Level of Cumulative Significance Before Mitigation
Less than significant impact.

Mitigation Measures
No mitigation is necessary.
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3.12 - Public Services

3.12.1 - Introductions
This section describes the existing conditions related to public services in the project area, as well as the relevant regulatory framework. This section also evaluates the possible impacts related to public services that could result from implementation of the proposed project. Descriptions and analysis in this section are based on information provided by the City of American Canyon General Plan (General Plan), American Canyon Fire Protection District (ACFPD), and American Canyon Police Department (Police Department).

No public comments pertaining to public services were received in response to the Notice of Preparation (NOP).

3.12.2 - Environmental Setting
Fire Protection and Emergency Medical Services
The ACFPD provides fire protection and Emergency Medical Services (EMS) to the City of American Canyon (City) as well as nearby unincorporated areas of Southern Napa County. The ACFPD’s response area encompasses approximately 7 square miles. The ACFPD is headquartered at 911 Donaldson Way East (Station 11). The ACFPD’s Board of Directors, comprised of five elected members, oversees the District and the Fire Chief.
1 Stations
The ACFPD operates two fire stations: Station 11 (911 Donaldson Way) and Station 211 (225 James Road).2 Station 211 was reopened in June 2020 after being closed for several years. Station 11 is approximately 1.57 miles from the project site. Station 211 is approximately 1.26 miles from the project site.

Organization
The ACFPD is organized into two groups: Administration and Support, and Operations. Operations is the largest division and is responsible for responding to calls for service. Administration is the principal responsibility of the Fire Chief, and this division oversees field operations, policy reviews, and budgeting.

Services Provided
The ACFPD provides emergency operations, fire suppression, wildland firefighting, first-response non-transport EMS, Type 1 urban search and rescue and swiftwater rescue. The ACFPD is also a member of the Napa County HazMat Team, provides public education and prevention programs, and maintains a Community Emergency Response Team.
3 1
American Canyon Fire Protection District (ACFPD). 2022. Long-Range Master Plan. Website:
https://www.cityofamericancanyon.org/home/showpublisheddocument/19513/638084122376770000. Accessed January 3, 2024. 2 Ibid. 3
American Canyon Fire Protection District (ACFPD). 2022. Long-Range Master Plan. Website:
https://www.cityofamericancanyon.org/home/showpublisheddocument/19513/638084122376770000. Accessed January 3, 2024. 969
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The ACFPD has four six-line apparatus, all but one are in excellent condition. Currently, the ACFPD ladder truck is cross-staffed and located at Station 11. If not initially staffed in response to an incident, a mutual aid ladder truck from Vallejo Station 21 (about 4 miles from the City center) or Napa Station 1 (about 8 miles from the City center) would need to be dispatched. The ACFPD also has air/light/rescue apparatus, command/utility vehicles, inflatable rescue boats, an ambulance, and towable technical rescue equipment trailers.4
Staffing
The ACFPD relies on a three-platoon system (A, B, and C shifts) wherein each platoon is scheduled for a 48-hour shift which achieves a minimum staffing level of six personnel. The ACFPD is authorized with 22 emergency personnel to provide fire suppression, rescue, and EMS services. The 22 authorized positions includes six Captains, 10 Firefighters/driver-operators, two probationary Firefighters, and three reserve support staff. The career staffing level for the ACFPD is 0.992 per 1,000 population, which is below the recommended national average of 1.54 per 1,000.5 Incidents
The ACFPD responded to over 1,800 incidents in 2021; 62 percent of the emergency medical responses and motor vehicle responses. According to ACFPD data, 10.6 percent of the incidents were recorded as providing mutual aid, most of which went to either unincorporated Napa County or the City of Vallejo.
6 Response Times
The response time goal for delivering the full Emergency Response Framework (ERF) to a building fire is within 9 minutes, 20 seconds, 90 percent of the time. In 2021, overall response time for all priority incidents was within 5 minutes, 53 seconds, 90 percent of the time.7 Insurance Services Office Rating
As of 2014, ACFPD has an Insurance Services Office (ISO) rating of Class 2/2Y on a scale of 1 to 10, with 1 being the best. An ISO rating accounts for factors such as emergency communication, fire department, water supply, divergence, and community risk reduction. 8 Police Protection
The American Canyon Police Department (Police Department) provides police protection to the City of American Canyon. The Police Department is staffed by the Napa County Sheriff’s Office, which provides law enforcement services on a contract basis to the City of American Canyon. The Police Department is headquartered at 911 Donaldson Way East.
4 American Canyon Fire Protection District (ACFPD). 2022. Long-Range Master Plan. Website:
https://www.cityofamericancanyon.org/home/showpublisheddocument/19513/638084122376770000. Accessed January 3, 2024. 5 Ibid. 6 Ibid. 7 Ibid. 8 Ibid. 970
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The Sheriff’s Office consists of the following divisions: Operations and Services. The Operations Division includes Patrol, Investigations Bureau, Napa Special Investigations Bureau, ProblemOriented Policing Program, Animal Services, Special Assignments (including SWAT and Dive Teams), and Team Auxiliaries. The Services Division consists of the Coroner’s Bureau, Court Services Bureau, Transportation Bureau, Technical Services Bureau, Administration, Property and Evidence Bureau, and Special Assignments (including Honor Guard).
9 Staffing
As of the 2023/2024 Fiscal Year, the Police Department was staffed with 27 sworn officers, two police technicians, and one Records Technician. The 27 sworn officers include the Chief, two School Resource Officers, one Community Resource Officer, two K-9 Handlers, five Sergeants, and 16 Patrol Officers.
10 Calls for Service
In 2023 the Police Department received 15,294 calls for service.11

3.12.3 - Regulatory Framework
State
California Building Standards Code
Title 24 of the California Code of Regulations, also known as the California Building Standards Code (CBC), is a compilation of three types of building standards from three different origins:
• Building standards that have been adopted by state agencies without change from building standards contained in national and international model codes. • Building standards that have been adopted and adapted from national and international model code standards to meet California conditions.
• Building standards, authorized by the California legislature, which constitute extensive additions not covered by the model codes that have been adopted to address particular California concerns.

The California Fire Code is a component of the CBC and contains fire safety-related building standards.

Local
City of American Canyon
General Plan
The General Plan sets forth the following goals relevant to public services:
9 Napa County Sheriff’s Office. 2021. 2021 Annual Report. Website:
https://www.countyofnapa.org/DocumentCenter/View/25161/2021-NCSO-Annual-Report---Final_Web. Accessed January 3, 2024. 10 American Canyon Police Department. 2024. 2023 Annual Report. March. 11 Ibid. 971
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Goal 6B Ensure a high level of police protection for the City’s residents, businesses, and visitors.

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

Municipal Code Chapter 15.08
Chapter 15.08 of the American Canyon Municipal Code establishes development impact fees for parks and civic facilities fees to defray the actual costs of constructing improvements to mitigate impacts resulting from proposed new development identified in the American Canyon General Plan.

As defined in the Municipal Code, ““civic facilities” include, but are not necessarily limited to “ . . . a police station, a corporation yard, a public library, or similar facilities desired to serve the public . . . .” Fees are calculated based on a cost per unit (e.g., dwelling unit, square feet, hotel/motel rooms, etc.) as identified in the Ordinance Chapter.

Ordinance 2013-01 Fire Service Fee
Ordinance 2013-01 provides revenue necessary to maintain current fire service levels via the required payment of fees based on a formula that includes structure construction type, fire flow area (in square feet), proximity of other structures, type of occupancy, and presence of fire protection devices.

American Canyon Fire Protection District
Resolution 83-4
ACFPD Resolution 83-4, as amended by Resolution 2023-16, is the “Fire Mitigation Fee,” a one-time assessment to all new development for capital improvements (i.e., a new fire station).

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

FCS evaluated project impacts on public services through review of the proposed project in relation to the General Plan, ACFPD, and information regarding Police Department services and facilities.

3.12.5 - Thresholds of Significance
The lead agency utilizes the criteria in the California Environmental Quality Act (CEQA) Guidelines Appendix G Environmental Checklist to determine whether impacts to public services and utilities resulting from the implementation of the proposed project would be considered significant if the project would:
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a) Fire protection?
b) Police protection?
c) Schools? (Refer to Chapter 4, Effects Found not to be Significant) d) Parks? (Refer to Chapter 4, Effects Found not to be Significant) e) Other public facilities? (Refer to Chapter 4, Effects Found not to be Significant)

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

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

Impact Analysis
The proposed project would be served with fire protection and EMS provided by the ACFPD. The ACFPD will have the opportunity to review and comment on security measures during the proposed project’s plan check review process.

Vehicular access would be taken from one driveway on Commerce Court. Reciprocal access would be provided with the existing wine warehouse (SDG Commerce 330) to the south and the entitled wine warehouse (SDG Commerce 217) to the north. All access points would be accessible to large emergency vehicles such as fire engines. This would comply with California Fire Code requirements for emergency vehicle accessibility.

The project site is located 4.4 miles from Station 11, via Paoli Loop Road and Green Island Road.

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

3.6 miles. Using an average travel speed of 35 miles per hour (mph), it would take a fire engine 6 minutes and 10 seconds to reach the project site when responding from Station 11. This would be outside the ACFPD’s 5-minute response time objective. Furthermore, congestion on SR-29 may increase travel time such that it is longer.

The ACFPD indicated in July 2022 that it intends to develop a new fire station in the northern portion of the American Canyon city limits, within the project vicinity. A site has not yet been selected, nor has any facility planning occurred at the time of Draft EIR release. The ACFPD would undertake a separate environmental review process for this new fire station. The ultimate development of a new fire station in the industrial area would significantly improve fire response times in the northern portion of American Canyon, including at the project site. 973
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In summary, while the proposed project is in an area that does not meet the ACFPD’s response time objective, the ACFPD has plans to build a new “North” fire station that would significantly reduce response time to the project site. This facility would be subject to a separate environmental review process. Furthermore, the proposed project is required to pay a Fire Mitigation Fee and Fire Service Fee to support facility development and calls for service. As such, the proposed project would not create a need for new or expanded fire protection facilities (beyond the new “North” fire station).

Impacts would be less than significant.

Level of Significance Before Mitigation
Less than significant impact.

Mitigation Measures
No mitigation is necessary.

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

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

The proposed project would be expected to be staffed from 6:00 a.m. to 6:00 p.m., Monday through Friday and 6:00 a.m. to 12:00 a.m., Monday through Friday during peak seasonal months, typically June through November. Security measures including exterior lighting, alarm systems, and video surveillance would be employed to deter and prevent criminal activity. For these reasons, the proposed project would be expected to generate minimal calls for service and, therefore, would not create a need for new or expanded police facilities. The Police Department will have the opportunity to review and comment on security measures during the plan check review process. Lastly, new developments are required by Chapter 15.08 of the Municipal Code to pay a fair share Park and Civic Facilities Development Impact Fee, which includes funding for police facilities as needed. Impacts would be less than significant.

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

3.12.7 - Cumulative Impacts
The geographic scope of the cumulative public services analysis is the service area of each of the providers serving the proposed project. Because of differences in the nature of the public service areas, they are discussed separately.

Fire Protection and Emergency Medical Services
The geographic scope of the cumulative fire protection and EMS analysis is the ACFPD service area, which consists of the American Canyon city limits and small portions of unincorporated Napa County.

The proposed project would result in the development of a 219,834-square-foot wine warehouse on the project site. The project site is located within 3.6 miles of the nearest fire station and is within an area and that does not meet the ACFPD’s response time objective. However, the ACFPD has plans to build a new “North” fire station which would significantly reduce response time to the project site.

This facility would be subject to a separate environmental review process. Furthermore, the proposed project is required to pay a Fire Mitigation Fee and Fire Service Fee to support facility development and calls for service. As such, the proposed project would not create a need for new or expanded fire protection facilities (beyond the new “North” fire station) and would not result in a physical impact on the environment. Additionally, the proposed project would comply with all applicable requirements of the California Fire Code, including provision of adequate emergency access points, and it would be accessible to fire apparatus. Other past, present, and reasonably foreseeable development projects in the ACFPD service area have been and would be reviewed for impacts on fire protection and EMS and have been and would be required to address any potential impact with mitigation and compulsory fee payments. Additionally, the ACFPD plans for service needs consistent with existing demands and growth anticipated in the City planning documents.

Therefore, the proposed project, in conjunction with other past, present, and reasonably foreseeable development, would not have a cumulatively significant impact related to fire protection and EMS.

Police Protection
The geographic scope of the cumulative police protection analysis is the service area of the American Canyon Police Department, which consists of the American Canyon city limits.

The proposed project and other past, present, and reasonably foreseeable projects in the police service area have been and would continue to be reviewed for impacts on police services and also have been and would continue to be required to address any potential impact with mitigation.

Additionally, the Police Department plans for service needs consistent with existing demands and growth anticipated in the City planning documents. Therefore, the proposed project, in conjunction with other past, present, and reasonably foreseeable development, would not have a cumulatively significant impact related to police protection.
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Fire Protection and Emergency Medical Services: Less than significant impact.

Police Protection: Less than significant impact.

Mitigation Measures
No mitigation is necessary.
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3.13 - Transportation

3.13.1 - Introduction
This section describes existing conditions related to transportation in the project area as well as the relevant regulatory framework. This section also includes an evaluation of the possible impacts related to transportation that could result from implementation of the project.

The following comments were received during the Environmental Impact Report (EIR) scoping period related to transportation:
• A commenter noted that the proposed project could result in increased daily truck and passenger car trips, which could contribute to increased traffic jams, traffic accidents, and unsafe conditions for pedestrians and bicyclists.
• A commenter provided example measures to reduce traffic impacts, including the enforcement of truck routes, prevention of truck parking in residential neighborhoods, a requirement for the preparation and approval of a truck routing plan, construction of new or improved alternative transit method infrastructure, securing increase public transit service to the project area, designated areas for employee pickup and drop-off, implementing traffic control and safety measures, strategic placement of entrances and exits, construction of roadway improvements, and the preparation of a construction traffic control plan. A commenter requested that parking demand is evaluated.
• A commenter requested that increases in truck traffic in the area are evaluated. • A commenter requested evidence that a majority of employees at the project site would be local residents.
• A commenter outlines methodology for a Travel Demand Analysis and for ConstructionRelated Impacts Analysis.

3.13.2 - Environmental Setting
Roadway Network
The following roads provide primary access to the project site:
• Commerce Court is a two-lane connector that provides access to the project site from Green Island Road. The southern end of the street is a cul-de-sac, adjacent to the project driveway.

The speed limit on Commerce Court is 25 miles per hour (mph). • Green Island Road is a two-lane connector providing access for southbound traffic on State Route (SR) 29 traveling to and from the project area. In 2016, counts indicated that Green Island Road carried 8,200 vehicles per day.
• Paoli Loop Road provides access to and from the project area for northbound traffic on SR-29.

It is a two-lane connector extending from SR-29 to Green Island Road with a speed limit of 25 mph.
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Pedestrian Facilities
Pedestrian facilities include sidewalks, crosswalks, pedestrian signal phases, curb ramps, curb extensions, and various streetscape amenities such as lighting, benches, etc. Sidewalks are present along Commerce Court on the project frontage as well as the segment of Commerce Court north of the project site, although the sidewalks do not extend to Green Island Road, and Green Island Road also lacks pedestrian facilities between Commerce Court and SR-29. A sidewalk connection is provided at the southern terminus of Commerce Court, extending to the northern terminus of Wetlands Edge Road and connecting to the sidewalk network in the adjacent residential neighborhood. Because of this connection south of the project site, there are continuous pedestrian facilities connecting the project site to Napa Junction Elementary School, nearby residences, and recreational areas in the vicinity, as well as commercial land uses and bus stops over 1 mile from the project site on the SR-29 corridor.

The existing sidewalk gaps along the connecting roadways north of the project impact convenient and continuous access for pedestrians and present safety concerns in those locations where appropriate pedestrian infrastructure would address potential conflicts with vehicle traffic. However, given the industrial character of the area and lack of residential areas, commercial land uses, or bus stops, the pedestrian demand is expected to be low. The pedestrian facilities network south of the project provides access between the site and nearby land uses expected to generate pedestrian trips.

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

Bike lanes are present along the segment of Commerce Court immediately north of the project site.

A Class I path extends from the southern terminus of Commerce Court to the northern terminus of 978
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Table 3.13-1: Bicycle Facility Summary
Status Facility Class
Length
(miles) Beginning Point Ending Point
Existing Commerce-Wetlands Edge
Connector
I 0.12 Commerce Court Wetlands Edge Court
Eucalyptus Drive I 0.17 Wetlands Edge Court Greenwing Street Wetlands Edge Court I 0.14 Eucalyptus Drive End
Wetlands Edge Road I 1.36 Eucalyptus Drive Kensington Way Planned Broadway I 2.80 Northern City limit Southern City limit Green Island Road I 0.33 Vine Trail Commerce Court
Hess Road Path I 0.83 Commerce Court Lombard Road
Vine Trail I 1.62 Middleton Way Watson Lane
Commerce Court II 0.30 Hess Collection
Driveway
Green Island Road
Donaldson Way II 0.80 Eucalyptus Drive Benton Way
Lombard Road II 0.35 Vine Trail Napa Junction Road
Napa Junction Road II 0.33 Theresa Avenue End
Rio del Mar II 1.00 Wetlands Edge Road Broadway
Theresa Avenue II 0.30 Napa Junction Road Eucalyptus Drive Source: W-Trans. 2023.

Transit Facilities
Vine Transit provides fixed route bus service throughout Napa County (County). American Canyon Transit (ACT) operates a local shuttle route within American Canyon (City), but primarily serves as the City’s paratransit service provider, operating an on-demand, door-to-door service for persons with disabilities who cannot independently use regular fixed route transit services. Neither Vine Transit nor ACT maintains stops within an acceptable walking distance of the project site. The nearest bus stop to the project site is located on Rio del Mar near Eucalyptus Drive and serves Vine Transit Route 11, approximately 1.3 miles south of the project site.

On-demand private taxi services are available in the study area 24 hours a day. Taxis can be used for trips in the project vicinity as well as other destinations in Napa County and the Bay Area. Ride979 City of American Canyon—SDG Commerce 220 Distribution Center Project Transportation Draft EIR

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3.13.3 - Regulatory Framework
State
California Department of Transportation (Caltrans)
Caltrans builds, operates, and maintains the State highway system, which includes SR-29 through American Canyon. The department’s strategic goals include providing a safe transportation system, enhancing and connecting the multimodal transportation network, efficiently managing the use of transportation funding, and advancing equity and livability.

In its 2020 Vehicle Miles Traveled-Focused Transportation Impact Study Guide (TISG), Caltrans developed an approach for evaluating the transportation impacts of land use projects and plans on State highway facilities; this document does not address the impacts of transportation projects. In accordance with current California Environmental Quality Act (CEQA) requirements, the TISG does not consider vehicle delay in its evaluation of transportation impacts, instead focusing on Vehicle Miles Traveled (VMT). The purposes of the TISG include providing guidance to lead agencies regarding when they should analyze potential impacts to the State highway system; aiding Caltrans staff in reviewing projects; and ensuring consistency in the assessment of impacts and identification of non-capacity increasing mitigation measures.

Senate Bill 743
On September 27, 2013, Senate Bill (SB) 743 was signed into law, supporting previous climatefocused and transportation legislation, including the Sustainable Communities and Climate Protection Act of 2008 (SB 375), the California Global Warming Solutions Act of 2006 (Assembly Bill [AB] 32), as well as the Complete Streets Act (AB 1358), which requires local governments to plan for a balanced, multimodal transportation network that meets the needs of all users. SB 743 eliminates the use of automobile delay metrics, such as Level of Service (LOS), as the primary metric to evaluate transportation impacts under CEQA. Instead, VMT has been identified as the most appropriate metric to evaluate a project’s transportation impacts, as projects that result in lower-than-average VMT support goals of reducing greenhouse gas (GHG) emissions, while projects that result in higher-thanaverage levels of vehicle travel contribute to an increasing rate of GHG emissions.

In December 2018, the California Governor’s Office of Planning and Research (OPR) issued a final advisory to guide lead agencies in implementing SB 743, Technical Advisory on Evaluating Transportation Impacts in CEQA (Technical Advisory).
1 Key guidance includes the following.
• VMT is the most appropriate metric to evaluate a project’s transportation impact under CEQA. • VMT for residential and office projects should generally be assessed using efficiency metrics, i.e., on a “per rate” basis.
1 California Governor’s Office of Planning and Research (OPR). 2018. Technical Advisory on Evaluating Transportation Impacts in CEQA. December. Website: https://opr.ca.gov/docs/20190122-743_Technical_Advisory.pdf. Accessed October 12, 2023. 980
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• Lead agencies have the discretion to set or apply their own significance thresholds in lieu of those recommended in the advisory, provided they are based on substantial evidence. • Cities and counties still have the ability to use metrics such as LOS for other plans, studies, or network monitoring. However, LOS and similar metrics cannot constitute the sole basis for determining CEQA impacts.

As noted in the OPR Technical Advisory, lead agencies have the authority to choose metrics that are appropriate for their jurisdiction to evaluate the potential VMT impacts of land development projects.

Regional
Metropolitan Transportation Commission
The Metropolitan Transportation Commission (MTC) serves as the Metropolitan Planning Organization (MPO) for the nine-county San Francisco Bay Area and is responsible for transportation planning, coordination, and establishment of funding priorities. Plan Bay Area 2050 is the Bay Area’s long-range plan that addresses regional transportation, housing, economic development, and environmental resilience. The plan identifies funding priorities for a $1.4 trillion vision over a 30-year period, directed toward addressing the Plan’s 35 strategies. Plan Bay Area 2050 was adopted by MTC and the Association of Bay Area Governments in 2021.

Plan Bay Area 2050 includes the following transportation strategies.

T1 Restore, operate and maintain the existing system. Commit to operate and maintain the Bay Area’s roads and transit infrastructure while reversing pandemic-related cuts to total transit service hours.

T2 Support community-led transportation enhancements in Equity Priority Communities. Provide direct funding to historically marginalized communities for locally identified transportation needs.

T3 Enable a seamless mobility experience. Eliminate barriers to multi-operator transit trips by transfer hubs.

T4 Reform regional transit fare policy. Streamline fare payment and replace existing operator-specific discounted fare programs with an integrated fare structure across all transit operators.

T5 Implement per-mile tolling on congested freeways with transit alternatives. Apply a per-mile charge on auto travel on select congested freeway corridors where transit 981
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T6 Improve interchanges and address highway bottlenecks. Rebuild interchanges and widen key highway bottlenecks to achieve short- to medium-term congestion relief.

T7 Advance other regional programs and local priorities. Fund regional programs like motorist aid and 511 while supporting local transportation investments on arterials and local streets.

T8 Build a Complete Streets network. Enhance streets to promote walking, biking and other micro-mobility through sidewalk improvements, car-free slow streets, and 10,000 miles of bike lanes or multiuse paths.

T9 Advance regional Vision Zero policy through street design and reduced speeds.

Reduce speed limits to between 20 and 35 miles per hour on local streets and 55 miles per hour on freeways, relying on design elements on local streets and automated speed enforcement on freeways.

T10 Enhance local transit frequency, capacity and reliability. Improve the quality and availability of local bus and light rail service, with new bus rapid transit lines, South Bay light rail extensions, and frequency increases focused in lower-income communities.

T11 Expand and modernize the regional rail network. Better connect communities while increasing frequencies by advancing the Link21 new transbay rail crossing, BART to Silicon Valley Phase 2, Valley Link, Caltrain Downtown Rail Extension and Caltrain/High-Speed Rail grade separations, among other projects.

T12 Build an integrated regional express lanes and express bus network. Complete the buildout of the regional express lanes network to provide uncongested freeway lanes for new and improved express bus services, carpools and toll-paying solo drivers.

County
Napa Valley Transportation Authority
Napa Valley Transportation Authority (NVTA) (formerly known as the Napa County Transportation Planning Authority) oversees countywide transportation planning and programming activities in Napa County, including the establishment of the countywide priorities, development of the countywide transportation plan, and provision of project oversight. Vision 2045: Advancing Mobility, adopted in 2021, is the current version of the plan and establishes countywide goals, objectives, and policies for improving mobility on Napa County’s streets, highways, transit systems, and bicycle/pedestrian facilities, as well as strategies to reduce transportation-related impacts. Projects identified in the countywide plan in the project vicinity include a new industrial collector from the 982
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Local
City of American Canyon
General Plan
The City of American Canyon General Plan (General Plan) sets forth the following guiding and implementing policies relevant to transportation.

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

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

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

Guiding Policy 1.6 Achieve and maintain a Multimodal LOS D or better for roadways and intersections during peak-hours where possible and as long as possible.

However, recognizing that LOS D may not be achievable or cannot be maintained upon full buildout of the General Plan, due to traffic generated from sources beyond the control of the City, the City Council shall have the discretion to only require feasible mitigation measures that may not achieve LOS D, but will reduce 983
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The following locations that may not achieve or maintain LOS D are as follows and therefore will be exempt from the LOS D policy:
• State Route 29 through the City
• American Canyon Road from SR-29 to Flosden Road–Newell Drive • Flosden Road south of American Canyon Road
Guiding Policy 1.9 Use of existing facilities. Make efficient use of existing transportation facilities, and improve these facilities as necessary in accordance with the Circulation Map.

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

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

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

Implementing Policy 1.17
Regional fair-share fee program. Work with Caltrans, NCTPA, Napa County, and other jurisdictions to establish a fair-share fee program for improvements to routes of regional significance and State highways. This fee should reflect traffic generated by individual municipalities/unincorporated communities as well as pass-through traffic.

Implementing Policy 1.24
Impacts of new development. Based upon the findings of a transportation impact analysis, consistent with Guiding Policy 1.26, new development will be responsible for mitigation of transportation-related impacts. 984
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General transit and pedestrian access. In reviewing designs of proposed developments, ensure that provision is made for access to current and future public transit services. In particular, pedestrian access to arterial and collector streets from subdivisions should not be impeded by continuous segments of sound walls.

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

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

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

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

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

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

Guiding Policy 4.6 Location of industrial development. Continue industrial expansion in the north industrial area to minimize the neighborhood impacts of truck movements.

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

Performance Standards
The General Plan Circulation Element specifies minimum LOS standards for all streets and intersections in the City’s jurisdiction. In Section 4.1.6, the City establishes the following performance standards for acceptable LOS for purposes of compliance with its General Plan:
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The locations that may not achieve or maintain LOS D are as follows and will be exempt from the LOS D policy:
• SR-29 through the City
• American Canyon Road from SR-29 to Flosden Road–Newell Drive • Flosden Road south of American Canyon Road
American Canyon Vehicle Miles Traveled (VMT Policy)
On September 5, 2023, the American Canyon City Council adopted a VMT policy for use in analyzing potential transportation impacts under CEQA. This policy included the following elements:
• The baseline for VMT analysis shall be the citywide average as estimated by the City’s travel demand model. As estimated using the most recent version of the model, the averages are

16.6 miles per resident and 34.1 miles per employee.
• The VMT threshold of significance shall be 19 percent below the citywide average for the appropriate metric. This threshold applies to land development projects of all land use types, transportation projects, as well as General Plan amendments and other long-range plans. This threshold was selected based on the California Air Resource Board (ARB) 2035 target for reduction of GHG emissions of passenger vehicles in comparison with 2005 emissions. • Projects that are consistent with a Program EIR for which a VMT analysis has been conducted are presumed to have a less than significant VMT impact.

American Canyon Bicycle Plan
The City of American Canyon Bicycle Plan was prepared in conjunction with the Napa Countywide Bicycle Plan and was adopted into the General Plan in 2020. The following policies were adopted for the countywide plan and incorporated into the City’s plan. • Build and maintain a local and countywide bicycle transportation and recreation network that connects Napa County’s incorporated cities/town and unincorporated communities and provides access to public transportation and community destinations. • Develop and maintain continuous low Level of Traffic Stress (LTS) bicycle facilities of all types to provide accessible intra-city connections that serve as the framework of the Countywide Bikeway System.
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• Provide secure bicycle parking at public and private destinations throughout Napa County. • Integrate the bicycle network and bicycle facility amenities into land use decisions and developments.
• Implement projects that improve access for disadvantaged and/or underserved communities, particularly those reliant on walking, biking and transit for transportation. • Work to reduce the number and severity of bicycle collisions. • Work to reduce bicycle fatalities to zero by 2035.
• Improve locations that have high incidences of bicycle collisions, and/or impediments or conflicts to bicyclists.
• Implement Complete Streets policies that ensure accommodation and enable safe access for users of all ages and abilities.

Implement appropriate, well-designed bicycle facilities using accepted design standards, including intersection and other crossing improvements.

3.13.4 - Methodology
This analysis assesses impacts to the study area’s transportation system as a result of implementation of the project. The potential impacts were identified based on the Checklist questions included in Appendix G of the CEQA Guidelines.

Trip Generation
Typically, the trip generation of a project is estimated based on rates published in the Institute of Transportation Engineers’ (ITE) Trip Generation Manual, 11th Edition, 2021. However, the Trip Generation Handbook that complements the Manual notes that locally collected data may be used when available. Counts were collected at six wine warehouse and storage facilities in the City of American Canyon and used for the analysis prepared for the SDG 217 project, which is adjacent to SDG 220.
2 Given the geographic proximity of these projects to the proposed SDG 220 project and the similarity in land use type, the trip generation rates from those analyses were applied to the current project. Based on the application of these rates, the proposed project would be expected to generate an average of 372 trips per day, including 35 AM peak-hour trips and 27 trips during the PM peak-hour. These results are summarized in Table 3.13-2. 2 GHD. 2020. Traffic Impact Analysis Memorandum. SDG 217 Commerce Boulevard Distribution Center Project. 987
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Land Use Units
Daily AM Peak-hour PM Peak-hour
Rate Trips Rate Trips In Out Rate Trips In Out
Wine Warehouse 219.834 ksf 1.69 372 0.16 35 21 14 0.125 27 10 17 Notes:
ksf = 1,000 square feet
Source: GHD. 2020. Traffic Impact Analysis Memorandum. SDG 217 Commerce Boulevard Distribution Center Project.

Vehicle Miles Traveled
In accordance with City policy, outputs from the City’s travel demand model were used as the metric for evaluating VMT. Since the proposed project is an employment site, the citywide VMT per employee of 34.1 miles was used as the baseline for evaluating potential VMT impacts associated with the proposed project, and the significance threshold was 19 percent below this level, or 27.6 miles. As noted in the City policy, the 19 percent emissions reduction target established by the ARB that was the basis for this threshold was focused on passenger vehicle emissions. The use of passenger vehicle emissions for VMT analysis is supported by the OPR Technical Advisory, which states that in Section 15064.3 of the CEQA Guidelines, “automobiles” refers to “on-road passenger vehicles, specifically cars and light trucks.” (Technical Advisory, p. 4); 3 further, the OPR explicitly
notes that VMT does not include consideration of heavy-duty trucks. Accordingly, the appropriate source of VMT to analyze for the proposed project is associated with employee commute trips rather than heavy vehicle trips. Note that while heavy-duty trucks are not the focus of transportation-based VMT analyses, truck VMT is still analyzed under other CEQA discipline areas including GHG emission analyses.

To evaluate the proposed project VMT, it was assumed that the VMT per employee would reflect the citywide average of 34.1 miles. Therefore, for the proposed project to have a less than significant VMT impact, the VMT per employee would need to be reduced by 19 percent to a maximum of 27.6 miles.

Traffic Operations Analysis
A traffic operations analysis was previously conducted for the SDG Commerce 217 project, which is similar to the proposed project and located on the adjacent parcel to the north. Commerce Court, formerly known as Commerce Boulevard, has been truncated and redesigned as a cul-de-sac, preventing vehicle traffic to and from the south. As a result, all vehicles entering the project site must pass through the Green Island Road/Commerce Court intersection. The analysis prepared for the SDG Commerce 217 project found that this intersection would operate acceptably under Cumulative Plus Project conditions. Since the current project is consistent with the City’s General Plan, the proposed project generated trips were presumably included in the future traffic volume 3 California Governor’s Office of Planning and Research (OPR). 2018. Technical Advisory on Evaluating Transportation Impacts in CEQA. December. Website: https://opr.ca.gov/docs/20190122-743_Technical_Advisory.pdf. Accessed October 12, 2023. 988
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It is noted that a traffic operations analysis does not address a CEQA issue. As a result of the passage of SB 743, since July 2020, lead agencies may no longer measure adverse transportation effects for CEQA purposes in terms of “automobile delay, as described solely by level of service or similar measures of vehicular capacity or traffic congestion” (with an exception not relevant here) (Public Resources Code [PRC] § 21099(b)(2)). Even so, many public agencies still require analyses of proposed projects’ potential effects on LOS, but do so under their general police power or General Plan policies, wholly independent of, and separate from, CEQA.

3.13.5 - Thresholds of Significance
Appendix G to the CEQA Guidelines is a sample Initial Study Checklist that includes questions for determining whether impacts related to transportation are significant. These questions reflect the input of planning and environmental professionals at the OPR and the California Natural Resources Agency, based on input from stakeholder groups and experts in various other governmental agencies, nonprofits, and leading environmental consulting firms. As a result, many lead agencies derive their significance criteria from the questions posed in Appendix G. The City has chosen to do so for this project. Thus, the proposed project would have a significant effect related to transportation if the proposed project would:
a) Conflict with a program plan, ordinance or policy of the circulation system, including transit, roadway, bicycle and pedestrian facilities.
b) Conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b). c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment). d) Result in inadequate emergency access.

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

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

Impact Analysis
Circulation
General Plan Policy 4.6 indicates that industrial uses should be located in the City’s north industrial area to minimize the impacts of truck traffic on residential neighborhoods. The proposed project is located adjacent to similar warehouse projects, and with the redesign of Commerce Court as a culde-sac, the roadway connection to the residential neighborhood to south of the project is not available, and truck traffic would be required to access the site via Green Island Road. As the proposed project would minimize truck traffic impacts on residential neighborhoods, the proposed 989
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Transit
As described above, the nearest bus stop to the project is located on Rio del Mar near Eucalyptus Drive and serves Vine Transit Route 11, approximately 1.3 miles south of the project. An acceptable walking distance to a bus stop is generally considered to be 0.5 mile. Should an employee desire to use transit, they could ride a bicycle along the path at the southern terminus of Commerce Court to Waters Edge Court and proceed along Eucalyptus Drive to the nearest bus stop. General Plan Circulation Element Implementing Policy 1.35 calls for the provision of continuous access to existing and future transit service. As there are continuous sidewalks between the proposed project and the nearest bus stop and a route for bicyclists is available between the project site and the bus stop is available, the proposed project would not conflict with this policy. Impacts would therefore be less than significant with regard to transit facilities.

Bicycles
Existing bicycle facilities, including the Class I path connecting to the southern terminus of Commerce Court and linking to other nearby facilities together with shared use of minor streets provide adequate access for bicyclists in the project vicinity. The planned extension of the Class I facility along Eucalyptus Drive and planned Class II bicycle facilities on Green Island Road, Commerce Court, and other streets near the proposed project would improve bicycle connectivity near the project site. General Plan Circulation Element Guiding Policy 2.1 supports development of a safe and efficient non-motorized circulation system. Since the existing bicycle facilities network provides connections to surrounding neighborhoods and destinations and would be further enhanced by the implementation of planned facilities, the proposed project would not conflict with this policy. For this reason, the impacts to bicycle facilities would be less than significant.

Pedestrian
The project site would be accessible to pedestrians approaching from the south due to the presence of the Class I path at the southern terminus of Commerce Court and the connecting path and sidewalk facilities in the residential neighborhood south of Eucalyptus Drive. Employees would also have access to recreational walking opportunities along the unpaved path at Wetlands Edge Park. It is reasonable to assume that few project employees would desire to walk to the project site from the north, given the industrial character of the surrounding area and the incomplete sidewalk network.

As a continuous pedestrian network provides access from the project site to the adjacent neighborhoods, nearest transit options, and the SR-29 corridor, the project would not conflict with General Plan Circulation Element Guiding Policy 2.1. Pedestrian facility impacts would thus be less than significant.

Level of Significance Before Mitigation
Less than significant impact.

Mitigation Measures
No mitigation is required.
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Impact Analysis
The proposed project VMT was evaluated in accordance with the City’s adopted VMT policy as described in Section 3.13.4-Methodology, and in response to direction from City staff. For the project’s VMT impact to be less than significant, the VMT per employee would need to be reduced by at least 19 percent below current levels. It is noted that Napa County uses a similar approach to analyze VMT impacts for wine warehouses in the project vicinity, although the County applies a different threshold. VMT reductions are typically achieved by applying Transportation Demand Management (TDM) measures which provide incentives to encourage use of alternatives to vehicle transportation.

According to the Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity, California Air Pollution Control Officers Association (CAPCOA), 2021 (CAPCOA Handbook), a reduction in the VMT of 15 percent is generally considered the maximum feasible mitigation for suburban environments, such as that of the proposed project. If this level of trip reduction could be achieved, that would mitigate most of the project’s VMT impact, although not to a level that would be less than significant (19 percent). However, given the lack of transit services within an acceptable walking distance of the project, achieving even this level of mitigation is considered infeasible.

Nonetheless, Mitigation Measure (MM) TRANS-2 requires the implementation of a TDM program to reduce VMT to the extent possible. As noted, the nearest bus stop to the project site is 1.3 miles away and serves only limited destinations; therefore, given the land use context of the project area and per the CAPCOA Handbook, a TDM program is estimated to result in a VMT reduction of approximately 4 percent. As such, even with the implementation of mitigation, impacts related to VMT would remain significant and unavoidable.

Level of Significance Before Mitigation
Significant impact.

Mitigation Measure
MM TRANS-2 Transportation Demand Management Program
The proposed project shall develop a Transportation Demand Management (TDM) program to encourage employees to choose non-personal vehicle modes of transportation for commuting. This includes a commute trip reduction marketing initiative, through which the employer would disseminate information about available transportation options. Strategies would include encouraging ride sharing among project employees and linking them to resources to find rideshare partners working nearby, such as through the Napa Valley Transportation Authority (NVTA) VCommute program or the regional 511.org program. Marketing materials can also 991
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Level of Significance After Mitigation
Significant and unavoidable impact.

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

Impact Analysis
Site access and sight distance were evaluated for the proposed project.

Site Access
The proposed project would be located between two warehouse facilities, one of which is existing while the second is under construction. The three sites would be connected via internal roadways as shown on the site plan (Chapter 2, Project Description, Exhibit 2-4a and Exhibit 2-4b). Therefore, vehicular access to the project site would be provided via two existing driveways located on adjacent parcels. The internal roadways would need to be designed to current City standards to accommodate heavy vehicles and so can be expected to accommodate the access requirements for both emergency and passenger vehicles. The adequacy of the driveways was assessed as part of the development review process for their respective projects. Impacts with respect to site access would therefore be less than significant.

Sight Distance
A substantially clear line of sight should be maintained between the driver of a vehicle waiting at a driveway and the driver of an approaching vehicle. As noted, access to the proposed project would be provided via two previously approved driveways. The southernmost driveway is at the end of a cul-de-sac, while the second driveway is approximately 500 feet to the north. Approaching vehicle speeds would be slow in this setting. The street is flat with a slight curve that would not impact visibility of approaching vehicles, and it is noted that obstacles would be minimized as on-street parking is prohibited along both sides of the street. As such, there would be a less than significant impact on sight distance.

Parking
Parking is not typically considered a safety issue. However, the lack of adequate parking can result in vehicles being parked in inappropriate and hazardous locations. Given that on-street parking is prohibited along Commerce Court, the adequacy of the proposed parking supply was evaluated. Per Section 19.21.030 of the City’s Municipal Code, the required off-street parking for warehouses is one space for the first 20,000 square feet of space plus one space for each additional 2,000 square feet of gross floor area. With a proposed building area of 224,593 square feet, 122 spaces would be 992
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Level of Significance Before Mitigation
Less than significant impact.

Mitigation Measures
No mitigation is required.

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

Impact Analysis
As previously noted, vehicular access to the proposed project would be provided via two driveways to adjacent properties on Commerce Court. The driveways were included as part of previously approved projects, which included project-level review for compliance with emergency access requirements. In addition, based on the analysis of traffic operations at the Green Island Road/Commerce Boulevard intersection conducted for SDG 217, the proposed project would have a negligible impact on delay and the associated emergency vehicle response times. Regarding site design, the internal roadways of the proposed project would need to be designed to current City standards to accommodate heavy vehicles and so can be expected to accommodate the access requirements for both emergency and passenger vehicles. Impacts to emergency access would therefore be less than significant.

Level of Significance Before Mitigation
Less than significant impact.

Mitigation Measures
No mitigation required.

3.13.7 - Cumulative Impacts
The geographic scope of the cumulative transportation analysis is the nine-county San Francisco Bay Area region. VMT is evaluated and regulated at a regional level and, thus, the San Francisco Bay Area region is an appropriate geographical area.

Impact TRANS-1 concluded that the proposed project would not have a significant impact on the circulation system and, therefore, no mitigation would be necessary. As such, the proposed project would not have a cumulative considerable contribution in this regard.

Impact TRANS-2 concluded that the proposed project would have a significant and unavoidable impact on VMT because the proposed project would be required to reduce VMT by a minimum of 19 percent below the citywide average, which would be challenging given the project’s location and lack of access to high-quality transit. MM TRANS-2 would reduce project-related VMT but not to a 993
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With respect to Impact TRANS-3, the potential hazards from design features or incompatible uses are specific to the project site (e.g., site access, sight distance, etc.) and would not combine with other projects. The proposed project and other past, present, and reasonably foreseeable future projects have complied and must comply with local standard requirements for transportation-related design features specifically adopted to avoid and reduce hazards from project design or the location of incompatible uses, thereby reducing potential significant cumulative impacts to less than significant levels. Therefore, no significant impacts would result from the proposed project combined with cumulative projects.

With respect to Impact TRANS-4, the provision of adequate emergency access is site specific and would not combine with other projects. The proposed project and other past, present, and reasonably foreseeable future projects must comply with local standard requirements for adequate emergency access specifically adopted to avoid or reduce the potential for inadequate access.

Furthermore, as was determined in the operational analysis conducted for SDG Commerce 217, the proposed project and other projects would not have significant impacts on the performance of the Green Island Road/Commerce Boulevard intersection and, therefore, it can be inferred that it would also not impair emergency response to the project vicinity. Therefore, no significant adverse cumulative impacts would result.

Level of Cumulative Significance Before Mitigation
Significant VMT impact.

Mitigation Measures
MM TRANS-2 as described above.

Level of Cumulative Significance After Mitigation
Significant and unavoidable impact.
994
56390001 • 03/2024 | 3.13-1_street_network.cdr CITY OF AMERICAN CANYON SDG COMMERCE 220 PROJECT

ENVIRONMENTAL IMPACT REPORT
Exhibit 3.13-1
Local Street Network
Source: W-trans.

I
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56390001 • 03/2024 | 3.13-2_bikew
ays.cdr CITY OF AMERICAN CANYON
SDG COMMERCE 220 PROJECT

ENVIRONMENTAL IMPACT REPORT
Exhibit 3.13-2
Existing and Proposed Bikeways
Source: W-trans.

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City of American Canyon—SDG Commerce 220 Distribution Center Project Draft EIR Utilities and Service Systems
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3.14 - Utilities and Service Systems

3.14.1 - Introduction
This section describes the existing conditions related to utilities and service systems (water, wastewater, stormwater, and solid waste) in the City of American Canyon (City) and project area as well as the relevant regulatory framework. This section also evaluates the possible impacts related to such utilities and service systems that could result from implementation of the proposed project.

Descriptions and analyses in this section are based, in part, on information provided by the City of American Canyon General Plan, the 2020 Urban Water Management Plan (2020 UWMP), and the City of American Canyon Sewer Master Plan.

No public comments pertaining to utilities or service systems were received in response to the Notice of Preparation (NOP).

3.14.2 - Environmental Setting
Water
The City of American Canyon Public Works Department provides potable and nonpotable water to a service area of approximately 30 square miles. The area encompasses the city limits and its Sphere of Influence (SOI) and extends from the Napa River to the west to the Napa/Solano County line to the east and from the Napa/Solano County line to the south to Soscol Ridge north of the Napa Airport.1
Water Supply
The City obtains its water supply from a variety of sources, all of which (except for recycled water) are imported from outside of the City. Imported water is mostly sourced from the State Water Project (SWP) and purchased from the Napa County Flood Control and Water Conservation District (FCWCD) and the City of Vallejo. The City’s imported water comes through the North Bay Aqueduct system.2 Table 3.14-1 identifies the City’s sources and volume of water used in 2020. Each source is discussed in detail after the table.

Table 3.14-1: 2020 Sources of Water Supply
Source
Actual Volume
(Acre-Feet in 2020)
State Water Project “Table A” Water 29
State Water Project Article 21 Water 191
Article 56 Carryover Water 1,819
Table A Exchange Return Water 12
Vallejo Permit Water 500
1 City of American Canyon. 2022. 2020 Urban Water Management Plan. Website:
https://www.cityofamericancanyon.org/government/maintenance-and-utilities/water Accessed January 18, 2024. 2 Ibid.
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Actual Volume
(Acre-Feet in 2020)
Vallejo Treated Water 58
Vallejo Emergency Water 0
Recycled Water 208
Total: 2,817
Source: City of American Canyon. 2023. 2020 Urban Water Management Plan, Submittal Table 6- 8 Retail: Water Supplies—Actual. Website:
https://www.cityofamericancanyon.org/government/maintenance-and-utilities/water. Accessed January 18, 2024.

State Water Project
A significant portion of the City’s supply is obtained through various indirect contracts for water from the SWP. The Napa County FCWCD is the State Water Contractor with the California Department of Water Resources (DWR), and the City receives its water through subcontracts with the Napa Flood Control and Water Conservation District.

Table A Allocation
In January 1967, the American Canyon County Water Agency3 entered into an agreement with the Napa County FCWCD for SWP water (“Table A” allotments) supply from the North Bay Aqueduct. This contract runs through 2035 with provisions for extension and is anticipated to be extended through 2085. The City’s current “Table A” allotment is 5,200 acre-feet per year (AFY). The actual amount of SWP water available to the City under the “Table A” allocation process (the method used by the DWR to allocate water in the SWP system) varies from year to year due to hydrologic conditions, water demands of other contractors, SWP facility capacity, and environmental/regulatory requirements.

The 2020 UWMP assumes that “Table A” water allotment would be 56 percent, 5 percent, and 27 percent of the full contracted volume (5,200 AFY) for average, single-dry, and 5-consecutive-year drought water types, respectively.4
Article 21 Water
In certain years, the City may also receive additional SWP water known as Article 21 water, which is identified in Article 21 of SWP long-term water supply contracts between DWR and each SWP water contractor. The year-to-year availability of Article 21 water supply varies. Article 21 water becomes available only when the following conditions are met:
• Such deliveries do not interfere with SWP “Table A” allocations and SWP operations. • Excess water is available in the Delta.
• Capacity is not being used for SWP purposes or scheduled SWP deliveries. • Contractors can use the SWP Article 21 water directly or can store it in their own system (I.e., the water cannot be stored in the SWP system).
3 A predecessor agency to the City of American Canyon, which was not incorporated until 1992. 4 City of American Canyon. 2022. 2020 Urban Water Management Plan. Website:
https://www.cityofamericancanyon.org/government/maintenance-and-utilities/water Accessed January 18, 2024. 1000
City of American Canyon—SDG Commerce 220 Distribution Center Project Draft EIR Utilities and Service Systems
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Article 56 Carryover Water
DWR’s Article 56 Carryover Program allows water that is allocated to an SWP contractor but not used by the end of the year to be used in the next year. This water is exported from the Delta by the Banks Pumping Plant and stored in the San Luis Reservoir.6
“Table A” Exchange Return Water
DWR’s “Table A” Exchange Return Water Program allows interested SWP contractors to receive a portion of another SWP contractors approved “Table A” allotment in exchange for return of future approved SWP “Table A” water at an established exchange ratio.7 City of Vallejo
In 1996, the City of American Canyon entered into an agreement with the City of Vallejo to allow the purchase of additional water supply. Vallejo receives its water from a variety of sources, including SWP water and an appropriative water right. The City’s agreement with the City of Vallejo allows for the purchase of Vallejo Permit Water (raw water), Vallejo Treated Water (potable water), and Vallejo Emergency Water (raw water).

Vallejo Permit Water
The City of Vallejo holds an appropriative right for Sacramento Bay-Delta water from the California State Water Resources Control Board (State Water Board) that pre-dates the construction of the SWP. The City of American Canyon has an agreement with the City of Vallejo for delivery of up to 500 AFY under this permit. This source of water is more reliable than the City’s Table A supply, but the Vallejo Agreement still allows for reductions. Addendum 2 to the 1996 Vallejo Agreement states that “In the event the State Water Resources Control Board, or any other agency, restricts Vallejo’s diversion of water [under the appropriative pre-SWP contract] for any reason whatsoever, American Canyon’s diversions will be reduced in the same proportion.” Since the City began receiving Vallejo Permit Water, it has received 100 percent of the full contracted volume every year with the exception of a supply reduction in 2015.

The 2020 UWMP predicts that the full contract volume of 500 AFY would be available under average, single-dry, and 5-consecutive-year drought water types.8 Vallejo Treated Water
In 1996, the City of American Canyon entered into an agreement with the City of Vallejo to purchase up to 628.6 AFY of Vallejo Treated Water. The water is treated at the City of Vallejo’s Flemming Hill Water Treatment Plant and delivered via an intertie connection. 5 A predecessor agency to the City of American Canyon, which was not incorporated until 1992. 6 Ibid. 7 Ibid. 8 Ibid. 1001
City of American Canyon—SDG Commerce 220 Distribution Center Project Utilities and Service Systems Draft EIR

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Vallejo Emergency Water
When the City’s “Table A” water allotment is curtailed, the City of American Canyon has the option to purchase up to 500 acre-feet of emergency raw water supply from Vallejo under an agreement amended in 1996.

The 2020 UWMP assumes that the full contracted volume of 500 AFY would be available for singledry and consecutive dry years 1 to 2; 400 AFY would be available for consecutive dry years 3 to 5; and 0 AFY for average year water type (i.e., not available when the City’s “Table A” allotment is not curtailed).10
Other Sources of Potable Supply
Dry Year Purchase Program
The DWR’s Dry Year Water Purchase Program allows SWP contractors to purchase emergency water supplies from Sacramento Valley rice farmers during dry years if supply is made available.

Turn-back Water Pool Program
DWR has a program for interested SWP contractors called the Turn-back Water Pool Program. SWP contractors may choose to sell “Table A” water or purchase turn-back pool water that is available through the program. The City has not purchased water through this program since 2015.

Dry Year Transfer Program
During dry years, varying amounts of additional water may be made available to SWP contractors through DWR’s Dry Year Transfer Program, which allows for transfers through a combination of crop idling, groundwater substitution, and changes in reservoir operation. The City has not purchased water through this program since 2015.

Yuba Accord
In 2008, the DWR adopted the Lower Yuba River Accord, an agreement to settle issues related to instream flows in the Yuba River and fisheries habitat. As part of that agreement, participating SWP contractors are able to purchase water from the Yuba River Water Agency during dry years. The City has not purchased water through this program since 2015.

City of Napa
The City has an agreement with the City of Napa for the purchase of treated (potable) water under emergency conditions or when the North Bay Aqueduct system or the City’s Water Treatment Plant (WTP) is off-line for maintenance or other reasons. This water source would be deducted from the City’s “Table A” water allotment. The City has not purchased water through this program since 2014. 9 A predecessor agency to the City of American Canyon, which was not incorporated until 1992. 10 Ibid. 1002
City of American Canyon—SDG Commerce 220 Distribution Center Project Draft EIR Utilities and Service Systems
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The City is located over the Napa-Sonoma Valley Lowlands Subbasin. According to the 2020 UWMP, groundwater productivity in and near the City indicated that usable groundwater resources in the City may be limited. The City does not operate groundwater wells for water supply. The City does not have any surface water sources as part of its water supply and has not identified any stormwater recapture opportunities to offset potable water use.

Recycled Water
American Canyon Recycled Water
The City’s Water Reclamation Facility (WRF) produces disinfected tertiary recycled water under the General Water Reuse Order (Order No. 96-011) per the recycled water criteria defined by the Division of Drinking Water (DDW), formerly the California Department of Public Health, under California Administrative Code, Division 4, Title 22, California Code of Regulation. The City currently delivers recycled water to meet demand on an as-needed basis to nine private customers for agricultural and landscape irrigation and 21 City-owned facilities for landscape irrigation and as dust control at construction sites.

Wastewater
The City and the Napa Sanitary District (NSD) provide municipal wastewater collection within the City’s water service area. The City’s wastewater collection system consists of gravity pipelines, two force mains, and pump stations that convey wastewater to the City’s WRF located near the Napa River at the City’s northwest limits. The NSD collects wastewater from the residents and businesses in the City of Napa, Silverado Country Club, the Napa County Airport, and several adjacent unincorporated areas, including northeastern portions of the City’s water service area. The wastewater is conveyed to NSD’s Soscol WRF, located outside of the City’s water service area. The 2020 wastewater flows from the City’s service area consisted of 1,625 AF collected by the City’s wastewater collection agency and diverted to the City’s WRF and 139 AF collected by the NSD and diverted to the Soscol WRF for a total of 1,764 AF of wastewater. The American Canyon WRF is owned and operated by the City of American Canyon. The treatment plant has an existing design capacity of 2.5 million gallons per day (mgd) at average dry weather conditions and 5.0 mgd at peak weather flow conditions. The City has plans to expand the WRF’s treatment capacity to 4.0 mgd.

Storm Drainage
The City of American Canyon Public Works Department oversees municipal storm drainage within the American Canyon City limits. The municipal storm drainage system consists of ditches, inlets, basins, and underground piping that ultimately discharge flows into the Napa River. The City maintains a Storm Drain Master Plan, adopted in 1996, and engineering standards that guide the development of the municipal storm drainage system.

The City requires stormwater discharges to comply with San Francisco Bay Regional Water Quality Control Board (San Francisco Bay RWQCB) permit requirements and establishes non-point source pollution control measures as required by federal and State law. Stormwater pollution prevention measures for new development projects, such as bioswales, detention ponds, erosion, and 1003
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Project Site Drainage
The project site does not contain any formal storm drainage facilities. The project site frontage with Commerce Court is currently improved with curb and gutter.

Solid Waste
Recology American Canyon (Recology) provides garbage pickup for all residents and businesses pursuant to a franchise waste hauling agreement with the City of American Canyon. Roll-off service is also available.

Devlin Road Transfer Station
Recology transports solid waste to the Devlin Road Transfer Station within the Napa County Airport Industrial Area. The Transfer Station is owned by the Napa-Vallejo Waste Management Authority (NVWMA), a joint-powers agency consisting of the cities of American Canyon, Napa, and Vallejo and the County of Napa. The Transfer Station accepts municipal solid waste and construction and demolition (C&D) debris and incentivizes such activities through pricing. The NVWMA has plans to construct an enclosed C&D Debris Recycling Facility on a vacant parcel it owns immediately south of the Devlin Road Transfer Station. California Environmental Quality Act (CEQA) documentation has been completed and certified for the new facility, but it has yet to be constructed.

Potrero Hills Landfill
Municipal solid waste and demolition debris from the Devlin Road Transfer Station are landfilled at the Potrero Hills Landfill in Solano County. The Potrero Hills Landfill, located approximately 1 mile southeast of Suisun City, is a regional facility that serves numerous jurisdictions within a 150-mile radius.
11 In 2005, the County of Solano approved a 260-acre expansion that increased capacity to

83.1 million cubic yards. In 2010, the San Francisco Bay Conservation and Development Commission (BCDC) issued a permit allowing the expansion to proceed. Following the conclusion of litigation, the expansion was cleared to move forward in 2014. Table 3.14-2 summarizes the Potrero Hills Landfill.

Table 3.14-2: Potrero Hills Landfill Summary
Permitted Area Permitted Daily Throughput
Permitted Disposal
Capacity Remaining Capacity
Estimated Closure
Date
525.7 acres (total) 4,330 tons (single day) 83.1 million cubic yards

13.872 million
cubic yards
2/14/2048
340.0 acres
(disposal)
4,330 tons (single day)
11 California Department of Resources Recycling and Recovery (CalRecycle). 2024. Solid Waste Information System (SWIS) Facility/Site Activity Details – Potrero Hills Landfill (48-AA-0075). Website:
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1194?siteID=3591. January 18, 2024. 1004
City of American Canyon—SDG Commerce 220 Distribution Center Project Draft EIR Utilities and Service Systems
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Permitted Disposal
Capacity Remaining Capacity
Estimated Closure
Date
Note:

Data obtained from Solid Waste Facility Permit No. 48-AA-0075 Source: California Department of Resources Recycling and Recovery (CalRecycle) 2024. SWIS Facility/Site Activity Details.

Website: https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1194?siteID=3591. January 18, 2024.

3.14.3 - Regulatory Framework
Federal
National Pollutant Discharge Elimination System
Pursuant to Section 402 of the Clean Water Act and the Porter-Cologne Water Quality Control Act, municipal stormwater discharges in Suisun City are regulated under the San Francisco Bay Region Municipal Regional Stormwater National Pollutant Discharge Elimination System (NPDES) Permit, MS4 Order No. 2013-001 (General Permit). In 1987, Congress amended the Clean Water Act to mandate controls on discharges from Municipal Separate Storm Sewer Systems (MS4s). Acting under the federal mandate and the California Water Code, RWQCBs require cities, towns, and counties to regulate activities that can result in pollutants entering their storm drains. All municipalities prohibit non-stormwater discharges to storm drains and require residents and businesses to use Best Management Practices (BMPs) to minimize the amount of pollutants in runoff. The Municipal Regional Permit is overseen by the San Francisco Bay RWQCB. On February 5, 2013, the State Water Board reissued the Phase II Stormwater NPDES Permit for small MS4s. Provision E.12, “PostConstruction Stormwater Management Program,” mandates municipalities to require specified features and facilities—to control pollutant sources, to control runoff volumes, rates, and durations, and to treat runoff before discharge from the site—be included in development plans of projects that create or replace 5,000 square feet or more impervious surface as conditions of issuing approvals and permits. The new requirements continue a progression of increasingly stringent requirements since 1989.

Provision E.12 requires all municipal permittees to implement these requirements by June 30, 2015, to the extent allowed by applicable law. This includes projects requiring discretionary approvals that have not been deemed complete for processing and discretionary permit projects without vesting tentative maps that have not requested and received an extension of previously granted approvals.

In July of 2014, the Bay Area Stormwater Management Agencies Association (BASMAA), through the BASMAA Phase II Committee, created the BASMAA Manual to assist applicants for development approvals to prepare submittals that demonstrate their project complies with the NPDES permit requirements. Applicants who seek development approvals for applicable projects should follow the manual when preparing their submittals. The manual is designed to ensure compliance with the requirements and promote integrated Low Impact Development (LID) design.

Section E.12.c of the General Permit pertains to LID and how it relates to hydromodification management. This permit provision requires that stormwater discharges not cause an increase in the erosion potential of the receiving stream over the existing condition. Increases in runoff flow and 1005
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State
California Urban Water Management Planning Act
The Urban Water Management Planning Act (California Water Code §§ 10610–10656) requires that all urban water suppliers prepare UWMPs and update them every 5 years. In preparing a UWMP, an urban water supplier must describe or identify the following, among other things (as set forth in Water Code § 10631):
• “The service area of the supplier, including current and projected population, climate, and other demographic factors affecting the supplier’s water management planning.” • “Projected population estimates” based on “data from the State, regional, or local service agency population projections within the service area,” in “5-year increments to 20 years or as far as data is available.”
• “Past and current water use” and “projected water use.” • “Existing and planned sources of water” for each 5-year increment of the 20-year planning period.
• Specific detailed information about groundwater where it is identified as “an existing or planned source of water available to the supplier.”
• “All water supply projects and water supply programs” that may be undertaken to meet “total projected water use,” including “specific projects” and the “increase in water supply” expected from each project.
• An estimate of “the implementation timeline for each project or program.” • “Plans to supplement or replace” any “water source that may not be available at a consistent level of use, given specific legal, environmental, water quality, or climatic factors” with “alternative sources or water demand management measures, to the extent practicable.” • “The reliability of the water supply and vulnerability to seasonal or climatic shortage, to the extent practicable,” for (i) an “average water year,” (ii) a “single dry water year,” and (iii) “[m]ultiple dry water years.”
• “Opportunities for exchanges or transfers of water on a short-term or long-term basis.” • “Opportunities for development of desalinated water, including, but not limited to, ocean water, brackish water, and groundwater, as a long-term supply.” • “Water demand management measures.”
1006
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As revised by Senate Bill (SB) 610 (Stats. 2002, ch. 643), Section 10910, et seq. of the California Water Code set forth the circumstances in which CEQA lead agencies must seek preparation of, or prepare themselves, “water supply assessments” for defined proposed “projects.” At the time a lead agency determines that a proposed project requires an Environmental Impact Report (EIR), the lead agency shall identify any “public water system” that would serve the project site and shall request that any such entity prepare a Water Supply Assessment (WSA) for the project. In the absence of such a public water system, the city or county lead agency must prepare its own WSA. SB 610 functions together with CEQA, in that a WSA must be included in “any environmental document” for any “project” subject to SB 610 (Water Code Section 10911(b); see also State CEQA Guidelines Section 15155(e); see also Id. Section 15361 [defines “environmental documents” to include “Negative Declarations . . . (and) draft and final EIRs”]).

One of the fundamental tasks of a WSA is to determine whether “total projected water supplies available during normal, single dry, and multiple dry water years during a 20-year projection will meet the projected water demand associated with the proposed project, in addition to the public water system’s existing and planned future uses, including agricultural and manufacturing uses” (Water Code § 10910 (c)(3), (c)(4)). In making such a determination, the authors of the WSA must address several factors. Specifically, the WSA must contain information regarding existing water supplies, projected water demand, and dry year supply and demand. In Vineyard Area Citizens for Responsible Growth v. City of Rancho Cordova (2007) 40 Cal.4th 412, 433 (“Vineyard”), the California Supreme Court briefly summarized the key content requirements as follows:

With regard to existing supply entitlements and rights, a Water Supply Assessment must include assurances such as written contracts, capital outlay programs and regulatory approvals for facilities construction . . . but as to additional future supplies needed to serve the project, the assessment need include only the public water system’s plans for acquiring the additional supplies, including cost and time estimates and regulatory approvals the system anticipates needing (Water Code §§ 10910, subd. (d)(2), and 10911, subd. (a)). (Original italics.)
“Existing” water supplies can be based on different kinds of legal rights or arrangements, including entitlements, water rights, and water service contracts. In many cases, these supplies are likely already described in detail in the supplier’s UWMP (Water Code § 10631(b)). Suppliers are expressly permitted to rely on information contained in the most recently adopted UWMPs, provided that the water needed for proposed development project was accounted for therein (Water Code § 10910(c)(2)).

In preparing a WSA, the public water system must disclose and document the quantity of water received from these various sources. Such supplies must be demonstrated by providing the following:
(A) Written contracts or other proof of entitlement to an identified water supply. 1007
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(C) Federal, State, and local permits for construction of necessary infrastructure associated with delivering the water supply.
(D) Any necessary regulatory approvals that are required in order to be able to convey or deliver the water supply.
(Id. subd. (d)(2)).

A finding of insufficiency in a WSA does not require a city or county to deny or downsize a proposed development project. Rather, after identifying a shortfall, the public water system must provide its plans for acquiring “additional supplies” (or what the California Supreme Court called “future” supplies) (Water Code § 10911(a)). These plans should include information concerning the following:
(1) The estimated total costs, and the proposed method of financing the costs, associated with acquiring the additional water supplies.
(2) All federal, State, and local permits, approvals, or entitlements that are anticipated to be required in order to acquire and develop the additional water supplies. (3) Based on the considerations set forth in paragraphs (1) and (2), the estimated timeframes within which the public water system, or the city and county . . . expects to be able to acquire additional water supplies.

These particular Water Code requirements for assessments are action-forcing, in that they require the public water system to lay out a roadmap for obtaining new water supplies once it becomes aware that existing supplies are insufficient for the proposed project together with other foreseeable planned growth.

Regardless of the information provided to a city or county in a WSA, SB 610 stops short of preventing cities and counties from approving the “projects” at issue absent “sufficient” water supplies. But where “existing water supply entitlements, water rights, or water service contracts” are “insufficient” to serve proposed projects, SB 610 does require that, in approving projects in the face of insufficient supplies, cities and counties must “include” in their “findings for the project[s]” their “determination[s]” regarding water supply insufficiency. SB 610 functions together with CEQA, in that a WSA must be included in “any environmental document” for any “project” subject to SB 610. (Id. subd. (b); Guidelines, § 15155, subd. (e); see also id. § 15361 [defines “environmental documents” to include “Negative Declarations. . . (and) draft and final EIRs”]).

Recycled Water Policy
On February 3, 2009, by Resolution No. 2009-0011, the State Water Board adopted a Recycled Water Policy in an effort to move toward a sustainable water future. The Recycled Water Policy states that “we declare our independence from relying on the vagaries of annual precipitation and move toward sustainable management of surface waters and groundwater, together with enhanced water conservation, water reuse and the use of stormwater.”
1008
City of American Canyon—SDG Commerce 220 Distribution Center Project Draft EIR Utilities and Service Systems
FirstCarbon Solutions 3.14-11 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/EIR/2 - Screencheck EIR/56390001 Sec03-14 Utilities.docx The following goals were included in the Recycled Water Policy:
• Increase use of recycled water over 2002 levels by at least 1 million AFY by 2020 and at least 2 million AFY by 2030.
• Increase the use of stormwater over use in 2007 by at least 500,000 AFY by 2020 and at least 1 million AFY by 2030.
• Increase the amount of water conserved in urban and industrial areas by comparison to 2007 by at least 20 percent by 2020.
• Included in these goals is the substitution of as much recycled water for potable water as possible by 2030.

The Recycled Water Policy provides direction to the RWQCBs regarding issuing permits for recycled water projects, addresses the benefits of recycled water, addresses a mandate for use of recycled water, and indicates the State Water Board will exercise its authority to the fullest extent possible to encourage the use of recycled water.

The Recycled Water Policy also indicates that some groundwater basins contain salts and nutrients that exceed or threaten to exceed water quality objectives established in basin plans and states that it is the intent of this Recycled Water Policy that all salts and nutrients be managed on a basin-wide or watershed-wide basis through development of regional or subregional management plans. Finally, the Recycled Water Policy addresses the control of incidental runoff from landscape irrigation projects, recycled water groundwater recharge projects, anti-degradation, control of emerging constituents and chemicals of emerging concern, and incentives for use of recycled water.

In accordance with the provisions of the Recycled Water Policy, a Constituents of Emerging Concerns Advisory Panel was established to address questions about regulating constituents of concern (COCs) with respect to the use of recycled water. The Advisory Panel’s primary charge was to provide guidance for developing monitoring programs that assess potential COC threats from various water recycling practices, including groundwater recharge/reuse and urban landscape irrigation. On June 25, 2010, the Advisory Panel provided recommendations to the State Water Board and California Department of Public Health in their Final Report “Monitoring Strategies for Chemicals of Emerging Concern in Recycled Water – Recommendations of a Scientific Advisory Panel.” The State Water Board used those recommendations to amend the Recycled Water Policy in 2013 (State Water Board Resolution No. 2013-003).

The April 2013 amendment provides direction to the RWQCBs on monitoring requirements for COCs in recycled water. The monitoring requirements pertain to the production and use of recycled water for groundwater recharge reuse by surface and subsurface application methods and for landscape irrigation. The amendment identifies three classes of constituents to monitor:
• Human health-based COCs: COCs of toxicological relevance to human health. • Performance indicator COCs: An individual COC used for evaluating removal through treatment of a family of COCs with similar physicochemical or biodegradable characteristics. 1009
City of American Canyon—SDG Commerce 220 Distribution Center Project Utilities and Service Systems Draft EIR

3.14-12 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/EIR/2 - Screencheck EIR/56390001 Sec03-14 Utilities.docx • Surrogates: A measurable physical or chemical property, such as chlorine residual or electrical conductivity, that provides a direct correlation with the concentration of an indicator compound. Surrogates are used to monitor the efficiency of COC treatment.

Only groundwater recharge reuse facilities would be required to monitor for COCs and surrogates.

Surface application and subsurface application facilities would have different mandatory COCs and a different monitoring schedule. Monitoring is not required for recycled water used for landscape irrigation projects that qualify for streamlined permitting unless monitoring is required under the adopted salt and nutrient management plan. Streamlined permitting projects must meet the criteria specified in the policy, including compliance with Title 22, application at agronomic rates, compliance with any applicable salt and nutrient management plan, and appropriate use of fertilizers.

Water Conservation Act of 2009
Requirements regarding per capita water use targets are defined in the Water Conservation Act of 2009, which was signed into law in November 2009 as part of a comprehensive water legislation package. Known as SB X7-7, the legislation sets a goal of achieving a 20 percent reduction in urban per capita water use Statewide by 2020. SB X7-7 required retail water suppliers to define in their 2010 UWMPs the gallons per capita per day targets for 2020, with an interim 2015 target.

Assembly Bill 1881
Assembly Bill (AB) 1881 expanded previous legislation related to landscape water use efficiency. AB 1881, the Water Conservation in Landscaping Act of 2006, enacted landscape efficiency recommendations of the California Urban Water Conservation Council for improving the efficiency of water use in new and existing urban irrigated landscapes in California. AB 1881 required the DWR to update the existing Model Local Water Efficient Landscape Ordinance and local agencies to adopt the updated model ordinance or an equivalent. The law also requires the California Energy Commission (CEC) to adopt performance standards and labeling requirements for landscape irrigation equipment, including irrigation controllers, moisture sensors, emission devices, and valves to reduce the wasteful, uneconomic, inefficient, or unnecessary consumption of energy or water.

Assembly Bill 2882
AB 2882 was passed in 2008 and encourages public water agencies throughout California to adopt conservation rate structures that reward consumers who conserve water. AB 2882 clarifies the allocation-based rate structures and establishes standards that protect consumers by ensuring a lower base rate for those who conserve water.

California Integrated Waste Management Act
To minimize the amount of solid waste that must be disposed of by transformation and land disposal, the State Legislature passed AB 939, the California Integrated Waste Management Act of 1989, effective January 1990. The legislation required each local jurisdiction in the State to set diversion requirements of 25 percent by 1995 and 50 percent by 2000; established a comprehensive Statewide system of permitting, inspections, enforcement, and maintenance for solid waste facilities; and authorized local jurisdictions to impose fees based on the types or amounts of solid 1010
City of American Canyon—SDG Commerce 220 Distribution Center Project Draft EIR Utilities and Service Systems
FirstCarbon Solutions 3.14-13 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/EIR/2 - Screencheck EIR/56390001 Sec03-14 Utilities.docx waste generated. In 2007, SB 1016, Wiggins, Statutes of 2008, Chapter 343, introduced a new per capita disposal and goal measurement system that moved the emphasis from an estimated diversion measurement number to an actual disposal measurement number as a per capita disposal rate factor. As such, the new disposal-based indicator (pounds per person per year) uses only two factors:
(1) a jurisdiction’s population (or in some cases employment) and (2) its disposal as reported by disposal facilities.

Assembly Bill 341 (75 Percent Solid Waste Diversion)
In 2011, the Legislature implemented a new approach to the management of solid waste. AB 341 (Chesbro, Chapter 476, Statutes of 2011) required that the California Department of Resources Recycling and Recovery (CalRecycle) oversee mandatory commercial recycling and established a new Statewide goal of 75 percent recycling through source reduction, recycling, and composting by 2020.

This paradigm adds to the policies in AB 939 in several significant ways. First, AB 341 established a Statewide policy goal rather than a jurisdictional mandate. This places the onus for achieving the goal on the State rather than on the cities and counties that are directly responsible for waste disposal and recycling. Under the law, individual jurisdictions are not required to meet the new policy goal.

AB 341 required CalRecycle to issue a report to the Legislature that included strategies and recommendations that would enable the State to divert 75 percent of the solid waste generated in the State from disposal by January 1, 2020, required businesses that meet specified thresholds in the bill to arrange for recycling services by January 1, 2012, and also streamlined various regulatory processes.

California Code of Regulations Title 24
Part 6 (Energy Efficiency Standards for Residential and Nonresidential Buildings) Title 24, Part 6, of the California Code of Regulations establishes California’s Energy Efficiency Standards for Residential and Nonresidential Buildings. The standards were updated in 2013. The 2013 standards set a goal of reducing growth in electricity use by 561.2 gigawatt-hours per year (GWh/y) and growth in natural gas use by 19 million therms per year. The savings attributable to new nonresidential buildings are 151.2 GWh/y of electricity savings and 3.3 million therms. For nonresidential buildings, the standards establish minimum energy efficiency requirements related to building envelope, mechanical systems (e.g., heating, ventilation, and air conditioning [HVAC] and water heating systems), indoor and outdoor lighting, and illuminated signs.

Part 11 (California Green Building Standards Code)
California Code of Regulations Title 24, Part 11, is a comprehensive and uniform regulatory code for all residential, commercial, and school buildings that went in effect January 1, 2011. The Code is updated on a regular basis, with the most recent update consisting of the 2022 California Green Building Code Standards that became effective January 1, 2023.12 Local jurisdictions are permitted to adopt more stringent requirements as State law provides methods for local enhancements. The Code recognizes that many jurisdictions have developed existing construction and demolition 12 California Energy Commission (CEC). 2023. Building Energy Efficiency Standards. Website: https://www.energy.ca.gov/programsand-topics/programs/building-energy-efficiency-standards/2022-building-energy-efficiency. Accessed April 26, 2024. 1011
City of American Canyon—SDG Commerce 220 Distribution Center Project Utilities and Service Systems Draft EIR

3.14-14 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/EIR/2 - Screencheck EIR/56390001 Sec03-14 Utilities.docx ordinances and defers to them as the ruling guidance provided they include a minimum 50 percent diversion requirement. The Code also provides exemptions for areas not served by construction and demolition recycling infrastructure. California Building Standards Code (CBC) provides the minimum standard that buildings need to meet in order to be certified for occupancy, which is generally enforced by the local building official.

Local
City of American Canyon
General Plan
The City of American Canyon General Plan sets forth the following goals and policies relevant to utilities and service systems:

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

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

Goal 5C Establish and maintain adequate planning, construction, maintenance, and funding for storm drain and flood control facilities to support permitted land uses and preserve the public safety; upgrading existing deficient systems and expanding, where necessary, to accommodate new permitted development and to protect existing development in the City. Pursue public funding sources (i.e., grants) to reduce fiscal impacts of implementation to the City.

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

Policy 5.10.12 Require that new development be designed to prevent the diversion of floodwaters onto neighboring parcels.

Policy 5.10.18 Require that development projects maximize the use of pervious surface materials (grass, ground cover, and other) that minimize stormwater runoff.

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

Policy 5.12.2 Incorporate features in new drainage detention facilities which enhance the water quality of discharges from the facility.

Policy 5.13.1 Require that development activities comply with the State General Storm Water Permit for Construction Activities with measures that protect surface water quality to the maximum extent practicable.
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City of American Canyon—SDG Commerce 220 Distribution Center Project Draft EIR Utilities and Service Systems
FirstCarbon Solutions 3.14-15 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/EIR/2 - Screencheck EIR/56390001 Sec03-14 Utilities.docx Municipal Code
Chapter 8.20.030 Requires that commercial businesses shall have separate compost, recycling, and trash containers.

Chapter 8.20.110 Requires compliance with the model water efficient landscaping ordinance of the CalGreen Building Code including design plan submittal to ensure landscaping water use efficiency.

Chapter 13.10 New Water and Sewer Connections and Services. Establishes and requires, among other things, capacity fees, service fees, maximum allowable water use, use of no flow or low flow fixtures, and use of recycled water for irrigation.

Chapter 13.14.065 New or existing non-residential customers whose properties may be served by recycled water are required to connect or convert their property to connect to recycled water for use in irrigation and dual plumbing for toilet flushing.

Chapter 19.22.070 Recycled Water. Requires the use of recycled water for irrigation systems.

Zero Water Footprint Policy
The City’s Zero Water Footprint Policy requires no loss of water service reliability or increase in water rates to the City of American Canyon's existing water service customers due to a requested increase in demand for water within the City's water service area.

3.14.4 - Methodology
FirstCarbon Solutions (FCS) reviewed relevant City documents, including, but not limited to, the City of American Canyon General Plan, the American Canyon Municipal Code, the City of American Canyon Sewer Master Plan, the 2020 UWMP, as well as actual water consumption data on the existing Commerce Court 330 project.

3.14.5 - Thresholds of Significance
The lead agency utilizes the criteria in CEQA Guidelines Appendix G Environmental Checklist to determine whether impacts to utilities and service systems are significant environmental effects.

Would the proposed project:
a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years? c) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
1013
City of American Canyon—SDG Commerce 220 Distribution Center Project Utilities and Service Systems Draft EIR

3.14-16 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/EIR/2 - Screencheck EIR/56390001 Sec03-14 Utilities.docx d) Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? e) Comply with federal, State, and local statutes and regulations related to solid waste?

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

Facilities Expansion
Impact UTIL-1: The proposed project would not require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects.

Impact Analysis
The proposed project would connect to existing water (both potable and recycled), wastewater, electricity, and telecommunication infrastructure in Commerce Court. Existing service laterals would extend from Commerce Court lines to the proposed building (a minor distance of less than 10 feet).

As discussed in Impact UTIL-2 and Impact UTIL-3, sufficient water supply and wastewater capacity is available to serve the proposed project, and, therefore, new or expanded water or wastewater facilities would not be required beyond those constructed on-site. The proposed project’s stormwater runoff would be directed via storm drainpipes into an on-site bioretention pond, the construction of which is considered in this Draft EIR. No off-site stormwater infrastructure would be required. Electricity and telecommunication infrastructure would also be extended on-site from connections in Commerce Court and would not require new or expanded facilities. The project does not contemplate the use of natural gas. In summary, the proposed project would not result in the relocation or construction of new or expanded utilities facilities outside the project boundaries.

Impacts would be less than significant.

Level of Significance Before Mitigation
Less than significant impact.

Mitigation Measures
No mitigation is necessary.

Water Supply
Impact UTIL-2: The proposed project would have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years.

Impact Analysis
Potable water demand for the project was estimated based on actual water consumption from the SDG Commerce 330 project, which is a similarly sized wine distribution warehouse operation located directly adjacent to the project site. Estimates are summarized in Table 3.14-3. Also shown are the 1014
City of American Canyon—SDG Commerce 220 Distribution Center Project Draft EIR Utilities and Service Systems
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Table 3.14-3: SDG Commerce 220 Estimated Water Consumption Water Type
Estimated AcreFeet/Year1 Will-Serve AcreFeet/Year2
Domestic 0.0635 0.31
Reclaimed 0.0537 1.55
1These estimates are based on actual water use rates for the adjacent SDG Commerce 330 wine distribution warehouse recorded at a rate of 94.07 domestic gallons per 1,000 square feet per year or 0.2577 domestic gallons per 1,000 square feet per day, and 0.0053 reclaimed acre-feet per year (AFY) per acre or approximately 0.0000 reclaimed acre-feet per day per acre. 2These estimates are based on the approved will-serve letter for the SDG Commerce 330 project.

As shown above, the proposed project is estimated to demand between approximately 0.0635 and

0.31 domestic acre-feet and between 0.0537 and 1.55 reclaimed acre-feet of water per year, for a combined total of between 0.1172 and 1.86 AFY. The project would incorporate Demand Management Measures (DMMs) through compliance with water waste prevention ordinances, including the Municipal Code’s Water Waste Prohibitions Ordinance (Section 13.14.060), as well as codes related to water efficient landscaping (Section 16.14 and 19.22).

Tables Table 3.14-4, Table 3.14-5, and Table 3.14-6 demonstrate the City of American Canyon’s estimated normal, single dry year, and multiple dry years supply and demand, as indicated by the UWMP.
13 Table 3.14-4: Normal Year Supply and Demand Comparison (AFY) 2025 2030 2035 2040 2045
Supply Totals 4,959 4,959 5,575 5,575 5,575
Demand Totals 3,543 3,785 4,580 4,822 5,075
Difference 1,416 1,174 994 753 500
Source: City of American Canyon. 2023. 2020 Urban Water Management Plan.

As indicated in Table 3.14-4, the City would have a surplus of at least 500 acre-feet of water in normal years through the year 2045. The water demanded by the proposed project is approximately .02 percent of the projected water surplus for the year 2045.14 As such, the City would be able to serve the proposed project during normal years through the year 2045. 13 City of American Canyon. 2023. 2020 Urban Water Management Plan. 14 0.1172/500*100=0.2344 1015
City of American Canyon—SDG Commerce 220 Distribution Center Project Utilities and Service Systems Draft EIR

3.14-18 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/EIR/2 - Screencheck EIR/56390001 Sec03-14 Utilities.docx Table 3.14-5: Single Dry Year Supply and Demand Comparison (AFY) 2025 2030 2035 2040 2045
Supply Totals 1,897 1,897 2,132 2,132 2,132
Demand Totals 3,543 3,785 4,580 4,822 5,075
Difference -1,646 -1,888 -2,448 -2,689 -2,943
Notes:

Demand reductions due to water shortage stage rationing measures are not included in the single dry year demand estimates.

Source: City of American Canyon. 2023. 2020 Urban Water Management Plan.

Table 3.14-6: Multiple Dry Year Supply and Demand Comparison (AFY) Year Totals 2025 2030 2035 2040 2045
First Year Supply Totals 3,359 3,359 3,776 3,776 3,776
Demand Totals 3,543 3,785 4,580 4,822 5,075
Difference -184 -426 -804 -1,046 -1,299
Second Year Supply Totals 3,359 3,359 3,776 3,776 3,776 Demand Totals 3,543 3,785 4,580 4,822 5,075
Difference -184 -426 -804 -1,046 -1,299
Third Year Supply Totals 3,251 3,251 3,655 3,655 3,655
Demand Totals 3,543 3,785 4,580 4,822 5,075
Difference -291 -534 -925 -1,167 -1,420
Fourth Year Supply Totals 3,251 3,251 3,655 3,655 3,655 Demand Totals 3,543 3,785 4,580 4,822 5,075
Difference -291 -534 -925 -1,167 -1,420
Fifth Year Supply Totals 3,251 3,251 3,655 3,655 3,655
Demand Totals 3,543 3,785 4,580 4,822 5,075
Difference -291 -534 -925 -1,167 -1,420
Note:

Demand reductions due to water shortage stage rationing measures are not included in the 5-consecutive-year drought demand estimates.

Source: City of American Canyon. 2023. 2020 Urban Water Management Plan.

The Single Dry Year scenario is the year that represents the lowest water supply available to the City.

The Multiple Dry Year scenario, in this case, a 5-consecutive-year drought, is the period that represents the driest 5-year historical sequence for the City. 1016
City of American Canyon—SDG Commerce 220 Distribution Center Project Draft EIR Utilities and Service Systems
FirstCarbon Solutions 3.14-19 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/EIR/2 - Screencheck EIR/56390001 Sec03-14 Utilities.docx As shown in Tables 3.14-5 and 3.14-6, for the single and multiple dry year scenarios there is a projected water deficit in all years, beginning in the year 2025. However, the City is expanding the use of local water resources and reducing waste through implementation of DMMs.15 As indicated in the UWMP, demand reductions due to rationing measures are not included in scenario estimates.

Therefore, the deficit could be reduced by implementing the DMMs. In addition, the City’s UWMP contains a Water Waste Prohibition Ordinance, Metering, Conservation Pricing, Public Outreach and Education, Water Loss Assessment Programs, Water Conservation Program Coordination and Staffing Support, etc. These initiatives are described in greater detail in the City’s UWMP and all contribute to the reduced demand for water supply.

The City also has several planned methods to expand recycled water use. The City’s Recycled Water Master Plan identifies 15 capital improvement projects to upgrade the City’s recycled water system to serve projected buildout demands of nearly 1,000 AFY.16 This would be sufficient to meet the City’s water deficits in multiple dry years through the year 2035.

Lastly, the City can implement additional supply augmentation methods, including purchasing additional water with existing dry-year agreements, decreasing line flushing, increasing water waste patrols, or employing a moratorium or net zero demand increase on new connections. As indicated in the UWMP, the City anticipates it can supply all its water demands through the 2045 planning horizon by purchasing supplemental imported water through existing agreements for all water year scenarios (without accounting for use reduction savings, therefore making this a conservative conclusion). As indicated in Table 7-5 of the UWMP, shortfalls could adequately be met in each multiple dry year.

In sum, the City is able to meet project demand in all years under the normal year scenario. In the dry and multiple dry year scenarios, the City is projected to have a deficit. However, planned increases in recycled water use would increase supplies to be sufficient through 2035, in dry and multiple dry year scenarios. DMMs, supply augmentation methods, recycled water use, and agreements would further reduce water deficits in the dry and multiple dry year scenarios. Finally, the UWMP concluded that predicted water supply constraints could be resolved through the purchase of “supplemental imported water through existing agreements through the planning horizon (2045) for all water year scenarios.”17 Furthermore, water purchases, both temporary and permanent, are commonly used in California to redirect water resources to areas of greatest need, consistent with the legislative policy of the State to facility water transfers (see California Water Code § 575.480, et seq.).

The City has a Zero Water Footprint Policy, which is defined as “no loss in reliability or increases in water rates for existing water service customers due to requested increased demand for water within the City’s water service area.” Consistent with the policy, the proposed project’s estimated water use would be reviewed. This process would ensure that either the proposed project meets the adopted Zero Water Footprint Policy (projects that either require no additional water demand or projects which offset increased water demand by off-site measures) or requires a Water Supply 15 City of American Canyon. 2023. 2020 Urban Water Management Plan. 16 City of American Canyon, 2023. 2020 Urban Water Management Plan. 17 Ibid. 1017
City of American Canyon—SDG Commerce 220 Distribution Center Project Utilities and Service Systems Draft EIR

3.14-20 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/EIR/2 - Screencheck EIR/56390001 Sec03-14 Utilities.docx Report. If a Water Supply Report is required it would determine the proposed project’s water demand measures needed to reach a zero water footprint. The remaining water footprint of the proposed project would be offset through a method agreed upon by the City and the developer. The proposed project would offset its water footprint by contributing funding to the City’s water projects. In either instance, a zero water footprint would be obtained.

Furthermore, per Municipal Code Section 13.10, the proposed project is limited to an average use of 650 gallons of water per day per acre (measured monthly). For the proposed project’s 10.45-acre site, this would equate to 6,792.5 gallons of water per day. As indicated in Table 3.14-3, the proposed project’s estimated domestic water consumption would be between 0.0635 and 0.31 acre feet per year or 20,691 to 101,014 gallons per year. This equates to less than 57 to 277 gallons of water per day, far below the allowable amount.

Finally, the proposed project would be consistent with Municipal Code Section 19.22.070 by using recycled water for landscaping irrigation, thus eliminating the use of potable water for landscaping purposes. The proposed project would also be required to submit landscaping plans to the City as part of project applicant and approval process demonstrating compliance with the City’s Model Water Efficient Landscape Ordinance (Municipal Code 8.20.110).

In summary, the City’s ability to purchase additional water in all dry year scenarios, along with DMMs, the Zero Water Footprint Policy, water use reduction, and use of recycled water, ensures that sufficient water would be available to serve existing, planned, and future buildout, including the proposed project. Furthermore, the proposed project’s water demand would be far below average allowable use. Therefore, for the reasons discussed herein, there would be sufficient water supplies available to serve the proposed project and reasonably foreseeable future development during normal, dry, and multiple dry years. Impacts would be less than significant.

Level of Significance Before Mitigation
Less than significant impact.

Mitigation Measures
No mitigation is necessary.

Wastewater Treatment Capacity
Impact UTIL-3: The proposed project would not result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments.

Impact Analysis
The proposed project would be served by the City of American Canyon for wastewater collection and treatment. Table 3.14-7 provides the proposed project’s estimated wastewater generation based on estimated water consumption. For the purposes of a conservative analysis, it is assumed that 100 percent of water consumed becomes wastewater. Note that it is standard industry assumption that wastewater represents only 90 percent of water consumption. 1018
City of American Canyon—SDG Commerce 220 Distribution Center Project Draft EIR Utilities and Service Systems
FirstCarbon Solutions 3.14-21 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/EIR/2 - Screencheck EIR/56390001 Sec03-14 Utilities.docx Table 3.14-7: Wastewater Generation Estimate
Water Consumption Estimate Source
Anticipated Daily
Water Consumption
Wastewater
Generation Calculation
Daily Wastewater
Generation
SDG Commerce 330–Actual Use 57 gallons1 57 gallons x 1 57 gallons (0.000057 mgd)
SDG Commerce 330–Will-Serve Letter 275 gallons2 275 gallons x 1 275 gallons (.000275 mgd)
Notes:

MGD = million gallons per day

1. 0.0635 acre-feet per year (AFY) (as indicated in Table 3.13-3) = 20,691.5349 gallons per year = ~57 gallons per day 2 0.31 acre-feet per year (AFY) (as indicated in Table 3.13-3) = 101,013 gallons per year = ~275 gallons per day Source: FirstCarbon Solutions (FCS), 2024; City of American Canyon, 2024.

As shown in Table 3.14-7, the proposed project would produce between approximately 57 and 275 gallons of effluent per day (0.000057 to 0.000275 mgd). The City’s WTP has a maximum capacity of

2.5 mgd at dry weather flow conditions and 5.0 mgd at peak wet weather flow conditions. In the year 2020, the WRF treated 1,625 acre-feet in total, which is approximately 529 million gallons. 18 This is approximately 1.5 mgd per day, meaning there was 1 mgd of additional capacity in the year 2020. The proposed project would produce between 0.000057 and 0.000275 mgd, which is approximately 0.0057 to .0275 percent of the remaining daily capacity of the WTP. As such, existing treatment capacity would be sufficient to serve the proposed project in addition to existing commitments. Impacts would be less than significant.

Level of Significance Before Mitigation
Less than significant impact.

Mitigation Measures
No mitigation is necessary.

Solid Waste
Impact UTIL-4: The proposed project would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals.

Impact Analysis
This impact discussion assesses whether the proposed project would be served by a landfill with adequate capacity or comply with federal, State, and local statutes and regulations related to solid waste. Solid waste would be generated by construction and operational activities. Each is discussed as follows.
18 City of American Canyon. 2023. 2020 Urban Water Management Plan. Table 6-2 Retail: Wastewater Collected Within Service Area in 2020.
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City of American Canyon—SDG Commerce 220 Distribution Center Project Utilities and Service Systems Draft EIR

3.14-22 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/EIR/2 - Screencheck EIR/56390001 Sec03-14 Utilities.docx Construction Waste
The proposed project would result in the construction of a 219,834-square-foot wine distribution warehouse. Using a nonresidential construction waste generation rate published by the United States Environmental Protection Agency (EPA), an estimate of the total construction debris generated by the proposed project is provided in Table 3.14-8.

Table 3.14-8: Construction Solid Waste Generation
Waste Generation Rate Square Feet
Construction Waste Generation
Tons Cubic Yards

3.89 pounds/square foot 219,834 428 599
Notes:
1 ton = 2,000 pounds; 1 ton = approximately 1.4 cubic yards Sources:

United States Environmental Protection Agency (EPA). 1998.

FirstCarbon Solutions (FCS). 2024.

Development of the proposed project would generate an estimated 599 cubic yards of construction debris. This waste volume represents less than 0.01 percent of the 13.872 million cubic yards of remaining capacity at the Potrero Hills Landfill. Moreover, the values shown in the table do not adjust construction solid waste generation to account for C&D debris recycling that would serve to divert waste from the landfill. The Napa Valley Waste Management Authority provides C&D debris recycling at the nearby Devlin Road Transfer Station. The proposed project would be required to dispose of C&D debris in compliance with the City’s C&D Ordinance.

Therefore, short-term construction impacts on landfill capacity would be less than significant.

Operational Waste
Table 3.14-9 summarizes the proposed project’s annual operational waste generation based on a rate provided by CalRecycle.

Table 3.14-9: Annual Operational Solid Waste Generation Waste Generation Rate Square Feet
Operational Waste Generation
Tons Cubic Yards

4.8 pounds/square foot 219,834 528 739
Notes:
1 ton = 2,000 pounds; 1 ton = 1.4 cubic yards
Sources:

California Department of Resources Recycling and Recovery (CalRecycle).

FirstCarbon Solutions (FCS). 2022.

The proposed project would generate an estimated 739 cubic yards of operational solid waste on an annual basis at buildout. This waste volume represents less than 0.01 percent of the 13.872 million 1020
City of American Canyon—SDG Commerce 220 Distribution Center Project Draft EIR Utilities and Service Systems
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Level of Significance Before Mitigation
Less than significant impact.

Mitigation Measures
No mitigation is necessary.

3.14.7 - Cumulative Impacts
The cumulative utilities analysis' geographic scope is the service area of each provider serving the proposed project. Because of differences in the nature of the utility topical areas, they are discussed separately.

Water
The geographic scope of the cumulative potable water analysis is the City of American Canyon Public Works Department service area, which encompasses the American Canyon city limits.

Cumulative projects, including those listed in Table 3-1 (refer to Chapter 3, Environmental Impact Analysis, Table 3-1, Cumulative Projects) are located within areas of the City of American Canyon and Napa County. As discussed under Impact UTIL-2, the City has available water supplies to serve the proposed project under normal hydrologic conditions. Furthermore, the City would be able to serve the proposed project during the single dry or multiple dry year scenario with the use of DMMs, recycled water, supply augmentation methods, and agreements with other agencies. The proposed project would be required to comply with the City’s Zero Water Footprint Policy, Municipal Code Chapter 13.10 and Section 19.22.070. Developers of other cumulative projects would be required to comply with the Zero Water Footprint Policy as well as Municipal Code requirements related to water usage. Additionally, the proposed project and other pending projects are accounted for in the UWMP and would not create the need for any new or expanded facilities that could have significant cumulative impacts. Therefore, cumulative impacts would be less than significant. Because the proposed project would comply with these requirements as well, the proposed project would not have a cumulatively considerable contribution toward the less than significant cumulative impacts related to water supply.

Wastewater
The geographic scope of the cumulative wastewater analysis is the American Canyon WRF service area, which encompasses the American Canyon City limits and areas within the Napa County Airport Industrial Park south of Fagan Creek. The cumulative projects, including those listed in Table 3-1, located in the City are within the service area and would generate volumes of wastewater conveyed 1021
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The WRF has an existing design capacity of 2.5 mgd and the City has plans to increase that to 4.0 mgd over time. The proposed project is estimated to generate 57 gallons of wastewater on a daily basis (0.00005 mgd) at buildout. The proposed project’s estimated wastewater generation of 0.005 mgd per day would represent about 0.005 percent of the average daily flow treated by the expanded WRF. As such, cumulative impacts would be less than significant.

Additionally, the proposed project’s contribution to this less than significant impact would not be cumulatively considerable. Each applicant for individual development proposals in the service area would be required to comply with applicable wastewater requirements. Therefore, the proposed project’s contribution to this less than significant impact related to wastewater generation and treatment would not be cumulatively considerable.

Storm Drainage
The City of American Canyon Public Works Department oversees municipal storm drainage within the American Canyon City limits. The municipal storm drainage system consists of ditches, inlets, basins, and underground piping that ultimately discharges flows into the Napa River. The City maintains a Storm Drainage Master Plan and engineering standards that guide development of the municipal storm drainage system.

All future development projects in the City are required to provide storm drainage facilities that collect and detain stormwater. The storm drainage facility shall include provisions for future upstream development and no development shall discharge at a rate that exceeds the capacity of any portion of the existing downstream system. Runoff from storms up to the 100-year return frequency are conveyed through storm facilities and disposed of in a manner that protects public and private improvements from flood hazards.

During project construction, the proposed project would implement standard stormwater pollution prevention measures to ensure downstream water quality impacts are minimized to the greatest extent possible.

As described in Section 3.9, Hydrology, the proposed project would install an on-site storm drainage system consisting of inlets, piping, and a series of detention basins that would result in a net decrease in peak stormwater runoff rates. As such, the proposed project would ensure no net increase in stormwater would leave the project site during a peak storm event and would avoid cumulatively significant stormwater impacts to downstream waterways at times when capacity is most constrained.

Cumulative projects would be required to prepare and implement a Stormwater Pollution Prevention Plan (SWPPP) for project construction. Cumulative projects would be required to incorporate a stormwater control plan and stormwater collection systems into the development that would reduce the volume of stormwater runoff that cumulative projects would generate. Therefore, cumulative impacts in this regard would be less than significant.
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Solid Waste
The geographic scope of the cumulative solid waste analysis is the City of American Canyon.

Recology provides solid waste and recycling collection services to commercial customers in the City of American Canyon.

Many past and all present and reasonably foreseeable future development projects that have or would generate construction and operational solid waste, depending on the volumes and end uses, have been or would be required to implement recycling and waste reduction measures. The proposed project is anticipated to generate 599 cubic yards of solid waste during construction and 739 cubic yards annually during operations. For comparison purposes, the Potrero Hills Landfill has a remaining capacity of 13.872 million cubic yards. As such, it appears that sufficient capacity would be available to serve the proposed project as well as existing and planned land uses in the City of American Canyon for the foreseeable future.

Additionally, the nearby Devlin Road Transfer Station offers C&D debris recycling and incentivizes such activities through pricing. Thus, it would be expected that some of the projects listed in Chapter 3, Environmental Impact Analysis, Table 3-1 would take advantage of C&D debris recycling, which would divert materials from the solid waste stream and contribute to conserving landfill capacity, thereby extending the operational life of Potrero Hills Landfill. For these reasons, cumulative impacts to solid waste would be less than significant.

The proposed project’s construction and operational solid waste generation would represent less than 0.01 percent of the remaining capacity at the Potrero Hillas Landfill facility. Therefore, the proposed project, in conjunction with other cumulative projects, would result in a less than significant cumulative impact related to solid waste generation and landfill capacity.

Level of Cumulative Significance Before Mitigation
Water–Less than significant impact.

Wastewater–Less than significant impact.

Storm Drainage–Less than significant impact.

Solid Waste–Less than significant impact.

Mitigation Measures
No mitigation is necessary.
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City of American Canyon—SDG Commerce 220 Distribution Center Project Draft EIR Effects Found not to be Significant
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4.1 - Introduction
This chapter is based on the Notice of Preparation (NOP), dated October 27, 2023, and contained in Appendix A of this EIR. The NOP was prepared to identify the potentially significant effects of the project and was circulated for public review between October 27, 2023 and November 27, 2023. In the course of the NOP evaluation, certain impacts were found to be less than significant because construction and operation of the proposed project would not result in such impacts. This chapter provides a brief description of effects found not to be significant or less than significant, based on the NOP, NOP public comments received, or more detailed analysis conducted as part of the EIR preparation process. Note that a number of impacts that are found to be less than significant are addressed in the various EIR topical sections (Sections 3.1 through 3.14) to provide more comprehensive discussion of why impacts are less than significant, in order to better inform decision-makers and the general public.

4.2 - Environmental Effects Found not to be Significant

4.2.1 - Aesthetics, Light, and Glare
Scenic Vistas
The project site is surrounded by eucalyptus groves (west and east) and existing industrial buildings (north and south). Because of these characteristics, the project site is not visible from a scenic vista.

Furthermore, the project site is flat and does not contain any features that would be characterized as a scenic vista (e.g., ridgeline, overlook, etc.). This precludes the possibility of the proposed project having an adverse impact on a scenic vista. No impact would occur.

State Scenic Highways
State Route (SR) 29 is located more than 1 mile to the east of the project site. SR-29 is an “Eligible” State Scenic Highway. SR-29 is not visible from the project site due to the presence of intervening topography and vegetation. No impact would occur.

4.2.2 - Agriculture Resources and Forestry Resources
Loss of Important Farmland
The project site contains undeveloped land and is not used for agricultural land use activities. The California Department of Conservation maps the project site as “Other Land,” which does not fall under the Important Farmland umbrella. No impact would occur.

Williamson Act Contracts or Agricultural Zoning
The project site contains undeveloped land and is not used for agricultural land use activities. The project site is not encumbered by an active Williamson Act Contract. The project site is zoned for industrial use; thus, no conflicts with agricultural zoning would occur. No impact would occur. 1025
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The project site contains undeveloped land and does not have any commercially harvestable stands of trees. The project site is zoned for commercial recreational and winery use; thus, no conflicts with forest zoning would occur. No impact would occur.

Loss of Forest Land
The project site contains undeveloped land and does not have any commercially harvestable stands of trees. Thus, the proposed project would not convert forestland to non-forest use. No impact would occur.

Pressures to Convert Surrounding Agricultural Land or Forest Land The California Department of Conservation maps the areas immediately adjacent to the project site as “Other Land.” Furthermore, the eucalyptus groves to the west and east of the project site are not considered commercially harvestable timer. For these reasons, the proposed project would not create pressures to convert surrounding agricultural or forest land to other use. No impact would occur.

4.2.3 - Biological Resources
Sensitive Natural Communities or Riparian Habitat.

Seasonal wetland communities are typically considered sensitive under the California Environmental Quality Act (CEQA). The wetland features on-site would be avoided by the proposed project through the implementation of 25-foot buffers (Section 3.3, Biological Resources, Exhibit 3.3-4). The wetland buffer avoidance area would ensure that construction activities do not impact the on-site jurisdictional wetland features. Upon operation, the project’s stormwater would be directed away from the features, as required by the proposed project’s Storm Water Pollution Prevention Plan (SWPPP). No other sensitive communities occur on-site. Therefore, no impacts on sensitive natural communities would occur.

Conservation Plans
No adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State Habitat Conservation Plan is applicable to the project site. Therefore, the proposed project would not conflict with the provisions of such a document. No impacts would occur.

4.2.4 - Geology, Soils, and Seismicity
Septic or Alternative Wastewater Disposal Systems
The proposed project would be served with wastewater collection and treatment service provided by the City of American Canyon. No septic or alternative wastewater disposal systems would be employed. No impact would occur.
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4.2.5 - Hazards and Hazardous Materials
Wildfires
The project site is located within an urbanized area of the City of American Canyon. The eucalyptus groves to the west and east of the project site are small in size and surrounded by urban uses or marshland, making the susceptibility to wildland fires low. As such, the proposed project would not expose persons or properties to wildland fire hazards. No impact would occur.

4.2.6 - Hydrology and Water Quality
100-Year Flood Hazards
The Napa County Geographic Information System (GIS) online mapping tool indicates that the project site is not within a 100-year flood hazard zone. This condition precludes the possibility of the proposed project being exposed to 100-year food hazards. No impact would occur.

Levee or Dam Failure
The project site is not protected by a levee, a condition that precludes flooding from levee failure.

Napa County General Plan Safety Element Figure SAF-5 indicates that the project site is not within a dam failure inundation zone for any impounded bodies of water. No impact would occur.

Seiches, Tsunamis, or Mudflows
The project site is not near any inland bodies of water that may be susceptible to a seiche. The project site is more than 25 miles from the Pacific Ocean. The project site is not with an area of volcanic activity or at the base of any slopes that are susceptible to mudflows. No impact would occur.

4.2.7 - Land Use
Division of an Established Community
The project site is vacant and does not contain any dwelling units or other structures that would constitute an established community. As such, the development of the proposed project would not divide an established community. No impact would occur.

4.2.8 - Mineral Resources
Loss of Mineral Resources of Statewide or Local Importance The project site contains undeveloped land. No mineral extraction occurs on-site and there are no mineral resources of statewide or local importance at the project site. This precludes the possibility of conflicts in this regard. No impact would occur.

4.2.9 - Population and Housing
Growth Inducement
The proposed project would develop 219,834 square feet of light industrial uses on an undeveloped site. No direct residential growth would occur. The proposed project would employ an estimated 35 1027
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Displacement of Persons or Housing
The project site is vacant and does not contain any dwelling units. As such, the development of the proposed project would not displace persons or housing. No impact would occur.

4.2.10 - Public Services and Utilities
Schools
The proposed project would not involve construction of dwelling units and, thus, would not result in direct enrollment growth in public schools. Therefore, no new or expanded school facilities would be required. No impact would occur.

Parks
The proposed project would not involve construction of dwelling units and, thus, would not result in increased demand for parks. Therefore, no new or expanded park facilities would be required. No impact would occur.

Other Public Facilities
The proposed project would not involve construction of dwelling units and, thus, would not result in increased demand for libraries or community facilities. Therefore, no new or expanded libraries or community facilities would be required. No impact would occur.

4.2.11 - Recreation
The proposed project would not involve construction of dwelling units and, thus, would not result in direct population growth. As such, it would not increase use of existing recreational facilities or require construction or expansion of new recreational facilities. No impact would occur.

4.2.12 - Wildfire
Emergency Evacuation
The proposed project would take vehicular access from two driveways on Commerce Court.

Accordingly, the proposed project would provide two points of emergency access and, thus, would comply with California Fire Code requirements.

The Commerce Court cul-de-sac has a gated Emergency Vehicle Access connection to Eucalyptus Drive to the south. This would be available for emergency response and evacuation to and from the project site.
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Wildfire Risks
The project site is located within a Local Responsibility Area and is not located in a very high fire hazard severity zone. The project site is flat and located in an urbanized area. The eucalyptus groves to the west and east of the project site are small in size and surrounded by urban uses or marshland, making the susceptibility to wildland fires low. As such, the proposed project would not expose persons or properties to wildland fire hazards. No impact would occur.

Fire Infrastructure
The proposed project would connect to existing utilities infrastructure. The project site is surrounded and has development on two sides and Commerce Court on the east side. No impact would occur.

Post-Fire Hazards
The project site is flat and would not be at risk of a landslide. As explained in Section 3.9, Hydrology and Water Quality, the proposed project would result in a net decrease in peak stormwater runoff rates because of the proposed detention and treatment system. The proposed project would not substantially alter the existing drainage pattern. No impact would occur. 1029

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City of American Canyon—SDG Commerce 220 Distribution Center Project Draft EIR Other CEQA Considerations
FirstCarbon Solutions 5-1 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/EIR/2 - Screencheck EIR/edit/56390001 Sec05-00 Other CEQA.docx CHAPTER 5: OTHER CEQA CONSIDERATIONS

5.1 - Significant Unavoidable Impacts
California Environmental Quality Act (CEQA) Guidelines Section 15126.2(a)(c) requires an Environmental Impact Report (EIR) to identify and focus on the significant environmental effects of the proposed project, including effects that cannot be avoided if the proposed project were implemented.

Based on the analyses contained in this Draft EIR, the City of American Canyon (City) has determined that the proposed project in conjunction with other cumulative development in the southeast portion of the City of American Canyon would result in the following a significant and unavoidable impacts:
• Inconsistency with CEQA Guidelines Section 15064.3, subdivision (b): The City’s travel demand model establishes 34.1 miles per employee as the baseline for evaluating potential Vehicle Miles Traveled (VMT) impacts associated with the proposed project, and the significance threshold was 19 percent below this level, or 27.6 miles. The 19 percent emissions reduction target established by the California Air Resources Board (ARB) was the basis for this threshold. Given the lack of transit services within an acceptable walking distance of the project, a 19 percent reduction was determined infeasible. Mitigation is proposed to require the preparation and implementation of a transportation demand management program; however, these measures would not sufficiently reduce VMT. Therefore, the significance after mitigation is significant and unavoidable.
• Cumulative Transportation: Impact TRANS-2 concluded that the proposed project would have a significant and unavoidable impact on VMT because the proposed project would be required to reduce VMT by a minimum of 19 percent below the citywide average, which would be challenging given the project’s location and lack of access to high-quality transit. MM TRANS-2 would reduce project-related VMT but not to a level below significance. As such, the proposed project would also have a cumulatively considerable contribution on VMT.

5.2 - Growth-inducing Impacts
There are two types of growth-inducing impacts that a project may have: direct and indirect. To assess the potential for growth-inducing impacts, the proposed project’s characteristics that may encourage and facilitate activities that individually or cumulatively may affect the environment must be evaluated (CEQA Guidelines § 15126.2(e)). CEQA Guidelines, as interpreted by the City, state that a significant growth-inducing impact may result if the project would:
• Induce substantial population growth in an area (for example, by proposing new homes and commercial or industrial businesses beyond the land use density/intensity envisioned in the general plan);
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• Include extensions of roads or other infrastructure not assumed in the general plan or adopted capital improvements project list, when such infrastructure exceeds the needs of the project and could accommodate future developments.

Direct growth-inducing impacts occur when the development of a project imposes new burdens on a community by directly inducing unplanned population growth or by leading to the construction of additional developments in the same area. Also included in this category are projects that remove physical obstacles to population growth (such as a new road into an undeveloped area or a wastewater treatment plant with excess capacity that could allow additional development in the service area). Construction of these types of infrastructure projects cannot be considered isolated from the development they facilitate and serve. Projects that physically remove obstacles to growth, or projects that indirectly induce growth, may provide a catalyst for future unrelated development in an area, such as a new residential community that requires additional commercial uses to support residents.

The proposed project does not include residential uses and therefore would not directly induce population growth. As discussed in Chapter 2, Project Description, the proposed project would develop a 219,834-square-foot wine storage and distribution center on a 443,005-square-foot undeveloped project site. The proposed project would employ an estimated 35 full-time employees and 20 part-time employees when fully operational at buildout.

The California Employment Development Department estimated Napa and Solano County’s combined labor force at 267,800 in November 2022. As such, the local labor force is sufficiently large enough to allow the project’s employment opportunities to be filled locally such that unplanned growth would not occur.

At the time of this writing, no prospective employees have been identified and, thus, it would be speculative to make any statements about where they would reside. Nonetheless, the City of American Canyon has more than 2,400 dwelling units in the pipeline (refer to Table 3-1 in Chapter 3, Environmental Impact Analysis). For comparison purposes, American Canyon’s population was estimated to be 20,837. Thus, the addition of more than 2,400 dwelling units to the City’s housing inventory would more than offset the employment growth attributable to the proposed project.

The proposed project would be served by connections to existing water, wastewater, storm drainage, and electricity lines that exist in Commerce Court. No extension of infrastructure into unserved areas would be required, and, therefore, no removal of physical barriers to growth would occur.

As such, the proposed project would not indirectly induce substantial population growth. No impacts would occur.
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5.3 - Mandatory Findings of Significance
Public Resources Code Section 21083 requires lead agencies to make a finding that a project may have a “significant effect on the environment” if one or more of the following conditions exist:
1) A proposed project has the potential to degrade the quality of environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife species to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare, or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory. 2) The possible effects of a project are individually limited but cumulatively considerable. 3) The environmental effects of a project will cause substantial adverse effects on human beings, either directly or indirectly.

Finding No. 1: Less than significant impact with mitigation incorporated.

The proposed project would develop a 219,834-square-foot wine storage and distribution center on the 443,005-square-foot project site. As described previously in Section 3.3, Biological Resources, the proposed project would not result in significant impacts to wildlife or plant species with mitigation incorporated. The analysis provides mitigation of pre-construction surveys, construction monitoring, and avoidance measures in order to protect Swainson’s hawk, burrowing owl, nesting birds, roosting bats, western pond turtle, and monarch butterfly.

Additionally, the proposed project includes mitigation and avoidance measures to reduce construction-related impacts to historical and archaeological resources as well as the accidental discovery of human remains. These include required Worker Environmental Awareness Program (WEAP) training, archaeological monitoring, and procedures in the event of accidental discovery of cultural resources and human remains.

Based on the discussion provided above, with implementation of the listed mitigation measures, the proposed project would not substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below selfsustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare of endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory.

Therefore, impacts would be less than significant with implementation of Mitigation Measure (MM) BIO-1a through MM BIO-1g, MM CUL-1a through MM CUL-1c, and MM CUL-3.

Finding No. 2: Significant and unavoidable impact.

The analysis presented in this Draft EIR includes a review of proposed project’s potential impacts related to air quality, biological resources, cultural resources, noise, and transportation, among other environmental issue areas. As presented throughout this Draft EIR, the proposed project’s 1033
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The proposed project would develop a 219,834-square-foot wine storage and distribution center on the 443,005-square-foot project site. There would be a less than significant cumulative impact with regard to aesthetics, light, and glare; air quality; energy; hazards and hazardous materials; public services; noise; and utilities and service systems.

Potentially significant impacts related to biological resources, cultural and tribal cultural resources, geology and soils, and hydrology and water quality would be mitigated to less than significant levels with the implementation of MM BIO-1a through MM BIO-1g, MM CUL-1a through MM CUL-1c, MM CUL-3, MM GEO-1, MM GEO-5, and MM HYD-1.

Significant and unavoidable impacts would occur related to transportation. While implementation of MM TRANS-2 would reduce impacts to this topical section, there is no feasible mitigation available that would fully bring these impacts to less than significant levels. Potential cumulative impacts are discussed in detail in each topical section of this Draft EIR.

Finding No. 3: Significant and unavoidable impact.

Potential human-related impacts are discussed and evaluated throughout this Draft EIR. Compliance with and implementation of project-specific mitigation measures and existing regulations would ensure that the proposed project would not result in substantial adverse effects on human beings for direct, indirect, or cumulative impacts related to air quality, seismic and geologic hazards, hazards and hazardous materials, flooding and natural disasters, and noise and vibration. Impacts with respect to these topical areas would be less than significant with mitigation incorporated and application of all relevant regulations.
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6.1 - Introduction
In accordance with California Environmental Quality Act (CEQA) Guidelines Section 15126.6, this Draft Environmental Impact Report (Draft EIR) contains a comparative impact assessment of alternatives to the proposed project. The primary purpose of this section is to provide decision makers and the general public with a reasonable number of feasible project alternatives that could attain most of the basic project objectives while avoiding or reducing any of the proposed project’s significant adverse environmental effects. Important considerations for these alternatives analyses are noted below (as stated in CEQA Guidelines § 15126.6). • An EIR need not consider every conceivable alternative to a project. • An EIR should identify alternatives that were considered by the lead agency but rejected as infeasible during the scoping process.
• Reasons for rejecting an alternative include:
- Failure to meet most of the basic project objectives; - Infeasibility; or
- Inability to avoid significant environmental effects.

6.1.1 - Significant Unavoidable Impacts
The proposed project would result in the following significant unavoidable impacts:
• Inconsistency with CEQA Guidelines Section 15064.3, subdivision (b): The proposed project’s VMT was evaluated in accordance with the City’s adopted VMT policy. For the project’s VMT impact to be less than significant, the VMT per employee would need to be reduced by at least 19 percent below current levels. However, according to the 2021 California Air Pollution Control Officers Association (CAPCOA) Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (CAPCOA Handbook), a reduction in the VMT of 15 percent is generally considered the maximum feasible mitigation for suburban environments such as that of the proposed project. If this level of trip reduction could be achieved, that would mitigate most of the project’s VMT impact, although not to a level that would be less than significant (19 percent); however, given the lack of transit services within an acceptable walking distance of the proposed project, achieving this level of mitigation is considered infeasible. Even with implementation of a TDM Plan as required by MM TRANS-2, the significance after mitigation is still significant and unavoidable.
• Cumulative Transportation: Impact TRANS-2 concluded that the proposed project would have a significant and unavoidable impact on VMT because the proposed project would be required to reduce VMT by a minimum of 19 percent below the citywide average, which would be challenging given the project’s location and lack of access to high-quality transit. MM TRANS-2 1035
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6.1.2 - Alternatives to the Proposed Project
The two alternatives to the proposed project analyzed in this section are as follows:
• No Project Alternative: The project site would remain undeveloped for the foreseeable future and no development would occur.
• Reduced Density Alternative: A 164,875-square-foot wine warehouse would be developed on the project site, which represents a 25 percent reduction in square footage.

Two alternatives to the proposed project are analyzed in the following section. These analyses compare the proposed project and each individual project alternative. In several cases, the description of the impact may be the same under each alternative when compared with the CEQA Thresholds of Significance (i.e., both the proposed project and the alternative would result in a less than significant impact). The actual degree of impact may be slightly different between the proposed project and each alternative, and this relative difference is the basis for a conclusion of greater or lesser impacts.

6.2 - Project Objectives
As stated in Chapter 2, Project Description, the objectives of the proposed project are to:

1. Positively contribute to the local economy through new capital investment, the creation of new jobs, and the expansion of the tax base.

2. Develop land to its highest and best use.

3. Continue the buildout of the City of American Canyon in accordance with the General Plan.

4. Meet regional demand for wine warehouse uses by adding to the inventory of this space.

5. Develop nonresidential uses on the project site that are compatible with the City of American Canyon’s Water Reclamation Facility and the Napa County Airport.

6. Maximize the efficient use of land by developing an industrial project at the upper end of the allowable Floor Area Ratio range.

7. Complete the buildout of the SDG Commerce development.

8. Protect North Slough by employing stormwater pollution prevention measures during construction and operation.

9. Provide development fees to the American Canyon Fire Protection District to fund the development of a new fire station.
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6.3 - Alternative 1—No Project Alternative
CEQA Guidelines Section 15126.6(e) requires that an EIR evaluate a “No Project Alternative,” which is intended to allow decision-makers to compare the impacts of approving the proposed project with the impacts of not approving the proposed project. In cases where the proposed project constitutes a land development project, the No Project Alternative is the “circumstance under which the project does not proceed.” For many projects, the No Project Alternative represents a “No Development” scenario, in which the project site remains in its existing condition and no development occurs for the foreseeable future. However, CEQA Guidelines Section 15126.6(e)(3)(B) establishes that “If disapproval of the project under consideration would result in predictable actions by others such as the proposal of some other project, this ‘no project’ consequence should be discussed.” Because the project site has not been previously entitled for development, the No Project Alternative consists of the project site remaining undeveloped for the foreseeable future.

6.3.1 - Impact Analysis
The project site would remain undeveloped for the foreseeable future. Accordingly, this alternative would avoid all of the proposed project’s significant impacts (including significant and unavoidable impacts), as well as the need to implement any mitigation measures.

6.3.2 - Conclusion
The No Project Alternative would avoid the proposed project’s significant and unavoidable impacts and would avoid any potential impacts related to all environmental topical areas. However, this alternative would not advance any of the project objectives, including those related to facilitating the development of land to its highest and best use; positively contributing to the local economy; and meeting regional demand for wine warehouse uses. Finally, it should be noted that the project site is zoned for wine storage and distribution warehouse use, borders two neighboring wine storage and distribution warehouses, and is currently served with infrastructure suitable for this type of development. Thus, should the proposed project not advance, it would be expected that another industrial development proposal would be submitted, resulting in development similar to what is already being proposed by the proposed project.

6.4 - Alternative 2—Reduced Density Alternative
Under the Reduced Density Alternative, a 164,875 square-foot wine warehouse would be developed on the project site, which represents a 54,958-square-foot reduction (25 percent reduction) in the proposed project’s square footage and buildout potential. The reduction in building square footage would allow for approximately 1.26 additional acres of the site to be assigned to another use, such as a larger wetland buffer. Connectivity to the adjacent warehouses to the north and south would still be constructed.

Aside from the square footage, all other aspects of this alternative would be identical to the proposed project. This includes project boundaries, layout, design, and vehicular access points. 1037
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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/EIR/2 - Screencheck EIR/edit/56390001 Sec06-00 Alternatives.docx Table 6-1 summarizes the Reduced Density Alternative. The purpose of this alternative is to evaluate a smaller project with end uses identical to the proposed project that may avoid or substantially lessen the severity of significant project impacts.

Table 6-1: Reduced Density Alternative Summary
Scenario Total Acres End Use Square Feet
Proposed Project 10.45 Wine Warehouse 219,834
Reduced Density Alternative 10.45 Wine Warehouse 164,875 Difference — — -54,959

6.4.1 - Impact Analysis
Aesthetics, Light, and Glare
The Reduced Density Alternative consists of a 164,875-square-foot wine warehouse and associated infrastructure on the project site. The building developed under this alternative would retain a similar appearance to the proposed project’s structure and similar exterior light fixtures would be installed, although the 54,958-square-foot reduction in warehouse building space would result in a corresponding reduction in the visual appearance of the project site. Therefore, the Reduced Density Alternative would have slightly less impact on aesthetics, light, and glare than the proposed project.

Air Quality
The Reduced Density Alternative would result in less construction activity and 93 fewer daily vehicle trips, which would correspond to an approximately 25 percent reduction in construction and operational criteria pollutant and toxic air contaminant (TAC) emissions. Implementation of MM AIR1 would still be required to reduce construction impacts related to fugitive dust. Therefore, this alternative would have slightly reduced potential for impacts to air quality compared to the proposed project.

Biological Resources
The reduction in square footage would allow for up to 1.26 acres to be available for other uses, such as a greater wetland buffer. However, MM BIO-1a through MM BIO-1g would still be required to protect species that have potential to occur on-site. Based on the reduced project footprint, the Reduced Density Alternative would have slightly reduced potential for impacts to biological resources compared to the proposed project.

Cultural Resources
Under the Reduced Density Alternative, there would be a slightly reduced area of ground disturbance due to the increased wetland buffer. However, MM CUL-1a through MM CUL 1c and MM CUL-3 would be still required. Therefore, the Reduced Density Alternative would have slightly reduced potential for impacts to cultural resources relative to the proposed project. 1038
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The Reduced Density Alternative would result in a smaller facility and, as such, would use less electricity and fuel during construction and operation. This alternative would result in 93 fewer daily vehicle trips, which would have a corresponding reduction in energy usage. Therefore, this alternative would have a reduced potential for impacts related to energy compared to the proposed project.

Geology, Soils, and Seismicity
The Reduced Density Alternative would result in a smaller facility, although MM GEO-1a, MM GEO1b, MM HYD-1a, and MM GEO-5 would still be required to be implemented. Therefore, the Reduced Density Alternative would have similar geology, soils, and seismicity resources impacts as the proposed project.

Greenhouse Gas Emissions
The Reduced Density Alternative would result in less construction activity and 93 fewer daily vehicle trips, which would have a corresponding reduction construction and operational GHG emissions.

Therefore, this alternative would have less GHG impacts than the proposed project.

Hazards and Hazardous Material
As with the proposed project, no hazardous conditions exist on-site; therefore, impacts would also be less than significant under this alternative. This alternative would result in a 54,958-square-foot reduction in warehouse development, which would reduce the potential for hazardous material releases during construction and operations. Therefore, this alternative would have less potential for impacts related to hazards and hazardous materials than the proposed project.

Hydrology and Water Quality
The Reduced Density Alternative would result in a smaller facility, although MM HYD-1 would still be required to be implemented. This alternative would create a smaller extent of impervious surfaces, which would result in a slightly reduced potential for impacts related to hydrology and water quality relative to the proposed project.

Land Use
This alternative would develop a similar use as the proposed project; therefore, it would yield similar conclusions related to consistency with the City of American Canyon General Plan, American Canyon Zoning Ordinance, and the Napa County Airport Land Use Compatibility Plan. Therefore, the Reduced Density Alternative would have land use impacts similar to the proposed project.

Noise
The Reduced Density Alternative would result in less construction activity and 93 fewer daily vehicle trips, which would have a corresponding reduction in the severity of construction and operational noise impacts. The reduction in development potential and vehicle trips would slightly reduce the 1039
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Public Services
End uses would be similar to the proposed project. Although the proposed project’s public services impacts were found to be less than significant and did not require mitigation, this alternative would result in less demand for fire protection and police protection through the 54,958-square-foot reduction in development potential. Therefore, the Reduced Density Alternative would have less impact on public services than the proposed project.

Transportation
Table 6-2 summarizes the daily and peak-hour trip generation associated with the Reduced Density Alternative. As shown in the table, this alternative would yield a reduction of 93 daily vehicle trips, 9 AM peak-hour vehicle trips, and 7 PM peak-hour vehicle trips.

Table 6-2: Reduced Density Alternative Trip Generation Comparison Scenario Daily AM Peak-hour PM Peak-hour
Proposed Project 372 35 27
Reduced Density Alternative1 279 26 20
Difference -93 -9 -7
Source: W-Trans. 2023. 1 Reduced Density Alternative Trip Generation was calculated by FCS by taking 75 percent of Trip Generation numbers calculated by W-Trans.

Despite reducing the number of trips to the project site, this alternative would generate the same VMT per employee of 34.1 miles. While transportation demand management (TDM) measures (MM TRANS-2) could provide approximately a 4 percent reduction in VMT, a 19 percent reduction would be required to bring impacts to a less than significant level. As such, while impacts would be reduced under this alternative, they would remain significant and unavoidable.

Utilities and Service Systems
End uses would be similar to the proposed project. Although the proposed project’s utilities and service system impacts were found to be less than significant and did not require mitigation, this alternative would result in an approximately 25 percent reduction in demand for water and energy and an approximately 25 percent reduction in generation of wastewater and solid waste through the 54,958-square-foot reduction in development potential. Therefore, the Reduced Density Alternative would have less impact on utilities and service systems than the proposed project.

6.4.2 - Conclusion
The Reduced Density Alternative would lessen the severity of, but would not avoid, the significant and unavoidable transportation impacts associated with the proposed project. Additionally, the 1040
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The Reduced Density Alternative would advance several of the project objectives, although several of the objectives would be advanced to a lesser degree than the proposed project. This alternative would not meet the objective to develop the land to its highest and best use and would not maximize the efficient use of land. Furthermore, the reduction in square footage would result in fewer positive economic benefits and, thus, would advance economic benefits to a lesser degree than the proposed project. This includes objectives related to facilitating the development of land planned for business park/industrial uses to its highest and best use; positively contributing to the local economy; providing the City of American Canyon with a high-quality, employment-generating industrial development; and serving local and regional demand for wine warehouse uses.

6.5 - Environmentally Superior Alternative
CEQA Guidelines Section 15126(e)(2) requires identification of an environmentally superior alternative. If the No Project Alternative is environmentally superior, CEQA requires selection of the “environmentally superior alternative other than the No Project Alternative” from among the project and the alternatives evaluated.

The qualitative environmental effects of each alternative in relation to the proposed project are summarized in Table 6-3.

Table 6-3: Summary of Alternatives
Environmental Topic Area Proposed Project No Project Alternative Reduced Density
Alternative
Aesthetics, Light, and Glare Less than significant
impact
Less impact Less impact
Air Quality Less than significant
impact with mitigation
incorporated
Less impact Less impact
Biological Resources Less than significant
impact with mitigation
incorporated
Less impact Less impact
Cultural Resources and Tribal
Cultural Resources
Less than significant
impact with mitigation
incorporated
Less impact Less impact
Energy Less than significant
impact
Less impact Less impact
Geology and Soils Less than significant
impact with mitigation
incorporated
Less impact Similar impact
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Alternative
Greenhouse Gas Emissions Less than significant
impact
Less impact Less impact
Hazards and Hazardous Materials Less than significant
impact
Less impact Less impact
Hydrology and Water Quality Less than significant
impact with mitigation
incorporated
Less impact Less impact
Land Use Less than significant
impact
Less impact Similar impact
Noise Less than significant
impact
Less impact Less impact
Public Services Less than significant
impact
Less impact Less impact
Transportation Significant and
unavoidable impact
Less impact Less impact
Utilities and Service Systems Less than significant
impact
Less impact Less impact
The No Project Alternative reduces impacts on all categories and, thus, would be the environmentally superior alternative. If the No Project Alternative is the environmentally superior alternative, the Draft EIR must also identify an environmentally superior alternative from among the other alternatives.

The Reduced Density Alternative was the only other alternative considered and it reduces impacts on all categories and, thus, would be the environmentally superior alternative. However, as previously noted, the Reduced Density Alternative would not advance the project objectives to the same degree of the proposed project and would not eliminate the significant and unavoidable impacts of the proposed project.

6.6 - Alternatives Rejected From Further Consideration
The following alternatives were initially considered but were rejected from further consideration for the reasons described below.

6.6.1 - Greater Reduced Density
The Greater Reduced Density Alternative would reduce the proposed project’s square footage by 50 percent, resulting in the development of a 109,917-square-foot warehouse. The reduction in square footage would allow for an additional 2.52 additional acres of the site to be assigned to another use, such as a larger wetland buffer.
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This alternative was considered but ultimately rejected because it would not meet project objectives to develop the land to its highest and best use and to maximize the efficient use of land.

Furthermore, it would meet all other objectives to a lesser extent than the Reduced Density Alternative and it would still would not avoid significant transportation impacts.

Therefore, this alternative was not considered feasible and, thus, it was rejected from further consideration.

6.6.2 - Alternative Location
CEQA Guidelines Section 15126.6(f)(2) sets forth considerations to be used in evaluating an alternative location. The section states that the “key question” is whether any of the significant effects of the proposed project would be avoided or substantially lessened by relocating the proposed project. The CEQA Guidelines identify the following factors that may be taken into account when addressing the feasibility of an alternative location:

1. Site suitability

2. Economic viability

3. Availability of infrastructure

4. General Plan consistency

5. Other plans or regulatory limitations

6. Jurisdictional boundaries

7. Whether the project applicant can reasonably acquire, control, or otherwise have access to the alternative site
Here, “General Plan consistency” is an important factor. CEQA case law is clear that EIRs for proposed private projects consistent with governing General Plan designations generally need not address alternative sites, given that such existing General Plan designations embody policy decisions already made by governing city councils and boards of supervisors. “[T]he keystone of regional planning is consistency—between the general plan, its internal elements, subordinate ordinances, and all derivative land use decisions” (Citizens of Goleta Valley v. Board of Supervisors [1990] 52 Cal.3d 553, 572). “Case-by-case reconsideration of regional land use policies, in the context of a project-specific EIR, is the very antithesis of that goal.” (Id. at p. 573.) “[A]n EIR is not ordinarily an occasion for the reconsideration or overhaul of fundamental land use policy” (Ibid.).

Table 6-4 evaluates the feasibility of three alternative locations located within 1.5 miles of the project site in either the City of American Canyon or unincorporated Napa County (Exhibit 6-1). As indicated in Table 6-4, none of the sites would meet CEQA Guidelines criteria for a feasible alternative location. Furthermore, utilization of a different project site would not meet the project objective of building out the SDG Commerce complex. Therefore, this alternative was not considered feasible and, thus, it was rejected from further consideration. 1043

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56390001•03/2024| 6-1_altern ative_lo catio n s.m xd
Exhibit6-1
Altern ativeLo catio n s
So urce:Bin gAerialIm agery.

CITYOFAMERICANCANYON
SDGCOMMERCE220PROJECT

ENV IRONMENTALIMPACTREPORT
2,000 1,000 0 2,000
Feet
Legend
Project Site
Sentinels of Freedom Property
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Name Description Analysis
Sentinels of Freedom
Property
Approximately 25 acres located west of
Napa Logistics Park and south of Napa
County Airport in unincorporated Napa
County and within the City of American
Canyon Sphere of Influence. This site
contains undeveloped land, is bisected
by No Name Creek, and parts are within
a 100-year flood hazard area. This site
is designated “Industrial” by the Napa
County General Plan and zoned
“Business/Industrial” by the Napa
County Airport Industrial Area Specific
Plan.

Not Feasible: This site is controlled by
the Sentinels of Freedom and is not
owned, controlled, or otherwise
accessible to the project applicant. The
Sentinels of Freedom have conceptually
proposed developing two warehouses
on the property with vehicular access
coming from Napa County Airport.

Furthermore, this property site is not
located closer to any public transit. As
such, locating the proposed project at
this site would not reduce impacts to a
less than significant level.

Devlin Road Transfer
Station Property
Approximately 12 acres located east of
Napa Logistics Park and south of the
Devlin Road Transfer Station. This site
contains undeveloped land. This site is
designated “Industrial” by the Napa
County General Plan and zoned
“Business/Industrial” by the Napa
County Airport Industrial Area Specific
Plan.

Not Feasible: This site is not owned,
controlled, or otherwise accessible to
the project applicant. The Napa
Recycling and Transfer Facility has
conceptually proposed developing a
construction and demolition debris
sorting facility on the property.

Furthermore, this property is not
located closer to any public transit. As
such, locating the proposed project at
this site would not reduce impacts to a
less than significant level.

Northeast of State Route
29 and Watson Lane
The project site is located in
unincorporated Napa County and is
designated for agricultural uses in the
Napa County General Plan.

Not Feasible: This site is not owned,
controlled, or otherwise accessible to
the project applicant. It is designated
for agricultural uses and the proposed
project would not be permitted at the
site.

Source: FirstCarbon Solutions (FCS). 2024.
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City of American Canyon—SDG Commerce 220 Distribution Center Project Persons and Organizations Consulted/ Draft EIR List of Preparers
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PREPARERS

7.1 - Persons and Organizations Consulted

7.1.1 - Lead Agency - City of American Canyon
Community Development Department
Community Development Director ............................................................................Brent Cooper, AICP Senior Planner ............................................................................................................... William He, AICP Administrative Technician.......................................................................................................Nicolle Hall City Attorney................................................................................................................................ Bill Ross Public Works Department
Public Works Director.......................................................................................... Erica Ahmann Smithies Senior Civil Engineer..............................................................................................Edison C. Bisnar, Jr. PE Police Department
Police Chief ...................................................................................................................... Rick Greenberg Fire Protection District
Fire Chief...............................................................................................................................Geoff Belyea

7.1.2 - Public Agencies
State Agencies
California Department of Fish and Wildlife
Regional Manager................................................................................................................Erin Chappell California Department of Justice
Supervising Deputy Attorney General ............................................................................Christie Vosburg California Department of Transportation
Branch Chief, Local Development Review ..........................................................................Yunsheng Luo Native American Heritage Commission
Cultural Resources Analyst ................................................................................................. Cameron Vela

7.1.3 - Private Parties and Organizations
Public Comment Letters
City of Napa Resident ..................................................................................................... Yvonne Baginski City of American Canyon Resident ...........................................................................Jeannette Goyetche 1049
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7.2 - List of Preparers

7.2.1 - City of American Canyon
Community Development Department
Community Development Director............................................................................ Brent Cooper, AICP Senior Planner ................................................................................................................William He, AICP

7.2.2 - Lead Consultant
FirstCarbon Solutions
Project Director....................................................................................................................... Mary Bean Project Manager.............................................................................................................Janna Waligorski Assistant Project Manager ............................................................................................... Madelyn Dolan Legal Counsel .................................................................................................................. Megan Starr, JD Biological Resources Manager ........................................................................................... Robert Carroll Biologist ................................................................................................................................... Kelly Evans Biological Resource Analyst .............................................................................................Hannah Carney Director of Cultural Resources..........................................................................Dana DePietro, PhD, RPA Cultural Resources Analyst............................................................................................................. Ti Ngo Director of Noise and Air Quality ...............................................................................Phil Ault, LEED® AP Air Quality Analyst............................................................................................................ Marianne Aydil Air Quality Analyst........................................................................................................................ Tsui Lee Senior Managing Editor..........................................................................................................Susie Harris Publications Coordinator ........................................................................................................ Alec Harris Document Specialist....................................................................................................... Melissa Ramirez GIS/Graphics ................................................................................................................Karlee McCracken

7.2.3 - Technical Subconsultants
Cameron Cole
Principal Scientist.....................................................................................................Michael Stephenson Geologist II ............................................................................................................................Amy Robson Environmental Scientist II............................................................................................ Angela Mattmiller W-Trans
President ............................................................................................................................ Mark Spencer Principal ................................................................................................................................ Zack Matley Senior Planner...................................................................................................................Barry Bergman Pinecrest Research Corporation
Director ............................................................................................................................ Chris DiVittorio 1050
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Managing Engineer....................................................................................................... David R. Jarosz, II RSA+
Director........................................................................................................................... Paul S. Warnock 1051

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Appendix A:

Notice of Preparation/Comments
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City of American Canyon
Notice of Preparation and Notice of Public Scoping Meeting SDG Commerce 220 Distribution Center Project
Date: October 27, 2023
To: Public Agencies and Private Parties
From: William He, AICP, Senior Planner, City of American Canyon Subject: Notice of Preparation of an Environmental Impact Report and Public Scoping Meeting The City of American Canyon will be the Lead Agency and will prepare an Environmental Impact Report (EIR) for the project identified herein. The project description, location, and probable environmental effects of the SDG Commerce 220 Distribution Center Project are described in the attached materials. The project applicant is SDG Commerce 220, LLC.

The City of American Canyon is soliciting comments from public agencies, organizations, and members of the public regarding the scope and content of the EIR, and the environmental issues and alternatives to be addressed in the document. Public agencies may need to use the EIR when considering permitting or other approvals that are germane to the agencies’ responsibilities in connection with the projects.

Because of time limits mandated by state law, public agencies must submit any comments in response to this notice at the earliest possible date but not later than 30 days after receipt of this notice. The City of American Canyon also will accept comments from other interested parties regarding this notice during this time period. Accordingly, please provide your written response to the address shown below by 5 p.m. November, 27, 2023. If you wish to be placed on the notification list for this project, or if you have any questions or need additional information, please contact the person below.

William He, AICP, Senior Planner
City of American Canyon
4381 Broadway Street, Suite 201
American Canyon, CA 94503
Phone: (707) 647-4337
Email: [email protected]
Public Scoping Meeting
A virtual public scoping meeting will be held at Friday, November 17 at 2:00 PM. Refer to the ‘Scoping Meeting’ portion of this NOP for details. At this meeting, public agencies, organizations, and members of the public will be able to review the proposed project and provide comments on the scope of the environmental review process.
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SDG Commerce 220 Distribution Center Project
City of American Canyon Notice of Preparation
FirstCarbon Solutions 2 U:\Planning & Building\PLANNING\PROJECTS\2023 PROJECTS\PL23-0017 SDG 220 Warehouse CUP\CEQA\NOP\NOP 2nd Submittal 10.20.2023\SDG Commerce 220 NOP rev2.docx SDG COMMERCE 224 PROJECT
Project Location
The 10.45-acre project site is located at 1055 Commerce Court in the City of American Canyon, Napa County, California; refer to Exhibit 1. The rectangular project site is bounded by a Eucalyptus grove and North Slough (west), a parcel entitled for a wine distribution warehouse known as SDG Commerce 217 (north), Commerce Court (east), beyond which is a paintball recreation area, and a wine distribution warehouse known as SDG Commerce 330 (south); refer to Exhibit 2. The project site is located on the Cuttings Wharf, California, United States Geological Survey 7.5-minute topographic quadrangle, Township 4 North, Range 4 West, Section 14 (Latitude 38° 11’ 22” North; Longitude 122° 16’ 19” West).

Existing Conditions

1.1.1 - Land Use Activities
The project site contains undeveloped land, which slopes downward from east to west and is approximately 13 to 25 feet above mean sea level. The project frontage with Commerce Court is improved with curb, gutter, and sidewalk.

The southern portion of the project site contains several soil stockpiles that are intended for use at the SDG Commerce 217 property. A young Euctalyptus tree is located near Commerce Court, and a linear wetland and an isolated wetland are located within the northern portion of the property.

1.1.2 - Land Use Designations
The project site is designated “Commercial Recreation (CR)” by the City of American Canyon General Plan and is zoned Recreation (REC).

A Recreation Zoning District Code Amendment (Ordinance No. 2018-01) was adopted by the City Council on January 16, 2018. The Ordinance allows wine-related warehousing and distribution facilities as a conditionally permitted use within the REC zone district.

The project site is within Compatibility Zone D (Common Traffic Pattern) of the Napa County Airport’s Land Use Compatibility Plan.

Project Description

1.1.3 - Project Summary
The applicant, SDG Commerce, is proposing to develop a 219,834 square-foot wine storage and distribution center on the 10.45-acre (443,005-square-foot) project site. The warehouse would provide 23 truck doors and up to 4,400 square feet of office space. It would have perimeter concrete tilt wall panels with varying parapet heights and accent spandrel glass/metal canopy features around offices and corners of the building. The average roof height would be approximately 35 feet, and 1056
SDG Commerce 220 Distribution Center Project
City of American Canyon Notice of Preparation
FirstCarbon Solutions 3 U:\Planning & Building\PLANNING\PROJECTS\2023 PROJECTS\PL23-0017 SDG 220 Warehouse CUP\CEQA\NOP\NOP 2nd Submittal 10.20.2023\SDG Commerce 220 NOP rev2.docx portions of the building exterior walls would have varied heights to provide architectural relief. The building would be insulated and refrigerated at approximately 58°F (degrees Fahrenheit), making it suitable for storage of wine and related products. The amount of refrigeration necessary would be reduced through the use of intake louvers and fans, which would allow cool night air to be utilized.

Table 1 summarizes the project characteristics. Exhibit 3 depicts the site plan.

Table 1: SDG Commerce 220 Project Summary
Acres Building Square Feet
Floor Area
Ratio Building Height End Use/Characteristics

10.451 219,834 0.5 35 feet Wine Distribution Warehouse/23 truck doors 1Project site consists of assessor’s parcel number 058-030-069 (10.17 acres) plus small additional improvement areas for a total of 10.45 acres.

Source: SDG Commerce 220, LLC. 2023.

Operation and Employment
The building would be designed to accommodate approximately three tenants. Typical hours of operation for wine distribution and storage are generally 6:00 a.m. to 6:00 p.m., Monday through Friday; during the peak seasonal months, typically June through November, hours are extended from 6:00 a.m. to 12:00 a.m., Monday through Friday. It is anticipated that the project would employ approximately 35 full-time employees and 20 part-time employees, working in up to three overlapping shifts.

Warehousing and storage of wine and other wine-related industries are not labor intensive, and the proposed uses for the building do not demand frequent client or user trips to the site. It is estimated that the proposed project would generate approximately 2 to 4 client or visitor trips per day, likely during off-peak season and during normal working hours. Forklifts used within the building would be electrically powered.

Site Access, Circulation, and Parking
Vehicular and truck access would be taken from one driveway on Commerce Court that would be shared with the SDG Commerce 330 project. Drive aisles would be provided around the full perimeter of the building to support emergency ingress and egress.

A total of 134 car spaces and 23 truck parking stalls would be provided. Of the parking spaces, five would be designated for handicap access and one would be a compact space. There would be five electric vehicle supply equipment (EVSE) stalls, one van accessible EVSE stall, and 19 electric vehicle (EV) capable stalls. Per the 2022 California Green Building Standards Code (CALGreen), nonresidential developments with 101–150 parking spaces must provide at least 17 EV capable spaces and at least four EV capable spaces provided with EVSE (Title 24, Part 11, Chapter 5, Table

5.106.5.3.1). The proposed project would meet these requirements.

Pedestrian circulation throughout the project site would be provided in accordance with CalDAG and ADA recommendations and standards. The proposed project would also provide three bicycle 1057
SDG Commerce 220 Distribution Center Project
City of American Canyon Notice of Preparation
FirstCarbon Solutions 4 U:\Planning & Building\PLANNING\PROJECTS\2023 PROJECTS\PL23-0017 SDG 220 Warehouse CUP\CEQA\NOP\NOP 2nd Submittal 10.20.2023\SDG Commerce 220 NOP rev2.docx lockers, each of which would accommodate up to four bicycles, for a total of 12 bicycle parking spaces. The proposed 12 bicycle parking spaces would be five more than required per the City’s Zoning Ordinance Chapter 19.14.090 (A), Bicycle Parking Requirements.

Lighting
Exterior lighting for the proposed project would include lighting on the building and on parking lot poles on the north side of the property. Parking lot lighting would be consistent with City of American Canyon municipal code requirements Section 19.21.030(M). The 30-foot-tall lights would be “shoebox” dimmable light-emitting diode (LED) fixtures designed to be dark-sky friendly by directing the light toward the ground and reducing glare to surrounding properties.

Signage
One monument sign is proposed, (approximately 8 feet wide by 5 feet tall) located at the entry to the site from Commerce Court.

Landscaping
Landscaping would be provided around the site perimeter on the east, north and partial west sides and within parking islands throughout. Mechanical equipment would be placed on the north side of the building behind a 6-foot-high color slatted chain link fence. The irrigation system would be connected to the City’s reclaimed water system, thus eliminating the use of the City’s potable water for landscape purposes.

Storm Drainage
Stormwater runoff would be directed via an onsite storm drain system into a detention/bioretention pond located on the western side of the site. Roof drainage would be connected to the proposed detention/bioretention pond via the onsite storm drain system surrounding the building by way of down spouts on the exterior of the building, which would be painted to blend-in with the building façade.

Wetland Areas
The two existing, on-site wetland areas would be preserved in place.

Utilities
Water
The City of American Canyon would provide potable and recycled water service to the proposed project. Potable and recycled water infrastructure currently exists within Commerce Court, and service laterals would be extended to the project building. The warehouse would be dual plumbed to allow use of recycled water for non potable water use within the building.

Wastewater
The City of American Canyon would provide wastewater collection and treatment service to the proposed project. Sewer infrastructure currently exists within Commerce Court. Connection back to 1058
SDG Commerce 220 Distribution Center Project
City of American Canyon Notice of Preparation
FirstCarbon Solutions 5 U:\Planning & Building\PLANNING\PROJECTS\2023 PROJECTS\PL23-0017 SDG 220 Warehouse CUP\CEQA\NOP\NOP 2nd Submittal 10.20.2023\SDG Commerce 220 NOP rev2.docx the existing City sewer infrastructure in Commerce Court will be made through the existing sanitary sewer system and lift station that was previously designed and constructed on the Commerce 330 site for future shared use with the SDG Commerce 220 project.

Electricity
Pacific Gas and Electric Company (PG&E) would deliver electricity to the proposed project. Electric infrastructure currently exists within Commerce Court. Service laterals would extend from the Commerce Court facilities to project buildings. No natural gas would be used. Solar would be installed on the building roof top and would produce an estimated 235,204 kilowatt-hour (kWh) per year.

Telecommunications Services
Telephone service provided by AT&T would be extended from the existing underground infrastructure in the Commerce Court right-of-way (ROW) to the electrical room located in the northeast corner of the building.

Off-site Improvements
A small portion of the development extends beyond the parcel boundaries to the north and south of the project site to provide connection to the adjacent parking lots and to enhance internal circulation between the sites. The properties to the north and south of the project site are under related ownership as the proposed project and the potential impacts associated with development and site disturbance on those parcels was analyzed in previous California Environmental Quality Act (CEQA) documentation.1,2 Long-term reciprocal access would be ensured through recorded easements between the two properties.

Construction
Construction would occur in a single phase, lasting approximately 9.5 months. For this analysis, construction is assumed to start in September 2024. During the construction phase, an average of 12 to 24 workers would be at the site, with a maximum of up to 80 workers and a minimum of one.

Construction hours would be from 7:00 a.m. to 6:00 p.m. Monday through Friday.

Construction of the concrete building slab, wall panels and large concrete paving pours would be required to be performed during nighttime hours starting no earlier than 12:00 a.m. Pre-notification of these night pour dates and times would be provided to the City and property owners in the vicinity. Typical construction equipment that would be used at the site would include self-loading dirt scraper, bulldozer, motor grader, compactor, roller, water truck, backhoe, excavator, trencher, drilling auger, front end loader, paving machine, laser screed, concrete finishing trowels, tractor, crane, forklift, generator, man lift, scissor lift, welding machine, and light tower. Imported soil would be required for grading but would be less than 1,000 cubic yards. 1 City of American Canyon. 2021. Commerce 217 Distribution Center Project Initial Study/Mitigated Negative Declaration. Website:
https://ceqanet.opr.ca.gov/2020120302/2. Accessed August 16, 2023. 2 City of American Canyon. 2018. SDG 330 Wine Warehouse Project Initial Study/Mitigated Negative Declaration. Website:
https://ceqanet.opr.ca.gov/2018112067. Accessed August 16, 2023. 1059
SDG Commerce 220 Distribution Center Project
City of American Canyon Notice of Preparation
FirstCarbon Solutions 6 U:\Planning & Building\PLANNING\PROJECTS\2023 PROJECTS\PL23-0017 SDG 220 Warehouse CUP\CEQA\NOP\NOP 2nd Submittal 10.20.2023\SDG Commerce 220 NOP rev2.docx Required Discretionary Approvals
The proposed project requires the following discretionary approvals from the City of American Canyon:
• Conditional Use Permit
Subsequent ministerial actions would be required for the implementation of the proposed project, including issuance of grading and building permits.

The following parties would act as responsible agencies for the proposed project:
• United States Army Corps of Engineers (USACE)
• California Department of Fish and Wildlife (CDFW)
• San Francisco Bay Regional Water Quality Board (RWQCB) • County of Napa
• Napa County Airport Land Use Commission (ALUC)
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SDG Commerce 220 Distribution Center Project
City of American Canyon Notice of Preparation
FirstCarbon Solutions 7 U:\Planning & Building\PLANNING\PROJECTS\2023 PROJECTS\PL23-0017 SDG 220 Warehouse CUP\CEQA\NOP\NOP 2nd Submittal 10.20.2023\SDG Commerce 220 NOP rev2.docx Environmental Review

1.1.4 - Potential Environmental Effects
The EIR will evaluate whether the proposed project may potentially result in one or more significant environmental effects, which will be evaluated in the relevant sections listed below. • Aesthetics, Light, and Glare • Hydrology and Water Quality • Air Quality • Land Use
• Biological Resources • Noise
• Cultural Resources • Public Services
• Geology, Soils, and Seismicity • Transportation
• Greenhouse Gas Emissions/Energy • Utilities and Service Systems • Hazards and Hazardous Materials

1.1.5 - Effects Found not to be Significant
Unless specific comments are received during the NOP public comment period that indicate a potential for the project to result in significant impacts, the following issues will be addressed in the Effects Found not to be Significant section of the EIR.

Agriculture and Forest Resources
The project site contains undeveloped land and is not used for agricultural land use activities. The California Department of Conservation maps the project site as ‘Other Land,’ which does not fall under the Important Farmland umbrella. The project site is not encumbered by an active Williamson Act contract. The project site is zoned for industrial use; thus, no conflicts with agricultural or forest zoning would occur. The project site does not contain any stands of commercially harvestable trees and, thus, would not convert forestland to non-forest use. No impact would occur.

Mineral Resources
The project site contains undeveloped land. No mineral extraction occurs onsite. This precludes the possibility of conflicts in this regard. No impact would occur.

Population and Housing
The proposed project would develop a 224,539 square-foot wine warehouse on an undeveloped site. No direct residential growth would occur, and no existing dwelling units would be removed. The proposed project would employ an estimated 225 workers when fully operational at buildout. The California Employment Development Department estimated Napa and Solano County’s combined labor force at 267,800 in November 2022. As such, the local labor force is sufficiently large enough to allow the project’s employment opportunities to be filled locally such that unplanned growth would not occur. Lastly, roadways and infrastructure exist adjacent to the project site and, therefore, no impacts would occur.
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SDG Commerce 220 Distribution Center Project
City of American Canyon Notice of Preparation
FirstCarbon Solutions 8 U:\Planning & Building\PLANNING\PROJECTS\2023 PROJECTS\PL23-0017 SDG 220 Warehouse CUP\CEQA\NOP\NOP 2nd Submittal 10.20.2023\SDG Commerce 220 NOP rev2.docx Recreation
The proposed project would not involve construction of dwelling units and, thus, would not result in direct population growth. As such, it would not increase use of existing recreational facilities. No impact would occur.

Wildfire
The project site contains undeveloped land. There are no wildlands or other areas susceptible to wildfire within or near the project site. No impact would occur.

Scoping Meeting
A public scoping meeting will be held Friday, November 17 at 2:00 p.m. at American Canyon City Hall, 4381 Broadway, Suite 201, American Canyon, CA 94503.

The meeting will also be streamed virtually:
https://zoom.us/join
Meeting ID: 847 0393 6328
Passcode: 418059
Phone: (408) 638-0968
At this meeting, agencies, organizations, and members of the public will be able to review the proposed project and provide comments on the scope of the environmental review process. 1062
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Contra Costa County
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Montezuma Slou gh
Carquinez Strait
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County
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24 Napa River
Jack London
State Park
Vacaville
Napa
Fairfield
Suisun City
Vallejo
Novato Benicia
Bay Point
Hercules Pinole Martinez
San Anselmo
San Rafael Concord
San Pablo
Pleasant Hill Richmond
Larkspur
El Cerrito
Mill Valley
Albany Walnut Creek
Lafayette
Orinda
Berkeley
Alamo
Sonoma
American
Canyon
Clayton
Exhibit1
Region al Location Map
5 2.5 0 5
Miles
Text
Project Site
Source:Cen sus2000Data,TheCalifo rn iaSpatial In fo rmation Library (CaSIL).

CITYOFAMERICANCANYON
SDGCOMMERCE220DISTRIBU TIONCENTERPROJECT

NOTICEOFPREPARATION
56390001•10/2023|1_reg ion al.mxd
Project Site
80 Legend
City of American Canyon
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56390001• 10/2023| 2_local_vicin ity.mxd
Exhibit2
LocalVicin ityMap
Source:Bin gAerialImagery.

CITY OFAMERICANCANY ON
SDGCOMMERCE220DISTRIBUTIONCENTERPROJECT

NOTICEOFPREPARATION
1,000 500 0 1,000
Feet
Legend
Project Site
City of A
mer ci an Canyon
City of A
merican Canyon
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56390001• 10/2023 | 3_Site_Plan.cdr
Exhibit 3
Site Plan

CITY OF AMERICAN CANYON
SDG COMMERCE 220 DISTRIBUTION CENTER PROJECT

NOTICE OF PREPARATION
Source: Ward Architects, Inc. 08/01/2023. I
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SDG 220 Distribution Center Conditional Use Permit
Date *
Name *
Company
Email*
Phone Number*
Please check all that
apply *
Address *
Comments *
11/21/2023
Yvonne Baginski
[email protected]
7076945486
I own a home in American Canyon
I rent a home in American Canyon
I own a business in American Canyon
I work in American Canyon
None of the above
City
Napa
State / Province / Region
CA
Postal / Zip Code
94558
Country
USA
Street Address
3205 Montclair Ave.

Address Line 2
If comments are being provided through the upload of a document, please indicate so.

While awaiting environmental review, this property has already been cleared and graded. It currently is being used as a parking lot for the labor constructing the two warehouses on either side. How is it possible to determine a biological review when the soil is cleared and vegetation removed? Is it even legal to move forward on an environmental review when the land has already been significantly altered? There is nothing but flattened dirt over most of the property. The only part of the property not already contaminated by bulldozers and other earth-moving machines is fenced off on the north side. It is very small, hardly large to notice or utilize by animals, It's about the size of a small backyard. We couldn't imagine that such a minuscule piece of land would be cordoned off as wetland preservation. This wetland will be surrounded by asphalt parking lots and driveways and driven on by hundreds of cars and enormous trucks. Any animal attempting to use this wetland would be in peril.

Please explain what animals will have access to, or be able to use, these tiny pieces of "conserved" wetland. There is no access corridor, nothing. How will the wetland be maintained, protected? Who will monitor the wetland? Is there any possibility of making it larger, and connecting it to the a larger wildlife area? Has a wildlife biologist studied this location and offered any suggestions? It seems as if the project has jumped ahead without following protocols. Asking for an environmental review after all the vegetation has been removed, doesn't make sense. Please advise. 1066
I am concerned that this property is so near the bay wetlands and walking trail. That small line of trees in the back does little to protect wildlife from the lighting and noise of these warehouses, which it seems, will be operational 24/7. There is no information on how many trucks will be lumbering up to those 23 ramps every day, and how often. This is going to be a very busy court. Three warehouses and all bringing in noise and traffic alongside the wetland trail.

Especially confusing are the estimates of the number of people who will be working on site. There are different numbers bandied about in the NOP. Specifically, that 250 employees will be employed (yet, only 132 parking places), then only 2-4 visitors a day, and finally that there will be 35 fulltime and 30 part-time employee working three different shifts...which, still adds up to only 195 employees. So, it seems that the numbers are inconsistent with one another. Plus, the three tenants are not identified, and I am supposing that this is all guesswork for now. A comment is also made about the employees being local, and not having to drive in from other localities, yet there is no substantive evidence to this statement. Is there going to be a mandate for the employer to hire a certain percentage of local people? (And, then require them to all ride their bikes to work?) How will you be able to regulate who employers hire based on location or miles driven into work? This statement is inaccurate unless it is backed up with substantive, enforceable regulations. There is no way to guess how many people hired will be living in American Canyon. Right now, 80 percent of American Canyon residents who work, commute to other cities/counties to work. Warehouse work is not professional work. It is low-paying labor, and the rate of pay is still under $20/hour. These are not the people who will be purchasing Watson Ranch homes. I wonder whether the City has ever surveyed the other warehouses in American Canyon and determined what percentage of people working in those warehouses are actually residents of American Canyon. (And, how many are riding their bikes to work?) From what I see on the streets and in the driveways of American Canyon homes, I am willing to surmise that the most favored car is an SUV, and it is driven to work, to pick up kids, and on errands, daily.

The lighting and noise of this area, so near the wetlands and the tree foliage across the street, will be disruptive to the birds and wildlife. It will change their mating and sleeping patterns. Already, it has destroyed their habitat and will force them to leave the area, or die. What, if any, safeguards are being put in place to protect and safeguard wildlife?
The NOP hearing was held on a Friday afternoon before Thanksgiving week. Even with notice, it was unattendable by many who were heading off on vacation travels.

Now, all of the comments are to be submitted and written over Thanksgiving Week, when many people are with family and not working. I believe the timing of this public hearing puts the public at a disadvantage in being able to respond to this project's environmental toll on this community. We cannot even view the meeting until after November 27, the dates all the comments are due. This doesn't give those of us missing the meeting a chance to review what was said before comments are submitted.

And, finally, the increase of greenhouse gas emissions will be considerable with this project. How many trips a day from the trucking traffic alone? And, the diesel fumes will further pollute the bayside air and the noise and traffic will disrupt the peace of 1067
File Upload
will further pollute the bayside air, and the noise and traffic will disrupt the peace of recreational walkers along the trail just feet away from the furthest edge of the property. Using electric forklifts inside the facility may keep the air cleaner inside, but there's no doubt that the diesel truck engines will be emitting harmful carbon and destructive gases outdoors, contributing significantly the GHG emissions.

Now, in 2023, it's time to start looking at all these proposed projects through the lens of the climate crisis. Each project needs to be re-scrutinized and upgraded to the new reality. This property is zoned open space/recreational, but the city council voted to allow this warehouse build back in 2018. Now, five years later, we are facing a different world. We need to keep certain lands free from development, especially lands near the bay. There will be rising seas affecting this area in the very near future. Pay attention.
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“Provide a safe and reliable transportation network that serves all people and respects the environment” DISTRICT 4

OFFICE OF REGIONAL AND COMMUNITY PLANNING
P.O. BOX 23660, MS–10D | OAKLAND, CA 94623-0660
www.dot.ca.gov
November 27, 2023 SCH #: 2023100842
GTS #: 04-NAP-2023-00338
GTS ID: 31389
Co/Rt/Pm: Napa/29/2.907
William He, Senior Planner
City of American Canyon
4381 Broadway Street, Suite 201
American Canyon, CA 94503
Re: SDG Commerce 220 Distribution Center Project ─ Notice of Preparation (NOP) of a Draft Environmental Impact Report (DEIR)
Dear William He:

Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the SDG Commerce 220 Distribution Center Project.

We are committed to ensuring that impacts to the State’s multimodal transportation system and to our natural environment are identified and mitigated to support a safe, sustainable, integrated and efficient transportation system.

The Local Development Review (LDR) Program reviews land use projects and plans to ensure consistency with our mission and state planning priorities. The following comments are based on our review of the October 2023 NOP.

Project Understanding
The proposed project is to develop a 219,834 square-foot wine storage and distribution center that would provide 23 truck doors and 4,400 square-foot of office space.

Travel Demand Analysis
With the enactment of Senate Bill (SB) 743, Caltrans is focused on maximizing efficient development patterns, innovative travel demand reduction strategies, and multimodal improvements. For more information on how Caltrans assesses Transportation Impact Studies, please review Caltrans’ Transportation Impact Study Guide (link).
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William He, Senior Planner
November 27, 2023

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American Canyon City CouncilNovember 19, 2024

American Canyon City Council
November 19, 2024